Enrique Rodolfo Escobar López

Enrique Escobar has extensive experience in the banking field, in which he has served as manager of legal departments and legal advisor of several local banks, including Banco Agricola, S. A., which is one of the largest banks in the region. He has also advised KPMG regarding taxes, has been a member of several boards of state entities such as ANDA (National Water Supply and Sewerage) and SIGET (Superintendence of Telecommunications and Electricity) as well as private enterprises such as CASALCO (Salvadoran Chamber of the Construction Industry).

Within his practice, he has also advised several corporate and individual clients, with particular emphasis on heritage structures and corporate governance, both locally and internationally.

Education:

Degree in Law, Lawyer and Notary, Nueva San Salvador University; Authorized by the Supreme Court of Justice of El Salvador to exercise as a Lawyer and Notary (1985); Diploma in International Business Legal Aspects, Georgetown University – INCAE (2004). Enrique Escobar has also participated in several conferences, courses and seminars offered by various national and international institutions, obtaining diplomas in the areas of negotiation, arbitration, alternative dispute resolution, management, policies on foreign trade, technology transfer contracts, Export credit insurance, securitization and secularization, banking and finance.

Tax Law Practice:

At LEXINCORP we are committed to providing advice to our clients across the region. That’s why we pay special emphasis to creating corporate structures that are tax-efficient, minimizing the impact that taxation might have on a business.

Our team is highly trained in providing legal advice regarding both local and regional tax issues, which apply to exports, imports, and all sorts of tax-generating activities. In addition, we represent our clients in legal claims that the States of the region initiate against them. Some of our partners have served as judges in tax matters, even as Court of Appeals judges.

Lexincorp:

In LEXINCORP we specialize in providing legal advisory services to large and medium sized corporations operating in Central America.

For more than 40 years we have been learning from the market to reach the final objective of INTEGRATION…

At LEXINCORP, we evolved to integrate processes, services, knowledge, businesses, values and solutions to provide quality results to our customers, in each of the services offered and in all of our offices in the region.

With over 80 lawyers with the expertise to care and respond to the needs of our customers, as well as a network of 6 offices across 5 countries in Central America; LEXINCORP, is an enterprising and innovative Firm that has a robust and unique structure, which has enabled it to reach a leading position among all Firms in Central America, recognized by many of the most successful companies around the world.

Todor Tabakov

Todor Tabakov is one of the founders of Tabakov, Tabakova and Partners. He is a reputable attorney, having extensive experience in various fields of national and International law, including Taxation, Arbitration, Litigation, M&A, Commercial Law, Contracts Law, Competition, Banking and Financing, Real Estates, Oil and Natural Gas (upstream, mainstream and downstream), Energy.

He has comprehensive knowledge and expertise in Taxation and international tax planning. Todor is a well known and probably the most highly regarded international tax planner in Bulgaria. He practically laid down the foundations of the international tax planning business in the country. Todor’s advice has been sought in almost every complex international transaction ever to take place in Bulgaria.

Todor has held numerous positions at the Bulgarian Ministry of Finance and the Ministry of Economy and Planning. He was a consultant at the Organisation for Economic Cooperation and Development – Committee of Tax Affairs. Todor is currently a correspondent of Tax Notes International and Tax Analysts, IBFD. He is a member of IFA, TTN and the American Bar Association. Todor’s contribution to the international community has been recognized by the Madison Who’s Who and Who’s Who in the World biographical records, IBA and ABA biographical records.

Todor’s professional experience record includes: Judge at the City Court of Sofia and District Court of Sofia; Legal Advisor at the Ministry of Finance; Expert on International double taxation at the Ministry of Finance, Head of the International Tax and Investment Treaties Division of the Ministry of Finance, Head of International Financial Relations Department of the Ministry of Finance; Consultant at OECD – Fiscal Affairs Committee; Chief Executive Officer of Preston Finance Ltd.

