International Tax ConferenceSan Francisco and WebcastDec. 12, 2014

Hyatt Regency San Francisco5 Embarcadero Center

San Francisco, CA 94111

2014 INTERNATIONAL TAX CONFERENCEDEC. 12, 2014

HYATT REGENCY SAN FRANCISCO AND WEBCAST

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 offersconcurrent 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 HoursAdditional credit available during bonus session.

Level: Update

Prerequisites: None

CONFERENCE OVERVIEW

Bonus Session: Defending Taxpayer Penalties (one additional hour CPE)

Welcome and Introductions

The Government’s Carrot and Stick Approach to Foreign Income and Account Reporting

Break

Inbound Income Tax Compliance for Individuals

or

Income Tax Treaties

Structuring Foreign Investment in the U.S.

or

Cross Border Social Security and Retirement Issues

AGENDA {AT-A-GLANCE}

07:30

08:30

08:35

09:30

09:40

12:25

01:40

01:10

02:35

11:30 Outbound Income Tax Compliance for Individuals

or

Pre-Immigration Tax Planning

Lunch (plated lunch provided)

Luncheon Keynote: Buying Real Estate and Doing Business in Mexico without Acting or Being Treated as a “Gringo” (keynote will not be webcast).

How to Prepare and File the Disclosures of Foreign Financial Assets: Forms FinCEN 114 and 8938

or

Brains Across Borders

Estate and Gift Tax Compliance for Non-Citizens

or

Foreign Tax Credits for U.S. Persons

Break

International Tax Compliance

Networking Reception for San Francisco Attendees

Adjourn

03:40

04:45

03:30

04:30

10:35

Thank you to our Silver Sponsor:

Bonus Session: Defending Taxpayer PenaltiesHelp 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., LLMGreenberg Traurig, LLPSan Francisco

Welcome and Introductions

Phillip D.W. Hodgen, Esq., LLMHodgenLaw PCConference Chair

The Government’s Carrot & Stick Approach to Foreign Income and Account ReportingWith 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

{Break}

CONCURRENT SESSIONS

Inbound Income Tax Compliance for IndividualsDo 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, CPARINA 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

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; pre-immigration 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 IssuesHelp 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) TrentKS&Co

07:30

08:30

SESSIONDETAILS

International Tax Conference Dec. 12 Hyatt Regency San Francisco and Webcast

08:35

09:30

09:40

10:35

12:25

01:1011:30 CONCURRENT SESSIONS

Outbound Income Tax Compliance for IndividualsDiscover 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, CPAMoss Adams LLP

OR

Pre-Immigration Tax Planning PanelThis 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, EAMowat Mackie & Anderson LLP

{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

CONCURRENT SESSIONS

How to Prepare and File the Disclosures of Foreign Financial Assets: Forms FinCEN 114 and 8938Become 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, CPASpott, Lucey & Wall, Inc. CPAs

OR

Brains Across BordersDo 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.

01:40

CONFERENCE PLANNING COMMITTEE

Philip D. W. Hodgen, Esq., LLMHogdenLaw PCConference Chair

Dennis R. Brach, CPABurr Pilger Mayer, Inc.

Cindy H. Hsieh, CPARowbotham & Company LLP

Stella M. Leung, CPADZH Phillips, LLP

A.J. Major, CPAVavrinek, Trine, Day & Company, LLP

Thomas Neff, CPARINA Accountancy Corporation

Jacob Stein, Esq.Klueger & Stein, LLP

C. J. (Jodi) Trent, CPAKS&Co

Charlotte D. Wall, CPASpott, Lucey & Wall, Inc. CPAs

Conference Planning Committee

CONCURRENT SESSIONS

Estate and Gift Tax Compliance for Non-CitizensDo 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. PersonsLearn 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, CPARBZ LLP

{Break}

International Tax ComplianceThe 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 TEPDeloitte Tax LLP

Reception

Adjourn

03:30

04:45

03:40

05:30

02:35

ContactCalCPA Education FoundationP.O. Box 45066San Francisco, CA 94145-0066

Phone (800) 922-5272Fax (888) 868-8558Web calcpa.org

Event PricingMember $325 Nonmember $425

Conference RegistrationDec. 12 Hyatt Regency San Francisco Event Code 5141315ADec. 12 Webcast Event Code 5141315B

Discount ProgramsSave hundreds with Value-Priced Education (VPE) and Coupons.

VPE 80 $1,295 CalCPA MemberVPE 40 $795 CalCPA MemberVPE 24 $675 CalCPA MemberCoupon 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 PolicyAll registrations are taken on a first-come, first-served basis. The CalCPA Education Foundation reserves the right to refuse admission to any individual whose behavior it deems inappropriate.

Cancellation PolicyIf 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.

REGISTRATION INFORMATIONREGISTER ONLINE calcpa.org/InternationalTax14