International Tax Conference- Virtual (ITCWEB)
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.
Overview:
Are You A Global CPA, Attorney, or do you Practice in the International Tax arena?
Are You A Global CPA, Attorney, or do you Practice in the International Tax arena?
Are You A Global CPA, Attorney, or do you Practice in the International Tax arena?
Are You A Global CPA, Attorney, or do you Practice in the International Tax arena?
Are You A Global CPA, Attorney, or do you Practice in the International Tax arena?
Join us online for our 42nd Annual FICPA Virtual 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 - Online
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 virtual ITC Boot Camp visit the ITC Boot Camp Livestream site. Our Boot camp will also be available in-person.
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.
Conference Materials
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 for your convenience.
Schedule:
Thursday, January 18, 2024
I would like to claim CLE Credit for this conference for an additional fee $50
Time: Thursday 8:00am - 8:01am
Outbound - Current Developments
Time: Thursday 8:50am - 9:50am Credits: 1 TB
A U.S. international outbound update including: new cases, Pillar II, regulatory update; the upcoming sunsetting/numeric changes to the TCJA provisions.
Presenters:
Moore and More: Current Challenges to Statutes and Regulations
Time: Thursday 9:50am - 10:40am Credits: 1 TB
This presentation will address the arguments in and the broader implications of the Moore case that is pending before the United States Supreme Court, as well as other current challenges to international tax statutes and regulations, such as those relating to downward attribution, deemed paid foreign tax credits, and FBAR (and other) filing requirements for dual-resident taxpayers.
Presenters:
Planning for U.S. Closely-Held Acquisitions and Divestitures of Foreign Businesses
Time: Thursday 11:00am - 11:50am Credits: 1 TB
The panelists will discuss the latest planning trends in the taxation of U.S. acquisitions and divestitures of foreign businesses. The discussion will cover Pillar II tax related issues, basis step-up planning, potential recast issues, and items to consider in the acquisition to make post-acquisition business earnings as tax-efficient as possible.
Presenters:
IRS Implementation of the Inflation Reduction Act – What it Means for Taxpayers and Exam Activity
Time: Thursday 12:30pm - 1:20pm Credits: 1 TB
Capitalizing on Inflation Reduction Act funding and following a top-to-bottom review of enforcement efforts, the Internal Revenue Service is shifting more attention onto high-income earners, partnerships, large corporations, and promoters abusing the nation's tax laws. The effort, building off work following last August's IRA funding, will center on adding more attention on wealthy taxpayers and partnerships and other high earners that have seen sharp drops in audit rates for these taxpayer segments during the past decade, including some of the large partnerships in the U.S. that represent a cross section of industries including hedge funds, real estate investment partnerships, publicly traded partnerships, large law firms and other industries. The IRS has launched numerous compliance efforts to address serious issues being seen. Some of these, like abusive micro-captive insurance arrangements and syndicated conservation easement abuses, have already received extensive public attention. But much more work continues behind the scenes on other issues. And among some of the additional priority areas that comprise the new focus include expanded work on digital assets, and more scrutiny on FBAR violations. IRS analysis of multi-year filing patterns has identified hundreds of possible FBAR non-filers with account balances that average over $1.4 million. The IRS plans to audit the most egregious potential non-filer FBAR cases in Fiscal Year 2024.
Presenters:
Proper US classification of certain foreign entities and structures
Time: Thursday 1:20pm - 2:10pm Credits: 1 TB
This presentation will review various current U.S. tax and reporting issues regarding certain commonly encountered offshore entities and estate planning techniques that may be “foreign” to many U.S. practitioners. We will examine entities such as non-U.S. private foundations and fideicomisos, along with the usufruct and other civil law planning techniques that have been used for many years to preserve and maintain the wealth of high-net-worth individuals. As part of this analysis, we will discuss the potential U.S. tax treatment of U.S. persons who have created or may derive benefits from such planning structures and techniques, as well as how to (hopefully) satisfy the often-uncertain associated U.S. compliance requirements.
Presenters:
Recent Tax and Regulatory Updates from Latin America
Time: Thursday 2:30pm - 3:20pm Credits: 1 TB
This panel discussion will provide an overview of various tax and regulatory updates coming out of Latin America. The presentation will focus on Brazil and Chile, surveying the latest developments and highlighting relevant US planning considerations. Topics covered will include the anticipated CFC rules and latest trust developments coming out of Brazil, as well as analysis of the US/Chile Income Tax Treaty.
