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39th Annual International Tax Conference

January 14, 2021

Originally presented on January 14, 2021. This program is no longer available for CLE credit.

The International Tax Conference is an advanced course for attorneys and advisors to multinational organization and clients.

Current Developments in International Taxation- Outbound Update
This session will review significant statutory, regulatory, administrative, and judicial developments in U.S. outbound international taxation that occurred during 2020.
Larry Kemm, Esq., Partner, Holland & Knight LLP

Planning for Foreign Investment in Distressed Debt 
One of the consequences of the unfortunate COVID 19 pandemic is increased interest by foreign persons in acquiring distressed debt of U.S. borrowers. This presentation will discuss the various tax rules that are applicable as well as planning opportunities to consider and pitfalls to avoid.
Seth J. Entin, Esq., Partner, Holland & Knight LLP

Loss Planning in a Pandemic — Making the Most of Tough Year
This presentation will explore loss planning transactions in a post-TCJA and pandemic environment. Particular focus will be on NOL utilization, planning for CFCs with losses, and impact of GILTI.
Robert H Moore, Partner, Baker McKenzie, LLP
Michael D. Melrose, Partner, Baker McKenzie, LLP

International Initiatives for 2021 and Beyond – What to Expect from the IRS
Charles Rettig, Esq., Commissioner, Internal Revenue Service

Is it Time to Expatriate? 
This presentation will review the U.S. “exit tax” rules under Code Sections  877A and 2801, and discuss situations often faced by practitioners with clients wanting to expatriate, including related planning considerations.
Hal Webb, Esq., Partner, Bilzin Sumberg
Jen Wioncek, Esq., Partner, Bilzin Sumberg

FDII for All: Practical Strategies for U.S. and non-U.S. Businesses for a Reduced Tax Rate under the FDII Regim
A discussion of creative planning strategies to take advantage of the reduced tax rates available under the so-called FDII regime. The presentation will discuss how FDII can be used to the advantage of non-US and US businesses that export goods and services, especially into Latin America, Europe and Asia. When applicable FDII can reduce federal tax rates on income to 13.125%.
Steve Hadjiliogiou, McDermott,Will & Emory LLP

State and Local Taxation – GILTI and International 
We will discuss recent attempts by states to tax foreign income, including global intangible low-taxed income.  
Katie Quinn, Esq., Partner, McDermott, Will & Emory, LLP 
Alysse McLoughlin, Esq., McDerott, Will & Emory LLP

Practical Cross Border Estate Planning Considerations for the Global Family
Our presentation will review various U.S. tax and planning issues that U.S. practitioners regularly encounter with regard to asset and business holding structures for wealthy multinational families which include current or prospective U.S. persons. It will also analyze how certain popular offshore planning techniques (for example, usufructs, private foundations, and “shortcut title planning”) can cause difficulties for U.S. attorneys and tax preparers along with providing suggested potential solutions and reporting positions.
Leslie Share Esq., Shareholder, Packman, Neuwahl & Rosenberg, PA
Shawn Wolf Esq., Shareholder, Packman, Neuwahl & Rosenberg, PA

Current Developments in International Taxation: Inbound and Controversy Update 
The presentation will highlight and provide practitioner comments related to two general areas: first “inbound” U.S. statutory, regulatory,  administrative and judicial developments; and second, a review of the past year’s most important U.S. Tax Court & Federal Court decisions addressing inbound, controversy and compliance issues, including a review of recent IRS/DOJ initiatives and recent FBAR litigation outcomes as well as pending cases.
William M. Sharp Sr, Esq., Partner, Holland & Knight

Latest Pitfalls and Planning Considerations for GILTI and CFC Classification 
This session will cover (i) relevant aspects of 2020 final regulations released on section 951A and the section 250 deduction, (ii) tested loss considerations; (iii) proposed and final regulations relating to the repeal of section 958(b)(4); and (iv) some of the latest planning strategies and pitfalls for closely held CFCs that produce GILTI.
Michael Bruno Esq., McDermott, Will & Emory LLP 

What  Every US Tax Advisor Must Know When Representing Clients with  Operations in Europe: Impact of Mandatory Reporting Regime under DAC 6
The presentation will review the background and application of the EU DAC6 Mandatory Disclosure Regime and how US taxpayers (with European Union  connections) and advisors should navigate this regime. 
Alan Granwell, Partner, Holland & Knight 
Emma White Esq., Partner, Forsters
Monique van Hersken, Partner, Simmons & Simmons 

Holding Taxpayers(and their Advisors) Accountable: An Update on the IRS’ Continued International Enforcement Efforts
In one of their first joint presentations since starting their newly announced positions, IRS Criminal Investigation Chief Lee and National Fraud Counsel Schenck will give us an update on their enforcement efforts on both the criminal and civil fronts. In their own words, we will hear about IRS priorities, the impact of unprecedented international information sharing, and how the IRS continues to combat offshore tax evasion.  
Jeff Neiman, Esq., Partner, Marcus, Neiman, Rashbaum & Pineiro LLP
Vince Cintro, Esq., Partner, Horwitz & Cintro,PA
Carolyn Schenck, National Fraud Counsel & Assistant Division Counsel(International) SB/SE
James C. Lee, Chief, IRS Criminal Investigation 

Post 2020 Election Tax Policy Outlook
The presentation will cover changes in players and priorities on the federal tax policy landscape in light of the 2020 elections. Consideration of time sensitive legislation, developments in the OECD Pillars I and II project and design issues with respect to the international tax reforms of the Tax Cuts And Jobs Act of 2017. 
Mark Prater, Managing Director, Tax Policy Services PwC US

U.S. Treaty Policy: Where Are We Today?
This presentation will survey the current state of U.S. Treaty policy, including a discussion of recently ratified treaties, pending treaties, and the potential future direction of U.S. treaty policy.  
Robert Stack, Esq., Partner Deloitte 
Harrison Cohen, Esq., Managing Director, International Tax Practice, Deloitte Tax LLP

The Use of Hybrid Instruments in Cross-Border Tax Planning
This panel will focus on recent regulations under Sections 267A, 245A, and 1.881-3 impacting the use of cross-border hybrid instruments in both the inbound and outbound context. The panel also will discuss planning opportunities that remain available under current law, including under relevant US tax treaties.
Jeff Rubinger Esq. partner, Baker McKenzie
Summer Ayers LePree partner, Baker McKenzie

Tips to Take Home
This presentation will provide practical tips for the international tax practitioner regarding various international tax issues from a compliance perspective. The discussion will include how to avoid making common errors and preparation considerations as well as suggested best practices. The topics will range from applications for ITINs (Form W-7), withholding under FIRPTA (Forms 8288-B, 8288 and 8288-A), nonresident income tax reporting and disclosure forms (Forms 1040NR and 5472), along with U.S. tax resident disclosure forms (Forms 3520, 5471, 8865, FINCEN  114) including discussion of attribution rules for the disclosure forms, and GILTI tax considerations.
David Cumberland, CPA, Kerkering, Barberio & Co. 
Sarasota  Laura Plotner, CPA, Partner, Global Services, Chastang & Partners LLP


January 14, 2021
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