International Tax Conference- Virtual (ITCWEB)

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
• Migrating intellectual property (IP)
• Debt/equity determinations; bad debt/worthless stock deductions
• Transfer pricing planning (establishing, documenting, and pricing intercompany relationships) and transfer pricing controversies
• U.S. international tax compliance (IRS Forms 5471, 5472, 8865, 8858, 8621, and 3520), with a view to the avoidance of penalties and statute of limitation issues
• Cross-border foreign currency transactions
• Voluntary disclosures and expatriations (including relocations to Puerto Rico)

Seth Entin

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 recognized as "Miami Lawyer of the Year" in Tax Law by The Best Lawyers in America guide. He has also been recognized by Chambers USA— America's Leading Business Lawyers guide since 2007. Seth is currently ranked Band 1 in Tax for Florida and has been noted by Chambers for his "practical approach" and "strong knowledge base" that is always "focused on achieving the best possible results."

Seth has written for Tax Notes, Tax Notes International, Bloomberg Tax & Accounting and Law 360, and has been quoted by The Wall Street Journal and Bloomberg BusinessWeek. In addition, he is an adjunct professor of international taxation at the University of Miami School of Law and has served as Director of International Tax Law for The Florida Bar Tax Section.

A fellow of the American College of Tax Counsel, Seth regularly speaks at national and international tax conferences, including before the American Bar Association (ABA), International Bar Association (IBA), International Fiscal Association (IFA), Florida Institute of Certified Public Accountants (FICPA) and The Florida Bar. He also passed the Certified Public Accountant exam.

Scott 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-exempt entities in structuring and negotiating M&A and other strategic transactions. 
Scott also represents clients in domestic and international tax controversy matters, including administrative audits and appeals before the Internal Revenue Service, as well as negotiation and settlement of taxes and civil penalties. 
Scott received his law degree from Vanderbilt University, where he was honored for outstanding scholastic achievement, and received his LL.M. in tax from New York University, where he earned high honors. He is a frequent speaker and has been recognized by Chambers USA and Best Lawyers in America as one of the leading tax lawyers in Georgia.

Justin 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 insurance experience allows Justin to bring a unique perspective to each matter. Prior to joining the insurance world, Justin, a licensed attorney in three states and the District of Columbia, facilitated efficient and timely negotiations, planning, and structuring for Fortune 500 companies and high growth businesses, providing tax and business-centric advice to help his clients achieve objectives and avoid costly disputes.
Justin is a frequent speaker at industry events and on tax focused podcasts and has published multiple articles on tax and tax insurance. He holds an LL.M. in taxation from the NYU School of Law, a J.D., magna cum laude, from New York Law School, and a B.A., magna cum laude, in chemistry from Florida Atlantic University.

Christopher Callahan

As the Co-Chair of the International Taxation & Wealth Planning Practice, Christopher provides wealth management and international tax planning advice to high net worth clients and businesses.  He handles a full range of international taxation and wealth issues, including:

U.S. taxation of foreign pensions, retirement accounts and similar plans
Outbound income tax planning for U.S. citizens and income tax residents
Subpart F, GILTI, FDII, and PFIC planning
Inbound income and estate tax planning for non-resident individuals, companies, trusts and estates
Including investment in U.S. real estate, securities, and active businesses, as well as trust planning, FIRPTA withholding matters, pre-immigration tax planning, and structuring investment through U.S. funds
International tax planning for partnerships and corporations
Cross border wealth and estate planning
U.S. income and estate tax treaties
Tax compliance disclosure matters (e.g., submissions to the IRS Streamlined Offshore Procedures)

Daniel 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 disclosure practice, the Streamlined Filing Compliance Procedures, and international penalty regimes allows him craft strategies to mitigate civil penalties and criminal exposure.

For over 19 years Dan served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. Dan's prior government service included extensive work in the arena of international enforcement and included assisting the IRS in completely revising the Voluntary Disclosure Practice. Dan also worked with the various Offshore Voluntary Disclosure Programs, the Streamlined Filing Compliance Procedures, foreign bank account reporting, Bank Secrecy Act investigations, various LB&I compliance campaigns, expatriation issues, international collection of taxes, and much more.

Dan received his J.D., with honors, from the University of Texas School of Law. While attending law school, he passed the Uniform CPA exam (not licensed as a CPA) and was a staff member on two law journals.  

Arianne Plasencia

Arianne Plasencia is an attorney in the Miami office of McDermott Will & Emery. Ms. Plasencia focuses her on US & International tax matters. She provides international and domestic income, gift and estate tax planning for entities and high-net-worth individuals with a focus on multijurisdictional families and inbound investment planning. She also represents clients in tax audits, offshore voluntary disclosures, and streamlines disclosures as well as advises them on criminal tax examinations and other criminal tax matters. Arianne provides estate and income tax advice, including pre-immigration planning, to wealthy families and works on a wide variety of real estate matters.

