International Estate Planning Summit 2015

IFZ-Conference
International Estate
Planning Summit 2015
Tax-Compliant Estate Planning through Switzerland and Liechtenstein for Argentinian,
Brazilian, Mexican and Colombian High Net Worth Individuals and Corporations
22 September 2015, 8.45 a.m. – 05.30 p.m.
21 September 2015, 6.45 p.m. Gala Dinner at Romantik Seehotel Sonne, Küsnacht
Institute of Financial Services Zug IFZ
www.hslu.ch/ifz-conferences
International Estate Planning 2015
Target Groups
Employees, family offices,
bankers, tax consultants,
trustees, fund managers,
asset managers, auditors,
lawyers, government
officers, practitioners,
consultants, accountants in
financial market industries,
financial intermediaries and
investors, in particular from
Argentina, Brazil, Mexico,
Colombia, Switzerland and
Liechtenstein.
Time
Tuesday, 22 September 2015,
08.45 a.m. – 05.30 p.m.
A gala dinner will be held
the evening before, on 21
September 2015, 6.45 p.m.
Costs
CHF 690.–, per person,
including conference materials, lunch and apéro.
CHF 940.–, per person
including gala dinner on the
evening of 21 September
2015.
Applications are open
until 11 September 2015
Lucerne School of Business
Institute of Financial
Services Zug IFZ
Grafenauweg 10
6304 Zug
Switzerland
T +41 41 757 67 67
F +41 41 757 67 00
[email protected]
Registration will be firstcome, first-served
and is strictly limited to
70 participants.
Information
www.hslu.ch/ifz-conferences
Concept
The aim of this “International Estate Planning Summit” is to discuss
and analyse important aspects in relation to cross-border wealth
structuring for a number of selected countries. The Conference will
focus mainly on aspects of tax law, family law, inheritance law,
property law and contract law that should be considered in tax and
wealth planning for high net worth individuals and corporations.
Outstanding practitioners and scholars will explore structuring ideas
for individuals and corporations domiciled in Argentina, Brazil, Mexico,
Colombia, Switzerland and Liechtenstein, including tax-compliant
uses of trusts, foundations, partnerships and collective investment
schemes.
Speakers
Tatiana Antunes Valente Rodrigues, Enseada Partners, Brazil;
Javier Ayuso, Bruchou, Fernández Madero & Lombardi, Argentina;
Prof Dr João Dácio Rolim, Rolim, Viotti & Leite Campos, Brazil;
Frederico de Almeida Fonseca, Rolim, Viotti & Leite Campos, Brazil;
Dr Richard Gassmann, Baker & McKenzie, Zurich; Mónica Inés
Hernández Gómez, Godoy & Hoyos Abogados, Colombia;
Prof Dr Hans Rainer Künzle, Kendris AG, Zurich and University
of Zurich; Ezequiel Lipovetzky, Bruchou, Fernández Madero &
Lombardi, Argentina; Irma Mosquera, Hamelink & Van den Tooren,
the Hague; Roland A. Pfister, Lucerne University of Applied
Sciences and Arts and Badertscher Rechtsanwälte Zurich/Zug;
Manuel E. Tron, Manuel Tron S.C., Mexico; Dr René Vallaster,
Allied Finance, Vaduz; Dr Ernst J. Walch, Walch & Schurti Attorneys
at Law, Liechtenstein
Moderation
Chantal Raymond, David Carrie LLC, New York
Place
The Summit takes place at the Romantik Seehotel Sonne,
Seestrasse 120, 8700 Küsnacht/Lake Zurich (www.sonne.ch).
Either 10 minutes by taxi from Zurich main station or 5 minutes
walking distance from Küsnacht train station.
Programme
08.45 a.m. 08.55 a.m.
Introduction and Welcome
Roland A. Pfister
Estate Planning in Switzerland and Liechtenstein
Prof Dr Hans Rainer Künzle
09.50 a.m.
Switzerland and Liechtenstein as Excellent Jurisdictions for Tax-Compliant
Estate Planning Solutions for Argentinian, Brazilian, Mexican and
Colombian High Net Worth Individuals and Corporations
10.30 a.m.
Coffee break
11.00 a.m.
Asset Protection as a Key Element of Estate Planning
Roland A. Pfister
Dr René Vallaster, Dr Ernst J. Walch, Prof Dr Hans Rainer Künzle, Dr Richard Gassmann
11.40 a.m.
