Inspiration How can you help your clients avoid double taxation, complex reporting and more?

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2 Draw from Worldly Inspiration How can you help your clients avoid double taxation, complex reporting more? Join the FICPA at the 33rd Annual International Tax Conference in Miami on January 8-9, 2015 (earlier date) to experience an event that offers updates tips on the issues that matter most to you your clients. Conference sessions include inbound outbound developments in international taxation, residence vs. domicile, tax planning with inversions more. We are proud to bring some of the best instructors experts from all over the globe to share their worldly inspiration insight with YOU. ITC is Going Global This conference will be available by webcast to satellite offices in London Zurich. See page 10 for details. Follow the FICPA on use #ficpaitc to tweet about this conference. 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. CLE credit will be awarded by The Florida Bar. The number of credit hours is to be determined.

3 Conference at-a-glance Thursday Jan. 8 7:30-8:45 a.m. Registration Continental Breakfast 8:45-9 a.m. Introduction Opening Remarks 9-9:50 a.m. Current Developments in International Taxation Outbound Update 9:50-10:40 a.m. How to Escape Houdini s FIRPTA Straight Jacket Before After the Show! 10:40-11 a.m. Networking Break 11-11:50 a.m. FATCA, the OECD s Global FATCA, the Fiduciary Industry: Current Challenges Practical Next Steps 11:50 a.m.-1:20 p.m. Lunch Presentation: Puerto Rico as an Investment Destination: Current Tax Economic Incentives 1:20-2:10 p.m. Selected Effectively Connected Income Issues 2:10-3 p.m. Don t Leave Home without It (Tax Advice) 3-3:20 p.m. Networking Break 3:20-4:10 p.m. Ethical Issues in International Estate Planning for U.S. Lawyers 4:10-5 p.m. Residence Domicile Off the Beaten Path Friday Jan :30 a.m. Continental Breakfast 8:30-9:20 a.m. Current Developments in International Taxation Inbound Update 9:20-10:10 a.m. Representing the Mexican Client Investing in the U.S. Advising the U.S. Client Investing in Mexico 10:10-10:30 a.m. Networking Break 10:30 a.m.-12:10 p.m. Panel on Miscellaneous Civil Criminal Procedural Issues 12:10-1:30 p.m. Lunch Presentation: Update from Washington DC with a Focus on BEPS Beyond 1:30-2:20 p.m. Using a DISC corporation to Reduce U.S. Income Tax on U.S. Exports 2:20-2:35 p.m. Networking Break 2:35-3:25 p.m. Inbound U.S. Tax Planning ( Hidden Traps) With Inversions 3:25-4:15 p.m. FATCA Forms Are Totally Changing Again Can't Attend in Person? If you can't make it to the 33rd Annual International Tax Conference, 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. 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. See page 11 for webcast pricing.

4 Thursday Jan. 8 7:30-8:45 a.m. Registration Continental Breakfast 8:45-9 a.m. Introduction Opening Remarks Lawrence J. Chastang, CPA FICPA/Florida Bar Conference Co-Chair Managing Partner of International Services CliftonLarsonAllen LLP Orlo Shawn P. Wolf, Esq. FICPA/Florida Bar Conference Co-Chair Shareholder Packman, Neuwahl & Rosenberg Coral Gables & Boca Raton 9-9:50 a.m. Current Developments in International Taxation Outbound Update (1 TB) Larry R. Kemm, Esq. Harrison Kemm P.A. Tampa This session will review current U.S. developments in outbound international taxation will provide a comprehensive overview of all key statutory, regulatory, administrative, judicial related authorities that occurred during the past 12 months. 9:50-10:40 a.m. How to Escape Houdini s FIRPTA Straight Jacket Before After the Show! (1 TB) Robert F. Hudson, Jr. Partner Baker & McKenzie LLP Miami Robert H. Moore Partner Baker & McKenzie LLP Miami This session will focus on techniques for reorganizing out of ill-advised structures that normally would lead taxpayers to higher than necessary FIRPTA income withholding taxes ( unnecessary U.S. estate tax exposures) plus planning approaches that establish more tax efficient structures from inception. 10:40-11 a.m. Networking Break 4 International Tax Conference

