Seeing Things. CPE/CLE Credit

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2 Seeing Things Globally How do you stay current in the ever changing field of international finance? We ve got the perfect solution join us for an incredible professional development opportunity where you ll learn the latest--greatest information on new trends, laws technology as well as discover how to move ahead in your career. The 34th Annual International Tax Conference will be held in beautiful Miami on January 7-8, 2015 making this the Do Not Miss international tax conference of the year. You ll receive updates on current developments regarding taxation; discuss planning U.S. transfer tax treaties; review tips for advising foreign clients; hear a panel discussion on civil criminal procedural issues. You ll leave this two-day conference with take-a-way s you can put into motion right away to help you your clients succeed. Looking for a beginner level summary of international inbound outbound taxation? We are pleased to announce the International Tax Boot Camp, which will take place on January 6, The International Tax Boot Camp will also provide an introduction to the topics that will be discussed during our two-day International Tax Conference. See page 5 for more details. CPE/CLE Credit This conference qualifies for 16 Technical Business (TB) hours of CPE credit is subject to change. CPE credit is subject to approval by the Florida Department of Business Professional Regulation. Type of credit is dependent upon breakout selection. CLE credit to be awarded by the Florida Bar. The number of CLE credit hours is to be determined.

3 Conference at-a-glance Wednesday Jan. 6 International Tax Boot Camp Separate registration fee required. See page 5 for more details. Thursday Jan. 7 7:30 8:45 a.m. Registration Continential Breakfast 8:45 9 a.m. Introduction 9 9:50 a.m. Current Developments in International Taxation Outbound Update 9:50 10:40 a.m. The PFIC Regime: Scalpel or Sledgehammer? 11 11:50 a.m. Foreign Tax Credit Planning What Every International Tax Practitioner Should Know 11:50 a.m. 1:20 p.m. Lunch Presentation: Current Developments Trends in International Taxation 1:20 3 p.m. Pack Your Bags, We re Moving: Pre-Immigration Planning for Foreigners Moving to the U.S. from Argentina, Colombia, or Brazil 3:20 4:10 p.m. Exceptions, Exclusions, Exchanges, Exhilaration Planning with U.S. Transfer Tax Treaties 4:10 5 p.m. Tax-Free Spinoffs in the International Context 5 p.m. Until Reception Friday Jan :30 a.m. Continental Breakfast 8:30 9:20 a.m. Current Developments in International Taxation Inbound Update Including Global Compliance Controversy Developments 9:20 10:10 a.m. All the Extra U.S. Tax Issues about Advising Foreign Clients on U.S. Real Estate Investments, but Were Afraid to Ask 10:30 11:20 a.m. Transfer Pricing for Small Medium Sized Businesses 11:20 a.m. 12:10 p.m. Panel on Miscellaneous Civil Criminal Procedural Issues 12:10 1:30 p.m. Lunch Presentation 1:30 2:20 p.m. Canadians Investing in U.S. Real Estate 2:35 3:25 p.m. The Brave New World of Tax Transparency: Exchange of Information, Transparency of Entities, New Dems on Taxpayers Tax Intermediaries 3:25 4:15 p.m. Tips to Take Home 3

4 Planning Committee International Tax Conference Planning Committee Lawrence Chastang, Co-Chair Shawn P. Wolf, Co-Chair Renea M. Glendinning, Vice Chair Mirtha G. Aguirre James R. Attkisson Gene S. Bonham John L. Brantley Mirtha T. Carballo Kevin Carmichael Rall M. Cathell David A. Cumberl Arthur J. Dichter Manuel Ferro, Jr. Richard A. Jacobson Lewis B. Kevelson Denis A. Kleinfeld Maria M. Lopez Clarece Y. Nash Daniel A. Nieda Sebastian Nye-Schmitz Laura A. Prevratil Michael Rosenberg James W. Spencer Alfredo R. Tamayo Brian S. Walgamott 4 International Tax Conference

