International Tax Conference
Registration is Closed
Online registration for this course is now closed. Please contact the Member Service Center at (800) 342-3197 if you wish to inquire about registering.
Are You A Global CPA?
Come to the only conference in Florida for international training.
Come to the only conference in Florida for international training.
Please plan on joining us at the 38th Annual FICPA –Florida Bar International Tax Conference in Miami in January 2020. With changes and developments happening in international finance every day, there's only once conference in Florida that you can trust to provide the knowledge needed for your multinational organization or clients.
FICPA's International Tax Conference & Boot Camp is tailored specifically for international tax professionals to assist them in the various challenges they will face in this dynamic field.
ITC Boot Camp
This conference is the place to master need-to-know skills and trends in the international tax realm. At this year's Boot Camp, learn how the latest legislation affects business internationally. Recommended to all levels of tax practitioners and advisors. For more details on the ITC Boot Camp visit ficpa.org/ITCBC.
Can't Attend in Person?
No need to miss a thing! Take part in the ITC Live Stream.
CPE/CLE CreditThis conference will qualify for 16 Technical Business (TB) hours, subject to approval by the Florida Department of Business and Professional Regulation. CLE credit to be awarded by The Florida Bar. The number of CLE credit hours to be determined.
Can't attend in person?
If you can't make it to the 38th Annual International Tax Conference, we'll have the full conference available through live stream. Details to come.
NOTETo receive CPE or CLE credit, each person attending the live stream must be registered individually. Nonmember fee is waived for the 2019 International Tax Conference!
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 of going paperless.
If you prefer a hard copy Course-book, it will be available for purchase. Cost: $65 including tax.
EZMaterials Course Booklet
I will download the EZMaterials electronic course manual
I would like a hardcopy course manual for an additional $65, plus the EZMaterials electronic course manual
Thursday, January 16, 2020
Registration & Continental Breakfast
Time: Thursday 7:30am - 8:45am
Introductions & Opening Remarks
Time: Thursday 8:45am - 9:00am
Current Developments in International Taxation – Outbound Update
Time: Thursday 9:00am - 9:50am Credits: 1 TB
This session will review significant statutory, regulatory, administrative, and judicial developments in U.S. outbound international taxation that occurred during 2019.
Tax Planning with S Corporations and Hybrids After the TCJA
Time: Thursday 9:50am - 10:40am Credits: 1 TB
This presentation will explore international tax planning opportunities and traps involving the use of S corporations, with particular emphasis on changes resulting from the Tax Cuts and Jobs Act (the “TCJA”). This presentation will also explore the effect of the new "anti-hybrid" provisions of the TCJA on international tax planning structures, particularly structures affecting high net worth individuals and closely held international businesses.
Recent Developments in the Taxation of the Digital Economy
Time: Thursday 10:40am - 11:30am Credits: 1 TB
This panel will provide an overview of U.S. taxation of cross-border transactions involving software, digital goods and services, including issues that arise under recent proposed regulations on cloud computing transactions. This panel will review recent developments concerning tax and digitalization at the OECD and in select foreign countries.
Lunch Presentation: Offshore update & Comparison with the U.S: Beneficial Ownership Information and Registers, Economic Substance Legislation, & CRS
Time: Thursday 12:10pm - 1:00pm Credits: 1 TB
According to the Book of Proverbs, "Human eyes are never satisfied". The same is true of the prying eyes of government and the public when it comes to individuals' and entities' financial assets and affairs. As a result, legally mandated transparency is ever increasing, both here in the U.S. and overseas. This presentation will focus on recent developments in this area, will contrast the U.S.'s approach with the approaches taken by other countries, and will also touch on the wave of "economic substance" legislation engulfing offshore countries.
The Impact of Tax Reform on the Cross-Border Sale of a Business
Time: Thursday 1:20pm - 2:10pm Credits: 1 TB
This presentation will examine the TCJA’s effect on the sale of a business from both an inbound and outbound perspective. The inbound portion of the panel will focus in particular on the impact of new rules under Code Sections 864(c)(8) and 1446(f), while on the outbound side, relevant changes to the CFC rules, including Sections 245A, 964(e)(4), and 1248, will be covered.
