International Tax Conference (ITC)

Thursday, January 13, 2022 - Friday, January 14, 2022
JW Marriott Miami - 1109 Brickell Ave, Miami, FL 33131-3101
9:00AM - 5:00PM (opens at 8:45AM) EST
16Credits
Technical Business

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.

Members
$735.00 Regular Price
Non-Members
$810.00 Regular Price
Course Type: CPE Conferences
Course Code: 21/ITC
Field of Study: Taxes

Overview:

Are You A Global CPA, attorney or practice in the International Tax arena? 

Please plan on joining us at the 40th Annual FICPA –Florida Bar Tax Section International Tax Conference.  With changes and developments happening in international tax every day, there's only one 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.

ITC Boot Camp

This Boot Camp 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 basics behind international inbound and outbound taxation. Recommended for all levels of tax practitioners, attorneys, and advisors. For more details on the ITC Boot Camp visit https://www.ficpa.org/event/international-tax-conference-boot-camp-4.

CPE/CLE Credit
This 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. 

NOTE

To receive CPE or CLE credit, each person attending the live stream must be registered individually.

ACCOMODATIONS

JW Marriott
1109 Brickell Avenue
Miami, FL 33131
Phone: 305-329-3500
Reservations: 800-228-9290 or 800-503-1434

FICPA Room Rate: $339 + tax
Hotel Cutoff Deadline: *December 20, 2021

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 2022 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.


 Twitter

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

Conference Materials

Book Purchase: If you wish to purchase a hard copy of the text book for an additional $65 please make sure to add the book on to your registration.

A printed text book of the much wanted International Tax Conference is available for purchase for $65 (including tax). Textbooks will be available for pickup at the conference hotel. Deadline for a guaranteed textbook is noon January 3rd.  Additional copies may be available for purchase.

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:

Thursday, January 13, 2022

I would like a hardcopy course manual for an additional $65, plus the EZMaterials electronic course manual

Time: Thursday 8:30am

Current Developments in International Taxation: U.S. Outbound and Global Tax Developments Through the Lens of U.S. Multinationals

Time: Thursday 9:00am - 9:50am Credits: 1 TB

Scott Klein, Managing Director, BDO USA, LLP
Michael Masciangelo, Senior Client Executive, International Tax Services, BDO USA, LLP.


The presentation will focus on US international outbound tax reform and the intersection with global tax reform.  In a world with US and global minimum tax rates, tax planning and opportunities for complex international tax analysis will remain. The presentation will highlight impacts of international outbound tax reform provisions on some common operating structures, including practical application of US CFC and foreign tax credits rules.

Presenters:

International Tax Aspects of De-SPACing Transactions

Time: Thursday 9:50am - 10:40am Credits: 1 TB

Seth Entin, Shareholder, Greenberg Traurig LLP

The SPAC market has been quite active during the past several years.  Regardless of whether the same level of SPAC IPO activity will continue, there are many “De-SPACing” transactions that will occur in 2022 and beyond. This presentation will discuss the various tax issues and planning considerations that arise where a foreign SPAC combines with a U.S. target company, where a U.S. SPAC combines with a foreign target company, and where a foreign SPAC having U.S. shareholders combines with a foreign target company.

Presenters:

Morning Break

Time: Thursday 10:40am - 11:00am

Tax Planning for Bona Fide Residents of Puerto Rico

Time: Thursday 11:00am - 11:50am Credits: 1 TB

Jeffrey L. Rubinger, Principal, Global Tax Practice,  Baker & McKenzie LLP

The presentation will focus on the US federal income tax consequences to US taxpayers who become bona fide residents of Puerto Rico, including a discussion of the residency requirements, the sourcing provisions, the implications of the CFC rules, and planning with hybrid entities and income tax treaties.

Presenters:

Lunch Break

Time: Thursday 11:50am - 12:30pm

International Initiative for 2022 and Beyond: What to Expect from the Internal Revenue Service

Time: Thursday 12:30pm - 1:20pm Credits: 1 TB

Charles Rettig, Commissioner Internal Revenue Service

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.

Presenters:

GILTI Planning for High Net Worth Families

Time: Thursday 1:20pm - 2:10pm Credits: 1 TB

Steve Hadjiliogiou, Partner, McDermott, Will & Emery

Michael Bruno, Partner, McDermott, Will & Emery

The speakers will present the law and planning techniques for closely held foreign corporations that generate global intangible low-tax income (GILTI). The presentation will discuss the latest legislative changes to the GILTI regime. The panelists will also discuss planning to minimize the negative impacts of GILTI, use of 962 elections, distribution ordering rules and affirmatively using GILTI.

