The Florida Bar
www.floridabar.org


The Florida Bar Continuing Legal Education Committee and the
Tax Section present
30th Annual International Tax Conference

Course Classification: Advanced Level
Live Presentation: January 19-20, 2012
J.W. Marriott * 1109 Brickell Avenue * Miami, Florida 33131 * 800-228-9290

Course No. 1313R


The seminar is an advanced conference on international tax and trust issues, both for U.S. taxpayers investing abroad and non-US taxpayers investing in the United States. Topics to be covered include: Current Developments in International Taxation -- Outbound Update, International Choice of Entity Restructuring, International Investment and Business Structures—Identifying and Reporting the Proper Taxpayer, Treaty Provisions that Every Individual (or His Lawyer/CPA) Should Know, The Foreign Account Tax Compliance Act (“FATCA”) or is it "Forget about the Carrot Approach" -- the U.S. Opts for Swinging the Stick, The FBAR Regulations are Now Final – The FATCA – Reporting is Coming – A Survival Guide for CPA’s and Attorneys, International Tax Planning for Companies Operating in Cyberspace, PFICs owned by Foreign Trusts: How to Treat Them and How to Report Them, Current Developments in International Taxation -- Inbound Update, Update on Tax Efficient Planning Transactions and Structures, Practical Discussion of Intellectual Property Migrations for Closely Held U.S. Companies, Panel on Miscellaneous Civil and Criminal Procedural Issues, The U.S. and Canada – A Cross Border Perspective (How to Walk the Line Without Crossing the Line), Warning to All Foreign Wealthy Individuals: When Large Estates, Foreign Trusts and U.S. Beneficiaries are Involved, a Move to the U.S., Even Temporarily, May Be Harmful to Your (Financial) Health, Do Not Proceed Until You Have Consulted with U.S. Tax Counsel, and Ethical Issues in Dealing with International Private Clients.



Thursday, January 19, 2012


8:00 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, FICPA’s International Tax Conference Co-Chair
Shawn P. Wolf, Esq., The Florida Bar Tax Section’s International Tax Conference Co-Chair

9:00 a.m. - 9:50 a.m.
Current Developments in International Taxation -- Outbound Update
Larry Kemm, Esq., Tampa, FL & Zurich, Switzerland

9:50 a.m. - 10:40 a.m.
International Choice of Entity Restructuring
Seth J. Entin, Esq., Miami, FL

10:40 a.m. - 11:00 a.m.
Networking Break
Sponsored by: ATC

11:00 a.m. - 11:50 a.m.
International Investment and Business Structures—Identifying and Reporting the Proper Taxpayer
Leslie A. Share, Esq., Coral Gables, FL

11:50 a.m. - 1:20 p.m.
Lunch (included in registration fee)
Treaty Provisions that Every Individual (or His Lawyer/CPA) Should Know
Patricia A. Brown, Director/Graduate Program in Taxation, University of Miami School of Law
Michael G. Pfeifer, Washington, D.C.

1:20 p.m. - 2:10 p.m.
The Foreign Account Tax Compliance Act (“FATCA”) or is it "Forget about the Carrot Approach" -- the U.S. Opts for Swinging the Stick
Ozzie A. Schindler, Esq., Miami, FL
Erika G. Litvak, Esq., Miami, FL

2:10 p.m. - 3:00 p.m.
The FBAR Regulations are Now Final – The FATCA – Reporting is Coming – A Survival Guide for CPA’s and Attorneys
Kevin Packman, Holland & Knight Partner, Miami, FL
James Wall, J.H. Cohn LLP Principal, New York, NY

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

3:20 p.m. - 4:10 p.m.
International Tax Planning for Companies Operating in Cyberspace
Jeffrey Rubinger, KPMG, LLP Principal, Fort Lauderdale, FL

4:10 p.m. - 5:00 p.m.
PFICs owned by Foreign Trusts: How to Treat Them and How to Report Them
Hal J. Webb, Esq., Miami, FL
Arthur J. Dichter, Esq., Miami, FL

5:00 p.m. – 6:30 p.m.
Networking Reception
Sponsored by: Trident Trust


Friday, January 20, 2012

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, Esq., Tampa & Zurich, Switzerland

9:20 a.m. - 10:10 a.m.
Update on Tax Efficient Planning Transactions and Structures
Robert F. Hudson, Jr., Esq., Miami, FL

10:10 a.m. - 10:25 a.m.
Networking Break

10:25 a.m. - 11:15 a.m.
Practical Discussion of Intellectual Property Migrations for Closely Held U.S. Companies
James H. Barrett, Esq., Miami, FL
Steven Hadjilogiou, Esq., Miami, FL
Bob Heller,PricewaterhouseCoopers

11:15 a.m. - 12:55 p.m.
Panel on Miscellaneous Civil and Criminal Procedural Issues
Robert E. Panoff, Esq., Panel Moderator, Miami, FL
Sam Berman, Special Counsel to the Small Business/Self-Employed Division Counsel, IRS, Washington, D.C.
David A. Breen, Senior Counsel in the Small Business/Self-Employed Division of IRS’s Office of Chief Counsel, Philadelphia, PA
Kevin M. Downing, Senior Trial Attorney, Office of the Assistant Attorney General, Tax Division, U.S. Department of Justice, Washington, D.C.
Jose (Tony) A. Gonzalez, Special Agent in Charge of the Miami Field Office of IRS Criminal Investigation (CI), Plantation, FL
Rosemary J. Sereti, Director, International Individual Compliance in the Large Business and International (LB&I) Division, New York, NY
Toni Marie Weirauch, Deputy Director of International Operations for Criminal Investigation, Washington, D.C.

12:55 p.m. - 1:30 p.m.
Lunch (included in registration fee)

1:30 p.m. - 2:20 p.m.
The U.S. and Canada – A Cross Border Perspective (How to Walk the Line Without Crossing the Line)
Jack Bernstein, Esq., Toronto, Canada

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

2:35 p.m. - 3:25 p.m.
Warning to All Foreign Wealthy Individuals: When Large Estates, Foreign Trusts and U.S. Beneficiaries are Involved, a Move to the U.S., Even Temporarily, May Be Harmful to Your (Financial) Health. Do Not Proceed Until You Have Consulted with U.S. Tax Counsel
Michael Rosenberg, Esq., Coral Gables, FL
Jose L. Nuñez, Esq., Coral Gables, FL

3:25 p.m. - 4:15 p.m.
Ethical Issues in Dealing with International Private Clients
Steve Cantor, Esq., Miami
Renea M. Glendinning, CPA, Sarasota, FL


1313-30th-InternatlTaxConference-12-for PDF.pdf1313-30th-InternatlTaxConference-12-for PDF.pdf











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Effective July 1, 2010, every CLE course will feature an electronic course book in lieu of a printed book for all live presentations, live webcasts, webinars, teleseminars, audio CDs and video DVDs. This searchable, downloadable, printable material will be available via e-mail several days in advance of the live course presentation or thereafter for purchased products. We strongly encourage you to purchase the book separately if you prefer your material printed but do not want to print it yourself.

Print the attached PDF brochure for more detailed information.



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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]