5 Wednesday Jan. 6 9 a.m. 5 p.m. International Tax Boot Camp The International Tax Boot Camp will provide young CPAs attorneys a beginner level summary of international inbound outbound taxation (Separate Registration Fee) Topics to be covered in the International Tax Boot Camp include: Inbound Tax: Residence of Individuals Entities Entity Classification Source of Income Rules Gross Basis Net Basis Taxation of US Source Income Foreign Investment in Real Property Tax Act ( FIRPTA ) Effectively Connected Income Pre-Immigration Planning Outbound Tax: Taxation of Worldwide Income Subpart F Passive Foreign Investment Company Taxation Foreign Tax Credits Code Sections 367 Inversions Expatriation Offshore Voluntary Disclosure Program International Tax Boot Camp Discounts Available Register five or more people from the same organization receive special group discounts! Restrictions may apply. For more information, visit ficpa.org/policies. 5

6 Thursday Jan. 7 7:30 8:45 a.m. Registration Continental Breakfast 8:45 9 a.m. Introduction (1 TB) Lawrence J. Chastang, CPA Chairman - Global Advisory Services CliftonLarsonAllen LLP Orlo Shawn P. Wolf, Esq. Attorney Shareholder Packman, Neuwahl & Rosenberg, PA Coral Gables 9 9:50 a.m. Current Developments in International Taxation Outbound Update (1 TB) Larry R. Kemm, Esq. Partner Harrison Kemm, P.A. Tampa Review current U.S. developments in outbound international taxation provide an overview of significant statutory, regulatory, administrative, judicial authorities that occurred during :50 10:40 a.m. The PFIC Regime: Scalpel or Sledgehammer? (1 TB) Seth J. Entin, Esq. Shareholder Greenberg Traurig, PA Miami In the international tax arena, the PFIC rules are among the most notorious in their complexity harshness. Unfortunately, these rules are often overbroad can cause adverse consequences even in seemingly innocent scenarios. This presentation will go through many of these traps provide suggestions for avoiding them :50 a.m. Foreign Tax Credit Planning What Every International Tax Practitioner Should Know (1 TB) Jeffrey L. Rubinger, Esq. Partner Bilzin Sumberg Miami Discussion focuses on foreign tax credit issues planning opportunities that every international tax practitioner should be aware of. Learn more with indepth dialog on what constitutes a creditable foreign tax; the relevance of the "check the box" rules in foreign tax credit planning; special sourcing rules; foreign tax credit splitting events; the impact of U.S. income tax treaties. 11:50 a.m. 1:20 p.m. Lunch Presentation: Current Developments Trends in International Taxation (1 TB) Lee Sheppard Contributing Editor Tax Notes Washington, D.C. 6 International Tax Conference

7 1:20 3 p.m. Pack Your Bags, We re Moving: Pre-Immigration Planning for Foreigners Moving to the U.S. from Argentina, Colombia, or Brazil (2 TB) Hal J. Webb, Esq. Partner Cantor & Webb, PA Miami Ana Cláudia Akie Utumi, PhD, CFP, TEP Head of Tax Area TozziniFreire Advogados Sao Paulo, Brazil Valeria Paula D'Alessro Associate Marval O'farrell & Mairal Buenos Aires, Argentina Adrián Rodríguez Partner Lewin & Wills Bogota, Colombia When a foreign person is planning to move to the U.S., the U.S. tax advisors tend to focus primarily on the U.S. tax implications related planning strategies. Sometimes, the tax non-tax issues in the foreigner s home country are just as important as the U.S. issues. This session will cover some pre-immigration issues planning strategies from a U.S. perspective, but it will primarily focus on the issues involved in the foreigner s home country. In particular, this session will feature a case study analyzing the similarities differences encountered by people moving to the U.S. from Argentina, Brazil, Colombia. 3:20 4:10 p.m. Exceptions, Exclusions, Exchanges, Exhilaration Planning with U.S. Transfer Tax Treaties (1 TB) Leslie A. Share, Esq Shareholder Packman, Neuwahl & Rosenberg, PA Coral Gables The purpose of this presentation is to review consider the potential planning opportunities provided by U.S. estate, gift, generationskipping transfer tax treaties. These bilateral government agreements offer certain asset structuring other benefits to qualified individuals their estates which are otherwise unavailable under the regularly applicable U.S. tax law rules. Also discussed are the treaty exchange of information provisions their possible repercussions in client situations. Discussion will focus upon how such planning should be approached hled from both a technical practical stpoint. 4:10 5 p.m. Tax-Free Spinoffs in the International Context (1 TB) James H. Barrett, Esq. Partner Baker & McKenzie, LLP Miami Steven Hadjilogiou, Esq. Partner Baker & McKenzie, LLP Miami Code Section 355 Spin-offs Divisive Type D Reorganizations are complex highly scrutinized transactions. These transactions in the international context provide even more complexity. Closely held public US multinational corporations have been increasingly utilizing spin-offs to accomplish their business goals. The panelists will discuss the U.S. foreign tax ramifications of international spin-offs creative solutions to issues encountered in international spinoffs. The discussion will include an overview of the taxation of closely held public US multinationals that are engaging in corporate reorganizations. 7

