Globally. Seeing Things

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2 Seeing Things Globally Keeping up with the constant flow of international tax developments worldwide can be a real challenge. Do you have the skills knowledge to help your clients navigate through these everchanging times? Join the FICPA The Florida Bar at the 32nd Annual International Tax Conference to look beyond borders. Experience an event that will take a closer look at what we can do as CPAs to make doing business all over the world easier. Conference sessions include discussion of pertinent issues such as civil criminal procedural issues, tax planning, portfolio interest exemptions, expatriation more. 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 credit hours is to be determined. Follow the FICPA on use #ficpaitc to tweet about this conference.

3 Conference at-a-glance Thursday Jan. 23 8:00-8:45 a.m. Registration Continental Breakfast 8:45-9:00 a.m. Introduction Opening Remarks 9:00-9:50 a.m. Current Developments in International Taxation Outbound Update 9:50-10:40 a.m. U.S. Taxation of Partnerships in the International Context Something Old, Something New Something Blue? 11:00-11:50 a.m. FATCA: The Impact on the Trust Private Client Industry 11:50 a.m.-1:20 p.m. Lunch Presentation: What Every US Tax Practitioner Must Know About VAT 1:20-3:00 p.m. Optimizing the Tax Consequences of Inbound Investments into the United States from the United Kingdom, Brazil, Venezuela Colombia 3:20-4:10 p.m. Expatriation: An Update Several Years After HEART Surgery 4:10-5:00 p.m. FIRPTA Under Fire Friday Jan. 24 8:00-8:30 a.m. Continental Breakfast 8:30-9:20 a.m. Current Developments in International Taxation: Inbound Update 9:20-10:10 a.m. The Portfolio Interest Exemption: Opportunities Traps 10:30-11:20 a.m. Tax Planning with the U.S. Virgin Isls Puerto Rico Recent Developments, Tax Incentives Litigation 11:20 a.m.-12:10 p.m. Panel on Miscellaneous Civil Criminal Procedural Issues 12:10-1:30 p.m. Lunch Presentation: Update from Washington, D.C. 1:30-2:20 p.m. Tax Traps in Canada U.S. Personal Tax Planning 2:35-3:25 p.m. Foreign Pensions, Retirement Plans the U.S. Taxpayer 3:25-4:15 p.m. Rectifying International Tax Information Return Errors Seeking Penalty Abatement Practical Ethical Considerations Can't Attend in Person? If you can't make it to the 32nd Annual International Tax Conference, we'll have the entire conference available through live webcast! For more information, or to register for the webcast, please call The Florida Bar Order Entry Department at (800) , Ext

4 Thursday Jan. 23 7:30-8:45 a.m. Registration Continental Breakfast 8:45-9:00 a.m. Introduction Opening Remarks Lawrence J. Chastang, CPA FICPA/Florida Bar Conference Co-Chair Managing Partner-International Services Clifton Larson Allen, LLP Orlo Shawn P. Wolf, Esq. FICPA/Florida Bar Conference Co-Chair Shareholder Packman Neuwahl & Rosenberg Coral Gables/Boca Raton 9:00-9:50 a.m. Current Developments in International Taxation Outbound Update Larry R. Kemm, Esq. Sharp Kemm P.A. Tampa This session reviews current U.S. developments in outbound international taxation provides 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. U.S. Taxation of Partnerships in the International Context: Something Old, Something New Something Blue? Robert F. Hudson, Jr. Principal Baker & McKenzie LLP Miami Robert H. Moore Partner Baker & McKenzie LLP Miami The topic addresses interesting U.S. income, gift estate tax planning uses planning techniques of partnerships in the international cross-border situations, both for individuals multinational entities (including Section 956, subpart F, FTC, ECI, PIE, of course estate tax issues). 10:40-11:00 a.m. Networking Break 11:00-11:50 a.m. FATCA: The Impact on the Trust Private Client Industry Denise Hintzke Global FATCA Tax Leader Deloitte Tax LLP New York This session provides an update on the FATCA requirements, including the latest news on Intergovernmental Agreements reporting requirements that may be implemented by other countries with a focus on the impact on the trust private client industry. 4 International Tax Conference

