International Tax Conference - FICPA
International Companies & Clients Trust You.Global CPAs Trust Us.With changes and developments happening in international finance every day, there’s onlyone conference in Florida that you can trust to provide the knowledge needed for yourmultinational organization or clients.At the FICPA’s International Tax Conference in Miami from January 5-6, 2017, you willlearn about everything that’s new and coming soon while earning up to 16 hours of CPE.Join us and our handpicked instructors at the five-star JW Marriott Miami – or attend onlinewith the Simulcast.New to the field? Join us for the return of our popular International Tax Boot Camp(6 CPE) on January 4, 2017, at the same location (separate registration required). Thisintroductory program covers the basics of international inbound and outbound taxation andprepares you for the topics to follow in our full conference.CPE CreditThis conference qualifies for 16 Technical Business (TB) hours of CPE credit and is subject to change.CPE credit is subject to approval by the Florida Department of Business and Professional Regulation.Type of credit is dependent upon breakout selection.#ficpaITC
Conference at-a-glanceWednesdayJan. 4International Tax Boot CampSeparate registration and fee required. See page 5 for more details.ThursdayJan. 59 – 9:50 a.m.Current Developments in International Taxation – Outbound Update9:50 – 10:40 a.m.Characterizing Income: Why It is So Important for the International TaxPractitioner11 – 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 – SelectedEthics and Related Issues1:20 – 2:10 p.m.An Overview of the Permitted Activities Under the U.S. Embargo andTaxation of U.S. Investment into Cuba2:10 – 3 p.m.Tax Planning with Cross-Border Loans – Successfully Navigating Aroundthe Proposed Section 385 Regulations3:20 – 4:10 p.m.Exploring International Estate Tax and Income Tax Planning StrategiesInvolving Issues That are Overlooked4:10 – 5 p.m.Base Erosion and Profit Shifting: Key Impacts on Transfer PricingFridayJan. 68:30 – 9:20 a.m.Current Developments in International Taxation: “Inbound” Update toInclude Global Compliance and Controversy Developments9:20 – 10:10 a.m.International Partnerships: To Boldly Go Where Few Have Gone Before10:30 – 11:20 a.m.Hot Topics in CRS11:20 a.m. – 12:10 p.m.Panel on Miscellaneous Civil and Criminal Procedural Issues12:10 – 1:30 p.m.Lunch Presentation: Update from Washington, D.C.1:30 – 2:20 p.m.More Than You Need to Know about Florida Corporate Income Taxand Sales Tax2:35 – 3:25 p.m.Life Insurance and Annuities: Effective Tools for Pre-ImmigrationTax Mitigation3:25 – 4:15 p.m.Tips to Take Home: What’s New with International Tax Formswww.ficpa.org3
2016-2017 International Tax Conference Planning CommitteeLawrence Chastang, ChairRenea M. Glendinning, Vice ChairBayardo N. Aguilar JrNestor L. GuillenJoseph W. RendonMirtha G. AguirreLewis B. KevelsonMichael RosenbergJames R. AttkissonDenis A. KleinfeldJames W. SpencerKevin CarmichaelAndrew J. LeonardAlfredo R. TamayoDavid A. CumberlandSebastian Nye-SchmitzBrian S. WalgamottRenea M. GlendinningManuel E. PraviaRodney S. WhiteThank you to Our Sponsors4International Tax Conference
Wednesday Jan. 4International Tax Boot Camp (6 CPE)This event requires a separate registration fee.The International Tax Boot Camp will provide young CPAs and attorneys a beginner-levelsummary of international inbound and outbound taxation.8 – 9 a.m.Registration and Continential Breakfast9:05 a.m. – 12:25 p.m.International Inbound Taxation (3 TB)Scott A. BowmanPartnerAlthough there has been an increase of a traditional outbound taxpractice in Florida during the last decade or so, inbound directinvestment remains the dominant international tax practice area inFlorida and accordingly will receive the most emphasis in thispresentation. This presentation will briefly summarize the basic U.S.federal income, estate and gift tax issues that affect U.S. inboundinternational tax planning.12:25 – 1:35 p.m.Lunch1:40 – 3:50 p.m.International Outbound Taxation (2 TB)William B. ShermanPartner Holland & Knight, LLP Ft LauderdaleKevin E. PackmanPartner Holland & Knight, LLP MiamiThis presentation brings a different focus on outbound investment.Instead of presenting the U.S. outbound rules in the traditional context ofthe large U.S. based multinational, this presentation will present theoutbound topic in a context more often seen in Florida, that of membersof a U.S. family encountering the outbound rules in a closely heldbusiness. This presentation will briefly summarize the basic U.S. federalincome, estate and gift tax issues that affect U.S. federal income taxissues that affect outbound international tax planning.4 – 4:50 p.m.International Tax Forms (1 TB)Renea M. Glendinning, CLU, CPAShareholder Kerkering, Barberio & Company, CPA SarasotaAmy FondoPrincipal CliftonLarsonAllen OrlandoDavid A. Cumberland, CGMA, CPATax Manager Kerkering, Barberio & Company, CPA SarasotaThese presentations will provide practical tips for the international taxpractitioner regarding various inbound and outbound disclosure forms,including ways to avoid common errors in their completion.www.ficpa.org5
