U.S.-Mexico International Tax Update
on the Latest U.S.-Mexico Cross-Border Tax Issues
Early Bird Registration Extended to January 31 - Register Now!
February 23-24, 2006
Joan B. Kroc Institute for Peace & Justice, University of San Diego
5998 Alcalá Park, San Diego, CA 92110-2492
Hear the Experts. Learn the Latest. Expand your Practice.
The USD School of Law – Procopio International Tax Institute Conference (ITI), now in its second year, is the only conference dedicated to the latest developments in the dynamic field of U.S. and Mexican international tax law. This educational two-day intensive conference attracts internationally recognized tax experts in government and private practice to present, explore, learn and discuss current research and innovations affecting the field of international tax. Leading experts from both sides of the border participate in this in-depth, practical curriculum.
Featuring introductory and advanced courses, simultaneous Spanish translation, and expert teaching panels in a state-of-the-art facility, the ITI provides the ideal atmosphere for education and interaction with internationally recognized leaders and experts in the field of international tax law. Among the speakers will be the highest ranking U.S. and Mexican international tax officials, many of whom are returning to share the latest updates and developments.
Who should attend:
- U.S. and Mexican attorneys, accountants, corporate tax directors, managers and controllers
- Banking and financial advisors to multi-national investors
- Real estate specialists with cross-border accountability
- Financial executives responsible for Mexican or U.S. business operations
If your profession or business requires the most current information about the effect of international tax law on commerce between the United States and Mexico, this conference is for you. You will learn the latest from the experts in this rapidly developing field.
Earn MCLE Credit: The University of San Diego School of Law is a State Bar of California approved MCLE provider. MCLE credit pending for the following states: TX, NV, IL, NY, FL, AZ and NM.
2006 Confirmed Speakers (will be updated regularly)
Speakers from the United States
Rufus von Thülen Rhoades, Esq.
Author, Rhoades & Langer, U.S. International Taxation and Tax Treaties
John Breen, Esq.
Office of the Associate Chief Counsel (International), Internal Revenue Service (IRS)
Patrick W. Martin, Esq.
Tax Team Leader - Procopio
Past Chair, International Committee, Taxation Section, State Bar of California
Robert W. Lorence, Esq.
Office of the Associate Chief Counsel (International), IRS
Herbert I. Lazerow
Professor, University of San Diego School of Law
John Forry, Esq.
Visiting Professor, University of San Diego School of Law
Author, Practical Guide to Foreign Investment in the United States
Richard Shaw, Esq.
Distinguished Adjunct Professor, University of San Diego School of Law
Higgs, Fletcher & Mack
Past Chair, American Bar Association, Section of Taxation
Richard Fultz, Esq.
Special Counsel, Office of Chief Counsel, IRS
Phyllis Marcus, Esq.
Office of the Associate Chief Counsel (International), IRS
Grace Fleeman, Esq.
Office of the Associate Chief Counsel (International) IRS
David Sotos, Esq.
Office of International Tax Counsel, Treasury Department
David Forst, Esq.
Fenwick & West LLP
Frederic Adam, Esq.
Greenberg Traurig LLP
William F. Colgin, Jr., Esq.
Fenwick & West LLP
Enrique Hernandez, Esq.
Procopio
Chair, International Committee, Taxation Section, State Bar of California
Walter M. Kolligs, Esq.
Principal, International Tax Services Group, Ernst & Young LLP
Ramon Camacho, Esq.
Managing Director, Wealth and Tax Advisory Services, Inc./HSBC
Peter J. Elias, Esq.
Foley & Lardner LLP
Diane M. Ring
Associate Professor, Boston College Law School
Speakers from Mexico
Lic. Alfredo Gutiérrez Ortiz Mena
Chief Counsel - Mexican Tax Administration Service (SAT), Mexico
Julio Cesar Aguilar
Head of Tax Policy, Ministry of Finance and Public Credit (SHCP), Mexico
Lic. Roberto Schatan Pérez
Head of the Transfer Pricing Unit, SAT
Lic. Ambrosio Michel Higuera
Under Fiscal Federal Attorney General of Criminal Affairs - SHCP (Mexican Ministry of Finance)
Lic. Gabriel Ortiz Gómez
Ortiz, Sainz y Erreguerena, S.C.
