International Tax Conference (ITC)

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Thursday, January 10, 2019
Registration & Continental Breakfast
7:30am-8:45am

Introductions & Opening Remarks
8:45am-9:00am



Thursday Morning General Sessions

Current Developments In International Taxation - Outbound Update (Credits: 1.0 TB)
9:00am-9:50am

Larry R. Kemm, Esq
Of Counsel / Carlton Fields Jorden Burt, P.A.
Tampa, FL
This session will review significant statutory, regulatory, administrative, and judicial developments in U.S. outbound international taxation that occurred during 2018.


Income Tax Planning for a Foreign Inheritance After TCJA: Working with the New Regime (Credits: 1.0 TB)
9:50am-10:40am

Seth J. Entin, Esq
Shareholder / Greenberg Traurig, PA
Miami, FL
Now that a year has passed since the enactment of massive international tax reform, this presentation will analyze the new rules, pitfalls, and planning strategies that apply to a U.S. person inheriting foreign companies from a nonresidential alien. This presentation will include, among other things, the effect of the repeal of the "30 day" CFC grace period and the new CFC constructive ownership rules. This presentation will also discuss how these new rules intersect with the I.S. estate tax planning that is necessary for a nonresident alien owning United States situs assets.


GILTI vs. FDII: The Epic Showdown (Credits: 1.0 TB)
10:40am-11:30am

Steven Hadjilogiou
Partner / McDermott, Will & Emery LLP
Miami, FL
The Tax Cuts and Jobs Act introduced two corollary provisions into the tax code. One provision (FDII) was designed to provide a benefit to corporations that create jobs and retain assets, especially intellectual property, in the United States. The other provision (GILTI) was designed to punitively tax American owned foreign corporations that own intellectual property that generates low-taxed foreign income. The speakers will review the similarities and differences between these provisions and discuss the benefits and burdens of both provisions. Finally, the presentation will look at structuring options that may be considered by taxpayers faced with the punitive GILTI regime and taxpayers seeking to obtain the benefits of the FDII regime.


Lunch - Luncheon Presentation

Lunch Presentations: IRS and Department of Justice Report (Credits: 1.0 TB)
12:00pm-1:00pm

Charles P. Rettig
Commissioner / Internal Revenue Service
Washington, DC
AND
Richard E. Zuckerman
Deputy Assistant Attorney General / The U.S. Deparmtnet of Justice
Washington, DC


Thursday Afternoon General Sessions

Risk Management & Immigration Strategies for the UHNW Families (Credits: 1.0 TB)
1:20pm-2:10pm

Reaz H. Jafri
CEO / Withers Berman LLP
New York, NY
We have unprecedented prosperity on a global level and at the same time tremendous political, social, financial and personal risk. In the past, wealthy families would look at off shore structures to protect themselves from financial risk but now that CRS and information sharing have made that more difficult, they are physically moving themselves and their assets/structures to the various corners of the world. I will discuss where, why and how are they going.


Business and Passive Investment Holding Structures for Foreign Investors After the Tax Cuts and Jobs Act - Opportunities, Traps and Tribulations (Credits: 1.0 TB)
2:10pm-3:00pm

Alfredo R. Tamayo, CPA,Esq.,LLM (TAX)
Shareholder / Packman, Neuwahl & Rosenberg, PA
Miami, FL
AND
Leslie A. Share, Esq
Shareholder / Packman, Neuwahl & Rosenberg, PA
Miami, FL
This presentation will review the effects of the 2017 Tax Cuts and Jobs Act on the traditional business and passive investment structures used by foreign individuals and entities in the United States. We will discuss the effect of the changes in the applicable U.S. tax rates, the new Section 199A Qualified Business Income Deduction rules for effectively-connected income (other than as relevant to U.S. real estate), using Electing Small Business Trusts (ESBTs), and various other related practical and legal considerations, including where the associated U.S. tax compliance requirements are not timely satisfied. We will also review how U.S. income tax treaties may provide significant advantages where they apply to a particular inbound planning situation.


The Intersection of International and SALT (Credits: 1.0 TB)
3:20pm-4:10pm

Alysse McLoughlin
Partner / McDermott, Will & Emery LLP
New York, NY
AND
Kathleen Quinn
Associate / McDermott, Will & Emery LLP
New York, NY
This presentation will focus on the state tax treatment of the international provisions of the Tax Cuts and Jobs Act, the federal tax reform bill passed in December 2017. We will also discuss the Supreme Court’s decision in South Dakota v. Wayfair and the impact of that decision on non-US persons and businesses.


Choice of Entity Post TCJA for Doing Business Outside the United Staes (Credits: 1.0 TB)
4:10pm-5:00pm

James H. Barrett
Partner / Baker McKenzie, LLP
Miami, FL
AND
Abrahm Smith
Baker McKenzie, LLP
Miami, FL
We will discuss the entity options for doing business outside of the United States, including pass-through entities, C Corporations doing business through a branch, and C Corporations doing business through CFCs. Our discussion will address GILTI, FDII, foreign tax credits, the new hybrid rules for entities and debt and other major changes introduced by TCJA. We will discuss IP migrations, export of goods and services, locating factories and other depreciable property outside of the United States, and other relevant issues. If an offshore business is currently being conducted by individuals using CFCs, we will discuss the benefits of imposing a US corporation into the holding structure. After our presentation, you should have a better understanding of the advantages and disadvantages of when to use partnerships and when to use corporate structures for closely held businesses operating offshore.


