35th Annual International Tax Conference
The Florida Bar Continuing Legal Education Committee, the TaxSection and the FICPA present the35th AnnualInternational TaxConferenceCOURSE CLASSIFICATION: ADVANCED LEVELJanuary 5 - 6, 2017lionatanInter t Camp!Boo ary 4,TaxanuJ.dWe 2017J.W. Marriott Hotel1109 Brickell AvenueMiami, Florida 33131800-228-9290LiveWebcaAvaila stbLondo le innZurich &!Course No. 2330/2331R
Schedule of Events2017 International Tax BootcampCourse No. 2330RWednesday, January 4, 2017INTERNATIONAL INBOUND TAXATION (3 hours)INTERNATIONAL OUTBOUND TAXATION (3 hours)9:00 a.m. – 9:05 a.m.Introduction1:40 p.m. – 3:10 p.m.Outbound Session9:05 a.m. – 10:30 a.m.Inbound Session3:10 p.m. – 3:30 p.m.Afternoon Break10:30 a.m. – 10:50 a.m.Morning Break3:30 p.m. – 5:00 p.m.Outbound Session Continued10:50 a.m. – 12:25 p.m.Inbound Session ContinuedNETWORKING RECEPTION (Included)12:25 p.m. – 1:40 p.m.Lunch (Included)CLE Credit:General:7.0 hoursCertification CreditInternational:7.0 hours5:00 p.m. – 6:00 p.m.International Tax Conference Course No. 2331RTHURSDAY, JANUARY 5, 20177:30 a.m. - 8:45 a.m. Registration8:45 a.m. - 9:00 a.m. IntroductionSteven Hadjilogiou, Esq./Partner/Baker & McKenzie LLP/Miami, FLLarry Chastang, CPA//Principal/CliftonLarsonAllen LLP/Orlando, FL9:00 a.m. - 9:50 a.m.Current Developments in International Taxation – OutboundUpdateLarry R. Kemm, Esq./Harrison Kemm P.A./TampaThis session will review significant statutory, regulatory,administrative, and judicial developments in U.S. outboundinternational taxation that occurred during 2016.9:50 a.m. - 10:40 a.m.Characterizing Income: Why it is so Important for theInternational Tax PractitionerSeth J. Entin, Esq./Shareholder/Greenberg Traurig, P.A./Miami, FLIt is very dangerous for an international tax practitioner to operatein a vacuum and lose sight of the “general principles” of U.S.federal income taxation. A case in point is the characterization ofincome. This presentation will highlight key characterization ofincome issues and show how many important consequences inboth the inbound and outbound contexts turn on how the incomein question is characterized. This presentation will also providemultiple examples of how a change in the character of income canresult in adverse or favorable consequences.10:40 a.m. - 11:00 a.m. Networking Break11:00 a.m. - 11:50 a.m.Professor Denis Kleinfeld, Esq./Of Counsel/Fuerst Ittleman David& Joseph, PL/Miami, FLIs the United States the Dominant Financial Haven of the World?The world is full of competing tax havens, asset protectionjurisdictions, banking and investment states, and wealthmanagement destinations. Every country, big and small, wantsand needs to attract and keep wealth. Capital is the lifeblood ofevery economy. This presentation will inform you why and howthe United States positions itself as the dominant country in theglobal economic contest for capital and financial success.11:50 a.m. - 1:20 p.m. (Lunch Included)U.S. As An Asset Hiding Haven Selected Ethics and RelatedIssuesShawn Wolf & Michael A. LampertMuch has been written about asset protection and privacy. Thereis even a BNA Tax Management Portfolio on the topic. (8103rd) There are also many articles and seminars on the ethicsand related issues in undertaking asset protection planning. Inaddition, there are articles addressing helping clients hide assets,particularly in the divorce arena.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 CubaPedro A. Freyre & Michael J. BrunoThis presentation will cover the US tax options for US companiesthat are permitted to do business in Cuba. We will discuss thepermitted activities under the U.S. Embargo and how best toaddress US tax challenges that are particular to an operation inCuba. Finally, we will outline the Cuban taxes that generally applyto a US company that is engaged in a permitted business in Cubaand how best to mitigate the applicable Cuban taxes.2:10 p.m. - 3:00 p.m.Tax Planning with Cross-Border Loans - SuccessfullyNavigating Around the Proposed Section 385 RegulationsJames H. Barrett/Partner/ Baker & McKenzie / Miami, FLJeffrey Rubinger, Esq./Partner/Bilzin Sumberg/Miami, FLThis panel will cover the inbound and outbound tax consequencesof the Proposed Section 385 debt/equity rules. Last April,Treasury proposed debt/equity rules that broadly impact howdebt and equity are classified for international transactions.Areas impacted by these controversial proposed regulationsinclude inbound loans (including portfolio debt), outbound loansthat are used to facilitate repatriation of profits, treaty benefitteddebt and certain foreign to foreign arrangements. The proposedregulations have a retroactive effective date and can readilyapply to existing loans. As such, taxpayers are preparing for theissuance of the final regulations which are expected to be issuedin the fall of 2016. This panel will review the proposed regulations(and if they have been issued, the final regulations) as they applyto inbound and outbound investments (with a focus on closelyheld investments) and what taxpayers can do to better prepare forthese proposed regulations.
