International Tax Conference
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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.
International Companies & Clients Trust You.
Global CPAs Trust Us.
Please plan on joining us at the 37th Annual FICPA –Florida Bar International Tax Conference in Miami in January 2019. With the changes as a result of the Tax Cuts and Jobs Act and subsequent changes in regulations, you really cannot afford to miss this conference. If you practice in the area of international taxation, whether your practice area is inbound, outbound or both; corporate or public practice, this conference has you covered. I guarantee you will learn something, pick up a few tips from the experts and expand your knowledge base at the same time.
This conference has grown to be one of the largest and most respected international tax conferences in the country attracting speakers not only from Florida, but from across the country and from around the world. Join us in Miami on January 10-11, 2019 for two days of intense learning while earning 16 hours of CPE.
We will also be holding on January 9, 2019 our International Tax Boot Camp- TheTax Reform Edition. This session will provide a more interactive learning environment for practitioners at all levels of experience. The changes brought about by the recent tax law changes have caused a total sea of change in international tax planning and reporting. Many of the old rules have been cast out and caused international tax advisors to relook at all existing structures for their clients as well as make significant adjustments to their planning. In prior years, this session had been focused at an intermediate level of learning compared to the advanced level of the main conference. This year, due to the changes brought about by the Tax Cuts and Jobs Act, it will fall somewhere between intermediate and advanced. I am hearing this year, many of the more seasoned practitioners are planning on attending the Boot Camp and I encourage you to attend as well.
FICPA International Taxation Chair
Chairman-Global Advisory Services
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 37th Annual International Tax Conference, we'll have the full conference available through live simulcast!
To receive CPE or CLE credit, each person attending the simulcast 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.
Thursday, January 10, 2019
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 2018.
Income Tax Planning for a Foreign Inheritance After TCJA: Working with the New Regime
Time: Thursday 9:50am - 10:40am Credits: 1 TB
Now that a year has passed since the enactment of massive international tax reform, this presentation will analyze the new rules, pitfalls, and planning strategies that apply to a U.S. person inheriting foreign companies from a nonresidential alien. This presentation will include, among other things, the effect of the repeal of the "30 day" CFC grace period and the new CFC constructive ownership rules. This presentation will also discuss how these new rules intersect with the I.S. estate tax planning that is necessary for a nonresident alien owning United States situs assets.
GILTI vs. FDII: The Epic Showdown
Time: Thursday 10:40am - 11:30am Credits: 1 TB
The Tax Cuts and Jobs Act introduced two corollary provisions into the tax code. One provision (FDII) was designed to provide a benefit to corporations that create jobs and retain assets, especially intellectual property, in the United States. The other provision (GILTI) was designed to punitively tax American owned foreign corporations that own intellectual property that generates low-taxed foreign income. The speakers will review the similarities and differences between these provisions and discuss the benefits and burdens of both provisions. Finally, the presentation will look at structuring options that may be considered by taxpayers faced with the punitive GILTI regime and taxpayers seeking to obtain the benefits of the FDII regime.
Lunch Presentations: IRS and Department of Justice Report
Time: Thursday 12:00pm - 1:00pm Credits: 1 TB
Risk Management & Immigration Strategies for the UHNW Families
Time: Thursday 1:20pm - 2:10pm Credits: 1 TB
We have unprecedented prosperity on a global level and at the same time tremendous political, social, financial and personal risk. In the past, wealthy families would look at off shore structures to protect themselves from financial risk but now that CRS and information sharing have made that more difficult, they are physically moving themselves and their assets/structures to the various corners of the world. I will discuss where, why and how are they going.
Business and Passive Investment Holding Structures for Foreign Investors After the Tax Cuts and Jobs Act - Opportunities, Traps and Tribulations
Time: Thursday 2:10pm - 3:00pm Credits: 1 TB
This presentation will review the effects of the 2017 Tax Cuts and Jobs Act on the traditional business and passive investment structures used by foreign individuals and entities in the United States. We will discuss the effect of the changes in the applicable U.S. tax rates, the new Section 199A Qualified Business Income Deduction rules for effectively-connected income (other than as relevant to U.S. real estate), using Electing Small Business Trusts (ESBTs), and various other related practical and legal considerations, including where the associated U.S. tax compliance requirements are not timely satisfied. We will also review how U.S. income tax treaties may provide significant advantages where they apply to a particular inbound planning situation.
