John A. Mclees
Partner, Baker & McKenzie

National tax rules and enforcement activities continue to be at the center of both the policy debates in Latin America and the preoccupations of companies doing business in the region. Whether a company is dealing with expansion or consolidation, whether it is analyzing new channels of distribution or new strategies to preserve tax losses, it is more important than ever to deal effectively with the tax issues in their Latin American operations. That reality is intensified by increasing scrutiny of restructuring transactions, the enactment of aggressive and unconventional tax rules, and the tax reform efforts being undertaken this year in several jurisdictions in the region.


This two-part conference will provide a unique opportunity to obtain both a comprehensive foundation in the operation of the tax systems in Latin America and answers to practical questions that companies typically face in such ventures – in two separate sessions, a one-day introduction and update followed by a two-day session on Tax Strategies for Latin American Operations. Both parts of the conference will pay particular attention to the growing importance of Brazil in regional tax planning.


The format of both parts of the conference is interactive. Over 3 days, this extraordinary two-part conference offers you a superior learning and networking experience designed to cover the most critical taxation issues affecting operations in the Latin American region, including:



• Tax issues that affect the structuring and financing of operations in Latin America
• Minimizing the tax burden on crossborder payments for services - regional service centers, multijurisdiction service contracts, staffing major projects
• Rationalizing the supply chain for manufacturing and distribution in Latin America
• Use of tax treaties and local holding company regimes in structuring Latin American operations to minimize global tax costs
• Practical tax issues for businesses in financial difficulties
• Dealing with tax losses, bad debts and forced dispositions
• Brazil’s thin cap and tax haven rules as a manifestation of regional trends
— Mexico’s Single Rate Tax - techniques for dealing with the complexity and mitigating the extra tax burden, taking into account recent amendments to the law
• Developments in the examination of economic substance as the basis for tax assessments in Brazil and other countries in the region
— Exploring pitfalls arising from Brazil’s unique transfer pricing rules
• Dealing effectively with national and regional trends and ongoing tax changes, including:
— Increasingly serious transfer pricing audits and documentation requirements
— Enhanced penalties, reporting requirements and other new rules designed to reduce tax evasion and increase collections
— New limits on interest deductions, including Brazil’s new thin capitalization rules
— Spread of bank transactions taxes in the region
— Developments in Brazil’s credit mechanisms and higher rates for PIS and COFINS
• Structuring Latin American and acquisitions and joint ventures
• And much more!