In recent years, tax authorities worldwide have been increasingly scrutinizing cross-border transactions by private equity funds (“PEFs”) and multinational corporations (“MNCs”). Given the governments’ need to replenish their coffers depleted by the pandemic, these tax audits will very likely increase—and become more sophisticated—in the years to come. Consequently, PEFs and MNCs must plan well in advance, assessing their existing structures for acquisitions and holdings of foreign assets and anticipating the tax audit challenges at exit. Anticipating the local country tax controversy and knowing what venues of relief are available in the residency jurisdiction (e.g., the US for US MNCs) will increase your chances of successfully resolving the tax controversy.
Join us for Part 2 of our two-part series on the exit-related taxation of inbound investments in Asia, the European Union and Brazil. In this webinar, we will discuss:
- Technical and practical tax considerations in the initial acquisition structuring in these regions
- Exit strategies and post-exit tax controversy in these regions
- As an alternative fund structure (to the traditional Cayman offshore fund), onshore fund structures in Singapore and Hong Kong and the benefits and other considerations related to these options
- The venues for foreign tax dispute resolution and double tax relief available in the US for US MNCs and PEFs with US investors
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