Presenters:

Afternoon Break

Time: Thursday 2:10pm - 2:30pm

Mitigating International Tax Risk

Time: Thursday 2:30pm - 3:20pm Credits: 1 TB

Mark G. McTigue, Managing Director, Tax Insurance, Marsh Scott Harty
Scott A. Harty, Alston & Bird LLP
Justin Pierce Berutich , Euclid Tranactional, LLC
Ben Furtick, Certa Insurance Partners
Mike Gaffney, Atlantic Global Risk 

Over the past few years transaction liability coverage has grown rapidly.  Tax insurance is a fast growing segment of this market and an important tool in managing tax risk and facilitating deals.  Many have heard of, or even used, the product to cover tax exposure in various contexts but there is much that remains unknown about the product in the broader market.  This panel will review the various considerations for taxpayers and their advisors in securing a tax insurance policy to mitigate U.S. and international tax risk, both in the M&A context and as a stand-alone policy for balance sheet tax risks.

Presenters:

International Tax Law Changes

Time: Thursday 3:20pm - 5:00pm Credits: 2 TB

Bob Stack, Managing Director, Deloitte Tax LLP
Ryan Bowen, Tax Senior Manager, Deloitte Tax LLP
Andrew Moss, Tax Manager, Deloitte Tax LLP

This session will review Congress' last minute changes in international tax law. 

Presenters:

Friday, January 14, 2022

Current Developments in Intl. Taxation: Inbound Planning Update incl Recent Global Tax Compliance & Controversy Developments Along W/ FBAR Litigation

Time: Friday 8:30am - 9:20am Credits: 1 TB

William M Sharp Sr., Partner, Holland & Knight Atlanta/Tampa/San Francisco

The 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, all with a focus on technical and pragmatic cutting edge commentary; 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).

Presenters:

Intersection of Tax Planning and The Corporate Transparency Act

Time: Friday 9:20am - 10:10am Credits: 1 TB

Kevin E. Packman, Partner, Holland & Knight LLP
Glenn G. Fox, Partner, Baker & McKenzie LLP

The Corporate Transparency Act (the “Act”) passed on January 1, 2021 and Proposed Regs are supposed to be issued by January 1, 2022.  The Act is another step towards placing the US on similar footing with other similarly positioned OECD and FATF nations in requiring the reporting of the ultimate beneficial owners of companies and similar corporate entities. This seminar will discuss the provisions of the Act, how it may be applied in practice, some of the open issues subject to pending regulations, and matters that must be addressed by future legislation.

Presenters:

Morning Break

Time: Friday 10:10am - 10:30am

Choice of Entity - Another Round of Tax Reform and its Impact on Structuring Inbound and Outbound Investments

Time: Friday 10:30am - 11:20am Credits: 1 TB

Bobby Moore, Baker & McKenzie, LLP

This session will analyze the impact of recent tax reform and other developments on choice of entity in structuring both inbound and outbound investment. We'll cover a range of topics impacting choice of entity from FIRPTA, portfolio debt planning, US estate tax, SALT, US trade or business issues, Subpart F, GILTI, and Section 962 elections.



 

Presenters:

In The Eye of the Beholder: When Does a Civil Tax Case Move to a Criminal Tax Investigation?

Time: Friday 11:20am - 12:10pm Credits: 1 TB

Caroline D. Ciraolo, Partner, Kostelanetz & Fink, LLP, Washington DC

Jeffrey Neiman, Marcus Neiman & Rashbaum LLP

The IRS puts the current gross tax gap at more than $1 trillion dollars. The gap consists of underreporting, underpayment, and non-filing, and each of these areas includes potential criminal targets. So what moves tax noncompliance from the civil to the criminal realm? This panel will address the IRS focus on civil fraud enforcement and criminal referrals.  Topics will include the creation, organization, and initiatives of the IRS Office of Fraud Enforcement, current IRS enforcement priorities, recent criminal tax prosecutions, and more.

