Category: Tax Law, Business Litigation, International Law Category: Tax Law, Business Litigation, International Law (show less)

The 44th Annual FICPA – Florida Bar Tax Section International Tax Conference, 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. 

Introductions & Opening Remarks
Lawrence Chastang, Chairman, Chastang & Partners, LLC Abrahm Smith, Partner/Shareholder, Abrahm Smith Law PLLC

Current Developments In International Taxation: "Inbound" Tax Planning Update And Recent Global Tax Compliance And Controversy Developments
William Sharp Sr, Partner, Holland & Knight, LLP
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.

Effectively Connected Income: The Latest and Greatest
Seth Entin, Shareholder, Greenberg Traurig, PA
This presentation will address cutting-edge issues in the area of effectively connected income, in light of longstanding case law dating back decades, together with interesting and important recent developments in case law, Regulations, and IRS pronouncements.

Canadian Tax Issues Associated with US Investments and Immigration
Hal Webb, Partner, Bilzin Sumberg Baena Price & Axelrod Elie Roth, Partner, Davies Ward Phillips & Vineberg LLP Stewart Kasner, Partner, Holland & Knight, LLP
This session will cover:
• Canadian estate planning and taxation
• US stocks and bonds owned by Canadian residents
• US personal use real estate owned by Canadians
• Estate planning
• Pre-immigration planning

Q&A Chat Between Jarod Koopman, Chief Tax Compliance Officer (Acting), IRS, Washington D.C. and Robert ("Bob") E. Panoff, Esq,. Miami, FL
Jarod Koopman, Chief Tax Compliance Officer (Acting), Internal Revenue Service Robert Panoff, Tax Litigator, Robert E. Panoff, PA

Outbound Tax Planning for OBBB
Michael Bruno, Partner / Attorney, McDermott, Will & Emery LLP Steven Hadjilogiou, Partner, McDermott, Will & Emery LLP
The key takeaways of this session will be:
• OBBBA's meaningful relief from TCJA's
• Section 951B creates a targeted, parallel anti deferral regime
• What tax payers must follow
• How to be proactive in post-TCJA and post-OBBBA environments

Use of Florida Community Property Trusts for NRAs and Other Planning Options
Alfredo Tamayo, Shareholder, Packman, Neuwahl & Rosenberg, PA Leslie Share, Of Counsel, Packman, Neuwahl & Rosenberg, PA
This presentation will review the formation and maintenance of Florida Community Property Trusts by foreign individuals from both a non-immigrant and intended pre-immigration standpoint. We will compare these trusts to “traditional” jointly settled Florida
trusts and the tenancy by the entireties for Florida-based assets from an estate planning, wealth preservation, and federal tax perspective. In this regard, we will consider the potential related advantages and disadvantages of such planning versus other marital planning alternatives.

Malta Pension Plans: International Disputes Generating Novel Tax and Procedural Issues
Hale Sheppard, Partner, Eversheds Sutherland
For lovers of tax controversy, federal income tax disputes between taxpayers and the IRS over Malta pension plans should be legendary. In short, taxpayers followed the applicable treaty, they disclosed their positions to the IRS on all returns, the IRS disliked the result, and it is now implementing aggressive measures, including some that supposedly have retroactive effect. This presentation explores U.S. tax treatment of foreign retirement plans, key aspects of the US-Malty treaty, favorable positions claimed by taxpayers, initial IRS enforcement actions, significance of the Competent Authority Arrangement, effect of recent Proposed Regulations, current IRS settlement offers, court battles to come, and more.

It's 2801, Do You Know Where Your Inheritance is Coming From?
Shawn Wolf, Partner / Attorney, Bilzin Sumberg Baena Price & Axelrod Jennifer Wioncek, Partner, Bilzin Sumberg Baena Price & Axelrod
The session will give an initial, and very general overview, of the U.S. expatriation income tax rules. Thereafter, the focus of the presentation will be on Section 2801, the so-called U.S. inheritance tax, and will get into the details of the Regulations that were issued in early 2025. In particular, the presentation will discuss: (1) who the rules apply to; (2) how the tax is calculated; how to determine if the gift or inheritance involved is from a “covered expatriate”; and (4) other nuanced issues relevant to the application of the rule.