Todor has over 60 publications in Bulgaria on legal matters, related mainly to tax and investment agreements and relevant legislation, publications in TNI (tax analysts) and Central European (Euromoney) publications.

Todor’s membership of professional bodies includes: Sofia Bar Association; European Association of Trustees, International Fiscal Association, Bulgarian Chamber of Tax Advisers. Todor is a member of the board of directors of the Bulgarian Chamber of Commerce and Industry and of the Board of the Bulgarian Association of Professional football players. He is also a member of the International Biographic Association and correspondent of Tax Notes International.

Todor is fluent in English, French and Russian.

Tom Rosenstock

Mr. Rosenstock has been advising clients in Afghanistan since 2008. Mr. Rosenstock advises clients on transactional matters, early stage dispute resolution, and in conjunction with locally qualified attorneys, on matters of Afghan law including registration, taxation, employment law and other interaction with Afghan government departments. Mr. Rosenstock was an entrepreneur and a business consultant before studying law at New York University in the United States. He has been admitted to practice law in the State of New York and began his career in the New York office of Paul, Weiss, Rifkind, Wharton & Garrison. In addition to his work with RLS, Mr. Rosenstock is a founder and current member of the Board of the American Chamber of Commerce in Afghanistan.

Tax Law Practice:

Rosenstock Legal Services has been working within the tax system since 2008, and has an intimate understanding of the evolving approaches used by the Afghan Government with respect to the enforcement of the Income Tax Law.

The tax environment in Afghanistan has been rapidly evolving over the past several years from one which had minimal impact on the operations of international companies to where we are today, with complex issues surrounding tax exemptions, withholding obligations, and contradictory interpretations of International Tax Agreements.

Because of the nature of the tax environment in Afghanistan, and the uncertainty that has prevailed in the marketplace, most of our clients come to us wanting to discuss both the past and the future. With respect to the past, we can’t change the law, but we can give comfort to our clients about what the real liabilities may be and how to address them. When it comes to the future, we make certain that our clients know exactly what to expect from the current enforcement regime.

RLS’ tax engagements with our clients run the full spectrum from initial advice on the Afghan corporate tax regime, to full-scale implementation where RLS handles our clients ongoing and annual tax filings. RLS also trains administrative personnel to perform ongoing tax filings

Rosenstock Legal Services:

Afghanistan is a challenging place for international companies to do business. The local legal and regulatory system is less transparent than in many other jurisdictions, and local professionals are not always able to provide international companies with the level of comfort they require. RLS has extensive experience helping clients understand and navigate the local corporate registration and tax environment, and advising in connection with local employment law and other interaction with governing bodies.

RLS has advised both buyers and sellers in mergers, acquisitions and other corporate re-organizations. RLS also assists small to medium size international companies doing business in Afghanistan by acting as their outside general counsel, advising in transactional and other matters. RLS combines its international legal skills and local experience, working closely with locally qualified counsel to provide international companies with international caliber legal services applicable to this challenging environment.

RLS’ work for Afghan companies involves assisting them with complex contracts and contract disputes. The Afghan legal community does not have extensive experience in complex contracts, and RLS believes that it’s important to enable Afghan businesses to do business with international private and public organizations on an equal footing.

Stephen A. Malley

Stephen A. Malley has for over 40 years specialized in the areas of international business, tax and finance, captive insurance structures, transnational estate, tax, and asset protection planning, and pre-immigration and expatriation planning. Mr. Malley’s practice includes domestic and foreign licensing of intellectual property, and the formation of captive liability insurance companies.

Clients include:

  • U.S. companies with foreign operations
  • U.S. citizens conducting business and investing overseas
  • Foreign individuals and businesses dealing with U.S. taxation issues

Professional Associations:

  • California State Bar, International Law Section
  • Advisor to Executive Committee
  • State Bar of California
  • LA County Bar – Member: Business, Tax and International Sections
  • International Bar Association
  • Offshore Institute
  • Asian Business League
  • Center for International Legal Studies
  • Society for Trust and Estate Planners
  • Provisors

Areas of Practice:

Stephen A. Malley offers specialized and experienced counsel in U.S. and International tax and business planning, transnational business structures, international licensing, pre-immigration tax planning and estate planning for U.S. individuals and families with foreign interests and for foreign families with U.S. beneficiaries or U.S. based assets.