Presenters:

Lunch Break

Time: Friday 12:10pm - 12:30pm

Crypto Assets – U.S. International Taxation Hot Topics

Time: Friday 12:30pm - 1:20pm Credits: 1 TB

Arthur J. Dichter, Director of International Tax Services, Berkowitz Pollack Brant Advisors + CPAs
Peter Psiachos, Coinbase
Rahul Ranadive / Shareholder / Carlton Fields


This panel will discuss the U.S. international tax treatment of transactions in digital currency, including classification and character, U.S. trade or business, crypto lending, and compliance issues, as well as highlighting various open questions and relevant reform proposals. 

Presenters:

Pros and Cons of NRAs Using Florida Based Trusts

Time: Friday 1:20pm - 2:10pm Credits: 1 TB

Hal J. Webb, Partner, Bilzin Sumberg
Jennifer J. Wioncek, TEP, Partner, Bilzin Sumberg

This presentation will discuss tax planning benefits now available after recent Florida trust law changes, traps for the unwary using Florida revocable trusts, and other planning considerations.

Presenters:

Afternoon Break

Time: Friday 2:10pm - 2:30pm

Foreign Investor Opportunities in Opportunity Zone Planning

Time: Friday 2:30pm - 3:20pm Credits: 1 TB

Logan E. Gans, Esq., CPA, Partner, Shutts & Bowen LLP, Miami, FL

This session will focus on the Tax Cut and Jobs Act’s Incentive for investment in opportunity zones and its potential application by foreign investors and their U.S. investment structures.

Presenters:

Look Before (After) You Leap - Tax, Estate and Wealth Preservation Planning for High Net Worth Latin American Families Moving to the United States

Time: Friday 3:20pm - 4:10pm Credits: 1 TB

Alfredo R. Tamayo, Esq. Packman, Neuwahl & Rosenberg, PA - Miami, FL
Leslie A. Share, Esq. Packman, Neuwahl & Rosenberg PA – Miami, FL

In recent years, for various reasons, the trickle of wealthy families moving to the United States from Latin America has become a flood. Our presentation will review the U.S. tax, estate planning and wealth preservation issues generally associated with becoming U.S. citizens and domiciliaries. We will discuss individuals who have sufficient time to effectuate such planning before they come here, as well as possible methods of rectifying the situations of those who may have already become borderline U.S. persons.

Presenters:

Presenters:

  • 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 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...

    Read more about Seth J Entin here
  • Jeffrey L Rubinger, Esq

    Jeffrey Rubinger is a partner in Baker McKenzie's Tax Practice Group. A skilled legal practitioner with more than 20 years of international tax experience, he also served for many years as a certified public accountant at a major accounting firm, giving him a unique and thorough understanding of the business issues, his clients face every day. Jeff has been recognized as one of America's leading...

    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
  • 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

    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
  • Jennifer J Wioncek, Esq., LL.M.

    Jennifer 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. Her broad practice covers international and domestic tax and estate planning issues, pre-immigration tax planning, expatriation tax planning, private trust company structuring, cross-border estate administration...

    Read more about Jennifer J Wioncek here
  • Kevin E Packman

    Kevin E. Packman, a native of Miami, is a partner with Holland & Knight and a member of its International Estate Planning Group, an integral part of the firm's Private Wealth Services Department. He also chairs the firm's Offshore Compliance Team. His practice includes tax controversies, estate planning (domestic and international) and creditor protection planning. He is also recognized as a...

    Read more about Kevin E Packman 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
  • Arthur J Dichter, JD,LLM (TAX)

    Arthur J. Dichter is a Director of International Tax Services with Berkowitz Pollack Brant, Advisors and Accountants. Mr. Dichter  has over 25 years of experience assisting international private clients and foreign trusts with income tax planning, cross-border estate planning, pre-immigration planning, and US compliance and reporting matters. Dichter has been a guest lecturer at the University of...

    Read more about Arthur J Dichter here
  • Logan Evan Gans, CPA,Esq.

    Logan E. Gans is a partner in the Miami office of Shutts & Bowen LLP, where he is a member of the Tax and International Law Practice Group. Logan regularly represents clients on U.S. Federal tax, international tax, and state and local tax matters. Logan also advises U.S. clients on outbound corporate and tax planning, including Subpart F, GILTI, and FDII matters. He counsels foreign clients on...

    Read more about Logan Evan Gans here
  • Jeffrey A Neiman, Esq.

    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...

    Read more about Jeffrey A Neiman here
  • Caroline D Ciraolo

    Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz & Fink and a founder of its Washington, D.C. office. Her practice focuses on complex and sophisticated civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation in federal and state courts and...