Panel Discussion: Compliance Issues for the International Tax Practicioner
Time: Thursday 2:10pm - 3:00pm Credits: 1 TB
This panel will provide information regarding certain tax compliance issues affecting international tax practitioners who prepare U.S. tax returns and information forms for taxpayers involved in cross-border activities. The discussion will address certain “best practices” when preparing such returns and forms.
To Be Taxed Under GILTI,Subpart F,FDII or Flow-Through Structure,That Is The Question:US Tax Considerations For Outbound Business Invest. & Activ.
Time: Thursday 3:20pm - 4:10pm Credits: 1 TB
This presentation will provide an overview of the four US international tax regimes that are potentially applicable and available post-US tax reform to US taxpayers with respect to their non-US business investments and activities. The panelists will compare and contrast the benefits, disadvantages and burdens of the four tax regimes and discuss tax planning opportunities and considerations for structuring non-US business investments and activities for US taxpayers with respect to different types of businesses and jurisdictions.
Common Law Doctrines and Nominee Arrangements - Identifying and Reporting the "Real" Taxpayers and Transactions in International Tax Matters
Time: Thursday 4:10pm - 5:00pm Credits: 1 TB
This presentation will review a number of the most important “common law doctrines” in US tax law—"economic substance”, “sham” and “step” transactions and their application in the international tax context. It will also analyze the requirements for establishing, respecting and reporting where the titleholder to an asset acts as a nominee for its principal in the offshore planning and compliance areas. In addition, the potential effects of the TCJA upon each of these issues will be considered.
Friday, January 17, 2020
Time: Friday 7:30am - 8:30am
Current Developments in International Taxation: Inbound Tax Planning Update Including Recent Global Tax Compliance and Controversy Developments
Time: Friday 8:30am - 9:20am Credits: 1 TB
This presentation will highlight and provide practitioner comments related to two general areas: first, “inbound” U.S. statutory, regulatory, administrative and judicial developments, including selected foreign law developments; and second, a review of the past year’s most important U.S. Tax Court & Federal Court decisions addressing inbound and compliance issues, including a review of recent IRS/DOJ initiatives and recent FBAR litigation outcomes (and the current “pipeline” of pending cases).
Inbound Structuring for U.S. Real Estate - Latest and Greatest Structures and More
Time: Friday 9:20am - 10:10am Credits: 1 TB
This panel will explore recent changes under TCJA and the impact of those changes on structuring investments in U.S. real estate.
The Modern Day Closely Held Foreign Corporation - Post-Tax Reform
Time: Friday 10:30am - 11:20am Credits: 1 TB
Closely held foreign corporations face significant challenges in both classification and tax liability to U.S. shareholders. The panelists will discuss the latest developments impacting the classification of foreign corporations as Controlled Foreign Corporations (CFCs), including issues that arise because of the repeal of former Code Section 958(b)(4). Moreover, the panelists will discuss planning ideas for GILTI and Subpart F generated by closely held CFCs. Topics include the use of the 962 election, the GILTI high tax exception, corporate contributions and the use of S Corporations.
An Interview of and Discussion with Eric Hylton, Commissioner of the SBSE Operating Division of the Internal Revenue Service
Time: Friday 11:20am - 12:10pm Credits: 1 TB
Robert Panoff interviews and discusses with Commissioner Eric Hylton to gain a better understanding of SBSE's current views towards various tax procedural issues affecting international tax practitioners.
Lunch Presentation: IRS Commissioner Charles Rettig
Time: Friday 12:30pm - 1:20pm Credits: 1 TB
This session will provide a comprehensive overview of the areas of focus and concentration by the international division of the Internal Revenue Service for the coming years. It will cover the upcoming initiatives impacting the international tax professionals and discuss ways in which the IRS and the international tax professionals can work together more cohesively to deliver services demanded by taxpayers working across borders. It will also touch on offshore tax compliance initiatives and the impact this is having on increasing taxpayer compliance with current US tax laws.
Compliance Options in a Post OVDP World
Time: Friday 1:30pm - 2:20pm Credits: 1 TB
This panel will review and discuss the real world challenges and options available to international tax practitioners for the millions of US citizens and permanent residents who still have not come in from the cold….. Are they willful, reckless, grossly negligent, non-willful or somewhere else along the continuum of intent? Are they all now criminals?
