Collaborating in International Tax. CPE/CLE Credit

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2 Collaborating in International Tax Today s economy brings more changes to the already rapidly evolving field of international tax. The 29th Annual International Tax Conference offers professionals a chance to collaborate hear what the experts are saying about the latest tax developments what they expect in the future. Join the FICPA The Florida Bar for an exceptional opportunity for CPAs, attorneys, businesses government practitioners to come together brainstorm about issues affecting the international tax industry. Join specialists as they cover current developments in international taxation, the attorney-cpa international client relationship, the always-popular panel on civil criminal procedural issues. CPE/CLE Credit This conference will qualify for 16 Technical Business (TB) hours, subject to approval by the Florida Department of Business & Professional Regulation. CLE credit will be awarded by The Florida Bar. The number of CLE credit hours is to be determined. 2 29th Annual International Tax Conference

3 Conference at-a-glance Thursday Jan. 13 8:00-8:45 a.m. Registration Continental Breakfast 8:45-9:00 a.m. Introduction Opening Remarks 9:00-9:50 a.m. International Tax Developments Outbound Update 9:50-10:40 a.m. Structuring the Acquisition of a Foreign Company 11:00-11:50 a.m. The U.S. Tax Compliance Nightmare of the International Executive 11:50 a.m.-1:20 p.m. Lunch Presentation: Swiss Corporate Tax Strategies for Global Players 1:20-2:10 p.m. Everything You Wanted to Know about Expatriation but Were Afraid to Ask 2:10-3:00 p.m. The PFIC Storm: A Preparation Survival Guide 3:20-4:10 p.m. Recent Developments Planning Opportunities with U.S. Income Tax Treaties 4:10-5:00 p.m. Determining Gain or Loss on Remittances from Foreign Operations with Different Functional Currencies 5:00-6:30 p.m. Cocktail Reception Friday Jan. 14 8:00-8:30 a.m. Continental Breakfast 8:30-9:20 a.m. International Tax Developments Inbound Update 9:20-10:10 a.m. Something Old, Something New, How to Keep Your Foreign Clients from Being Blue 10:25-11:15 a.m. The Attorney/CPA/International Client Relationship Joint Representation in Turbulent Times 11:15 a.m.-12:05 p.m. Panel on Miscellaneous Civil Criminal Procedural Issues 12:05-1:30 p.m. Lunch Presentation: Washington Update View from Inside the Internal Revenue Service 1:30-2:20 p.m. Canadians Investing in Florida Real Estate A Depressed Market a Strong Loonie A Perfect Combination or the Perfect Storm? 2:35-3:25 p.m. Complexities of Foreign Nongrantor Trusts with U.S. Beneficiaries 3:25-4:15 p.m. Don t Leave Home Without It (Proper Tax Advice) Follow the FICPA use #ITC11 to tweet about this conference. 3

4 Thursday Jan. 13 8:00-8:45 a.m. Registration Continental Breakfast 8:45-9:00 a.m. Introduction Opening Remarks Lawrence J. Chastang, CPA, FICPA International Tax Conference Chair Jonathan H. (Jason) Warner, Esq. Florida Bar International Tax Conference Chair 9:00-9:50 a.m. International Tax Developments Outbound Update (1 TB) William M. Sharp, Esq. Partner / Sharp Kemm P.A. / Tampa/Zurich This course offers an overview of the tax cases, rulings legislation from the past year applicable to outbound tax issues. 9:50-10:40 a.m. Structuring the Acquisition of a Foreign Company (1 TB) Seth J. Entin, Esq. Shareholder / Greenberg Traurig, P.A. / Miami The acquisition by U.S. persons of a foreign target company is often the best time to maximize the future tax efficiencies of the foreign corporate structure. This can only be done with proper tax planning in advance of the acquisition. This presentation discusses some of the planning strategies that should be considered in structuring the acquisition. 11:00-11:50 a.m. The U.S. Tax Compliance Nightmare of the International Executive (1 TB) Dale W. Mason, CPA Director of International Tax / The Wolf Group P.C. / Washington, D.C. This presentation covers the myriad of challenges facing the tax professional representing international executives when entering leaving the United States. 11:50 a.m.-1:20 p.m. Lunch Presentation: Swiss Corporate Tax Strategies for Global Players (1 TB) Michel Hirsig Deputy Manager of the Economic Promotions Office for the Canton (State) of Geneva, Department of Economy Health Greater Geneva Berne Area Working Committee Delegate This presentation reviews from the Swiss perspective tax planning opportunities for U.S. multinationals using Swiss companies. The presentation also touches on tax planning involving intellectual property, banking reform, the Swiss forfait system. 1:20-2:10 p.m. Everything You Wanted to Know about Expatriation but Were Afraid to Ask (1 TB) Michael G. Pfeifer, Esq. Member / Caplin & Drysdale / Washington, D.C. Jennifer J. Wioncek, Esq. Associate / Baker & McKenzie LLP / Miami This session provides an in-depth analysis of the current law the most recent guidance issued by the IRS. Practical solutions planning for those who want to expatriate may be subject to the mark-to-market tax regime. 4 29th Annual International Tax Conference

