The Florida Bar

The Florida Bar
and the Tax Section present
32nd Annual International Tax Conference

Course Classification: Advanced Level
Live Presentation - January 23-24, 2014 - J.W. Marriott Hotel, 1109 Brickell Avenue, Miami, FL 33131 - 800-228-9290

Course No. 1715R

The 32st Annual International Tax Conference, presented by the Tax Section of the Florida Bar and the Florida Institute of Certified Public Accountants, is designed as an intermediate to advanced level conference. This conference will update practitioners in the accounting, legal, business and other financial sectors on current and relevant international tax topics. Prominent tax practitioners (both attorneys and CPAs), as well as government speakers, will discuss new developments, tax planning ideas, current issues, and changes in the laws applying to international ta planning and how it impacts your clients. For those no located in South Florida, in addition to all of the technical knowledge, add the fact that this is located in Miami ... in January! This is the "DO NOT MISS" international tax conference of the year!

Thursday, January 23, 2014

7:30 a.m. - 8:45 a.m. Late Registration and Continental Breakfast

8:45 a.m. - 9:00 a.m. Introduction and Opening Remarks:
Lawrence J. Chastang, CPA /Shawn Wolf, Esq., Coral Gables & Boca Raton, Florida
FICPA/Fla Bar Conference Co-Chairs.

9:00 a.m. –9:50 a.m. Current Developments in International Taxation – Outbound Update
Larry R. Kemm, Esq./Sharp Kemm P.A./Tampa, FL

This session will review current U.S. developments in "outbound" international taxation and will provide a comprehensive overview of all key statutory, regulatory, administrative, judicial and related authorities that occurred during the past 12 months.

9:50 a.m -10:40 a.m. US taxation of Partnerships in the International Context
Something Old, Something New and Something Blue?
Robert F. Hudson, Jr., Principal, Baker & McKenzie LLP
Robert H. Moore, Partner, Baker & McKenzie LLP

The topic will address interesting US income, gift and estate tax planning uses and planning techniques of partnerships in the international and cross-border situations, both for individuals and multinational entities (including Section 956, subpart F, FTC, ECI, PIE, and of course estate tax issues).

10:40 a.m. -11:00 a.m. Networking Break

11:00 a.m. – 11:50 a.m. FATCA: The Impact on the Trust and Private Client Industry
Denise Hintzke, Global FATCA Tax Leader, Deloitte Tax LLP

An update on the FATCA requirements, including the latest news on Intergovernmental Agreements and reporting requirements that may be implemented by other countries with a focus on the impact on the trust and private client industry.

11:50 a.m. – 1:20 p.m. Lunch Speaker
What Every US Tax Practitioner Must Know About VAT
John Voyez, Partner, Smith & Williamson LLP

1:20 p.m. – 3:00 p.m. Optimizing the Tax Consequences of Inbound Investments into the US from the UK, Brazil, Venezuela and
Moderators: Hal J. Webb, Esq. /Partner /Cantor & Webb P.A./Miami, FL
James H. Barrett/Partner/Baker & McKenzie LLP/Miami
Humberto Sanches/Partner/ Ulhôa Canto/Sao Paulo, Brazil
Juan Guillermo Ruiz/Partner/Posse Herrera Ruiz/Bogota,
Ronald Evans/Partner/ Baker & McKenzie, S.C./Caracas,
Paul Hocking/Chairman/Frank Hirth/London, United Kingdom

This two-hour panel will address the US and foreign tax planning opportunities that are available to investors from Brazil, the UK, Venezuela and Colombia when they invest in the US. The panel discussion will cover both US and foreign income and gift and estate tax planning opportunities for investments in the US. In addition to covering typical inbound investments, the session will also address pre-immigration planning from a US and a foreign law perspective in the four covered jurisdictions. Specific topics that will be addressed will include choice of entity, financing options, optimizing the effective tax rate on US operating income, repatriation planning, disposition planning, foreign tax credit issues, treaties, pre-immigration planning techniques and related ethical issues.

3:00 p.m. – 3:20 p.m. Networking Break

3:30 p.m. – 4:10 p.m. Expatriation: An Update Several Years After HEART Surgery.
Shawn P. Wolf, Esq., Packman, Neuwahl & Rosenberg, Coral Gables & Boca Raton, Florida
Laura U. Daly, IRS Counsel (Invited)
Lara A. Banjanin, IRS Counsel (Invited)

This presentation will be an interactive dialogue that will provide an overview and discussion of the current U.S. expatriation rules of Section 877A, 2801 and 7701(b)(6), as well as Notice 2009-85 and any guidance that has been published on Section 2801.

4:10 p.m. – 5:00 p.m. FIRPTA Under Fire
Renea M. Glendinning, CPA/Shareholder/Kerkering, Barberio & Co./Sarasota,
Jonathan H. (Jason) Warner, Law Offices of Jonathan H. (Jason) Warner, P.A.,
Miami, FL

Reviews current criticisms of FIRPTA and reform proposals; discusses compliance problems caused by new ITIN requirements and Qualified Substitute procedure; discusses impact on FIRPTA of inversion regulations and how to deal with inherited bad (or lack of) planning for U.S. real estate investments by foreigners.

