New U.S.-Mexico Cross Border Corporate Tax Challenges

Planning and Compliance Strategies After the Latest Mexican Tax Reforms

Recording of a 100-minute CPE webinar with Q&A

Conducted on Wednesday, June 3, 2009

Program Materials

This seminar will update U.S. corporate tax professionals with the latest developments in U.S.-Mexico cross-border tax compliance. The panel will provide the tools to ensure accurate compliance and minimize tax liability through effective planning.


Tax compliance with Mexico has never been more challenging for U.S. corporations. The new flat tax (IETU), which replaced the Mexican fixed asset tax (IMPAC) as of Jan. 1, 2008, is expected to draw numerous constitutional attacks.

Meanwhile, Mexico's federal tax reform law of 2007 imposes new corporate taxes on cash deposits in Mexican banks and on cash received related to loans or capital contributions as of July 1, 2008. And, U.S. state sales tax compliance aspects of Customs brokers' export certificates are difficult.

Corporate tax specialists for U.S. companies must stay current on how the latest tax laws in Mexico affect the cost of doing business there through corporations and partnerships, branch offices and maquiladora plants.

Listen as our panel of experienced tax counsel and CPAs analyzes and explains all of the most recent, relevant developments in corporate and transactional taxes for doing business in Mexico.



  1. Transfer pricing issues in Mexico
    1. Increase in audit activity
    2. New disclosure requirements in annual tax report, progress of discussions
  2. Recent cross-border tax planning developments and opportunities
    1. Changes in the Mexican withholding system
    2. IETU and eligibility for U.S. foreign tax credit
    3. Repatriation decree
  3. Mexican treaty network update
  4. Issues for maquiladoras and U.S. manufacturers
    1. Supply chain restructuring strategies
    2. Advantages of setting up a maquiladora operation
    3. Tax incentives
    4. Mexican inbound considerations and opportunities for multijurisdictional manufacturers and sales structures
  5. OECD working documents
    1. Document on restructuring
    2. Document on attribution of profits


This panel will discuss tax laws and accounting strategies on new laws and emerging developments including:

  • The new flat tax: What goes into the tax base, and how can business taxpayers qualify for credits?
  • The new tax on cash deposits: What it applies to, and how to obtain credits and offsets.
  • The 2007 tax reform law: Key changes in the corporate income tax law and preferential tax regimes (REFIPRE).
  • The 2007 maquiladora reorganization: Income and value-added tax implications.


Enrique Hernandez-Pulido
Enrique Hernandez-Pulido

Procopio Cory Hargreaves and Savitch

He specializes in international tax planning, with a focus on business and transactions between the U.S. and Mexico....  |  Read More

Simon Somohano
Simon Somohano


He has over 14 years of experience in U.S.-Mexico tax issues, with a specialty in the international planning aspects of...  |  Read More

Luis C. Carbajo
Luis C. Carbajo

Baker & McKenzie

He has practiced tax law in Mexico for over 20 years. He specializes in cross-border tax planning, VAT and indirect...  |  Read More

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