U.S.–Latin america - International Fiscal Association

6TH Annual
U.S.–Latin America
Tax Planning Strategies
Mandarin Oriental Hotel • Miami
JUNE 13-14, 2013
WEALTH AND ASSET PLANNING WORKSHOP • JUNE 12
Tax executives workshop • JUNE 12
CONFERENCE BROCHURE
USA Branch

CONFERENCE ORGANIZERS
American Bar Association Section of Taxation
740 15th Street, NW, Washington, DC 20005, USA
www.americanbar.org/groups/taxation
As the national representative of the legal profession, the mission of the ABA Section of
Taxation is to serve our members and the public through education and leadership to
achieve an equitable, efficient, and workable tax system. The Tax Section puts all of the
latest information on administrative and procedural developments right at your fingertips.
Our publications, programs, and expert advice help you navigate the constantly changing
landscape of tax law.
IFA – USA Branch
2604 Elmwood Avenue, Suite 347, Rochester, NY 14618, USA
www.ifausa.org
USA Branch
Formed in 1938, the International Fiscal Association is a leading non-governmental,
international organization dealing with tax matters. The USA Branch is the largest
national IFA branch, with approximately 1,000 members. The Branch hosts a two-day
conference in late February/early March of each year with presentations by eminent
international tax experts on topics, planning ideas and issues of current importance. The
USA Branch also holds joint meetings each year with branches from other countries.
International Bar Association, Taxes Committee
4th Floor, 10 St. Bride Street, London EC4A 4AD, England
www.ibanet.org
The International Bar Association (IBA) is the world’s leading organization 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 over 45,000 individual lawyers and 200
bar associations and law societies spanning all continents. It has considerable expertise
in providing assistance to the global legal community as well as being a source of
distinguished legal commentators for international news outlets.
Tax Executives Institute, Inc.
1200 G Street, NW, Suite 300, Washington, DC 20005, USA
www.tei.org
Tax Executives Institute, founded in 1944, is the preeminent association of corporate
tax professionals worldwide. Its 7,000 members are accountants, lawyers, and other
corporate and business employees who are responsible for the tax affairs of 3,000 of the
leading companies in North America, Europe, and Asia. Through educational forums,
liaison meetings with government officials, testimony at public hearings, and written
submissions, TEI supports the development and effective implementation of sound tax
policy, promotes the uniform and equitable enforcement of the tax laws, and works to
reduce the cost and burden of administration and compliance to the benefit of taxpayers
and government alike.
American Bar Association Section of International Law
740 15th Street, NW, Washington, DC 20005, USA
www.americanbar.org/groups/international_law
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6th Annual U.S. - Latin America Tax Planning Strategies

GENERAL INFORMATION
CONFERENCE CO-CHAIRS
Joan C. Arnold, Pepper Hamilton LLP, Philadelphia, PA, USA
Sam Kaywood, Alston & Bird LLP, Atlanta, GA
Raquel Novais, Machado Meyer Sendacz & Opice Advogados, São Paulo, Brazil
Leandro M. Passarella, Passarella Abogados, Buenos Aires, Argentina
Monica Reyes, Reyes Abogados Asociados S.A., Bogotá, Colombia
Emin Toro, Covington & Burling LLP, Washington, DC, USA
Alejandro Torres, Chevez, Ruiz, Zamarripa y Cia., S.C., Mexico City, Mexico
WEALTH AND ASSET PLANNING WORKSHOP CHAIR
Monica Reyes, Reyes Abogados Asociados S.A., Bogotá, Colombia
TAX EXECUTIVES WORKSHOP CHAIR
Lionel Nobre, Dell Computadores do Brasil Ltda., Rio Grande do Sul, Brazil
PROGRAM DESCRIPTIONS
Wealth and Asset Planning Workshop - June 12, 2013
The Workshop will focus on tax issues relating to wealth management and asset
protection planning arising at the time of transfer of assets from Latin America into North
America and Europe, from initial structuring through the holding period to consideration
of exit strategies. The transfer of wealth and assets located both within and outside an
individual’s or entity’s country of residence will be addressed, as well as use of such
intermediary vehicles as corporations, partnerships, and trusts in a variety of jurisdictions.
Tax Executives Workshop - June 12, 2013
The Workshop will address the main issues affecting Tax Directors that cover Latin
America in regards to managing a multinational’s taxes in the region. Topics will
include tax compliance, tax systems, tax planning and tax reporting. It will be a unique
opportunity to learn from experienced in-house tax professionals from diverse industries
such as IT, manufacturing, services and banking what their best practices and main tax
concerns are in Latin America.
U.S. - Latin America Tax Planning Strategies Conference - June 13-14, 2013
The Conference addresses key tax issues for a wide range of in-house and outside tax
and finance personnel doing business in the U.S. and Latin America. Case studies will
underscore the effect of treaties, court decisions and domestic laws to provide insight into
local planning opportunities. Panels will feature industry speakers, leading practitioners
and government representatives offering the latest perspectives from the U.S. and Latin
America on such topics as cross-border mergers and acquisitions, financing and transfer
pricing.
REGISTRATION
Registration for the Workshops and Conference is available at the following website:
https://meetings.abanet.org/meeting/tax/MIAMI13/register.cfm. All individuals attending
any part of the Conference must register and pay the registration fee. Shared registrations
are not permitted. Payment may be by check, credit card, or wire transfer. Checks
should be made payable to the ABA Section of Taxation. The Section accepts American
Express, MasterCard, and Visa. To pay by wire transfer, please contact Tim Brady at tim.
brady@americanbar.org to request banking details. No registration will be processed or
considered received unless payment is included.
http://meetings.abanet.org/meeting/tax/MIAMI13 3