    Read more about Caroline D Ciraolo here
  • Robert B. Stack, Esq.

    Bob Stack is a Managing Director in Deloitte’s Washington National Tax international tax practice where he advises U.S. companies on a full range of international tax issues and collaborates with Deloitte’s global member firms on international tax developments and initiatives, including those from the Organization for Economic Co-Operation and Development  (OECD).    Until January of this year, he...

    Read more about Robert B. Stack 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
  • Scott M Klein

    Scott has 12 years of experience in public accounting advising corporations on cross-border tax planning with a focus on developing tax efficient structures for his clients that align with their global business objectives.  Scott advises large multinational corporations on inbound and outbound tax structuring in the areas of income characterization and sourcing, controlled foreign corporation...

    Read more about Scott M Klein here
  • Glenn G. Fox

    Glenn G. Fox is a partner of Baker McKenzie's Wealth Management and Tax Practice Groups in New York and a member of the firm’s Global Tax Wealth Management Steering Committee. He is a domestic and international tax, estate planning, and tax-exempt (charitable) organizations lawyer with vast experience working with closely held businesses, families and charitable organizations from the US and...

    Read more about Glenn G. Fox here
  • Scott A. Harty

    Scott Harty is a partner in the Federal & International Tax Group and focuses his practice on complex domestic and cross-border commercial transactions, including taxable and tax-free mergers and acquisitions, joint ventures, and corporate restructurings. Scott has broad industry experience and works with publicly traded companies, private equity funds, closely held businesses, and large tax...

    Read more about Scott A. Harty here
  • Mark McTigue

    Mark McTigue is Managing Director, Tax Insurance specialist at Marsh. He has expertise in international taxation, financial services taxation, financial product taxation, general corporate tax, accounting and regulatory capital issues for banks, insurance companies, hedge funds, corporates, etc. Mark has significant experience in Private Equity and M&A transactions, significant structuring and...

    Read more about Mark McTigue here
  • Justin Pierce Berutich

    Justin Pierce Berutich is Managing Director and Head of Tax at Euclid Transactional, where he is responsible for leading Euclid’s tax insurance practice and developing bespoke, commercial solutions to diverse tax matters.A former M&A and transactional tax attorney, Justin enhances client value through the promotion and underwriting of tax indemnity insurance solutions. His corporate, tax, and...

    Read more about Justin Pierce Berutich here
  • Mike Gaffney

    Mike is a Director and a member of the tax team responsible for tax liability insurance products. Prior to joining Atlantic, Mike most recently was PwC’s global tax leader for the Banking & Capital Markets practice and advised financial institutions on complex tax matters. Before joining PwC in 2009, Mike was the Co-Head of Global Tax at Merrill Lynch and a member of the Special Structured...

    Read more about Mike Gaffney here
  • Michael Masciangelo

    Michael joins BDO’s National Tax Office where he is responsible for international tax strategy development, including working with the firm’s U.S. offices and hub markets to develop and implement strategic cross-border solutions.  Michael has more than 25 years of experience at a Big Four firm in corporate and international tax. He has a combination of firmwide technical leadership and market...

    Read more about Michael Masciangelo here
  • Peter Psiachos

    Peter Psiachos is Senior Tax Counsel at Coinbase since May, 2021.  He was previously with Goldman Sachs in the Investment Banking Division working in capital markets and derivatives structuring and prior to that with HSBC Securities in their structured finance group.  He began his career with Shearman & Sterling LLP as well as Cleary Gottlieb

    Read more about Peter Psiachos here
  • Ryan Bowen

    Ryan Bowen is a Senior Manager in the Washington National Tax Office and a member of the International Tax Services group. Ryan joined Deloitte Tax LLP in 2017 at the WNT following a 7-year career at the IRS Office of Associate Chief Counsel, International.  While at the IRS Ryan worked on guidance under sections 367 and 721(c).  He currently focuses on issues in outbound taxation.He received his...

    Read more about Ryan Bowen here
  • Rahul Ranadive

    Rahul Ranadive has over 20 years of experience advising international high net worth families on global estate and trust planning, private banking, and other personal tax matters. He advises closely held family businesses on a wide range of international and domestic tax and corporate issues. Having been raised in two cultures, Rahul understands the difficulties faced by families spread across...

