International Tax Conference (ITC)

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Thursday, January 11, 2018
Registration & Continental Breakfast

Introduction & Opening Remarks

Thursday Morning General Sessions

Current Developments in International Taxation – Outbound Update (Credits: 1.0 TB)

Larry R. Kemm, Esq
Of Counsel / Carlton Fields Jorden Burt, P.A.
Tampa, FL

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

Timing of Income: Key Issues for the International Tax Practitioner (Credits: 1.0 TB)

Seth J. Entin, Esq
Shareholder / Greenberg Traurig, PA
Miami, FL

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.

Taxation of Cross-border Transactions Involving Digital Goods and Services: Primer and Selected Issues (Credits: 1.0 TB)

Michael J. Bruno
Associate / Baker McKenzie, LLP
Miami, FL
Erik J. Christenson
Partner / Baker McKenzie, LLP
San Francisco, CA
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

Lunch - Luncheon Presentation

Lunch Presentation - Practical Cybersecurity Tips for CPA and Law Firms (Credits: 1.0 TB)

Ken Stasiak
CEO / SecureState
Bedford Heights, OH

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. 

Thursday Afternoon General Sessions

Mitigating Life’s Two Certainties -- U.S. Estate Tax and Treaty Planning for Nonresident Alien Decedents (Credits: 1.0 TB)

Renea M. Glendinning, CPA
Shareholder / Kerkering, Barberio & Company
Sarasota, FL
Leslie A. Share, Esq
Shareholder / Packman, Neuwahl & Rosenberg, PA
Miami, FL
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.

Domestication of Foreign Trusts - Dos and Don'ts and the Ethical Considerations (Credits: 1.0 TB)

Hal J. Webb, Esq
Partner / Bilzin Sumberg Baena Price & Axelrod LLP
Miami, FL
Jennifer J. Wioncek, Esq., LL.M.
Partner / Bilzin Sumberg Baena Price & Axelrod
Miami, FL
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.

Selling into the US Market in a Digital World: The Interaction of Tax & Customs Law (Credits: 1.0 TB)

Mindy Herzfeld, LL.M.
Professor & Director / University of Florida
Gainesville, FL
Thomas G. Travis
Managing Partner / Sandler, Travis & Rosenberg PA
Miami, FL
Debora D. Correa Talutto
Group Transfer Pricing Manager / Temenos Banking Software Co.
Lake Mary, FL

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.

Community Property: What’s Mine is Yours and What’s Yours is Mine, Right? (Credits: 1.0 TB)

Shawn P. Wolf, Esq.
Attorney/Shareholder / Packman, Neuwahl & Rosenberg, PA
Miami, FL
Alfredo R. Tamayo
Shareholder / Packman, Neuwahl & Rosenberg, PA
Miami, FL
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.

Networking Reception


Sponsored by Trident Trust

Friday, January 12, 2018
Continental Breakfast
Friday Morning General Sessions

Current Developments in International Taxation: “Inbound" Update Including Global Compliance and Controversy Developments (Credits: 1.0 TB)

William M. Sharp Sr., Esq
Shareholder / Sharp Partners, PA
Tampa, FL
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.

Tax Reform and its Impact on the International Tax Practitioner (Credits: 1.0 TB)

Alan W. Granwell, Esq
Sharp Partners, PA
Tampa, FL
Robert B. Stack, Esq.
Managing Director / Deloitte & Touche LLP
Washington, DC
Robert H. Moore
Partner / Baker McKenzie, LLP Sabadell Financial Center
Miami, FL

This session will focus on the recent changes as a result of the "Tax Cuts and Jobs Act”. 

"Hi, I just moved to the US, can you help me with my US tax planning?" (Credits: 1.0 TB)

Stewart L. Kasner, Esq.
Partner / Holland & Knight, LLP
Miami, FL
Sean J. Tevel
Associate / Holland & Knight, LLP
Miami, FL
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.

Panel on Miscellaneous Civil and Criminal Procedural Issues (Credits: 1.0 TB)

Robert E. Panoff, Esq
Tax Litigator / Robert E. Panoff, PA
Miami, FL
Mark F. Daly
Senior Litigation Counsel / Department of Justice
Washington, DC
Misha A. Weitzner
St Petersburg, FL
Eric Hylton
Deputy Chief, Criminal Investigation / Internal Revenue Service
Washington, DC
Daniel N. Price
Austin, TX
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.

Lunch Presentation: International Tax in Transition (Credits: 1.0 TB)

Robert B. Stack, Esq.
Managing Director / Deloitte & Touche LLP
Washington, DC
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 activities.

Friday Afternoon General Sessions

FIRPTA and Non-Recognition Transactions: Planning Opportunities and Pitfalls (Credits: 1.0 TB)

Jeffrey L. Rubinger, Esq
Partner / Bilzin Sumberg Baena Price & Axelrod
Miami, FL
Summer Ayers LePree, Esq
Partner / Bilzin Sumberg Baena Price & Axelrod, LLP
Miami, FL

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. 

Foreign Pensions and Retirement Plans: What Every US Tax Professional Must Know!! (Credits: 1.0 TB)

Lawrence J. Chastang, CPA, TEP
Managing Partner, Chairman-Global Advisory Services / CliftonLarsonAllen, LLP
Orlando, FL
Steven K. Yeager, CPA
Principal / CliftonLarsonAllen, LLP
Orlando, FL
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.

Tips to Take Home: What's New With International Tax Forms (Credits: 1.0 TB)

Amy Fondo
Principal / CliftonLarsonAllen, LLP
Orlando, FL
David A. Cumberland, CGMA,CPA
Tax Manager / Kerkering, Barberio & Company
Sarasota, FL
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, and new reporting requirements for domestic disregarded entities.