THE FLORIDA BAR TAX SECTION & CLE COMMITTEE, AND FICPA PRESENT THE

35TH ANNUAL

INTERNATIONAL TAX CONFERENCE

Jan. 5 – 6, 2017

JW Marriott, Miami 1109 Brickell Avenue, Miami, Florida 33131

FEATURING • The ITC Boot Camp

Jan. 4, 2017

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Overview of Event Schedule

Wednesday – Jan. 4

International Tax Boot Camp (7 CLE) Separate registration and fee required.

Thursday – Jan. 5 9:00 a.m. – 9:50 a.m. Current Developments in International Taxation – Outbound Update

9:50 a.m. – 10:40 a.m. Characterizing Income: Why It is So Important for the International Tax Practitioner

11:00 a.m. – 11:50 a.m. Is the United States the Dominant Financial Haven of the World?

11:50 a.m. – 1:20 p.m. Lunch Presentation: The U.S. As An Asset Hiding Haven – Selected Ethics and

Related Issues

1:20 p.m. – 2:10 p.m. An Overview of the Permitted Activities Under the U.S. Embargo and Taxation of U.S.

Investment into Cuba

2:10 p.m. – 3:00 p.m. Tax Planning with Cross-Border Loans – Successfully Navigating Around the

Proposed Section 385 Regulations

3:20 p.m. – 4:10 p.m. Exploring International Estate Tax and Income Tax Planning Strategies Involving

Issues That are Overlooked

4:10 p.m.– 5:00 p.m. Base Erosion and Profit Shifting: Key Impacts on Transfer Pricing

Friday – Jan. 6 8:30 a.m. – 9:20 a.m.

9:20 a.m. – 10:10 a.m.

10:30 a.m. – 11:20 a.m.

11:20 a.m. – 12:10 p.m.

12:10 p.m. – 1:30 p.m.

1:30 p.m. – 2:20 p.m.

2:35 p.m. – 3:25 p.m.

3:25 p.m. – 4:15 p.m.

Current Developments in International Taxation: “Inbound” Update to Include Global

Compliance and Controversy Developments

International Partnerships: To Boldly Go Where Few Have Gone Before

Hot Topics in CRS

Panel on Miscellaneous Civil and Criminal Procedural Issues

Lunch Presentation: Update from Washington, D.C.

More Than You Need to Know about Florida Corporate Income Tax and Sales Tax

Life Insurance and Annuities: Effective Tools for Pre-Immigration Tax Mitigation

Tips to Take Home: What’s New with International Tax Forms

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Wednesday, Jan. 4, 2017

ITC Boot Camp

The International Tax Boot Camp will provide young CPAs

and attorneys a beginner-level summary of international

inbound and outbound taxation.

This event requires a separate registration fee.

8:00 a.m. – 9:00 a.m.

Registration and Continental Breakfast (Included)

9:05 a.m. – 12:25 p.m. (Break: 10:30 a.m. - 10:50 a.m.)International Inbound Taxation

Scott A. Bowman

Partner | Proskauer Rose LLP | Boca RatonLeslie A. Share, Esq.Attorney | Packman, Neuwahl & Rosenberg | MiamiAlthough there has been an increase of a

traditional outbound tax practice in Florida during the last

decade or so, inbound direct investment remains the

dominant international tax practice area in Florida and

accord-ingly will receive the most emphasis in this

presentation. This presentation will briefly summarize

the basic U.S. federal income, estate and gift tax issues

that affect U.S. inbound international tax planning.

12:25 p.m. – 1:35 p.m.

Lunch (Included)

1:40 p.m. – 4:00 p.m. (Break: 3:40 p.m. - 4:00 p.m.) International Outbound Taxation

William B. Sherman

Partner | Holland & Knight, LLP | Ft Lauderdale

Kevin E. Packman

Partner | Holland & Knight, LLP | Miami

This presentation brings a different focus on outbound

investment. Instead of presenting the U.S. outbound rules

in the traditional context of the large U.S. based

multinational, this presentation will present the outbound

topic in a context more often seen in Florida, that of

members of a U.S. family encountering the outbound rules

in a closely held business. This presentation will briefly

summarize the basic U.S. federal income, estate and gift

tax issues that affect U.S. federal income tax issues that

affect outbound international tax planning.