5 11:50 a.m.-1:20 p.m. Lunch Presentation: What Every US Tax Practitioner Must Know About VAT John Voyez Partner Smith & Williamson LLP London, UK VAT around the world, what every Tax Practitioner should know to properly advise their clients. 1:20-3:00 p.m. Optimizing the Tax Consequences of Inbound Investments into the United States from the United Kingdom, Brazil, Venezuela Colombia Moderators: Hal J. Webb, Esq. Partner Cantor & Webb P.A. Miami James H. Barrett Partner Baker & McKenzie LLP Miami Panel: Humberto Sanches Partner Ulhôa Canto Sao Paulo, Brazil Juan Guillermo Ruiz Partner Posse Herrera Ruiz Bogota, Colombia Ronald Evans Partner Baker & McKenzie, S.C. Caracas, Venezuela Paul Hocking Chairman Frank Hirth London, United Kingdom This two-hour panel addresses the U.S. foreign tax planning opportunities that are available to investors from Brazil, the United Kingdom, Venezuela Colombia when they invest in the U.S. The panel discussion covers U.S. foreign income as well as gift estate tax planning opportunities for investments in the U.S. In addition to covering typical inbound investments, the session also addresses preimmigration planning from a U.S. a foreign law perspective in the four covered jurisdictions. Specific topics that will be addressed will include choice of entity, financing options, optimizing the effective tax rate on U.S. operating income, repatriation planning, disposition planning, foreign tax credit issues, treaties, pre-immigration planning techniques related ethical issues. 3:00-3:20 p.m. Networking Break 5

6 Thursday continued 3:30-4:10 p.m. Expatriation: An Update Several Years After HEART Surgery Shawn P. Wolf, Esq. Shareholder Packman, Neuwahl & Rosenberg Cora Gables/Boca Raton Laura U. Daly IRS Counsel (Invited) Washington, D.C. Lara A. Banjanin IRS Counsel (Invited) Washington, D.C. Experience an interactive dialogue that provides an overview discussion of the current U.S. expatriation rules of Section 877A, (b)(6), as well as Notice any guidance that has been published on Section :10-5:00 p.m. FIRPTA Under Fire Renea M. Glendinning, CLU, CPA Shareholder Kerkering, Barberio & Co. Sarasota Jonathan H. (Jason) Warner Law Offices of Jonathan H. (Jason) Warner, P.A. Miami Review current criticisms of FIRPTA reform proposals; discuss compliance problems caused by new ITIN requirements Qualified Substitute procedure; discuss impact on FIRPTA of inversion regulations how to deal with inherited bad (or lack of) planning for U.S. real estate investments by foreigners. 6 International Tax Conference

7 Friday Jan. 24 8:00-8:30 a.m. Continental Breakfast 8:30-9:20 a.m. Current Developments in International Taxation: Inbound Update William M. Sharp, Sr., Esq. Sharp Kemm P.A. Tampa, FL; San Francisco, CA Zurich, Switzerl 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 as well as an update of the ongoing IRS/DOJ s efforts in combating global tax non-compliance bank secrecy. 9:20-10:10 a.m. The Portfolio Interest Exemption: Opportunities Traps Seth J. Entin, Esq. Shareholder Greenberg Traurig, P.A. Miami The use of debt qualifying for the portfolio interest exemption is a powerful tool in inbound international tax planning. This presentation focuses on the nuances of the exemption, beneficial tax planning opportunities that are available, the various misconceptions pitfalls that exist. 10:10-10:30 a.m. Networking Break 10:30-11:20 a.m. Tax Planning with the U.S. Virgin Isls Puerto Rico Recent Developments, Tax Incentives Litigation Marjorie Roberts, Esq. Marjorie Roberts, P.C. St. Thomas, United States, Virgin Isls Joseph A. DiRuzzo, III, Esq., CPA Fuerst Ittleman David & Joseph, PL Miami This session provides an overview of the tax planning opportunities offered in the U.S. Virgin Isls Puerto Rico, including the statutory provisions (federal local), the relevant Treasury Regulations, the IRS s view of possession taxation. Join us for an in-depth discussion regarding recent litigation developments tax credits in the news. Finally, the session also discusses unique tax planning immigration opportunities offered in the territories. 7

