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20211102 US Tax System and Commonly Encountered US Tax Issues and Traps for the Unwary

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Programme Code:
20211102
Date:
02 November 2021 (Tuesday)
Time:
6:30 pm - 8:00 pm
Speakers:

Mr Jeremy Litton, Partner, Asia-Pacific and US Tax Desk Leader, Ernst & Young, Hong Kong

Ms Ellen Tong, Associate Partner, US Tax Desk, Ernst & Young, Hong Kong

Mr Kevin Hughes, Director, US Tax Desk, Ernst & Young, Hong Kong

Language:
English
Venue:
Live webinar
Proficiency Level:
Foundation to Intermediate Level
Fee:
$150 – $200
CPD Hours:
1.5
Seat:
100
Event Categories:
,
Application Form:
20211102 flyer

Description

With the US being such a large market for consumers and business to business transactions, many non-US companies and businesses continue to enter the US to pursue these opportunities.  Navigating the US tax system for any non-US company or business can be challenge.  The US tax system is notoriously complicated, and it can be especially harsh to those who are unwary as there are many “traps” that could subject them to US tax and/or tax filing obligations. However, having a good understanding of the US tax system and being aware of the potential US tax issues that may arise from doing the intended business will help avoid those “traps” and mitigate the risk of adverse US tax consequences.

In this session, join us as we talk about the US tax system and some of those common US tax issues and “traps” encountered by non-US companies doing businesses in connection with the US market.  We will touch upon the overview of the US tax system including US federal, state and local income tax and non-income tax that would be relevant to the non-US businesses.  Some of the US tax issues that we will discuss in the session include remote sales to US customers, unexpected US trade or business where employees work from home in the US, and typical M&A and restructuring related situations.

Speaker Profile

Background

  • Jeremy is a member of Ernst & Young Hong Kong’s International Tax and Transaction Services practice and the Asia-Pacific (APAC) Tax Desk Leader.
  • Jeremy has 20+ years of experience working closely with companies of all sizes (including Fortune 500 companies as well as privately held companies) and in different industries (including technology, consumer products, manufacturing and healthcare) in all areas of international tax including international expansion, cross border mergers and acquisitions, internal restructurings, cross-border financings, foreign tax credit analysis and U.S. international tax compliance.
  • Jeremy also has extensive experience advising on and implementing US international tax compliance and filing requirement matters.
  • Jeremy’s main line of practice has been in the international tax consultation area including planning and compliance.
  • Jeremy has worked on projects involved with international tax reform, tax planning, transaction tax structuring, supply chain structuring and due diligence considerations. These involved projects relating to U.S. international aspects, Asia, Europe and Latin America.
  • Jeremy also has in-depth experience reviewing and advising clients on ASC 740 tax accounting issues from an international tax perspective.

Academic Qualifications

  • Juris Doctorate from University of Mississippi School of Law
  • B.B.A. in Accounting from Millsaps College

Professional Qualifications

  • Member of the American Bar Association and the Tennessee Bar

Background

  • Ellen is an Associate Partner with EY’s U.S. Tax Desk based in Hong Kong
  • Ellen has worked in the U.S. and Hong Kong with over 20 years of experience in providing U.S. and international individual tax advisory and compliance services
  • Ellen has multi-jurisdictional personal tax capabilities including the U.S., Hong Kong and China
  • She is a frequent speaker for individual tax workshops on cross-border and international tax planning.
  • She is a member of AICPA and California State Board of Accountancy

Professional experience

  • Extensive experience in advising senior executives, high net-worth individuals as well as their family offices on cross-border and multi-jurisdictional personal tax matters
  • Extensive experience in income tax planning, wealth transfer and exit strategies
  • Specializing in advising international tax issues with application of income tax treaty
  • In-depth experience in advising private equity/hedge funds and venture capital on their reward/profit share structures, including carried interest and co-investment programs
  • Proven track record in providing high touch, distinct and holistic client services to high net-worth individuals and senior executives
  • Served clients in various industry sectors including financial services, professional services, innovative and technology, public and non-profit sectors

Background

  • Kevin has nearly 20 years of experience providing US federal tax advice to a wide range of US and foreign clients.
  • Kevin is currently a Director on the US Tax Desk in Hong Kong, where he has worked for past 3 years.
  • Prior to joining EY in Hong Kong, Kevin spent 7 years in the M&A Tax groups of two other Big Four accounting firms in New York, providing domestic and cross-border merger and acquisition tax services to private equity and corporate clients.
  • Kevin also worked for several years in the US Federal Tax groups of two other accounting firms in New York and Kansas City.
  • Kevin has a bachelor’s degree in accounting and business finance (B.S.) from Baker University, a masters degree in accounting (M.S.A.) from the University of Missouri Kansas City, a law degree (J.D.) from New York Law School, and a master of laws in taxation (LL.M.) from Georgetown University Law Center.
  • Kevin’s professional licenses and professional association memberships include:
  • Attorney, admitted to the New York bar;
  • Certified Public Accountant, licensed in both New York and Kansas; and
  • Member of the American Bar Association, the New York State Bar Association and the American Institute of Certified Public Accountants.

Professional experience

  • Kevin has advised clients, ranging from Fortune 50 companies to smaller privately-held companies, on a variety US federal income tax matters throughout his career. However, he specializes in providing domestic and cross-border (i.e., US inbound, US outbound, and foreign-to-foreign) acquisition, disposition and tax restructuring advice to both US and foreign private equity and corporate clients.
  • Kevin regularly assists clients with acquisition structuring, tax-efficient financing, US tax due diligence, IPO restructuring and other internal restructuring transactions (e.g., post-deal integration, out-from-under transactions).
  • Kevin’s experience also includes advising clients on other US international tax matters, such as: (i) US inbound investment planning; (ii) US inbound and US outbound cash repatriation planning; (iii) US withholding tax issues; and (iv) US tax issues applicable to controlled foreign corporations and passive foreign investment companies.
  • During his career, Kevin has advised clients in many different industries (e.g., financial services, pharmaceutical and healthcare, technology, consumer products, manufacturing, media and entertainment).