GENERAL INFORMATION
CLE CREDIT
You must be registered for the Conference in order to attend and be eligible to receive
CLE and CPE credit. ABA programs ordinarily receive CLE credit in AK, AL, AR, AZ, CA,
CO, DE, FL, GA, GU, HI, IA, ID, IL, IN, KS, KY, LA, ME, MN, MS, MO, MT, NH, NM,
NV, NY, NC, ND, OH, OK, OR, PA, RI, SC, TN, TX, UT, VT, VA, VI, WA, WI, WV, and WY.
These states sometimes do not approve a program for credit before the program occurs.
This course is expected to qualify for 13.5 CLE credit hours in 60-minute-hour states,
and 16.2 credit hours in 50-minute-hour states. This transitional program is approved for
both newly admitted and experienced attorneys in NY. For more information about CLE
accreditation in your state, please visit the following website: http://meetings.abanet.org/
meeting/tax/miami13/cle.cfm.
CPE CREDIT
The ABA Section of Taxation is registered with the National Association of State Boards of
Accountancy (NASBA) as a sponsor of continuing professional education on the National
Registry of CPE Sponsors. State boards of accountancy have final authority on the
acceptance of individual courses for CPE credit. Complaints regarding registered sponsors
may be submitted to the National Registry of CPE Sponsors through its website: www.
learningmarket.org.
SCHOLARSHIP INFORMATION
Scholarships to defray tuition expense for this program are available upon application on
a case-by-case basis. To request a scholarship application, please email Tim Brady at
tim.brady@americanbar.org.
ABA OPEN MEETINGS POLICY
In accordance with the ABA Open Meetings Policy, all ABA programs are open to
the media unless they are to conduct business sessions of a confidential nature. The
Association encourages media coverage of its activities. If you have questions about this
policy, please contact the Tax Section at +1.202.662.8670.
CONTENT DISCLAIMER
All Workshop and Conference content, including live, recorded, and written presentations,
represents the opinions of the authors and speakers and should not be construed to
be those of either the American Bar Association or Section of Taxation unless adopted
pursuant to the bylaws of the Association. Nothing contained herein is to be considered
as the rendering of legal advice for specific cases, and readers are responsible for
obtaining such advice from their own legal counsel. This Workshop and Conference
content and any forms and agreements herein are intended for educational and
informational purposes only.
All rights reserved. No part of these materials may be reproduced, stored in a retrieval
system, or transmitted, in any form by any means, electronic, mechanical, photocopying,
recording, or otherwise, without the written permission of the American Bar Association.
PHOTOGRAPHY AND VIDEO
Note that by attending the Conference, attendees have agreed to the terms of the
American Bar Association Image/Audio/Video Release which allows images, audio,
and video recorded on site to be used for educational and promotional purposes by the
American Bar Association.
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6th Annual U.S. - Latin America Tax Planning Strategies

