The Florida Bar

The Florida Bar
and the Tax Section present
31st Annual International Tax Conference

Course Classification: Advanced Level
January 10-11, 2013
J.W. Marriott Hotel - 1109 Brickell Avenue - Miami, Florida 33131 - 800-228-9290

Course No. 1440R

This is an advanced level course that will cover topics such as: International Taxation - International Choice of Entity Restructuring - International Investment - The FBAR Regulations - The FATCA - PFICs Owned by Foreign Trusts - Intellectual Property Migrations and much more.

Thursday, January 10, 2013

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 International Tax Conference, Co-Chair
Shawn Wolf, Esq./Florida Bar Tax Section International Tax Conference, Co-Chair

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

9:50 a.m. – 10:40 a.m.
Tax Treaties in Operation: New Directions in Intergovernmental Cooperation
Mary C. Bennett, Esq./Partner/Baker & McKenzie LLP/Washington, D.C.
Patricia A. Brown/Director/Graduate Program in Taxation, University of Miami School of Law/Miami, FL

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

11:00 a.m. – 11:50 a.m.
An Overview of the Various Pitfalls of Trusts and “Domestic” LLCs in International Tax Planning
Steven L. Cantor, Esq./Partner/Cantor & Webb P.A./Miami, FL
Hal J. Webb, Esq./Partner/Cantor & Webb P.A./Miami, FL

11:50 a.m. – 1:20 p.m.
Lunch - “Current Developments and Trends in International Taxation”
Lee Sheppard/Contributing Editor/Tax Notes/Washington D.C.

1:20 p.m. – 2:10 p.m.
The Foreign Account Tax Compliance Act (FATCA) – A Small Step for the United States, a Giant Leap (Forward?) for Mankind
Ozzie A. Schindler, Esq./Shareholder/Greenberg Traurig, P.A./Miami, FL
Carl A. Fornaris, Esq./Shareholder/Greenberg Traurig, P.A./Miami, FL

2:10 p.m. – 3:00 p.m.
The Nuts and Bolts of Complying with and Implementing FATCA
Alfredo Tamayo, Esq./Associate/Packman, Neuwahl & Rosenberg/Coral Gables, FL
Toby Lawrence, CPA/Partner/Financial Institutions Consulting Services/CliftonLarsonAllen LLP/Cedar Rapids, IA

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

3:20 p.m. – 4:10 p.m.
China: Challenges and Opportunities for U.S. Tax Professionals
George Qin, CPA/Partner/MaloneBailey, LLP/Houston, TX

4:10 p.m. – 5:00 p.m.
An Overview of Mayo and Home Concrete, and a Practical Discussion of How These Cases May Impact International Tax Planning
Samuel C. Ullman, Esq./Partner/Bilzin Sumberg Baena Price & Axelrod LLP/Miami, FL
Robert Chaves, Esq./Shareholder/Gutter Chaves Josepher Rubin Forman Fleisher, P.A./
Boca Raton, FL

5:00 p.m. – 6:30 p.m.
Cocktail Reception
Hosted by Trident Trust, Leading Provider of Corporate, Trust Fund Services to lawyers and Accountants Worldwide -

Friday, January 11, 2013

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./Sharp Kemm P.A./Tampa, FL/San Francisco, CA/Zurich, Switzerland

9.20 a.m. – 10:10 a.m.
Application of the Economic Substance Doctrines—Are We Free to Structure Businesses and Investments in a Manner Most Advantageous to Our Clients?
Robert F. Hudson, Jr., Esq./Partner/Baker & McKenzie LLP/Miami, FL

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

10:25 a.m. – 11:15 a.m.
Selling from Abroad into the United States: Challenges and Opportunities
Seth J. Entin, Esq./Shareholder/Greenberg Traurig, P.A./Miami, FL

11:15 a.m. – 12:55 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

12:55 p.m. – 1:30 p.m.

1:30 p.m. – 2:20 p.m.
Ethical Issues Confronting Practitioners When Dealing With Clients from Countries in Turmoil
Lawrence J. Chastang, CPA/Managing Partner of International Services/CliftonLarsonAllen LLP/Orlando, FL
Leslie Share, Esq./Shareholder/Packman, Neuwahl & Rosenberg P.A./Coral Gables, FL

2:20 p.m. – 2:40 p.m.
Networking Break

2:40 p.m. – 3:30pm
Tax Efficient Repatriation of Profits to and from the United States
Jeffrey L. Rubinger, Esq./Partner/Bilzin Sumberg/Miami, FL

3:30 p.m. – 4:20 p.m.
A Practical Approach to Navigating Through International Disclosures
Renea M. Glendinning, CPA/Shareholder/Kerkering, Barberio & Co./Sarasota, FL
Arthur J. Dichter, Esq./Partner/Cantor & Webb P.A./Miami, FL


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).

*** Live ** Videotaping Session * Videotaped Replay

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[Revised: 06-01-2008]