Estate Planning Solutions for Mexican High Net Worth Individuals and Corporations from Inbound and Outbound Perspectives
12.30 a.m.
Lunch
02.00 p.m.
Estate Planning Solutions for Colombian High Net Worth Individuals and Corporations from Inbound and Outbound Perspectives
02.40 p.m.
Estate Planning Solutions for Argentinian High Net Worth Individuals and Corporations from Inbound and Outbound Perspectives
03.20 p.m.
Coffee break
03.40 p.m.
Estate Planning Solutions for Brazilian High Net Worth Individuals and Corporations from Inbound and Outbound Perspectives
04.20 p.m.
Exchange of Information under “Automatic Exchange of Information”,
“Double Tax Conventions”, ”Tax Information Exchange Agreements”,
“FATCA”, “Rubik Agreements” and “Action Plan on Base Erosion and Profit Shifting (BEPS)”: Implications for Tax-Compliant Wealth Planning Strategies for High Net Worth Individuals and Corporations
05.20 p.m.
Closing Speech
Manuel E. Tron
Irma Mosquera, Mónica Inés Hernández Gómez
Javier Ayuso and/or Ezequiel Lipovetzky
Frederico de Almeida Fonseca and/or Prof Dr João Dácio Rolim, Tatiana Antunes Valente
Rodrigues
05.30 p.m.
Roland A. Pfister, Manuel E. Tron, Javier Ayuso and/or Ezequiel Lipovetzky,
Prof Dr João Dácio Rolim and/or Frederico de Almeida Fonseca, Irma Mosquera
Roland A. Pfister
Apéro
Special thanks go to our sponsors
Contact
Lucerne School of Business
Institute of Financial Services Zug IFZ
Grafenauweg 10
P.O. Box 4332
6304 Zug
Switzerland
T +41 41 757 67 67
F +41 41 757 67 00
[email protected]
www.hslu.ch/ifz
www.facebook.com/ifz.zug
blog.hslu.ch/ifz
Speakers
Tatiana Antunes Valente Rodrigues, Enseada
Partners, São Paulo, graduated from the University
of São Paulo (USP) Law School. She has experience
of over 12 years in family and probate law, estate
and succession planning, mainly for high & ultra
high networth individuals, assisting them in Brazil
and abroad. She is an Advisor at Enseada Partners, a
Brazilian Multi Family Office and started her carreer
in Wealth Advisory / Estate Planning and Estate at
Souza, Cescon, Barrieu and Flesch Advogados and
Freitas e Leite Advogados. She has written several
publications related to family and succession law.
Javier Ayuso, Bruchou, Fernández Madero &
Lombardi, Buenos Aires, graduated with honors from
the Law School of the Argentine Catholic University
in 1988, obtained a Master of Science in Finance
from the University of Illinois at Urbana-Champaign
(US) in 1993 and completed a Master in Business
Administration from the Belgrano University (Argen
tina) in 1994. Since he joined the firm in 1993, he
has specialized in mergers & acquisitions, venture
capital investment and wealth and succession planning. He has published various articles and commentaries to case-law in connection to the utilization of
trusts, foundations and other wealth management
structures.
Prof Dr João Dácio Rolim, Rolim, Viotti & Leite Campos, São Paulo, graduated from the University of São
Paulo (USP) Law School. He has an LL.M. in International Tax Law from the London School of Economics
(LSE) and a PhD in Tax Law from the Federal University of Minas Gerais (UFMG). He is a tax lecturer at
the Fundação Getulio Vargas (FGV SP and Rio) and a
Researcher in International Trade Law, Taxation and
Human Rights at Queen Mary, University of London.
He started his tax career at KPMG and PwC and
founded the law firm Rolim, Viotti & Leite Campos
in 1993, with five offices in Brazil and one in Lisbon
(Portugal). His expertise is in international taxation
in Brazil and he also deals with complex litigation tax
cases. He is Director of the AIBAT (Iberian-American
Tax Arbitration Association) and of the IFA Brazilian
branch (ABDF).
