International Tax Conference (ITC)
16.0 Credits
Member Price $1,025.00
Non-Member Price $1,275.00
Overview
45th Annual International Tax Conference (ITC)
Jan 7-8, 2027
JW Marriott Miami, Get unique accounting and legal perspectives!
The ITC is the only event in Florida that brings together accountants, attorneys, and tax professionals to network and navigate complex and evolving international tax laws, compliance requirements, and cross-border issues.
Add-on the pre-conference ITC Boot Camp, it provides a foundational understanding of inbound and outbound taxation and forms making in-depth information digestible.
Registration includes CPE as well as IRS CE Credit and CLE Credit. You must specify during registration.
These events will sell out this year - so register early!
*This conference does not qualify for group registration discounts.
CPE Credit
This group-live (non-self-study) program is designed to qualify for CPE credit under the CPE Guidelines established by the Florida Board of Accountancy under the FL DBPR.
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 9th, 2026. 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 9th, 2026. 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 3rd, 2027.
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
$329+ Taxes and Fees when you reserve by Dec. 10 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 10, 2026*
(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 7th
General Session
- Registration & Breakfast
This session is available to registrants only.
General Session
- Introductions & Opening Remarks
Lawrence Chastang, Chairman, Chastang & Partners, LLCLawrence 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
Abrahm Smith is U.S. tax attorney guiding individuals, families and companies with cross border tax issues. He is chair elect of the Tax Section of the Florida Bar and will be the Chair of the Tax Section of the Florida bar in year 2027.
This session is available to registrants only.
General Session
- Current Developments-Inbound
William Sharp Sr, Partner, Holland & Knight, LLPWilliam 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.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- CFCs -Post Death
Seth Entin, Shareholder, Greenberg Traurig, PASeth 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.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- Morning Break
This session is available to registrants only.
General Session
- A Q&A Between Jarod Koopman, Chief Tax Compliance Officer & Chief, Criminal Investigation, IRS, Washington D.C. and Robert ("Bob") E. Panoff, Esq.
Jarod Koopman, Chief Tax Compliance Officer, Chief, Criminal Investigation, Internal Revenue ServiceJarod Koopman
Jarod Koopman is the Chief of IRS Criminal Investigation (IRS-CI) and serves as the Chief Tax Compliance Officer. As Chief of IRS-CI, he oversees a worldwide staff of approximately 3,200 employees, including roughly 2,100 special agents across 18 U.S. field offices and 13 foreign countries, who investigate crimes involving tax, money laundering, public corruption, cybercrime, identity theft, narcotics trafficking, and terrorist financing.
In his role as Chief Tax Compliance Officer, he oversees approximately 25,000 personnel and provides executive oversight of IRS compliance operations across Large Business & International, Small Business/Self Employed, Tax Exempt and Government Entities, the Tax Preparer Management Office, the Whistleblower Office, and Enterprise Case Management.
Chief Koopman began his career with IRS Criminal Investigation in 2002 as a Special Agent in Rochester, NY. In 2010, he was promoted to Supervisory Special Agent in the Western District of New York. He was subsequently selected for the Accelerated Senior Leadership Program (ASLP) and advanced through positions of increasing responsibility, serving as a Senior Analyst in Washington, D.C., Assistant Special Agent in Charge in Chicago, and Special Agent in Charge in Detroit before returning to headquarters in 2016.
He led the creation and development of IRS-CI’s Cyber Crimes and Cyber & Forensic Services programs, serving as Director of each. Under his leadership, IRS-CI significantly expanded its cyber capabilities and strengthened its position as a global leader in cryptocurrency tracing and dark web investigations. Prior to his selection as Chief, he served as Director of Field Operations, overseeing all enforcement activities within the Northern area.
Chief Koopman’s work has been recognized in the bestselling book Who Is Government by Michael Lewis and featured in the Washington Post series: Cyber Sleuth - Washington Post
Robert Panoff
Bob specializes in Civil and Criminal Tax Controversies, Voluntary Disclosures, Substantive and Procedural Strategic Analysis, Compliance Investigations, Review of Proposed Tax Planning by Others for Viability, and Related Matters. He provides consulting services to other professionals and/or their firms where it is possible for them to stay engaged and be involved with solving the problem.
