2014 TEI US Tax Conference
26 to 27 February 2014 | Singapore
Dates:
26 to 27 February 2014
Venue:
York Hotel Singapore
Carlton Hall, Level 2
21 Mount Elizabeth
Singapore 228516
The Tax Executives Institute (TEI) and the Tax Academy of Singapore
(TAS) are pleased to jointly present the TEI US Tax Conference in
Singapore on 26 and 27 February 2014.
This 2-day event will feature leading US tax experts from Deloitte &
Touche, PricewaterhouseCoopers and Ernst & Young, who will step
participants through the overview and discuss key features of the US
tax system and its recent developments. It is a unique conference not
to be missed!
Fees:
Discussion topics will include:
TEI members:
SGD560 / USD440
Non-TEI members:
SGD760 / USD600
Above fees exclude 7% GST.
Local participants need to pay
above fees plus 7% GST.
Closing date for registration:
17 February 2014
Join TEI as a member before
the event to enjoy the TEI
member’s rate !
To register and become a TEI
member, please visit TEI
website at :
www.tei.org/membership/pag
es/default.aspx
Tax Academy and Tax
Executives Institute
reserve the right to cancel
the event, or make changes
to the schedule, venue and
speakers.
For enquiries, please contact:
Jocelyn Chong
DID: (65) 6351 3040
Amuna
DID: (65) 6351 3023
Email:
seminars@taxacademy.sg
Overview of the US tax system
• types of entities/taxpayers
• entity classification/Check the box principles
• consolidation, territorial vs. worldwide taxation
• general US tax filing requirements for foreign affiliates, loss utilization
US outbound - Controlled foreign corporations, Subpart F, E&P, PFIC,
and FTC
• issues around Asia and credit for underlying income tax, Indirect
Transfers
• Section 987 and 988 (FX gain/losses)
Sourcing rules, Section 367 transfers (including GRA), Section 1248
dividend, Section 304
Transfer pricing
• TP principles and issues (sec. 482)
• cost sharing and services regulations
• APA across Asia
Anti-abuse principles
• legal and statutory (including codification of economic substance)
• context in US tax treaties
• US tax treaty update
Tax Technical Update on main US tax issues
• proposed US international tax changes/ reform
• FATCA Updates
Current non-US international tax developments
• OECD developments on BEPS, beneficial ownership
• Permanent Establishment, intangibles, AP country developments in
India, China, top cases in 2013
• substance in planning and why you need it
• in-depth discussion on the practical application and the experience of
in-house tax staff
PROGRAMME | 26 & 27 February 2014
26 February 2014
27 February 2014
9.00am:
9.00am:
9.15am:
President's Address/Introduction
Overview of the US tax system
• types of entities/taxpayers
• entity classification/Check the box
principles
• consolidation, territorial vs. worldwide
taxation
• general US tax filing requirements for
foreign affiliates, loss utilization
Transfer pricing - TP principles and issues
(section 482), cost sharing and services
regulations and APA across Asia
By Ernst & Young
10.30am:
Coffee break
10.45am:
By PricewaterhouseCoopers
Anti-abuse principles
• legal and statutory including codification
of economic substance
• context in US tax treaties
10.30am:
Coffee break
US tax treaty update
10.45am:
Overview of the US tax system (cont.)
