Skip to main content

International Tax Conference (ITC)

-

(Check-In )

Add to Calendar

JW Marriott Miami

1109 Brickell Ave
Miami, FL 33131

Get Directions

16.0 Credits

Member Price $895.00

Non-Member Price $1,045.00

Overview

“If you advise international clients, you cannot miss ITC.” 

Global CPAs, attorneys, and those who practice in the international tax arena know that the International Tax Conference is the only event in Florida that addresses the unique challenges and opportunities that come with practicing in this dynamic field! 

  • Attend in-person in Miami to network with 300 colleagues and professional partners. 
  • Speakers and panelists, hand-selected by the FICPA and the Tax Section of the Florida Bar, know the ins and outs of this exclusive and ever-changing field. 
  • Up to 24 CPE hours when you attend both events (8 for Bootcamp, 16 for Conference).
  • The conference venue - the JW Marriot Miami - is unsurpassed for its luxury and location.

Add on and arrive for the Jan. 21 ITC Boot Camp – a perfect introduction to our main conference. We will cover the core concepts behind inbound and outbound tax, setting you up for success in the days ahead. 

Whether you have attended ITC before or will be joining us for the first time, this conference always provides the newest and most impactful information impacting international tax.

Conference
Member Price $895     Non-Member Price $1,045

  • Includes breakfast and lunch on Jan. 22 and Jan. 23
  • Entry to all general sessions with up to 16 hours of CPE.
  • A virtual copy of the ITC Textbook.

*This conference does not qualify for group registration discounts.


CPE Credit

This conference will qualify for 16 Technical Business (TB) hours, subject to approval by the Florida Department of Business and Professional Regulation. CPE credit will be tracked with session check-ins through the Engagefully App.


CLE Credit

CLE credit is awarded by The Florida Bar. You must select you wish to earn CLE from the sessions menu during the registration process and provide the FICPA with your FL BAR number to receive your CLE course codes for self reporting.


IRS CE Credit

IRS Continued Education Credit can be awarded for participation in this conference. CE credit is reported to the IRS on the registrants behalf. You must select you wish to earn IRS CE from the sessions menu during the registration process and provide the FICPA with your PTIN within 10 days of the conclusion of the conference for the FICPA to report your CE credits.


Conference Materials & Textbook

Conference materials are available electronically as PDFs, making them easily available to view on your personal tablet, laptop or e-reader.  Download the materials in advance and enjoy the convenience by going paperless. The conference textbook will also be available to all registrants digitally to download.


Social Media

Follow the FICPA on LinkedIn, Facebook, Instagram and X, and share news about this conference using the hashtag #FICPAITC


Cancellation Policy

We love to see you commit to the ITC early, but know sometimes life forces schedules to change. If that happens, you have options. Please let our member services team know which option you select below:

  • Receive a full refund to your original payment method, transfer your balance to a future event, or place money on account by canceling before December 18th, 2025. Call or email MSC at msc@ficpa.org or call 850-224-2727.
  • Receive a partial refund to your original payment method, transfer your balance to a future event, or place money on account, minus the event cancellation fee of $150 by canceling on or after December 18th, 2025. Call or email MSC at msc@ficpa.org or call 850-224-2727.

Please review the FICPA CPE Policies for additional information: CPE Policies

*Transfers to the virtual conference livestream must be completed before the livestream registration cutoff of January 15th, 2026 by 4:00pm est.


Highlights

  • Current Developments in International Taxation
  • Outbound Update
  • Tax Mitigation
  • Inbound Financing Strategies
  • Multinational Families
  • US Beneficiaries of Foreign Trusts
  • Fraud Enforcement
  • U.S. Income Tax Treaty 
  • Tips to Take Home
  • ... And More


Prerequisites

Some familiarity with accounting and International Tax


Designed For

CPAs, accountants, attorneys and consultants practicing International Tax


Preparation

None.


Notice

JW Marriott Miami 
1109 Brickell Ave. Miami, FL 33131 
$389+ when you reserve by Dec. 31 with your emailed link. 

The event location is unsurpassed for its luxury and location in the heart of Miami's hot destination for dining, shopping, and nightlife. This iconic property has a British-styled pub on the lobby level, fine dining, and a stylish stainless-steel pool on the 7th floor. 

Hotel Cutoff Deadline: December 31, 2025*

Parking: Rates are subject to change in the new year.

Daily

  • 0-2 hours: $27.07+
  • 2-4 hours: $39.38+
  • 4-8 hours: $47.99+

Overnight $57+

***Upon completion of registration for the conference, you will receive an email confirmation with the hotel link to book your accommodation. Please note: Attendees are solely responsible for issues that may arise when rooms are booked using a third-party.

(Please note that the conference accommodations rate will sell out prior to the advertised reservation cutoff date. Reservations made after the cutoff date will be subject to availability and current room rate)


Thursday, January 22nd

General Session

- Registration & Continental Breakfast

This session is available to registrants only.

General Session

- Introductions & Opening Remarks

Lawrence Chastang, Manager and Chairman of the Board of, Chastang & Partners, LLC

Lawrence Chastang

Lawrence J. Chastang, CPA, TEP specializes in international taxation, assisting clients ranging from small entrepreneurs to major multi-national subsidiaries with their individual and corporate work. He advises on a wide range of domestic and international tax issues with clients that include multinational corporations, partnerships, and entrepreneurs, as well as foreign persons investing in the United States.

Having served international clients for more than 35 years, he has developed strong business ties in the international community. He is acknowledged as one of Florida's leading experts in international business and taxation and is fluent in Spanish and French.

Chastang & Partners is a boutique international practice with multiple offices in Central and West Florida.The firm is focused on serving global high net worth families, entrepreneurs, multi-national corporations and private equity firms.

Abrahm Smith, Partner/Shareholder, Abrahm Smith Law PLLC

Abrahm Smith

Abrahm Smith is an attorney in Miami, Florida who has practiced tax law for almost 20 years. He started as an attorney at White & Case and was a partner at Baker McKenzie before starting his own firm. He specializes in private client work for high net worth cross border families. He has a strong network of clients, service providers and professionals throughout the world.

