2018 Cross-border Considerations for the Global Client


Date: Jun 26, 2018 - Jun 28, 2018

CPD hours: 9 Hours

Time: 07:30 - 16:30

Event Type: Seminar

Presenter: TBA

2018 Cross-border Considerations for the Global Client


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Cross-border Considerations for the Global Client

Overview

The worldwide advisory and compliance web is closing-in. Local advisors must be ready to comply and manage the twists and turns of foreign rules and the impact of non-compliance. The 2018 Cross-border Considerations for the Global Client workshop intends to ignite industry awareness, and although it has an international angle, it will have a definite South African perspective, given the current tax, wealth, succession and compliance landscape. 

The multi-layered world of tax planning and global compliance has created a new professional playing field. The advisory sector is an ever-changing, digitalised and transparent area which triggers certain unique challenges for clients and advisors.


Event Dates

26 June 2018, Sandton, Johannesburg

Venue name: FNB Conference Centre and Learning

28 June 2018, Cape Town

Venue name: FNB, Portside, Cape Town


Course Content

The workshop will proactively deal with the following topics:

  • The potential consequences for lawyers, accountants, financial and tax advisors, banks and other service providers when one fails to follow the global anti-avoidance reporting regimes.
  • How can a South African tax resident manage their economic and political risk by holding offshore assets without falling foul of the situs rules?
  • Do trusts still have a role as a tax planning vehicle or are their days numbered?
  • What's next on the transparency agenda in the age of data sharing and the Common Reporting Standard?
  • The role of tax planning in citizenship and residency planning
  • The recent US tax reforms. Has the US become the destination of choice for offshore investors?
  • Global wealth and inter-generational estate planning in a highly regulated and complex world
  • High-level international tax principles from a South African perspective, such as substance over form, residency including place of effective management and Controlled Foreign Company (‘CFC’) rules
  • Transfer pricing, focusing on loans to offshore group entities, and practical and tax challenges
  • BEPS and its impact on international tax treaties with specific reference to permanent establishments

AGENDA

Registration: 7h30 – 8h00

Welcome and opening address: 8h15 – 8h30

Presented by

Professor Keith Engel, SAIT’s Chief Executive: Setting the scene

As part of Keith’s core duties managing the South African Institute of Tax Profesionals, he is heavily engaged in tax at a policy, legislative and interpretative level (e.g., with National Treasury, Parliament, SARS, the Davis Tax Committee and the private sector). 

His role also includes presentations and participation in regional African tax issues. Outside of the Institute, he regularly teaches at the University of Johannesburg and is an honorary adjunct professor at the University of Cape Town, North Western University and Rhodes University. Keith is well known for his leading role at National Treasury in the formulation of tax legislation from 2000 to 2013.


Facilitator

Hugo van Zyl, Local & Global Solutions Specialist at FNB Fiduciary

Hugo van Zyl is a chartered accountant who is passionately committed to assisting people facing tax challenges, be it the resident or migrated taxpayer, trusted accountant, auditor, tax lawyer or the trustee of the family office or trust. 

Since qualifying with and joining SAICA as CA (SA) some 30 odd years ago, Hugo joined SAIT as a Master Tax Practitioner and STEP as a Trust and Estate Practitioner. Hugo is part of the FNB, Wealth and Investments, Fiduciary Advisory team, where he acts as a local and global solutions specialist. Since 1994, his focus has been on migrant taxpayers. In 2003/2004 Hugo consulted on more than 1 000 tax and exchange control amnesty applications, and he lectured from Johannesburg to Wembley (UK) and in between in Springbok Bar, Encino, Los Angeles. 

Hugo has also lectured countrywide (on behalf of STEP, SARS, SAICA and SAIT) on the challenges facing onshore and offshore trusts. In 2017, CNBC Africa invited Hugo to participate on their live broadcast of #BudgetBreakfaxt2017. In April 2017, he presented a paper at the STEP Mauritius conference, focusing on the risks trustees face when they deal with non-compliant clients.