8 Friday Jan :30 a.m. Continental Breakfast 8:30 9:20 a.m. Current Developments in International Taxation Inbound Update Including Global Compliance Controversy Developments (1 TB) William M. Sharp, Esq Shareholder Sharp Partners, PA Tampa, San Francisco, Washington, D.C. Zurich Switzerl The presentation will highlight provide practitioner comments related to two general areas: inbound U.S. statutory, regulatory, administrative judicial developments, including selected foreign law developments; U.S. global tax compliance developments, encompassing a review of IRS/DOJ initiatives selected foreign country voluntary disclosure programs. 9:20 10:10 a.m. All the Extra U.S. Tax Issues about Advising Foreign Clients on U.S. Real Estate Investments, but Were Afraid to Ask (1 TB) Robert F. Hudson Jr, Esq Partner Baker & McKenzie, LLP Miami Robert H. Moore, Esq. Partner Baker & McKenzie, LLP Miami This presentation will focus on how NRAs should own U.S., real property interests ( USRPIs ) considering both FIRPTA FIRPTA withholding tax Section 1446 withholding tax issues; whether a lease should be entered between the UBO the USRPI owning entity; how to own valuable artworks, furniture other tangible personal properties associated with the USRPIs; Florida sales tax issues that could arise (e.g., on short term leases vs. long-term leases) other ancillary issues of USRPI ownership by NRAs. 10:30 11:20 a.m. Transfer Pricing for Small Medium Sized Businesses (1 TB) H. Edward Morris Jr., CPA/ABV, ASA Director National Transfer Pricing Leader CliftonLarsonAllen LLP Chicago, IL This presentation is for executive suite level individuals will provide participants in non-technical language the basic concepts of transfer pricing; why it is important for small medium size businesses to underst the basics of transfer pricing; business risks of not paying attention to transfer pricing; documentation requirements, including after the fact when being audited by IRS /or one or more foreign tax authorities. 8 International Tax Conference

9 11:20 a.m. 12:10 p.m. Panel on Miscellaneous Civil Criminal Procedural Issues (1 TB) Robert E. Panoff, Esq - Panel Moderator Tax Litigator Robert E. Panoff, PA Miami Invited IRS Law Enforcement Experts This panel continues its tradition of providing up-to-the-minute information regarding civil criminal international tax procedural issues affecting tax practitioners their clients. Greater emphasis will be placed on taxpayers within the jurisdiction of the IRS s Small Business/Self Employed Division, but the panel also will discuss issues affecting taxpayers within the Large Business International Division. 12:10 1:30 p.m. Lunch Presentation: TBD (1 TB) 1:30 2:20 p.m. Canadians Investing in U.S. Real Estate (1 TB) Jack Bernstein, Esq. Partner Aird & Berlis LLP Toronto This presentation will discuss Canadians acquiring rental properties, participating in development purchasing personal residences businesses. 2:35 3:25 p.m. The Brave New World of Tax Transparency: Exchange of Information, Transparency of Entities, New Dems on Taxpayers Tax Intermediaries (1 TB) Bruce Zagaris, Esq Partner Berliner, Corcoran & Rowe, LLP Washington, D.C. The presentation will discuss the initiatives of the U.S. governments foreign governments (especially tax authorities) to develop enhanced tax transparency international tax enforcement cooperation the new dems on taxpayers tax intermediaries. 3:25 4:15 p.m. Tips to Take Home (1 TB) David A. Cumberl, CPA, CGMA Tax Manager Kerkering, Barberio & Company Sarasota Renea M. Glendinning, CPA Shareholder Kerkering, Barberio & Company Sarasota This presentation will provide practical tips for the international tax practitioner regarding various inbound tax issues. The discussion will include how to avoid making common errors in completing applications for ITINs (Form W-7), withholding under FIRPTA (Forms 8288-B, A), nonresident income tax reporting (Form 1040NR). 9

