2020 Offshore Asset Uncertainty: The New Normal For Mexican Residents Join us May 7th from 10-11 am

Presented by Abel Francisco Mejia Consenza 1- Changes to CFC/REFIRE regime a. New limitations on lack of control exemption b. Carve out for assets held through transparent vehicles c. Treatment of accumulated e&p of previous years d. Transfer of capital and e&p to new structures 2- New Regime for Transparent Vehicles a. Definition of transparent vehicles: legal figures and transparent companies b. Attraction rule for foreign vehicles managed in Mexico c. Treatment of contributions and withdrawals of assets into and out of transparent vehicles d. Treatment of foreign currency Exchange gain and preferential capital gains rate 3- Relevant issues on foreign exchange currency gain for direct investments a. Instruments subject to foreign currency Exchange gain b. Application of losses vs gains in credits and debts c. Estimated tax payments and reporting 4- Areas of risk and opportunity: What is the new normal?? a. Is deferral still possible for certain structures and instruments? b. Currents trends in full transparency vs. Limited confidentiality? c. Increased scrutiny from Mexican tax authorities and importance of having complete files