Presenters:
Pilar 2 Considerations for Closely-Held Businesses
Time: Thursday 3:20pm - 4:10pm Credits: 1 TB
This session will explore the impact of Pillar 2 on closely held businesses, including how to determine revenue thresholds across closely held groups, unexpected traps and practical advice for companies without large in-house tax departments, and potential ways to mitigate the impact of Pillar 2.
Presenters:
Partnership reporting – Focus on K2-K3
Time: Thursday 4:10pm - 5:00pm Credits: 1 TB
This presentation will provide practical guidance, tips, and strategies for reporting Schedules K-2 and K-3 in the context of preparing domestic and foreign partnership returns (Forms 1065 and 8865). The new schedules were designed by the IRS to provide more clarity to the individual partners and their individual filing compliance requirements. However, if the Schedules K-2 and K-3 are not prepared correctly or include the proper reporting at the entity level then the schedules may create more confusion and complexity than clarity. This presentation will help tax professional understand how to properly complete the Schedules K-2 and K-3 at the entity level, how to input the Schedule K-3 at the individual level, how to identify an incomplete or inaccurate Schedule K-3 that has been provided to an individual partner, and how to deal with ancillary reporting that may be required at the entity and/or individual level.
Presenters:
Friday, January 19, 2024
Inbound Update
Time: Friday 8:30am - 9:20am Credits: 1 TB
The presentation will explore cutting-edge “inbound” tax planning developments, including recent U.S. statutory, regulatory, administrative, and judicial developments. This session also will address significant U.S. Tax Court and federal court decisions addressing inbound and compliance issues as well as important foreign case developments, recent IRS and U.S. Department of Justice initiatives, and recent Foreign Bank Account Report (FBAR) litigation developments.
Presenters:
Cross-Border Tax Planning with the Qualified Small Business Stock Exclusion
Time: Friday 9:20am - 10:10am Credits: 1 TB
The panel will focus on the basics of the Section 1202 qualified small business stock exclusion and then delve into the inbound and outbound tax planning opportunities that may be available with Section 1202. In particular, the panel will include a discussion of how Section 1202 can be utilized when structuring outbound investments in CFCs and the tax-efficient repatriation of profits earned abroad, as well as inbound investments where Section 1202 trumps the FIRPTA provisions.
Presenters:
Taxation of Mobile Executives
Time: Friday 10:30am - 11:20am Credits: 1 TB
Presenters:
Piecing it Together: An Inside Look into the IRS Whistleblower Program and Criminal Tax Investigations
Time: Friday 11:20am - 12:10pm Credits: 1 TB
This panel will hear directly from the IRS Whistleblower Director and his Deputy about how whistleblowers help further tax enforcement and also from the Deputy Chief of IRS Criminal Investigation about how criminal investigations are investigated and pieced together. Specifically, we will discuss government efforts to gather evidence from overseas through the use of whistleblowers, the importance of tax treaties, how investigators get witnesses to talk, the use of whistleblowers, and what we can expect from the international world of tax enforcement.
Presenters:
International Civil Tax Disputes
Time: Friday 12:50pm - 1:40pm Credits: 1 TB
New Commissioner, new budget, and new priorities. The IRS is increasing scrutiny in the international area, focusing on unreported foreign assets and activities, repatriation taxes, foreign investors with U.S. property, FATCA violations, tax withholding on foreign payments, receipt of foreign gifts, unfiled international information returns, and much more. This presentation explains critical international tax cases, administrative rulings, and other developments during the past year.
Presenters:
2024 Update on Inbound Structures for Foreign Investors
Time: Friday 1:40pm - 2:30pm Credits: 1 TB
With high interest rates and elevated asset values, 2024 is expected to be a very challenging US real estate investment climate. Nonetheless, US real estate is still a desired asset class for many foreign investors and international family offices. This session provides a 2024 update on inbound US real estate structuring, including key planning considerations for a high interest environment.
Presenters:
IRS Penalty Panel – How to Protect you and your firm from Malpractice.
Time: Friday 2:50pm - 3:40pm Credits: 1 TB
The IRS continues to systemically assess maximum penalties for late and imperfect international information returns (e.g. Form 3520,3520A, 5471, 5472 and 8938) without considering the facts. This session will provide the practitioner with “best practices” to avoid penalty assessments and practical strategies to convince the IRS to abate and refund penalties. We will also cover strategies to protect you and your firm from malpractice claims resulting from IRS penalty assessments and unhappy clients.