    Read more about Rahul Ranadive here
  • Andrew Moss

    Read more about Andrew Moss here
  • Ben Furtick

    Read more about Ben Furtick here

Presenters:

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 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...Read more about Seth J Entin here

Jeffrey L Rubinger, Esq

Jeffrey Rubinger is a partner in Baker McKenzie's Tax Practice Group. A skilled legal practitioner with more than 20 years of international tax experience, he also served for many years as a certified public accountant at a major accounting firm, giving him a unique and thorough understanding of the business issues, his clients face every day. Jeff has been recognized as one of America's leading...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

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

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

Jennifer J Wioncek, Esq., LL.M.

Jennifer 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. Her broad practice covers international and domestic tax and estate planning issues, pre-immigration tax planning, expatriation tax planning, private trust company structuring, cross-border estate administration...Read more about Jennifer J Wioncek here

Kevin E Packman

Kevin E. Packman, a native of Miami, is a partner with Holland & Knight and a member of its International Estate Planning Group, an integral part of the firm's Private Wealth Services Department. He also chairs the firm's Offshore Compliance Team. His practice includes tax controversies, estate planning (domestic and international) and creditor protection planning. He is also recognized as a...Read more about Kevin E Packman 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

Arthur J Dichter, JD,LLM (TAX)

Arthur J. Dichter is a Director of International Tax Services with Berkowitz Pollack Brant, Advisors and Accountants. Mr. Dichter  has over 25 years of experience assisting international private clients and foreign trusts with income tax planning, cross-border estate planning, pre-immigration planning, and US compliance and reporting matters. Dichter has been a guest lecturer at the University of...Read more about Arthur J Dichter here

Logan Evan Gans, CPA,Esq.

Logan E. Gans is a partner in the Miami office of Shutts & Bowen LLP, where he is a member of the Tax and International Law Practice Group. Logan regularly represents clients on U.S. Federal tax, international tax, and state and local tax matters. Logan also advises U.S. clients on outbound corporate and tax planning, including Subpart F, GILTI, and FDII matters. He counsels foreign clients on...Read more about Logan Evan Gans here

Jeffrey A Neiman, Esq.

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...Read more about Jeffrey A Neiman here

Caroline D Ciraolo

Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz & Fink and a founder of its Washington, D.C. office. Her practice focuses on complex and sophisticated civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation in federal and state courts and...Read more about Caroline D Ciraolo here

Robert B. Stack, Esq.

Bob Stack is a Managing Director in Deloitte’s Washington National Tax international tax practice where he advises U.S. companies on a full range of international tax issues and collaborates with Deloitte’s global member firms on international tax developments and initiatives, including those from the Organization for Economic Co-Operation and Development  (OECD).    Until January of this year, he...Read more about Robert B. Stack 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

Scott M Klein

Scott has 12 years of experience in public accounting advising corporations on cross-border tax planning with a focus on developing tax efficient structures for his clients that align with their global business objectives.  Scott advises large multinational corporations on inbound and outbound tax structuring in the areas of income characterization and sourcing, controlled foreign corporation...Read more about Scott M Klein here

Glenn G. Fox

Glenn G. Fox is a partner of Baker McKenzie's Wealth Management and Tax Practice Groups in New York and a member of the firm’s Global Tax Wealth Management Steering Committee. He is a domestic and international tax, estate planning, and tax-exempt (charitable) organizations lawyer with vast experience working with closely held businesses, families and charitable organizations from the US and...Read more about Glenn G. Fox here

Scott A. Harty

Scott Harty is a partner in the Federal & International Tax Group and focuses his practice on complex domestic and cross-border commercial transactions, including taxable and tax-free mergers and acquisitions, joint ventures, and corporate restructurings. Scott has broad industry experience and works with publicly traded companies, private equity funds, closely held businesses, and large tax...Read more about Scott A. Harty here

Mark McTigue

Mark McTigue is Managing Director, Tax Insurance specialist at Marsh. He has expertise in international taxation, financial services taxation, financial product taxation, general corporate tax, accounting and regulatory capital issues for banks, insurance companies, hedge funds, corporates, etc. Mark has significant experience in Private Equity and M&A transactions, significant structuring and...Read more about Mark McTigue here

Justin Pierce Berutich

Justin Pierce Berutich is Managing Director and Head of Tax at Euclid Transactional, where he is responsible for leading Euclid’s tax insurance practice and developing bespoke, commercial solutions to diverse tax matters.A former M&A and transactional tax attorney, Justin enhances client value through the promotion and underwriting of tax indemnity insurance solutions. His corporate, tax, and...Read more about Justin Pierce Berutich here