Schedule of Events3:00 p.m. - 3:20 p.m. Networking Break3:20 p.m. - 4:10 p.m.In Case You Thought This Was Easy, It Isn’t: ExploringInternational Estate Tax and Income Tax Planning StrategiesInvolving Issues That Are Overlooked or Do Not Get TheAttention They DeserveHal J. Webb, Esq./Partner/Bilzin Sumberg/Miami, FLJennifer J. Wioncek, Esq./Partner/Bilzin Sumberg/Miami, FLThis session will cover various interesting issues that arisewhen dealing with international estate planning matters, suchas planning to obtain a step-up in basis in assets held byrevocable and irrevocable trusts, planning related to check-thebox elections, dealing with UNI, domestication of trust structures,challenges involved when working with foreign private foundationsand planning for clients who own valuable tangible personalproperty located in the U.S.4:10 p.m. - 5:00 p.m.Base Erosion and Profit Shifting: Key Impacts on TransferPricingBarry Freeman, PhD, Principal and Transfer Pricing GlobalLeader Crowe Horwath LLP, New York, NYJosh JohnstonThis presentation will provide participants with the key impacts onthe global transfer pricing landscape as a result of the OECD’sBase Erosion and Profit Shifting project. The discussion willrevolve around recommendations for policy changes with respectto the valuation of intangibles, the allocation of risk within amultinational group, transfer pricing documentation, and othertopics. The session will also inform on recent legislative actions,court rulings, and other developments in the transfer pricingworld.5:00 p.m. - 6:00 p.m. Reception (Included)FRIDAY, JANUARY 6, 20178:00 a.m. - 8:30 a.m. Breakfast (Included)8:30 a.m. - 9:20 a.m.Current Developments in International Taxation: “Inbound”Update Including Global Compliance and ControversyDevelopmentsWilliam M. Sharp, Sr., Esq./Sharp Partners P.A./Tampa, FL Zurich, Switzerland San Francisco, CA Washington, D.C.The presentation will technically highlight and provide practitionercommentary pointers 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 reviewof IRS/DOJ global compliance initiatives and relevant selectedforeign jurisdiction initiatives.9:20 a.m. - 10:10 a.m.International Partnerships: To Boldly Go Where Few HaveGone BeforeRobert H. Moore/Partner/Baker & McKenzie LLP/Miami, FLThis presentation will examine the many uses of partnerships inthe international context, exploring both inbound and outbounduses of partnerships, including FIRPTA issues, estate tax issues,and foreign tax credit issues.10:10 a.m. - 10:30 a.m. Networking Break10:30 a.m. - 11:20 a.m. Hot Topics in CRSPeter Cotorceanu, CEO and Founder of www.gatcandtrusts.com/Zurich, SwitzerlandLike FATCA before it, CRS is a moving target. This presentationwill address the hottest topics in CRS, especially those affectingthe fiduciary industry.11:20 a.m. - 12:10 p.m.Panel on Miscellaneous Civil and Criminal Procedural IssuesRobert E. Panoff, Esq., Panel Moderator Tax Litigator Miami,Select IRS and Law Enforcement ExpertsThis panel continues its tradition of providing up-to-the-minuteinformation regarding civil and criminal international taxprocedural issues affecting everyday tax practitioners and theirclients. Greater emphasis will be placed on taxpayers within thejurisdiction of the IRS’s Small Business /Self Employed Division,but the panel also will discuss issues affecting taxpayers withinthe Large Business and International Division.12:10 p.m. - 1:30 p.m. (Lunch Included)Update from Washington, D.C.Douglas Poms/Senior Counsel to the International Tax Counsel/US Department of TreasuryThis presentation will address current developments related tointernational tax.1:30 p.m. - 2:20 p.m.More Than You Need to Know About Florida CorporateIncome Tax and Sales TaxWilliam D. Townsend, Esq./Of Counsel/Dean Mead & Dunbar/Tallahassee, FLState tax traps for the unwary foreign entity. Introduction toFlorida corporate income tax issues faced by foreign entitiesdoing business in the state. Application of Florida sales taxes tobusiness activities in the state of Florida.2:20 p.m. - 2:35 p.m. Networking Break2:35 p.m. - 3:25 p.m.Life Insurance and Annuities: Effective Tools for PreImmigration Tax MitigationMichael H. Ripp, Jr., Esq., Partner, Giordani, Swanger, Ripp &Phillips, LLP, Austin,TexasThis presentation addresses the various applications of lifeinsurance and annuity products for mitigating the U.S. taxconsequences of immigrating to the U.S., whether temporarilyor permanently, and will emphasize the use of private placementcontracts and other cost-efficient products of particular interest tothe high net worth (HNW) immigrant.3:25 p.m. - 4:15 p.m.Tips to Take Home: What’s New with International Tax FormsAmy Fondo, CPA/Principal/CliftonLarsonAllen LLP, OrlandoRenea M. Glendinning, CPA/Shareholder/Kerkering, Barberio &Company, SarasotaDavid A. Cumberland, CPA, CGMA/Tax Manager/Kerkering,Barberio & Company, SarasotaThis presentation will provide practical tips for the international taxpractitioner regarding various inbound and outbound disclosureforms, including ways to avoid common errors in their completion.Also discussed will be recent procedural changes implemented bythe IRS, including an update on the ITIN renewal process.