WEDNESDAY, JUNE 12
WEALTH AND ASSET PLANNING WORKSHOP
12:30 p.m. – 1:15 p.m. registration of Delegates
1:15 p.m. – 1:30 p.m. Opening Remarks
1:30 p.m. – 3:00 p.m.
Investment Incentives in the United States, Canada, Spain, and Brazil:
Immigration and Tax Issues
This panel will focus on immigration and tax issues applying to individuals who intend
to move to the United States, Canada, Spain, or Brazil with an emphasis on available
Investment Incentive Programs.
Co-Chairs
Alberto I. Benshimol, D’Empaire Reyna Abogados, Caracas, Venezuela
Steven L. Cantor, Cantor & Webb P.A., Miami, FL, USA
Speakers
Marisa Casablanca, Casablanca Legal Group P.L., Miami, FL, USA
Shoshana Green, Green and Spiegel, Barristers and Solicitors, Toronto, ON, Canada
Eduardo Martinez-Matosas, Gómez-Acebo & Pombo, Barcelona, Spain
Kristina Soutar, Thorsteinssons LLP, Toronto, ON, Canada
3:00 p.m. – 3:30 p.m. networking Break
3:30 p.m. – 5:30 p.m.
Private Client Legislative Updates: United States, Argentina, Colombia,
Venezuela and Guatemala
This panel will provide an update of tax and other legislative changes in various Latin
countries which impact upon wealth management and asset protection for individuals
and their family enterprises. The transfer of wealth and assets located both within and
outside an individual’s or entity’s country of residence, as well as the use of intermediary
vehicles such as corporations, partnerships and trusts in a variety of jurisdictions, will be
analyzed under the light of these legislative developments.
Co-Chairs
Ron Choudhury, Aird & Berlis LLP, Toronto, ON, Canada
Monica Reyes, Reyes Abogados Asociados S.A., Bogotá, Colombia
Speakers
Roberto Barrieu, Souza, Cescon, Barrieu & Flesch Advogados, São Paulo, Brazil
Juan Carlos Casellas, Mayora & Mayora, S.C., Guatemala, Guatemala
Erika Litvak, Greenberg Traurig PA, Miami, FL, USA
Sebastián López Sansón, Salaberren & López Sansón, Abogados, Buenos Aires, Argentina
Nathalie Rodriguez Paris, Hoet Pelaez Castillo & Duque, Caracas, Venezuela
http://meetings.abanet.org/meeting/tax/MIAMI13 5

WEDNESDAY, JUNE 12
TAX EXECUTIVES WORKSHOP
12:30 p.m. – 1:15 p.m. registration of Delegates
1:15 p.m. – 1:30 p.m. Opening Remarks
1:30 p.m. – 3:00 p.m.
Managing your Tax Compliance in Latin America – Systems, Process, and
People
This panel will cover the main challenges for companies in Latin America in establishing
and managing their tax compliance in the region. It is known that Latin America has
significantly more difficult compliance rules from “form over substance” to electronic
invoicing. Companies need to be prepared to operate in such a harsh environment. The
speakers will cover what are the best systems for Latin America and how to create and
maintain processes that are compliant from a local perspective. Finally, how to attract,
hire & retain tax talent for Latin America will be covered.
Chair
Lionel Nobre, Dell Computadores do Brasil Ltda., Rio Grande do Sul, Brazil
Speakers
Russell Dover, Thomson Reuters, New York, NY, USA
Ivan Ferreira, MWV Rigesa, Campinas, Brazil
Leopoldo Lombardi, Deloitte, Buenos Aires, Argentina
Roberto Lopez Alvarez, Grupo Posadas, Mexico City, Mexico
3:00 p.m. – 3:30 p.m. networking Break
3:30 p.m. – 4:30 p.m.
How a Tax Department Can Add Value to Your Business in Latin America –
Tax Enablement and Tax Planning
This panel will address how an in-house tax professional in Latin America can add value
to the business. This includes supporting & enabling businesses in the more than 21
different jurisdictions in the region. In-house professionals will address the question of
“what to do with the memo” once the technical aspects are known. Or rather, “how
can I internally implement a tax strategy that can save money or mitigate risks” in Latin
America?
Chair
Stuart Chessman, Vivendi S.A., New York, NY, USA
Speakers
Daniel Hora do Paço, Petróleo Brasileiro S.A. – Petrobras, Rio de Janeiro, Brazil
Lionel Nobre, Dell Computadores do Brasil Ltda., Rio Grande do Sul, Brazil
Sergio Abrajan Sevilla, Telefonica, Mexico City, Mexico
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6th Annual U.S. - Latin America Tax Planning Strategies