Friday, January 11, 2019
Continental Breakfast
7:30am-8:30am
Friday Morning General Sessions

Current Developments in International Taxation: Inbound Tax Planning Update Including Recent Global Tax Compliance and Controversy Developments (Credits: 1.0 TB)
8:30am-9:20am

William M. Sharp Sr., Esq
Partner / Holland & Knight, LLP
Tampa, FL
The presentation will highlight and provide practitioner comments related to two general areas: first “inbound” U.S. statutory, regulatory, administrative and judicial developments; and second, a review of the past year’s most important U.S. Tax Court & Federal Court decisions addressing inbound and compliance issues, including a review of recent IRS/DOJ initiatives and selected foreign country tax compliance initiatives.


Inbound Structuring For U.S. Real Estate in a Post-Tax Reform World (Credits: 1.0 TB)
9:20am-10:10am

Robert H. Moore
Partner / Baker McKenzie, LLP
Miami, FL
AND
Michael D. Melrose
Baker McKenzie, LLP
Miami, FL
Given the changes as a result of the TCJA, in particular the lowering of the corporate rate and new pass through deduction, this session will explore what are the most efficient ways to structure inbound investment in US real estate. This session also will address the impact the TCJA had on debt financing structures, in particular the far reaching impact of the repeal of section 958(b)(4), revised section 163(j), and new section 267A.


Better Late than Never- The Use of Section 962 in Cross-Border Tax Planning (Credits: 1.0 TB)
10:30am-11:20am

Jeffrey L. Rubinger, Esq
Partner / Bilzin Sumberg Baena Price & Axelrod
Miami, FL
AND
Summer Ayers LePree, Esq
Partner / Bilzin Sumberg Baena Price & Axelrod, LLP
Miami, FL
This panel will discuss the increasing relevance of Section 962 elections to U.S. individual shareholders of CFCs after 2017 tax reform with respect to their Subpart F, Section 956, and GILTI inclusions. A comparison of the tax treatment of taxpayers who make such elections and those taxpayers owning shares of CFCs indirectly through actual U.S. C corporations also will be included.  In addition, the presentation will cover recent IRS guidance and case law relating to Section 962 and the unanswered questions that remain.


Panel - Miscellaneous Civil & Criminal Procedural Issues (Credits: 1.0 TB)
11:20am-12:10pm

Robert E. Panoff, Esq
Tax Litigator / Robert E. Panoff, PA
Miami, FL
AND
Mark F. Daly
Senior Litigation Counsel / Department of Justice
Washington, DC
AND
Eric Hylton
Deputy Chief, Criminal Investigation / Internal Revenue Service
Washington, DC
AND
Daniel N. Price
Attorney / IRS
Austin, TX
This panel continues its tradition of providing up-to-the-minute information regarding civil and criminal international tax procedural issues affecting everyday tax professionals and their clients. Greater emphasis will be placed on taxpayers within the jurisdiction of the Small Business/Self Employed Division of the IRS, but we will also discuss issues affecting taxpayers within the Large Business and International Division.


Lunch - Luncheon Presentation

Lunch Presentation - Working Inside and Outside Government (Credits: 1.0 TB)
12:20pm-1:10pm

Danielle E. Rolfes
Co-Lead, International Tax Group / KPMG LLP
Washington, DC


Friday Afternoon General Sessions

A Washington Update on the TCJA’s International Tax Provisions (Credits: 1.0 TB)
1:30pm-2:20pm

Alan W. Granwell, Esq
Of Counsel / Holland & Knight, LLP
Washington, DC
AND
Danielle E. Rolfes
Co-Lead, International Tax Group / KPMG LLP
Washington, DC
AND
Jose Murillo
Partner / Ernst & Young LLP
Miami, FL
This panel, composed of former senior members of the Office of International Tax Counsel of the U.S. Treasury Department, will provide an update of the TCJA’s International Tax Provisions, including a summary overview of the current international tax system and where are we going? The panel will review regulatory developments, including what is covered in the regulatory guidance, what is not covered, unanticipated provisions and what we can expect going forward. There will be an opportunity for questions.


Estate Planning for Brazilians and Mexicans with U.S. Heirs or U.S. Assets (Credits: 1.0 TB)
2:35pm-3:25pm

Hal J. Webb, Esq
Partner / Bilzin Sumberg Baena Price & Axelrod LLP
Miami, FL
AND
Jennifer J. Wioncek, Esq., LL.M.
Partner / Bilzin Sumberg Baena Price & Axelrod
Miami, FL
This presentation will be a panel discussion covering current trends related to estate planning and transfer tax planning for Brazilians and Mexicans with U.S. Heirs or U.S. Assets.


The Long Arm of Uncle Sam: A Practical Guide to Navigating the Dangers of Advising Foreign Clients (Credits: 1.0 TB)
3:25pm-4:15pm

Jeffrey A. Neiman, Esq.
Attorney / Marcus Neiman & Rashbaum LLP
Fort Lauderdale, FL
AND
Jared E. Dwyer
Shareholder / Greenberg Traurig, PA
Miami, FL
It will be surprising to many to learn that not all conversations between an attorney and a client always remain privileged and that the US government has the ability to bring charges when a foreign country’s taxes are evaded. He will discuss practical concerns every advisor should consider when providing advice to a foreign/dual citizen.


Tips to Take Home (Credits: 1.0 TB)
4:15pm-5:05pm

Renea M. Glendinning, CPA
Shareholder / Kerkering, Barberio & Company
Sarasota, FL
AND
David A. Cumberland, CGMA,CPA
Tax Manager / Kerkering, Barberio & Company
Sarasota, FL
This presentation will discuss foreign owners and their reporting obligations for disregarded entities and the most recent guidance regarding withholding requirements on the sale of a partnership interest. It will also include constructive suggestions to help the practitioner in preparing various applications, including reduced FIRPTA withholding, ITINs and nonresident estate tax returns.


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