He is a Fellow of the American College of Tax Counsel.
He was an adjunct Professor for 25 years at the University of Miami School of Law in Federal Tax Litigation and a Member of the University of Miami School of Law Visiting Committee, the Dean’s advisory committee, for eight years. He is a past chair of both The Tax Section and the CLE Committee of the Florida Bar and is a member of the Tax Section’s Executive Council and Director’s Committee. He is also a member and past President of the Greater Miami Tax Institute and a member of the International Tax Group.
Bob is a recipient of the Florida Bar Tax Section’s Gerald T. Hart Outstanding Tax Attorney of the Year Award.
Bob was a member of the Internal Revenue Service Advisory Council ( “IRSAC”) for the 2020 to 2022 term ( SBSE Subgroup Chair for 2021 and 2022) and was also a member of IRSAC from 2005 through 2007. He was Chair of the IRS South Florida District Compliance Plan Study Group under then District Director Thomas for four years. He has been an invited guest seven times at the Judicial Conference of the United States Tax Court.
Bob is one of a select group of tax litigators who has successfully invalidated a tax regulation and may be the only person who has ever invalidated two tax regulations in the same case. See the Tax Court’s Decision in Durbin Paper Stock Co. v. Commissioner, 80 T.C. 252. Bob is also the only attorney ever to have had attorneys fees awarded and paid against the Florida Department of Revenue in a Florida corporate income tax case.
Bob is a Florida Bar Board Certified Specialist in Tax Law.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- Lunch Break
This session is available to registrants only.
General Session
- Maximizing AI In Your Practice
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- The Great Wealth Transfer
Mathew Slootsky, Associate, Baker McKenzie, LLPMathew Slootsky
Matt is an associate in Baker McKenzie’s Private Capital Group. He sits in the Miami office and focuses his practice in the areas of international tax planning, reorganizations, inbound real estate investment, trust and succession matters, and wealth management.
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
- Afternoon Break
This session is available to registrants only.
General Session
- FIRPTA 2027
Leslie Share, Of Counsel, Packman, Neuwahl & Rosenberg, PALeslie Share
Leslie A. Share is Of Counsel 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
- DOJ’s New Fraud Division - The Players, Priorities, and Criminal Tax Prosecutions
Caroline Ciraolo, Partner, Kostelanetz LLPCaroline Ciraolo
Caroline Ciraolo is a partner with Kostelanetz LLP and founder of its Washington, DC office. She served as Acting Assistant Attorney General of the U.S. Department of Justice's Tax Division. She defends clients in civil tax controversies, litigation, and criminal tax investigations and prosecutions. She also serves as an expert witness and independent mediator in tax-related proceedings. Caroline is former President of the American College of Tax Counsel, former Chair of the Civil & Criminal Tax Penalties Committee of the ABA Tax Section, and former inaugural Chair of the Loretta Collins Argrett Fellowship Program. Caroline served as an instructor with the IRS Military VITA program at Ft. George G. Meade. Caroline co-chairs the NYU Tax Controversy Forum, Cambridge Forum on International Tax & Disputes, and Financial Crime Enforcement Across Borders Conference. Caroline is an Adjunct Professor at Georgetown University Law Center (International Tax Controversies and Criminal Tax Law and Procedure). She serves on the Tax Notes Federal Council for Tax Analysts, Advisory Board for the Journal of Tax Practice and Procedure, Board of Directors for The Theodore Tannenwald, Jr. Foundation for Excellence in Tax Scholarship, Inc., and Board of Consultant Editors of the International Journal of Economic Crime.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.
