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THE FLORIDA BAR TAX SECTION & CLE COMMITTEE, AND FICPA PRESENT THE
35TH ANNUAL
INTERNATIONAL TAX CONFERENCE
Jan. 5 – 6, 2017
JW Marriott, Miami 1109 Brickell Avenue, Miami, Florida 33131
FEATURING • The ITC Boot Camp
Jan. 4, 2017
2
Overview of Event Schedule
Wednesday – Jan. 4
International Tax Boot Camp (7 CLE) Separate registration and fee required.
Thursday – Jan. 5 9:00 a.m. – 9:50 a.m. Current Developments in International Taxation – Outbound Update
9:50 a.m. – 10:40 a.m. Characterizing Income: Why It is So Important for the International Tax Practitioner
11:00 a.m. – 11:50 a.m. Is the United States the Dominant Financial Haven of the World?
11:50 a.m. – 1:20 p.m. Lunch Presentation: The U.S. As An Asset Hiding Haven – Selected Ethics and
Related Issues
1:20 p.m. – 2:10 p.m. An Overview of the Permitted Activities Under the U.S. Embargo and Taxation of U.S.
Investment into Cuba
2:10 p.m. – 3:00 p.m. Tax Planning with Cross-Border Loans – Successfully Navigating Around the
Proposed Section 385 Regulations
3:20 p.m. – 4:10 p.m. Exploring International Estate Tax and Income Tax Planning Strategies Involving
Issues That are Overlooked
4:10 p.m.– 5:00 p.m. Base Erosion and Profit Shifting: Key Impacts on Transfer Pricing
Friday – Jan. 6 8:30 a.m. – 9:20 a.m.
9:20 a.m. – 10:10 a.m.
10:30 a.m. – 11:20 a.m.
11:20 a.m. – 12:10 p.m.
12:10 p.m. – 1:30 p.m.
1:30 p.m. – 2:20 p.m.
2:35 p.m. – 3:25 p.m.
3:25 p.m. – 4:15 p.m.
Current Developments in International Taxation: “Inbound” Update to Include Global
Compliance and Controversy Developments
International Partnerships: To Boldly Go Where Few Have Gone Before
Hot Topics in CRS
Panel on Miscellaneous Civil and Criminal Procedural Issues
Lunch Presentation: Update from Washington, D.C.
More Than You Need to Know about Florida Corporate Income Tax and Sales Tax
Life Insurance and Annuities: Effective Tools for Pre-Immigration Tax Mitigation
Tips to Take Home: What’s New with International Tax Forms
3
Wednesday, Jan. 4, 2017
ITC Boot Camp
The International Tax Boot Camp will provide young CPAs
and attorneys a beginner-level summary of international
inbound and outbound taxation.
This event requires a separate registration fee.
8:00 a.m. – 9:00 a.m.
Registration and Continental Breakfast (Included)
9:05 a.m. – 12:25 p.m. (Break: 10:30 a.m. - 10:50 a.m.)International Inbound Taxation
Scott A. Bowman
Partner | Proskauer Rose LLP | Boca RatonLeslie A. Share, Esq.Attorney | Packman, Neuwahl & Rosenberg | MiamiAlthough there has been an increase of a
traditional outbound tax practice in Florida during the last
decade or so, inbound direct investment remains the
dominant international tax practice area in Florida and
accord-ingly will receive the most emphasis in this
presentation. This presentation will briefly summarize
the basic U.S. federal income, estate and gift tax issues
that affect U.S. inbound international tax planning.
12:25 p.m. – 1:35 p.m.
Lunch (Included)
1:40 p.m. – 4:00 p.m. (Break: 3:40 p.m. - 4:00 p.m.) International Outbound Taxation
William B. Sherman
Partner | Holland & Knight, LLP | Ft Lauderdale
Kevin E. Packman
Partner | Holland & Knight, LLP | Miami
This presentation brings a different focus on outbound
investment. Instead of presenting the U.S. outbound rules
in the traditional context of the large U.S. based
multinational, this presentation will present the outbound
topic in a context more often seen in Florida, that of
members of a U.S. family encountering the outbound rules
in a closely held business. This presentation will briefly
summarize the basic U.S. federal income, estate and gift
tax issues that affect U.S. federal income tax issues that
affect outbound international tax planning.
