International Tax Conference (ITC)

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Thursday, January 16, 2020
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
Partner / Holland & Knight, LLP
Tampa, FL
This session will review significant statutory, regulatory, administrative, and judicial developments in U.S. outbound international taxation that occurred during 2019.


Tax Planning with S Corporations and Hybrids After the TCJA (Credits: 1.0 TB)
9:50am-10:40am

Seth J. Entin, Esq
Shareholder / Holland & Knight, LLP
Miami, FL
This presentation will explore international tax planning opportunities and traps involving the use of S corporations, with particular emphasis on changes resulting from the Tax Cuts and Jobs Act (the “TCJA”).  This presentation will also explore the effect of the new "anti-hybrid" provisions of the TCJA on international tax planning structures, particularly structures affecting high net worth individuals and closely held international businesses.


Recent Developments in the Taxation of the Digital Economy (Credits: 1.0 TB)
10:40am-11:30am

Michael J. Bruno
Associate / McDermott, Will & Emery LLP
Miami, FL
AND
Brian H. Jenn
Partner/Attorney / McDermott Will & Emery
Chicago, IL
This panel will provide an overview of U.S. taxation of cross-border transactions involving software, digital goods and services, including issues that arise under recent proposed regulations on cloud computing transactions. This panel will review recent developments concerning tax and digitalization at the OECD and in select foreign countries.


Lunch
11:30am-1:00pm

Lunch Presentation: Offshore update & Comparison with the U.S: Beneficial Ownership Information and Registers, Economic Substance Legislation, & CRS (Credits: 1.0 TB)
12:10pm-1:00pm

Peter A. Cotorceanu, Esq
CEO and Founder
According to the Book of Proverbs, "Human eyes are never satisfied". The same is true of the prying eyes of government and the public when it comes to individuals' and entities' financial assets and affairs. As a result, legally mandated transparency is ever increasing, both here in the U.S. and overseas. This presentation will focus on recent developments in this area, will contrast the U.S.'s approach with the approaches taken by other countries, and will also touch on the wave of "economic substance" legislation engulfing offshore countries.


Networking Break
1:00pm-1:20pm
Thursday Afternoon General Sessions

The Impact of Tax Reform on the Cross-Border Sale of a Business (Credits: 1.0 TB)
1:20pm-2:10pm

Summer Ayers LePree, Esq
Partner / Bilzin Sumberg Baena Price & Axelrod, LLP
Miami, FL
AND
Arianne Plasencia
Associate / DLA Piper
Miami, FL
This presentation will examine the TCJA’s effect on the sale of a business from both an inbound and outbound perspective.  The inbound portion of the panel will focus in particular on the impact of new rules under Code Sections 864(c)(8) and 1446(f), while on the outbound side, relevant changes to the CFC rules, including Sections 245A, 964(e)(4), and 1248, will be covered.


Panel Discussion: Compliance Issues for the International Tax Practicioner (Credits: 1.0 TB)
2:10pm-3:00pm

Renea M. Glendinning, CPA
Shareholder / Kerkering, Barberio & Company
Sarasota, FL
AND
Alfredo R. Tamayo, CPA,Esq.,LLM (TAX)
Shareholder / Packman, Neuwahl & Rosenberg, PA
Miami, FL
AND
ReDel Lloyd
US Department of Treasury
Washington, DC
AND
Lauren E. Busterna
Attorney-Advisor, Estate & Gift Tax Policy / Internal Revenue Service
Cincinnati, OH
This panel will provide information regarding certain tax compliance issues affecting international tax practitioners who prepare U.S. tax returns and information forms for taxpayers involved in cross-border activities.  The discussion will address certain “best practices” when preparing such returns and forms.


Networking Break
3:00pm-3:20pm
Thursday Afternoon General Sessions

To Be Taxed Under GILTI,Subpart F,FDII or Flow-Through Structure,That Is The Question:US Tax Considerations For Outbound Business Invest. & Activ. (Credits: 1.0 TB)
3:20pm-4:10pm

Erez I. Tucner
Shareholder/Attorney / Greenberg Traurig, LLP
New York, NY
AND
Gennette E. Faust
Shareholder/Attorney / Greenberg Traurig, PA
Miami, FL
This presentation will provide an overview of the four US international tax regimes that are potentially applicable and available post-US tax reform to US taxpayers with respect to their non-US business investments and activities. The panelists will compare and contrast the benefits, disadvantages and burdens of the four tax regimes and discuss tax planning opportunities and considerations for structuring non-US business investments and activities for US taxpayers with respect to different types of businesses and jurisdictions.


Common Law Doctrines and Nominee Arrangements - Identifying and Reporting the "Real" Taxpayers and Transactions in International Tax Matters (Credits: 1.0 TB)
4:10pm-5:00pm

Leslie A. Share, Esq
Shareholder / Packman, Neuwahl & Rosenberg, PA
Miami, FL
This presentation will review a number of the most important “common law doctrines” in US tax law—"economic substance”, “sham” and “step” transactions and their application in the international tax context. It will also analyze the requirements for establishing, respecting and reporting where the titleholder to an asset acts as a nominee for its principal in the offshore planning and compliance areas. In addition, the potential effects of the TCJA upon each of these issues will be considered.