This session is available to registrants only.

General Session

- Inbound Update (excluding OBBB)

William Sharp Sr, Partner, Holland & Knight, LLP

William Sharp Sr

William Sharp is an attorney in Holland & Knight's Atlanta, Tampa and San Francisco offices (residing in Atlanta and San Francisco) with more than 35 years of experience representing clients in a wide variety of international tax planning and tax controversy cases. Mr. Sharp provides international and domestic tax advice to numerous U.S.-based and foreign-based clients, including publicly traded and closely held entities. His tax practice also focuses on globally oriented high-net-worth clients, including many U.S. and foreign-based family offices. Mr. Sharp has served as lead counsel with respect to U.S. Tax Court proceedings, Internal Revenue Service (IRS) appeals and examination cases. He also has served as lead counsel or co-counsel to more than 1,500 IRS voluntary disclosure cases.

Mr. Sharp advises financial institutions and their clients on international tax enforcement and compliance initiatives. In addition, Mr. Sharp represents several Swiss-based banking institutions in connection with the U.S. Department of Justice Swiss Bank Program, including the largest bank participating in the program and one of the major cantonal banks (both cases were resolved under Category 3 of the program). Mr. Sharp also has extensive experience in handling matters related to the Foreign Account Tax Compliance Act (FATCA) and other cross-border compliance and disclosure initiatives.

Mr. Sharp has served as an adjunct professor at the Stetson University College of Law and a lecturer at the University of South Florida Executive MBA program. He is a frequent speaker on international tax and business law matters. In addition, Mr. Sharp has been featured as well as quoted in publications such as the Wall Street Journal, The New York Times, The Washington Post, Reuters, USA Today and other media on international tax issues.

Prior to joining Holland & Knight, Mr. Sharp was founding and managing partner of a boutique international tax law firm with offices in Tampa, San Francisco, Washington, D.C., and Zurich, Switzerland.

The presentation will explore cutting-edge “inbound” tax planning developments, including recent U.S. statutory, regulatory, administrative, and judicial developments. This session also will address significant U.S. Tax Court and federal court decisions addressing inbound and compliance issues as well as important foreign case developments, recent IRS and U.S. Department of Justice initiatives, and recent Foreign Bank Account Report (FBAR) litigation developments..

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Effectively Connected Income: The Latest and Greatest

Seth Entin, Shareholder, Greenberg Traurig, PA

Seth Entin

Seth J. Entin is a Tax shareholder in Greenberg Traurig's Miami office. He focuses his practice on the international taxation of high-net-worth individuals and families, international corporate taxation, Internal Revenue Service international tax audits, and Internal Revenue Service voluntary disclosures.

With more than 23 years of experience, Seth has earned numerous accolades. In 2016, he was recognized as "Miami Lawyer of the Year" in Tax Law by The Best Lawyers in America guide. He has also been recognized by Chambers USA— America's Leading Business Lawyers guide since 2007. Seth is currently ranked Band 1 in Tax for Florida and has been noted by Chambers for his "practical approach" and "strong knowledge base" that is always "focused on achieving the best possible results."

Seth has written for Tax Notes, Tax Notes International, Bloomberg Tax & Accounting and Law 360, and has been quoted by The Wall Street Journal and Bloomberg BusinessWeek. In addition, he is an adjunct professor of international taxation at the University of Miami School of Law and has served as Director of International Tax Law for The Florida Bar Tax Section.

A fellow of the American College of Tax Counsel, Seth regularly speaks at national and international tax conferences, including before the American Bar Association (ABA), International Bar Association (IBA), International Fiscal Association (IFA), Florida Institute of Certified Public Accountants (FICPA) and The Florida Bar. He also passed the Certified Public Accountant exam.

This presentation will address cutting-edge issues in the area of effectively connected income, in light of longstanding case law dating back decades, together with interesting and important recent developments in case law, Regulations, and IRS pronouncements.

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Morning Break

This session is available to registrants only.

General Session

- Outbound Tax Planning for OBBB

Michael Bruno, Partner / Attorney, McDermott, Will & Emery LLP

Michael Bruno

Michael J. Bruno is a Partner with McDermott, Will & Emery, LLP .  He focuses his practice on domestic and international tax planning for multinational companies, funds, and entrepreneurial families. Michael has written numberous articles on international tax planning and frequently submits comments on statutory & regulatory promulgations. As a strong proponent for pro bono legal services, Michael founded the "Transactional Equal Justice Program" with Legal Services of Greater Miami, which offers free legal advice to non-profits and low-to-moderate income small business owners, helping them to launch a business. He graduated form the University of Central Florida, BSBA, Finance and Accounting, (2009), cum laude from the University of Florida Levin College of Law (2012), and received his LL.M. in Taxation from New York University (2013).

Steven Hadjilogiou, Partner, McDermott, Will & Emery LLP

Steven Hadjilogiou

Steven Hadjilogiou focuses his practice on international inbound and outbound international tax planning for multinational companies and high net worth individuals. Steven has represented various Fortune 500 companies and major privately held businesses in their tax planning and supply chain projects, and also has substantial experience advising on transfer pricing, tax-related intellectual property matters, Subpart F and foreign investment in US real property. Steven also advises clients on pre-immigration planning and cross-border wealth succession. Steven has also worked on the taxation of partnerships and corporations, and international corporate reorganizations.

Steven is an adjunct professor of International Inbound Taxation at the University of Miami Graduate Tax Program. He is the co-chair of the annual Florida Bar/FICPA International Tax Conference. Steven has written numerous articles and presented on topics related to tax. He was a primary drafter of the amicus curiae brief submitted to the US Supreme Court on behalf of the Florida Bar Tax Section in Knight v. Commissioner in 2008.

 

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Lunch Break

This session is available to registrants only.

General Session

- Special Session Announcement Coming Soon!

 

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Special Session Announcement Coming Soon!

 

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Afternoon Break

This session is available to registrants only.

General Session

- Use of Florida Community Property Trusts for NRAs and Other Planning Options

Alfredo Tamayo, Shareholder, Packman, Neuwahl & Rosenberg, PA

Alfredo Tamayo

Shareholder
Packman, Neuwahl & Rosenberg, P.A.

