IRS tax counsel to speak at U.S., Latin America tax conference

Peter H. Blessing, associate chief counsel, International, at the Internal Revenue Service, will deliver a keynote speech during the Virtual 13th Annual U.S. and Latin America Tax Practice Trends Conference Monday through Thursday, June 21-24. The event is co-sponsored by the American Bar Association Section of Taxation, the International Bar Association Taxes Committee and the International Fiscal Association – USA Branch.

International tax professionals from industry and private practice will gather to focus on practical tax practice trends for multinational corporations and their international advisers, as well as provide insight into how government tax officials may view the international tax landscape in light of important international developments that impact corporate taxpayers.

The conference will be supplemented by a half-day workshop on Monday, June 21, featuring panels on private wealth management, a view of Latin America from tax executives and cryptocurrency for young lawyers.

Blessing joined the IRS Office of Chief Counsel after serving as managing director for Washington National Tax and International Tax units of KPMG LLP. He was a partner for more than 25 years with Shearman & Sterling LLP where he had a tax practice with an emphasis on financial institutions and international tax matters. He will speak at the opening plenary on Tuesday, June 22, at 9:30 a.m.

Other program highlights include:

“Current State of the M&A Market: Private Equity, Public Offerings and Other Alternative Investment Vehicles” — The panelists will cover private equity investment in Latin America, the recent increase in public offering transactions and the increased use of SPACs in the region. Speakers: Andrea Bazzo Lauletta, Mattos Filho, São Paulo, Brazil; Devon Bodoh, Weil, Gotshal & Manges LLP, New York City; Alejandro Santoyo, Creel, García-Cuéllar, Aiza y Enriquez, S.C., Mexico City, Mexico; Monica Bolanos, Deloitte Tax LLP, Bogotá, Colombia; and Julio Castro, KPMG LLP, London.

“U.S. Inbound” — The panel will focus on investing in the United States from Latin America. Attention will be given to the use of leverage, hybrid instruments and base erosion. Common pitfalls of investing in U.S. real estate will also be considered. Speakers: Layla Asali, Miller & Chevalier, Washington, D.C.; Ricardo León Santacruz, Sánchez Devanny Eseverri S.C., Mexico City, Mexico; Luiz Felipe Centeno Ferraz, Mattos Filho, São Paulo, Brazil; Juan Carlos Garanton, Torres Plaz & Araujo, Caracas, Venezuela; Mario Gorziglia, Prieto y Cía. Abogados, Santiago, Chile; and Carolina Rozo, Philippi Prietocarrizosa Ferrero DU & Uría, Bogotá, Colombia.

“Corporate Tax Structuring with Intellectual Property” — The discussion will focus on tax structuring techniques that are utilized in the cross-border deployment of intellectual property rights. Panelists will discuss in particular structuring solutions for problems that may arise when the tax and non-tax rules in a jurisdiction limit the standard options for direct licensing of IP rights. Speakers: Maria Ines Brandt, Marval, O’Farrell & Mairal, Buenos Aires, Argentina; Richard Winston, Winston Legal Group LLC, Miami, Florida; Fabiola Diaz, Anaya Abogados Asociados, S.C., Mexico City, Mexico; Renata Emery, TozziniFreire, São Paulo, Brazil; Maria Javiera Contreras, EY, Santiago, Chile; and Javier Otegui, Guyer, & Regules, Montevideo, Uruguay.

“Tax Treaties — the MLI, Beneficial Ownership and Hybrid Entities” — Panelists will focus on the practical implications for cross-border corporate structures deriving from the MLI anti-treaty abuse provisions as well as beneficial ownership issues and the current state of hybrid entities. Speakers: Manuel Alcalde, Carey, Santiago, Chile; Sylvia Dikmans, Houthoff, Amsterdam, The Netherlands; Armando Lara Yaffar, KPMG LLP, Mexico City, Mexico; Jeff Rubinger, Baker McKenzie, Miami, Florida; and Ana Claudia Akie Utumi, Utumi Advogados, São Paulo, Brazil.

“The Impact of the Biden Tax Proposal and Other Tax Reform Responses to COVID” — The panel will cover the Biden tax proposal impact on Latin America. Further consideration will be given to various tax policy responses to the COVID pandemic and the impact on Latin America. A practical view will be given to how to plan in the region considering these proposals and legislation. Speakers: Fernando Camarena, Foley & Lardner LLP, Mexico City, Mexico; John Gimigliano, KPMG LLP, Washington, D.C.; Nita Asher, PwC, Washington, D.C.; and Raquel Novais, Machado Meyer Sendacz & Opice Advogados, São Paulo, Brazil
“Criminal Tax” — This panel will focus on the interaction of criminal tax statutes across Latin America, with focus on traps and pitfalls in the criminal tax arena. Panelists will pay particular attention to compliance-related issues that give rise to criminal implications. Speakers: Caroline D. Ciraolo, Kostelanetz, & Fink LLP, Washington, D.C.; Igor Mauler Santiago, Mauler Advogados, São Paulo, Brazil; and Manuel Sainz Orantes, Chévez Ruíz Zamarripa y Cía SC, Mexico City, Mexico.

For additional information or to register for the conference, visit www.americanbar.org/groups/taxation.