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International Investments paper


This paper covers:

  • U.S. tax reform
  • FIRPTA & qualified foreign pension funds
  • due diligence of international investments
  • structuring & modelling
  • U.S. tax compliance
  • IRS audit of withholding tax & ATO audit of FITO.

Author profiles

Todd Chesla
Todd Chesla is an International Tax Director for PwC based in the New York office for the last ten years. During his time in New York, Todd has been advising leading hedge funds, private equity funds, venture capital funds, family offices of high net worth individuals and asset management divisions of global investment banks. Todd has provided these clients a broad range of international tax services including deal structuring, fund structuring, management company structuring, investor level planning, U.S. international tax planning, global diagnostic reviews and U.S. international tax compliance. - Current at 04 October 2017
Jeff Miller
Jeff Miller is an International Tax Partner in the San Francisco office of PwC with over 16 years of tax experience. Jeff began his career in Tax with PwC in St. Louis, serving the financial services industry. Jeff transferred to PwC’s London office in 1998 where he continued to serve the financial services industry in the international arena. Since 2001, Jeff has worked in the San Francisco office and has focused around the traditional sectors of banking and investment advisory, serving both US outbound as well as foreign inbound clients. Jeff advises his clients in all areas of taxation including federal income tax, withholding tax and FIRPTA. In addition to being an International Tax specialist, Jeff has a broad background in Federal Tax and has knowledge in FAS 109 and US tax compliance issues associated with off-shore and inbound structures. - Current at 04 October 2017
Makoto Takahashi
Makoto Takahasi is a Director at PwC San Francisco. He has over 15 years of tax experience and has led the tax work on a number of Australian and high profile clients. His areas of expertise include advising Australian clients and foreign-based clients on their US operations and investments, organisation structuring to enhance tax efficiency, and statutory tax compliance. Makoto provides tax advice and tax services to clients with complex tax issues. His clients include multinational companies and foreign-based clients that operate or invest in the United States. He has contributed tax articles to PwC Japan publications as well as the “International Taxation” magazine in Japan. Makoto has also presented tax seminars in various cities in the US and Japan. - Current at 04 October 2017


This was presented at 2017 National Superannuation Conference .

Get a 20% discount when you buy all the items from this event.

Individual sessions

ATO presentation: superannuation funds

Author(s):  James O'HALLORAN

Materials from this session:

Indirect taxes

Author(s):  James GORDON

Materials from this session:


Author(s):  Mark WILKINSON

Materials from this session:

Discussion with the ATO

Author(s):  Kasey MacFarlane

Materials from this session:

International Tax Planning for SMSFs

Author(s):  Denise HONEY

Materials from this session:

Where to for Retirement Incomes and Product Design?

Author(s):  Michael Rice

Materials from this session:

Further details about this event:


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