Alfredo R. Tamayo is a shareholder with Packman, Neuwahl & Rosenberg, a Miami, Florida based law firm who practices in the areas of international taxation (both inbound and outbound) and general taxation, including business planning and estate planning. Alfredo particularly specializes in and devotes a large part of his practice to the Federal income taxation of international transactions involving foreign investors with U.S. businesses and investments and U.S. investors with foreign businesses and foreign investments. Alfredo received his B.S. from Villanova University, his J.D. from the Shepard Broad Law Center at Nova Southeastern University, and his LL.M in estate planning from the Villanova University School of Law. Prior to being admitted to the Florida Bar, Alfredo was a Florida certified public accountant (CPA) with 10 years of experience in public accounting primarily dealing with international tax planning and compliance issues.

Leslie Share, Shareholder, Packman, Neuwahl & Rosenberg, PA

Leslie Share

Leslie A. Share is a shareholder in Packman, Neuwahl & Rosenberg, P.A., specializing in the areas of domestic and international tax, estate and wealth preservation planning. Mr. Share has advised clients in numerous and diverse areas such as Broadway theatrical productions, domestic and foreign real estate like-kind exchanges, Internet sales, services and licensing tax planning, advanced domestic and foreign wealth preservation techniques, U.S. tax treaties, Internal Revenue Service examinations and voluntary compliance programs and preferred structures for inbound and outbound business and investment planning. Mr. Share has written for publications such as Checkpoint Catalyst, Florida Bar Journal, Asset Protection Journal, Estate Planning, Entertainment Law & Finance, the University of Florida Law Review, and an American Bar Association book entitled Foreign Investment in U.S. Real Estate—A Comprehensive Guide, along with several times being recognized as an FICPA Outstanding Discussion Leader. He has served as an Adjunct Professor and Guest Lecturer at the University of Miami Law School Graduate Program in Taxation. Les is AV rated by Martindale-Hubbell, and listed in Best Lawyers in America and Florida Super Lawyers in the field of tax law. Mr. Share received his B.A. from Northwestern University, his J.D., with honors, from the University of Florida, and his Master of Laws in Taxation from New York University.

 

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Real Estate Opportunity Zones, Tax Credits (Real Estate), Portfolio Interest

Robert Moore, Partner, Baker McKenzie, LLP

Robert Moore

Robert H. Moore's practice focuses on international tax planning for US multinational companies, both publicly traded, and private, financing structures, post-acquisition restructuring, reorganizations, wealth management, and tax controversy and litigation. Also advises foreign ultra-high net worth clients investing structuring US real estate investments. Serves as lead partner for the Miami Office's Diversity & Inclusion Committee, serves on the North America Anti-Racism Task Force. Previously served as a member of the Baker & McKenzie North America Tax Practice Group's Tax Planning and Transactions Steering Committee and Best Practices Committee. Previously served as the Managing Partner of the Miami office from 2017-2019.

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- It's 2801, Do You Know Where Your Inheritence is Coming From?

Shawn Wolf, Partner / Attorney, Bilzin Sumberg Baena Price & Axelrod

Shawn Wolf

Sought out for his reputation as a cultivator of strong, long-term client relationships, Shawn counsels foreign and domestic high net worth individuals, families and closely-held companies wherever they need international and domestic tax, estate planning, and pre-immigration and expatriation planning and strategies. Many of his clients are multi-generational in nature, spanning decades of private wealth planning needs. His Florida Bar Board Certification in Tax Law represents one of the most distinguished markers of expertise among practitioners in the private wealth planning field. 

Among the areas of his practice for which he is most approached are matters involving the application of U.S. Federal income tax rules to U.S. taxpayers conducting business abroad or moving abroad, foreign nationals investing in or moving to the United States, and the utilization of foreign and domestic trusts in strategies related to such matters. For 25 years, Shawn has also assisted hundreds of clients in coming into compliance with U.S. tax filing requirements, particularly international clients with complex situations involving multiple jurisdictions, in addition to counseling them on the minimization of applicable penalties. Finally, Shawn also assists clients in forming and operating domestic and offshore businesses, including corporations, partnerships and limited liability companies. 

An active member of the Florida Bar Tax Section, he currently serves as its Director-at-Large and previously served as Co-Director of the Long Range Planning Division, Co-Director of the Federal Tax Division, Section Administration Division, and Chair of the Outbound Tax Committee. His many years of leadership in the Tax Section recently earned him nomination as its Chair for 2023-2024.

The session will give an initial, and very general overview, of the U.S. expatriation income tax rules.  Thereafter, the focus of the presentation will be on Section 2801, the so-called U.S. inheritance tax, and will get into the details of the Regulations that were issued in early 2025. In particular, the presentation will discuss: (1) who the rules apply to; (2) how the tax is calculated; how to determine if the gift or inheritance involved is from a “covered expatriate”; and (4) other nuanced issues relevant to the application of the rule.

 

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Welcome Reception

This session is available to registrants only.

Friday, January 23rd

General Session

- Continental Breakfast

This session is available to registrants only.

General Session

- Outbound Update (Excluding OBBB)

Philip Hodgen

Philip Hodgen

Philip D. W. Hodgen is the principal attorney for Hodgen Law Group, which specializes in the international tax arena. He earned his undergraduate degree from Claremont McKenna College and his law degree from the School of Law at the University of California, Los Angeles. He then went on to earn a Master of Laws degree with a specialty in taxation from the University of San Diego School of Law. Admitted to the California bar in 1982, Mr. Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. For six years of his youth, he lived in Rhodesia, South Africa and New Zealand. Mr. Hodgen is a past chair of the International Tax Committee of the State Bar of California’s Tax Section and was a member of the Executive Committee of the State Bar of California’s Tax Section for 2004-2007. Mr. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, real estate professionals and other groups.

The OBBBA gets all of the attention, but plenty of administrative and judicial action happened in 2025 for outbound tax planning. We will review what the IRS and the courts did in 2025 that affect outbound tax planning, with selected deeper dives.