UNITED STATES AND INTERNATIONAL TAX AND BUSINESS TRANSACTIONS

Individuals or companies with international assets and /or business interests must consider not only the applicable laws of each Country, but also the tax implications of both the U.S. and relevant foreign jurisdictions. Tax rates on dividends, interest, and royalties are often determined by tax treaties. While “treaty shopping” is discouraged by the terms of many tax treaties, careful planning might take advantage of the most favorable tax treaties. The application of tax credits is often complex . Mr. Malley represents individuals and business entities engaged in domestic and international commerce. Of primary importance is planning to achieve the desired business purposes, taking into consideration foreign law and business practices.

Mr. Malley assists non-U.S. clients in planning for U.S. legal, regulatory, and tax issues, and US clients in their business transactions and arrangements overseas.

Failure to comply with foreign and domestic legal and tax obligations can result in serious problems.

LICENSING AND SALE OF TRADEMARKS, PATENTS, COPYRIGHTS AND COMPUTER SOFTWARE

U.S. tax law imposes strict guidelines of the transfer of intellectual property but it is often possible to minimize or defer U.S. tax exposure in connection with overseas licensing. Many but not all tax treaties limit the withholding tax on royalty payments, both into and out of the U.S. Joint development of IP with a foreign partner or subsidiary is also subject to IRS rules and regulations, and these do change from time to time. Foreign licensors into the U.S. must consider the tax implications in all relevant jurisdictions to maximize returns. Business issues, such as control and payment, need careful analysis and consideration of applicable business practices, currency controls and exchange rates.

TRANSACTIONAL ESTATE AND TAX PLANNING

Estate planning often involves consideration of Estate, gift and income taxes. US persons with overseas assets, and foreigners with US assets, require specialized professional advice to avoid negative tax and probate issues. U.S. taxpayers with foreign spouses are particularly vulnerable to negative tax consequences absent appropriate planning. The U.S. estate tax regime is in flux, and the tax exemption amount for 2013 is in doubt.

Foreign persons with U.S. assets can be subject to U.S. gift tax, and, on death, to U.S. estate tax, and this comes often as an unpleasant surprise. The U.S. tax code provides guidance on what types of assets are “sited” in the U.S. for gift and estate tax purposes. Often, it is advantageous for a foreigner to hold U.S.based assets in an offshore entity, for example in a Trust or corporation, as best determined by the foreigner’s own or selected jurisdiction. The use of U.S. tax free offshore private placement life insurance may be very advantageous in the right circumstances.

Foreign families with U.S. beneficiaries can achieve tax minimization and/or control with proper planning.

ASSET PRESERVATION PLANNING

Mr. Malley provides transnational estate, tax and asset protection planning for United States citizens and for foreign nationals. Asset protection should be considered in any estate plan. There are many planning opportunities to achieve this protection, depending on factors such as the extent and location of assets, and the individual’s family arrangements, beneficiaries, and other planning goals, which may include privacy and anonymity. Asset protection should be part of any estate planning whenever significant assets are involved.

In the U.S., fraudulent conveyance laws (not discussed here in detail) must be considered whenever there exists a known creditor, any transfer of ownership of assets, including to a domestic or offshore irrevocable trust, might be deemed by a court to be a fraudulent conveyance which can be “set aside” for the benefit of a judgment creditor. However, the Transfer of assets in such circumstance may not automatically constitute a “fraudulent conveyance” but careful analysis is required. In such circumstances, there are arrangements which can be made to lawfully protect assets, including the use of limited liability companies in beneficial jurisdictions and possibly private placement life insurance.

