International Tax Update : A View from US , Ireland , the Netherlands and Luxembourg

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This program will provide an overview of recent important topics for those dealing with or are responsible for international tax issues at their company.  From inversions to base erosion and profit shifting, this program will discuss recent changes and proposed changes in tax law in the United States, Ireland and mainland Europe, and what to expect in the coming years.

As governments look for more ways to generate revenue, they have increasingly focused on deterring structures and planning they view as abusive or overly aggressive.  To this end, the OECD has recently released preliminary reports and proposals on various topics designed to limit the ability to shift income to low tax jurisdictions.  Although these proposals are not binding, governments have pledge support for adopting and following the approaches contained in these reports.

Finally, for IP intensive companies, the proliferation in Europe of special regimes focusing on IP returns, including a new proposed regime in Ireland, will be of particular interest

Educational Objectives:
• Gain a better understanding of recent trends and activities in the international tax arena 
• Guidance as to what to potentially expect in the future based on the recent multi-governmental approach to perceived aggressive tax planning.

Who would benefit most from attending this program?
Tax directors, CFOs, in-house tax counsels



Gregory Hartker focuses his practice on domestic and international corporate and partnership tax issues. He has broad experience with both taxable and tax deferred mergers and acquisitions, public and private issuances of debt instruments, and partnership and LLC structuring and operating issues, combined with an extensive international tax background, including areas involving Subpart F, PFIC, foreign tax credits, withholding, treaty issues, cost sharing, and cross border transfer pricing. In addition, Greg focuses a substantial portion of his time on investment fund structuring and representing investors in such funds.

Greg also advises on the tax aspects of financial instruments including notional principal contracts and other derivative products and has played a key role in the development of the next generation of standard derivatives documentation following the enactment of the Dodd Frank Act.


Mark O’Sullivan is a partner in the firm’s Tax Department and advises on all aspects of Irish corporate taxation. His primary focus is advising overseas clients establishing operations and doing business in and through Ireland. Mark also advises extensively on all aspects of international tax planning, including IP planning, cross-border reorganizations and financing transactions. Mark was previously seconded to the legal department of a large investment bank in London in 2004. Mark has been based in the firm's Palo Alto office since 2007. Mark is an active member of the Tax Section of the American Bar Association (ABA), the International Fiscal Association and is also a member of the New York City Bar Committee on Taxation of Business Entities. Mark regularly speaks on international tax issues at Tax Section meetings of the ABA and has presented at a number of Tax Executives Institute (TEI) seminars. Mark has also published articles in the International Tax Review, the Irish Taxation Review, IFLR, BNA and Finance Magazine.


Michiel van Kempen is a member of the international tax practice and is currently heading the New York office’s tax practice. He advises mainly international operating corporate clients, (real estate) private equity and investment funds on all areas of Dutch and Luxembourg taxation. His practice focuses primarily on international tax planning relating to reorganizations, mergers and acquisitions, structured finance, joint ventures and partnerships.

In addition to advising US based clients, Michiel has a considerable amount of experience in advising Italian and Latin American based clients.