Presenters:
Tips to take Home
Time: Friday 3:40pm - 4:30pm 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 across both resident and nonresident considerations and include nonresident income tax reporting as well as disclosure forms (Forms 1040NR and 5472), along with U.S. foreign disclosure forms (Forms 3520, 5471, 8865, FINCEN 114).
Presenters:
Presenters:
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Lawrence Joseph Chastang, CPA
Lawrence J. Chastang, CPA, TEP specializes in international taxation, assisting clients ranging from small entrepreneurs to major multi-national subsidiaries with their individual and corporate work. He advises on a wide range of domestic and international tax issues with clients that include multinational corporations, partnerships, and entrepreneurs, as well as foreign persons investing in the...
Read more about Lawrence Joseph Chastang here -
William M Sharp Sr, Esq.
William Sharp is an attorney in Holland & Knight's Atlanta, Tampa and San Francisco offices (residing in Atlanta and San Francisco) with more than 35 years of experience representing clients in a wide variety of international tax planning and tax controversy cases. Mr. Sharp provides international and domestic tax advice to numerous U.S.-based and foreign-based clients, including publicly traded...
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 is known worldwide as the lawyer to seek out when companies require a creative, sophisticated solution to a complex international tax situation. Jeffrey is a tax partner in the Miami office. A skilled legal practitioner with more than 25 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...
Read more about Jeffrey L Rubinger 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 -
David A Cumberland, CGMA, CPA
DAVID A. CUMBERLAND, CPA, CGMA is lead shareholder of the International Tax Team 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 international work covering both individual and business tax preparation and consulting. Additionally, David is fluent in...
Read more about David A Cumberland here -
William B Sherman
William B. Sherman is a partner in Holland & Knight’s Miami and Fort Lauderdale offices. Mr. Sherman serves as chair of the firm’s Tax Team and concentrates his practice in the area of domestic and international taxation. He provides sophisticated tax planning for mergers and acquisitions, restructurings, joint ventures and investments for clients in diverse industries, such as hospitality...
Read more about William B Sherman 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, LLM (TAX), Esq.
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 -
Logan Evan Gans, CPA, Esq.
Logan E. Gans is a tax attorney and partner in the Miami office of Holland & Knight LLP. 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 their inbound investments in the United States...
Read more about Logan Evan Gans here -
Fred F Murray, CPA, JD, Esq.
Read more about Fred F Murray 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 -
Daniel N. Price
Dan's legal practice focuses on federal tax and Title 31 matters including civil and criminal defense of IRS audits and investigations. Dan also assists taxpayers in navigating the process of coming into compliance, especially international taxpayers who have for one reason or another failed to comply fully with U.S. tax and Title 31 laws. Dan's deep expertise concerning the IRS' voluntary...
Read more about Daniel N. Price here -
Paul D'Alessandro
Read more about Paul D'Alessandro here -
Mishkin Santa
Mishkin is a Principal of The Wolf Group and oversees the firm's international tax services in the areas of Offshore Voluntary Disclosure, US Exit Tax, foreign grantor and non-grantor trusts, nonresident alien taxation, international organization employee taxation, pre-immigration tax planning, and cryptocurrency. He assists individuals and businesses with highly specialized and complex tax...
Read more about Mishkin Santa here -
Hale E. Sheppard
Hale E. Sheppard (B.S., M.A., J.D., LL.M. and LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka in Atlanta. He defends individuals and businesses during tax audits, appeals, and litigation. Hale has participated in over 150 cases in the Tax Court, District Court, and Court of Appeals. In addition, he has obtained dozens of favorable Private Letter Rulings for...
Read more about Hale E. Sheppard here -
Nicole LaCava
Nikki is a CPA and Senior Tax Manager at The Wolf Group, who specializes in assisting entrepreneurs, high-net-worth individuals, and multinational businesses with their international tax planning and tax preparation needs. She regularly advises clients on tax-efficient structuring of international transactions, proper reporting of global income and assets, effective use of tax treaties, and ways...
Read more about Nicole LaCava here -
Maria Zhandalinova
Masha is a CPA and Senior Tax Manager at The Wolf Group, who specializes in assisting entrepreneurs, high-net-worth individuals, and multinational businesses with their international tax planning and tax preparation needs. She regularly advises clients on proper reporting for their international businesses (whether inbound to or outbound from the US), proper reporting of global income and assets...
