International Tax Conference San Francisco and Webcast Dec. 12, 2014
2014 INTERNATIONAL TAX CONFERENCE DEC. 12, 2014 HYATT REGENCY SAN FRANCISCO AND WEBCAST
CONFERENCE OVERVIEW Overview: Whether your clients are individuals with international holdings, U.S. citizens working in foreign countries, multinational families, families with international business interests, or foreign nationals working in the U.S., you need an understanding of the forms, reporting requirements, standards and regulations required for international tax. This conference offers concurrent sessions with advanced topics for experienced international tax practitioners as well as introductory presentations for those who are new to this exciting field. Clear overviews, insightful discussions and best practices from international tax experts are the hallmarks of this event.
Designed for: CPAs, attorneys and other tax or finance professionals who advise nonresidents with U.S. investments, U.S. citizens living or doing business abroad, as well as individuals and families moving across borders. Credit Information: CPE: 8 Hours MCLE: 6.5 Hours Additional credit available during bonus session. Level: Update Prerequisites: None
Hyatt Regency San Francisco 5 Embarcadero Center San Francisco, CA 94111
AGENDA {AT-A-GLANCE}
07:30
Bonus Session: Defending Taxpayer Penalties (one additional hour CPE)
08:30
Welcome and Introductions
08:35
The Government’s Carrot and Stick Approach to Foreign Income and Account Reporting
09:30
Break
09:40
Inbound Income Tax Compliance for Individuals
10:35
11:30
Outbound Income Tax Compliance for Individuals or Pre-Immigration Tax Planning
12:25
Lunch (plated lunch provided)
01:10
Luncheon Keynote: Buying Real Estate and Doing Business in Mexico without Acting or Being Treated as a “Gringo” (keynote will not be webcast).
01:40
How to Prepare and File the Disclosures of Foreign Financial Assets: Forms FinCEN 114 and 8938
or
or
Income Tax Treaties
Brains Across Borders
Structuring Foreign Investment in the U.S.
02:35
Estate and Gift Tax Compliance for Non-Citizens
or
or
Cross Border Social Security and Retirement Issues
Foreign Tax Credits for U.S. Persons
Thank you to our Silver Sponsor:
03:30
Break
03:40
International Tax Compliance
04:45
Networking Reception for San Francisco Attendees
04:30
Adjourn
International Tax Conference Dec. 12 Hyatt Regency San Francisco and Webcast 07:30
Bonus Session: Defending Taxpayer Penalties Help your clients prevent notices, respond to notices whether they are valid or not and understand various approaches to penalty relief. During this session, you’ll also learn the new IRS guidance for unfiled forms through which no tax is assessed. Courtney A. Hopley, Esq., LLM Greenberg Traurig, LLP San Francisco
08:30
Welcome and Introductions Phillip D.W. Hodgen, Esq., LLM HodgenLaw PC Conference Chair
08:35
The Government’s Carrot & Stick Approach to Foreign Income and Account Reporting With increased visibility due to FATCA, you must understand the government’s approach to foreign income and account reporting. This session will cover the definition of willful conduct; process and procedures; and Swiss and other bank revelations. Jay R. Weill, Esq. Sideman & Bancroft LLP
09:30
{Break}
09:40
CONCURRENT SESSIONS
10:35
CONCURRENT SESSIONS Structuring Foreign Investment in the U.S. Learn to effectively structure foreign investments in the U.S. by gaining an understanding of income, gift and estate taxation for NRAs; how to determine residence; structuring and planning options for NRAs; preferred ownership structures for NRAs; preimmigration tax planning; how to do business in the U.S. and use of agents; withholding on U.S. income; and FIRPTA. Jacob Stein, Esq. Klueger & Stein, LLP OR Cross Border Social Security and Retirement Issues Help your clients successfully navigate social tax and retirement issues associated with working and/or living abroad. During this session, you will review the general rules regarding social taxes for an international workforce including where Social Security will be paid, Totalization Agreements, U.S. compliance for foreign pensions, super annuations, RRSPs, treaty positions and local country impacts of U.S. plans. C. J. (Jodi) Trent KS&Co
Inbound Income Tax Compliance for Individuals Do you know what income is reportable in the U.S. for foreign individuals entering the U.S.? Get an overview of Form 1040NR including where income goes and when a nonresident should file, as well as Schedule OI and treaty position. Thomas Neff, CPA RINA Accountancy Corporation OR Income Tax Treaties Treaties will be demystified by experienced tax attorney Rufus v. Rhoades. Understand treaty clauses vs. code sections, residence under a treaty and permanent establishment. Rufus v. Rhoades, Esq. Law Offices of Rufus v. Rhoades
SESSION DETAILS
11:30
CONCURRENT SESSIONS
01:10
Outbound Income Tax Compliance for Individuals Discover the best ways to handle tax planning and compliance for U.S. citizens abroad. Learn when to claim the foreign earned income exclusion, common foreign tax credits and fiscal year host countries, understand California residency and termination, explore stock option issues, review helpful tax treaty issues and tax equalization. Plus, special attention will be paid to Chinese tax issues for individuals. Andrew M. Mattson, CPA Moss Adams LLP OR Pre-Immigration Tax Planning Panel This session will provide you with best practices for pre-immigration from a panel of experts. The panel will discuss tax planning including evaluation of visa choices, filing options, planning issues around foreign trusts, FATCA and preventing compliance problems, planning for cross border couples and community property issues. MODERATOR Jacob Stein, Esq. Klueger & Stein, LLP PANELISTS Stephanie Corinna Smith, Esq. Weaver Schlenger Mazel LLP Angela D. Warren, Esq. Warren Law Firm Karen E. Wilson, EA Mowat Mackie & Anderson LLP 12:25
