Conference programme

This session will have a special focus on recent judicial decisions on beneficial ownership and will additionally consider the following topics:

• beneficial ownership in tax treaties, EU tax directives and domestic law; and
• the latest case law developments in Canada, Czech Republic, France, Poland and the UK.

1) Panellists will discuss the recent trend of companies taking steps to access US capital markets and support US listings and/or inclusion in US Market Indexes and the varied tax considerations that follow, including:

• overview of some typical restructuring steps undertaken by companies to support such listing or inclusion;
• consequences of restructuring, moving headquarters (management and control) or formally redomesticating from present jurisdiction to the US; and
• stakeholder impacts.

2) Additionally, many US-formed companies will often reorganise or enter into transformative business combination transactions in the pursuit of capital in non-US jurisdiction or [other objectives]. Panellists will discuss:

• application of the US anti-inversion rules to redomesticated US companies or new foreign (non-US) parent company;
• consequences of an inverted company in the US and relevant non-US jurisdiction(s); and
• challenges faced by both US and non-US stakeholders receiving distributions from or participating in reorganisation transactions involving an inverted US company.

• the future of artificial intelligence (AI) and the future of our profession;
• big data in tax administrations – and big problems for taxpayers; and
• chaotic crypto taxation: decentralised autonomous organisations (DAOs)