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Crypto Tax: Policy and Practice

This presentation will provide an update on crypto tax matters with a focus on both legal issues and practical tax preparation questions. In 2026, taxpayers will be receiving Forms 1099-DA for the first time but those forms will not provide cost basis information, so this presentation will provide some techniques and approaches for preparing returns, understanding tax issues, and protecting your clients interests.

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Morning Break

This session is available to registrants only.

General Session

- QSBS Expansion Under the One Beautiful Bill Act: A Global Perspective

This presentation examines Section 1202 Qualified Small Business Stock (QSBS), addressing eligibility and planning strategies, with a focus on how cross-border ownership, residency, and foreign entity structures can affect both the availability of the QSBS exclusion and related planning opportunities.

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Who's Prosecuting Tax Crimes? The Current State of Criminal Tax Enforcement

Caroline Ciraolo, Partner, Kostelanetz & Fink, LLP

Caroline Ciraolo

Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz & Fink and a founder of its Washington, D.C. office. Her practice focuses on complex and sophisticated civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation in federal and state courts and administrative tax tribunals, providing related tax advice, conducting internal investigations, consideration of domestic and foreign compliance options including voluntary disclosures, and representing individuals and institutions in criminal tax investigations and prosecutions.

Jeffrey Neiman, Partner, Marcus Neiman & Rashbaum LLP

Jeffrey Neiman

Jeffrey Neiman is an experienced trial lawyer who regularly defends individuals and corporations in white collar criminal litigation, matters involving tax controversies, government regulatory enforcement matters, internal investigations, compliance counseling, and complex civil litigation. Jeff has tried more than a dozen white collar matters in federal court. Having worked at the forefront of the United States government's offshore tax enforcement efforts, Jeff has vast experience assisting clients who nd themselves with unreported or undeclared bank accounts outside of the United States. Jeff advises clients regarding the Internal Revenue Service's Offshore Voluntary Disclosure Program as well as clients who face civil and Reports ("FBARS").

Prior to being a Founding Member of Marcus Neiman & Rashbaum LLP, Jeff had his own law firm that focused on white collar and tax controversy matters. An alum of the United States Department of Justice Attorney General's Honors Program, Jeff began his career working for the Department of Justice Tax Division and then the Criminal Division, Fraud Section in Washington, D.C. He then served as an Assistant United States Attorney for the Southern District of Florida, where he received national recognition for handling complex, high pro le matters including the ground-breaking and historic prosecution of Switzerland's largest bank, UBS AG, for aiding American citizens to commit tax fraud. For his efforts on the UBS investigation, Jeff was awarded the Attorney General's John Marshall Award for Outstanding Legal Achievement and the Internal Revenue Service Commissioner's Award, the highest recognition a prosecutor can receive.

Raised in South Florida, Jeff graduated with honors from the University of Florida and also graduated from law school at the University of Florida where he was a member of Order of the Coif. Jeff currently serves as an adjunct professor at Florida Atlantic University, where he teaches Criminal Procedure and Tax Fraud in their graduate accounting executive program. Jeff also is a frequent lecturer, panelist, and contributor at national conferences on topics including offshore tax evasion, tax fraud, Ponzi schemes and trial practice.

With Tax Division prosecutors now working for the DOJ Criminal Division, the IRS in a state of flux, and the government’s focus on fraud, waste, and abuse, taxpayers and their representatives are wondering about the state of criminal tax enforcement. Despite predictions to the contrary, IRS criminal investigation and DOJ continue to pursue criminal tax investigations involving high income non-filers, tax evasion coupled with pandemic fraud, employment tax violations coupled with immigration offenses, conspiracies to defraud the government, offshore tax schemes, and abusive tax-advantaged transactions. This panel will address recent prosecutions, lessons learned, and what we can expect in the coming years.

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Lunch Break

This session is available to registrants only.

General Session

- International Provisions of the OBBBA - JCT Perspective

This presentation will discuss the legislative history of the international tax provisions of the OBBBA, along with a brief overview of the role of the Joint Committee on Taxation in the legislative process. The presentation will also provide a legislative outlook.

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Gifting/Cash/Non-US Situs Assets

Lawrence Chastang, Manager and Chairman of the Board of, Chastang & Partners, LLC

Lawrence Chastang

Lawrence J. Chastang, CPA, TEP specializes in international taxation, assisting clients ranging from small entrepreneurs to major multi-national subsidiaries with their individual and corporate work. He advises on a wide range of domestic and international tax issues with clients that include multinational corporations, partnerships, and entrepreneurs, as well as foreign persons investing in the United States.

Having served international clients for more than 35 years, he has developed strong business ties in the international community. He is acknowledged as one of Florida's leading experts in international business and taxation and is fluent in Spanish and French.

Chastang & Partners is a boutique international practice with multiple offices in Central and West Florida.The firm is focused on serving global high net worth families, entrepreneurs, multi-national corporations and private equity firms.

Daniel Price, Attorney, Law Offices of Daniel Price, PLLC

Daniel Price

Dan's legal practice focuses on federal tax and Title 31 matters including civil and criminal defense of IRS audits and investigations. Dan also assists taxpayers in navigating the process of coming into compliance, especially international taxpayers who have for one reason or another failed to comply fully with U.S. tax and Title 31 laws. Dan's deep expertise concerning the IRS' voluntary disclosure practice, the Streamlined Filing Compliance Procedures, and international penalty regimes allows him craft strategies to mitigate civil penalties and criminal exposure.

For over 19 years Dan served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. Dan's prior government service included extensive work in the arena of international enforcement and included assisting the IRS in completely revising the Voluntary Disclosure Practice. Dan also worked with the various Offshore Voluntary Disclosure Programs, the Streamlined Filing Compliance Procedures, foreign bank account reporting, Bank Secrecy Act investigations, various LB&I compliance campaigns, expatriation issues, international collection of taxes, and much more.

Dan received his J.D., with honors, from the University of Texas School of Law. While attending law school, he passed the Uniform CPA exam (not licensed as a CPA) and was a staff member on two law journals.  

 

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Afternoon Break

This session is available to registrants only.