Current Trends & Succession Planning for US Beneficiaries of Domestic & Foreign Trusts w/a Focus on Underlying Securities & Private Equity Investments
Time: Friday 2:35pm - 3:25pm Credits: 1 TB
A discussion of (1) succession planning for U.S. beneficiaries of foreign trusts holding underlying domestic and foreign securities and private equity investments; (2) recently proposed PFIC regulations; and (3) comparative uses of domestic trusts and (newer) foundations in connection with cross border family planning.
Tips to Take Home
Time: Friday 3:25pm - 4:15pm Credits: 1 TB
This presentation will provide practical tips for the international tax practitioner regarding various international tax issues from a compliance perspective. The discussion will include how to avoid making common errors and preparation considerations as well as suggested best practices. The topics will range from applications for ITINs (Form W-7), withholding under FIRPTA (Forms 8288-B, 8288 and 8288-A), and nonresident income tax reporting (Form 1040NR), disclosure forms (Form 5471, 5472, 8865, FINCEN 114), GILTI tax, and compliance considerations when handling expatriation compliance work.
Renea Moseley Glendinning, CPA
ShareholderKerkering, Barberio & Co.Renea M. Glendinning, CPA joined Kerkering, Barberio & Co. in 1987 and became a shareholder and has led their International Tax Department since 1997. Ms. Glendinning received her Bachelor of Arts and Master of Accountancy degrees from the College of Business Administration of the University of South Florida and has been a certified public accountant since 1984...Read more about Renea Moseley Glendinning here
Lawrence Joseph Chastang, CPA
Lawrence J. Chastang, CPA, TEP, is the Manager and Chairman of the Board of Directors for Chastang & Partners. He 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...Read more about Lawrence Joseph Chastang here
Robert E Panoff, Esq
Certified Tax AttorneyRobert E. Panoff, PARobert ("Bob") E. Panoff is a certified tax attorney specializing in representing individual and entity taxpayers in civil and criminal tax litigation matters at all levels of the IRS and in court. He is a member of the Internal Revenue Service Advisory Council (“IRSAC") for the 2020-2022 term and was previously a member of the IRSAC for the 2005-2007 term...Read more about Robert E Panoff here
William M Sharp Sr., Esq
William Sharp is a partner in Holland & Knight with more than 35 years of experience representing clients in a wide variety of international tax planning and tax controversy cases. Mr. Sharp splits his time among Holland & Knight's Atlanta, San Francisco and Tampa offices and he resides in Atlanta and San Francisco. Prior to joining Holland & Knight in 2018, Mr. Sharp was founding and managing...Read more about William M Sharp Sr. here
Seth J Entin, Esq
Seth J. Entin is a tax attorney in Holland and Knight's Miami office who focuses his practice on international taxation. Mr. Entin was named Miami Lawyer of the Year in Tax law for 2016 by "the Best Lawyers in America" guide and is ranked in Band 1 for Tax in Florida by "Chambers USA - America's leading Business Lawyers" Guide. Mr. Entin has experience handling international taxation of high-net...Read more about Seth J Entin here
Hal J. Webb, Esq
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...Read more about Hal J. Webb here
Peter A Cotorceanu, Esq
Of CounselAnaford Attorneys at LawPeter Cotorceanu is Of Counsel to Anaford Attorneys at Law in Zurich. Peter is also CEO and Founder of GATCA & Trusts Compliance Associates LLC (G&TCA) and creator of the website www.gatcaandtrusts.com. The website is tailored specifically to the fiduciary industry and to those who interact with the fiduciary industry, such as bankers and advisors. Its sole aim is...Read more about Peter A Cotorceanu here
Robert H 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...Read more about Robert H Moore here
Michael J. 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...Read more about Michael J. Bruno here
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...Read more about Steven Hadjilogiou here
Larry R Kemm, Esq
Larry Kemm’s practice focuses on international tax matters for both domestic and non-U.S. clients. With 30 years of combined practice as a tax lawyer and CPA, Larry has vast experience advising clients in structuring international transactions and business operations in a tax efficient manner, and in representing clients before the IRS in international tax disputes.Larry counsels clients on...Read more about Larry R Kemm here
David A Cumberland, CGMA,CPA
David A. Cumberland, CPA, CGMA is a tax manager with Kerkering, Barberio & Co. in Sarasota, FL. He received his Bachelor of Arts degree from the College of Business Administration of the University of South Florida. David primarily practices in the area of inbound international work covering both individual and business tax preparation and consulting. David is fluent in Spanish. He is a member of...Read more about David A Cumberland here
Leslie A Share, Esq
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...Read more about Leslie A Share here
Alfredo R Tamayo, CPA,Esq.,LLM (TAX)
ShareholderPackman, 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...Read more about Alfredo R Tamayo here
Sherwin P Simmons II
PrincipalAsgard Worldwide ServicesSherwin Simmons is a Principal of Asgard Worldwide Services where he serves as a trusted advisor to businesses and high net worth individuals with a primary focus on minimizing clients’ worldwide tax exposure. Mr. Simmons provides sophisticated wealth planning strategies as well as structuring for multi-national families, businesses and entrepreneurs. He assists...Read more about Sherwin P Simmons II here
Stewart L Kasner, Esq.
