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Program Details
2026-07-23 08:25:00
Over 1,000+ webinars
Course Overview
2026-07-23 08:25:00
12.08h CLE Credits
Intermediate
12.08
Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY
The One Big Beautiful Bill Act made substantial changes to the rules that impose US taxation of US shareholders of CFCs. This session addresses how those changes affect planning opportunities and traps for the unwary. Some of the topics discussed include changes made to the rules relating to how US shareholders determine their pro rata share of Subpart F income and net CFC tested income or NCTI (previously GILTI), the reinstatement of Section 958(b)(4) which prohibits downward attribution from a foreign person to a US person under the constructive ownership rules, a new provision, Section 951B, which provides for CFC inclusions in the case of certain ownership structures, and the various changes to the GILTI (now NCTI) regime, including corresponding foreign tax credit changes. This session also discusses how the Subpart F and NCTI rules apply in certain partnership structures. Finally, the session discusses the application of certain exceptions to Subpart F income (e.g., the CFC look through rule of Section 954(c)(6), the active rent and royalty exception, and the high-tax exception) as well as certain exceptions relating to NCTI regime (e.g., the high-tax exception).
Joseph M. Calianno, JD, LLM, MBA, CPA, Managing Director; National Tax Practice, Andersen Tax, Washington, DC
Sean Dokko, JD, LLM, Managing Director; National Tax Practice, Andersen Tax, New York, NY
Enrica Ma, Esq., Principal, National Tax Department, International Tax and Transaction Services, EY, Washington, DC
Brandon C. Svetcov, Esq., Principal, International Tax Services, EY, New York, NY
Joseph M. Calianno
Sean Dokko
Enrica Ma
Brandon C. SvetcovA principal focus of both the TCJA and OB3 was reforming the taxation of US based multinationals. Unfortunately, the impact of that reform on individuals who own foreign corporations either directly or through pass-through entities, such as partnerships and S corporations, appears not to have been well thought out. This panel addresses the taxation of such individuals, the problems that they face under TCJA/OB3, and the steps that they can take to mitigate these apparent unintended consequences of tax reform.
Thomas M. Giordano-Lascari, Esq., Partner, Greenberg Glusker, Los Angeles, CA
Michael J.A. Karlin, Esq., Partner, Holland & Knight, Los Angeles, CA
Thomas M. Giordano-Lascari
Michael J.A. KarlinAmong the topics covered in this session are the US tax considerations for taxable and tax-free stock acquisitions of foreign companies, CFC issues, tax-free acquisitions of US companies, planning for the use of holding companies, inversion transactions, debt-equity regulations, use of hybrid instruments, OECD BEPS issues, and recent developments. The session also includes planning in light of tax law changes from OB3, including the base erosion anti-abuse tax (BEAT) and the anti-hybrid deduction limitations.
William S. Dixon, Esq., Managing Director, Mergers and Acquisitions, Citigroup Global Markets, New York, NY
Sam K. Kaywood, Esq., Partner, Alston & Bird, Atlanta, GA
William B. Sherman, Esq., Partner, Holland & Knight, Fort Lauderdale, FL
William S. Dixon
Sam K. Kaywood
William B. ShermanWith over six months having elapsed after their promulgation, this session dives into the final foreign tax credit regulations, exploring some of the key provisions and issues including what constitutes a creditable foreign income tax and how to allocate and apportion foreign tax to different “baskets.” The session covers, among other things, applying and navigating the newly renamed “attribution” and “cost recovery” requirements and the treaty coordination rules for foreign tax credit creditability determinations, as well as the rules for allocating and apportioning foreign tax applicable to disregarded distributions, foreign law distributions and dispositions.
Adam Bair, Esq., Principal, National Tax Services, PwC, New York, NY
Steven Burns, CPA, Director, National Tax Services, PwC, Washington, DC
Adam Bair
Steven BurnsThis session addresses the definition of US real property interest; tax rules applicable to foreign persons disposing of US real property interests; special rules applicable to investments through real estate investment trusts; special exceptions including for interests in publicly traded companies and domestically controlled real estate investment trusts, as well as special exemptions for qualified pension investors and foreign sovereign investors; and treaty and other withholding tax exemptions for payments of interest to foreign investors.
Alan I. Appel, Esq., Professor of Law, New York Law School, New York, NY
Heather Ripley, Esq., Partner, Alston & Bird, New York, NY
Sean J. Tevel, Esq., Partner, Holland & Knight, Miami, FL
Alan I. Appel
Heather Ripley
Sean J. TevelThis session addresses issues relating to investments by foreign persons in US debt, including US trade or business status, the safe harbors for certain investing and trading activities, “season and sell” techniques, and the use of income tax treaties including “bring your own treaty” funds.
Jason Schwartz, Esq., Partner, Cahill Gordon & Reindel, Washington, DC
Matthew Stevens, Esq., Principal, EY, Washington, DC
Jason Schwartz
Matthew StevensTax controversy professionals, and the Taxpayer Advocate, have long been sounding the alarm about the complex filing requirements for international information returns and the often life-altering penalties imposed for noncompliance. Due in part to the IRS’s overzealous approach towards enforcement in this area, taxpayers have challenged international information return penalties on various technical grounds and on the basis of reasonable cause. Recently, some of these challenges have been addressed by the courts. This session discusses recent cases in the area as well as their implications going forward.
Leila D. Carney, Esq., Partner, Caplin & Drysdale, Washington, DC
Jorge M. Oben-Cuadros, Esq., Partner, Procopio, Washington, DC
Lawrence A. Sannicandro, Esq., Partner, Pillsbury Winthrop Shaw Pittman, New York, NY
Michael Sardar, Esq., Partner, Kostelanetz, New York, NY
Leila D. Carney
Jorge M. Obén-Cuadros
Lawrence A. Sannicandro
Michael Sardar
Andersen Tax