5 2:10-3:00 p.m. The PFIC Storm: A Preparation Survival Guide (1 TB) Shawn P. Wolf, Esq. Shareholder / Packman Neuwahl & Rosenberg P.A. / Coral Gables Daniel Bensimon, Esq. Shareholder / Bensimon Law, P.A. / West Palm Beach This presentation provides an overview of the Passive Foreign Investment Company rules, including the qualified electing fund mark to market elections. It also reviews form 8621 in light of the relevant rules, considers any relevant guidance on PFIC issues as part of the voluntary disclosure initiative, raise several complex issues present practical guidance as to the resolution of these issues. 3:20-4:10 p.m. Recent Developments Planning Opportunities with U.S. Income Tax Treaties (1 TB) Jeffrey Rubinger, Esq. Partner / Holl & Knight / Ft. Lauderdale This presentation provides an update on the most recent developments involving U.S. income tax treaties, as well as discuss planning opportunities available to U.S. inbound investors that may result in more tax efficient structures. 4:10-5:00 p.m. Determining Gain or Loss on Remittances from Foreign Operations with Different Functional Currencies (1 TB) Jason R. Connery, CPA Principal / KPMG LLP / Washington, D.C. After some 24 years, the Internal Revenue Service has yet to provide taxpayers with final rules addressing the computation of gain or loss realized upon receipt of a remittance from a qualified business with a different functional currency. However, every IRS examination now requires a 987 computation to finalize the examination process. This session will help you get through that process. 5:00-6:00 p.m. Cocktail Reception Hosted by Trident Trust Leading Provider of Corporate, Trust Fund Services to Lawyers Accountants Worldwide 5

6 Friday Jan. 14 8:00-8:30 a.m. Continental Breakfast 8:30-9:20 a.m. International Tax Developments Inbound Update (1 TB) Robert A. Chaves, Esq. Shareholder / Gutter Chaves Josepher Rubin Forman Fleisher P.A. / Boca Raton Charles D. Rubin, Esq. Shareholder / Gutter Chaves Josepher Rubin Forman Fleisher P.A. / Boca Raton This session gives an overview of tax cases, rulings, other tax items from the past year applicable to inbound tax issues, including a review of the provisions of the HIRE Act that may affect inbound foreign investment. 9:20-10:10 a.m. Something Old, Something New, How to Keep Your Foreign Clients from Being Blue (New Ways to Minimize U.S. Tax on Foreign Corporate Clients Investments in U.S. Real Estate Businesses) (1 TB) Robert F. Hudson, Jr., Esq. Partner / Baker & McKenzie LLP / Miami This subject will address both traditional inbound structuring approaches (including the two-tier partnership for nonresident aliens) creative new structures that take advantage of Portfolio Debt financing the use of trusts in a way that allows even foreign corporate investors to utilize the preferred long-term capital gains rates that are normally only available to individual trusts, producing much lower effective tax rates than is the norm. 10:25-11:15 a.m. The Attorney/CPA/International Client Relationship--Joint Representation in Turbulent Times (1 TB) Leslie A. Share, Esq. Shareholder / Packman, Neuwahl & Rosenberg P.A. / Coral Gables Lawrence J. Chastang, CPA Managing Principal of International Services / LarsonAllen LLP / Orlo In the current world of voluntary compliance initiatives, FIN 48, Uncertain Tax Positions, privilege preparer issues, numerous other important but unsettled considerations, how do you delineate the work responsibility of the accountant that of the attorney in hling international tax matters? Where do you draw the line in client representation when should a white collar criminal attorney be consulted? This session focuses on all of these issues more facing international tax professionals in today s everchanging complex world, using commonly-encountered client fact situations. 6 29th Annual International Tax Conference