General Session

- Canada Panel

Hal Webb, Partner, Bilzin Sumberg Baena Price & Axelrod

Hal Webb

Hal J. Webb is a trusted advisor and counselor to high-net-worth international families. He is Head of Bilzin Sumberg's International Private Client Services and Partner in the Firm's Tax & Estate Planning Group. Hal's practice focuses on advising high-net-worth private clients in all aspects of international tax and estate planning. He also advises family offices and trust companies. Hal frequently deals with foreign trusts with U.S. beneficiaries, pre-immigration planning for foreigners moving to the U.S., large gifts and inheritances being received by U.S. persons from foreign persons or foreign estates, tax compliance and voluntary disclosures, structuring a foreign person's investment into the U.S. (particularly the acquisition of business interests and residential and commercial real estate), and expatriation planning. He also handles matters involving tax planning for foreign companies doing business in the U.S. Hal's technical expertise helps him tailor a solution which best fits the needs of his clients. Hal is discreet and highly professional. 
Hal is a frequent author and lecturer on various topics of international tax and estate planning. Additionally, he is Chair of the International Tax In-Bound Committee of The Florida Bar Tax Section, and the immediate Past Chair of the Miami Branch of STEP. Hal has consistently been recognized by legal publications and by his peers as being a top tax and estate planning lawyer, including being named in Florida Super Lawyers, Best of the Best USA, Citywealth Leaders List, Legal Week International Trusts & Private Client Elite, and Guide to the World's Leading Trusts & Estates Practitioners.

Elie Roth, Partner

Stewart Kasner, Partner, Holland & Knight, LLP

Stewart Kasner

Stewart Kasner is a partner in the Miami office of Baker & McKenzie LLP. His practice is focused primarily in the areas of international taxation, international trusts and international estates. Mr. Kasner has advised foreign clients as to the U.S. tax issues and consequences relating to their international estates, offshore trusts, U.S. sitused assets including U.S. real property interests, closely held companies both engaged and not engaged in U.S. trades or businesses, gifts to U.S. family members, U.S. reporting requirements, portfolio debt instruments, withholding taxes, international reorganizations, liquidations, and reporting requirements of qualified and nonqualified intermediaries. In addition, Mr. Kasner has advised domestic clients as to the U.S. tax issues and consequences relating to their offshore corporate and trust activities, information reporting compliance, including voluntary disclosures, investments in offshore hedge funds, offshore life insurance and annuity products, treaty benefits, taxation of foreign trusts, their grantors and beneficiaries, entity classification elections, foreign tax credits and assignments of intellectual property rights. Mr. Kasner is Board Certified in Tax Law by the Florida Bar. He is listed in the publication The Best Lawyers in America for the tax law specialty. Mr. Kasner is recognized as a leading individual in the tax law field by Chambers & Partners in the publication America’s Leading Lawyers for Business, and recognized by Euromoney in its Guide to the World’s Leading Trusts & Estates Practitioners. Mr. Kasner earned an LL.M. in Taxation from the University of Florida Fredric G. Levin College of Law Graduate Tax Program in 1998 and a J.D. cum laude from Saint Thomas University School of Law in 1997. He earned a Bachelor of Commerce in finance and international business from McGill University in Montreal, Quebec, Canada in 1991.

Credits: 1 - Technical Business

This session is available to registrants only.

General Session

- Tax Tips to Take Home

Mishkin Santa, Principal, Director of International, The Wolf Group

Mishkin Santa

Mishkin is a Principal of The Wolf Group and oversees the firm's international tax services in the areas of Offshore Voluntary Disclosure, US Exit Tax, foreign grantor and non-grantor trusts, nonresident alien taxation, international organization employee taxation, pre-immigration tax planning, and cryptocurrency.

He assists individuals and businesses with highly specialized and complex tax issues related to offshore corporations, family businesses, trusts, and retirement plans. As a former Attorney with the IRS Chief Counsel, Mishkin is well-positioned to guide clients on a range of reporting and disclosure issues. In addition, he speaks regularly at professional events sponsored by attorney and CPA groups in the US and abroad.

Before joining The Wolf Group, Mishkin was a Partner of the International Tax Division at the Krueger CPA Group. He split his time between the main office in Austin, Texas and the sister office in Zurich, Switzerland.

Outside of work, Mishkin's favorite activity is to spend time with his wife and two children. He also enjoys all things related to history, specifically Greek Mythology and the Argead Dynasty (Alexander the Great), Old Testament Bible, the rise and fall of the Roman Republic, the British Empire, and the Republic of the United States. He is also a big movie buff and fan of 80s and 90s pop culture.

This presentation offers practical tips that CPAs and attorneys can immediately apply in their practice and with their clients.  The presentation will focus on relevant and significant international and domestic tax law updates that related to complex compliance and consulting issues using real world examples and developments.

Credits: 1 - Technical Business

This session is available to registrants only.

Optional Session

- CLE Credit: Please select if you wish to receive CLE credit.

This session is available to registrants only.

Optional Session

- IRS CE Credit: Please select if you wish to receive CE credit.

Registrants are responsible for providing the FICPA with their PTIN within 10 days of the completion of the conference for IRS CE Credit reporting.

Registrants can provide their PTIN by emailing CPE@ficpa.org

This session is available to registrants only.

Optional Session

- Florida BAR: Please select if you are a member of the Florida BAR

This session is available to registrants only.

Leader(s):

Leader Bios

Abrahm Smith, Partner/Shareholder, Abrahm Smith Law PLLC

Abrahm Smith is an attorney in Miami, Florida who has practiced tax law for almost 20 years. He started as an attorney at White & Case and was a partner at Baker McKenzie before starting his own firm. He specializes in private client work for high net worth cross border families. He has a strong network of clients, service providers and professionals throughout the world.

Return to Top

Alfredo Tamayo, Shareholder, Packman, Neuwahl & Rosenberg, PA

Shareholder
Packman, Neuwahl & Rosenberg, P.A.