4:00 p.m. – 4:50 p.m.

International Tax Forms

Renea M. Glendinning, CLU, CPA

Shareholder | Kerkering, Barberio & Company, CPA |

Sarasota

Amy Fondo

Principal | CliftonLarsonAllen | Orlando

David A. Cumberland, CGMA, CPA

Tax Manager | Kerkering, Barberio & Company, CPA |

Sarasota

These presentations will provide practical tips for the

international tax practitioner regarding various inbound and

outbound disclosure forms, including ways to avoid

common errors in their completion.

7:30 a.m. – 8:45 a.m.

Registration and Continental Breakfast (Included)

8:45 a.m. – 9:00 a.m.

Introductions and Opening Remarks

Lawrence J. Chastang, CPA

Managing Partner | Clifton Larson Allen | Orlando

Steven Hadjilogiou

Partner | Baker & McKenzie, LLP | Miami

9:00 a.m. – 9:50 a.m.

Current Developments in International Taxation –

Outbound Update

Larry R. Kemm, Esq.

Partner | Harrison Kemm, P.A. | Tampa

This session will review significant statutory,

regulatory, administrative and judicial developments in U.S.

outbound international taxation that occurred during 2016.

Thursday, Jan. 5, 2017

5:00 p.m. - 6:00 p.m.Networking Reception (Included)

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Thursday, Jan. 5, 2017 (cont.)

9:50 a.m. – 11:00 a.m. (Break: 10:40 a.m. - 11:00 a.m.)Characterizing Income: Why It is So Important for the

International Tax Practitioner

Seth J. Entin, Esq.

Shareholder | Greenberg Traurig, PA | Miami

It is very dangerous for an international tax practitioner to

operate in a vacuum and lose sight of the "general principles"

of U.S. federal income taxation. A case in point is the

characterization of income. This presentation will highlight key

characterization of income issues and show how many

important consequences in both the inbound and outbound

contexts turn on how the income in question is characterized.

This presentation will also provide multiple examples of how a

change in the character of income can result in adverse or

favorable consequences.

11:00 a.m. – 11:50 a.m.

Is the United States the Dominant Financial Haven of

the World?

Denis A. Kleinfeld, CPA, JD

Of Counsel | Fuerst Ittleman David & Joseph, PL | Miami

The world is full of competing tax havens; asset protection

jurisdictions; banking and investment states; and wealth

management destinations. Every country wants and needs to

attract and keep wealth. Capital is the lifeblood of every

economy. Learn why and how the United States positions itself

as the dominant country in the global economic contest for

capital and financial success.

11:50 a.m. – 1:20 p.m. (Included)Lunch Presentation: The U.S. as an Asset

Hiding Haven – Selected Ethics and Related Issues

Michael Lampert, Esq.

Attorney | Law Offices of Michael A. Lampert, PA | West

Palm Beach

Shawn P. Wolf, Esq.

Attorney/Shareholder | Packman, Neuwahl &

Rosenberg, PA | Miami

Much has been written about asset protection and privacy.

There is even a BNA Tax Management Portfolio on the topic.

There are also many articles and seminars on the ethics and

related issues in undertaking asset protection planning. In

addition, there are articles that address helping clients hide

assets – particularly in the divorce arena. But what about the offshore client that wants to “hide” money in the U.S. or to engage the services of U.S. attorneys to “hide” funds domestically or internationally. This presentation willtouch on some of the myriad of ethics and related issues.

1:20 p.m. – 2:10 p.m.

An Overview of the Permitted Activities Under the

U.S. Embargo and Taxation of U.S.