5 11-11:50 a.m. FATCA, the OECD s Global FATCA, the Fiduciary Industry: Current Challenges Practical Next Steps (1 TB) Alfredo R. Tamayo, Esq. Packman, Neuwahl & Rosenberg Coral Gables Peter A. Cotorceanu, Esq. Partner Anaford AG Zurich, Switzerl This presentation will focus on how FATCA is actually being implemented by the fiduciary industry the challenges that lie ahead. It will address questions such as which FATCA rules apply to a given entity how FATCA s open questions are being answered in practice. It also will look ahead to FATCA s reporting obligations, which go live in 2015, key differences between FATCA the OECD s Common Reporting Stard (so-called global FATCA ). 11:50 a.m.-1:20 p.m. Lunch Presentation Puerto Rico as an Investment Destination: Current Tax Economic Incentives (1 TB) Rogelio J. Carrasquillo, Esq. Partner Akerman LLP New York Sherwin P. Simmons II, Esq. Partner Akerman LLP Tampa Puerto Rico Government Official Discuss the various tax economic incentives available in Puerto Rico. This includes Act 20 for Export Services, which provides tax incentives for companies that establish exp eligible export services businesses in Puerto Rico Act 22 for Individual Investors, which provides certain exemptions from local income taxes on particular gains realized or accrued after an individual becomes a resident of Puerto Rico. Our panelists will focus on providing participants an understing of these incentives Puerto Rico s legal tax framework. 1:20-2:10 p.m. Selected Effectively Connected Income Issues (1 TB) Seth J. Entin, Esq. Shareholder Greenberg Traurig, P.A. Miami The issue of whether a foreign individual or entity has income that is effectively connected with a trade or business in the United States is of great importance. This area, however, is filled with pitfalls uncertainties. This presentation will tackle interesting difficult effectively-connected income (ECI) scenarios. It also will touch on some of the state tax ramifications. 5

6 Thursday continued 2:10-3 p.m. Don t Leave Home without It (Tax Advice) (1 TB) Jonathan H. (Jason) Warner Law Offices of Jonathan H. (Jason) Warner, P.A. Miami A review of pitfalls planning opportunities for non-resident aliens becoming U.S. tax residents resident aliens leaving the United States. 3-3:20 p.m. Networking Break 3:20-4:10 p.m. Ethical Issues in International Estate Planning for U.S. Lawyers (1 TB) Steven L. Cantor, Esq. Managing Partner Cantor & Webb P.A. Miami Of the myriad ethical issues U.S. lawyers encounter on a day-to-day basis, those encountered by the international estate planning lawyer are particularly unique. In this session, we will discuss some of the important ethical issues for international estate planning lawyers, such as the unauthorized practice of law, aiding abetting fraudulent or criminal activities, representation of, interaction with, foreign clients. 4:10-5 p.m. Residence Domicile Off the Beaten Path (1 TB) Leslie Share, Esq. Shareholder Packman, Neuwahl & Rosenberg P.A. Coral Gables Todd Rosenberg, Esq. Shareholder Packman, Neuwahl & Rosenberg P.A. Coral Gables In this presentation we will review consider certain often overlooked issues that arise in CPA attorney practices in connection with foreign individuals who may become (or unknowingly have already become) U.S. income tax residents or U.S. estate gift tax domiciliaries. Join us for a discussion of real-life client situations a comprehensive analysis of their unique facts circumstances. We will focus upon how to approach document these client situations from both a technical practical stpoint. 6 International Tax Conference

7 Friday Jan :30 a.m. Continental Breakfast 8:30-9:20 a.m. Current Developments in International Taxation Inbound Update (1 TB) William M. Sharp, Sr., Esq. Sharp Partners P.A. Tampa, FL; San Francisco, CA; Zurich, Switzerl; Washington, D.C. This session provides an overview of all key statutory, regulatory, administrative, judicial related authorities changes that have occurred during the past 12 months, including a segment dealing with relevant portions of foreign law developments. Discussion will include an update of the ongoing IRS/DOJ s efforts in combating global tax noncompliance bank secrecy. 9:20-10:10 a.m. Representing the Mexican Client Investing in the U.S. Advising the U.S. Client Investing in Mexico (1 TB) Abel Mejía Cosenza, Esq. Partner Sanchez Devanny Eseverri S.C. Mexico Manuel E. Tron Partner Manuel Tron SC Mexico This presentation will review the tax related issues relevant to tax efficient structuring of Mexican inbound outbound investments. 10:10-10:30 a.m. Networking Break 10:30 a.m.-12:10 p.m. Panel on Miscellaneous Civil Criminal Procedural Issues (2 TB) Robert E. Panoff, Esq. Panel Moderator Tax Litigator Miami Select IRS Law Enforcement Experts This panel continues its tradition of providing up-to-the-minute information regarding civil criminal international tax procedural issues affecting everyday 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. 7