Alfredo R. Tamayo is a shareholder with Packman, Neuwahl & Rosenberg, a Miami, Florida based law firm who practices in the areas of international taxation (both inbound and outbound) and general taxation, including business planning and estate planning. Alfredo particularly specializes in and devotes a large part of his practice to the Federal income taxation of international transactions involving foreign investors with U.S. businesses and investments and U.S. investors with foreign businesses and foreign investments. Alfredo received his B.S. from Villanova University, his J.D. from the Shepard Broad Law Center at Nova Southeastern University, and his LL.M in estate planning from the Villanova University School of Law. Prior to being admitted to the Florida Bar, Alfredo was a Florida certified public accountant (CPA) with 10 years of experience in public accounting primarily dealing with international tax planning and compliance issues.

Return to Top

Caroline Ciraolo, Partner, Kostelanetz & Fink, LLP

Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz & Fink and a founder of its Washington, D.C. office. Her practice focuses on complex and sophisticated civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation in federal and state courts and administrative tax tribunals, providing related tax advice, conducting internal investigations, consideration of domestic and foreign compliance options including voluntary disclosures, and representing individuals and institutions in criminal tax investigations and prosecutions.

Return to Top

Daniel Price, Attorney, Law Offices of Daniel Price, PLLC

Dan's legal practice focuses on federal tax and Title 31 matters including civil and criminal defense of IRS audits and investigations. Dan also assists taxpayers in navigating the process of coming into compliance, especially international taxpayers who have for one reason or another failed to comply fully with U.S. tax and Title 31 laws. Dan's deep expertise concerning the IRS' voluntary disclosure practice, the Streamlined Filing Compliance Procedures, and international penalty regimes allows him craft strategies to mitigate civil penalties and criminal exposure.

For over 19 years Dan served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. Dan's prior government service included extensive work in the arena of international enforcement and included assisting the IRS in completely revising the Voluntary Disclosure Practice. Dan also worked with the various Offshore Voluntary Disclosure Programs, the Streamlined Filing Compliance Procedures, foreign bank account reporting, Bank Secrecy Act investigations, various LB&I compliance campaigns, expatriation issues, international collection of taxes, and much more.

Dan received his J.D., with honors, from the University of Texas School of Law. While attending law school, he passed the Uniform CPA exam (not licensed as a CPA) and was a staff member on two law journals.  

Return to Top

Hal Webb, Partner, Bilzin Sumberg Baena Price & Axelrod

Hal J. Webb is a trusted advisor and counselor to high-net-worth international families. He is Head of Bilzin Sumberg's International Private Client Services and Partner in the Firm's Tax & Estate Planning Group. Hal's practice focuses on advising high-net-worth private clients in all aspects of international tax and estate planning. He also advises family offices and trust companies. Hal frequently deals with foreign trusts with U.S. beneficiaries, pre-immigration planning for foreigners moving to the U.S., large gifts and inheritances being received by U.S. persons from foreign persons or foreign estates, tax compliance and voluntary disclosures, structuring a foreign person's investment into the U.S. (particularly the acquisition of business interests and residential and commercial real estate), and expatriation planning. He also handles matters involving tax planning for foreign companies doing business in the U.S. Hal's technical expertise helps him tailor a solution which best fits the needs of his clients. Hal is discreet and highly professional. 
Hal is a frequent author and lecturer on various topics of international tax and estate planning. Additionally, he is Chair of the International Tax In-Bound Committee of The Florida Bar Tax Section, and the immediate Past Chair of the Miami Branch of STEP. Hal has consistently been recognized by legal publications and by his peers as being a top tax and estate planning lawyer, including being named in Florida Super Lawyers, Best of the Best USA, Citywealth Leaders List, Legal Week International Trusts & Private Client Elite, and Guide to the World's Leading Trusts & Estates Practitioners.

Return to Top

Jeffrey Neiman, Partner, Marcus Neiman & Rashbaum LLP

Jeffrey Neiman is an experienced trial lawyer who regularly defends individuals and corporations in white collar criminal litigation, matters involving tax controversies, government regulatory enforcement matters, internal investigations, compliance counseling, and complex civil litigation. Jeff has tried more than a dozen white collar matters in federal court. Having worked at the forefront of the United States government's offshore tax enforcement efforts, Jeff has vast experience assisting clients who nd themselves with unreported or undeclared bank accounts outside of the United States. Jeff advises clients regarding the Internal Revenue Service's Offshore Voluntary Disclosure Program as well as clients who face civil and Reports ("FBARS").

Prior to being a Founding Member of Marcus Neiman & Rashbaum LLP, Jeff had his own law firm that focused on white collar and tax controversy matters. An alum of the United States Department of Justice Attorney General's Honors Program, Jeff began his career working for the Department of Justice Tax Division and then the Criminal Division, Fraud Section in Washington, D.C. He then served as an Assistant United States Attorney for the Southern District of Florida, where he received national recognition for handling complex, high pro le matters including the ground-breaking and historic prosecution of Switzerland's largest bank, UBS AG, for aiding American citizens to commit tax fraud. For his efforts on the UBS investigation, Jeff was awarded the Attorney General's John Marshall Award for Outstanding Legal Achievement and the Internal Revenue Service Commissioner's Award, the highest recognition a prosecutor can receive.

Raised in South Florida, Jeff graduated with honors from the University of Florida and also graduated from law school at the University of Florida where he was a member of Order of the Coif. Jeff currently serves as an adjunct professor at Florida Atlantic University, where he teaches Criminal Procedure and Tax Fraud in their graduate accounting executive program. Jeff also is a frequent lecturer, panelist, and contributor at national conferences on topics including offshore tax evasion, tax fraud, Ponzi schemes and trial practice.

Return to Top

Lawrence Chastang, Manager and Chairman of the Board of, Chastang & Partners, LLC

Lawrence J. Chastang, CPA, TEP specializes in international taxation, assisting clients ranging from small entrepreneurs to major multi-national subsidiaries with their individual and corporate work. He advises on a wide range of domestic and international tax issues with clients that include multinational corporations, partnerships, and entrepreneurs, as well as foreign persons investing in the United States.

Having served international clients for more than 35 years, he has developed strong business ties in the international community. He is acknowledged as one of Florida's leading experts in international business and taxation and is fluent in Spanish and French.