7 11:15 a.m.-12:05 p.m. Panel on Miscellaneous Civil Criminal Procedural Issues (1 TB) Robert E. Panoff, Esq. (Panel Moderator) Chair, Private Sector Tax Litigator / Miami Select IRS Law Enforcement Speakers This panel continues its tradition of providing up-to-the minute information regarding civil criminal international tax procedural issues affecting ordinary tax practitioners their clients. Greater emphasis will be on taxpayers within the jurisdiction of the Small Business Self Employed operating division, but the panel also will discuss issues affecting taxpayers within the (newly renamed) Large Business International operating division of the IRS. 12:05-1:30 p.m. Lunch Presentation: Washington Update View from Inside the Internal Revenue Service (1 TB) Speaker TBD 1:30-2:20 p.m. Canadians Investing in Florida Real Estate A Depressed Market a Strong Loonie A Perfect Combination or the Perfect Storm? (1 TB) Jack Bernstein, Esq. Senior Tax Partner / Aird & Berlis, LLP / Toronto, Canada This course addresses Canadian U.S. tax issues in structuring investments by Canadians in Florida real estate. 2:35-3:25 p.m. Complexities of Foreign Nongrantor Trusts with U.S. Beneficiaries (1 TB) Hal J. Webb, Esq. Partner / Cantor & Webb P.A. / Miami Stewart L. Kasner, Esq. Partner / Baker & McKenzie LLP / Miami Discussion of U.S. federal income tax matters associated with complex foreign nongrantor trusts with U.S. beneficiaries, as well as strategies to address complications unfavorable income tax consequences caused by income accumulations, underlying controlled foreign corporations underlying passive foreign investment companies. This course covers strategies through practical case studies. 3:25-4:15 pm Don t Leave Home Without It (Proper Tax Advice) (1 TB) Jonathan H. (Jason) Warner, Esq. Shareholder / Law Offices of Jonathan H. (Jason) Warner, P.A. / Miami Spruce Pine, N.C. Daniel J. Glassman, Esq. Associate / Gunster / West Palm Beach This session reviews the pitfalls planning opportunities for nonresident aliens becoming U.S. tax residents. It also covers tax planning for resident aliens leaving the United States. 7

8 Thank you to our sponsors: 8 29th Annual International Tax Conference

9 Conference info International Taxation committee Lawrence J. Chastang, Co-Chair Jonathan H. (Jason) Warner, Co-Chair James R. Attkison John L. Brantley Jason P. Catlin Arthur J. Dichter Carol A. Doerr Manuel Ferro, Jr. Renea M. Glendinning Richard A. Jacobson Antonio D. Jacomino Lewis B. Kevelson Michael Rosenberg Jana Sayler Joseph R. Schortz James W. Spencer Renu D. Vardhan Conference site JW Marriott Miami 1109 Brickell Ave. Miami, FL (305) Accommodations FICPA Room Rate: $279 single/double Hotel Cutoff Deadline: Wednesday, Dec. 29, 2010 (Reservations made after the cutoff date will be subject to availability current room rate.) Please call the JW Marriott Miami Reservations at (305) or (800) to reserve your room. Be sure to mention the FICPA/Florida Bar International Tax Conference to receive the special group rate. Resort Fees There may be a fee for some guest services. Not all features services are available in all rooms. Contact hotel for details Group Discounts available Register 5 or more people from the same organization receive special group discounts! Restrictions may apply. For more information, visit Save money Take advantage of the Early Bird Price by registering more than 10 days before the course date receive $55 off the Regular Price registration fee. CPE Policies you may need to know A list of CPE policies may be found on our website at or on the registration confirmation correspondence sent upon complete registration. Electronic materials Conference reference materials are distributed to registrants electronically in advance of the program. There will not be printed material available on site. This fully searchable PDF includes speaker presentations is intended for electronic use only. 9

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11 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) (in Florida), 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 Name FICPA Member No. Firm Address City/State/ZIP Telephone ( ) Check here if registration reflects an address change. 4ways to register for FICPA CPE Programs 2 Pricing International Tax Conference Member Price* Early Bird Price* $465 Regular Price (as of 1/04/11) $520 Total $ The FICPA is not responsible for checks or registrations delayed or lost in the mail. * Take advantage of the Early Bird Price by registering more than 10 days before the course date receive $55 off the Regular Price. 3Method of Payment Check enclosed in the amount of $. Please charge my company-issued credit card: Please charge my personal credit card: VISA MasterCard American Express Discover Card Validation Code: (3 or 4 digit code located on the credit card) Cardholder Name Signature Exp. Date 11

12 (800) (in Florida) (850) P.O. Box 5437 Tallahassee, Florida th Annual International Tax Conference Jan , 2011 Miami