Itpa, Geneva

Itpa - The International Tax Planning Association

Geneva Meeting - 1-3 June, 2014 - Grand Hotel Kempinski

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The Tax members, at Chetcuti Cauchi, will be attending the International Tax Planning Association Geneva Meeting on the 1st to 3rd of June, 2014.

Programme

Sunday, 1^st June

15.00     Registration

18.30     Welcome Reception

Monday, 2^nd June

09.00     Automatic Exchange of Information – Niklas Schmidt

                What it means to your client

• The OECD Model Convention
• The Joint Council of Europe/OECD Convention on Mutual Administrative Assistance in Tax Matters.
• The EU Savings Directive
• FATCA and its offspring
• The EU Mutual Assistance Directive The OECD Model Competent Authority Agreement (CAA) and Common Reporting and Due Diligence Standard (CRS)

09.40     Locating Fund Management – Andrew Knight

                The impact of the location of the management function on the tax profile                   of the fund:

• What is the potential for an onshore management activity to create a local tax footprint for an offshore fund?
• What are the risks (distinguishing between residence and source)?
• To what extent do different jurisdictions create an environment that neutralizes those risks?
• Are there any countries that can be regarded either as safe havens or “no go” areas in this context

10.20     Coffee

10.50     Discussion session with Niklas Schmidt and Andrew Knight11.35     The New Malta Citizenship Programme and Other Developments in Residence and Citizenship Planning – Christian Kalin

• How Malta is setting a new standard
• What’s happening in Portugal?
• The future of the Caribbean Citizenship-by-investment programmes
• Updates from Switzerland, Canada, UK and other countries

12.15     Pre-lunch drinks, followed by set lunch

14.30     Preparing for FATCA – Marnin J. Michaels

• Less than one month to go
• What to do if you have not registered
• Can you get last minute sponsoring
• Unsettled issues
• The new regulations help or hurt?

15.10     Discussion Session with Christian Kalin and Marnin J. Michaels

15.55     Tea and close of Day One

18.30     Reception, hosted by BSI Ltd.

Tuesday, 3^rd June

09.00     A fresh Look at Canada – Robert L. Reymond

• Offshore trust rules adopted after 14 years
• Immigration trust: gone
• Planning for cross=border families with Canadian connections
• Canada tackles international evasion
• Treaty shopping anti-avoidance

09.40     The Dutch Stichting in Focus – Nico Francken

• The use of Dutch Foundation in international tax planning
• Forming and administering a Foundation
• The use of Foundations in Asia, especially Indonesia
• Foundations and the future

10.20     Coffee

10.50     Discussion Session with Robert L. Reymond and Nico Francken

11.30     Planning Opportunities with Foreign Branches – Julien Dif

12.15     Pre-lunch drinks, followed by set lunch

12.30     The News from Brussels – Timothy Lyons Q.C.

• EU Financial Transactions Tax: two proposals and a law suit – whatever next?
• Savings tax – agreement – now what?
• Patent boxes in the EU – use or abuse?
• EU provisions in double tax treaties
• Applying competition rules in tax cases – the new approach?

15.10     Discussion Session with Julien Dif and Timothy Lyons Q.C.

15.55     Tea and Close of Meeting

The International Tax Planning Association is a multi-disciplined association of over 1,000 bankers, trust officers, finance directors, accountants, lawyers and others with a practical interest in the tax aspects of cross-frontier transactions.