By Ernst & Young
By PricewaterhouseCoopers
12.00pm:
Lunch
12.00pm:
Lunch
1.30pm:
1.30pm:
US outbound - Controlled foreign
corporations, Subpart F, E&P, PFIC, and FTC
• issues around Asia and credit for
underlying income tax, Indirect Transfers
• Section 987 and 988 (FX gain/losses)
Panel discussion on
Tax Technical Update on main US tax
issues
• proposed US international tax changes/
reform
By PricewaterhouseCoopers, Deloitte, Ernst
& Young, TEI Board member
By Deloitte
Panel discussion on FATCA updates
3.30pm:
Coffee break
3.45pm:
Sourcing rules, Section 367 transfers
(including GRA), Section 1248 dividend,
Section 304
3.00pm:
Coffee break
By Deloitte
3.15pm:
Current non-US international tax
developments
• OECD developments on BEPS, beneficial
ownership, Permanent Establishment
• intangibles, AP country developments in
India, China
• top cases in 2013 including substance in
planning and why you need it
• practical application and the experience of
in-house tax staff
5.30pm:
By PricewaterhouseCoopers, Ernst &
Young, TEI Board member
End of day 1
By Deloitte, PricewaterhouseCoopers,
Ernst & Young, TEI Board member
5.30pm:
End of day 2
About the Speakers
John S. MacArthur
International Tax Services - Asia Pacific Financial Services Leader – Hong Kong
Ernst & Young
John currently is one of the leaders of EY’s Global Private Equity Tax Committee. The committee addresses
emerging international tax issues that impact the private equity and global venture capital industries. He joined
EY’s Asia Pacific Financial Services Office in 2011 and is based in Hong Kong. John is a Principal with over 25
years of practice experience in serving global financial service clients. John’s focus is on cross border M&A
planning, global fund structuring, taxation of cross border financing transactions, derivatives and hedging
transactions, repatriation planning, FIN48 analysis for global financial service entities, tax efficient use of
treasury and risk management entities including captive insurance companies, acquisition planning for real
estate investments in Asia.
Prior to moving to Hong Kong, John practiced in National Tax Department in Washington, D.C. and in EY’s ITS
Capital Markets and Financial Services groups in New York (1989-2000). He also led EY’s International Tax
Services (ITS) and Financial Services Tax Practice (2002-2011) in the Western portion of the U.S. and was based
in San Francisco, California. John left the firm and served as the lead tax lawyer for Morgan Stanley’s Global
Structured Products Group in New York (2000-2002), where he and his team were responsible for structuring
cross border investment and financing transactions for the firm and its clients worldwide.
John is a frequent speaker at conferences, such as the Alliance for Tax, Legal and Accounting Seminars (ATLAS),
Private Equity International (PEI), and the Tax Executive Institute (TEI), and has authored articles in the Journal
of International Taxation and other publications. John received a B.A., cum laude, in Economics , with
Distinction, from St. Olaf College, Northfield, Minnesota ; and a J.D., from William Mitchell College of Law, St.
Paul , Minnesota , where he served as the Editor-in-Chief of the William Mitchell Law Review.
David M. Allgaier
Executive Director, US Tax Desk, Global Tax Desk Network, Asia Pacific
Ernst & Young
David is a part of Ernst & Young’s Global Tax Desk network in Asia Pacific, advising multinational clients across a
variety of industries throughout Asia Pacific on US tax related matters. David’s focus is advising on US tax
matters related to holding company structuring, profit repatriation, withholding tax planning, supply chain
management, tax-efficient financing alternatives, and merger & acquisition transactions.
Currently based in Shanghai since 2008, David has over 15 years of client-serving experience, including more
than 13 years serving clients in Europe and Asia Pacific on matters related to US federal income tax inbound and
outbound planning and structuring. Prior to joining Ernst & Young in Shanghai, David spent over six years as part
of the US Tax Desk in London and over two years as part of the US Tax Desk in Dublin.
Prior to working in Europe, David was part of the International Tax Services group of Ernst & Young in
Washington, DC. David also successfully completed an internship with Ernst & Young in Irvine, California prior to
joining Ernst & Young on a full-time basis.
David is a US Certified Public Accountant (licensed in the state of Maryland), and Member of the American
Chamber of Commerce (Shanghai) Tax Committee. He is a frequent presenter on US taxation at various
conferences and seminars throughout Asia Pacific.
About the Speakers
Andy Baik
Partner, International Tax Services
PricewaterhouseCoopers
Andy is a partner in the US firm of PricewaterhouseCoopers. He is currently on a long term assignment in
Singapore and is a partner in the International Tax Services group at PwC Singapore. He has spent the last 9
years in Singapore and Korea , working on inbound into Asia and outbound from Asia transactions.