Mike Gaffney

Mike is a Director and a member of the tax team responsible for tax liability insurance products. Prior to joining Atlantic, Mike most recently was PwC’s global tax leader for the Banking & Capital Markets practice and advised financial institutions on complex tax matters. Before joining PwC in 2009, Mike was the Co-Head of Global Tax at Merrill Lynch and a member of the Special Structured...Read more about Mike Gaffney here

Michael Masciangelo

Michael joins BDO’s National Tax Office where he is responsible for international tax strategy development, including working with the firm’s U.S. offices and hub markets to develop and implement strategic cross-border solutions.  Michael has more than 25 years of experience at a Big Four firm in corporate and international tax. He has a combination of firmwide technical leadership and market...Read more about Michael Masciangelo here

Peter Psiachos

Peter Psiachos is Senior Tax Counsel at Coinbase since May, 2021.  He was previously with Goldman Sachs in the Investment Banking Division working in capital markets and derivatives structuring and prior to that with HSBC Securities in their structured finance group.  He began his career with Shearman & Sterling LLP as well as Cleary GottliebRead more about Peter Psiachos here

Ryan Bowen

Ryan Bowen is a Senior Manager in the Washington National Tax Office and a member of the International Tax Services group. Ryan joined Deloitte Tax LLP in 2017 at the WNT following a 7-year career at the IRS Office of Associate Chief Counsel, International.  While at the IRS Ryan worked on guidance under sections 367 and 721(c).  He currently focuses on issues in outbound taxation.He received his...Read more about Ryan Bowen here

Rahul Ranadive

Rahul Ranadive has over 20 years of experience advising international high net worth families on global estate and trust planning, private banking, and other personal tax matters. He advises closely held family businesses on a wide range of international and domestic tax and corporate issues. Having been raised in two cultures, Rahul understands the difficulties faced by families spread across...Read more about Rahul Ranadive here

Andrew Moss

Read more about Andrew Moss here

Ben Furtick

Read more about Ben Furtick here

Major Topics:

  • Current Developments in International Taxation
  • International Tax Aspects of De-SPACing Transactions
  • Tax Planning for Bona Fide Residents of Puerto Rico
  • International Initiative for 2022 and Beyond: What to Expect from the IRS
  • Intersection of Tax Planning and The Corporate Transparency Act
  • Mitigating International Tax Risk
  • GILTI Planning for High New Worth Families
  • Look Before and After You Leap - Tax, Estate and Wealth Preservation Planning for High Net Worth
  • Inbound Planning Update and Controversy Developments along with FBAR Litigation
  • Crypto Assets - U.S. International Taxation Hot Topics
  • Choice of Entity in International Tax Arena
  • Holding Taxpayers and their Advisors Accountable
  • Pros and Cons of NRAs Using Florida Based Trusts
  • Foreign Investor Opportunities in Opportunity Zone Planning
  • Tips to Take Home
  • ... And More

Major Topics:

  • Current Developments in International Taxation
  • International Tax Aspects of De-SPACing Transactions
  • Tax Planning for Bona Fide Residents of Puerto Rico
  • International Initiative for 2022 and Beyond: What to Expect from the IRS
  • Intersection of Tax Planning and The Corporate Transparency Act
  • Mitigating International Tax Risk
  • GILTI Planning for High New Worth Families
  • Look Before and After You Leap - Tax, Estate and Wealth Preservation Planning for High Net Worth
  • Inbound Planning Update and Controversy Developments along with FBAR Litigation
  • Crypto Assets - U.S. International Taxation Hot Topics
  • Choice of Entity in International Tax Arena
  • Holding Taxpayers and their Advisors Accountable
  • Pros and Cons of NRAs Using Florida Based Trusts
  • Foreign Investor Opportunities in Opportunity Zone Planning
  • Tips to Take Home
  • ... And More

Designed For:

CPAs,accountants, attorneys and consultants practicing International Tax

Prerequisties:

Some familiarity with accounting and International Tax

Accommodations:

JW Marriott
1109 Brickell Avenue
Miami, FL 33131
Phone: 305-329-3500
Reservations: 800-228-9290 or 800-503-1434

FICPA Room Rate: $339 + tax
Hotel Cutoff Deadline: *December 20, 2021

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

Please mention The Florida Bar and FICPA in order to get the discounted rate.

*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.

Sponsor & Exhibitor Information

Sponsor
KBKG
coaxis
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