8 Friday continued 12:10-1:30 p.m. Lunch Presentation Update from Washington, D.C. with a Focus on BEPS & Beyond (1 TB) Robert B. Stack Deputy Assistant Secretary International Tax Affairs Enjoy lunch an update highlighting the BEPS initiative in the coming years. 1:30-2:20 p.m. Using a DISC corporation to Reduce U.S. Income Tax on U.S. Exports (1 TB) Neal J. Block Senior Counsel Baker & McKenzie LLP Chicago, IL This presentation will first summarize the DISC tax saving opportunities requirements as set forth in sections of the Internal Revenue Code accompanying regulations. Discussion includes various ownership structures which may maximize the U.S. tax savings from using a DISC. 2:20-2:35 p.m. Networking Break 2:35-3:25 p.m. Inbound U.S. Tax Planning ( Hidden Traps) With Inversions (1 TB) Jeffrey Rubinger, Esq. Partner Bilzin Sumberg Miami Summer A. LePree Esq. Partner Bilzin Sumberg Miami Briefly discuss Section 7874 the legislative intent behind the enactment of the statute. This session will focus on U.S. tax planning opportunities, such as avoidance of FIRPTA U.S. withholding tax on payments of FDAP income; the potential hidden traps, such as treaty override estate tax situs issues, arising in the inbound context when foreign taxpayers engage in so-called inversion transactions. 3:25-4:15 p.m. FATCA Forms Are Totally Changing Again (1 TB) Renea M. Glendinning, CPA Shareholder Kerkering, Barberio & Co. Sarasota Arthur J. Dichter, Esq. Partner Cantor & Webb P.A. Miami This presentation will provide an update on the changes in existing forms the forms that have been newly created in compliance with FATCA. 8 International Tax Conference

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10 Conference info International Tax Conference Planning Committee James Attkisson John Brantley Christin Bucci Mirtha Carballo Kevin Carmichael Rall Cathell Arthur Dichter Lawrence Chastang, Co-Chair Harri Eloranta Manuel Ferro Renea Glendinning Richard Jacobson Lewis Kevelson Denis Kleinfeld Clarece Nash Shawn Wolf, Co-Chair Sebastian Nye-Schmitz Laura Prevratil Brenda Pryor Michael Rosenberg James Spencer Alfredo Tamayo Conference Site Accommodations JW Marriott Miami 1109 Brickell Avenue Miami, Florida (305) FICPA Room Rate: $289 single/double Hotel Cutoff Deadline: Thursday, December 17, 2014 Reservations made after the cutoff date will be subject to availability current room rate. Please call the JW Marriott Miami 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. CPE Policies You May Need to Know CPE policies may be found on our website at or on the registration confirmation sent upon completion of registration. Save Money Take advantage of the Early Bird Price by registering more than ten days before the course date receive $55 off the Regular Price registration fee. Conference EZMaterials 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! 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. Can't Attend in Person? If you can't attend the 33rd 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. 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. FICPA webcasting has gone global! There will be a satellite location in both London Zurich for practitioners to attend this conference via webcast network with other practitioners. Call Committee Chair Larry Chastang at (407) for more information. 10 International Tax Conference

11 Registration Name FICPA Member No. Firm Address City/State/ZIP Telephone ( ) m Check here if registration reflects an address change. Pricing Four ways to register for FICPA CPE Programs 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 ITC Conference (ITC) m In accordance with ADA requirements, if you are disabled require special services, please check here. Someone from our office will contact you. Price Early Bird Price* $625 Regular Price (as of 12/30/2014)** $680 Price Early Bird Price Both Days $725 Regular Price Both Days (as of 12/30/2014)** $780 To register for the webcast, go to tfb.inreachce.com. Click on Hello Guest to set up an account. Search for International Tax Conference. 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. Subtotal $ Total $ *Non-member fee does not apply. Save Money! Take advantage of the Early Bird Price Register more than 10 days before the course date receive $55 off of your registration. **Please note the earlier date. Don t wait until 2015 to register!! Seats fill up fast. 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 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 Draw from Worldly Inspiration (800) (850) P.O. Box 5437 Tallahassee, Florida January 8-9, 2015 Miami