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Section Conference

23rd Annual U.S. and Europe Tax Practice Trends Conference

29-31 March 2023

Wednesday, 29 March 2023

“Tax Aftermath of the Crypto Winter: Exchange Collapses, Including FTX” – A View from the United States and Europe – Navigating Developing Tax Regulations in Various Jurisdictions

Dual Residency: Identifying and Solving Common Problems

Holding Family Assets: Common and Evolving Structures in Europe and the United States


Thursday, 30 March 2023

Opening Keynote Address

U.S. GILTI, Book Minimum Tax and Pillar 2 – How Will They Interact?

Managing Uncertainty In Transfer Pricing: Evolving Methods and Current State of APA Play

Is My Footprint Big Enough? Implementing ATAD 3 – Substance Requirements and Impact on Transatlantic Investment Structures

Purpose and Process: The Increasing Importance of Purpose and Substance in Tax Controversy, and Its Effect on Outcomes

Cracks in the Bricks: The Impact of Recent Treaty Developments on Real Estate Investment Structures

The Role of Competent Authority and Double Taxation Resulting from DSTs, Minimum Tax and Other Taxes

Private Equity Alternative Liquidity: Secondary Transactions, GP-Led, etc.


Friday, 31 March 2023

Government Panel

Is My Investment Fund a Bank? Lending Activities and PE/Trade or Business Issues

Hot Topics in Transatlantic M&A

What Is This Asset? Sourcing Issues With Digital Based Assets, Data Access, Cloud Software, and New Tech

Offramps: Managing Criminal Tax Investigations to Avoid Charges

Workers (and Executives) Without Borders – Traps for the Outwardly Mobile Taxpayer

The Future of Entity Choice: Endangered Hybrids and New Choices for IPOs