Dear Lucie,

                                      

I have just spent New Year's Eve at Dromoland Castle, 10 minutes from Shannon Airport (check it out, it's amazing!), so carrying on the holiday spirit, I want to wish you a very happy new year – I hope it is a successful, healthy and stress free year for you!  And while on the subject of Dromoland Castle, and before Lucie informs you of upcoming events in the first quarter of 2017, let me float an idea I have for a workshop at Dromoland Castle in the first week of October, and gauge your interest in attending a rather unique event for the IBSA.

   

The technical part would be a workshop on a topic which the European committee has not yet decided upon, but which could for example be Transfer Pricing – we may have a two tier workshop to include Brexit arrangements if these are any clearer by then.  That would be on Friday 6th October (date not yet finalised) followed by a gala dinner, with the next day an activity day with a choice of golf (on a fabulous golf course where Sonia and I played three times over the New Year's break – and in glorious sunshine, yes, it is in Ireland!), tennis, archery, clay-pigeon shooting, swimming, spa treatments etc – we will arrange everything with the hotel to ensure everyone can enjoy their own preference.   The package would include Thursday, Friday and (optional) Saturday nights and would be available to IBSA members and their partners.  At this stage, I would just like to hear from you whether you may be interested so that I can consider numbers and arrange the best possible package at the lowest price.

  

As we start 2017, we can reflect on a turbulent and unexpected series of events in 2016 and wonder how these are going to manifest themselves over this coming year. In particular of course, the Trump and Brexit phenomenons, but we can also wonder what will happen in Italy, France, Greece, Denmark, the Netherlands and Austria as regards their membership of the Eurozone and indeed even the European Union.  Will Brexit be the least of the worries the European Community faces in this coming year?

    

The IBSA’s membership comprises entrepreneurs themselves and their professional advisers, by nature a relatively optimistic crowd of individuals. Combining reality with optimism will be the theme of IBSA’s discussion group meetings, workshops and conferences throughout the year in all of our five branches, North America, UK, Continental Europe, Asia and the Middle East.  We will also be sending members’ articles to our database, and would encourage all of our members to submit interesting comments on structuring international businesses in the current climate.

   

We have a busy schedule of discussion group meetings and workshops over the next few months.  Please scroll down for details of each event and to register your attendance.

           

Kind regards and all the best for a great 2017,

                                  

                    

Roy Saunders

UK Branch Meeting - London

Corporate Incentives to Employees and Investors

19th January 2017, 18:00

Frank Hirth, London

Join Michael Lewis of Frank Hirth, Nigel Sloam of Nigel Sloam & Co, Robert Field of Farrer & Co and Mike Luckett of Shipleys who will be discussing employee incentive schemes including the EMI scheme and stock option arrangements, employee benefit trusts, disguised remuneration provisions and pension arrangements. The meeting will also discuss investor incentives including EIS and SEIS reliefs, Angel Investor reliefs and Business Investment Reliefs.  UK and potentially different US treatment of profits subject to income tax or capital gains tax will be considered along with valuation and reporting differences.

  

Networking drinks and canapes follow the discussion and offers the opportunity to meet fellow IBSA members and their guests.


European Branch Meeting - Cyprus

International Tax Planning in the Current Environment

26th January 2017, 17:30

Centre of Visual Arts & Research, Nicosia

The next IBSA Cyprus discussion group meeting with be held in conjunction with the TMF Group at the Centre of Visual Arts & Research in the charming old city of Nicosia on 26th January 2017 at 17:30. Join Roy Saunders, Founder and Chairman of IFS Consultants and IBSA, Sara Gunnervik from TMF Cyprus, Dmitry Zapol from IFS Consultants and Neofytos Neofytou from Taxatelier.

      

The meeting will discuss the implementation of the OECD’s BEPS initiatives in Cyprus, Luxembourg, Netherlands and Malta amongst other countries with reference to the implementation of so-called patent box regimes in these countries. We will also be discussing treaty access limitations in respect of the double tax treaties entered into by these countries, as well as the effect of the Common Reporting Standard on entrepreneurial clients and their requirement to disclose beneficial ownership of their holding companies.   

 

Networking drinks and canapes follow the discussion and offers the opportunity to meet fellow members and their guests.