Investment into Cuba

Pedro A. Freyre

Partner – Chair, International Practice | Akerman LLP

| Miami

Michael J. Bruno

Associate | Baker & McKenzie, LLP | Miami

Join us as we cover the U.S. tax options for U.S.

companies that are permitted to do business in Cuba. We’ll

discuss the permitted activities under the U.S. Embargo

and how best to address U.S. tax challenges for an

operation in Cuba. Finally, we will outline the Cuban taxes

that can generally apply to a U.S. company and how best

to mitigate them.

2:10 p.m. – 3:20 p.m. (Break: 3:00 p.m. - 3:20 p.m.) Tax Planning with Cross-Border Loans –

Successfully Navigating Around the Proposed

Section 385 Regulations

James H. Barrett

Partner | Baker & McKenzie, LLP | Miami

Jeffrey L. Rubinger, Esq.

Partner | Bilzin Sumberg Baena Price & Axelrod, LLP |

Miami

We will cover the inbound and outbound tax consequences

of the Proposed Section 385 debt/equity rules. Last April,

the Treasury proposed debt/equity rules that broadly impact

how debt and equity are classified for international

transactions. These controversial proposed regulations

impact inbound loans (including portfolio debt); outbound

loans that are used to facilitate repatriation of profits; treaty

benefitted debt; and certain foreign-to-foreign

arrangements. The proposed regulations have a retroactive

effective date and can readily apply to existing loans.

Taxpayers are preparing now for these regulations. Our

panel will review the proposed (or if issued, final) regula-

tions as they apply to inbound and outbound investments,

and what taxpayers can do to better prepare for these

proposed regulations.

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Thursday, Jan. 5, 2017

(cont.) 3:20 p.m. – 4:10 p.m.

Exploring International Estate Tax and Income

Tax Planning Strategies Involving Issues That are

Overlooked

Hal J. Webb, Esq.

Bilzin Sumberg Baena Price & Axelrod LLP | Miami

Jennifer J. Wioncek, Esq., LL.M.

Bilzin Sumberg Baena Price & Axelrod LLP | Miami

We will cover issues arising with international estate

planning matters, such as planning to obtain a step-up in

basis in assets held by revocable and irrevocable trusts;

planning related to check-the-box elections; dealing with

UNI; domestication of trust structures; challenges involved

when working with foreign private foundations; and plan-

ning for clients who own valuable tangible personal proper-

ty located in the U.S.

4:10 p.m. – 5:00 p.m.

Base Erosion and Profit Shifting: Key Impacts on

Transfer Pricing

Barry Freeman, Ph.D.

Principal | Crowe Horwath LLP | New York, N.Y.

Joshua Johnston

Manager | Crowe Horwath LLP | Oak Brook, Ill.

This presentation will provide participants with the key

impacts on the global pricing landscape as a result of the

OECD’s Base Erosion and Profit Shifting project. The

discussion will revolve around recommendations for policy

changes with respect to the valuation of intangibles, the

allocation of risk within a multinational group, transfer

pricing documentation and other topics. The session will

also inform on recent legislative actions, court rulings and

other developments in the world of transfer pricing.

8:30 a.m. – 9:20 a.m.

Current Developments in International Taxation:

“Inbound” Update to Include Global Compliance

and Controversy Developments

William M. Sharp, Esq.

Shareholder | Sharp Partners, PA | Tampa

The presentation will technically highlight and provide

practitioner commentary regarding two areas: first,

“inbound” U.S. statutory, regulatory, administrative and

judicial developments, including selected foreign law

developments; and second, U.S. and global tax compliance

developments, encompassing a review of IRS/DOJ global

compliance initiatives and relevant selected foreign jurisdic-

tion initiatives.

9:20 a.m. – 10:30 a.m. (Break: 10:10 a.m. - 10:30 a.m.)International Partnerships: To Boldly Go Where Few

Have Gone Before

Robert H. Moore

Partner | Baker & McKenzie LLP | Miami

We will examine the many uses of partnerships in the

international context, exploring both inbound and outbound

uses of partnerships. Discussion will include FIRPTA issues,

estate tax issues and foreign tax credit issues.

