International Tax Conference Boot Camp (ITCBC)

ITC Boot camp in person
ITC Boot camp in person
Wednesday, January 11, 2023
JW Marriott Miami - 1109 Brickell Ave, Miami, FL 33131-3101
9:00AM - 5:10pm (opens at 8:45AM) EST
8Credits
Technical Business

Registration is Open

Members
$320.00 Regular Price
Non-Members
$395.00 Regular Price
Course Type: CPE Conferences
Course Code: 22/ITCBC
Field of Study: Taxes

Overview:

ITC Boot Camp

The 8th Annual International Tax Boot Camp is the place to master need-to-know skills and trends in the international tax realm and is designed to prepare an attendee with a foundational understanding of international tax. The Boot Camp will cover the basic topics of international inbound and outbound taxation. This program is recommended for all levels of tax practitioners and advisors. Individuals who attend this program will be prepared for substantive content covered during the following 2-day International Tax Conference.  The International Tax Boot camp Textbook is included with your registration fee.

Are You A Global CPA?
Come to the only conference in Florida for international training.

Want to learn more! Join us also for our 41st Annual FICPA –Florida Bar Tax Section International Tax Conference.  With changes and developments happening in international tax every day, there's only once conference in Florida that you can trust to provide the knowledge needed for your multinational organization or clients.

The FICPA and Florida Bar Tax Section's International Tax Conference is tailored specifically for international tax professionals to assist them in the various challenges they will face in this dynamic field. For more details on the International Tax Conference visit the FICPA –Florida Bar Tax Section International Tax Conference site.

CPE/CLE Credit
This conference will qualify for 8 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. 

Twitter

Follow the FICPA on Twitter @ficpa and use #ficpaITC to tweet about this conference.

Conference Materials

Registration to the Boot Camp includes our must have International Tax Boot Camp text book if registered by noon on January 7th. Pick up your textbook at the Boot Camp. Additional copies may become available on-site.

Conference materials are also 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. 

Schedule:

Wednesday, January 11, 2023

International Inbound Taxation

Time: Wednesday 9:05am - 10:45am Credits: 2 TB

Arianne Plasencia, Partner, McDermott, Will & Emery LLP

Ryan Coyle, Counsel, McDermott, Will & Emery LLP

Residency, Sourcing, FDAPI, ECI, FIRPTA, Branch Profits Tax, Treaties  
TCJA Specific Changes to Inbound Taxation  
Choice of Entity for Inbound Structuring 
Base Erosion Anti-abuse Tax (“BEAT”) 
Interest Limitation under Section 163(j)  
Treatment of gain or loss of foreign persons from sale or exchange in interests in partnerships engaged in US T/B (Sections 1446(f) and 864(c)(8))  
TCJA Specific Changes to Inbound Taxation (continued)  
Choice of Entity for Inbound Structuring  
Base Erosion Anti-abuse Tax (“BEAT”) (Section 59A)  
Interest Limitation under Section 163(j)  
Treatment of gain or loss of foreign persons from sale or exchange in interests in partnerships engaged in US T/B (Sections 1446(f) and 864(c)(8))  
Sourcing of Inventory Sales based solely on production activities (Section 863(b))

Presenters:

Morning Break

Time: Wednesday 10:45am - 11:05am

International Inbound Taxation (continued)

Time: Wednesday 11:05am - 12:45pm Credits: 2 TB

Arianne Plasencia, Partner, McDermott, Will & Emery LLP

Ryan Coyle, Counsel, McDermott, Will & Emery LLP

Residency, Sourcing, FDAPI, ECI, FIRPTA, Branch Profits Tax, Treaties  
TCJA Specific Changes to Inbound Taxation  
Choice of Entity for Inbound Structuring 
Base Erosion Anti-abuse Tax (“BEAT”) 
Interest Limitation under Section 163(j)  
Treatment of gain or loss of foreign persons from sale or exchange in interests in partnerships engaged in US T/B (Sections 1446(f) and 864(c)(8))  
TCJA Specific Changes to Inbound Taxation (continued)  
Choice of Entity for Inbound Structuring  
Base Erosion Anti-abuse Tax (“BEAT”) (Section 59A)  
Interest Limitation under Section 163(j)  
Treatment of gain or loss of foreign persons from sale or exchange in interests in partnerships engaged in US T/B (Sections 1446(f) and 864(c)(8))  
Sourcing of Inventory Sales based solely on production activities (Section 863(b))

Presenters:

Lunch Break

Time: Wednesday 12:45pm - 1:30pm

International Outbound Taxation

Time: Wednesday 1:30pm - 3:10pm Credits: 2 TB

Shawn Wolf, Esq., Bilzin Sumberg Baena Price & Axelrod

Carlos Somoza, Kaufman Rossin

TCJA Specific Changes to Outbound Taxation 
General overview of outbound taxation 
Expansion of CFC and US shareholder definitions 
Elimination of 30-day rule under Section 951(a)(1) 
Repeal of downward attribution rule (Section 958(b)(4)) 
Transition Tax under Section 965 
Global intangible low-taxed income (“GILTI”) regime (Section 951A) 
Participation Exemption under Section 245A 
Deduction for Foreign-derived intangible income (“FDII”) 
Foreign tax credit buckets (GILTI and foreign branch baskets) 
Others worth noting, but not going into detail: 
Repeal of indirect foreign tax credit under Section 902 
Elimination of foreign base company oil related income from Sub F 
Changes to foreign base company shipping income 
Transfers of specified 10% owned foreign corporations
Consider mentioning AEP & PHC rules somewhere throughout the day (important especially in inbound and 10/50 foreign corp context) 
Restriction on PFIC insurance exception 
Section 267A (anti-hybrid rules) 
Termination OVDP