CLE COMMITTEETAX SECTIONWilliam Lane, Jr., Tampa, ChairJoseph Schimmel, Miami, Chair-ElectAbrahm Smith, Miami , Director, Education DivisionMicah Fogarty, Tampa , Director, Education DivisionEvett Simmons, Port Saint Lucie, ChairTerry L. Hill, Director, Programs DivisionFACULTY & STEERING COMMITTEESteven Hadjilogiou, Miami, Program Co-ChairLawrence J. Chastang, Orlando, Program Co-ChairSeth Entin, MiamiLawrence R. Kemm, TampaKevin E. Packman, MiamiJeffrey L. Rubinger, MiamiHal J. Webb, MiamiCLE CREDITSCLER PROGRAMCERTIFICATION PROGRAM(Max. Credit: 17.5 hours)General: 17.5 hoursEthics: 2.0 hours(Max. Credit: 17.5 hours)Immigration and Nationality Law: 2.0 hoursInternational Law: 17.5 hoursTax Law: 17.5 hoursSeminar credit may be applied to satisfy CLER / Certification requirements in the amounts specified above, not to exceedthe maximum credit. See the CLE link at www.floridabar.org for more information.Prior to your CLER reporting date (located on the mailing label of your Florida Bar News or available in your CLE recordon-line) you will be sent a Reporting Affidavit if you have not completed your required hours (must be returned by yourCLER reporting date).REFUND POLICYA 25 service fee applies to all requests for refunds. Requests must be in writing and postmarked no later thantwo business days following the live course presentation or receipt of product. Registration fees are non-transferrable, unless transferred to a colleague registering at the same price paid. Registrants who do not notify TheFlorida Bar by 5:00 p.m., January 4, 2017 that they will be unable to attend the seminar, will have an additional 150 retained. Persons attending under the policy of fee waivers will be required to pay 150.HOTEL RESERVATIONSA block of rooms has been reserved at the JW Marriott, at the rate of 309 single/double occupancy. To makereservations, call the JW Marriott directly at (800) 228-9290. Reservations must be made by 12/13/16 to assurethe group rate and availability. After that date, the group rate will be granted on a “space available” basis.
RegistrationRegister me for the 35th Annual International Tax ConferenceONE LOCATION: (190) J.W. MARRIOTT HOTEL, MIAMI, FL (JANUARY 5 - 6, 2017)TO REGISTER OR ORDER AUDIO CD OR COURSE BOOKS BY MAIL, SEND THIS FORM TO: The Florida Bar, Order EntryDepartment, 651 E. Jefferson Street, Tallahassee, FL 32399-2300 with a check in the appropriate amount payable to The FloridaBar or credit card information filled in below. If you have questions, call 850/561-5831. ON-SITE REGISTRATION, ADD 25.00.On-site registration is by check only.Name Florida Bar #Address Phone: ( )City/State/ZipE-mail* Asst. Email*E-mail address required to receive electronic course material and will only be used for this order.CH: Course No. 2331RELECTRONIC COURSE MATERIAL NOTICE: Florida Bar CLE Courses feature electronic course materials for all live presentations, livewebcasts, webinars, teleseminars, audio CDs and video DVDs. This searchable electronic material can be downloaded and printed and isavailable via e-mail several days in advance of the live presentation or thereafter for purchased products. Effective July 1, 2010.ITC Conference (ITC):ITC Webcast: Early Bird Price*: 660 Regular Price (as of 12/6/16): 715To register visit: http://tinyurl.com/FloridabarCLE2331RInternational Tax Course Book:Regular Price: 750International registrants contact:Lawrence J. Chastang at (407) 802-1200 for information Hardcopy course Book: 64.50 plus taxInternational Tax Boot Camp: (2330R)METHOD OF PAYMENT (CHECK ONE): Check enclosed made payable to The Florida Bar Credit Card (Fax to 850/561-9413.) MASTERCARD VISA DISCOVER AMEX Early Bird Price*: 250 Regular Price (as of 12/5/16): 305Exp. 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 appropriateaccommodations, 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, 2017AUDIO CD — DVD VIDEO — ON-LINE — PUBLICATIONSPrivate 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, including a street address for delivery. Please add sales tax. Those eligible for the abovementioned fee waiver may order a complimentary audio CD in lieu of live attendance upon written request and for personaluse 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. AUDIO CD(2331C)(includes Electronic Course Material) 715 plus tax (section member) 715 plus tax (non-section member) TAX TOTAL DVD VIDEO(2331C)(includes Electronic Course Material) 765 plus tax (section member) 765 plus tax (non-section member) TAX TOTAL
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debt and equity are classified for international transactions. Areas impacted by these controversial proposed regulations include 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
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