Automatic Exchange of Financial Information between tax authorities: 8h30 – 9h45

Topics:

  • An update on the automatic sharing of financial information between tax authorities and the impact of the sharing of information on individuals and entities
  • A general update on reporting duties: Africa and the world
  • Who is responsible for reporting?
  • OECD rules vs CRS avoidance strategies: What does this mean to an advisor or financial institution?
  • The consequences of non-compliance
  • Reality check: Will tax authorities collect more taxes because of the exchange of information or do you think taxpayers are generally compliant?

Presented by

RC Terblanché, Director at CRSMondial Ltd

RC Terblanché is responsible for FATCA and CRS advice and the implementation of the exchange of information. RC assists with the exchange of information systems in African Revenue Administrations and has, to date, assisted the following countries: Swaziland, Tanzania, Togo, Uganda, Lesotho and Zimbabwe. 

Previously, RC was the competent authority for exchange of information at SARS where he was responsible for the implementation of FATCA. RC also liaised with the IRS on the interpretation and implementation of the Intergovernmental Agreement and was instrumental in dealing with the financial industry on the interpretation and implementation of the agreement. Through comprehensive analysis, RC been instrumental in developing strategies amongst which was the proof of concept for compliance evaluation and the introduction of an equitable case selection methodology as well as capacity planning for SARS’ Enforcement Division.


 

Coffee break: 9h45 – 10h00

 


Global Planning Challenges and Opportunities in a highly regulated and uncertain world: 10h00 – 11h30

Topics

  • Data sharing, Paradise Papers, ultimate beneficial owner registers, unexplained wealth orders, adviser penalties: What have we learned from the past 12 months and what's next on the global transparency agenda?
  • How can a South African tax resident manage their economic and political risk by holding offshore assets without falling foul of the situs rules?
  • Are offshore investments still worth the hassle in the CRS era?
  • Do trusts still have a role as a tax planning vehicle or are their days numbered?
  • Globally mobile families: Where does tax fit into citizenship and residency planning? What special considerations must be made before emigrating to the US or obtaining a US green card?
  • What's on the agenda for the UK's non-dom regime?
  • Is the UK still a destination of choice with Brexit and poor weather when countries in sunnier climes have equally attractive programmes for temporary residents?
  • Trump's tax reforms: Has the biggest overhaul of tax legislation in a generation made the US a destination of choice for offshore investors? Was the 'big, beautiful tax cut' actually a white elephant?

Presented by

Rachel Bentley,, Director in PwC’s Private Client tax team

Rachel joined PwC in Tokyo, Japan in 2002 and has worked with the firm successfully for 16 years in London, New York, Cape Town, Tokyo and Honolulu. She specialises in providing cross-border tax services to wealthy individuals and families with complex international tax and legal situations. Her particular focus is US taxation but she also has a working knowledge of the UK and Japanese individual tax systems. 

In addition to her individual income tax expertise, Rachel is also comfortable with the tax treatment of trusts, estates and closely held entities set up for commercial and philanthropic purposes. She regularly advises on the impact of data sharing regimes such as CRS and FATCA as well as the broader transparency agenda. Rachel's client base consists of internationally mobile families, entrepreneurs and executives. She supports her clients effectively by working closely with family office representatives and other intermediaries. 

At present, she is focused on developing PwC’s private wealth offering across the PwC Africa Network. In 2016 and 2017, Rachel was named by Spear's magazine as one of the UK's top recommended tax accountants. Outside of her day job Rachel is a trustee of Fair Money Advice, a charity focusing on supporting the financially excluded and highly indebted.


Businesses and families, preserve the legacy and minise the impact of real and perceived challenges: 11h30 – 12h45

Topics

How should advisors assist families in developing comprehensive solutions? The below areas of relevance are considered:

  • Family governance
  • Succession planning
  • Family business strategy
  • Compliance and reputational risk factors and reporting
  • Private wealth management
  • Family office and philanthropy

Presented by

Catharina Prym, , Family Business Specialist at PwC

Catharina is specialised in owner strategy consulting. She is a 15th generation member of one of the oldest entrepreneurial dynasties in the world: the Prym Family, which was founded in 1530. 

