Session 1: OFFSHORE – The Tide is Changing (1 October 2019)

Session 2: ONSHORE – A Viable Option? (23 October 2019)

Session 3: Singapore Tax – Where is the Source of Income? What is Income? (14 January 2020)

Series Synopsis

Sharpen your skills at this 3-part seminar series designed to revisit the wealth management fundamentals in a fast-changing and increasingly complex world. This series will kick off with an in-depth look at the economic substance requirements, then bring attention back to the issues of determination of residency, and round off with a deep dive into the issue of income tax - what is taxable income and what are the source rules.

This must-attend series is recommended for all industry practitioners to equip and prepare them to be value-added advisors to their clients.

Register early as places are limited!

Session Programme

About Session 1: “OFFSHORE – The Tide is changing” (1 October 2019)

Once again, the international financial centres are in the spotlight with the EU and OECD tax transparency drive. The economic substance requirements caused a stir but how does it impact the wealth management industry?

In this session, we will examine the following issues:

• What are the rules on economic substance requirements?
• Which jurisdictions are affected by the requirements?
• Are there differing implementation rules in these jurisdictions?
• What is the impact on entities classified as "holding business" - standalone entities, subsidiaries, trust underlying companies?
• What are the options for families and trustees –

1. Comply and build substance – what is adequate today and in the near future?
2. tax residence – can the entity truly be tax resident offshore?
3. Moving from 'offshore' to 'onshore' - what would be the concerns?

About Session 2: “ONSHORE – A Viable Option?” (23 October 2019)

With the international financial centres progressively implementing the economic substance requirements, is going ‘onshore’ a viable option to replace an ‘offshore’ jurisdiction? Singapore companies and structures are in vogue.

In this session, we want to examine, among other things, the intricacies of tax presence and the concept of “tax residency” from a Singapore income tax perspective:

• Principles to determine tax residence of any company
• Overview of income tax principles in Singapore
• Consider a scenario of a Singapore company having a permanent establishment outside Singapore, how would it impact the tax presence of the company if it is an investment holding company or a trust underlying company
• The use of Singapore company - what are the additional administrative requirements compared to traditional offshore companies? Is it worth the extra effort?

About Session 3: “Singapore Tax – Where is the Source of Income? What is Income?” (14 January 2020)

As we determine the tax residency of a company, it is imperative to grasp the income source rules under the Singapore income tax law and appreciates its complexities.

This session will also delve into the fund management tax exemptions for various categories of income under Section 13 of the Singapore Income Tax Act. 

• The fundamentals of determining a source of income with examples of bankable assets and business income
• Tax treatment of income of asset holding companies tax resident in Singapore – is the tax treatment of passive income from portfolio gains as plain vanilla as many regard it today? What is considered trading income?
• Section 13 tax exemptions such as 13X, 13R, 13CA, and how they are relevant to families and trustees
• What are some potential traps of source rules?

About the Speakers:	Mr Thomas Granger – Partner, Walkers (Singapore) LLP  Thomas Granger is a Partner in the Investment Funds Group in Walkers' Singapore office. Thomas specialises in corporate work with an emphasis on investment funds and private equity matters. Thomas has extensive knowledge of the hedge funds and private equity market in Asia Pacific and in particular advises clients on public and private offerings in the region. Thomas advises investment managers, investment banks, private equity funds and corporates on private equity investment, fund formation, regulatory and general corporate matters. He has extensive experience with the structuring, formation and placement of investment funds, such as hedge funds, private equity funds and infrastructure funds, for Australian, Indonesian, Japanese and other Asia-Pacific clients.
	Mr Edmund Leow SC – Senior Partner, Dentons Rodyk & Davidson LLP Edmund is a senior partner heading up the firm’s Tax practice with three decades of experience in advising multinational organisations on cross-border tax planning, transfer pricing and tax disputes. He also advises on international trade issues such as customs, WTO and free-trade agreements. He also leads the firm’s Trust, Estates and Wealth Preservation practice and advises high net worth individuals, private banks and trust companies in personal tax, as well as in trust and estate planning matters. Edmund was invited by the government to serve as a Judicial Commissioner at the Supreme Court and served from 2013 to 2016. On stepping down, he was appointed Senior Counsel in 2017, making him the first and only Tax and Trust lawyer to be given this accolade nationwide. Edmund is the President and an honorary member of the Singapore Trustees Association (STA). He is a co-founder of the STA, and previously served as its President from 2004 to 2008, then as Vice President from 2008 to 2013. He was elected President again this year. The STA represents the interests of trust companies in Singapore. In addition, he has been appointed Deputy Chairman of the Income Tax Board of Review, which is a statutory tribunal which hears income tax disputes between the Inland Revenue Authority of Singapore and taxpayers.
	Mr Gurbachan Singh – Managing Partner, GSM Law LLP Gurbachan Singh is the managing partner of GSM Law LLP, a boutique law firm specialising in tax and trust matters. He is regarded as one of Singapore’s leading tax lawyers and is consistently ranked highly in legal publications such as Asia Pacific Legal 500. Mr Singh has over 40 years of tax experience. He sits on the boards of numerous companies and is a member of a number of professional associations and societies.
About the Chairpersons:	Mr Lionel Choi – Managing Director, LGT Bank (Singapore) Ltd Lionel Choi is Managing Director with the Wealth Planning team of LGT Asia, responsible for assisting clients on all aspects of succession planning as well as residency relocation needs of clients. Prior to joining LGT, he led the Singapore trust company of a reputable global, bank-owned trust business as its resident director and manager. He specialised in establishing and administering trust and fiduciary structures. He was responsible for the operation and supervision of a client relationship team and managing private clients’ estate planning interests. He also took an active role in business development, working closely with professional advisors in Singapore and internationally. Lionel began a career in law after graduating from the National University of Singapore with an LL.B (Hons) degree. He qualified as an advocate and solicitor in Singapore in 2000, practising in an international law firm. He also qualified as a solicitor in England and Wales in 2003.
	Ms Goh Seow Chee – Branch Committee Member, STEP Singapore Seow Chee has spent more than 20 years in the tax and financial services industry specialising in tax investigation, trust and family succession planning. Her expertise centres on advising families on their succession planning, philanthropic effort and sustainable investing. She is adept in formulating their family offices and governance processes. In the most recent years, Seow Chee has been sharpening her focus on the family office space, supporting Singapore and international clients. She is currently an independent consultant. Seow Chee was the Managing Director and Head of Wealth Advisory South East Asia at J P Morgan Private Bank, Singapore. She had previously held senior positions in HSBC Trustee Singapore and Equity Trust Singapore (now known as TMF Group). She started her career with Inland Revenue of Singapore as a tax investigator.

REGISTRATION FEES

Practice Area: Private Client  Training Level: General Public CPD Points: 1 (each session)

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