4:00 p.m. – 4:50 p.m.
International Tax Forms
Renea M. Glendinning, CLU, CPA
Shareholder | Kerkering, Barberio & Company, CPA |
Sarasota
Amy Fondo
Principal | CliftonLarsonAllen | Orlando
David A. Cumberland, CGMA, CPA
Tax Manager | Kerkering, Barberio & Company, CPA |
Sarasota
These presentations will provide practical tips for the
international tax practitioner regarding various inbound and
outbound disclosure forms, including ways to avoid
common errors in their completion.
7:30 a.m. – 8:45 a.m.
Registration and Continental Breakfast (Included)
8:45 a.m. – 9:00 a.m.
Introductions and Opening Remarks
Lawrence J. Chastang, CPA
Managing Partner | Clifton Larson Allen | Orlando
Steven Hadjilogiou
Partner | Baker & McKenzie, LLP | Miami
9:00 a.m. – 9:50 a.m.
Current Developments in International Taxation –
Outbound Update
Larry R. Kemm, Esq.
Partner | Harrison Kemm, P.A. | Tampa
This session will review significant statutory,
regulatory, administrative and judicial developments in U.S.
outbound international taxation that occurred during 2016.
Thursday, Jan. 5, 2017
5:00 p.m. - 6:00 p.m.Networking Reception (Included)
4
Thursday, Jan. 5, 2017 (cont.)
9:50 a.m. – 11:00 a.m. (Break: 10:40 a.m. - 11:00 a.m.)Characterizing Income: Why It is So Important for the
International Tax Practitioner
Seth J. Entin, Esq.
Shareholder | Greenberg Traurig, PA | Miami
It is very dangerous for an international tax practitioner to
operate in a vacuum and lose sight of the "general principles"
of U.S. federal income taxation. A case in point is the
characterization of income. This presentation will highlight key
characterization of income issues and show how many
important consequences in both the inbound and outbound
contexts turn on how the income in question is characterized.
This presentation will also provide multiple examples of how a
change in the character of income can result in adverse or
favorable consequences.
11:00 a.m. – 11:50 a.m.
Is the United States the Dominant Financial Haven of
the World?
Denis A. Kleinfeld, CPA, JD
Of Counsel | Fuerst Ittleman David & Joseph, PL | Miami
The world is full of competing tax havens; asset protection
jurisdictions; banking and investment states; and wealth
management destinations. Every country wants and needs to
attract and keep wealth. Capital is the lifeblood of every
economy. Learn why and how the United States positions itself
as the dominant country in the global economic contest for
capital and financial success.
11:50 a.m. – 1:20 p.m. (Included)Lunch Presentation: The U.S. as an Asset
Hiding Haven – Selected Ethics and Related Issues
Michael Lampert, Esq.
Attorney | Law Offices of Michael A. Lampert, PA | West
Palm Beach
Shawn P. Wolf, Esq.
Attorney/Shareholder | Packman, Neuwahl &
Rosenberg, PA | Miami
Much has been written about asset protection and privacy.
There is even a BNA Tax Management Portfolio on the topic.
There are also many articles and seminars on the ethics and
related issues in undertaking asset protection planning. In
addition, there are articles that address helping clients hide
assets – particularly in the divorce arena. But what about the offshore client that wants to “hide” money in the U.S. or to engage the services of U.S. attorneys to “hide” funds domestically or internationally. This presentation willtouch on some of the myriad of ethics and related issues.
1:20 p.m. – 2:10 p.m.
An Overview of the Permitted Activities Under the
U.S. Embargo and Taxation of U.S.