Ryan Coyle

Ryan J. Coyle focuses his practice on international tax matters, with an emphasis on providing tax-efficient restructuring solutions for high-net-worth international families and their closely held businesses. In addition to advising US-based families on income, gift, and estate tax matters, he assists non-US families with tax matters relating to pre-immigration planning and inbound investment.

Ryan has extensive experience advising on US anti-deferral legislation (i.e., Subpart F and GILTI) applicable to non-US entities that become controlled foreign corporations as a result of migration to the United States. In addition, he advises on planning related to tax treaty interpretation, expatriation, qualified small business stock (QSBS), the Foreign Investment in Real Property Tax Act (FIRPTA), and international enforcement initiatives such as the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS). Ryan also advises non-US residents on US gift and estate tax rules affecting non-US residents with US income and assets, as well as US residents with non-US income and assets.

In conjunction with such planning, Ryan assists high-net-worth individuals in establishing complex trust structures and other vehicles to protect wealth and to efficiently transfer wealth from one generation to another. He advises on the formation of private trust companies to serve as trustees of family trusts and assists trust companies with compliance requirements.

Having been based in London and Hong Kong at various points in his career, Ryan has unique insight into the needs of global clients and speaks extensively on topics related to international taxation.

Bradley Birkenfeld

Bradley C. Birkenfeld is the most significant financial whistleblower in history and the author of Lucifer's Banker UNCENSORED: The Untold Story of How I Destroyed Swiss Bank Secrecy, (September 2020). As an international private banker he exposed how UBS, the world's largest bank, helped ultra-wealthy Americans commit billions in tax fraud. His bombshell revelations cracked the impenetrable fortress of Swiss banks, proving that offshore financial institutions systematically aided clients' tax evasion, corruption and terrorist activities. His case triggered monumental changes in banking laws, the federal tax code and international tax treaties.

In 2005, despite a thriving career spanning Credit Suisse, Barclays Bank and UBS, Birkenfeld could no longer keep silent about bank-enabled tax fraud. When UBS rejected his concerns, he turned to the U.S. authorities. Though jailed for 30 months, he was soon vindicated with a record-breaking IRS reward: his work had enabled the U.S. Treasury to recover $30 billion in back taxes, fines and penalties. The case set off a domino effect of international investigations into offshore banking's secret crimes, including the Panama Papers and much more. Now retired, Birkenfeld is a philanthropist and supports whistleblowing efforts worldwide.

Daniel Mayo

Jeffrey Rubinger

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 and thorough understanding of the business issues, his clients face every day. Jeff has been recognized as one of America's leading tax lawyers by Chambers USA.  

From U.S. companies expanding overseas to foreign businesses investing in the United States, clients turn to Jeff for his extensive knowledge of the tax laws in a wide variety of jurisdictions, including countries in South America, Europe, Asia, and the Middle East. Jeff is distinctive in Florida for his significant experience with outbound matters.

William Sharp Sr

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 and closely held entities. His tax practice also focuses on globally oriented high-net-worth clients, including many U.S. and foreign-based family offices. Mr. Sharp has served as lead counsel with respect to U.S. Tax Court proceedings, Internal Revenue Service (IRS) appeals and examination cases. He also has served as lead counsel or co-counsel to more than 1,500 IRS voluntary disclosure cases.

Mr. Sharp advises financial institutions and their clients on international tax enforcement and compliance initiatives. In addition, Mr. Sharp represents several Swiss-based banking institutions in connection with the U.S. Department of Justice Swiss Bank Program, including the largest bank participating in the program and one of the major cantonal banks (both cases were resolved under Category 3 of the program). Mr. Sharp also has extensive experience in handling matters related to the Foreign Account Tax Compliance Act (FATCA) and other cross-border compliance and disclosure initiatives.

Mr. Sharp has served as an adjunct professor at the Stetson University College of Law and a lecturer at the University of South Florida Executive MBA program. He is a frequent speaker on international tax and business law matters. In addition, Mr. Sharp has been featured as well as quoted in publications such as the Wall Street Journal, The New York Times, The Washington Post, Reuters, USA Today and other media on international tax issues.

Prior to joining Holland & Knight, Mr. Sharp was founding and managing partner of a boutique international tax law firm with offices in Tampa, San Francisco, Washington, D.C., and Zurich, Switzerland.

Caroline 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 administrative tax tribunals, providing related tax advice, conducting internal investigations, consideration of domestic and foreign compliance options including voluntary disclosures, and representing individuals and institutions in criminal tax investigations and prosecutions.

Jeffrey Neiman

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 the United States government's offshore tax enforcement efforts, Jeff has vast experience assisting clients who nd themselves with unreported or undeclared bank accounts outside of the United States. Jeff advises clients regarding the Internal Revenue Service's Offshore Voluntary Disclosure Program as well as clients who face civil and Reports ("FBARS").