10:30 a.m. – 11:20 a.m.

Hot Topics in CRS

Peter A. Cotorceanu, Esq.

CEO and Founder | www.gatcandtrusts.com | Zürich,

Switzerland

Like FATCA before it, CRS is a moving target. This

presentation will address the hottest topics in CRS,

especially those affecting the fiduciary industry.

Friday, Jan. 6, 2017

5:00 p.m. – 6:00 p.m.

Networking Reception (Included)

8:00 a.m. – 8:30 a.m.

Continental Breakfast (Included)

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Friday, Jan. 6, 2017 (cont.)

11:20 a.m. – 12:10 p.m.

Panel on Miscellaneous Civil and Criminal

Procedural Issues

Robert E. Panoff, Esq. (Panel Moderator)

Tax Litigator | Robert E. Panoff, PA | Miami

Select IRS and Law Enforcement Experts

This panel continues its tradition of providing up-to-the-

minute information regarding civil and criminal international

tax procedural issues affecting everyday tax practitioners

and their clients. Greater emphasis will be placed on

taxpayers within the jurisdiction of the Small Business/Self

Employed Division of the IRS, but we will also discuss

issues affecting taxpayers within the Large Business and

International Division.

12:10 p.m. – 1:30 p.m. (Included) Lunch Presentation: Update from

Washington, D.C.

Douglas Poms

Senior Counsel to the International Tax Counsel |

U.S. Department of Treasury | Washington, D.C.

This presentation will address current developments

related to international tax.

1:30 p.m. – 2:35 p.m. (Break: 2:20 p.m. - 2:35 p.m.) More Than You Need to Know About Florida

Corporate Income Tax and Sales Tax

William D. Townsend, JD

Of Counsel | Dean Mead & Dunbar | Tallahassee Will

discuss state tax traps for the unwary foreign entity; provide

an introduction to Florida corporate income tax issues

faced by foreign entities doing business in the state; and

cover application of Florida sales taxes to business

activities in the state of Florida.

2:35 p.m. – 3:25 p.m.

Life Insurance and Annuities: Effective Tools for

Pre-Immigration Tax Mitigation

Michael H. Ripp, Jr.

Giordani, Swanger, Ripp, & Phillips, LLP | Austin,

Texas

This presentation addresses the various applications of life

insurance and annuity products for mitigating the U.S. tax

consequences of immigrating to the U.S., whether

temporarily or permanently, and will emphasize the use of

private-placement contracts and other cost-efficient

products of particular interest to the high-net-worth (HNW)

immigrant.

3:25 p.m. – 4:15 p.m.

Tips to Take Home: What’s New with International

Tax Forms

David A. Cumberland, CPA, CGMA

Tax Manager | Kerkering, Barberio & Company |

Sarasota

Amy Fondo, CPA

Principal | CliftonLarsonAllen LLP | Orlando

Renea M. Glendinning, CPA

Shareholder | Kerkering, Barberio & Company |

Sarasota

This presentation will provide practical tips for the

international tax practitioner regarding various inbound and

outbound disclosure forms, including ways to avoid com-

mon errors in their completion. We will also discuss recent

procedural changes implemented by the IRS, including an

update on the ITIN renewal process.

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International Tax Conference Info

Hotel Information Please call the JW Marriott Miami at (800) 228-9290 to

JW Marriott Miami reserve your room. Be sure to mention this conference to

1109 Brickell Avenue receive the special group rate.

Miami, FL 33131 *Room availability is not guaranteed by this date and(305) 329-3500 inventory may fill up before the cutoff date. If any rooms

are left after the cutoff date, they will be added back to Rate: $309 single/double the general hotel inventory and sold at the prevailing hotel

Cut-Off Date: Tues, Dec 13, 2016* rate.