10 Conference info Conference Site Accommodations JW Marriott Miami 1109 Brickell Avenue Miami, FL (305) Fax: (305) FICPA Room Rate: $299 Hotel Cutoff Deadline: Wednesday, December 16, 2015* Please call the JW Marriott Miami Reservations at (800) or (800) to reserve your room. Be sure to mention the FICPA/Florida Bar International Tax Conference to receive the special group rate. *Room availability is not guaranteed by this date inventory may fill up before the cutoff date. If any rooms are left after the cutoff date, they will be added back to the general hotel inventory sold at the prevailing hotel rate. Miami or Online Can't Attend in Person? If you can't attend the 34th Annual International Tax Conference in person, we'll have the entire conference available through live webcast! To register for the webcast, go to tfb.inreachce.com. Click on Hello Guest to set up an account. Search for International Tax Conference. To register for the webcast, go to: For assistance with the webcast registration, please call PLEASE NOTE! To receive CPE or CLE credit, each person attending the webcast must be registered individually. Are you using all of the FICPA Conference EZMaterials advantages? Available in Advance Download the EZMaterials PDFs to your laptop, tablet or other device seven days before the event. Searchable Save time by jumping right to a subject no more flipping through pages or reading extra. Portable Upload your materials to the cloud or save to a flash drive access anywhere. Green Help preserve our beautiful planet by saving paper. More convenient, greener so much EZer! International Tax Course Book Cost $60 plus tax (CPE/CLE credit is not awarded for the purchase of the course book) Please include sales tax unless ordering party is tax-exempt or a nonresident of Florida. If tax exempt include documentation with the order. CPE Policies You May Need to Know CPE policies may be found on our website at ficpa.org/policies or on the registration confirmation sent upon completion of registration. Bring Your Team Save Register five or more people from the same organization receive special group discounts! Restrictions may apply. For more information, visit ficpa.org/policies. #ficpaitc 10 International Tax Conference *Early Bird Policy: The deadline for the Early Bird Price has moved from 10 days to 30 days before the event. This change is an opportunity for the FICPA to better manage the costs associated with these events, so we can continue to bring you quality CPE at an affordable price. Remember to register for CPE events 30 days prior to take advantage of the Early Bird Pricing. That is a $55 savings!

11 Four ways to register for FICPA CPE Programs Name FICPA Member No. Firm Address City/State/ZIP Telephone ( ) Pricing Registration Internet registration can be placed at Fax a completed registration form with credit card information to the FICPA at (850) Call the FICPA Member Service Center at (800) , or (850) to place a credit card order. Mail a completed registration form to: Continuing Professional Education, FICPA, P.O. Box 5437, Tallahassee, FL Contact Information m Check here if registration reflects an address change. m Check the following box(s) to receive membership information for: m Florida CPA/PAC m FICPA Educational Foundation m In accordance with ADA requirements, if you are disabled require special services, please check here. Someone from our office will contact you. ITC Conference (ITC) Price Early Bird Price* $635 Regular Price (as of 12/7/2015)** $690 International Tax Course Book Price Hardcopy Course Book $60 International Tax Boot Camp Price Early Bird Price* $250 Regular Price (as of 12/7/2015)** $275 Method of Payment m Check enclosed in the amount of $. m Please charge my company-issued credit card: m Please charge my personal credit card: Cardholder Name Price Early Bird Price Both Days $725 Regular Price Both Days (as of 12/7/2015)** $780 To register for the webcast, go to: For assistance with the webcast registration, please call PLEASE NOTE! To receive CPE or CLE credit, each person attending the webcast must be registered individually. Register more than 30 days before the course date receive $55 off of your registration. (optional) # of Books Subtotal $ Total $ m VISA mmastercard mamerican Express mdiscover Card Validation Code: (3 or 4 digit code located on the credit card) Signature Exp. Date The FICPA is not responsible for checks or registrations delayed or lost in the mail. 11

12 P.O. Box 5437 Tallahassee, Florida th Annual International Tax CONFERENCE Jan. 7-8, 2016 Miami or Online (800) (850)