Investment into Cuba
Pedro A. Freyre
Partner – Chair, International Practice | Akerman LLP
| Miami
Michael J. Bruno
Associate | Baker & McKenzie, LLP | Miami
Join us as we cover the U.S. tax options for U.S.
companies that are permitted to do business in Cuba. We’ll
discuss the permitted activities under the U.S. Embargo
and how best to address U.S. tax challenges for an
operation in Cuba. Finally, we will outline the Cuban taxes
that can generally apply to a U.S. company and how best
to mitigate them.
2:10 p.m. – 3:20 p.m. (Break: 3:00 p.m. - 3:20 p.m.) Tax Planning with Cross-Border Loans –
Successfully Navigating Around the Proposed
Section 385 Regulations
James H. Barrett
Partner | Baker & McKenzie, LLP | Miami
Jeffrey L. Rubinger, Esq.
Partner | Bilzin Sumberg Baena Price & Axelrod, LLP |
Miami
We will cover the inbound and outbound tax consequences
of the Proposed Section 385 debt/equity rules. Last April,
the Treasury proposed debt/equity rules that broadly impact
how debt and equity are classified for international
transactions. These controversial proposed regulations
impact inbound loans (including portfolio debt); outbound
loans that are used to facilitate repatriation of profits; treaty
benefitted debt; and certain foreign-to-foreign
arrangements. The proposed regulations have a retroactive
effective date and can readily apply to existing loans.
Taxpayers are preparing now for these regulations. Our
panel will review the proposed (or if issued, final) regula-
tions as they apply to inbound and outbound investments,
and what taxpayers can do to better prepare for these
proposed regulations.
5
Thursday, Jan. 5, 2017
(cont.) 3:20 p.m. – 4:10 p.m.
Exploring International Estate Tax and Income
Tax Planning Strategies Involving Issues That are
Overlooked
Hal J. Webb, Esq.
Bilzin Sumberg Baena Price & Axelrod LLP | Miami
Jennifer J. Wioncek, Esq., LL.M.
Bilzin Sumberg Baena Price & Axelrod LLP | Miami
We will cover issues arising with international estate
planning matters, such as planning to obtain a step-up in
basis in assets held by revocable and irrevocable trusts;
planning related to check-the-box elections; dealing with
UNI; domestication of trust structures; challenges involved
when working with foreign private foundations; and plan-
ning for clients who own valuable tangible personal proper-
ty located in the U.S.
4:10 p.m. – 5:00 p.m.
Base Erosion and Profit Shifting: Key Impacts on
Transfer Pricing
Barry Freeman, Ph.D.
Principal | Crowe Horwath LLP | New York, N.Y.
Joshua Johnston
Manager | Crowe Horwath LLP | Oak Brook, Ill.
This presentation will provide participants with the key
impacts on the global pricing landscape as a result of the
OECD’s Base Erosion and Profit Shifting project. The
discussion will revolve around recommendations for policy
changes with respect to the valuation of intangibles, the
allocation of risk within a multinational group, transfer
pricing documentation and other topics. The session will
also inform on recent legislative actions, court rulings and
other developments in the world of transfer pricing.
8:30 a.m. – 9:20 a.m.
Current Developments in International Taxation:
“Inbound” Update to Include Global Compliance
and Controversy Developments
William M. Sharp, Esq.
Shareholder | Sharp Partners, PA | Tampa
The presentation will technically highlight and provide
practitioner commentary regarding two areas: first,
“inbound” U.S. statutory, regulatory, administrative and
judicial developments, including selected foreign law
developments; and second, U.S. and global tax compliance
developments, encompassing a review of IRS/DOJ global
compliance initiatives and relevant selected foreign jurisdic-
tion initiatives.
9:20 a.m. – 10:30 a.m. (Break: 10:10 a.m. - 10:30 a.m.)International Partnerships: To Boldly Go Where Few
Have Gone Before
Robert H. Moore
Partner | Baker & McKenzie LLP | Miami
We will examine the many uses of partnerships in the
international context, exploring both inbound and outbound
uses of partnerships. Discussion will include FIRPTA issues,
estate tax issues and foreign tax credit issues.