WEDNESDAY, JUNE 12
4:30 p.m. – 5:30 p.m.
How to Clearly and Concisely Report Issues to Headquarters: FAS 5, FIN
48, ASC 740 (formerly FAS 109), etc.
This panel will focus on how to translate local tax issues for corporate headquarters
purposes. Latin America is known for its abundant indirect taxes and litigious
environment. How can in-house professionals adequately translate these challenges into
FAS 5, FIN 48, and ASC 740 language? How can in-house professionals work with local
advisors as to make sure that the criteria under these rules are covered?
Chair
Marie T. Lopez, S.C. Johnson & Son, Inc., Racine, WI, USA
Speakers
Stuart Chessman, Vivendi S.A., New York, NY, USA
Maria Fernanda Campos, Ford Motor Company, São Paulo, Brazil
Florencia Lucila Misrahi, Cargill S.A.C.I., Buenos Aires, Argentina
Lionel Nobre, Dell Computadores do Brasil Ltda., Rio Grande do Sul, Brazil
http://meetings.abanet.org/meeting/tax/MIAMI13 7

THURSDAY, JUNE 13
8:00 a.m. – 5:30 p.m. registration of Delegates
8:00 a.m. – 8:45 a.m. Continental Breakfast
8:45 a.m. – 9:00 a.m. Opening Remarks
9:00 a.m. – 10:30 a.m. Plenary Session
Mergers and Acquisitions and Capital Markets Update
This panel will discuss many of the most relevant and interesting M&A and capital
markets transactions in Latin America within the last twelve months from a local and
cross-border tax perspective.
Co-Chairs
Manuel Benites, Perez Alati, Grondona, Benites, Arnsten & Martinez de Hoz (h), Buenos
Aires, Argentina
William Dixon, Citigroup Global Markets Inc., New York, NY, USA
Speakers
Peter H. Blessing, KPMG LLP, Stamford, CT, USA
Celso Costa, Machado, Meyer, Sendacz e Opice Advogados, São Paulo, Brazil
Sylvia Dikmans, Houthoff Buruma, Amsterdam, The Netherlands
Juan Pablo Orellana, Cariola, Díez, Pérez-Cotapos & Cía. Ltda, Santiago, Chile
Ricardo Reséndiz Wong, Resendiz Wong Abogados, Mexico City, Mexico
10:30 a.m. – 11:00 a.m. networking Break
11:00 a.m. – 12:30 p.m. Concurrent Session A
Tax Treatment of Cross-Border Services
This panel will discuss the most common issues that arise from the performance of
cross-border services into Latin American countries. The panel will focus specifically on:
(1) techniques used to minimize VAT and income tax from service fees, including the
recharacterization of such service fees as cost reimbursements, (2) new e-commerce tax
issues that have arisen through the increase in cross-border services (including financial
services) rendered via the Internet, and (3) the tax distinction between pure services,
technical services, and the transfer of intellectual property (including know-how).
Co-Chairs
Luciana Rosanova Galhardo, Pinheiro Neto Advogados, São Paulo, Brazil
Richard L. Winston, K&L Gates LLP, Miami, FL, USA
Speakers
Joan C. Arnold, Pepper Hamilton LLP, Philadelphia, PA, USA
Paulo Marcelo de Oliveira Bento, Barbosa, Müssnich & Aragão Advogados, São Paulo,
Brazil
Devon M. Bodoh, KPMG LLP, Washington, DC, USA
Mauricio Ambrosi Herrera, Turanzas, Bravo & Ambrosi, S.C., Mexico City, Mexico
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6th Annual U.S. - Latin America Tax Planning Strategies