Presenters:

Afternoon Break

Time: Wednesday 3:10pm - 3:30pm

International Outbound Taxation (continued)

Time: Wednesday 3:30pm - 5:10pm Credits: 2 TB

Shawn Wolf, Esq., Bilzin Sumberg Baena Price & Axelrod

Carlos Somoza, Kaufman Rossin

TCJA Specific Changes to Outbound Taxation 
General overview of outbound taxation 
Expansion of CFC and US shareholder definitions 
Elimination of 30-day rule under Section 951(a)(1) 
Repeal of downward attribution rule (Section 958(b)(4)) 
Transition Tax under Section 965 
Global intangible low-taxed income (“GILTI”) regime (Section 951A) 
Participation Exemption under Section 245A 
Deduction for Foreign-derived intangible income (“FDII”) 
Foreign tax credit buckets (GILTI and foreign branch baskets) 
Others worth noting, but not going into detail: 
Repeal of indirect foreign tax credit under Section 902 
Elimination of foreign base company oil related income from Sub F 
Changes to foreign base company shipping income 
Transfers of specified 10% owned foreign corporations
Consider mentioning AEP & PHC rules somewhere throughout the day (important especially in inbound and 10/50 foreign corp context) 
Restriction on PFIC insurance exception 
Section 267A (anti-hybrid rules) 
Termination OVDP

Presenters:

Presenters:

  • Shawn P Wolf, Esq.

    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...

    Read more about Shawn P Wolf here
  • Arianne Plasencia

    Arianne Plasencia is an attorney in the Miami office of McDermott Will & Emery. Ms. Plasencia focuses her on US & International tax matters. She provides international and domestic income, gift and estate tax planning for entities and high-net-worth individuals with a focus on multijurisdictional families and inbound investment planning. She also represents clients in tax audits, offshore...

    Read more about Arianne Plasencia here
  • Ryan Coyle

    Ryan J. Coyle focuses his practice on international tax matters, with an emphasis on providing tax-efficient restructuring solutions for high-net-worth international families and their closely held businesses. In addition to advising US-based families on income, gift, and estate tax matters, he assists non-US families with tax matters relating to pre-immigration planning and inbound investment...

    Read more about Ryan Coyle here
  • Carlos A Somoza, JD, LL.M.

    Carlos A. Somoza leads Kaufman Rossin’s international tax services practice. He has more than 25 years of experience in federal income, gift and estate taxation. He has served clients in the private and public industries, advising them in the areas of international taxation, taxable acquisitions and tax-free reorganizations, IRS litigation and related tax compliance.Carlos provides international...

    Read more about Carlos A Somoza here

Presenters:

Shawn P Wolf, Esq.

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...Read more about Shawn P Wolf here

Arianne Plasencia

Arianne Plasencia is an attorney in the Miami office of McDermott Will & Emery. Ms. Plasencia focuses her on US & International tax matters. She provides international and domestic income, gift and estate tax planning for entities and high-net-worth individuals with a focus on multijurisdictional families and inbound investment planning. She also represents clients in tax audits, offshore...Read more about Arianne Plasencia here

Ryan Coyle

Ryan J. Coyle focuses his practice on international tax matters, with an emphasis on providing tax-efficient restructuring solutions for high-net-worth international families and their closely held businesses. In addition to advising US-based families on income, gift, and estate tax matters, he assists non-US families with tax matters relating to pre-immigration planning and inbound investment...Read more about Ryan Coyle here

Carlos A Somoza, JD, LL.M.

Carlos A. Somoza leads Kaufman Rossin’s international tax services practice. He has more than 25 years of experience in federal income, gift and estate taxation. He has served clients in the private and public industries, advising them in the areas of international taxation, taxable acquisitions and tax-free reorganizations, IRS litigation and related tax compliance.Carlos provides international...Read more about Carlos A Somoza here

Major Topics:

Inbound International Tax

Outbound International Tax

Major Topics:

Inbound International Tax

Outbound International Tax

Designed For:

New and intermediate in the field of international taxation.

Prerequisties:

Some familiarity with accounting and taxes. 

Accommodations:

JW Marriott
1109 Brickell Avenue
Miami, FL 33131
Phone: 305-329-3500
Reservations: 800-503-1434

FICPA Room Rate: $339 + tax
Hotel Cutoff Deadline: December 20, 2022*

Parking is $22 + tax daily; $42+ tax overnight.

Please mention The Florida Bar and FICPA in order to get the discounted rate or click the link below to book online.

Book your group rate for The Florida Bar 2023 International Tax Conference

*Reservations made after the cutoff date will be subject to availability and current room rate. Please note that the conference accommodation rate is subject to sell out prior to the advertised reservation cut off date.

CPE sponsors

The Florida Institute of Certified Public Accountants (FICPA) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: NASBARegistry.org