International Tax Conference - Tax Law Section - Florida Bar - Tax Law Section - Florida Bar

 

36th Annual International Tax Conference

January 11-12, 2018

(Please note: The 3rd Annual International Tax Boot Camp begins on January 10, 2018)

CLICK HERE TO REGISTER ONLINE

Hotel Information

JW Marriott

1109 Brickell Avenue

Miami, FL 33131

1-800-228-9290 (Reservations)

Online Reservation

 

Boot Camp Agenda (January 10, 2018)

International Tax Boot Camp – January 10, 2018

9:00 – 9:05 a.m. Introductions and Opening Remarks

Lawrence J. Chastang

Steven Hadjilogiou

9:05 – 10:30 a.m.

International Inbound Taxation

Scott A. Bowman, Partner | Proskauer Rose LLP | Boca Raton

Arthur Ditcher

10:30 – 10:50 a.m.     Networking Break

10:50 a.m. – 12:25 p.m.

International Inbound Taxation (continued)

Scott A. Bowman, Partner | Proskauer Rose LLP | Boca Raton

Arthur Ditcher

12:25 – 1:40 p.m.     Lunch

1:40 – 3:40 p.m.

International Outbound Session

William B. Sherman

Kevin E. Packman

3:40 – 4:00 p.m.     Networking Break

4:00 – 5:00 p.m.

Tips to Take Home: What’s New with International Tax Forms

This presentation will provide practical tips for the international tax practitioner regarding various inbound disclosure forms, including ways to avoid common errors in their completion.

David A. Cumberland, CPA, CGMA, Tax Manager | Kerkering, Barberio & Company, CPA | Sarasota, FL

Amy Fondo, Principal | CliftonLarsonAllen, LLP

 

International Tax Conference Agenda (January 11-12, 2018)

Day 1 – January 11, 2018

7:30 – 8:45 a.m. Check-In & Breakfast

8:45 – 9:00 a.m. Introductions and Opening Remarks

Lawrence J. Chastang

Steven Hadjilogiou

9:00 – 9:50 a.m.

Current Developments in International Taxation – Outbound Update

This session will review significant statutory, regulatory, administrative, and judicial developments in U.S. outbound international taxation that occurred during 2017.

Larry R. Kemm, Esq. | Carlton Fields Jorden Burt, P.A. | Tampa

9:50 – 10:40 a.m.

Timing of Income: Key Issues for the International Tax Practitioner

It is very dangerous for an international tax practitioner to operate in a vacuum and lose sight of the “general principles” of U.S. federal income taxation. A case in point is the timing of income. This presentation will highlight key timing of income issues and show how many important consequences in both the inbound and outbound contexts turn on the timing of income.

Seth J. Entin, Esq. | Shareholder | Greenberg Traurig, PA | Miami

10:40 – 11:00 a.m.     Networking Break

11:00 – 11:50 a.m.

Taxation of Cross-border Transactions Involving Digital Goods and Services: Primer and Selected Issues

This panel will begin with a high level overview of generally applicable rules governing the international taxation of transactions involving digital goods and services. In recent years, many of those rules have been re-written to target certain structures or commercial flows and as a result many US companies are facing unprecedented exposures and risks related to tax.  We will provide examples to illustrate the application of these rules, and to offer some ideas for mitigating tax risks.

Michael J. Bruno, Associate | Baker McKenzie | Miami

Erik Christenson, Partner | Baker McKenzie | San Francisco, CA

11:50 – 1:20 p.m.

Lunch Presentation – Practical Cybersecurity Tips for CPA and Law Firms

Every day the headlines cover a new cyber threat, from the latest malware to companies that have been hacked. How do you stay out of the headlines? Join me as we discuss practical ways to implement a cybersecurity program, industry trends, and how to address the latest cybersecurity threats.

Ken Stasiak, EMBA, CISSP, CISA, CGEIT, CISM, CEO | SecureState | Cleveland, OH

1:20 – 2:10 p.m.

Mitigating Life’s Two Certainties – U.S. Estate Tax and Treaty Planning for Nonresident Alien Decedents

This presentation discusses the U.S. estate tax ramifications of nonresident alien decedents owning U.S. situs property at time of death. It will cover the various U.S. estate tax treaties and the potential benefits available under those treaties along with certain associated planning pitfalls and opportunities.  It will also provide a comparison of the estate tax results of selected treaties.

Leslie A. Share, Esq. | Packman Neuwahl & Rosenberg | Miami

Renea M. Glendinning, CPA, Shareholder | Kerkering, Barberio & Co. | Miami

2:10 – 3:00 p.m.

Domestication of Foreign Trusts – Dos and Don’ts and the Ethical Considerations

Tax and non-tax issues in connection with causing a foreign trust to become a domestic trust , including a discussion of foreign private foundations, comparison of Florida trust law to other popular states for situs of the domesticated trust, and ethical considerations to domesticating trusts to avoid global disclosure requirements.

Hal J. Webb, Partner | Bilzin Sumberg Baena Price & Axelrod LLP | Miami

Jennifer J. Wioncek, Partner | Bilzin Sumberg Baena Price & Axelrod LLP | Miami

3:00 – 3:20 p.m. Networking Break

3:20 – 4:10 p.m.

FIRPTA and Non-Recognition Transactions: Planning Opportunities and Pitfalls

This panel will discuss the relationship between FIRPTA and various nonrecognition provisions, including rules relating to nonrecognition in corporate reorganizations, both in the inbound and foreign-to-foreign scenarios. The panel will highlight both traps and opportunities and will discuss different methods of planning effectively to obtain nonrecognition in everyday transactions.