Andy heads up the firm’s global Sovereign Wealth Fund Tax group in the Asia Pacific region. He is also centrally
involved in assisting many US and other MNCs on pan-Asian tax matters.
Andy’s extensive cross-border tax background includes both US and Asian tax systems. Andy’s practice
concentrates on the income tax aspects of inbound investment tax structuring for financing, M&A and local joint
ventures in the Asia Pacific region. He regularly advises multinational corporations on comprehensive tax
strategies and planning for investments into Asia and for U.S. inbound investments from the region.
Andy has also worked extensively with real estate and private equity funds on tax structuring aspects of
inbound-into-Asia transactions. He has worked with large sovereign wealth fund, real estate, and private equity
clients on fund and deal structuring of Asia target transactions, including transactions in Korea, China, India,
Singapore, Thailand, Indonesia, Vietnam, Philippines, Malaysia and Japan.
Andy is a frequent author on international tax subjects and has written articles on topics such as the U.S. checkthe-box regulations, passive foreign investment companies, tax risk management in Asia and tax planning in
Asia. Andy speaks regularly at seminars dealing with cross-border transactions. Since 2008, he has been a
regular lecturer on various international tax planning courses run by the Tax Academy of Singapore. Andy has a
law degree (Juris Doctor) from Georgetown University Law Center. He holds a New York State Bar attorney
license.
Ivan Strunin
Managing Director – US Tax Services
Asia Pacific International Core of Excellence (AP ICE)
Prior to joining the Deloitte AP ICE team, Ivan Strunin has advised businesses on both US domestic and
international taxation issues for the past 24 years. For the past 14 years his practice has focused exclusively on
matters of cross-border taxation, both inbound and outbound. Focusing mainly on businesses with operations in
the Carolinas, his clients have included financial services, textiles, manufacturing and high tech businesses.
As a director in Deloitte's Carolians International Tax Practice. Ivan was responsible for delivering Deloitte’s
international tax services to his clients in the Carolinas. He has been a local resource on tax-efficient supply
chain planning.
Prior to joining Deloitte, Mr. Strunin spent the majority of his career at Arthur Andersen both in Chicago and
Charlotte. Mr. Strunin has spoken frequently on topics of international taxation and has been a regular
contributor to, and has served on the editorial board of Corporate Business Taxation Monthly and, Mergers and
Acquisitions. Mr. Strunin has also served as regional vice president for the International Fiscal Association
Mr. Strunin has a BA from the Johns Hopkins University. He also has a JD from Chicago-Kent College of Law and
an MBA from the Stuart School of Business.
About the Speakers
Robert Lider
Executive Director and Regional Tax Counsel
JPMorgan Chase
Robert has been a U.S. Regional Tax Counsel in Asia for the past 18 years. Currently he is an Executive Director
and Regional Tax Counsel at JPMorgan Chase, based in Singapore, where he has coverage responsibilities for the
Treasury and Securities Services Product Groups. Formerly he was a Vice- President and Regional Tax Counsel
for Citibank in Asia. He is also an Adjunct Professor at Singapore Institute of Management (SIM University)
where he teaches international tax courses in the Graduate Tax Program. He has published numerous articles
on international tax matters and is currently serving as the Asia TEI Chapter’s Committee Chair and
Representative on the TEI International Board of Directors. He has served as Chairman of the NFTC Tax Treaty
Sub-Committee and member of the Hong Kong Association of Banks Tax Sub-Committee. Robert is currently a
member of Hong Kong’s Capital Markets Tax Committee. He is a frequent panellist on International Tax Review
and TEI sponsored tax programs.
Bill Husthwaite
Regional Tax Manager AsiaPacific
Shell Eastern Petroleum (Pte) Limited
Bill trained in the UK as a Chartered Accountant and Chartered Tax Adviser with Deloitte Haskins and Sells – this
is when there was a Big 8, which dates him a bit. He has almost 28 years tax experience in the oil and gas
industry. He spent 12 years with Exxon, mainly in the UK North Sea but with some time in Houston, covering a
full range of compliance and advisory activities in the upstream and downstream parts of the business. He has
spent the last 16 years with Shell, starting initially in the UK but followed by Regional Tax Manager roles in
Africa, Europe and AsiaPacific. During this time he has developed wide experience and skills in building and
leading tax teams through significant organisational and business change. He has been based in Singapore for
the last 5 years.
