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


35th Annual International Tax Conference
January 4-6, 2017
(Please note the International Tax Boot Camp begins on January 4, 2017)
Hotel Group Rate for Conference- $309.00
JW Marriott
1109 Brickell Avenue
Miami, FL 33131
1-800-228-9290 (Reservations)

Make Hotel Reservation Online





Schedule of Events:

Wednesday, January 4, 2017 – International Tax Boot Camp (CLE Credit: 7.0 hours)

The International Tax Boot Camp will provide young CPAs and attorneys a beginner-level summary of international inbound and outbound taxation. This event requires a separate registration fee.

8:00 a.m. – 9:00 a.m.

Registration and Continental Breakfast (Included)

9:05 a.m. – 12:25 p.m. (Break: 10:30 a.m. – 10:50 a.m.)

International Inbound Taxation

Scott A. Bowman

Partner | Proskauer Rose LLP | Boca Raton

Leslie A. Share, Esq.

Attorney | Packman, Neuwahl & Rosenberg | Miami

Although there has been an increase of a traditional outbound tax practice in Florida during the last decade or so, inbound direct investment remains the dominant international tax practice area in Florida and accordingly will receive the most emphasis in this presentation. This presentation will briefly summarize the basic U.S. federal income, estate and gift tax issues that affect U.S. inbound international tax planning.

12:25 p.m. – 1:35 p.m.

Lunch (Included)

1:40 p.m. – 4:00 p.m. (Break: 3:40 p.m. – 4:00 p.m.)

International Outbound Taxation

William B. Sherman

Partner | Holland & Knight, LLP | Ft Lauderdale

Kevin E. Packman

Partner | Holland & Knight, LLP | Miami

This presentation brings a different focus on outbound investment. Instead of presenting the U.S. outbound rules in the traditional context of the large U.S. based multinational, this presentation will present the outbound topic in a context more often seen in Florida, that of members of a U.S. family encountering the outbound rules in a closely held business. This presentation will briefly summarize the basic U.S. federal income, estate and gift tax issues that affect U.S. federal income tax issues that affect outbound international tax planning.

4:00 p.m. – 4:50 p.m.

International Tax Forms

Renea M. Glendinning, CLU, CPA

Shareholder | Kerkering, Barberio & Company, CPA | Sarasota

Amy Fondo

Principal | CliftonLarsonAllen | Orlando

David A. Cumberland, CGMA, CPA

Tax Manager | Kerkering, Barberio & Company, CPA | Sarasota

These presentations 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.

5:00 p.m. – 6:00 p.m.

Networking Reception (Included)

Thursday, January 5, 2017

7:30 a.m. – 8:45 a.m.

Registration and Continental Breakfast (Included)

8:45 a.m. – 9:00 a.m.

Introductions and Opening Remarks

Lawrence J. Chastang, CPA

Managing Partner | Clifton Larson Allen | Orlando

Steven Hadjilogiou

Partner | Baker & McKenzie, LLP (Mellon Financial Center) | Miami

9:00 a.m. – 9:50 a.m.

Current Developments in International Taxation –Outbound Update

Larry R. Kemm, Esq.

Partner | Harrison Kemm, P.A. | Tampa

This session will review significant statutory, regulatory, administrative and judicial developments in U.S. outbound international taxation that occurred during 2016.

9:50 a.m. – 11:00 a.m. (Break: 10:40 a.m. – 11:00 a.m.)

Characterizing Income: Why It is So Important for the International Tax Practitioner

Seth J. Entin, Esq.

Shareholder | Greenberg Traurig, PA | Miami

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 characterization of income. This presentation will highlight key characterization of income issues and show how many important consequences in both the inbound and outbound contexts turn on how the income in question is characterized. This presentation will also provide multiple examples of how a change in the character of income can result in adverse or favorable consequences.

11:00 a.m. – 11:50 a.m.

Is the United States the Dominant Financial Haven of the World?

Denis A. Kleinfeld, CPA, JD

Of Counsel | Fuerst Ittleman David & Joseph, PL | Miami

The world is full of competing tax havens; asset protection jurisdictions; banking and investment states; and wealth management destinations. Every country wants and needs to attract and keep wealth. Capital is the lifeblood of every economy. Learn why and how the United States positions itself as the dominant country in the global economic contest for capital and financial success.

11:50 a.m. – 1:20 p.m.(Included)

Lunch Presentation: The U.S. as an Asset Hiding Haven – Selected Ethics and Related Issues Michael Lampert, Esq.

Attorney | Law Offices of Michael A. Lampert, PA | West Palm Beach

Shawn P. Wolf, Esq.

Attorney/Shareholder | Packman, Neuwahl & Rosenberg, PA | Miami

Much has been written about asset protection and privacy. There is even a BNA Tax Management Portfolio on the topic. There are also many articles and seminars on the ethics and related issues in undertaking asset protection planning. In addition, there are articles that address helping clients hide assets – particularly in the divorce arena. But what about the offshore client that wants to “hide” money in the U.S. or to engage the services of U.S. attorneys to “hide” funds domestically or internationally. This presentation will touch on some of the myriad of ethics and related issues.

1:20 p.m. – 2:10 p.m.

An Overview of the Permitted Activities Under the U.S. Embargo and Taxation of U.S. Investment into Cuba Pedro A. Freyre

Partner – Chair, International Practice | Akerman LLP | Miami

Michael J. Bruno

Associate | Baker & McKenzie, LLP (Mellon Financial Center) | Miami

Join us as we cover the U.S. tax options for U.S. companies that are permitted to do business in Cuba. We’ll discuss the permitted activities under the U.S. Embargo and how best to address U.S. tax challenges for an operation in Cuba. Finally, we will outline the Cuban taxes that can generally apply to a U.S. company and how best to mitigate them.