{Lunch–plated lunch provided}
Luncheon Keynote: Buying Real Estate and Doing Business in Mexico Without Acting or Being Treated as a “Gringo” This session will not be webcast and does not offer CPE credit. As California’s neighbor to the south and primary trade partner, Mexico offers an attractive business environment, legal certainty, one of the world’s largest free trade agreement networks and numerous business opportunities. Take full advantage of business opportunities by gaining an understanding of Mexico’s current business and legal framework; regulatory framework for foreign investments; legal considerations for setting up a business and ownership of real property. Additionally, you’ll gain insights on opportunities for U.S. investors and tips on how to effectively do business in Mexico. Mauricio Leon de la Barra, Esq. Martin-Sanchez & Leon de la Barra, LLP
01:40
CONCURRENT SESSIONS How to Prepare and File the Disclosures of Foreign Financial Assets: Forms FinCEN 114 and 8938 Become your firm’s specialist in preparing and filing disclosures of foreign financial assets. In this session, you will evaluate the filing requirements for each form, determine the assets that need to be included and review how to handle unusual assets and necessary disclosures. Charlotte D. Wall, CPA Spott, Lucey & Wall, Inc. CPAs OR Brains Across Borders Do you have clients who work outside the country? Understand sourcing rules, what income is taxable, withholding rules, Forms 1042 and 1042-S, Social Security and self-employment tax. Critical issues regarding the evaluation of online delivery of services and providing services across borders will be addressed. Harry-Todd Astrov, Esq. Astrov P.C.
CONFERENCE PLANNING COMMITTEE 02:35
CONCURRENT SESSIONS Estate and Gift Tax Compliance for Non-Citizens Do you know when a non-citizen is subject. to U.S. gift and estate taxes or what types of property transfers by a non-citizen can be subject to gift and estate taxes? What about the tax and information return reporting requirements related to the estates of, and gifts made by, non-citizens? Get the answers to these questions and more during this session on federal taxation and compliance issues related to property transfers made by non-citizens and their estates. Pamela J. Drucker, Esq. Andersen Tax OR Foreign Tax Credits for U.S. Persons Learn the essential calculations for claiming credit treatment for foreign taxes paid or incurred, including: determination of the taxes deemed paid by a foreign subsidiary; the assignment of income and taxes to the two baskets; kick-out of high tax passive income; treatment of overall foreign and domestic losses; recently enacted limitations including loss of credits for investments in U.S. property, splitter events and basis step-ups in covered acquisitions; and basic strategies for optimal multi-year results. William K. Norman, Esq. Ord & Norman Michael F. Ozen, CPA RBZ LLP
03:30
{Break}
03:40
International Tax Compliance The IRS recently published the final regulations relating to Passive Foreign Investment Companies (PFICs). Be sure you know how this will impact your clients and review Forms 3520, 5471, 8621, 8865 and W-8BEN during the key update for accounting and finance professionals. John Apuzzo, CPA, GCMA, CBV, MST, MIT TEP Deloitte Tax LLP
04:45
Reception
05:30
Adjourn
Conference Planning Committee Philip D. W. Hodgen, Esq., LLM HogdenLaw PC Conference Chair Dennis R. Brach, CPA Burr Pilger Mayer, Inc. Cindy H. Hsieh, CPA Rowbotham & Company LLP Stella M. Leung, CPA DZH Phillips, LLP A.J. Major, CPA Vavrinek, Trine, Day & Company, LLP Thomas Neff, CPA RINA Accountancy Corporation Jacob Stein, Esq. Klueger & Stein, LLP C. J. (Jodi) Trent, CPA KS&Co Charlotte D. Wall, CPA Spott, Lucey & Wall, Inc. CPAs
REGISTRATION INFORMATION
REGISTER ONLINE calcpa.org/InternationalTax14
Contact CalCPA Education Foundation P.O. Box 45066 San Francisco, CA 94145-0066 Phone (800) 922-5272 Fax (888) 868-8558 Web calcpa.org Event Pricing Member $325 Nonmember $425 Conference Registration Dec. 12 Hyatt Regency San Francisco Event Code 5141315A Dec. 12 Webcast Event Code 5141315B Discount Programs Save hundreds with Value-Priced Education (VPE) and Coupons. VPE 80 $1,295 CalCPA Member VPE 40 $795 CalCPA Member VPE 24 $675 CalCPA Member Coupon 10 $2,495 CalCPA Member Learn more about CalCPA discount programs, (800) 922-5272 or calcpa.org/discount Materials for this conference are provided in PDF format. You will receive an email that contains a link for accessing the materials at least three days before the conference.
Registration Policy All registrations are taken on a first-come, firstserved basis. The CalCPA Education Foundation reserves the right to refuse admission to any individual whose behavior it deems inappropriate. Cancellation Policy If you need to cancel your registration, you must cancel four business days prior to the event to receive a full refund. After that time a refund will be given less a $125 cancellation fee. No refunds will be given for no-shows. VPE no-shows will have the number of registered CPE hours deducted from their VPE credit. Coupon no-shows will forfeit the coupon used to register. For registration policies please go to calcpa.org/policies. Note: Topics and speakers are subject to change. For up-to-date information, please go to calcpa.org CalCPA Education Foundation is registered with the National Association of State Boards of Accountancy (NASBA), as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417 or www.learningmarket.org.