Friday, January 24, 2014

8:00 a.m. – 8:30 a.m. Continental Breakfast

8:30 a.m. – 9:20 a.m. Current Developments in International Taxation: Inbound Update
William M. Sharp, Sr., Esq./Sharp Kemm P.A./Tampa, FL, San Francisco,
CA/Zurich, Switzerland

This session provides an overview of all key statutory, regulatory, administrative, judicial and related authorities' changes that have occurred during the past 12 months, including a segment dealing with relevant portions of foreign law developments as well as an update of the ongoing IRS/DOJ’s efforts in combating global tax noncompliance and bank secrecy.

9:20 a.m. – 10:10 a.m. The Portfolio Interest Exemption: Opportunities and Traps
Seth J. Entin, Esq./ Shareholder/Greenberg Traurig, P.A./Miami, FL
The use of debt qualifying for the portfolio interest exemption is a powerful tool in inbound international tax planning. This presentation will focus on the nuances of the exemption, some of the beneficial tax planning that is available, and various misconceptions and pitfalls that exist.

10:10 a.m. -10:30 a.m. Networking Break

10:30 a.m. – 11:20 a.m. Tax Planning with the U.S. Virgin Islands and Puerto Rico – Recent Developments, Tax Incentives, and Litigation
Marjorie Roberts, Esq./Marjorie Roberts, P.C., St. Thomas, United States Virgin Islands
Joseph A. DiRuzzo, III, Esq., CPA/Fuerst Ittleman David & Joseph, PL, Miami, Florida

This session provides an overview of the tax planning and opportunities offered in the U.S. Virgin Islands and Puerto Rico, including the statutory provisions (federal and local), the relevant Treasury Regulations, and the IRS’s view of possession taxation. The session further discusses recent litigation developments, and tax credits in the news. Finally, the session will also discuss unique tax planning and immigration opportunities offered in the territories.

11:20 a.m. – 12:10 p.m. Panel on Miscellaneous Civil and Criminal Procedural Issues Robert E. Panoff, Esq./Panel Moderator/Tax Litigator/Miami, FL& Select
IRS and law enforcement speakers

This panel continues its tradition of providing up-to-the minute information regarding civil and criminal international tax procedural issues affecting everyday tax practitioners and their clients. Greater emphasis will be on taxpayers within the jurisdiction of the Small Business Self Employed operating division, but the panel also will discuss issues affecting taxpayers within the (newly renamed) large business and international operating division of the IRS.

12:10 p.m. – 1:30 p.m. Lunch Speaker
Update from Washington DC.
Robert B. Stack/Deputy Assistant Secretary/International Tax Affairs

1:30 p.m. – 2:20 p.m. Tax Traps in Canada – US Personal Tax Planning
Jack Bernstein, Senior Tax Partner, Aird & Berlis, LLP

This presentation will discuss the risk of LLCs, estate freezes gone wrong, gift tax traps and some common mistakes made in the cross-border real estate.

2:20 p.m. – 2:35 p.m. Networking Break

2:35 p.m. – 3:25 p.m. Foreign Pensions/Retirement Plans and the U.S. Taxpayer
Lawrence J. Chastang, CPA, CliftonLarsonAllen LLP
Steve Yeager, CPA, CliftonLarsonAllen LLP

Prior to the issuance of Form 8938 “Statement of Specified Foreign Financial Assets” reporting issues associated with foreign pensions/retirement plans were often overlooked, ignored or omitted. The presentation will address the proper U.S. tax reporting of such accounts in an environment severely lacking in regulatory or legal authority.

3:25 p.m. - 4:15 p.m. Rectifying International Tax and Information Return Errors and Seeking Penalty Abatement--Practical and Ethical Considerations
Arthur J. Dichter, Esq./Partner / Cantor & Webb P.A. / Miami, FL
Leslie Share, Esq./Shareholder/Packman, Neuwahl & Rosenberg P.A./
Coral Gables, FL

The purpose of this presentation is to review and consider the respective and mutual roles of CPAs and attorneys in connection with representing clients in matters involving untimely filed or erroneously prepared international tax and information returns. The Internal Revenue Service’s enhanced examination of foreign-related tax filings, the increasing imposition of all potentially applicable penalties and the perceived unwillingness to abate them has put enormous pressure upon tax practitioners to solve such post-compliance issues. We will focus upon how such matters should be approached and handled from both a technical and practical standpoint, while taking into account the pertinent ethical rules and guidelines.

(September 10, 2013)

32nd ITC Brochure.pdf32nd ITC Brochure.pdf

To register for the live Webcast, please print and complete the registration form then send with payment by mail or fax. Call The Florida Bar Order Entry Department at (800) 342-8060 ext. 5831 with any questions.

AUDIO WEB CAST CONNECTION: Live audio web cast attendees receive course materials and audio via the Internet. Connection instructions will be e-mailed 2 days prior to scheduled course; or contact The Florida Bar Order Entry Department at 850-561-5831 for instructions 2 days prior to the event.

Florida Bar CLE Courses feature electronic course materials for all live presentations, live webcasts, webinars, teleseminars, audio CDs and video Dvds. This searchable electronic material can be downloaded and printed and is available via e-mail several days in advance of the live presentation or thereafter for purchased products. The Course Book can be purchased separately. Effective July 1, 2010.



Credit may be applied to more than one of the programs above but cannot exceed the maximum for any given program. Please keep a record of credit hours earned. RETURN YOUR COMPLETED CLER AFFIDAVIT PRIOR TO CLER REPORTING DATE (see Bar News label). (Rule Regulating The Florida Bar 6-10.5).

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[Revised: 06-01-2008]