Cyprus Workshop

Guiding the Development of SME Clients 

International Tax Issues in Practice through the Polycon Journey

27th January 2017, 09:00 - 13:00

Taxatelier, Nicosia

Join the IBSA Cyprus committee chaired by the Taxatelier international tax practice from 09.00 to 13.00 at their office in Nicosia at 5th Floor, 10 Delfon Street, Nicosia 1101, Cyprus for an IBSA workshop examining the international tax issues relevant to the expansion of the fictitious Polycon Lens Company as it morphs into the multinational Eyemax Corporation throughout its generational journey.  Roy Saunders, Chairman of the IBSA, and his IFS Consultants colleague Dmitry Zapol will explain these issues in the twelve stages of Polycon’s growth.

 

The Polycon journey was the basis of Roy’s leading international tax reference book for 30 years, International Tax Systems and Planning Techniques, as well as the MA course in international tax law at the University of London for the past 5 years.  The workshop will start with an explanation of an entrepreneur’s invention developed by the manufacturing entity, the company's overseas expansion with warehousing facilities, representative offices and then sales subsidiaries, corporate acquisitions made to expand the global reach of the company followed by an IPO as the company’s financial requirements dictate for its future growth.  The appropriate holding company regimes, along with financing and licensing techniques will be examined along with investment vehicles for real estate and other fringe activities, with the final stage being the creation of a private equity fund under the newly branded Eyemax umbrella.

 

The workshop will carry a fee of €300 but will be free to existing IBSA members, with the fee being waived for those participants who join the Association prior to the workshop, on the day, or refunded within one month if they join the IBSA subsequent to the workshop taking place.

  

The workshop will be followed by drinks and canapés kindly provided by the partners of Taxatelier.  



North American

Branch Meeting - New York

US Tax Outlook in a Trump World

7th February 2017, 09:30 

WithumSmith+Brown, New York

The next US discussion group meeting will be held at the offices of WithumSmith+Brown, 1411 Broadway, 9th Floor, NY 10018 in New York at 09:30 am on Tuesday 7th February 201.  


Join Scott Davis of WithumSmith+Brown and Robert Kiggins of Culhane Meadows on a meeting on how the legislative process in the US may deal with President Trump’s ideas of lower corporate taxes and the likely effectiveness of his repatriation proposal, plus current discussions on s385 issues and corporate inversions. The meeting will be a prelude to a larger combined US/UK event to be held mid-March on the implementation in each country of the BEPS proposals of the OECD and its recommendations for a multi-lateral agreement to implement these recommendations.  

           


Upcoming Discussion Groups

We are in the final stages of organising 5 discussion group meetings in February and March: Malta, Dubai, Geneva, Hong Kong and a combined UK/US discussion group mid-March, the details of which will be on our website in the next few weeks and outlined in full in our next newsletter.  

Members are encouraged to submit articles to the knowledge bank by contacting Lucie.Hoyland@istructuring.com

TRUMP ESTATE TAX PLAN

Robert Kiggins, Culhane Meadows

Under current US law, for 2017, the estate and gift tax exemption will be $5.49 million per individual, up from $5.45 million in 2016. That means an individual can pass $5.49 million to his or her heirs and pay no federal estate or gift tax. Surviving spouses can port over each other’s unused exemptions, allowing a couple to shield just a little less $11 million ($10.98 million) from federal estate and gift taxes. For taxable estates, the rate is 40%. Assets passing at death get a “stepped up basis” that allows capital gains to escape taxation. If a person bought stock for $200,000 and it’s worth $2 million when he or she dies, the $1,800,000 appreciation escapes capital gains taxation—but could be subject to the estate tax depending on the value of the person’s estate (including taxable gifts made during the person’s lifetime). Read more >>

GUIDING THE DEVELOPMENT OF SME CLIENTS - 

CONFERENCE SUMMARY

Roy Saunders, IFS Consultants

Many of you will be familiar with the Polycon case study, which I have often used to illustrate the issues involved in structuring the development of international companies. This was the basis of the recent IBSA annual conference at the Landmark hotel in London, and the issues that were raised were so varied and interesting that I thought I would summarise them – they epitomise the problems and opportunities when helping particularly medium sized companies develop their businesses internationally.  Read more >>

MAJOR TAX CHANGES TO NON-DOMICILED INDIVIDUALS

Darren Hersey, Simmons Gainsford

Over the last 10 years we have seen major changes to the taxation of UK resident but non-domiciled individuals (“non-doms”) and from April next year we will see the introduction of further more radical changes which will substantially change the landscape in which non-doms will operate. In this article I set out some of these points to consider.   Read more >>

IStructuring Ltd (trading as the IBSA) is a private limited company, registered in England and Wales with registered Company Number 06638150. Business address: 133 Houndsditch, 5th Floor, London, EC3a 7BX, United Kingdom. Registered office: 44 Southampton Buildings, London WC2A 1AP, United Kingdom.