Asset protection planning undertaken before there is a creditor issue offers many more options. For example, the use of “family” limited partnerships or limited liability companies can be appropriate; and irrevocable trusts domiciled in certain States can allow the settlor of the trust to be a discretionary beneficiary and still protect the trust assets from creditors (not the case in California.).

On-shore and offshore holding companies are of use in certain circumstances.

Private placement life insurance can be structured to provide substantial asset protection while also affording access to the funds through tax free loans from the policy. Offshore insurance companies offer more flexible terms, but the policies in any case should be made U.S. compliant, to earn U.S. tax free.

The ultimate forms used to protect assets will be determined by relevant facts, estate and tax planning objectives, and the particular wishes of the individual.

PRE-IMMIGRATION TAX PLANNING

Persons immigrating to the U.S., either permanently or for temporary employment, will be subject to tax on world- wide income. Depending on circumstances, planning before arriving in the U.S. can minimize exposure to U.S. income and estate tax; there is a minimal estate tax exemption for estates which pass to non-Citizens.

Cephas K. Birungyi

Cephas K. Birungyi is a highly qualified and distinguished tax expert, easily recognized as a leading tax advisor in Uganda, Africa and internationally. Mr. Birungyi is the expert witness for Heritage Oil and Gas limited in the ongoing arbitration in London.

He is the Managing Partner of the firm. Cephas has previously worked for the Ugandan government in various capacities including as Deputy Commissioner of Domestic Direct Taxes in the Uganda Revenue Authority. He has represented the country in the negotiations and drafting of several double taxation agreements with over 5 countries. He is the head of the tax department of the firm and regularly advises, consults for and represents major local and international corporations, governments, international agencies and financial institution in Uganda, Africa and all around the world.

He is thoroughly trained and holds various specialist qualifications including from the UK and South Africa. He is a member of the Uganda Law Society, East African Law Society, the International Bar Association, the Institute of Taxation and the Institute of Corporate Governance.

Professional Affiliations:

– Uganda Law Society

– East African Law Society

– International Bar Association of Taxation and institute of Corporate Governance

Dr. Bettina Bokeloh

Bettina Bokeloh is a national partner in the Tax Department, focusing on advising private equity firms and strategic investors on national and international M&A transactions. She also has significant experience in advising multinational corporations on corporate tax matters, including cross-border tax planning and reorganizations, and regularly advises on capital markets transactions.

Bettina is fluent in German (native) and English.

Firm Overview:

Willkie is an elite international law firm of approximately 700 lawyers located in nine offices in six countries. For more than 125 years, we have represented companies across a wide spectrum of businesses and industries, most notably financial services. The firm is comprised of attorneys who are recognized as some of the world’s foremost practitioners in their respective areas.

Client Service

Willkie’s collaborative approach is entrepreneurially inspired and client focused. Clients grow with us over time. They hire us because of our reputation and our experience, and then build longstanding allegiances based on results and the collegial process by which they are achieved. Our focus on client service includes:

  • A pragmatic approach to the practice of law that puts the client first and forms the basis for longstanding relationships
  • Best-in-class practices that are frequently recognized by peers, clients and independent review publications
  • An attention to successful collaboration that encourages our bright and energetic lawyers to serve clients’ needs while maintaining high ethical standards and treating others with respect
  • Lawyers who possess the legal knowledge and experience to handle any transaction and the ability to communicate effectively with clients

Our International Reach

Willkie’s international experience—including the representation of U.S. and international corporations throughout all regions of the world—is both deep and broad. Located in key business centers throughout the world, Willkie is comprised of the best local market talent in shared strategic areas of practice. Each of our European offices is ranked and recognized within its country as a top local firm. This is an extraordinary distinction and speaks to our specific focus on having the best local talent in each office. Our ability to provide sound judgment and sophisticated legal advice, coupled with significant knowledge of a region’s particular rules and regulations, financial and political regimes, and customs and culture, ensures that clients seeking to conduct cross-border business get the maximum benefit from our vast experience.