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...Read more about Stewart L Kasner here
Summer Ayers LePree, Esq
Summer LePree is a partner in Baker McKenzie's Tax Practice Group. Summer is a go-to lawyer for clients who need sophisticated, creative, international tax counsel. Summer is a frequent speaker and author on a variety of cross-border income tax issues, is actively involved in the ABA Tax Section, where she currently serves as the Council Director for the International Committees, and teaches as an...Read more about Summer Ayers LePree here
Laura Plotner, CPA,MST
Laura Plotner, CPA is a Partner, Global Services with Chastang & Parnters, LLP. She has more than 29 years of experience in public and private accounting, providing tax compliance and consulting services on a full range of tax issues. Her experience includes working with multi-state issues, international tax services, and public/SEC clients. She specializes in organization and transactional...Read more about Laura Plotner here
Michael D. Melrose
Michael Melrose is an associate in the Miami office and is a member of the Firm's Tax and Wealth Management Practice Groups. He frequently advises high net worth individuals, family offices, trust companies as well as US and foreign-based multinational corporations in relation to a variety of US and cross-border international tax, trust, and estate planning issues. Mr. Melrose received both his J...Read more about Michael D. Melrose here
Fred F Murray, CPA,Esq.,JDRead more about Fred F Murray here
Lauren E BusternaRead more about Lauren E Busterna here
Daniel N. Price
AttorneyU.S. Department of Treasury; Office of Chief Counsel of the Internal Revenue Service (SB/SE Division)Daniel N. Price is an attorney with the Office of Chief Counsel of the Internal Revenue Service (SB/SE Division) in Austin, Texas. Dan advises the IRS on national issues relating to Offshore Voluntary Disclosure Programs and the Streamlined Filing Compliance Procedures. His role in these...Read more about Daniel N. Price here
Brian H. JennRead more about Brian H. Jenn here
Arianne PlasenciaRead more about Arianne Plasencia here
Erez I TucnerRead more about Erez I Tucner here
Gennette E FaustRead more about Gennette E Faust here
CPA & CGMAUS Department of Treasury-Internal Revenue ServiceRaDel Lloyd is a CPA and Chartered Managerial Global Accountant, CGMA, with over twenty years of professional accounting experience. She has a bachelor’s and master’s degree in professional accountancy from the University of Utah and started her tax accounting career with Deloitte & Touché in 1999. RaDel joined the IRS in 2009 in their...Read more about RaDel Lloyd here
Charles P Rettig
CommissionerInternal Revenue ServiceCharles P. Rettig is the 49th Commissioner of the IRS. As Commissioner, Mr. Rettig presides over the nation’s tax system, which collects approximately $3.4 trillion in tax revenue each year. This revenue funds most government operations and public services. Mr. Rettig manages an agency of about 80,000 employees and a budget of approximately $11 billion.In...Read more about Charles P Rettig here
Commissioner, SBSE DivisionInternal Revenue ServiceEric Hylton is the Commissioner of the Small Business/Self-Employed Division of the Internal Revenue Service. He was appointed to the position in September 2019. He oversees taxpayer programs and services affecting the nation's small business and self-employed individuals. He is responsible for providing executive leadership and direction to a...Read more about Eric Hylton here