Michael Velten
Tax Partner – Business Tax
Southeast Asia FSI Tax Leader, Deloitte & Touche LLP, Singapore
Michael Velten is a Financial Services Tax Partner with Deloitte in Singapore and the firm’s SEA FSI Tax Leader.
Michael covers all area of Singapore tax (including GST and stamp duty) and specialises in Asia banking and
capital markets. Michael’s focus includes financial services transfer pricing and FATCA. Michael is a recognised
industry tax expert.
Michael has been advising on Singapore and Asia regional tax since the early 1990s, having held senior tax roles
in Asia with leading financial institutions and professional firms. Michael’s experience in Asia includes an 18
month secondment to Malaysia (1992 – 1993) under an Australian Government Fellowship program. As part of
the program Michael studied Bahasa Malaysia for 6 months.
Prior to joining Deloitte, Michael was Group Head of Tax at a leading brokerage and investment house and
before that he headed the Asia ex-Japan Tax Department of a leading global investment bank. He was also a Tax
Partner in a Big Four firm in Singapore and a Tax Partner in the Singapore office of a leading international law
firm. Michael has held appointments as an Adjunct Associate Professor of Law at the National University of
Singapore and Visiting Fellow to the University of Melbourne. Michael commenced his career in tax practice in
Melbourne and was a senior associate with a leading Australian law firm.
Michael holds Bachelor of Commerce, Bachelor of Laws and Master of Taxation degrees from the University of
Melbourne. He holds a Master of Laws degree from the National University of Singapore and a Master of
Business Administration degree from the University of New England. Michael is qualified as both a Solicitor and
CPA. He is an Accredited Tax Advisor: Income tax and GST (Singapore), a Certified Tax Adviser (Hong Kong) and
an Associate of the Chartered Tax of Malaysian Taxation.
About the Speakers
Chai Sui Fun
Partner, Global Structuring – Transfer Pricing
PricewaterhouseCoopers
Sui Fun is a partner with the Global Structuring unit of PricewaterhouseCoopers Services LLP (“PwC Singapore”),
with key focus in Transfer Pricing and Dispute Resolution matters. She joined PwC as a partner in July 2013. Sui
Fun has more than 25 years of tax experience. Prior to joining PwC, she was the Assistant Commissioner for Tax
Policy & International Tax Division of the Inland Revenue Authority of Singapore (“IRAS”). In this capacity, she
played an instrumental role in the formulation and implementation of tax polices in Singapore. She also served
as a Competent Authority of Singapore, representing the Singapore Government in tax treaty negotiations and
other international tax matters and in negotiation and implementation of bilateral/multilateral agreements and
Advance Pricing Arrangements (“APAs”). Before returning to IRAS, Sui Fun was the Global Tax Director of
Lenovo Group.
In her previous capacity as Competent Authority of Singapore, Sui Fun had established a strong track record in
resolving APAs and double taxation issues that arose from cross-border transactions for many MNC groups
through the mutual agreement procedure process. She is well recognised by MNC groups as pragmatic and
effective in facilitating cross-border dispute resolution. Since returning to IRAS from industry in November
2007, Sui Fun had led and successfully resolved more than 40 bilateral/multilateral APAs and double taxation
cases which helped provide significant tax certainty or relief from double taxation for the MNC groups
concerned. These include bilateral APAs and double taxation cases between Singapore and Japan, Australia,
China, United Kingdom and several other jurisdictions. Since joining PwC, Sui Fun has been working with and
advised several MNC groups to address their transfer pricing and related issues/ disputes arising from
international transactions. Sui Fun is a member of the Association of Chartered Certified Accountants (FCCA)
and has a Master in Public Administration/International Tax Program, Harvard University and a Bachelor of
Accountancy (Hons), National University of Singapore.