Strategically Focused Areas of Practice

Our firm’s shared areas of concentration and services are aligned to ensure high quality and consistently responsive counsel across our international network of offices. Our continuous focus on the synergies within our firm is supported by a firm culture that values collaboration and cooperation.

Stefanus Kurniadi

Stefanus has over 16 years experience in tax, specializing in tax compliances, tax diagnostic review, tax dispute resolution, transfer pricing and international tax. Previously he joined several tax consulting firms with Big Four environment.

Professional Licenses

Stefanus is a registered Tax Consultant in Indonesia. Stefanus holds Tax Consultant License C from the Indonesian Tax Consultant Association (IKPI), and it is enable him to assist and represent the multinational and domestic taxpayers during the tax audit, tax objection and various discussion with the Tax Office.

Stefanus also holds Tax Attorney License (“Kuasa Hukum”) to assist the taxpayer during the tax appeal process in the Tax Court.

Education Background

Stefanus holds Master of Business Administration (MBA) from the Gadjah Mada University. Previously he graduated from University of Parahyangan with the major of Accounting (Bachelor Degree).

International Tax Courses

During his career, Stefanus has followed numerous international tax courses conducted by IBFD and Loyens & Loeff, e.g. international taxation, and transfer pricing.

Firm Description

SSJK Consulting, which is based in Jakarta, is a tax consultancy firm that provides professional assistance and services to foreign investors and multinational companies to help them identify the Indonesian taxation issues affecting their business and transactions. Our services cover Tax Consulting, Tax Dispute Resolution, Tax Compliance, Tax Diagnostic Review, and Transfer Pricing Documentation.

SSJK Consulting employs professional consultants who are graduates in tax and accounting from well-known universities. Our professionals are also registered in Indonesia as Certified Tax Consultants and Certified Accountants. We continually refine our taxation skills through regular overseas training courses and in-house development to respond on behalf of our clients to economic and regulatory changes as they occur.

Our talented, professional collaborative team offers a formidable mix of knowledge and experience; this is rooted in a long history of advising on some of the most significant and complex taxation issues regarding corporate and commercial transactions across a broad range of industries:

  • Manufacturing
  • Trading
  • Retail and consumer products
  • Logistic and warehousing management
  • Consultancy services
  • Construction
  • Plantations

Filipa Arrobas da Silva

Filipa Arrobas da Silva has developed her work in the area of Real Estate law, with experience in national and international transactions in this area with a corporate and tax component.

Filipa provides legal support in transactions and operations at national and international level of purchase and sale of properties, leasing, management and operation of condominiums, works contracts and acquisitions of shares in commercial companies.

Firm Overview:

DLA Piper is a global law firm with lawyers located in more than 40 countries throughout the Americas, Europe, the Middle East, Africa and Asia Pacific, positioning us to help clients with their legal needs around the world.

We strive to be the leading global business law firm by delivering quality and value to our clients.

We achieve this through practical and innovative legal solutions that help our clients succeed. We deliver consistent services across our platform of practices and sectors in all matters we undertake.

Our clients range from multinational, Global 1000, and Fortune 500 enterprises to emerging companies developing industry-leading technologies. They include more than half of the Fortune 250 and nearly half of the FTSE 350 or their subsidiaries. We also advise governments and public sector bodies.

Jūlija Kozlova

She has received Master’s degree in University of Latvia, in Faculty of Finance and Trade. For raising qualification Jūlija has attended several professional training programmes in financial accounting, bank accounting, financial management, field of business law and tax legislation, as well as she has received diploma of UK Institute of Financial Analysts in international accounting standards and diploma of internal auditor issued by UK Institute of Certified Financial Managers.

In 2006 she graduated Master studies in the Baltic International Academy in programme “Business management and administration”. Jūlija has substantial experience obtained through a work for a long time in accounting, financial and economic sectors.

Along with changes in times, legislation and requirements of state institutions Jūlija always improves the range of her knowledge.