Andersen Tax

EY

EY

Greenberg Glusker

Holland & Knight

Citigroup Global Markets

Alston & Bird LLP

Holland & Knight

PwC

PwC

New York Law School

Alston & Bird

Holland & Knight LLP

Cahill Gordon & Reindel

EY

Caplin & Drysdale

Procopio

Pillsbury Winthrop Shaw Pittman

Kostelanetz

Andersen Tax
Joe Calianno is a Managing Director in Andersen’s US National Tax practice in the Washington, D.C. office, where he serves as the USNT leader for international tax. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act, the One Big Beautiful Bill Act, and cross-border restructurings.

Andersen Tax
Sean Dokko is a Managing Director in the Private Client Services practice at Andersen. He advises high-net-worth individuals, families, closely held businesses, family offices, and fiduciaries on sophisticated estate, gift, income, and generation-skipping transfer tax planning. Sean’s practice focuses on developing customized wealth transfer strategies, business succession planning, trust and estate planning, and charitable planning designed to preserve and efficiently transfer wealth across generations. He works closely with clients and their advisors to create integrated tax and estate planning solutions that address both personal and business objectives.

EY
Enrica Ma is a Principal in the National Tax practice at Ernst & Young LLP in Washington, D.C. She advises multinational corporations on complex U.S. and international tax matters, with a practice focused on cross-border acquisitions and divestitures, internal restructurings, intellectual property planning, supply chain planning, and tax-efficient repatriation strategies. Enrica regularly counsels clients on the international tax provisions enacted under the Tax Cuts and Jobs Act of 2017, including foreign tax credits, expense apportionment, BEAT, FDII, and GILTI planning. She also has significant experience advising pharmaceutical, medical device, and life sciences companies on corporate and international tax issues, including licensing and collaboration transactions.

EY
Brandon C. Svetcov is an attorney with Ernst & Young LLP in New York, where he advises clients on complex tax and legal matters. His practice focuses on helping businesses navigate sophisticated legal and regulatory issues through strategic planning and practical solutions. As part of EY’s tax practice, Brandon works with clients on matters involving corporate and transactional tax issues, drawing on his legal background to provide integrated business and tax advice.