The enforcement landscape is shifting rapidly as the Department of Justice restructures its approach to financial crimes. This panel provides an inside look at the DOJ’s recently launched National Fraud Enforcement Division, focusing on how its organizational changes and current enforcement priorities directly impact the investigation and prosecution of criminal tax violations. Attendees will gain critical insights into the key leadership driving enforcement actions, the specific actors and conduct under the microscope, and the cross-agency strategies being deployed to target tax evasion, offshore compliance failures, and sophisticated financial fraud. Our panel of legal experts and former prosecutors will break down what these developments mean for defense strategies, individual and corporate compliance, and risk mitigation in an era of heightened scrutiny.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- Offshore Jurisdiction Management
Hal Webb, Partner, Bilzin Sumberg Baena Price & AxelrodHal 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.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- Welcome Reception
This session is available to registrants only.
Friday, January 8th
General Session
- Breakfast
This session is available to registrants only.
General Session
- Current Developments – Outbound
Philip Hodgen, JD,LLM (TAX), HodgenLaw PCPhilip 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.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- The IRS’ Revised Voluntary Disclosure Practice and Other Options for International Reporting Issues
Daniel Price, Attorney and Managing Member, Law Offices of Daniel Price, PLLCDaniel Price
Daniel N. Price ("Dan") represents high-net-worth individuals, authors, musicians, international families, fiduciaries, family offices, and businesses in complex federal tax controversies and cross-border tax matters. His practice includes IRS examinations and appeals, tax litigation, international information-reporting and penalty matters, expatriation, tax treaty issues, voluntary disclosures, and sensitive private-client matters involving foreign trusts, pensions, investments, insurance, and more. Dan has experience defending IRS audits of Puerto Rico bona fide residents and audits of Malta pensions. Dan leverages his extensive prior government experience as an attorney and manager with the Office of Chief Counsel of the Internal Revenue Service to assist his clients. Dan also has background in ADR and serves as a mediator for tax disputes using IRS Post Appeals Mediation.Dan is an attorney licensed in Texas and New York. He is a fellow of the American College of Tax Counsel, a member of STEP, a member of the American Bar Association, and a volunteer member of the AICPA Foreign Trust Task Force.
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).
Abrahm Smith
Abrahm Smith is U.S. tax attorney guiding individuals, families and companies with cross border tax issues. He is chair elect of the Tax Section of the Florida Bar and will be the Chair of the Tax Section of the Florida bar in year 2027.
We will provide guidance on how to assist taxpayers who may not have filed or did not file correctly. This panel will discuss the IRS’ Revised Voluntary Disclosure Practice and other options for international reporting issues
1. How to clean up issues with the IRS.
2. Understanding IRS amnesty programs.
3. Understanding penalty exposure to clean up with the IRS.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- Morning Break
This session is available to registrants only.
General Session
- International Tax Disputes: Recent Cases, IRS Rulings, and Other Developments
Hale Sheppard, Partner, Eversheds SutherlandHale Sheppard
Hale E. Sheppard is a Partner and Co-Chair of the Tax Controversy and Litigation Group of Eversheds Sutherland in Atlanta. Hale defends individuals and businesses during tax audits, tax appeals, and tax litigation, involving both domestic and international issues.
Cases. Hale has participated in over 200 tax cases before the Tax Court, Courts of Appeal, District Courts, and state tax tribunals.
Administrative Rulings. In addition to resolving tax issues through litigation, Hale has obtained dozens of favorable Private Letter Rulings for clients from the IRS National Office.
Education. Hale holds five college degrees. At the University of Kansas, he earned a B.S., with distinction, M.A., with honors, and J.D. He later received an LL.M. degree in international law, with highest distinction, from the Universidad de Chile. Finally, he obtained an LL.M. degree in tax from the University of Florida, where he was a graduate tax scholar.
Awards and Recognitions. During his studies, Hale received several awards for academic excellence, including the prestigious Harry S. Truman Foundation Scholarship, Janice Dawson Quinn Tax Scholarship, Tinker Foundation Scholarship, and Senator James B. Pearson International Fellowship. Hale also served as a graduate editor of the Florida Tax Review and member of the Kansas Journal of Law & Public Policy. Professionally, Chambers USA, Legal 500, Super Lawyers, Best Lawyers in America, and other groups have recognized Hale as a leader in tax litigation for many years. He was also inducted into the American College of Tax Counsel.