Outbound Update (Excluding OBBB)
Philip Hodgen, HodgenLaw PC
The OBBBA gets all of the attention, but plenty of administrative and judicial action happened in 2025 for outbound tax planning. We will review what the IRS and the courts did in 2025 that affect outbound tax planning, with selected deeper dives.

Crypto Tax: Policy and Practice
Miles Fuller, Head of Government Solutions
This presentation will provide an update on crypto tax matters with a focus on both legal issues and practical tax preparation questions. In 2026, taxpayers will be receiving Forms 1099-DA for the first time but those forms will not provide cost basis information, so this presentation will provide some techniques and approaches for preparing returns, understanding tax issues, and protecting your clients interests.

QSBS Expansion Under the One Beautiful Bill Act: A Global Perspective
Adam Smith, Founder, BizTx Law, P.A.
This session will explore the sweeping changes to Section 1202’s Qualified Small Business Stock (QSBS) regime enacted under the One Big Beautiful Bill Act, including revised eligibility criteria, holding period rules, and gain exclusion limits. The presentation will also address key cross-border planning considerations, such as structuring QSBS-eligible entities with foreign investors and navigating outbound ownership transitions. Attendees will gain practical strategies for leveraging QSBS benefits in light of these new legislative and international tax developments.

Who's Prosecuting Tax Crimes? The Current State of Criminal Tax Enforcement
Caroline Ciraolo, Partner, Kostelanetz LLP Ronald Loecker, Special Agent, IRS-CI Jeffrey Neiman, Partner, Neiman Mays Floch & Almeida
With Tax Division prosecutors now working for the DOJ Criminal Division, the IRS in a state of flux, and the government’s focus on fraud, waste, and abuse, taxpayers and their representatives are wondering about the state of criminal tax enforcement. Despite predictions to the contrary, IRS criminal investigation and DOJ continue to pursue criminal tax investigations involving high income non-filers, tax evasion coupled with pandemic fraud, employment tax violations coupled with immigration offenses, conspiracies to defraud the government, offshore tax schemes, and abusive tax-advantaged transactions. This panel will address recent prosecutions, lessons learned, and what we can expect in the coming years.

International Provisions of the OBBBA
Caitlin Hird, Legislative Counsel, Joint Committee on Taxation
This presentation will discuss the legislative history of the international tax provisions of the OBBBA, along with a brief overview of the role of the Joint Committee on Taxation in the legislative process. The presentation will also provide a legislative outlook.

Non-Resident Alien Gift and Estate Tax Issues and Updates
Lawrence Chastang, Chairman, Chastang & Partners, LLC Daniel Price, Attorney, Law Offices of Daniel Price, PLLC Rosy Lor, Principal, BDO USA, LLP
This panel covers key updates in nonresident alien gift and estate taxation, including cash gifts from US bank accounts, IRS guidance versus statutes, transfer certificate procedures, green card and domicile considerations, and federal tax implications of Puerto Rico birth or residency. Practical insights for advisors working with international clients will be provided.

Real Estate Opportunity Zones, Tax Credits (Real Estate), Portfolio Interest
Robert Moore, Partner, Baker McKenzie, LLP
Keith Hagan, Partner, Baker McKenzie, LLP
Mathew Slootsky, Associate, Baker McKenzie, LLP
This session will cover the importance of data center incentives, structures, and investments for QOZ. We will cover how tax incentives work in these cases, where the restrictions are, and the tax benefits. We will also discuss the impact of OBBB in this area and technical considerations.

Tax Tips to Take Home
Mishkin Santa, Principal, The Wolf Group
This presentation offers practical tips that CPAs and attorneys can immediately apply in their practice and with their clients. The presentation will focus on relevant and significant international and domestic tax law updates that related to complex compliance and consulting issues using real world examples and developments.