Aviation Finance and the International Tax Reform on BEPS: What You Need to Know and Do
The previous year has been the turning point for numerous industries in the U.S., more importantly, for the aviation finance industry. Apart from the significant and unexpected developments, remarkable international tax reform has also marked the year 2017. The main factor for the changes and alteration to international taxation, that greatly impacted aviation finance and leasing, is the OECD's Base Erosion and Profit Shifting (BEPS) Action Plan and its heightened focus on double tax treaties. A more complex tax environment for the aviation industry is expected in 2018 and beyond.
In this LIVE Webcast a team of thought leaders and professionals assembled by The Knowledge Group will provide a thorough analysis of the fundamentals as well as legal perspectives on Aviation Finance and the International Tax Reform. Speakers will provide a clear view of the scope and considerations of this noteworthy topic.
Key Topics include:
- The International Tax Reform on BEPS – What It is, and What It Isn't
- Aviation Finance: Legal Steps Taken When Leasing/Financing Aircraft That Are Not Taken For Other Equipment
- What Should I Be Doing About the BEPS Tax Reform
- If I am a Lessor/Financer
- If I am a Lessee/Borrower
- Aviation Finance and Leasing Developments and Trends in 2018
Albert Givray, Partner
Davis Graham & Stubbs LLP
1.0—Special attributes of aircraft call for unique lease provisions not found in non-aircraft equipment leases.
2.0—There are aircraft leasing plays for equipment lessors who don't ordinarily do aircraft leases
3.0—There are six sets of clauses that your deal documents should contain, and it's easy to retrofit your documents, if these clauses are not there now:
3.1 where to file your lease
3.2 traffic rules to maintain the condition of the aircraft
3.3 insurance clauses
3.4 use and operation restrictions on the leased aircraft
3.5 return conditions for the aircraft when the lease is expired
3.6 rules on "Truth in Leasing"
Caroline Devlin, Partner
- Introduction to BEPS for leasing and Impact of BEPS on Irish Lessors
- Structuring the Irish leasing platform - different models and different uses
- Profit extraction/ financing
- Managing tax considerations for Irish lessors
- Withholding tax /treaty access
- Representations and impact on sharing of liability
Who Should Attend:
- Managing Directors
- Chief Executive Officers
- International Tax Attorneys
- International Tax Professionals
- Aviation Leasing Companies
- Aviation Finance Industry Professionals
- Aircraft Lessors
Al Givray is a partner in the Denver law firm of Davis Graham & Stubbs. He is also General Counsel of The NORDAM Group, Inc., headquartered in Tulsa. For 36 years, Mr. Givray has devoted his legal work to aviation: the leasing and financing of helicopters and fixed-wing aircraft; the acquisition and divestiture of aviation businesses and assets; the formation of aviation joint ventures; the development, certification, manufacture, sale, maintenance, repair, and overhaul of aviation products; and aviation litigation – all inside and outside the United States. Mr. Givray holds his J.D. and M.B.A degrees from the Cornell Law School and Cornell’s Johnson Graduate School of Management, as well as his B.S. in Engineering from Cornell’s School of Operations Research. He has also been named in Best Lawyers in America--Aviation. As Mr. Givray likes to say, "If it flies and it's not a bird, we can do the legal work."
Al Givray is a partner in the Denver law firm of Davis Graham & Stubbs. He is also General Counsel …
Caroline is co-chair of our Tax Group. She has extensive experience in advising both domestic and international companies on structuring their tax affairs for various types of transactions, including tax planning, such as IP structures, efficient cash extraction methods, advising on tax aspects of M&A transactions, loan portfolio transactions, restructuring, and financing structures, including aircraft and equipment leasing. Caroline also leads our Asia Pacific Group.
Caroline is co-chair of our Tax Group. She has extensive experience in advising both domestic and international companies on structuring …
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Method of Presentation:
Experience in Basic Knowledge in Aviation Finance and International Tax Reform
NY Category of CLE Credit:
Areas of Professional Practice
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About Davis Graham & Stubbs LLP
The Davis Graham & Stubbs aviation law group is a unique alternative to large leasing and finance law firms. They’re a small group of veterans who have been practicing aviation law for decades. One of them also serves as General Counsel to a company that manufactures and repairs aircraft components as a tier 1 supplier to airframe and engine makers, and to operators of large fleets. This role gives them a keen insight on how to satisfy client objectives efficiently. They also have a specialized knowledge about helicopters and fixed-wing aircraft leased and financed throughout the world. The firm’s aviation clients have presence in six continents, so the group has working relationships with local experts to support leasing and financing in many countries. Whether it's about the rules of the FAA, treaties like the Cape Town Convention, industry practices, or about the clauses that should be in your deal documents, DGS lawyers can recommend what's worth worrying about from the legal end, and what's not worth the bother. You can read more about the DGS aviation group at https://www.dgslaw.com/expertise/aviation.
About Arthur Cox
Arthur Cox is one of Ireland's largest law firms. We are an "all-island" law firm with offices in Dublin and Belfast. The firm also has offices in London, New York and Silicon Valley. Our practice encompasses all aspects of corporate and business law.
For almost 100 years, we have been at the forefront of developments in the legal profession in Ireland. From the outset, we have striven to deliver superior levels of service, building relationships that grow over time and developing specialist industry knowledge to help our clients achieve their goals.