South Florida Tax Controversies Seminar

Topics for this year’s program include:

• Filing for Non Profit Tax Exemptions -- What You Need to Know about the New Form 990
• Taxpayer and Preparer Penalties - The Latest Word from Washington
• Reporting Issues for US Persons with Foreign Corporations and/or Foreign Corporations with US assets
• When Does a Tax Payment Constitute a Deposit?
• Assessment and Collection of US Taxes from Non US Persons
• Potpourri of Updates

Speakers

Andrew H. “Andy” Weinstein is Florida Bar Board Certified in Tax Law and has more than 30 years’ experience handling complex domestic and international tax planning and compliance matters for ultra high net worth individuals; as well as demonstrated expertise representing clients with civil and criminal tax matters before the IRS and DOJ, from the early stages of examinations and investigations through termination. Highlights include responsibility for recommending, structuring and implementing all aspects of the largest expatriate matter in U.S. history; reorganizing ownership and control of a major international oil tanker fleet; in-depth structuring of domestic and foreign trusts involving cross-border investments and business activities; extensive coordination of large scale global trust projects; tax planning for inbound and outbound transactions involving matters ranging from several million dollars to several billions of dollars. Most importantly, his experiences enable him to provide substantial assurance to domestic and foreign clients that they will achieve their goals, while being fully compliant with all applicable laws in the United States and elsewhere. Andy is a Fellow in the American College of Tax Counsel and a Fellow in the American College of Trusts & Estates Counsel (Member, Professional Responsibility Committee and International Committee). He is listed in Best Lawyers in America and Chambers & Partners Law List. Andy is AV-rated in Martindale Hubbell.

Jeffrey L. Rubinger practices in the area of domestic and international taxation. He has been involved in tax planning for mergers and acquisitions, restructurings and joint ventures, and in the structuring of tax-driven financial products. In addition, Mr. Rubinger has experience in a broad range of transactions involving U.S. taxpayers doing business overseas, foreign taxpayers conducting business in the United States, as well as federal, state and local tax issues involving corporate reorganizations, partnerships, Subchapter S corporations, qualified and nonqualified stock option plans, and trust and estates. Mr. Rubinger lectures and has published several articles dealing with various domestic and international tax topics, including the Taxation of Financial Products, the Foreign Investment in Real Property Tax Act, International Tax Consequences of Cancellation of Indebtedness Income, the Taxation of Qualified Subchapter S Subsidiaries, “Check-the-Box” Tax Planning, Subpart F Income Minimization, Foreign Tax Credit Planning, and Tax Planning with Foreign Holding Companies.

Kevin E. Packman, a senior associate in the Private Wealth Services section, is a native of Miami, Florida. His practice focuses on estate and gift tax planning for domestic and international clients as well as on pre-immigration planning for international clients. He also assists clients with IRS tax controversies, creditor protection planning and probate administration. He has been recognized repeatedly by Florida Trend as an Up & Comer in the Florida Legal Elite. Mr. Packman lectures frequently and has published several articles on such topics as Establishing Residency in the U.S. Virgin Islands, Foreign Bank Account Report Compliance and Developments, the Internal Revenue Service’s Fast Track Settlement program, and on the Florida Homestead Exemption. He also drafted legislation that passed the U.S. Congress declaring May as “National ALS Awareness Month.” Mr. Packman is a member of the Florida Bar and is licensed to practice before the United States Tax Court. He is a member of the Tax and Real Property, Probate and Trust law sections of both the Florida Bar and American Bar Association.

Mauricio D. Rivero is an associate in Holland & Knight’s International Department concentrating his practice in the areas of tax planning and tax controversies. Mr. Rivero is a member of The Florida Bar and is licensed to practice before the local courts and the United States Tax Court. He is a member of the Tax, International and Real Property, Probate and Trust Law sections of The Florida Bar. Prior to joining Holland & Knight, Mr. Rivero served over ten years in the Examination Division of the Internal Revenue Service where he examined individual, partnership, and corporate returns including substantial cross-border transactions. While at the Service, Mr. Rivero also served as an instructor on a variety of subjects including F-BAR requirements, constructive dividends, foreign tax credit, withholding requirements, and indirect income examination methods. He was a speaker on November 2007 at a panel discussion on “Forms Over Substance: An Overview of International Tax Compliance Requirements,” hosted by B’nai B’rith International and Holland & Knight.