Lic. Luis Santos Theriot
Santos-Elizondo-Cantu-Rivera-González-De la Garza-Mendoza-S.C. - Monterrey
Lic. Christian R. Natera
Tron y Natera, S.C.
Lic. Mauricio Bravo Fortoul
Turanzas, Bravo y Ambrosi, S.C.
C.P. Miguel Ortiz Aguilar
Ortiz, Sosa, Ysusi y Cía, S.C.
C.P. Mauricio Monroy
Deloitte & Touche - Tijuana
Lic. Luis Carbajo
Baker & McKenzie - Ciudad Juárez
Lic. Simón Somohano
Deloitte & Touche - Mexico
Lic. Carl Koller
Despacho Paras, S.C.
Lic. Juan José Paullada Figueroa
Paullada, Del Rey y Guevara, S.C.
Former Mexican Fiscal Federal General Attorney
Lic. Miguel Gonzalez Guerra
González, Orozco, Rodríguez & Barajas, S.C. - Guadalajara
C.P.C. Alfredo Sanchez Torrado
Chevez, Ruiz, Zamarripa y Cia, S.C. - Mexico City
Course Topics 2006 :
- Mexico's New Tax Law Reform (2006) Update of Reforms Effecting Cross-Border Transactions
- Overview of the U.S. Tax System Regarding Mexican Business and Commercial Activities in the U.S. Choice of Entity Selection; Intersections of Subchapter C, K and S.A., S. de R.L. and S.C
- Complex Issues Regarding Partnerships with Foreign Partners (Newly Issued Regulations)
- Transfer Pricing: Current Developments in U.S. and Mexico (Xilinx, Cost Sharing, etc.)
- U.S. and Mexican Informational Reporting of International Transactions & the Hefty Penalty Provisions
- Beyond the Basics of U.S. and Mexican Taxation of Trusts (Taxation of Accumulated Income Simple and Complex Trusts)
- Mexico's Maquiladoras Taxation & Current Developments
- Overview of Mexico's Tax System Regarding U.S. Business and Commercial Activities in Mexico
- Mexico and U.S. Anti-Money Laundering Compliance How Can Tax Professionals Understand the Rules and Avoid the Risks?
- Cross-Border Tax Controversies and Tax Shelters New Focus of U.S. and Mexico Cross-Border Audits and Enforcement of Complex Foreign Transactions
- Cross-Border Financing Treaty Benefits, U.S. Portfolio Interest and Mexico's Thin Capitalization Rules and More
- Recent Developments in the U.S.- Mexico Income Tax Treaty Competent Authority and Beyond
- Current Developments in Reorganizing and Liquidating U.S. and Mexican Cross-Border Operations
- International Planning and Recent Reforms of Anti-Deferral Legislation in Mexico and the U.S. Repatriating Earnings
- Complex International Transfer Tax Issues for Cross-Border Estates and International Gifts Mexico's Exemptions and International Estates and Gifts
- Professional Responsibility Regulation Cross Border Application of New Circular 230 Rules and Mexico's Counterpart (Codification of Business Purpose Doctrine)
Conference Facts:
Dates:
February 23-24, 2006
Location:
Joan B. Kroc Institute for Peace & Justice, University of San Diego - 5998 Alcalá Park, San Diego, CA 92110-2492
2005 Attendees (Inaugural Year):
141 from Mexico and United States
2005 Keynote Speakers:
- Harry “Hal” Hicks, Jr., Esq. – newly appointed International Tax Counsel to the U.S. Treasury Department
2006 Keynote Speakers:
- Rufus von Thülen Rhoades, Esq., author, Rhoades & Langer, U.S. International Taxation and Tax Treaties
- Julio Cesar Aguilar, Head of Tax Policy, Ministry of Finance and Public Credit (SHCP), Mexico
Sponsors:
Cost to Attend:
The two-day conference fee is $895 and includes admission to all sessions, conference materials, two keynote speaker luncheons and special events. Professors, USD alumni and government attorneys are offered a registration fee of $695 (no other discount my apply).
Current special registration discounts include:
Please note: only one discount may apply to any single registration.
One-Day: Registration cost of $495
Group Rate (for qualifying organizations with three or more attendees): $695
To register by phone, please call (800) 491-7353.
For additional information, please email info@usdprocopioITI.org or call Summer King, event manager, at (619) 515-3297.
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More Information
To register by phone, please call
(800) 491-7353.
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