The Intersection of International and SALT
Time: Thursday 3:20pm - 4:10pm Credits: 1 TB
This presentation will focus on the state tax treatment of the international provisions of the Tax Cuts and Jobs Act, the federal tax reform bill passed in December 2017. We will also discuss the Supreme Court’s decision in South Dakota v. Wayfair and the impact of that decision on non-US persons and businesses.
Choice of Entity Post TCJA for Doing Business Outside the United Staes
Time: Thursday 4:10pm - 5:00pm Credits: 1 TB
We will discuss the entity options for doing business outside of the United States, including pass-through entities, C Corporations doing business through a branch, and C Corporations doing business through CFCs. Our discussion will address GILTI, FDII, foreign tax credits, the new hybrid rules for entities and debt and other major changes introduced by TCJA. We will discuss IP migrations, export of goods and services, locating factories and other depreciable property outside of the United States, and other relevant issues. If an offshore business is currently being conducted by individuals using CFCs, we will discuss the benefits of imposing a US corporation into the holding structure. After our presentation, you should have a better understanding of the advantages and disadvantages of when to use partnerships and when to use corporate structures for closely held businesses operating offshore.
Friday, January 11, 2019
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
The presentation will highlight and provide practitioner comments related to two general areas: first “inbound” U.S. statutory, regulatory, administrative and judicial 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 selected foreign country tax compliance initiatives.
Inbound Structuring For U.S. Real Estate in a Post-Tax Reform World
Time: Friday 9:20am - 10:10am Credits: 1 TB
Given the changes as a result of the TCJA, in particular the lowering of the corporate rate and new pass through deduction, this session will explore what are the most efficient ways to structure inbound investment in US real estate. This session also will address the impact the TCJA had on debt financing structures, in particular the far reaching impact of the repeal of section 958(b)(4), revised section 163(j), and new section 267A.
Better Late than Never- The Use of Section 962 in Cross-Border Tax Planning
Time: Friday 10:30am - 11:20am Credits: 1 TB
This panel will discuss the increasing relevance of Section 962 elections to U.S. individual shareholders of CFCs after 2017 tax reform with respect to their Subpart F, Section 956, and GILTI inclusions. A comparison of the tax treatment of taxpayers who make such elections and those taxpayers owning shares of CFCs indirectly through actual U.S. C corporations also will be included. In addition, the presentation will cover recent IRS guidance and case law relating to Section 962 and the unanswered questions that remain.
Panel - Miscellaneous Civil & Criminal Procedural Issues
Time: Friday 11:20am - 12:10pm Credits: 1 TB
This panel continues its tradition of providing up-to-the-minute information regarding civil and criminal international tax procedural issues affecting everyday tax professionals and their clients. Greater emphasis will be placed on taxpayers within the jurisdiction of the Small Business/Self Employed Division of the IRS, but we will also discuss issues affecting taxpayers within the Large Business and International Division.
Lunch Presentation - Working Inside and Outside Government
Time: Friday 12:20pm - 1:10pm Credits: 1 TB
A Washington Update on the TCJA’s International Tax Provisions
Time: Friday 1:30pm - 2:20pm Credits: 1 TB
This panel, composed of former senior members of the Office of International Tax Counsel of the U.S. Treasury Department, will provide an update of the TCJA’s International Tax Provisions, including a summary overview of the current international tax system and where are we going? The panel will review regulatory developments, including what is covered in the regulatory guidance, what is not covered, unanticipated provisions and what we can expect going forward. There will be an opportunity for questions.
Estate Planning for Brazilians and Mexicans with U.S. Heirs or U.S. Assets
Time: Friday 2:35pm - 3:25pm Credits: 1 TB
This presentation will be a panel discussion covering current trends related to estate planning and transfer tax planning for Brazilians and Mexicans with U.S. Heirs or U.S. Assets.
The Long Arm of Uncle Sam: A Practical Guide to Navigating the Dangers of Advising Foreign Clients
Time: Friday 3:25pm - 4:15pm Credits: 1 TB
It will be surprising to many to learn that not all conversations between an attorney and a client always remain privileged and that the US government has the ability to bring charges when a foreign country’s taxes are evaded. He will discuss practical concerns every advisor should consider when providing advice to a foreign/dual citizen.
Tips to Take Home
Time: Friday 4:15pm - 5:05pm Credits: 1 TB
This presentation will discuss foreign owners and their reporting obligations for disregarded entities and the most recent guidance regarding withholding requirements on the sale of a partnership interest. It will also include constructive suggestions to help the practitioner in preparing various applications, including reduced FIRPTA withholding, ITINs and nonresident estate tax returns.
