International Investments: The 2017 National Superannuation Conference

The Trump administration continues to create uncertainty for investors. Now more than six months into his presidency, advisers are still unclear on the long term policy direction of the new administration and its effect on investments made by Australian superannuation funds.

Significant issues affecting due diligence of international investments by large superannuation funds range from the US tax treatment of investments to laws enacted under the Obama administration, including the Protecting Americans from Tax Hikes (PATH) Act, and older laws like the Foreign Investment in Real Property Tax Act (FIRPTA).

At the 2017 National Superannuation Conference, PwC’s Jeff Miller, Makoto Takahashi and Todd Chesla all fly in from the US to present the session ‘International Investments’.

Jeff Miller and Makoto Takahashi
Reviewing current significant issues affecting international investments by large funds, they will cover the recent and proposed US tax reform and the issues for Australian funds investing in the U.S.

Jeff said “We’ll be looking to cover off the latest on US tax law changes, recent issues in Qualified Foreign Pension fund developments, and provide an update on The latest on US tax filing requirements.”

Makoto told us, “In the session, I’ll be taking a practical approach to dealing with U.S. tax compliance and U.S. investment and structuring. Delegates will hear about the issues that occur when dealing with tax compliance, investment and structuring, and leave with a better understanding of compliance issues and investment structuring developments, including QFP.”

Asked about what the year ahead holds, Jeff told us “In the coming financial year, I predict many funds are going to be looking into more U.S. investments, and when doing so they need to be aware of potential IRS audits of tax withholding as well as ATO audits on FITO, including U.S. tax returns.” Makoto said “As I see it, it will be a period of continued uncertainty in global tax strategies, especially around potential Trump Tax Reform, which I’ll be covering in the session.”

Jeff Miller is an International Tax Partner in the San Francisco office of PwC with over 20 years of U.S. tax experience, and two working in London, he has a background in serving financial services clients and most recently providing assistance to a number of Australian superannuation funds & Investment Advisors as well as similarly situated clients in other jurisdictions.

Makoto Takahashi, is a Tax Director at PwC in San Francisco. He has been assisting U.S. tax compliance and consulting for a number of superannuation clients past 10 years, and his specialities include state and local taxes and also U.S. investments by Australian and other non-U.S. investors.

Jeff and Makoto are joined by International Tax Director Todd Chesla for their session, taking place in the Large Funds stream of the conference.


The 2017 National Superannuation Conference takes place 24-25 August, in Sydney. Find out more about the program on our website.

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