10:30 a.m. – 11:20 a.m.
Hot Topics in CRS
Peter A. Cotorceanu, Esq.
CEO and Founder | www.gatcandtrusts.com | Zürich,
Switzerland
Like FATCA before it, CRS is a moving target. This
presentation will address the hottest topics in CRS,
especially those affecting the fiduciary industry.
Friday, Jan. 6, 2017
5:00 p.m. – 6:00 p.m.
Networking Reception (Included)
8:00 a.m. – 8:30 a.m.
Continental Breakfast (Included)
6
Friday, Jan. 6, 2017 (cont.)
11:20 a.m. – 12:10 p.m.
Panel on Miscellaneous Civil and Criminal
Procedural Issues
Robert E. Panoff, Esq. (Panel Moderator)
Tax Litigator | Robert E. Panoff, PA | Miami
Select IRS and Law Enforcement Experts
This panel continues its tradition of providing up-to-the-
minute information regarding civil and criminal international
tax procedural issues affecting everyday tax practitioners
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.
12:10 p.m. – 1:30 p.m. (Included) Lunch Presentation: Update from
Washington, D.C.
Douglas Poms
Senior Counsel to the International Tax Counsel |
U.S. Department of Treasury | Washington, D.C.
This presentation will address current developments
related to international tax.
1:30 p.m. – 2:35 p.m. (Break: 2:20 p.m. - 2:35 p.m.) More Than You Need to Know About Florida
Corporate Income Tax and Sales Tax
William D. Townsend, JD
Of Counsel | Dean Mead & Dunbar | Tallahassee Will
discuss state tax traps for the unwary foreign entity; provide
an introduction to Florida corporate income tax issues
faced by foreign entities doing business in the state; and
cover application of Florida sales taxes to business
activities in the state of Florida.
2:35 p.m. – 3:25 p.m.
Life Insurance and Annuities: Effective Tools for
Pre-Immigration Tax Mitigation
Michael H. Ripp, Jr.
Giordani, Swanger, Ripp, & Phillips, LLP | Austin,
Texas
This presentation addresses the various applications of life
insurance and annuity products for mitigating the U.S. tax
consequences of immigrating to the U.S., whether
temporarily or permanently, and will emphasize the use of
private-placement contracts and other cost-efficient
products of particular interest to the high-net-worth (HNW)
immigrant.
3:25 p.m. – 4:15 p.m.
Tips to Take Home: What’s New with International
Tax Forms
David A. Cumberland, CPA, CGMA
Tax Manager | Kerkering, Barberio & Company |
Sarasota
Amy Fondo, CPA
Principal | CliftonLarsonAllen LLP | Orlando
Renea M. Glendinning, CPA
Shareholder | Kerkering, Barberio & Company |
Sarasota
This presentation will provide practical tips for the
international tax practitioner regarding various inbound and
outbound disclosure forms, including ways to avoid com-
mon errors in their completion. We will also discuss recent
procedural changes implemented by the IRS, including an
update on the ITIN renewal process.
7
International Tax Conference Info
Hotel Information Please call the JW Marriott Miami at (800) 228-9290 to
JW Marriott Miami reserve your room. Be sure to mention this conference to
1109 Brickell Avenue receive the special group rate.
Miami, FL 33131 *Room availability is not guaranteed by this date and(305) 329-3500 inventory may fill up before the cutoff date. If any rooms
are left after the cutoff date, they will be added back to Rate: $309 single/double the general hotel inventory and sold at the prevailing hotel
Cut-Off Date: Tues, Dec 13, 2016* rate.