Publications. Hale ranks among the most active tax writers in the country. He has published over 300 major articles in top tax journals, including Journal of Taxation, International Tax Journal, The Tax Adviser, Journal of International Taxation, Journal of Tax Practice and Procedure, Taxes Magazine, Journal of Corporate Taxation, Practical Tax Lawyer, Journal of Passthrough Entities, Tax Management International Journal, Journal of Multistate Tax & Incentives, Tax Notes International, Taxation of Exempts, Practical Tax Strategies, Corporate Business Taxation, Trust and Estates Journal, Journal of Taxation of Financial Products, Real Estate Taxation, and others. He has also published major articles in more than 20 university law reviews, both in the United States and abroad.
Activities and Affiliations. Hale has held leadership positions in many professional and civic organizations, including: (i) Journal of Taxation, Editorial Board Member, (ii) IRS-Practitioner Liaison Committee, state bar representative, (iii) Journal of Tax Practice & Procedure, Editorial Board Member, (iv) Georgia Bar Tax Section, President, (v) Georgia Bar Journal, Editorial Board Member, (vi) GSU Low-Income Taxpayer Clinic, Advisory Committee Member, (vii) Atlanta Bar Tax Section Board Member, and (viii) Forbes contributor.
Licenses. Hale is a bar member in Florida, Texas, Georgia, and Washington, DC.
Disputes with international aspects abound despite reductions in IRS personnel. This presentation will explore recent events concerning Malta pension plans, Puerto Rico tax incentives, foreign trusts, gifts from foreign persons, FBAR penalties, tricky assessment periods, and much more. Think dirty dozen listings, compliance campaigns, proposed regulations, congressional hearings, settlement initiatives, and other enforcement-related actions.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- State Tax Issues when dealing with Foreign Clients
Jeanette Moffa, Esq., Attorney, Moffa, Sutton & Donnini, PAJeanette Moffa
Jeanette Moffa is a Florida state and local tax ("SALT") lawyer based in Fort Lauderdale. Her work includes SALT planning and consulting, with an emphasis on nexus, taxability, and the application of exemptions, inclusions, and exclusions from the tax base. She also represents clients in tax controversy matters and litigation, working with state and local agencies to resolve assessment and refund disputes, and has significant administrative law experience.
Jeanette advises both public and private business entities on a wide range of Florida tax issues across numerous industries, including e-commerce and multichannel retail; digital goods and software; transportation (automotive, marine, and aviation); shipping, security, and logistics; restaurants and hospitality; construction; and manufacturing. She is an active member, speaker, and author in the state and local tax community. In addition, she is a contributing author to the Sales and Use Tax Deskbook, CCH Sales and Use Tax Treatise, and Florida Bar's Florida Administrative Practice. Her monthly Florida tax newsletter, The SALTy Orange, can be found on ww.MoffaTaxLaw.com.
H. French Brown IV
French Brown offers clients more than fourteen years of experience practicing law and lobbying in the area of state and local taxation. French specializes in all Florida taxes including sales tax, corporate income tax, motor fuels tax, communications services tax, property tax, and documentary stamp tax.
French began his legal career at the Florida Department of Revenue, quickly rising to the position of Deputy Director of the Office of Technical Assistance and Dispute Resolution. Additionally, French served as the Department of Revenue's Legislative and Cabinet Affairs Director and staffed the 2012 Communications Services Tax Working Group. In this role, he worked directly with Legislators, longstanding legislative staff, and the Governor and Cabinet offices.
Over the last ten years, Mr. Brown has been deeply involved with most major tax legislation moving through the Florida Capitol. Through his representation of some of Florida's largest trade associations and taxpayers, French has directly worked on and advocated for tax legislation to benefit both companies and taxpayers.