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
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
Jeffrey L Rubinger, Esq
Jeffrey L. Rubinger practices in the area of domestic and international taxation. He has been involved in tax planning for cross border mergers and acquisitions, international restructurings and joint ventures, and in the use of financial products in cross-border settings. In addition, Mr. Rubinger has experience in a broad range of transactions involving U.S. taxpayers doing business overseas...Read more about Jeffrey L Rubinger 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
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
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
James H Barrett
PartnerBaker & McKenzie LLPJames Barrett is a partner in the Miami office tax department and is a senior editor for Baker McKenzie North America Tax Practice Group's Tax News & Developments. He is the immediate past chair of the Florida Bar Tax Section. Jim advises on United States federal income tax planning focusing on outbound and inbound international tax issues. He has extensive experience in...Read more about James H Barrett 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
Jennifer J Wioncek, Esq., LL.M.
Jennifer J. Wioncek is a partner in the law firm of Bilzin Sumberg Baena Price & Axelrod LLP. She is recognized as a leading Tax and Trusts & Estates lawyer and "Power Woman" by Citywealth. She is recognized in Florida Super Lawyers and South Florida Legal Guide, and previously recognized by the Florida Daily Business Review as one of their "40 under 40 Rising Stars." Ms. Wioncek has general...Read more about Jennifer J Wioncek 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
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
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
Alan W Granwell, Esq
Alan Winston Granwell is a tax lawyer with nearly 50 years of experience in the area of international taxation. He advises corporate and private clients on cross-border planning, controversy and compliance and is a former International Tax Counsel and Director,Office of International Tax Affairs, U.S. Treasury Department.Read more about Alan W Granwell here
Jeffrey A Neiman, Esq.
Jeffrey A. Neiman is a founding partner of Marcus Neiman Rashbaum & Pineiro, LLP in South Florida. He 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 civil litigation. Previously, Neiman worked...Read more about Jeffrey A Neiman here
PartnerBaker & McKenzie LLPAbrahm Smith works in the Firm’s Tax Practice Group, and practices mainly in the area of general tax planning. He is a recipient of the Chair’s Special Merit Award from The Tax Section of the Florida Bar. Admitted to practice in Florida in 2003, Mr. Smith served as chair of the Federal Tax Division and the New Tax Lawyers Committee. Mr. Smith has also engaged in pro bono...Read more about Abrahm Smith here
Reaz H. Jafri
PartnerWithers Berman LLPReaz is a partner in the private client and tax team and focuses on immigration.He has more than 20 years of experience advising large multi-facility healthcare providers, research foundations, American businesses, multi-national companies, foreign investors, entrepreneurs and ultra-high net worth individuals on all aspects of immigration and nationality law. Reaz has...Read more about Reaz H. Jafri here
Alysse McLoughlin focuses her practice on state and local tax matters, with particular emphasis on working with financial services companies. Alysse handles state tax litigation and also advises with respect to planning opportunities. Alysse was most recently the head of state tax at Barclays Capital, where she was responsible for all state tax matters, including income, franchise, sales and use...Read more about Alysse McLoughlin here
Kathleen Quinn is an associate attorney at the Law firm of McDermott Will & Emery. She focuses her practice on state and local tax matters. She represents business and individual taxpayers at all stages of state and local tax controversies, including the audit, administrative, and judicial levels. Kathleen also advises clients on state and local tax planning opportunities and the state and local...Read more about Kathleen Quinn here
Danielle E. Rolfes
PartnerKPMG LLPDanielle co-leads the International Tax Group within KPMG’s Washington National Tax office. Danielle joined KPMG in June 2017, following her tenure as the International Tax Counsel at the U.S. Department of the Treasury.Danielle advises clients on U.S. international tax matters, including tax planning with respect to their structures, operations, and transactions. In particular...Read more about Danielle E. Rolfes here
PartnerErnst & YoungJose is a National Tax partner and leads the International Tax Services group within Ernst & Young LLP’s National Tax Department. Jose also serves as the firm’s National Director of Technical Services for the International Tax Services practice. His practice focuses primarily on cross—border acquisitions, dispositions and restructurings. Prior to his current role, Jose was in...Read more about Jose Murillo here
Jared E. Dwyer
ShareholderGreenberTraurigJed Dwyer focuses his practice on white collar criminal matters, criminal and civil tax litigation, and other complex civil litigation. Jed has tried more than 40 jury and non-jury trials and has been involved in over 100 investigations and prosecutions, many of which included complex fraud and regulatory matters. Jed leverages his experience to represent individuals and...Read more about Jared E. Dwyer here
Caroline D CiraoloRead more about Caroline D Ciraolo here