Chastang & Partners is a boutique international practice with multiple offices in Central and West Florida.The firm is focused on serving global high net worth families, entrepreneurs, multi-national corporations and private equity firms.

Return to Top

Leslie Share, Shareholder, Packman, Neuwahl & Rosenberg, PA

Leslie A. Share is a shareholder in Packman, Neuwahl & Rosenberg, P.A., specializing in the areas of domestic and international tax, estate and wealth preservation planning. Mr. Share has advised clients in numerous and diverse areas such as Broadway theatrical productions, domestic and foreign real estate like-kind exchanges, Internet sales, services and licensing tax planning, advanced domestic and foreign wealth preservation techniques, U.S. tax treaties, Internal Revenue Service examinations and voluntary compliance programs and preferred structures for inbound and outbound business and investment planning. Mr. Share has written for publications such as Checkpoint Catalyst, Florida Bar Journal, Asset Protection Journal, Estate Planning, Entertainment Law & Finance, the University of Florida Law Review, and an American Bar Association book entitled Foreign Investment in U.S. Real Estate—A Comprehensive Guide, along with several times being recognized as an FICPA Outstanding Discussion Leader. He has served as an Adjunct Professor and Guest Lecturer at the University of Miami Law School Graduate Program in Taxation. Les is AV rated by Martindale-Hubbell, and listed in Best Lawyers in America and Florida Super Lawyers in the field of tax law. Mr. Share received his B.A. from Northwestern University, his J.D., with honors, from the University of Florida, and his Master of Laws in Taxation from New York University.

Return to Top

Michael Bruno, Partner / Attorney, McDermott, Will & Emery LLP

Michael J. Bruno is a Partner with McDermott, Will & Emery, LLP .  He focuses his practice on domestic and international tax planning for multinational companies, funds, and entrepreneurial families. Michael has written numberous articles on international tax planning and frequently submits comments on statutory & regulatory promulgations. As a strong proponent for pro bono legal services, Michael founded the "Transactional Equal Justice Program" with Legal Services of Greater Miami, which offers free legal advice to non-profits and low-to-moderate income small business owners, helping them to launch a business. He graduated form the University of Central Florida, BSBA, Finance and Accounting, (2009), cum laude from the University of Florida Levin College of Law (2012), and received his LL.M. in Taxation from New York University (2013).

Return to Top

Mishkin Santa, Principal, Director of International, The Wolf Group

Mishkin is a Principal of The Wolf Group and oversees the firm's international tax services in the areas of Offshore Voluntary Disclosure, US Exit Tax, foreign grantor and non-grantor trusts, nonresident alien taxation, international organization employee taxation, pre-immigration tax planning, and cryptocurrency.

He assists individuals and businesses with highly specialized and complex tax issues related to offshore corporations, family businesses, trusts, and retirement plans. As a former Attorney with the IRS Chief Counsel, Mishkin is well-positioned to guide clients on a range of reporting and disclosure issues. In addition, he speaks regularly at professional events sponsored by attorney and CPA groups in the US and abroad.

Before joining The Wolf Group, Mishkin was a Partner of the International Tax Division at the Krueger CPA Group. He split his time between the main office in Austin, Texas and the sister office in Zurich, Switzerland.

Outside of work, Mishkin's favorite activity is to spend time with his wife and two children. He also enjoys all things related to history, specifically Greek Mythology and the Argead Dynasty (Alexander the Great), Old Testament Bible, the rise and fall of the Roman Republic, the British Empire, and the Republic of the United States. He is also a big movie buff and fan of 80s and 90s pop culture.

Return to Top

Philip Hodgen

Philip D. W. Hodgen is the principal attorney for Hodgen Law Group, which specializes in the international tax arena. He earned his undergraduate degree from Claremont McKenna College and his law degree from the School of Law at the University of California, Los Angeles. He then went on to earn a Master of Laws degree with a specialty in taxation from the University of San Diego School of Law. Admitted to the California bar in 1982, Mr. Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. For six years of his youth, he lived in Rhodesia, South Africa and New Zealand. Mr. Hodgen is a past chair of the International Tax Committee of the State Bar of California’s Tax Section and was a member of the Executive Committee of the State Bar of California’s Tax Section for 2004-2007. Mr. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, real estate professionals and other groups.

Return to Top

Robert Moore, Partner, Baker McKenzie, LLP

Robert H. Moore's practice focuses on international tax planning for US multinational companies, both publicly traded, and private, financing structures, post-acquisition restructuring, reorganizations, wealth management, and tax controversy and litigation. Also advises foreign ultra-high net worth clients investing structuring US real estate investments. Serves as lead partner for the Miami Office's Diversity & Inclusion Committee, serves on the North America Anti-Racism Task Force. Previously served as a member of the Baker & McKenzie North America Tax Practice Group's Tax Planning and Transactions Steering Committee and Best Practices Committee. Previously served as the Managing Partner of the Miami office from 2017-2019.

Return to Top

Seth Entin, Shareholder, Greenberg Traurig, PA

Seth J. Entin is a Tax shareholder in Greenberg Traurig's Miami office. He focuses his practice on the international taxation of high-net-worth individuals and families, international corporate taxation, Internal Revenue Service international tax audits, and Internal Revenue Service voluntary disclosures.

With more than 23 years of experience, Seth has earned numerous accolades. In 2016, he was recognized as "Miami Lawyer of the Year" in Tax Law by The Best Lawyers in America guide. He has also been recognized by Chambers USA— America's Leading Business Lawyers guide since 2007. Seth is currently ranked Band 1 in Tax for Florida and has been noted by Chambers for his "practical approach" and "strong knowledge base" that is always "focused on achieving the best possible results."

Seth has written for Tax Notes, Tax Notes International, Bloomberg Tax & Accounting and Law 360, and has been quoted by The Wall Street Journal and Bloomberg BusinessWeek. In addition, he is an adjunct professor of international taxation at the University of Miami School of Law and has served as Director of International Tax Law for The Florida Bar Tax Section.

A fellow of the American College of Tax Counsel, Seth regularly speaks at national and international tax conferences, including before the American Bar Association (ABA), International Bar Association (IBA), International Fiscal Association (IFA), Florida Institute of Certified Public Accountants (FICPA) and The Florida Bar. He also passed the Certified Public Accountant exam.