Read more about Maria Zhandalinova here -
Lewis Greenwald
Lew has more than 30 years of deep technical experience in U.S. international tax planning, U.S. international tax compliance and controversy, and transfer pricing.His practice focuses on the provision of international tax planning for multinational corporations, entrepreneurs, and high-net worth individuals, including:• Tax-efficient acquisitions, dispositions, reorganizations, and repatriations•...
Read more about Lewis Greenwald here -
Rachel Ingwer
Rachel Ingwer advises clients on various domestic and cross-border tax issues, including both M&A and fund-related tax matters. In addition, she has significant experience with addressing tax issues for high net worth individuals.Rachel concentrates her practice on transactional matters. She advises clients on a wide variety of private equity and other transactional issues (both domestic and cross...
Read more about Rachel Ingwer here -
Maria Soledad Otero
Maria began her career in the International Assignment Services department of a Big Four accounting firm in Switzerland, consulting with individuals required to deal with multiple taxing jurisdictions. At first in Lausanne and, beginning in 2004, in Los Angeles, Maria worked with a broad range of clients including corporate executives on international assignments, multinational high net worth...
Read more about Maria Soledad Otero here -
Cynthia Brittain
Cynthia "Cindy" Brittain has decades of experience advising high-net-worth and ultra-high-net-worth individuals and families on domestic and international income and estate tax planning strategies and philanthropic endeavors. Her practice offers significant cross-border expertise for families whose members are multinational and whose companies have a global footprint. She helps clients navigate...
Read more about Cynthia Brittain here -
Kevin Sweeney
Kevin Sweeney is an experienced tax attorney and former federal prosecutor who specializes in defending clients in civil and criminal tax controversy and litigation matters. He focuses on high-stakes IRS audits, civil tax litigation, white-collar criminal defense and investigations, and whistleblower matters for high and ultra-high net worth individuals, corporate executives, business owners, and...
Read more about Kevin Sweeney here -
Scott Hessell
Scott Hessell has represented clients in complex commercial disputes throughout the country in both state and federal courts, as well as arbitration tribunals. He co-leads Sperling & Slater's tax shelter liability practice which is focused on professional liability claims arising out of tax shelter transactions. Mr. Hessell's specialized tax shelter liability practice has successfully recovered in...
Read more about Scott Hessell here -
Guy Ficco
Guy Ficco is the Deputy Chief of IRS Criminal Investigation. He is responsible for overseeing a worldwide staff of 3,200 CI employees, including approximately 2,200 special agents in 20 Field Offices and 11 foreign countries, who investigate crimes involving tax, money laundering, public corruption, cyber, ID theft, narcotics and terrorist-financing.Prior to his selection as Deputy Chief, Guy was...
Read more about Guy Ficco here -
Miles Humphrey
Miles Humphrey is an International Principal Tax Advisor in Baker McKenzie's NorthAmerica and EMEA Tax Practice Groups. Miles uses his deep knowledge of internationalaspects of US tax law and the interactions with UK/European tax law to act as a bridgebetween the UK and US to develop innovative tax planning solutions, often in response totax law changes. Prior to joining the Firm, Miles served as...
Read more about Miles Humphrey here -
John Hinman
John Hinman has served as the Director, IRS Whistleblower Office since May 2022. In this role, he serves as a principal advisor to the Deputy Commissioner for Services and Enforcement and top IRS officials on the execution of the Whistleblower Program. Prior to this position, John served for 5 years as the Director Field Operations, Transfer Pricing Practice in the IRS's Large Business &...
Read more about John Hinman here -
Dawn Applebaum
Dawn Applebaum, Whistleblower Office - Claim Administration, Associate Director began her IRS career in 1985 with the Examination Division in Miami, Florida. She has held many positions within the various compliance functions including Internal Revenue Agent, Special Enforcement Agent, Tax Computation Specialist, Appeals Officer, and Supervisory Internal Revenue Agent leading teams in Small...
Read more about Dawn Applebaum here -
Nicole Najjar
Experience Legal advice for individuals and family businesses; Structuring and implementing asset organization alternatives both in Brazil and abroad via a multidisciplinary approach that covers tax, corporate, succession and family matters; Expertise in corporate governance; Succession and estate planning; Advisory and litigation assistance with family and succession law; Assistance with...
Read more about Nicole Najjar here -
Eduardo Toretti
Admitted, 2006. He is an expert tax lawyer, with a wealth of experience counseling foreign and domestic clients with corporate tax matters and tax planning. He also advises HN individuals and families. Eduardo represents the firm's clients in tax disputes before the local tax authority and the Tax and Customs Courts. Praised by Chambers and Partners in 2017 for his "in-depth knowledge of taxation...