THURSDAY, JUNE 13
11:00 a.m. – 12:30 p.m. Concurrent Session B
Tax Issues Facing Mining, Oil, Natural Gas, and Other Natural Resource
Companies
This panel will discuss industry-specific issues facing mining, oil, natural gas, and other
natural resource companies.
Co-Chairs
Luiz Felipe Centeno Ferraz, Mattos Filho, Veiga Filho, Marrey Jr. e Quiroga Advogados,
São Paulo, Brazil
Alex Fischer, Carey y Cia., Santiago, Chile
Speakers
Fernando Camarena, Gardere Arena y Asociados, Mexico City, Mexico
Juan Carlos Garanton, Torres Plaz & Araujo, Caracas, Venezuela
Gustavo Lazo, Estudio Olaechea, Lima, Peru
Michael Silva, DLA Piper LLP, Miami, FL, USA
12:30 p.m. – 2:00 p.m. networking Luncheon
2:00 p.m. – 3:30 p.m. Concurrent Session A
Current Issues Affecting Customs Compliance in the Americas: Strategies
for Facilitating Customs Clearance While Minimizing Customs Duties,
Taxes and Fees
This panel will discuss recent trends in customs administration in the Americas, including
practical strategies for minimizing administrative hurdles at the border, key customs
considerations in developing and managing supply chains, the interaction between
customs value and tax transfer pricing requirements, and increased scrutiny of customs
country of origin issues.
Co-Chairs
Henrique Lopes, Koury Lopes Advogados, São Paulo, Brazil
David R. Grace, Covington & Burling LLP, Washington, DC, USA
Speakers
Carmilo Cortés, Cardenas & Cardenas, Bogotá, Colombia
Christian Natera, Natera, Mexico City, Mexico
Marcio Calvet Neves, Veirano Advogados, Rio de Janeiro, Brazil
Juan Pablo Rothschild, Marval O’Farrell & Mairal, Buenos Aires, Argentina
http://meetings.abanet.org/meeting/tax/MIAMI13 9

THURSDAY, JUNE 13
2:00 p.m. – 3:30 p.m. Concurrent Session B
Outbound Investment from Latin America
This panel will discuss the tax considerations and opportunities for Latin American
corporations as they expand their business operations outside of their home countries.
Topics to be addressed will include deferral versus current income inclusion, the use of
holding entities and the employment of trading structures to efficiently accommodate
business growth.
Co-Chairs
Jose Leiman, PricewaterhouseCoopers LLP, Miami, FL, USA
Leandro M. Passarella, Passarella Abogados, Buenos Aires, Argentina
Speakers
Maria Teresa Cremaschi, Barros y Errazuriz Abogados, Santiago, Chile
Juan Guillermo Becerra, Posse, Herrera & Ruiz Abogados, Bogotá, Colombia
Marcos Vinicius Neder de Lima, Trench, Rossi e Watanabe (Baker & McKenzie), São Paulo,
Brazil
Michiel van Kempen, Loyens & Loeff, New York, NY, USA
3:30 p.m. – 4:00 p.m. networking Break
4:00 p.m. – 5:30 p.m. Plenary Session
Tax Executive Perspectives: Issues Facing Tax Executives and Their
Advisors in the Context of International Tax Developments
This panel will discuss changes in legislation (including tax reform in the United States),
increased government effort on audits, transparency and information exchange, financial
and other disclosures, budget pressures, and effective global tax rate planning.
Co-Chairs
Maria Fernanda Campos, Ford Motor Company, São Paulo, Brazil
Stuart Chessman, Vivendi S.A., New York, NY, USA
Speakers
Sergio Abrajan Sevilla, Telefonica, Mexico City, Mexico
Seth Entin, Greenberg Traurig LLP, Miami, FL, USA
Florencia Lucila Misrahi, Cargill S.A.C.I., Buenos Aires, Argentina
Lionel Nobre, Dell Computadores do Brasil Ltda., Rio Grande do Sul, Brazil
6:00 p.m. – 7:30 p.m. Mandarin Oriental Beach
Networking Cocktail Reception (inclement weather location: Salon 1)
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6th Annual U.S. - Latin America Tax Planning Strategies