Jeffrey L . Rubinger, Partner | Bilzin Sumberg | Miami

Summer Ayers LePree, Partner | Bilzin Sumberg | Miami

3:55 – 4:45 p.m.

Community Property: What’s Mine is Yours and What’s Yours is Mine, Right?

This presentation will discuss various issues that arise in international tax planning and compliance where the taxpayer is from a community property jurisdiction. These issues include, but may not be limited to, how community property impacts: income and estate tax issues, pre-immigration planning, trust drafting and the related tax issues, divorce, compliance and other areas of interest.

Alfredo R. Tamayo, Esq. | Shareholder | Packman, Neuwahl & Rosenberg | Miami

Shawn Wolf, Esq. | Packman, Neuwahl & Rosenberg | Miami

 

Day 2 – January 12, 2018

7:30 – 8:30 a.m. Breakfast

8:30 – 9:20 a.m.

Current Developments in International Taxation: “Inbound” Update Including Global Compliance and Controversy Developments

The presentation will highlight and provide practitioner comments related to two general areas: first, “inbound” U.S. statutory, regulatory, administrative and judicial developments, including selected foreign law developments; and second, U.S. and global tax compliance developments, encompassing a review of IRS/DOJ initiatives and selected foreign country voluntary disclosure programs.

William M. Sharp, Sr., Esq. | Sharp Partners P.A. | Tampa | Zurich, Switzerland | San Francisco, CA | Washington, D.C.

9:20 – 10:10 a.m.

At last, a Grecian victory! This session will examine the implications of the Tax Court case on common partnership structures for non-US investors and other planning opportunities.

Robert H. Moore, Partner | Baker McKenzie | Miami

10:10 – 10:30 a.m.     Networking Break

10:30 – 11:20 a.m.

“Hi, I just moved to the US, can you help me with my US tax planning?”

This presentation will explore the options available to non-US persons who have recently moved themselves and/or their families to the US without seeking any advance US tax planning advice.  US federal income, gift and estate tax issues and  considerations will be discussed, as well as the impact of holding various US immigrant and non-immigrant visas.

Stewart L. Kasner, Esq. | Partner | Holland & Knight LLP | Miami

Sean J. Tevel, Esq. | Associate | Holland & Knight LLP | Miami

 

11:20 a.m. – 12:10 p.m.

Panel on Miscellaneous Civil and Criminal Procedural Issues

This panel continues its tradition of providing up-to-the-minute information regarding civil and criminal international tax procedural issues affecting everyday tax practitioners and their clients. Greater emphasis will be placed on taxpayers within the jurisdiction of the Small Business/Self Employed Division of the IRS, but we will also discuss issues affecting taxpayers within the Large Business and International Division.

Robert E. Panoff, Esq. (Panel Moderator) Tax Litigator | Robert E. Panoff, PA | Miami

Select IRS and Law Enforcement Experts

12:10 – 1:30 p.m.

Lunch Presentation — International Tax in Transition

With the completion of the Base Erosion and Profit Shifting Project (BEPS) at the OECD, the signing by countries of a new Multilateral Instrument to amend bi-lateral treaties, and U.S. Tax Reform, the international tax landscape for businesses is shifting.  As the Common Reporting Standard spreads around the world and the fallout from Panama Papers continues the landscape for individual is rapidly changing, as well. Bob will address each of these issues and consider the impact that they will have on U.S. businesses engaged in cross border activities, as well as individuals with global a

Bob Stack | Managing Director | Deloitte Tax LLP | International Tax in Transition | Washington, D.C.

1:30 – 2:20 p.m.

Selling into the US Market in a Digital World:  The Interaction of Tax & Customs Law

The panel will review the interaction of tax and customs rules in non-residents’ sales of goods into the US, including implications under new business models such as online platforms, and application of the first sale rule.  It will also consider how trends including online sales, trade policy, and potential tax law changes may impact current structures.

Mindy Herzfeld, Professor & Director | LL.M. in International Tax Program, UF Law | Gainesville

Thomas G. Travis, Managing Partner | Sandler Travis & Rosenberg, P.A. | Chairman and CEO of Sandler & Travis Trade Advisory Services | Miami

Debora De Souza Correa Talutto | Group Transfer Pricing Manager | Temenos Banking Software Co. | Lake Mary

2:20 – 2:35 p.m.     Networking Break

2:35 – 3:25 p.m.

Foreign Pensions and Retirement Plans:  What Every US Tax Professional Must Know!!

This presentation will help you to analyze and properly report the ownership and participation in foreign retirement plans and pension schemes for certain US taxpayers including U.S. persons working outside of the USA, foreign executives temporarily in the USA and new arrivals to the USA from both treaty and non-treaty countries.

Lawrence J. Chastang, CPA, TEP | Chairman – Global Advisory Services | CliftonLarsonAllen LLP | Orlando

Steve K. Yeager, CPA | Principal | CliftonLarsonAllen LLP | Orlando

 

3:25 – 4:15 p.m.

Tips to Take Home: What’s New With International Tax Forms

This presentation will provide practical tips for the international tax practitioner regarding various inbound and outbound disclosure forms, including ways to avoid common errors in their completion.  Also discussed will be recent procedural changes implemented by the IRS, including an update on the ITIN renewal process.

David A. Cumberland, CPA, CGMA, Tax Manager | Kerkering, Barberio & Company, CPA | Sarasota

Amy Fondo, Principal | CliftonLarsonAllen, LLP | Orlando