Read more about Eduardo Toretti here
Presenters:
Lawrence Joseph Chastang, CPA
Lawrence J. Chastang, CPA, TEP specializes in international taxation, assisting clients ranging from small entrepreneurs to major multi-national subsidiaries with their individual and corporate work. He advises on a wide range of domestic and international tax issues with clients that include multinational corporations, partnerships, and entrepreneurs, as well as foreign persons investing in the...Read more about Lawrence Joseph Chastang hereWilliam M Sharp Sr, Esq.
William Sharp is an attorney in Holland & Knight's Atlanta, Tampa and San Francisco offices (residing in Atlanta and San Francisco) with more than 35 years of experience representing clients in a wide variety of international tax planning and tax controversy cases. Mr. Sharp provides international and domestic tax advice to numerous U.S.-based and foreign-based clients, including publicly traded...Read more about William M Sharp Sr hereSeth 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 hereJeffrey L Rubinger, Esq.
Jeffrey is known worldwide as the lawyer to seek out when companies require a creative, sophisticated solution to a complex international tax situation. Jeffrey is a tax partner in the Miami office. A skilled legal practitioner with more than 25 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...Read more about Jeffrey L Rubinger hereRobert 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 hereMichael 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 hereSteven 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 hereDavid A Cumberland, CGMA, CPA
DAVID A. CUMBERLAND, CPA, CGMA is lead shareholder of the International Tax Team 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 international work covering both individual and business tax preparation and consulting. Additionally, David is fluent in...Read more about David A Cumberland hereWilliam B Sherman
William B. Sherman is a partner in Holland & Knight’s Miami and Fort Lauderdale offices. Mr. Sherman serves as chair of the firm’s Tax Team and concentrates his practice in the area of domestic and international taxation. He provides sophisticated tax planning for mergers and acquisitions, restructurings, joint ventures and investments for clients in diverse industries, such as hospitality...Read more about William B Sherman hereLeslie 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 hereAlfredo R Tamayo, CPA, LLM (TAX), Esq.
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 hereLogan Evan Gans, CPA, Esq.
Logan E. Gans is a tax attorney and partner in the Miami office of Holland & Knight LLP. 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 their inbound investments in the United States...Read more about Logan Evan Gans hereFred F Murray, CPA, JD, Esq.
Read more about Fred F Murray hereJeffrey 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 hereDaniel N. Price
Dan's legal practice focuses on federal tax and Title 31 matters including civil and criminal defense of IRS audits and investigations. Dan also assists taxpayers in navigating the process of coming into compliance, especially international taxpayers who have for one reason or another failed to comply fully with U.S. tax and Title 31 laws. Dan's deep expertise concerning the IRS' voluntary...Read more about Daniel N. Price herePaul D'Alessandro
Read more about Paul D'Alessandro hereMishkin Santa
Mishkin is a Principal of The Wolf Group and oversees the firm's international tax services in the areas of Offshore Voluntary Disclosure, US Exit Tax, foreign grantor and non-grantor trusts, nonresident alien taxation, international organization employee taxation, pre-immigration tax planning, and cryptocurrency. He assists individuals and businesses with highly specialized and complex tax...Read more about Mishkin Santa hereHale E. Sheppard
Hale E. Sheppard (B.S., M.A., J.D., LL.M. and LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka in Atlanta. He defends individuals and businesses during tax audits, appeals, and litigation. Hale has participated in over 150 cases in the Tax Court, District Court, and Court of Appeals. In addition, he has obtained dozens of favorable Private Letter Rulings for...Read more about Hale E. Sheppard hereNicole LaCava
Nikki is a CPA and Senior Tax Manager at The Wolf Group, who specializes in assisting entrepreneurs, high-net-worth individuals, and multinational businesses with their international tax planning and tax preparation needs. She regularly advises clients on tax-efficient structuring of international transactions, proper reporting of global income and assets, effective use of tax treaties, and ways...Read more about Nicole LaCava hereMaria Zhandalinova
Masha is a CPA and Senior Tax Manager at The Wolf Group, who specializes in assisting entrepreneurs, high-net-worth individuals, and multinational businesses with their international tax planning and tax preparation needs. She regularly advises clients on proper reporting for their international businesses (whether inbound to or outbound from the US), proper reporting of global income and assets...Read more about Maria Zhandalinova hereLewis Greenwald