Friday, January 17, 2020
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
This presentation will highlight and provide practitioner comments related to two general areas: first, “inbound” U.S. statutory, regulatory, administrative and judicial developments, including selected foreign law 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 recent FBAR litigation outcomes (and the current “pipeline” of pending cases).


Inbound Structuring for U.S. Real Estate - Latest and Greatest Structures and More (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
This panel will explore recent changes under TCJA and the impact of those changes on structuring investments in U.S. real estate.


Networking Break
10:10am-10:30am
Friday Morning General Sessions

The Modern Day Closely Held Foreign Corporation - Post-Tax Reform (Credits: 1.0 TB)
10:30am-11:20am

Steven Hadjilogiou
Partner / McDermott, Will & Emery LLP
Miami, FL
AND
Fred F. Murray, CPA,Esq.,JD

Closely held foreign corporations face significant challenges in both classification and tax liability to U.S. shareholders. The panelists will discuss the latest developments impacting the classification of foreign corporations as Controlled Foreign Corporations (CFCs), including issues that arise because of the repeal of former Code Section 958(b)(4). Moreover, the panelists will discuss planning ideas for GILTI and Subpart F generated by closely held CFCs. Topics include the use of the 962 election, the GILTI high tax exception, corporate contributions and the use of S Corporations.


An Interview of and Discussion with Eric Hylton, Commissioner of the SBSE Operating Division of the Internal Revenue Service (Credits: 1.0 TB)
11:20am-12:10pm

Robert E. Panoff, Esq
Tax Litigator / Robert E. Panoff, PA
Miami, FL
AND
Eric Hylton
Commissioner, SBSE Division / Internal Revenue Service
Washington, DC

Robert Panoff interviews and discusses with Commissioner Eric Hylton to gain a better understanding of SBSE's current views towards various tax procedural issues affecting international tax practitioners.


Lunch
12:10pm-1:20pm

Lunch Presentation: IRS Commissioner Charles Rettig (Credits: 1.0 TB)
12:30pm-1:20pm

Charles P. Rettig
Commissioner / Internal Revenue Service
Washington, DC

This session will provide a comprehensive overview of the areas of focus and concentration by the international division of the Internal Revenue Service for the coming years.  It will cover the upcoming initiatives impacting the international tax professionals and discuss ways in which the IRS and the international tax professionals can work together more cohesively to deliver services demanded by taxpayers working across borders.  It will also touch on offshore tax compliance initiatives and the impact this is having on increasing taxpayer compliance with current US tax laws.


Networking Break
1:20pm-1:30pm
Friday Afternoon General Sessions

Compliance Options in a Post OVDP World (Credits: 1.0 TB)
1:30pm-2:20pm

Lawrence J. Chastang, CPA, TEP
Chairman-Global Advisory Services / CliftonLarsonAllen, LLP
Orlando, FL
AND
Sherwin P. Simmons II
Principal / AsgardWorldwide
Tampa, FL
AND
Daniel N. Price
Attorney / IRS
Austin, TX
This panel will review and discuss the real world challenges and options available to international tax practitioners for the millions of US citizens and permanent residents who still have not come in from the cold….. Are they willful, reckless, grossly negligent, non-willful or somewhere else along the continuum of intent?  Are they all now criminals?


Networking Break
2:20pm-2:35pm
Friday Afternoon General Sessions

Current Trends & Succession Planning for US Beneficiaries of Domestic & Foreign Trusts w/a Focus on Underlying Securities & Private Equity Investments (Credits: 1.0 TB)
2:35pm-3:25pm

Hal J. Webb, Esq
Partner / Bilzin Sumberg Baena Price & Axelrod LLP
Miami, FL
AND
Stewart L. Kasner, Esq.
Partner / Holland & Knight, LLP
Miami, FL
A discussion of (1) succession planning for U.S. beneficiaries of foreign trusts holding underlying domestic and foreign securities and private equity investments; (2) recently proposed PFIC regulations; and (3) comparative uses of domestic trusts and (newer) foundations in connection with cross border family planning.


Tips to Take Home (Credits: 1.0 TB)
3:25pm-4:15pm

Laura Plotner, CPA,MST
CBIZ MHM, LLC
Clearwater, FL
AND
David A. Cumberland, CGMA,CPA
Tax Manager / Kerkering, Barberio & Company
Sarasota, FL
This presentation will provide practical tips for the international tax practitioner regarding various international tax issues from a compliance perspective. The discussion will include how to avoid making common errors and preparation considerations as well as suggested best practices. The topics will range from applications for ITINs (Form W-7), withholding under FIRPTA (Forms 8288-B, 8288 and 8288-A), and nonresident income tax reporting (Form 1040NR), disclosure forms (Form 5471, 5472, 8865, FINCEN 114), GILTI tax, and compliance considerations when handling expatriation compliance work.


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