FRIDAY, JUNE 14
8:00 a.m. – 4:15 p.m. registration of Delegates
8:00 a.m. – 8:45 a.m. Continental Breakfast
8:45 a.m. – 9:00 a.m. Opening Remarks
9:00 a.m. – 10:30 a.m. Plenary Session
Trends in Interpretation and Application of Double Taxation Treaties in
Latin America and Their Impact on Planning
This panel will address current trends in the interpretation and application of double
taxation treaties in Latin America and consider the implications of these developments for
planning efforts. The panel will also provide an update on treaty negotiations and recent
changes to exchange of information regimes.
Co-Chairs
Emin Toro, Covington & Burling LLP, Washington, DC, USA
Sonia Velasco Menal, Cuatrecasas, Gonçalves Pereira, Barcelona, Spain
Speakers
Roberto Duque Estrada, Xavier Bragança Advogados, Rio de Janeiro, Brazil
Rosario Huet, Goodrich Riquelme y Asociados, Mexico City, Mexico
Summer Ayers LePree, Holland & Knight LLP, Miami, FL, USA
Adrián Rodríguez, Lewin & Wills Attorneys at Law, Bogotá, Colombia
Jorge R. Postiglione, Brons & Salas Abogados, Buenos Aires, Argentina
10:30 a.m. – 11:00 a.m.
Networking Break
11:00 a.m. – 12:30 p.m. Concurrent Session A
Judges Roundtable: Recent Case Law on Beneficial Ownership
Tax Administrations tend to apply a broad interpretation of the concept of “beneficial
ownership,” which results in restrictions to the application of tax treaties to avoid
double taxation. This panel will discuss the concept of “beneficial ownership” to crossborder
payments of services, royalties and dividends. Recent cases will be discussed by
members of courts of different countries in order to compare different approaches and to
try to reach a common interpretation of the “beneficial ownership” concept.
Co-Chairs
João Francisco Bianco, Mariz de Oliveira e Siqueira Campos Advogados, São Paulo, Brazil
Alejandro Torres, Chevez, Ruiz, Zamarripa y Cia., S.C., Mexico City, Mexico
Speakers
Gustavo Lian Haddad, Lefossse Advogados, São Paulo, Brazil
Zulema Mosri Gutiérrez, Federal Court of Fiscal and Administrative Justice, Mexico City,
Mexico
Eugene P. Rossiter, Associate Chief Justice, Tax Court of Canada, President, IATJ,
Ottawa, ON, Canada
Erwin Ivan Romero Morales, Administrative and Tax Court, Guatemala, Guatemala
http://meetings.abanet.org/meeting/tax/MIAMI13 11

FRIDAY, JUNE 14
11:00 a.m. – 12:30 p.m. Concurrent Session B
Transfer Pricing: Audit and Litigation Developments
This panel will discuss recent transfer pricing controversy developments, including
recent audit and litigation trends, with a focus on developments affecting Brazil, Chile,
Argentina, Mexico, and the United States.
Co-Chairs
Mark Martin, McDermott Will & Emery, Houston, TX, USA
Ricardo León Santacruz, Sánchez DeVanny Esseverri, S.C., Garza García, Mexicoa
Speakers
Manuel Sainz, Chevez, Ruiz, Zamarripa y Cia., S.C., Mexico City, Mexico
Ana Cláudia Akie Utumi, TozziniFreire Advogados, São Paulo, Brazil
Mario Gorziglia, Prieto y Cía. Abogados, Santiago, Chile
Cristian E. Rosso-Alba, Rosso Alba, Francia & Asociados, Buenos Aires, Argentina
12:30 p.m. – 2:00 p.m.
Luncheon and Keynote Speaker
Speaker
Patricia A. Brown, Director, Graduate Program in Taxation, University of Miami School of
Law, Miami, FL, USA
2:00 p.m. – 3:30 p.m. Plenary Session
Government Roundtable
Tax administrators and policy makers will address issues, recent developments, and
legislative proposals in international taxation, including recent shifts to territorial systems,
transfer pricing, foreign tax credit limitations, controlled foreign corporation and other
anti-deferral regimes, information exchange, withholding taxes, transparency, and joint
audits of global businesses.
Co-Chairs
Sam Kaywood, Alston & Bird LLP, Atlanta, GA, USA
Raquel Novais, Machado Meyer Sendacz & Opice Advogados, São Paulo, Brazil
Elinore J. Richardson, Institute for International Taxation, Toronto, ON, Canada
Speakers
Zulema Mosri Gutiérrez, Federal Tribunal of Fiscal and Administrative Justice, Mexico
City, Mexico
Additional speakers to be announced.
3:30 p.m.
Conference Closes
12
6th Annual U.S. - Latin America Tax Planning Strategies

