36th Annual International Tax Conference
January 11-12, 2018
1109 Brickell Avenue
Miami, FL 33131
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
9:05 – 10:30 a.m.
International Inbound Taxation
Scott A. Bowman, Partner | Proskauer Rose LLP | Boca Raton
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
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
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