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42nd Annual International Tax Conference

January 18 @ 8:50 am - January 19 @ 4:30 pm

$795 – $845
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The 42nd Annual International Tax Conference is a two-day program that provides substantive content for certified public accountants and licensed attorneys with a specialization in tax. With changes and developments happening in international tax every day, there’s only one conference in Florida that you can trust to provide the knowledge needed for your multinational organization or clients. The FICPA and Florida Bar Tax Section’s International Tax Conference is tailored specifically for international tax professionals to assist them in the various challenges they will face in this dynamic field. In 2024, the ITC was offered in-person in Miami and via live webcast with 90-day, on-demand access.

  • 42nd Annual International Tax Conference—January 18–19, 2024
  • Course number: 8109
  • Course classification: Advanced
  • Credit: 
    • CLER Program (max credit: 16.0 hours): General: 16.0 hours, Ethics: 1.0 hours
    • Certification Program (max credit: 16.0 hours):  Business Litigation: 1.0 hours, Civil Trial: 1.0 hours, Criminal Appellate: 1.0 hours, Criminal Trial: 1.0 hours, International Law: 16.0 hours, International Litigation and Arbitration: 16.0 hours, Real Estate: 1.0 hours, Tax Law: 16.0 hours, Wills, Trusts & Estates: 2.0 hours


SCHEDULE

Day 1, January 18

7:30 – 8:45 am         Registration & Breakfast

8:50am – 9:00am    Introductions. Jeff Rubinger, Winston & Strawn, and Lawrence J. Chastang, CPA, Chastang & Partners, Program Co-Chairs

9:00 am – 9:50 am    Outbound – Current Developments. Lewis Greenwald, Sullivan & Worchester. A U.S. international outbound update including new cases, Pillar II, regulatory update; the upcoming sunsetting/numeric changes to the TCJA provisions.

9:50 am-10:40 am  Moore v. United States and Other Challenges to Regulatory Authority in the Cross-Border SettingSeth J. Entin, Greenberg Traurig. This presentation will address the arguments in and the broader implications of the Moore case that is pending before the United States Supreme Court, as well as other current challenges to international tax statutes and regulations, such as those relating to downward attribution, deemed paid foreign tax credits, and FBAR (and other) filing requirements for dual-resident taxpayers.

10:40 am-11:00 am   Break

11:00 – 11:50 am    Planning for U.S. Closely-Held Acquisitions and Divestitures of Foreign Businesses. Steve Hadjilogiou & Michael Bruno, McDermott Will & Emery. The panelists will discuss the latest planning trends in the taxation of U.S. acquisitions and divestitures of foreign businesses. The discussion will cover Pillar II tax-related issues, basis step-up planning, potential recast issues, and items to consider in the acquisition to make post-acquisition business earnings as tax-efficient as possible.

11:50 am – 12:30 pm    Lunch

12:30 – 1:20 pm   What’s Going on at the IRS After the Inflation Reduction Act? Fred Murray, Special Counsel IRS. Capitalizing on Inflation Reduction Act funding and following a top-to-bottom review of enforcement efforts, the Internal Revenue Service is shifting more attention onto high-income earners, partnerships, large corporations, and promoters abusing the nation’s tax laws.  The effort, building off work following last August’s IRA funding, will center on adding more attention on wealthy taxpayers and partnerships and other high earners that have seen sharp drops in audit rates for these taxpayer segments during the past decade, including some of  the large partnerships in the U.S. that represent a cross section of industries including hedge funds, real estate investment partnerships, publicly traded partnerships, large law firms and other industries.  The IRS has launched numerous compliance efforts to address serious issues being seen. Some of these, like abusive micro-captive insurance arrangements and syndicated conservation easement abuses, have already received extensive public attention. But much more work continues behind the scenes on other issues.  And among some of the additional priority areas that comprise the new focus include expanded work on digital assets, and more scrutiny on FBAR violations. IRS analysis of multi-year filing patterns has identified hundreds of possible FBAR non-filers with account balances that average over $1.4 million. The IRS plans to audit the most egregious potential non-filer FBAR cases in Fiscal Year 2024.

1:20 pm – 2:10 pm    Proper US classification of certain foreign entities and structures. Leslie Share & Alfredo Tamayo,  Packman, Neuwahl & Rosenberg. This presentation will review various current U.S. tax and reporting issues regarding certain commonly encountered offshore entities and estate planning techniques that may be “foreign” to many U.S. practitioners. We will examine entities such as non-U.S. private foundations and fideicomisos, along with the usufruct and other civil law planning techniques that have been used for many years to preserve and maintain the wealth of high-net-worth individuals.  As part of this analysis, we will discuss the potential U.S. tax treatment of U.S. persons who have created or may derive benefits from such planning structures and techniques, as well as how to (hopefully) satisfy the often-uncertain associated U.S. compliance requirements.

2:10 pm – 2:30 pm  Break

2:30 pm – 3:20 pm Recent Tax and Regulatory Updates from Latin America. Jennifer Wioncek and Paul D’Alessandro, Jr., Bilzin Sumberg.  This panel discussion will provide an overview of various tax and regulatory updates coming out of Latin America. The presentation will focus on Brazil and Chile, surveying the latest developments and highlighting relevant US planning considerations. Topics covered will include the anticipated CFC rules and latest trust developments coming out of Brazil, as well as analysis of the US/Chile Income Tax Treaty.