6TH ANNUAL
U.S. - LATIN AMERICA
TAX PLANNING STRATEGIES
JUNE 13-14, 2013 • MIAMI
REGISTRATION FORM
WEALTH AND ASSET PLANNING WORKSHOP • JUNE 12
TAX EXECUTIVES WORKSHOP JUNE • 12
Register online with your credit card at http://meetings.abanet.org/meeting/tax/MIAMI13/
Please Complete ALL Fields
Last Name (Surname):
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Business Address:
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E-mail*:
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*Confirmation will be sent by email.
ADVANCE - On or before May 17, 2013 Advance w/
Workshop
Advance w/o
Workshop
Workshop
Only
ABA, IFA, IBA, TEI, or Past Conference Attendee $695 $595 $195
Non-Member $795 $695 $295
Young Lawyer (under 35 years) $495 $395 $195
Government/Academic/Nonprofit $495 $395 $195
Full Time Law Student FREE FREE FREE
REGULAR - After May 17, 2013 Regular w/
Workshop
Regular w/o
Workshop
Workshop
Only
ABA, IFA, IBA, TEI, or Past Conference Attendee $795 $695 $195
Non-Member $895 $795 $295
Young Lawyer (under 35 years) $595 $495 $195
Government/Academic/Nonprofit $595 $495 $195
Full Time Law Student FREE FREE FREE
TOTAL (USD)
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http://meetings.abanet.org/meeting/tax/MIAMI13

CONFERENCE SESSIONS
PROGRAM
Please indicate below which sessions and events you plan to attend.
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Wealth Management Workshop
Wednesday, June 12, 2013
1:30 p.m. – 3:00 p.m. Investment Incentives in the United
States, Canada, Spain, and Brazil: Immigration and Tax Issues
3:30 p.m. – 5:30 p.m. Private Client Legislative Updates:
United States, Argentina, Colombia, Venezuela and Guatemala
Tax Executives Workshop
Wednesday, June 12, 2013
1:30 p.m. – 3:00 p.m. Managing your Tax Compliance in Latin
America – Systems, Process, and People
3:30 p.m. – 4:30 p.m. How a Tax Department Can Add Value
to Your Business in Latin America – Tax Enablement and Tax
Planning
4:30 p.m. – 5:30 p.m. How to Clearly and Concisely Report
Issues to Headquarters: FAS 5, FIN 48, ASC 740, etc.
Conference Program
Thursday, June 13, 2013
PLENARY SESSION, 9:00 a.m. – 10:30 a.m.
Mergers and Acquisitions and Capital Markets Update
CONCURRENT SESSIONS, 11:00 a.m. – 12:30 p.m. (please
select one)
Tax Treatment of Cross-Border Services
Tax Issues Facing Mining, Oil, Natural Gas, and Other Natural
Resource Companies
NETWORKING LUNCH, 12:30 p.m. – 2:00 p.m.
CONCURRENT SESSIONS, 2:00 p.m. – 3:30 p.m. (please
select one)
Current Issues Affecting Customs Compliance in the Americas:
Strategies for Facilitating Customs Clearance While Minimizing
Customs Duties, Taxes and Fees
Outbound Investment from Latin America
PLENARY SESSION, 4:00 p.m. – 5:30 p.m.
Tax Executive Perspectives: Issues Facing Tax Executives and
Their Advisors in the Context of International Tax Developments
COCKTAIL RECEPTION, 6:00 p.m. – 7:30 p.m.
Conference Program
Friday, June 14, 2013
PLENARY SESSION, 9:00 a.m. – 10:30 a.m.
Trends in Interpretation and Application of Double Taxation
Treaties in Latin America and Their Impact on Planning
CONCURRENT SESSIONS, 11:00 a.m. – 12:30 p.m. (please
select one)
Judges Roundtable: Recent Case Law on Beneficial Ownership
Transfer Pricing: Audit and Litigation Developments
KEYNOTE LUNCH, 12:30 p.m. – 2:00 p.m.
PLENARY SESSION, 2:00 p.m. – 3:30 p.m.
Government Roundtable
Payment Information
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Registration fee (from page one) $
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Taxation.
(Please include a copy of this form with your mailed check.)
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to my credit card:
American Express VISA MasterCard
Credit Card number:
Expiration Date:
Signature:
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CC Verification Code:
Billing Address for Credit Card is the same as the Business
Address on this form.
Billing Address:
Pay by bank wire transfer. Bank wire details are as follows:
Bank Name: JP Morgan Chase Bank NA
Bank Address: 2218 Fifth Ave., New York, NY 10037, USA
Routing Number: 021000021
Swift Code: CHASUS33
Account Name: American Bar Association
Account Number: 50-03997
RETURN TO:
MAIL: ABA Section of Taxation, Attn: Meetings Registrar, 740 15th
Street, NW, Washington, DC 20005, USA
FAX: +1.202.662.8682 EMAIL: tim.brady@americanbar.org
6th Annual U.S. - Latin America Tax Planning Strategies

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