Lew has more than 30 years of deep technical experience in U.S. international tax planning, U.S. international tax compliance and controversy, and transfer pricing.His practice focuses on the provision of international tax planning for multinational corporations, entrepreneurs, and high-net worth individuals, including:• Tax-efficient acquisitions, dispositions, reorganizations, and repatriations•...Read more about Lewis Greenwald hereRachel Ingwer
Rachel Ingwer advises clients on various domestic and cross-border tax issues, including both M&A and fund-related tax matters. In addition, she has significant experience with addressing tax issues for high net worth individuals.Rachel concentrates her practice on transactional matters. She advises clients on a wide variety of private equity and other transactional issues (both domestic and cross...Read more about Rachel Ingwer hereMaria Soledad Otero
Maria began her career in the International Assignment Services department of a Big Four accounting firm in Switzerland, consulting with individuals required to deal with multiple taxing jurisdictions. At first in Lausanne and, beginning in 2004, in Los Angeles, Maria worked with a broad range of clients including corporate executives on international assignments, multinational high net worth...Read more about Maria Soledad Otero hereCynthia Brittain
Cynthia "Cindy" Brittain has decades of experience advising high-net-worth and ultra-high-net-worth individuals and families on domestic and international income and estate tax planning strategies and philanthropic endeavors. Her practice offers significant cross-border expertise for families whose members are multinational and whose companies have a global footprint. She helps clients navigate...Read more about Cynthia Brittain hereKevin Sweeney
Kevin Sweeney is an experienced tax attorney and former federal prosecutor who specializes in defending clients in civil and criminal tax controversy and litigation matters. He focuses on high-stakes IRS audits, civil tax litigation, white-collar criminal defense and investigations, and whistleblower matters for high and ultra-high net worth individuals, corporate executives, business owners, and...Read more about Kevin Sweeney hereScott Hessell
Scott Hessell has represented clients in complex commercial disputes throughout the country in both state and federal courts, as well as arbitration tribunals. He co-leads Sperling & Slater's tax shelter liability practice which is focused on professional liability claims arising out of tax shelter transactions. Mr. Hessell's specialized tax shelter liability practice has successfully recovered in...Read more about Scott Hessell hereGuy Ficco
Guy Ficco is the Deputy Chief of IRS Criminal Investigation. He is responsible for overseeing a worldwide staff of 3,200 CI employees, including approximately 2,200 special agents in 20 Field Offices and 11 foreign countries, who investigate crimes involving tax, money laundering, public corruption, cyber, ID theft, narcotics and terrorist-financing.Prior to his selection as Deputy Chief, Guy was...Read more about Guy Ficco hereMiles Humphrey
Miles Humphrey is an International Principal Tax Advisor in Baker McKenzie's NorthAmerica and EMEA Tax Practice Groups. Miles uses his deep knowledge of internationalaspects of US tax law and the interactions with UK/European tax law to act as a bridgebetween the UK and US to develop innovative tax planning solutions, often in response totax law changes. Prior to joining the Firm, Miles served as...Read more about Miles Humphrey hereJohn Hinman
John Hinman has served as the Director, IRS Whistleblower Office since May 2022. In this role, he serves as a principal advisor to the Deputy Commissioner for Services and Enforcement and top IRS officials on the execution of the Whistleblower Program. Prior to this position, John served for 5 years as the Director Field Operations, Transfer Pricing Practice in the IRS's Large Business &...Read more about John Hinman hereDawn Applebaum
Dawn Applebaum, Whistleblower Office - Claim Administration, Associate Director began her IRS career in 1985 with the Examination Division in Miami, Florida. She has held many positions within the various compliance functions including Internal Revenue Agent, Special Enforcement Agent, Tax Computation Specialist, Appeals Officer, and Supervisory Internal Revenue Agent leading teams in Small...Read more about Dawn Applebaum hereNicole Najjar
Experience Legal advice for individuals and family businesses; Structuring and implementing asset organization alternatives both in Brazil and abroad via a multidisciplinary approach that covers tax, corporate, succession and family matters; Expertise in corporate governance; Succession and estate planning; Advisory and litigation assistance with family and succession law; Assistance with...Read more about Nicole Najjar hereEduardo Toretti
Admitted, 2006. He is an expert tax lawyer, with a wealth of experience counseling foreign and domestic clients with corporate tax matters and tax planning. He also advises HN individuals and families. Eduardo represents the firm's clients in tax disputes before the local tax authority and the Tax and Customs Courts. Praised by Chambers and Partners in 2017 for his "in-depth knowledge of taxation...Read more about Eduardo Toretti hereMajor 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