3:20 pm – 4:10 pm  Pillar 2 Considerations for Closely-Held Businesses. Robert H. Moore, Baker & McKenzie. This session will explore the impact of Pillar 2 on closely held businesses, including how to determine revenue thresholds across closely held groups, unexpected traps and practical advice for companies without large in-house tax departments, and potential ways to mitigate the impact of Pillar 2.

4:10 pm – 5:00 pm    Partnership Reporting – Focus on K2-K3. Mishkin Santa, Nicole LaCava, and Maria Zhandalinova, The Wolf Group. This presentation will provide practical guidance, tips, and strategies for reporting Schedules K-2 and K-3 in the context of preparing domestic and foreign partnership returns (Forms 1065 and 8865).  The new schedules were designed by the IRS to provide more clarity to the individual partners and their individual filing compliance requirements.  However, if the Schedules K-2 and K-3 are not prepared correctly or include the proper reporting at the entity level then the schedules may create more confusion and complexity than clarity.  This presentation will help tax professional understand how to properly complete the Schedules K-2 and K-3 at the entity level, how to input the Schedule K-3 at the individual level, how to identify an incomplete or inaccurate Schedule K-3 that has been provided to an individual partner, and how to deal with ancillary reporting that may be required at the entity and/or individual level.

Day 2, January 19

8:30am – 9:20am    Inbound Update. Bill Sharp – Holland & Knight. The presentation will explore cutting-edge “inbound” tax planning developments, including recent U.S. statutory, regulatory, administrative, and judicial developments. This session also will address significant U.S. Tax Court and federal court decisions addressing inbound and compliance issues as well as important foreign case developments, recent IRS and U.S. Department of Justice initiatives, and recent Foreign Bank Account Report (FBAR) litigation developments.

9:20 – 10:10 am  Cross Border Tax Planning with Section 1202Jeff Rubinger & Rachel Ingwer – Winston & Strawn. The panel will focus on the basics of the Section 1202 qualified small business stock exclusion and then delve into the inbound and outbound tax planning opportunities that may be available with Section 1202. In particular, the panel will include a discussion of how Section 1202 can be utilized when structuring outbound investments in CFCs and the tax-efficient repatriation of profits earned abroad, as well as inbound investments where Section 1202 trumps the FIRPTA provisions.

10:10 am -10:30 am Break

10:30 – 11:20 am     Taxation of Mobile Executives. Maria Otero & Cynthia Brittain, Karlin & Peebles.

11:20 am – 12:10 pm    Criminal Tax PanelJeff Neiman, Marcus Neiman Rashbaum & Pineiro LLP, and Kevin Sweeney, Chamberlain Hrdlicka. This panel will delve into how investigators and prosecutors gather evidence in a criminal tax investigation. Specifically, we will discuss government efforts to gather evidence from overseas through the use of treaties, how investigators get witnesses to talk, the use of whistleblowers, and what makes a strong/weak criminal tax matter.

12:10 -12:50 pm   Lunch

12:50 – 1:40 pm International Civil Tax Disputes. Hale Sheppard, Chamberlain Hrdlicka. New Commissioner, new budget, and new priorities.  The IRS is increasing scrutiny in the international area, focusing on unreported foreign assets and activities, repatriation taxes, foreign investors with U.S. property, FATCA violations, tax withholding on foreign payments, receipt of foreign gifts, unfiled international information returns, and much more.  This presentation explains critical international tax cases, administrative rulings, and other developments during the past year.

1:40 pm – 2:30 pm    2024 Update on Inbound Structures for Foreign Investors. Logan Gans & Bill Sherman, Holland & Knight, LLP. With high interest rates and elevated asset values, 2024 is expected to be a very challenging US real estate investment climate.  Nonetheless, US real estate is still a desired asset class for many foreign investors and international family offices.   This session provides a 2024 update on inbound US real estate structuring, including key planning considerations for a high-interest environment.

2:30 pm – 2:50 pm Break

2:50 pm – 3:40 pm   IRS Penalty Panel – How to Protect you and your Firm from Malpractice. Dan Price, Daniel N. Price, PLLC; Lawrence J Chastang CPA, Chastang & Partners; Arthur “Kip” Dellinger, CPA, Kallman + Logan & Company. The IRS continues to systemically assess maximum penalties for late and imperfect international information returns (e.g. Form 3520,3520A, 5471, 5472 and 8938) without considering the facts. This session will provide the practitioner with “best practices” to avoid penalty assessments and practical strategies to convince the IRS to abate and refund penalties.  We will also cover strategies to protect you and your firm from malpractice claims resulting from IRS penalty assessments and unhappy clients.

3:40 pm – 4:30 pm   Tips to Take Home. David Cumberland, CPA, Kerking Barberio. 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 across both resident and nonresident considerations and include nonresident income tax reporting as well as disclosure forms (Forms 1040NR and 5472), along with U.S. foreign disclosure forms (Forms 3520, 5471, 8865, FINCEN 114).

Details

Start:
January 18 @ 8:50 am
End:
January 19 @ 4:30 pm
Cost:
$795 – $845
Event Categories:
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Website:
https://member.floridabar.org/s/lt-event?id=a1RDm000000psBzMAI

Venue

JW Marriott Miami
1109 Brickell Avenue
Miami, FL 33131 United States
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Phone
305-329-3500
View Venue Website

©2024 Tax Law Section of The Florida Bar. All Rights Reserved.

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