A Unique Experience
Law International Tax Symposium will feature a host of world-class presenters—including distinguished tax practitioners and government officials from the United States, Mexico, Brazil, and Latin America—who will discuss international tax topics impacting taxpayers around the globe.
Featured speakers include:
- Caroline D. Ciraolo, Former Acting Assistant Attorney General of the U.S. Department of Justice Tax Division
- Sandra R. Brown, Former Acting United States Attorney for the Central District of California
- Frank Agostino, Former Special Assistant United States Attorney and adjunct professor at Seton Hall University W. Paul Stillman School of Business and Rutgers School of Law
Join us as we host an insightful, information-packed series of panels focused on trends and developments in international taxation. Participants will enjoy an unique opportunity to learn from global tax authorities and interact with other tax practitioners as we explore an array of timely topics.
International Civil Tax Penalties
International civil tax enforcement has been on the rise for more than a decade. The IRS and other tax agencies throughout the world have only increased their focus. Enforcement efforts have given rise to significant civil penalties, including FBAR and information-return penalties. Join our panel as they discuss developments with respect to civil tax penalties in the international tax context.
The Untold Story of How One Man Destroyed Swiss Bank Secrecy and Ushered in a Revolutionary Era of International Tax Enforcement
Bradley C. Birkenfeld is the recipient of the single-largest IRS whistleblower award in history—some $104 million—and is largely credited with bringing down Swiss Bank Secrecy and ushering in a revolution in international tax enforcement. In 2007, Birkenfeld made the so-called “Birkenfeld Disclosure” to the Department of Justice, leading DOJ to enter into a deferred prosecution agreement with UBS and, ultimately, to the IRS’s adoption of the Offshore Voluntary Disclosure Program. All told, his work enabled the U.S. Treasury to recover an estimated $25 billion.
Mr. Birkenfeld is the bestselling author of Lucifer’s Banker UNCENSORED: The Untold Story of How I Destroyed Swiss Bank Secrecy. He is a former insider and private banker with UBS in Switzerland, the largest bank in the world, and is now a fierce advocate for whistleblower efforts worldwide. His story is unprecedented and important.
The Tax Information Age—Global Information Exchange
For the better part of a decade, the Organization for Economic Cooperation and Development (OECD) has pushed for increased tax information sharing among tax authorities across the globe. The rise in bi-lateral Tax Information Exchange Agreements (“TIEAs”) and multi-lateral information-exchange instruments has given rise to a new era in international taxation. Join our panel as they discuss the Tax Information Age and developments in the global exchange of information among taxing authorities.
International Criminal Tax Enforcement
The United States and other countries have increased focus on investigating and prosecuting international tax crimes. With the rise of supranational bodies, such as the OECD, as well as multi-lateral and bi-lateral information-exchange agreements, international criminal tax enforcement is on the rise. We’ll discuss developments with respect to criminal tax enforcement in the international tax context.
Transfer Pricing Developments
Transfer pricing has long been a topic at the heart of the international tax system. The significance of transfer pricing has only increased in light of recent efforts by the Organization for Economic Cooperation and Development’s (OECD) and its Base Erosion and Profit Shifting (BEPS). Join our panel as they discuss the current state of affairs in transfer pricing and what you need to know now.
Global Tax Reform
More than 130 countries and jurisdictions have joined the Organization for Economic Cooperation and Development’s (OECD’s) two-pillar plan to reform international taxation rules, including the G-7 and G-20 member countries and nearly all developed countries. There is, perhaps more than ever before, a growing consensus among countries across the globe to move forward with a coordinated effort towards global tax reform. The implications for multinational corporations and taxpayers ultimately remain to be seen. Join our panel of international tax experts as they discuss global tax reform.
A Closer Look at GILTI and FDII
The Global Intangible Low Tax Income (GILTI) and Foreign Derived Intangible Income (“FDII”) categories were a product of the Tax Cuts & Jobs Act of 2017 (“TCJA”). GILTI portended a significant impact on Controlled Foreign Corporation (“CFCs”). FDII, on the other hand, created a tax preference incentivizing U.S. corporate taxpayers to serve foreign markets. Now several years into the TCJA, our panel takes a look back at these important provisions.
Cryptocurrency – Global Enforcement Trends
The rise of cryptocurrency has given rise to important regulatory and tax enforcement trends across the globe. For example, the United States and several partnering jurisdictions adopted the Joint Chiefs of Global Tax Enforcement—known as the “J5”—largely as part of a coordinated effort to meet the burgeoning threat posed by cryptocurrencies to tax administrations throughout the world. Join our panel of crypto experts
U.S.-Mexico Tax Planning Opportunities
Recent years have seen the United States undergo the most significant tax reform in over 35 years, as well as Mexican tax reform designed to implement recommendations from the Organization for Economic Cooperation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) Action Plans. This shifting landscape requires a fresh look at cross-border tax-planning opportunities. Join our panel of tax experts as they discuss U.S.-Mexico Tax Planning Opportunities in the current environment.