TEI's Houston Chapter: 25th Annual Tax School

Location: Houston, TX

Layla J. Asali and Rocco V. Femia will present at the TEI Houston Chapter's 25th Annual Tax School on January 30, 2013. This session, titled "Tax Treaty Primer: An Overview of Tax Treaties & Tax Planning Techniques," will provide an introduction to tax treaties, treaty issues and planning techniques. It will cover such topics as Permanent Establishment, both a primer of the PE concept and advanced PE topics with an eye toward issues arising in the natural resources space and Limitation on Benefits Clause.

In addition, the speakers will cover interpretative and controversy issues affecting treaties, including the last-in-time rule and the Air Liquide regulatory last-in-time issue, interrelationships between Malts and Tax Treaties, authority behind TIEAs and how that may be subject to challenge, Limitation on Benefits interpretative issues, whether an "international agreement" can bind the US without an official treaty, and public vs. private rights and the impact of that dichotomy on treaty application.

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