David Weisner
US Tax Counsel for Asia Pacific, Citigroup
David Weisner is based in Hong Kong and is US Tax Counsel for Asia Pacific for Citigroup. He is the technical
advisor for Citi’s FATCA implementation project and handles the tax issues for Citi’s Consumer, Private Bank,
Treasury and Trade Solutions (TTS) and Securities and Funds Services (SFS) businesses throughout Asia Pacific.
Prior to joining Citigroup in 2003, David worked at Fidelity Investments in Boston as international tax counsel.
Prior to Fidelity Investments, David worked for White & Case, a New York based law firm, and Deloitte &
Touche. He is a graduate of Washington University, St. Louis. He is a member of the Illinois Bar.
David is Chair of the tax committee of the American Chamber of Commerce in Hong Kong, Vice Chairman of the
Capital Market Tax Committee (CMTC), on the executive committee of the Asia Chapter of the Tax Executive
Institute (TEI) (and its former President), on the tax committee for the Hong Kong chapter of Alternative
Investment Management Association (AIMA) and leads the FATCA subcommittee for the Hong Kong Association
of Banks (HKAB).
Vineet Rachh
Senior Director and Head of Tax for Jabil Circuit (Singapore) Pte Ltd
Vineet Rachh is a Senior Director and Head of Tax for Jabil Circuit (Singapore) Pte Ltd, based in Singapore. He
leads Jabil’s Global Business Centre’s Tax and Transfer Pricing matters. His role entails developing and
implementing global supply chain solutions, and handling cross border tax and M&A matters. He also manages
tax compliance, audits and controversies.
In his 20 year career, he has had the opportunity to work with most tax authorities in the Asia Pac Region on
various subjects including APAs, MAPs and Audits. He was also the industry representative at OECD’s Tax Force
on Tax and Developments Sub-Group on Transfer Pricing in 2011.
Prior to joining Jabil, he has worked with other US MNCs and before that with the Big 4 Accounting firms. He is a
Member of the Institute of Chartered Accountants of India and a Graduate of the Institute of Cost and Works
Accountants of India. He is also a member of several Tax network groups and a regular speaker at tax
conferences and events.
REGISTRATION FORM
Two easy ways to register
 Email: seminars@taxacademy.sg
 Fax: (65) 6 2531214
Venue:
York Hotel Singapore
Carlton Hall, Level 2
21 Mount Elizabeth, Singapore 228516
1 - Provide your details
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number (if any):
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REGISTRATION FORM
2 – Payment options
 I enclose a cheque of SGD ______ / USD ______ made payable to Tax Academy of Singapore.
Cheques should be crossed and made payable to “Tax Academy of Singapore” indicating the seminar title at
the back of the cheque. Please send the registration form with your cheque to the following address:
Attn: Ms Faridah Omar - Tax Academy of Singapore, #B1-01, 55 Newton Road, Revenue House, Singapore
(307987)
 Telegraphic Transfers
Information concerning telegraphic transfers :
a) Bank number: 7375 / Branch number: 016 / Account number: 339-301-770-6 / Swift Code: UOVBSGSG
b) Applicant will bear all local and overseas bank charges for telegraphic transfers
c) A copy of the remittance advice to be faxed to (65) 6253 1214 or emailed to jocelyn@taxacademy.sg
 Please send me a receipt.
Other information
1. Registration and payment
Registrations for events are on a first-come-first-served basis.
Foreign participants, who in their business capacity belong overseas and sponsored by overseas employers,
are excluded from paying 7% GST.
2. Cancellation/Substitution policy
There will be no refund for cancellation. Substitute is welcome and must be submitted in writing with
personal details.
3. Others
CPD/CPE credit is only awarded to delegates who have signed for and attended the event.
4. Disclaimer
Tax Academy of Singapore and Tax Executive Institute reserve the right to cancel the event, or make
changes to the schedule, venue and speakers.