Tax

International tax talk quarterly series with Ernst & Young LLP's Global Tax Desk Network

A series addressing tax planning, risk and other pertinent global tax topics

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The deductibility of interest on borrowings has recently come under greater scrutiny in many countries and is seen as a cornerstone issue in the current base erosion and profit shifting (BEPS) debate.

This quarter our Global Tax Desk Network will focus on thin capitalization and the related debt/equity characterization issues that may arise under select foreign tax regimes in relation to related and non-related-party borrowings. The countries/regions we will cover in our webcast include: Germany, Benelux, India and China.

In brief, the webcast will cover relevant:

  • Interest deductibility concepts
  • Thin capitalization/earning stripping rules
  • Debt/Equity characterization considerations
  • Interest withholding tax
  • BEPS considerations and current political/legislative developments

This program will be of interest to vice presidents/directors of tax/international tax, directors of finance, CFOs, international tax managers and tax accountants looking for the latest practical information and planning ideas to support their global business initiatives.

 

Panelists:

Thomas Eckhardt

Ernst & Young LLP, German Tax Desk, International Tax Services

Thomas Eckhardt is a New York resident senior member of Ernst & Young LLP’s German Tax Desk in New York. He is responsible for German tax law subject matters, with a focus on German reorganization and international tax law issues.

Thomas received his legal degrees from the University of Frankfurt (German JD) and New York University (LLM Taxation). He is a licensed German tax advisor (“Steuerberater”) and is admitted to the German bar.

David Kuo

Ernst & Young LLP, China Tax Desk, International Tax Services

David T.W. Kuo is the International Tax Services China desk leader for Ernst & Young LLP in New York.

David has over 16 years of tax experience in both public accounting and private industry. He has provided Chinese tax advice to numerous US and non-US clients seeking to invest into China or to restructure their existing Chinese operations.

David received a Bachelor of Arts in Economics and Business Administration degree from Knox College and a Master of Science in Taxation degree from the University of Illinois. He passed the US CPA exam in 1994.

Tejas Mody

Ernst & Young LLP, India Tax Desk, International Tax Services

Tejas Mody leads Ernst & Young LLP’s India Tax Desk in New York. Tejas has over eight years of experience, and his clientele includes various large multinationals, leading Indian corporates (covering a wide spectrum of industries) and private equity houses.

Tejas is a Chartered Accountant in India and a Commerce graduate from Bombay University, India. He has been a regular contributor of articles, alerts and publications on transaction tax-related matters/ developments.

Dirk Stalenhoef

Ernst & Young LLP, Netherlands Tax Desk, International Tax Services

Dirk Stalenhoef is a member of Ernst & Young LLP’s International Tax Services practice. Located in New York, Dirk heads the Belgian-Netherlands Tax Desk. He advises on the pan-European tax aspects of international transactions and restructurings, including the Dutch tax regime.

Dirk has significant experience advising clients on international tax structuring, cross-border acquisitions and mergers, tax treaties, holding and finance regimes, Dutch corporate tax regime and TESCM-oriented structures. He also has broad experience advising on the implementation of large cross-border investment structures.

Jurjan Wouda Kuipers

Ernst & Young LLP, Luxembourg Tax Desk, International Tax Services

Jurjan Wouda Kuipers is a member of Ernst & Young LLP’s Tax Services practice in New York, where he heads the Luxembourg Tax Desk in the US. Jurjan frequently advises US multinationals on the tax aspects of centralizing European operations, holding, financing or licensing activities in Luxembourg, as well as on the tax implications of pan-European acquisition strategies, mergers and joint ventures.

Jurjan holds three master’s degrees: Tax Law, Corporate Law and Individual (Private) Law). He is a frequent speaker on EU and Luxembourg tax matters, both at firm-sponsored events and events sponsored by organizations such as the Tax Executives Institute, European American Tax Institute and the International Fiscal Association. Jurjan has authored several published articles.

Moderator:

Michael Anderson

Ernst & Young LLP, Australia Tax Desk, International Tax Services

Michael Anderson serves as a partner with the Transaction Tax team of Ernst & Young (Australia), providing transaction advisory support and advice in relation to social and economic infrastructure projects and mergers and acquisitions. Michael is currently on assignment as an international director with Ernst & Young LLP in New York, where he leads the firm’s Australian Tax Desk.

Michael has a BA (honors) from Australian National University and a Master of Commerce (Accounting) from University of New South Wales. He is a member of the Institute of Chartered Accountants in Australia.