Frederico de Almeida Fonseca, Rolim, Viotti & Leite
Campos, São Paulo, studied Law at the Catholic
University of Minas Gerais (PUC), Brazil. He holds an
LL.M. in Tax and Corporate Law from the Milton Campos University and an LL.M. in Regulatory Law from
the Fundação Getulio Vargas (FGV), Rio de Janeiro,
Brazil, with a focus on the taxation of the Brazilian
Energy Sector. He started his career with PwC in 1997
where he became a tax manager in 2003. In 2004
he was invited to join Rolim Viotti & Leite Campos
Attorneys at Law, with five offices in Brazil and one
in Lisbon (Portugal), where he became a Tax Partner
in 2008. He is now the Head of the Tax Consulting
department of Minas Gerais branch. His professional
focus is on national and international tax and estate
planning as well as M&A transactions. He is a tax
lecturer in many LL.M. Programs in Brazil such as FGV,
PUC and at the Brazilian Bar Association (OAB). He
joins both Corporate and Regulatory Commissions at
the Brazilian Bar Association and he is a member at
the Fiscal Studies Institute (IEFi), Brazil.
Dr Richard Gassmann, Baker & McKenzie, Zurich,
heads the Firm’s Dispute Resolution Practice Group in
Zurich, and serves as member of the Private Banking
Practice Group. He has extensive experience in dispute resolution, particularly on cross-border litigation
and international arbitration. He also advises clients
on international private law, complex multijurisdictional structures, debt enforcement, restructuring and
bankruptcy law. In addition to his practice, he has
authored several articles for the Journal of International Taxation, Europa Institut Zürich, European
Legal Development Bulletin and other publications.
He is a member of STEP, the Swiss Arbitration Association, the Société Suisse de Droit Internationale
and the Association LP. He has represented numerous
individuals and companies on international arbitration proceedings, specifically in ICC and UNCITRAL.
Working collaboratively with the Private Banking
groups in Geneva, Zurich and London, he also advises
Swiss and foreign clients on trust and estate issues,
particularly in relation to conflict of laws, compliance
and litigation matters.
Mónica Inés Hernández Gómez, Godoy & Hoyos
Abogados, Bogotá, Colombia, graduated in Law
at Pontificia Universidad Javeriana and with an
Advanced LL.M. in International Tax Law at Leiden
University (the Netherlands). She joined the firm in
2006 and currently works as Tax Director Associate
and leader of the transfer pricing area. She has given
advice to clients in tax matters in general, tax plan
ning, tax matters specifically in estate planning for
individuals and corporations. She has also partici
pated in the tax litigation department, defending
clients in front of the tax authorities and the
Colombian courts. She currently teaches the Tax Law
course of the bachelor program in Law at Pontificia
Universidad Javeriana. She has also taught at the
postgraduate (specialization) program in Tax Law.
Prof Dr Hans Rainer Künzle, Kendris AG, Zurich and
Universitiy of Zurich studied Law and Economics at
the University of St. Gall. He was a Main-Assistant
at the University of Zurich when he wrote his second
thesis (Habilitation). In 1989/1990 he was a Visiting
Scholar at the Boalt Hall Law School of the University
of California, Berkeley. He started his career with
KPMG in 1997 and became Partner in 2001. In 2005
he participated in a management buyout of KPMG
Private, which was renamed Kendris Private Ltd. and
subsequently Kendris Ltd. His professional focus is
on estate planning and estate administration in an
international context. He is known for his Bernese
Commentary on the Swiss Executor (Willensvollstre
cker). He is a co-editor of the Law Review Successio.
Ezequiel Lipovetzky, Bruchou, Fernández Madero
& Lombardi, Buenos Aires, received a law degree
from the Law School of the University of Buenos
Aires in 1998. He also made postgraduate studies in
Tax Law from the University of Buenos Aires School
of Economics in 2002. Prior to joining the firm in
2008, he was a member of Baker & McKenzie and
of Marval, O’Farrell & Mairal, among others, acting
mainly in tax consulting. He specializes in tax law, a
subject in which he has given and attended several
courses, and in which he legally advises most of the
firm’s clients. He has provided tax counsel in local
and international deals, and has been involved with
different clients of the firm in capital markets, project
finance, national and international tax planning,
M&A, general finance and general corporate advice
activities. Furthermore, he has been a speaker in Tax
seminars, both in Argentina and abroad, and has
written several articles on tax matters in specialized
publications, magazines and newspapers.
Irma Mosquera, Hamelink & Van den Tooren N.V.,
The Hague, obtained her PhD (cum laude) from
the University of Groningen in 2007. She works as
a tax advisor at Hamelink & Van den Tooren in the
Netherlands specializing in international tax law.
