Current International Tax Issues in Cross- Border Corporate Finance and Capital Markets

Presented by the International Bar Association, Tax Section in association with the Chartered Institute of Taxation European Branch

16–17 May 2011 Whitefriars Lecture Theatre Freshfields Bruckhaus Deringer LLP 65 Fleet Street London EC4Y 1HS Programme

Conference Co-Chairs Jack Bernstein Aird & Berlis LLP, Toronto (IBA) Jonathan Schwarz Temple Tax Chambers, London (CIOT)

Monday 16 May Tuesday 17 May

1230 – 1330 Registration of delegates 0900 – 1045 Use of Finance Companies by Multinationals 1330 – 1430 Carmine Rotandaro Gucci Interest Deductibility – Current State of Play and Sara Luder Slaughter and May Direction of Travel Klaus Sieker Flick Gocke Schaumburg Murray Clayson Freshfields Bruckhaus Deringer LLP Marcel Buur Loyens & Loeff Michel Collet CMS Bureau Francis Lefebvre; Website Officer, Michael Lukacs GE Capital IBA Taxes Committee John Sherman HM Treasury 1045 – 1100 Coffee and Tea Break

1430 – 1530 1100 – 1200 Financing Transactions in this Environment Capital Raising for Banks Under Regulatory including Securitizations Constraint Patrick Mears Allen & Overy Yash Rupal Linklaters Paul Carman Chapman & Cutler LLP Michael Nordin Schellenberg Wittmer Peter Maher A & L Goodbody Jen Zheng CITI Bank Jonathan Winstanley Lloyds Banking Group 1530 – 1600 Coffee and Tea Break 1200 – 1245 1600 – 1700 Withholding and Reporting Compliance Issues Hedging Including Credit Default Swaps and (Including FATCA and Beneficial Ownership) Managing Foreign Exchange Issues Andrew Solomon Sullivan Cromwell Carlos Ferrer Cuatrecasas Goncalves Pereira Rom P Watson Ropes & Gray LLP Erika Nijenhuis Cleary Gottlieb Justin Hamer Greenberg Traurig LLP 1245 – 1330 Buffet Lunch

1700 – 1800 1330 – 1530 Taxation of Offshore Income of Financial Institutions Current Trends in Structured Finance including (CFC Rules, Managing Foreign Tax Credits) impact of GAAR Richard Hartnig Sutherland Asbill & Brennan LLP Heather Gething Herbert Smith LLP Pano Pliotis GE Capital Eric Chun Ernst & Young Erica Gut Bank of America Merrill Lynch Chris Bates Norton Rose LLP Stephen Hoyle DLA Piper UK LLP 1845 Cocktails (all delegates welcome) Crowne Plaza Hotel (London – The City) 1530 – 1600 Coffee and Tea Break New Bridge Street EC4 1600 – 1730 1930 Dinner* Distressed Debt Issues Crowne Plaza Hotel (London – The City) Simon Yates Travers Smith LLP; Newsletter Editor, IBA Taxes New Bridge Street EC4 Committee *A separate charge of £60 will be made. Fernando Casanueva Garrigues Christophe Joosen Nauta Dutilh Mark Weinstein Hogan Lovells LLP Information

Date Registration Confirmation 16–17 May 2011 Upon receipt of your payment for the conference, a confirmation e-mail will be sent containing instructions on Conference Venue how to download conference materials prior to the event. Whitefriars Lecture Theatre Registration confirmation will not be distributed by post. Freshfields Bruckhaus Deringer LLP 65 Fleet Street Hotel Accommodation London EC4Y 1HS Hotel rooms have been held at The Crowne Plaza Hotel (London – The City) at the rate of £205. This price is per room/ Cocktails and Dinner Venue night, includes breakfast and is subject to VAT 20%. In case of Crown Plaza Hotel (London – The City) changes to the VAT, currently 20%, the hotel reserves the right 19 New Bridge Street to adjust the prices. A £10 supplement for double of occupancy London EC4V 6DB will be made.

Language Please make your reservations directly with the hotel by All working sessions and conference materials will be in English. 17 April 2011 to secure this rate.

How to Register Group code: SB3 Please complete the attached registration form and e-mail to Melissa Lawrence at [email protected]. Reservations can be made via: Website: www.crowneplaza.com/londonthecity Payment to be made by major credit card to be included when Email: [email protected] registering. You will receive an e-mail confirmation and invoice. Telephone: 44 (0) 207 438 8034

Fees The conference fee set out below includes the cocktail party. There is an additional charge of £60 for the dinner on Monday 16 May 2011.

IBA Member/CIOT Member* • Early Bird (before 1 April 2011) – £195 • Regular – £225

*Join now and benefit from discount

Non IBA Member/CIOT Member • Early Bird (before 1 April 2011) – £235 • Regular – £250

Delegate Fees include: • Attendance at seminar • Access to conference materials online • Business lunch on 17 May 2011 • Tea and coffee during breaks • Cocktail reception at Crowne Plaza Hotel London Registration Form

Current International Tax Issues in Cross-Border Corporate Finance and Capital Markets 16–17 May 2011, Whitefriars Lecture Theatre, Freshfields Bruckhaus Deringer LLP, London

To register please send this form via e-mail to [email protected] or via fax to +001 416 863 1515

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Signature ______Date �� International Bar Association the global voice of the legal profession

The International Bar Association (IBA), established in 1947, is the world’s leading organisation of international legal practitioners, bar associations and law societies.

The IBA influences the development of international law reform and shapes the future of the legal profession throughout the world. It has a membership of more than 40,000 individual lawyers and 197 bar associations and law societies spanning all continents. It has considerable expertise in providing assistance to the global legal community.

Divisions and committees Grouped into two divisions – the Legal Practice Division and the Public and Professional Interest Division – the IBA covers all practice areas and professional interests, providing members with access to leading experts and up-to-date information.

Through the various committees of the divisions, the IBA enables an interchange of information and views among its members as to laws, practices and professional responsibilities relating to the practice of business law around the globe.

Taxes Committee overview The IBA's widely respected and very active Taxes Committee offers its members access to the highest quality technical, practical and professional tax expertise to assist in understanding and finding solutions to international tax issues and concerns. It also encourages interface between international tax specialists and promotes the building of networks among tax lawyers worldwide to assist them in better serving the interests of their clients. The committee is divided informally into four practice group areas: Income Taxes, Other Taxes, Tax Litigation and Employee Benefits.

Members are encouraged to contribute to the committee newsletter which is published two to three times per year and to present papers at committee conferences and seminars. The committee also offers tax executives a forum, in its Tax Executives group, to exchange expertise and skills with their colleagues in industry on topics of special interest.

Additionally, the Taxes Committee works with the Individual Tax and Private Client committee to form the Taxation Section

Contact information: International Bar Association 10th Floor, 1 Stephen Street, London W1T 1AT, United Kingdom Tel: +44 (0)20 7691 6868. Fax: +44 (0)20 7691 6544 www.ibanet.org

Chartered Institute of Taxation

The CIOT is the leading body in the UK for taxation professionals dealing with all aspects of taxation. Our primary purpose is to promote education in taxation. One of our key aims is to achieve a more efficient and less complex tax systems for all. Our comments and recommendations on tax issues are made solely in order to achieve this aim; we are an entirely apolitical organisation.

Membership of the CIOT is by examination; nationally recognised as the gold standard of UK taxation education. We support our 15,000 members and 4,000 students throughout their tax careers, providing assistance through our London-based head office and worldwide network of 34 branches. The CIOT is a registered charity, number 1037771 and a regulatory body for the purposes of Anti-Money Laundering supervision of tax practitioners.