Tax planning for U.S. inbound of investment was the focus of the 13th Annual NYU/KPMG Lectures on Current Issues in Taxation, held at NYU Law on April 18.
The day commenced with a primer on U.S. taxation of portfolio investment and business income by foreign persons from Richard Anderson of WilmerHale. Next, H. David Rosenbloom, James S. Eustice Visiting Professor of Taxation, discussed U.S. treaty benefits and developments.
Watch video of the first two lectures (1 hr, 51 min):
Next, Sean Foley and Thomas Zollo of KPMG joined Carlo Garbarino, Global Visiting Professor of Law at NYU Law, for a panel discussion on "Attribution of Profit to a Permanent Establishment—the Authorized OECD Approach." Following this discussion, International Tax Counsel Danielle Rolfes of the U.S. Department of the Treasury's Office of Tax Policy gave the day's keynote speech on U.S. domestic treaty overrides. The discussion of this topic then continued with a debate panel featuring Willard Taylor, an adjunct professor at NYU Law; Professor H. David Rosenbloom; Daniel Shaviro, Wayne Perry Professor of Taxation; and Richard Andersen of WilmerHale.
Watch video of the above lectures and panel discussions (1 hr, 40 min):
The afternoon started off with a panel discussion on financing the U.S. corporate group from a U.S. foreign country perspective, featuring Fred Gander of KPMG London, Marko Gruendig of the KPMG German Tax Center, Kees van Meel of the KPMG Netherlands Tax Center, and Bastien Voisin of the KPMG Luxembourg Tax Center. After this discussion, Thomas Zollo and Patrick Jackman of KPMG gave a lecture on the foreign acquisition of a U.S. corporate group.
Watch video of the above discussion and lecture (1 hr, 53 min):
Peter Connors of Orrick, Herrington & Sutcliffe and Jeffrey Friedman of Sutherland Asbill & Brennan then took the stage to discuss federal and state taxation of U.S. branches of foreign corporations. Next, Ameek Ashok Ponda of Sullivan & Worcester joined Peter Genz of King & Spalding for a conversation on foreign investment in U.S. real property. Wrapping up the day, Patrick Fenn of Akin Gump Strauss Hauer & Feld gave a lecture entitled "Foreign government and sovereign wealth funds—U.S. inbound investment."
Watch video of the above lectures (2 hr, 40 min):
Posted on May 9, 2013