JK Consulting Group:

Founded in 2013, JK Consulting Group has already proved itself to be a trustworthy partner in the area of outsourcing services. Our aim is to find one-step, fast and precise solution for a customer to address wide range of their requirements, be it accounting, legal or tax advisory services, company management or budget preparation.

The key to our company’s success is our employees. Our team of wide spectrum specialists have been working together since 2002 which lead to a foundation of JK Consulting Group in 2013. All our employees have extensive experience, high qualifications and successes in their professional fields. Our team of ACCA qualified accountants are able to understand the needs of our customers, help them increase efficiency of their work and decrease risks. We treat our customers as business partners and work together with them to ensure their growth.

We want our customers find us and stay with us; therefore we are always open to a dialogue and are proud of our team’s professionalism, their personal, friendly and collaborative approach to business

We do not give promises that we are unable to fulfill – and we keep our promises.

Paolo Tognolo

Senior Partner at Studio Tributario Tognolo (estabilished by him in November, 2002), Paolo received his Economic’s degree as a Tax Consultant at the Bocconi University of Milan.

He is a member of the State tax consultants association from 1992 (Dottori Commercialisti) and a member of the State Chartered Accountant association (authorising to perform the activity of Statutory Auditor of Italian legal entities).

He is also included in the Register of technical consultants of the Milan tax Courts as expert of international tax matters.

He regularly provides tax advice to several Italian multinational groups and helps a trustful support to foreign multinational groups on Italian and international tax matters. He also performs the statutory auditor’ legal control activities for many relevant Italian legal entities. He is widely experienced in:

  • M&A (structuring and tax due diligence) and IPO (tax side).
  • Streamlining projects and reorganization of European groups;
  • International tax treaties and double taxation aspects;
  • Permanent Establishment;
  • Transfer Pricing (group planning, defence, documentation, benchmarking analysis, unilateral APA, bilateral APA, Patent box regimes);
  • Back-office assistance to companies during the assessment performed by tax authorities and following steps at domestic as well international implications (i.e. EU arbitration convention procedures and Mutual Agreement Procedures);
  • Standard Ruling and Ruling for New Investments;
  • Group business reorganisations (economic analysis, transfer pricing aspects, direct and indirect tax consequences);

Paolo Tognolo is member of International Tax Commission of the Milan’s Tax Consultant associations and he regularly partecipates as relator to Conferences and Matsters organized by the tax law school of the Tax Consultant’s foundation of Milan. He’s also a member of the Company law Board of Assolombarda, of B.I.A.C. (the Business and Industry Advisory Commitee to the OECD) and partner of I.F.A. (International Fiscal Association).

He regularly lectures at external courses, seminars and workshops for several domestic and international organisations on domestic and international tax matters (such as Business International, Sole 24 Ore, International Institute of Research, Learning Resources Associate and Cegos) and at masters in international taxation (CERTI-Bocconi University, Centro Studi Ragionieri and CEGOS).

Studio Tributario Tognolo:

The tax firm Studio Tributario Tognolo was created in 2002 as initiative of its only founder: Paolo Tognolo. It’s an Italian firm of Tax Consultants, Chartered Accountants and Tax Lawyers located in Milan (Italy) dealing with tax, account and company law advice for medium and large Italian legal entities and for Italian and foreign multinational groups.

The firm is not linked to any auditing company, or tax and legal international network. As a consequence it does not incur in any of the limitations or restrictions at present fixed by CONSOB (Italian regulatory Body), Sarbarnes-Oxley American Law, or by any other foreign regulatory Bodies.

In this environment, the firm represents both the interests of Italian investor’s abroad and foreign investors in Italy through the involvement of a selected group of skilled professional around the globe.

Studio Tributario Tognolo has the unique ability to anticipate the potential vulnerabilities of companies’ processes, planning an efficient management in an internationally dynamic context, building based on trustworthiness and partnership lasting in some cases over 15 years.