She also works as a post-doctoral research fellow
on issues related to tax treaties and is a Scientific
Researcher of the Global Tax Treaty Commentaries
at the International Bureau of Fiscal Documentation
in Amsterdam. She lectures in the Bachelor of Law
Program at The Hague University in the Netherlands.
She also participates in the DeStat Group, a research
group of researchers of seven countries studying
sustainable tax governance in developing countries in
the era of global fiscal transparency. She has worked
as a tax advisor at PwC in the Netherlands and as an
assistant professor at the University of Utrecht. She
has been a visiting professor in international tax law
and tax law and development at the University of
Florida (Gainesville) and two universities in Colombia.
She is a member of the International Fiscal Association, the Netherlands Comparative Law Association
and the National Tax Association (the United States).
She has published several articles.
Roland A. Pfister, Lucerne University of Applied
Sciences and Arts and Badertscher Attorneys-at-Law
Zurich/Zug, studied law at the Universities of Neuchâtel and Granada. After the completion of his law
degree, he worked for an international law firm in
Belgium and a leading investment bank in Zurich.
Then, he joined the tax department of one of the
«Big Four» firms in Zurich/Geneva. In addition, he
holds an Executive MBA in Wealth Management and
was a Visiting Researcher at Harvard Law School.
From 2011 to 2014, he worked at a law firm in
Geneva. As of 2015, he works in an international corporate and tax law firm in Zurich/Zug. He is a regular
contributor to tax journals and lectures frequently in
postgraduate tax programs. His main areas of expertise include Swiss, Liechtenstein and international tax
law for individuals and corporations, incl. funds, trusts
and foundations.
Chantal Raymond, David Carrie LLC, New York, graduated with a Juris Doctor from Harvard Law School
after having completed a bachelor’s degree in public
relations at the University of Florida, which she attended using nine academic scholarships. At Harvard,
her love for and commitment to her Caribbean roots
moved her to become co-president and co-founder
of the Harvard Caribbean Law Association. Chantal’s
life is marked by extensive voluntary contributions of
her time and services. She also completed a political/
economic internship at the US Department of State,
US Embassy, in Kingston, Jamaica. She also represented Jamaica at the Miss World 2010 competition
held in Sanya, China.
Manuel E. Tron, Manuel Tron S.C., Mexico City,
graduated and made postgraduate studies in Economic and Corporate Law, and Tax Law at the Universidad Panamericana and attended the International
Tax Institute (University of Wisconsin Law School).
For more than 30 years, he has advised clients in
both estate and succession planning (families, financial advisors and financial institutions) and corporate
clients on international tax matters. He has been
an advisor and instructor of international tax law
matters for different areas of the Tax Administration
Service in Mexico (SAT) and the Federal Tax Court.
He has advised various ad hoc commissions of the
Mexican Supreme Court, as well as the Tax Committees in both chambers of the Mexican legislature. He
has advised and worked together with international
organizations and foreign governments. He was the
President of the International Fiscal Association (IFA)
between 2009 and 2013 and was named Honorary
President at the end of his second term.
Dr René Vallaster, Allied Finance, Vaduz, has eight
years of professional experience in the Liechtenstein
trust business. He studied law at the University of
Innsbruck before completing his training as a lawyer
in Austria. He worked for a renowned Liechtenstein
trust company for more than four years, before joining Allied Finance in Vaduz at the end of 2011, where
he has since been working as Head of Fiduciary
Services and as a client advisor. His area of expertise
includes in particular the structuring of Liechtenstein
legal entities and trusts in estate planning and asset
protection.
Dr Ernst J. Walch, Walch & Schurti Attorneys at Law,
Liechtenstein, is senior partner of Walch & Schurti,
one of Liechtenstein’s foremost law practices (linked
with a renowned trustee company providing services
to international companies and high-wealth individuals). His firm has extensive litigation experience and
is an acknowledged leading player in the commercial
litigation field in Liechtenstein. He is admitted to
practice law in both New York and Liechtenstein,
where he has practiced since 1984. He also pursued
a political career, being a member of the Liechtenstein parliament from 1989 to 1996, president of the
parliament in 1993 and minister of foreign affairs
from 2001 to 2005. He is a regular contributor to
international journals, and lectures frequently at
conferences.

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