Tax efficient structuring of international transactions provides a unique opportunity to review systematically the interaction of United States and Latin American domestic and international tax systems. The purpose of this seminar is to address the major issues faced by tax practitioners when designing comprehensive tax planning solutions for multinational companies doing business in both the United States and Latin America. Case studies will be utilized to underscore the effect of treaties, domestic laws, and court decisions in several jurisdictions. The seminar explores principles applicable to the domestic taxation and international taxation of the United States and Latin America, in particular, permanent establishment/trade or business situations, double tax treaties, transfer pricing policies, foreign tax credit regulations, thin capitalization and CFC rules, worldwide harmonization, reorganizations and restructuring, and financing and debt restructuring. The seminar will also consider the role that European structures may play in the interaction US-LA.