2:10 p.m. – 3:20 p.m. (Break: 3:00 p.m. – 3:20 p.m.)

Tax Planning with Cross-Border Loans – Successfully Navigating Around the Proposed Section 385 Regulations

James H. Barrett

Partner | Baker & McKenzie, LLP (Mellon Financial Center) | Miami

Jeffrey L. Rubinger, Esq.

Partner | Bilzin Sumberg Baena Price & Axelrod, LLP | Miami

We will cover the inbound and outbound tax consequences of the Proposed Section 385 debt/equity rules. Last April, the Treasury proposed debt/equity rules that broadly impact how debt and equity are classified for international transactions. These controversial proposed regulations impact inbound loans (including portfolio debt); outbound loans that are used to facilitate repatriation of profits; treaty benefitted debt; and certain foreign-to-foreign arrangements. The proposed regulations have a retroactive effective date and can readily apply to existing loans. Taxpayers are preparing now for these regulations. Our panel will review the proposed (or if issued, final) regula-tions as they apply to inbound and outbound investments, and what taxpayers can do to better prepare for these proposed regulations.

3:20 p.m. – 4:10 p.m.

Exploring International Estate Tax and Income Tax Planning Strategies Involving Issues That are Overlooked

Hal J. Webb, Esq.

Bilzin Sumberg Baena Price & Axelrod LLP | Miami

Jennifer J. Wioncek, Esq., LL.M.

Bilzin Sumberg Baena Price & Axelrod LLP | Miami

We will cover issues arising with international estate planning matters, such as planning to obtain a step-up in basis in assets held by revocable and irrevocable trusts; planning related to check-the-box elections; dealing with UNI; domestication of trust structures; challenges involved when working with foreign private foundations; and planning for clients who own valuable tangible personal property located in the U.S.

4:10 p.m. – 5:00 p.m.

Base Erosion and Profit Shifting: Key Impacts on Transfer Pricing

Barry Freeman, Ph.D.

Principal | Crowe Horwath LLP | New York, N.Y.

Joshua Johnston

Manager | Crowe Horwath LLP | Oak Brook, Ill.

This presentation will provide participants with the key impacts on the global pricing landscape as a result of the OECD’s Base Erosion and Profit Shifting project. The discussion will revolve around recommendations for policy changes with respect to the valuation of intangibles, the allocation of risk within a multinational group, transfer pricing documentation and other topics. The session will also inform on recent legislative actions, court rulings and other developments in the world of transfer pricing.

5:00 p.m. – 6:00 p.m.

Networking Reception (Included)

Friday, January 6, 2017

8:00 a.m. – 8:30 a.m.

Continental Breakfast (Included)

8:30 a.m. – 9:20 a.m.

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

William M. Sharp, Esq.

Shareholder | Sharp Partners, PA | Tampa

The presentation will technically highlight and provide practitioner commentary regarding two 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 global compliance initiatives and relevant selected foreign jurisdiction initiatives.

9:20 a.m. – 10:30 a.m. (Break: 10:10 a.m. – 10:30 a.m.)

International Partnerships: To Boldly Go Where Few Have Gone Before

Robert H. Moore

Partner | Baker & McKenzie LLP | Miami

We will examine the many uses of partnerships in the international context, exploring both inbound and outbound uses of partnerships. Discussion will include FIRPTA issues, estate tax issues and foreign tax credit issues.

10:30 a.m. – 11:20 a.m.

Hot Topics in CRS

Peter A. Cotorceanu, Esq.

CEO and Founder | | Zürich, Switzerland

Like FATCA before it, CRS is a moving target. This presentation will address the hottest topics in CRS, especially those affecting the fiduciary industry.

11:20 a.m. – 12:10 p.m.

Panel on Miscellaneous Civil and Criminal Procedural Issues

Robert E. Panoff, Esq. (Panel Moderator)

Tax Litigator | Robert E. Panoff, PA | Miami

Select IRS and Law Enforcement Experts

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.

12:10 p.m. – 1:30 p.m. (Included)

Lunch Presentation: Update from Washington, D.C.

Douglas Poms

Senior Counsel to the International Tax Counsel | U.S. Department of Treasury | Washington, D.C.

This presentation will address current developments related to international tax.

1:30 p.m. – 2:35 p.m. (Break: 2:20 p.m. – 2:35 p.m.)

More Than You Need to Know About Florida Corporate Income Tax and Sales Tax

William D. Townsend, JD

Of Counsel | Dean Mead & Dunbar | Tallahassee

Will discuss state tax traps for the unwary foreign entity; provide an introduction to Florida corporate income tax issues faced by foreign entities doing business in the state; and cover application of Florida sales taxes to business activities in the state of Florida.

2:35 p.m. – 3:25 p.m.

Life Insurance and Annuities: Effective Tools for Pre-Immigration Tax Mitigation

Michael H. Ripp, Jr.

Giordani, Swanger, Ripp, & Phillips, LLP | Austin, Texas

This presentation addresses the various applications of life insurance and annuity products for mitigating the U.S. tax consequences of immigrating to the U.S., whether temporarily or permanently, and will emphasize the use of private-placement contracts and other cost-efficient products of particular interest to the high-net-worth (HNW) immigrant.

3:25 p.m. – 4:15 p.m.

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

David A. Cumberland, CPA, CGMA

Tax Manager | Kerkering, Barberio & Company | Sarasota

Amy Fondo, CPA

Principal | CliftonLarsonAllen LLP | Orlando

Renea M. Glendinning, CPA

Shareholder | Kerkering, Barberio & Company | Sarasota

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. We will also discuss recent procedural changes implemented by the IRS, including an update on the ITIN renewal process.