Thursday Jan. 57:30 – 8:45 a.m.Registration and Continental Breakfast8:45 – 9 a.m.Introductions and Opening RemarksLawrence J. Chastang, CPAManaging Partner CliftonLarsonAllen OrlandoSteven HadjilogiouPartner Baker & McKenzie, LLP (Mellon Financial Center) Miami9 – 9:50 a.m.Current Developments in International Taxation –Outbound Update (1 TB)Larry R. Kemm, Esq.Partner Harrison Kemm, P.A. TampaThis session will review significant statutory, regulatory, administrativeand judicial developments in U.S. outbound international taxation thatoccurred during 2016.9:50 – 10:40 a.m.Characterizing Income: Why It is So Important for theInternational Tax Practitioner (1 TB)Seth J. Entin, Esq.Shareholder Greenberg Traurig, PA MiamiIt is very dangerous for an international tax practitioner to operate in avacuum and lose sight of the "general principles" of U.S. federal incometaxation. A case in point is the characterization of income. Thispresentation will highlight key characterization of income issues andshow how many important consequences in both the inbound andoutbound contexts turn on how the income in question is characterized.This presentation will also provide multiple examples of how a change inthe character of income can result in adverse or favorableconsequences.11 – 11:50 a.m.Is the United States the Dominant Financial Haven ofthe World? (1 TB)Denis A. Kleinfeld, CPA, JDOf Counsel Fuerst Ittleman David & Joseph, PL MiamiThe 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 isthe lifeblood of every economy. Learn why and how the United Statespositions itself as the dominant country in the global economic contestfor capital and financial success.11:50 a.m. – 1:20 p.m. Lunch Presentation: The U.S. as an Asset-HidingHaven – Selected Ethics and Related Issues (1 TB)Michael Lampert, Esq.Attorney Law Offices of Michael A. Lampert, PA West Palm BeachShawn P. Wolf, Esq.Attorney/Shareholder Packman, Neuwahl & Rosenberg, PA MiamiMuch has been written about asset protection and privacy. There iseven a BNA Tax Management Portfolio on the topic. There are alsomany articles and seminars on the ethics and related issues inundertaking asset protection planning. In addition, there are articles thataddress helping clients hide assets – particularly in the divorce arena.6International Tax Conference
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 domesticallyor internationally?This presentation will touch on the myriad of ethicsand related issues.1:20 – 2:10 p.m.An Overview of the Permitted Activities Under theU.S. Embargo and Taxation of U.S. Investment intoCuba (1 TB)Pedro A. FreyrePartner – Chair, International Practice Akerman LLP MiamiJoin us as we cover the U.S. tax options for U.S. companies that arepermitted to do business in Cuba. We’ll discuss the permitted activitiesunder the U.S. Embargo and how best to address U.S. tax challengesfor an operation in Cuba. Finally, we will outline the Cuban taxes thatcan generally apply to a U.S. company and how best to mitigate them.2:10 – 3 p.m.Tax Planning with Cross-Border Loans – SuccessfullyNavigating Around the Proposed Section 385Regulations (1 TB)James H. BarrettPartner Baker & McKenzie, LLP (Mellon Financial Center) MiamiJeffrey L. Rubinger, Esq.Partner Bilzin Sumberg Baena Price & Axelrod, LLP MiamiWe will cover the inbound and outbound tax consequences of theProposed Section 385 debt/equity rules. Last April, the Treasuryproposed debt/equity rules that broadly impact how debt and equityare classified for international transactions. These controversialproposed regulations impact inbound loans (including portfolio debt);outbound loans that are used to facilitate repatriation of profits; treatybenefitted debt; and certain foreign-to-foreign arrangements. Theproposed regulations have a retroactive effective date and can readilyapply to existing loans. Taxpayers are preparing now for theseregulations. Our panel will review the proposed (or if issued, final)regulations as they apply to inbound and outbound investments, andwhat taxpayers can do to better prepare for these proposedregulations.3:20 – 4:10 p.m.Exploring International Estate Tax and Income TaxPlanning Strategies Involving Issues That areOverlooked (1 TB)Hal J. Webb, Esq.Bilzin Sumberg Baena Price & Axelrod LLP MiamiJennifer J. Wioncek, Esq., LL.M.Associate Baker & McKenzie, LLP (Mellon Financial Center) MiamiWe will cover issues arising with international estate planning matters,such as planning to obtain a step-up in basis in assets held by revocableand irrevocable trusts; planning related to check-the-box elections;dealing with UNI; domestication of trust structures; challenges involvedwhen working with foreign private foundations; and planning for clientswho own valuable tangible personal property located in the U.S.www.ficpa.org7
Thursday (continued)4:10 – 5 p.m.Base Erosion and Profit Shifting: Key Impacts onTransfer Pricing (1 TB)Barry Freeman, Ph.D.Principal Crowe Horwath LLP New York, N.Y.Joshua JohnstonManager Crowe Horwath LLP Oak Brook, Ill.This presentation will provide participants with the key impacts on theglobal pricing landscape as a result of the OECD’s Base Erosion andProfit Shifting project. The discussion will revolve aroundrecommendations for policy changes with respect to the valuation ofintangibles, the allocation of risk within a multinational group, transferpricing documentation and other topics. The session will also inform onrecent legislative actions, court rulings and other developments in theworld of transfer pricing.Friday Jan. 68 – 8:30 a.m.Continental Breakfast8:30 – 9:20 a.m.Current Developments in International Taxation:“Inbound” Update to Include Global Compliance andControversy Developments (1 TB)William M. Sharp, EsqShareholder Sharp Partners, PA TampaThe presentation will technically highlight and provide practitionercommentary regarding two areas: first, “inbound” U.S. statutory,regulatory, administrative and judicial developments, including selectedforeign law developments; and second, U.S. and global tax compliancedevelopments, encompassing a review of IRS/DOJ global complianceinitiatives and relevant selected foreign jurisdiction initiatives.9:20 – 10:10 a.m.International Partnerships: To Boldly Go Where FewHave Gone Before (1 TB)Robert H. MoorePartner Baker & McKenzie LLP MiamiWe will examine the many uses of partnerships in the internationalcontext, exploring both inbound and outbound uses of partnerships.Discussion will include FIRPTA issues, estate tax issues and foreign taxcredit issues.10:30 – 11:20 a.m.Hot Topics in CRS (1 TB)Peter A. Cotorceanu, Esq.CEO and Founder www.gatcandtrusts.com Zürich, SwitzerlandLike FATCA before it, CRS is a moving target. This presentation willaddress the hottest topics in CRS, especially those affecting the fiduciaryindustry.8International Tax Conference
11:20 a.m. – 12:10 p.m. Panel on Miscellaneous Civil and Criminal ProceduralIssues (1 TB)Robert E. Panoff, Esq. (Panel Moderator)Tax Litigator Robert E. Panoff, PA MiamiSelect IRS and Law Enforcement ExpertsThis panel continues its tradition of providing up-to-the-minute informationregarding civil and criminal international tax procedural issues affectingeveryday tax practitioners and their clients. Greater emphasis will beplaced on taxpayers within the jurisdiction of the Small Business/SelfEmployed Division of the IRS, but we will also discuss issues affectingtaxpayers within the Large Business and International Division.12:10 – 1:30 p.m.Lunch Presentation: Update from Washington, D.C.(1 TB)Douglas PomsSenior Counsel to the International Tax Counsel U.S. Department ofTreasury Washington, D.C.This presentation will address current developments related tointernational tax.1:30 – 2:20 p.m.More Than You Need to Know About FloridaCorporate Income Tax and Sales Tax (1 TB)William D. Townsend, JDOf Counsel Dean Mead & Dunbar TallahasseeI will discuss state tax traps for the unwary foreign entity; provide anintroduction to Florida corporate income tax issues faced by foreignentities doing business in the state; and cover application of Floridasales taxes to business activities in the state of Florida.2:35 – 3:25 p.m.Life Insurance and Annuities: Effective Tools for PreImmigration Tax Mitigation (1 TB)Michael H. Ripp, Jr.Giordani, Swanger, Ripp, & Phillips, LLP Austin, TexasThis presentation addresses the various applications of life insuranceand annuity products for mitigating the U.S. tax consequences ofimmigrating to the U.S., whether temporarily or permanently, and willemphasize the use of private-placement contracts and other cost-efficientproducts of particular interest to the high-net-worth (HNW) immigrant.3:25 – 4:15 p.m.Tips to Take Home: What’s New with InternationalTax Forms (1 TB)David A. Cumberland, CPA, CGMATax Manager Kerkering, Barberio & Company SarasotaAmy Fondo, CPAPrincipal CliftonLarsonAllen LLP OrlandoRenea M. Glendinning, CPAShareholder Kerkering, Barberio & Company SarasotaThis presentation will provide practical tips for the international taxpractitioner regarding various inbound and outbound disclosure forms,including ways to avoid common errors in their completion. We will alsodiscuss recent procedural changes implemented by the IRS, including anupdate on the ITIN renewal process.www.ficpa.org9