Return to Top

Shawn Wolf, Partner / Attorney, Bilzin Sumberg Baena Price & Axelrod

Sought out for his reputation as a cultivator of strong, long-term client relationships, Shawn counsels foreign and domestic high net worth individuals, families and closely-held companies wherever they need international and domestic tax, estate planning, and pre-immigration and expatriation planning and strategies. Many of his clients are multi-generational in nature, spanning decades of private wealth planning needs. His Florida Bar Board Certification in Tax Law represents one of the most distinguished markers of expertise among practitioners in the private wealth planning field. 

Among the areas of his practice for which he is most approached are matters involving the application of U.S. Federal income tax rules to U.S. taxpayers conducting business abroad or moving abroad, foreign nationals investing in or moving to the United States, and the utilization of foreign and domestic trusts in strategies related to such matters. For 25 years, Shawn has also assisted hundreds of clients in coming into compliance with U.S. tax filing requirements, particularly international clients with complex situations involving multiple jurisdictions, in addition to counseling them on the minimization of applicable penalties. Finally, Shawn also assists clients in forming and operating domestic and offshore businesses, including corporations, partnerships and limited liability companies. 

An active member of the Florida Bar Tax Section, he currently serves as its Director-at-Large and previously served as Co-Director of the Long Range Planning Division, Co-Director of the Federal Tax Division, Section Administration Division, and Chair of the Outbound Tax Committee. His many years of leadership in the Tax Section recently earned him nomination as its Chair for 2023-2024.

Return to Top

Steven Hadjilogiou, Partner, McDermott, Will & Emery LLP

Steven Hadjilogiou focuses his practice on international inbound and outbound international tax planning for multinational companies and high net worth individuals. Steven has represented various Fortune 500 companies and major privately held businesses in their tax planning and supply chain projects, and also has substantial experience advising on transfer pricing, tax-related intellectual property matters, Subpart F and foreign investment in US real property. Steven also advises clients on pre-immigration planning and cross-border wealth succession. Steven has also worked on the taxation of partnerships and corporations, and international corporate reorganizations.

Steven is an adjunct professor of International Inbound Taxation at the University of Miami Graduate Tax Program. He is the co-chair of the annual Florida Bar/FICPA International Tax Conference. Steven has written numerous articles and presented on topics related to tax. He was a primary drafter of the amicus curiae brief submitted to the US Supreme Court on behalf of the Florida Bar Tax Section in Knight v. Commissioner in 2008.

Return to Top

Stewart Kasner, Partner, Holland & Knight, LLP

Stewart Kasner is a partner in the Miami office of Baker & McKenzie LLP. His practice is focused primarily in the areas of international taxation, international trusts and international estates. Mr. Kasner has advised foreign clients as to the U.S. tax issues and consequences relating to their international estates, offshore trusts, U.S. sitused assets including U.S. real property interests, closely held companies both engaged and not engaged in U.S. trades or businesses, gifts to U.S. family members, U.S. reporting requirements, portfolio debt instruments, withholding taxes, international reorganizations, liquidations, and reporting requirements of qualified and nonqualified intermediaries. In addition, Mr. Kasner has advised domestic clients as to the U.S. tax issues and consequences relating to their offshore corporate and trust activities, information reporting compliance, including voluntary disclosures, investments in offshore hedge funds, offshore life insurance and annuity products, treaty benefits, taxation of foreign trusts, their grantors and beneficiaries, entity classification elections, foreign tax credits and assignments of intellectual property rights. Mr. Kasner is Board Certified in Tax Law by the Florida Bar. He is listed in the publication The Best Lawyers in America for the tax law specialty. Mr. Kasner is recognized as a leading individual in the tax law field by Chambers & Partners in the publication America’s Leading Lawyers for Business, and recognized by Euromoney in its Guide to the World’s Leading Trusts & Estates Practitioners. Mr. Kasner earned an LL.M. in Taxation from the University of Florida Fredric G. Levin College of Law Graduate Tax Program in 1998 and a J.D. cum laude from Saint Thomas University School of Law in 1997. He earned a Bachelor of Commerce in finance and international business from McGill University in Montreal, Quebec, Canada in 1991.

Return to Top

William Sharp Sr, Partner, Holland & Knight, LLP

William Sharp is an attorney in Holland & Knight's Atlanta, Tampa and San Francisco offices (residing in Atlanta and San Francisco) with more than 35 years of experience representing clients in a wide variety of international tax planning and tax controversy cases. Mr. Sharp provides international and domestic tax advice to numerous U.S.-based and foreign-based clients, including publicly traded and closely held entities. His tax practice also focuses on globally oriented high-net-worth clients, including many U.S. and foreign-based family offices. Mr. Sharp has served as lead counsel with respect to U.S. Tax Court proceedings, Internal Revenue Service (IRS) appeals and examination cases. He also has served as lead counsel or co-counsel to more than 1,500 IRS voluntary disclosure cases.

Mr. Sharp advises financial institutions and their clients on international tax enforcement and compliance initiatives. In addition, Mr. Sharp represents several Swiss-based banking institutions in connection with the U.S. Department of Justice Swiss Bank Program, including the largest bank participating in the program and one of the major cantonal banks (both cases were resolved under Category 3 of the program). Mr. Sharp also has extensive experience in handling matters related to the Foreign Account Tax Compliance Act (FATCA) and other cross-border compliance and disclosure initiatives.

Mr. Sharp has served as an adjunct professor at the Stetson University College of Law and a lecturer at the University of South Florida Executive MBA program. He is a frequent speaker on international tax and business law matters. In addition, Mr. Sharp has been featured as well as quoted in publications such as the Wall Street Journal, The New York Times, The Washington Post, Reuters, USA Today and other media on international tax issues.

Prior to joining Holland & Knight, Mr. Sharp was founding and managing partner of a boutique international tax law firm with offices in Tampa, San Francisco, Washington, D.C., and Zurich, Switzerland.

Return to Top

Non-Member Price $1,045.00

Member Price $895.00