During that time, Mr. Brown has passed dozens of pieces of tax legislation, which have saved his clients and Floridian's billions in reduced state and local taxes. This includes more than a billion dollars in corporate income tax refund paid in 2020 and 2022, which was a result of unintended state consequences of the Federal Tax Cuts and Jobs Act. French was also instrumental in Florida adopting remote seller and marketplace facilitator provisions after the Supreme Court's 2018 Wayfair decision.
In 2018, Mr. Brown served as counsel to the successful constitutional proposal to permanently preserve the State's annual ten-percent cap on commercial property tax increases, which passed by 66.5%.
He assists his clients with Florida tax planning and controversies before the Florida Department of Revenue and local Property Appraisers, while maintaining a professional and amicable relationship with those that he used to work next to at the agency.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- Lunch Break
This session is available to registrants only.
General Session
- Update from Office of Chief Counsel
Peter Blessing, IRS Associate Chief Counsel- InternationalPeter Blessing
Mr. Blessing is the Associate Chief Counsel (International) in the office of Chief Counsel, Internal Revenue Service, Department of the Treasury. He oversees an office of approximately 95 attorneys and other professionals responsible for legal advice, guidance, and support to the IRS, Treasury, and the public on international tax issues in all procedural postures.
Prior to joining Counsel, he practiced at Shearman & Sterling LLP for many years and subsequently at KPMG LLP.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- A Tale of Two Cities: U.S. Tax Considerations for Cross-Border Families with Family Offices and Private Trust Company Structures
Alex Denault, PartnerAlex Denault
Alex M. Denault concentrates his practice on domestic and international income tax, mergers and acquisitions, and estate and gift tax planning. His clients include high-net-worth individuals and family offices, international investors, private equity firms, real estate developers, and public and private corporations. He counsels families on the formation and operation of family offices as well as onshore and offshore private trust company structures. Alex guides clients through the tax structuring of a broad range of transactions, including M&A deals, tax-free reorganizations, corporate and partnership restructurings, and joint ventures. His work also encompasses inbound real estate and business ventures for nonresident aliens, outbound structures for U.S. persons, qualified opportunity zone investments, qualified small business stock planning, and real estate development projects. In addition, Alex represents charitable organizations and private foundations on income tax matters. Alex is Board Certified in Tax Law by the Florida Bar. He earned his LL.M. in Taxation from New York University School of Law and his J.D. from the University of Florida Levin College of Law. He received his B.S. in Accounting from the University of Florida Fisher School of Accounting, along with a minor in Classical Studies.Jennifer Wioncek
Jennifer J. Wioncek is the head of Bilzin Sumberg's Tax & Private Wealth Group. She is a highly experienced tax attorney with extensive expertise in handling the tax and succession planning needs of high net worth clients for domestic and cross-border families and family offices. Her broad practice covers international and domestic tax and estate planning issues, pre-immigration tax planning, expatriation tax planning, international tax reporting and compliance, private trust company structuring, family offices, cross-border estate administration, tax structuring for real estate funds with foreign investors, and other tax structuring for investment into the United States, and the acquisition, maintenance, and sale of U.S. real estate by foreigners.Jennifer is a Fellow of the American College of Trust and Estate Counsel ("ACTEC"). She is an active member of the Society of Trust and Estate Practitioners ("STEP") with TEP recognition. Jennifer is a well sought out speaker on international and domestic topics. She is also an adjunct professor at the University of Miami School of Law Tax LLM program where she teaches multiple classes in the area of trust and estates.
This session will provide a discussion around the use of family office and private trust company structures by cross-border families, and the U.S. tax considerations that such families need to consider when structuring, operational elements, and upon potential winddown. Learn about family office set up, operation, and the law applicable to family offices and private trust companies.
Credits: 1 - Technical Business
This session is available to registrants only.
General Session
- Afternoon 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
- Tax Tips to Take Home
Mishkin Santa, JD, LL.M, TEP, Principal, The Wolf GroupMishkin 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.
Non-Member Price $1,275.00
Member Price $1,025.00