Conference infoConference Site andAccommodationsJW Marriott Miami1109 Brickell AvenueMiami, FL 33131(305) 329-3500 Fax: (305) 374-4211FICPA Room Rate: 309Hotel Cutoff Deadline:Tuesday, Dec. 13, 2016*Please call the JW Marriott Miami at (800) 2289290 or (800) 503-0598 to reserve your room.Be sure to mention this conference to receive thespecial group rate.*Room availability is not guaranteed by this dateand inventory may fill up before the cutoff date. Ifany rooms are left after the cutoff date, they willbe added back to the general hotel inventory andsold at the prevailing hotel rate.Resort FeesThere may be a fee for some guest services. Notall features and services are available in all rooms.Please contact the hotel for details.Be Seen by Our AttendeesThe FICPA offers unique conference sponsorshipopportunities that can help increase visibility andexposure of services and products.For more information about the FICPA conferences,contact Drew Miller, Corporate Sales Manager,at (800) 342-3197, Ext. 270; or millerd@ficpa.org.10International Tax ConferenceTwo Ways to AttendIf you can't make it to the35th International TaxConference, we'll have theentire conference availablethrough Simulcast! To registerfor the Simulcast and learnmore, please visit:www.ficpa.org/ITC.International Tax Course BookHard-Copy Course Book 64.50 ( 60 Tax)(CPE/CLE credit is not awarded for thepurchase of the course book)Please include sales tax unless ordering party istax-exempt or a nonresident of Florida. If taxexempt include documentation with the order.CPE Policies You May Need to KnowCPE policies may be found on our website atwww.ficpa.org/policies or on the confirmationsent upon completion of registration.Bring Your Team and SaveRegister five or more people from the sameorganization and receive special group discounts!Restrictions may apply. For more information, visitwww.ficpa.org/policies.
RegistrationFour ways to register for FICPA CPE ProgramsInternet registration can be placed at www.ficpa.org/cpe.Fax a completed registration form with credit card information to the FICPA at (850) 681-2433.Call the FICPA Member Service Center at (800) 342-3197, or (850) 224-2727 to place a credit card order.Mail a completed registration form to: Continuing Professional Education, FICPA, P.O. Box 5437, Tallahassee, FL 32314-5437.Contact InformationNameFICPA Member No.FirmAddressTelephone (City/State/ZIP)m Check here if registration reflects an address change.m Check the following box(s) to receive membershipE-Mailm In accordance with ADA requirements, if you areinformation for:m Florida CPA/PAC m FICPA Educational Foundationdisabled and require special services, please checkhere. Someone from our office will contact you.PricingITC Conference (ITC)Early Bird Price*Regular Price (as of 12/6/2016)**International Tax Course BookHardcopy Course BookInternational Tax Boot CampPrice 660 715Price 64.50 ( 60 tax)Early Bird Price*Regular Price (as of 12/5/2016)**Price 250 305Early Bird Price – Both DaysRegular Price – Both Days (as of 12/6/2016)**Price 725 780To register for the webcast, go to: http://tinyurl.com/FloridabarCLE2331R.For assistance with the webcast registration, please call 1-877-880-1335.PLEASE NOTE! To receive CPE or CLE credit, each person attending thewebcast must be registered individually.Register more than 30 days before the course date and receive 55 off of your registration.(optional) # of BooksSubtotal Total Method of Paymentm Check enclosed in the amount of made payable to the FICPA and mailed to:FICPA, Continuing Professional Education, P.O. Box 5437, Tallahassee, FL 32314-5437.To pay with a credit card, please go online at nd click International Tax Conference, then click the “Register” button or call the FICPA MemberServices Center at (800) 342-3197 or (850) 224-2727.www.ficpa.org11
CONFERENCEJan. 5-6, 2017 Miami or OnlineInternational Tax35th AnnualP.O. Box 5437 Tallahassee, Florida 32314www.ficpa.org/cpe(800) 342-3197(850) 224-2727
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);
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