Prior to being a Founding Member of Marcus Neiman & Rashbaum LLP, Jeff had his own law firm that focused on white collar and tax controversy matters. An alum of the United States Department of Justice Attorney General's Honors Program, Jeff began his career working for the Department of Justice Tax Division and then the Criminal Division, Fraud Section in Washington, D.C. He then served as an Assistant United States Attorney for the Southern District of Florida, where he received national recognition for handling complex, high pro le matters including the ground-breaking and historic prosecution of Switzerland's largest bank, UBS AG, for aiding American citizens to commit tax fraud. For his efforts on the UBS investigation, Jeff was awarded the Attorney General's John Marshall Award for Outstanding Legal Achievement and the Internal Revenue Service Commissioner's Award, the highest recognition a prosecutor can receive.

Raised in South Florida, Jeff graduated with honors from the University of Florida and also graduated from law school at the University of Florida where he was a member of Order of the Coif. Jeff currently serves as an adjunct professor at Florida Atlantic University, where he teaches Criminal Procedure and Tax Fraud in their graduate accounting executive program. Jeff also is a frequent lecturer, panelist, and contributor at national conferences on topics including offshore tax evasion, tax fraud, Ponzi schemes and trial practice.

Alfredo Tamayo

Shareholder
Packman, 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 taxation of international transactions involving foreign investors with U.S. businesses and investments and U.S. investors with foreign businesses and foreign investments. Alfredo received his B.S. from Villanova University, his J.D. from the Shepard Broad Law Center at Nova Southeastern University, and his LL.M in estate planning from the Villanova University School of Law. Prior to being admitted to the Florida Bar, Alfredo was a Florida certified public accountant (CPA) with 10 years of experience in public accounting primarily dealing with international tax planning and compliance issues.

Leslie Share

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 and foreign wealth preservation techniques, U.S. tax treaties, Internal Revenue Service examinations and voluntary compliance programs and preferred structures for inbound and outbound business and investment planning. Mr. Share has written for publications such as Checkpoint Catalyst, Florida Bar Journal, Asset Protection Journal, Estate Planning, Entertainment Law & Finance, the University of Florida Law Review, and an American Bar Association book entitled Foreign Investment in U.S. Real Estate—A Comprehensive Guide, along with several times being recognized as an FICPA Outstanding Discussion Leader. He has served as an Adjunct Professor and Guest Lecturer at the University of Miami Law School Graduate Program in Taxation. Les is AV rated by Martindale-Hubbell, and listed in Best Lawyers in America and Florida Super Lawyers in the field of tax law. Mr. Share received his B.A. from Northwestern University, his J.D., with honors, from the University of Florida, and his Master of Laws in Taxation from New York University.

Michael 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 founded the "Transactional Equal Justice Program" with Legal Services of Greater Miami, which offers free legal advice to non-profits and low-to-moderate income small business owners, helping them to launch a business. He graduated form the University of Central Florida, BSBA, Finance and Accounting, (2009), cum laude from the University of Florida Levin College of Law (2012), and received his LL.M. in Taxation from New York University (2013).

Alexei Cowett

Alexei J. Cowett is a leading mergers and acquisitions (M&A) and corporate finance dealmaker, with a focus on emerging growth companies in the consumer and tech sectors and production companies, content creators, and high-profile talent in the media, entertainment and sports industries. He also advises recognized brands in other industries, including the food and beverage and health and wellness sectors.

Alexei's representations include complex corporate transactions, such as domestic and cross-border M&A, joint ventures and partnerships, and venture and private equity financings. In the media, entertainment and sports space, he advises high-profile talent in endorsement and equity deals tailored to their unique priorities. Alexei also represents clients in general corporate and securities matters and advises on corporate governance issues. For several clients, he serves as outside general counsel and a strategic advisor.

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 property matters, Subpart F and foreign investment in US real property. Steven also advises clients on pre-immigration planning and cross-border wealth succession. Steven has also worked on the taxation of partnerships and corporations, and international corporate reorganizations.

Steven is an adjunct professor of International Inbound Taxation at the University of Miami Graduate Tax Program. He is the co-chair of the annual Florida Bar/FICPA International Tax Conference. Steven has written numerous articles and presented on topics related to tax. He was a primary drafter of the amicus curiae brief submitted to the US Supreme Court on behalf of the Florida Bar Tax Section in Knight v. Commissioner in 2008.

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 issues related to offshore corporations, family businesses, trusts, and retirement plans. As a former Attorney with the IRS Chief Counsel, Mishkin is well-positioned to guide clients on a range of reporting and disclosure issues. In addition, he speaks regularly at professional events sponsored by attorney and CPA groups in the US and abroad.

Before joining The Wolf Group, Mishkin was a Partner of the International Tax Division at the Krueger CPA Group. He split his time between the main office in Austin, Texas and the sister office in Zurich, Switzerland.

Outside of work, Mishkin's favorite activity is to spend time with his wife and two children. He also enjoys all things related to history, specifically Greek Mythology and the Argead Dynasty (Alexander the Great), Old Testament Bible, the rise and fall of the Roman Republic, the British Empire, and the Republic of the United States. He is also a big movie buff and fan of 80s and 90s pop culture.