The 5th Annual Worldwide Tax Update

May 15, 2012 (Boston) and May 16, 2012 (New York)

Sullivan & Worcester held its 5th Annual Worldwide Tax Update, an annual symposium on international tax developments and tax planning in the United States and throughout the world, on May 15 and May 16, 2012, in Boston and New York, respectively. This year the focus was on Europe.

In addition to tax advisors from the United States, tax advisors from the United Kingdom, Ireland, Switzerland, Netherlands and Luxembourg provided updates on current tax law developments. This free one-day event — held first in Boston and then repeated in New York the next day — served as a source of new tax ideas and techniques, as well as a forum to learn about rapidly developing and changing tax rules.

Certificates of attendance were provided at the event for Continuing Professional Education ("CPE") purposes.


Douglas S. Stransky, Sullivan & Worcester LLP

8:30 a.m.

Registration & Continental Breakfast

9:00 a.m.

Welcome & Introductions
Douglas S. Stransky, Sullivan & Worcester LLP, Boston, MA

9:15 a.m.

United States International Tax Law Developments
Douglas S. Stransky, Sullivan & Worcester LLP, Boston, MA
David H. Kaplan, Sullivan & Worcester LLP, Boston, MA
Amy E. Sheridan, Sullivan & Worcester LLP, Boston, MA

  • Foreign Tax Credit Splitters
  • Notice 2012-15—Section 304 transactions and GRAs
  • New cash "D"/basis regulations
  • Proposed FATCA regulations
  • Tax Treaty update
  • New Foreign Entity Identification numbers
  • U.S. tax treatment of deferred compensation
  • Tax risks facing both foreign executives working in the U.S. and U.S. persons employed abroad

10:15 a.m.

United Kingdom Tax Law Developments
Michael L'Estrange, Watson, Farley & Williams LLP, London, United Kingdom

  • The UK as a holding company jurisdiction
  • New Controlled Foreign Companies (CFC) legislation
  • Patent Box
  • The introduction of a General Anti-Avoidance Rule (GAAR)
  • The UK as place to live and do business
  • Tax rates
  • Statutory Residence test
  • Non-UK domiciled individuals

11:15 a.m.

Refreshment Break

11:30 a.m.

Ireland Tax Law Developments
Philip McQueston, A&L Goodbody, Dublin, Ireland

  • The Irish 12.5% corporation tax rate - very much alive and well
  • Corporate migrations to Ireland - the trend continues
  • The Irish IP tax regime - current developments

12:30 p.m.


1:30 p.m.

Switzerland Tax Law Developments
Rolf Wüthrich, burckhardt Ltd., Basel, Switzerland

  • Leading decision on interpretation of beneficial ownership for tax treaty purposes
  • Running count down to register “old” reserves from contributed capital
  • Swiss International Group Coordination Centres
  • Swiss Franc exchange rate uncertainty

2:30 p.m.

Netherlands Tax Law Developments
Lodewijk Berger, Loyens & Loeff, New York, NY

  • Why do life sciences and alternative energy companies prefer the Netherlands? - The Innovation Box, Infocap Rulings and the CV/BV Structure
  • Dutch Coops - As International Holding and Finance Company
  • The Dutch Position on EU developments - Financial Transactions Tax, Bank Levy, Common Tax Base

3:30 p.m.

Refreshment Break

3:45 p.m.

Luxembourg Tax Law Developments
Jan Neugebauer, Arendt & Medernach LLC, New York, NY

  • The new limited partnership legislation
  • Intragroup-financing Circulars
  • VAT warehouse regime
  • Exchange of information procedure under the new US / Luxembourg protocol

4:45 p.m.

Questions & Answers

5:00 p.m.

Cocktail Reception