Today’s Prym Group has its head office in Germany and is a leading, worldwide supplier of creative sewing products, fashion accessories and mechatronics with production facilities around the globe. Catharina has been closely involved in the family business from a young age and was the first in her generation to be on the shareholders board. Due to her contributions she was honored with the Top Family Business Rising Star Award at the European Families in Business Awards 2015. 

She studied family businesses at Europe’s first entrepreneurial University Witten/Herdecke, then moved on to learn her craft in Germany’s leading consulting boutique for Owner Strategy, INTES. Here, PwC’s unique consulting method was originally developed before PwC incorporated the know-how to make it available worldwide. In 2016 Catharina joined PwC to assist the firm with establishing its Family Business Service in South Africa. She works as a consultant for renowned, multigenerational family businesses in Europe and Africa.


 

Lunch 12h45 – 13h30

 


Planning for successful individuals and entrepreneurial families with Middle Eastern exposure: 13h30 – 15h00

Topics

  • Tax and immigration practices with a specific focus on advising successful individuals and entrepreneurial families with Middle Eastern exposure
  • Strategies that should be considered for wealth protection1
  • Implementing inter-generational wealth transfer strategies
  • Structuring operational assets and global wealth
  • Planning for mobile families with a South African link

Presented by

Yann Mrazek, Managing Partner of M/HQ, Dubai

Yann chiefly focuses on private wealth, tax and immigration practice. He has vast experience advising successful individuals and entrepreneurial families with Middle Eastern exposure on implementing inter-generational wealth transfer strategies and structuring their operational assets and global wealth. 

He is the Chair of STEP Arabia and the sole Attorney in the Middle East referenced on the Who’s Who’s legal Private clients list.


Panel discussion on planning opportunities: 15h00 – 16h30

Topic

Planning opportunities in other jurisdictions, for example, using Mauritius as a cost-effective jurisdiction, advice considerations, traps and triggers for local clients in cross-border dealings

Presented by

Professor Keith Engel (facilicator for panel discussion)

Brendon Jones, CEO of Adansonia Holdings Limited, Mauritius

Brendon is the CEO of Adansonia Holdings Limited, a diversified financial services company offering corporate services to people doing business in Africa, based in Mauritius. With 11 years Mauritian experience, Brendon has built-up a valuable business network of clients, attorneys, accountants and service providers across a number of sub-Saharan countries. The Adansonia Group currently provides several value-add solutions to a range of corporate, high net-worth individuals and private equity clients, who have chosen Mauritius as their investment base. 

This is primarily done through Adansonia Management Services Limited, their Mauritian licenced offshore Management company and Corporate Trustee, which has channelled investment into no fewer than 16 African countries. In addition to servicing clients and facilitating investment into Africa, Adansonia PE Opportunities Limited, the Groups permanent capital vehicle is an active co-investor with an African focus.


Roxanna Nyiri, Head of Transfer Pricing at BDO

Roxanna has extensive transfer pricing experience, both in a consulting and auditing role, consulting to large multinational enterprises on all aspects of transfer pricing. Roxanna is also extensively involved in assisting companies with group structuring and implementation for investment into Africa. 

She has been on both sides of the market fence being a transfer pricing specialist for the ‘Big Four' in South Africa, the US and Canada, and in various financial positions in diverse industries. She was instrumental in establishing a transfer pricing unit at SARS and has received formal training from the IRS in the USA, IR in the UK and the ATO in Australia.


Event Investment

This seminar does not form part of the CPD subscription package

Cost: R1 800.00 (member and non-member)

Payments & Cancellations

  • All payments must be made by EFT or by credit card, at least 3 working days before commencement of an event.

  • Kindly note that should payment not been received 2 days after the event, legal action will be taken

  • Proof of payment will be requested at registration, if payment at that point in time has not been reflected on SAIT's bank account.

  • Only written notice of cancellation will be recognised.

  • Conditions:

    • If the cancellation occurs more than 4 working days prior to the event no cancellation fee will be charged.

    • If the cancellation occurs less than 4 working days prior to the event a 100% cancellation fee will apply.

  • Delegates who book and fail to attend will be liable for the full event fee.

  • SAIT's liability in the case of an event being cancelled will be limited to a refund or credit of the event fee.

  • Please click here for the full terms and conditions.

 

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