Make Your Reservations Online

The Florida Bar CLE Committee & Tax SectionEvett Simmons, Port Saint Lucie, Chair, CLE Committee

Terry L. Hill, Director, Programs Division, The Florida Bar

William Lane, Jr., Tampa, Chair, Tax Section

Joseph Schimmel, Miami, Chair-Elect, Tax Section

Abrahm Smith, Miami , Director, Education Division

Micah Fogarty, Tampa , Director, Education Division

Tax Section Faculty & Steering Committee

Steven Hadjilogiou, Miami, Program Co-Chair

Lawrence J. Chastang, Orlando, Program Co-Chair

James H. Barrett, Miami

Seth Entin, Miami

Lawrence R. Kemm, Tampa

Kevin E. Packman, Miami

Jeffrey L. Rubinger, Miami

Jonathan H. (Jason) Warner, Spruce Pine, NC

Hal J. Webb, Miami

Shawn P. Wolf, Miami

ITC Boot Camp (2330)

CLE Credit:

General: 7.0 hours

Certification Credit:

International: 7.0 hours

ITC Conference (2331)

CLER Program

(Max. Credit: 17.5 hours)

General: 17.5 hours

Ethics: 2.0 hours

Certification Program

(Max. Credit: 17.5 hours)

Immigration and Nationality Law: 2.0 hours

International Law: 17.5 hours

Tax Law: 17.5 hours

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Conference Registration 4 Ways to Register:

1. Register online www.floridabar.org/CLE. To register for the webcast, go to http://tinyurl.com/FloridaCLE2331R.

2. Call The Florida Bar Order Entry Department at (850) 561-5831

3. Fax completed registration form with credit card information to (850) 561-913 (secure fax).

4. Mail completed registration form to The Florida Bar, Order Entry Department, 651 East Jefferson Street,Tallahassee, Florida 32399-2300 with a check made payable to The Florida Bar or with credit card information.

One location (190) JW Marriott Hotel, Miami, FL (Jan. 5-6, 2017). On-site registration is by check only.

Name: _____________________________________________________ Florida Bar #: _________________________

Address: ________________________________________________ Phone: ( )________________________

City/State/Zip: _________________________________________________________________________________________

Email*: __________________________________________________ Asst. Email: __________________________

*Email address required to receive electronic course material and will only be used for this order. Course No. 2331R

International Tax Conference (2331R) Price Select One

Early Bird $660

Regular Price (as of 12/6/16) $715

International Tax Conference Webcast Price

Early Bird - both days $725

Regular Price - both days (as of 12/6/16) $780

To register for the webcast, go to: http://tinyurl.com/FloridaCLE2331R

International Tax Boot Camp (2330R) - Jan. 4 Price

Early Bird $250

Regular Price (as of 12/5/16) $305

International Tax Course Book/CD/DVD Price

Hardcopy Course Book $60 plus tax

Audio CD (2331C) $715

DVD Video (2331D) $765

Subtotal $

Total $

METHOD OF PAYMENT (CHECK ONE):

Check enclosed made payable to The Florida Bar

Credit Card (Fax to 850/561-9413.)

MASTERCARD VISA DISCOVER AMEX Exp. Date: ____/____ (MO./YR.)

Signature:______________________________________________________________________________________

Name on Card:_______________________________________________ Billing Zip Code:_____________________

Card No._______________________________________________________________________________________

Please check here if you have a disability that may require special attention or services. To ensure availability of appropriate accommo-dations, attach a general description of your needs. We will contact you for further coordination.

Enclosed is my separate check in the amount of $60 to join the Tax Section. Membership expires June 30, 2017

Private recording of this program is not permitted. Delivery time is 4 to 6 weeks after 1/09/17. TO ORDER AUDIO CD, fill out the order form above, includ-ing a street address for delivery. Please add sales tax. Those eligible for the above mentioned fee waiver may order a complimentary audio CD in lieu of live attendance upon written request and for personal use only. Please include sales tax unless ordering party is tax-exempt or a nonresident of Florida. If tax exempt, include documentation with the order form.

BRING YOUR FIRM & SAVE: 15% Discount (5-7); 20% Discount (8 or more). Call (850) 561-5625 for more details. Terms expire December 16, 2016.

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35th Annual International Tax Conference