Make Your Reservations Online
The Florida Bar CLE Committee & Tax SectionEvett Simmons, Port Saint Lucie, Chair, CLE Committee
Terry L. Hill, Director, Programs Division, The Florida Bar
William Lane, Jr., Tampa, Chair, Tax Section
Joseph Schimmel, Miami, Chair-Elect, Tax Section
Abrahm Smith, Miami , Director, Education Division
Micah Fogarty, Tampa , Director, Education Division
Tax Section Faculty & Steering Committee
Steven Hadjilogiou, Miami, Program Co-Chair
Lawrence J. Chastang, Orlando, Program Co-Chair
James H. Barrett, Miami
Seth Entin, Miami
Lawrence R. Kemm, Tampa
Kevin E. Packman, Miami
Jeffrey L. Rubinger, Miami
Jonathan H. (Jason) Warner, Spruce Pine, NC
Hal J. Webb, Miami
Shawn P. Wolf, Miami
ITC Boot Camp (2330)
CLE Credit:
General: 7.0 hours
Certification Credit:
International: 7.0 hours
ITC Conference (2331)
CLER Program
(Max. Credit: 17.5 hours)
General: 17.5 hours
Ethics: 2.0 hours
Certification Program
(Max. Credit: 17.5 hours)
Immigration and Nationality Law: 2.0 hours
International Law: 17.5 hours
Tax Law: 17.5 hours
8
Conference Registration 4 Ways to Register:
1. Register online www.floridabar.org/CLE. To register for the webcast, go to http://tinyurl.com/FloridaCLE2331R.
2. Call The Florida Bar Order Entry Department at (850) 561-5831
3. Fax completed registration form with credit card information to (850) 561-913 (secure fax).
4. Mail completed registration form to The Florida Bar, Order Entry Department, 651 East Jefferson Street,Tallahassee, Florida 32399-2300 with a check made payable to The Florida Bar or with credit card information.
One location (190) JW Marriott Hotel, Miami, FL (Jan. 5-6, 2017). On-site registration is by check only.
Name: _____________________________________________________ Florida Bar #: _________________________
Address: ________________________________________________ Phone: ( )________________________
City/State/Zip: _________________________________________________________________________________________
Email*: __________________________________________________ Asst. Email: __________________________
*Email address required to receive electronic course material and will only be used for this order. Course No. 2331R
International Tax Conference (2331R) Price Select One
Early Bird $660
Regular Price (as of 12/6/16) $715
International Tax Conference Webcast Price
Early Bird - both days $725
Regular Price - both days (as of 12/6/16) $780
To register for the webcast, go to: http://tinyurl.com/FloridaCLE2331R
International Tax Boot Camp (2330R) - Jan. 4 Price
Early Bird $250
Regular Price (as of 12/5/16) $305
International Tax Course Book/CD/DVD Price
Hardcopy Course Book $60 plus tax
Audio CD (2331C) $715
DVD Video (2331D) $765
Subtotal $
Total $
METHOD OF PAYMENT (CHECK ONE):
Check enclosed made payable to The Florida Bar
Credit Card (Fax to 850/561-9413.)
MASTERCARD VISA DISCOVER AMEX Exp. Date: ____/____ (MO./YR.)
Signature:______________________________________________________________________________________
Name on Card:_______________________________________________ Billing Zip Code:_____________________
Card No._______________________________________________________________________________________
Please check here if you have a disability that may require special attention or services. To ensure availability of appropriate accommo-dations, attach a general description of your needs. We will contact you for further coordination.
Enclosed is my separate check in the amount of $60 to join the Tax Section. Membership expires June 30, 2017
Private recording of this program is not permitted. Delivery time is 4 to 6 weeks after 1/09/17. TO ORDER AUDIO CD, fill out the order form above, includ-ing a street address for delivery. Please add sales tax. Those eligible for the above mentioned fee waiver may order a complimentary audio CD in lieu of live attendance upon written request and for personal use only. Please include sales tax unless ordering party is tax-exempt or a nonresident of Florida. If tax exempt, include documentation with the order form.
BRING YOUR FIRM & SAVE: 15% Discount (5-7); 20% Discount (8 or more). Call (850) 561-5625 for more details. Terms expire December 16, 2016.
9
35th Annual International Tax Conference