8 Friday continued 11:20 a.m.-12:10 p.m. Panel on Miscellaneous Civil Criminal Procedural Issues Moderator: Robert E. Panoff, Esq. Tax Litigator Miami Panel: 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 everyday 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 discusses issues affecting taxpayers within the (newly renamed) Large Business International Operating Division of the IRS. 12:10-1:30 p.m. Lunch Presentation: Update from Washington, D.C. Robert B. Stack, Esq. Deputy Assistant Secretary International Tax Affairs - U.S. Department of the Treasury Washington, D.C. 1:30-2:20 p.m. Tax Traps in Canada U.S. Personal Tax Planning Jack Bernstein, Esq. Senior Tax Partner Aird & Berlis, LLP Toronto, Ontario Canada Learn the risks of LLCs, estate freezes gone wrong, gift tax traps some common mistakes made in the cross-border real estate. 2:20-2:35 p.m. Networking Break 2:35-3:25 p.m. Foreign Pensions, Retirement Plans the U.S. Taxpayer Lawrence J. Chastang, CPA Clifton Larson Allen LLP Orlo Steve Yeager, CPA Clifton Larson Allen LLP Orlo Prior to the issuance of Form 8938 Statement of Specified Foreign Financial Assets reporting issues associated with foreign pensions/retirement plans were often overlooked, ignored or omitted. Join us to address the proper U.S. tax reporting of such accounts in an environment severely lacking in regulatory or legal authority. 8 International Tax Conference

9 3:25-4:15 p.m. Rectifying International Tax Information Return Errors Seeking Penalty Abatement Practical Ethical Considerations Arthur J. Dichter, Esq. Partner Cantor & Webb P.A. Miami Leslie Share, Esq. Shareholder Packman, Neuwahl & Rosenberg P.A. Coral Gables In this presentation, you ll review consider the respective mutual roles of CPAs attorneys in connection with representing clients in matters involving untimely filed or erroneously prepared international tax information returns. The Internal Revenue Service s enhanced examination of foreign-related tax filings, the increasing imposition of all potentially applicable penalties the perceived unwillingness to abate them has put enormous pressure upon tax practitioners to solve such post-compliance issues. We will focus upon how such matters should be approached hled from both a technical practical stpoint, while taking into account the pertinent ethical rules guidelines. 9

10 Conference info International Tax Conference Planning Committee James Attkisson John L. Brantley Mirtha T. Carballo Arthur J. Dichter Manuel J. Ferro Renea Glendinning Lawrence J. Chastang, Co-Chair Richard A. Jacobson Antonio D. Jacomino Lewis B. Kevelson Denis Kleinfeld Vicki H. Meyer Clarece Y. Nash Sebastian Nye-Schmitz Conference Site Accommodations JW Marriott Miami 1109 Brickell Avenue Miami, Florida (305) Shawn P. Wolf, Co-Chair Saulo Perez Manuel E. Pravia Laura Prevratil Michael Rosenberg James W. Spencer Alfredo R. Tamayo FICPA Room Rate: $289 single/double, plus applicable taxes Hotel Cutoff Deadline: Thursday, Jan. 2, 2014 Reservations made after the cutoff date will be subject to availability the hotel s room rate. For reservations, please contact the JW Marriott Miami directly at (800) or (800) 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. 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. Group Discounts Available Register five 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 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! Coursebook is also available for purchase. Cost is $60 plus tax. To purchase hardcopy, contact The Florida Bar Order Entry Department at (800) , Ext International Tax Conference

11 Registration ITC 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 Name FICPA Member No. Firm Address City/State/ZIP Telephone ( ) Check here if registration reflects an address change. Check here for more information on joining a Section. Someone from our office will contact you. In accordance with ADA requirements, if you are disabled require special services, please check here. Someone from our office will contact you. Pricing ITC Conference (ITC) Price Early Bird Price* $600 Regular Price (as of 01/14/2014) $655 Price Early Bird Price Both Days $700 Regular Price Both Days (as of 01/14/2014) $755 *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. Subtotal $ Total $ Method 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 The FICPA is not responsible for checks or registrations delayed or lost in the mail. 11

12 Seeing Things Globally (800) (850) P.O. Box 5437 Tallahassee, Florida January 23-24, 2014 Miami