Greenberg Glusker
Thomas Giordano-Lascari is a Partner in Greenberg Glusker’s Private Client Services Group with nearly two decades of experience counseling high-net-worth individuals and closely held businesses on international income tax and estate planning matters. Well known for his work with global families whose holdings span multiple jurisdictions, he helps clients structure worldwide assets to advance family objectives while minimizing income and transfer taxes, and regularly handles pre-immigration planning, foreign investment in the United States, U.S. residency planning and management, and expatriation planning. He is a sought-after advisor on foreign trusts, guiding foreign fiduciaries, U.S. beneficiaries, and grantors through compliance obligations and tax consequences.

Holland & Knight
Michael J.A. Karlin is a private wealth services and tax attorney in Holland & Knight’s Century City office. He advises corporate and individual clients on tax, estate planning, and business matters that involve a cross-border element. For more than 45 years, his practice has centered on private client work: he counsels individuals and families from abroad who invest in or move to the United States, as well as U.S. individuals and families investing or moving abroad, including on the ever-increasing regulatory and reporting obligations these activities carry. Pre-immigration and expatriation planning form an important part of his practice.

Citigroup Global Markets
Will Dixon is a Managing Director at Citigroup Global Markets Inc., where he advises clients on complex tax-advantaged domestic and cross-border mergers and acquisitions, capital structure solutions, and financings. His practice encompasses public and private company transactions, including mergers, acquisitions, spin-offs, divestitures, buyouts, and SPAC transactions. In addition to his transactional practice, Will serves on the firm’s Fairness Opinion Committee and is widely recognized for his extensive knowledge of U.S. federal income taxation, combining experience in investment banking, legal practice, and academia.

Alston & Bird LLP
Sam Kaywood is Senior Counsel in Alston & Bird’s Federal & International Tax Group and a co-chair of the firm’s International Team. Over a career spanning more than 30 years, he concentrated his practice on federal income tax and international tax, including cross-border M&A and joint ventures and inbound investment into the United States, offering an innovative approach to complicated federal and international tax issues wherever his clients’ global business objectives took them. He worked on virtually all forms of cross-border investment, with substantial experience in Canada, Europe, China, and Latin America, and was particularly active structuring investments and acquisitions in Latin America, including Brazil, Mexico, Argentina, and Chile.

Holland & Knight
William B. Sherman concentrates his practice on domestic and international taxation, providing sophisticated tax planning for mergers and acquisitions, restructurings, joint ventures, and investments for clients in industries as diverse as private equity, healthcare, hospitality, petrochemicals, aluminum, real estate, transportation, telecommunications, retailing, investment management, and pharmaceuticals. His experience spans U.S. investment overseas, foreign investment in the U.S., and international, federal, state, and local tax issues involving investment fund structuring, corporate reorganizations, partnerships, equipment leasing, Subchapter S, executive compensation, stock options, and trusts and estates.

PwC
Adam Bair is a Principal in PwC’s National Tax Services practice, where he advises high-net-worth individuals, family offices, and closely held businesses on sophisticated tax planning strategies. With deep expertise in partnership taxation, estate and gift tax, and income-shifting techniques, Adam works closely with clients and advisors to structure tax-efficient solutions aligned with wealth preservation and succession goals. He is a licensed attorney with extensive experience navigating the intersection of legal strategy and federal tax law.

PwC
Steven Burns, CPA, is a tax professional with an extensive career at PwC, where he served as a Tax Partner for more than 19 years. His professional background includes significant experience in tax services and a long-standing tenure with the firm, culminating in his retirement from PwC on December 31, 2020.

New York Law School
Alan I. Appel specializes in international and domestic tax planning involving the taxation of mergers and acquisitions, partnerships, joint ventures, and limited liability companies, as well as tax controversy matters. He is a Professor of Law at New York Law School and Director of its International Tax Program.

Alston & Bird
Heather Ripley is a partner in Alston & Bird’s Federal & International Tax Group and a member of the firm’s REITs and Real Estate Funds tax team. She helps U.S. and foreign business entities and high-net-worth individuals navigate U.S. federal and international tax law, counseling on tax-efficient structuring of U.S. and cross-border investments and activities, U.S. tax and compliance obligations and risks, and the correction of noncompliance. Her advisory work covers income tax treaty application, FATCA, FIRPTA, and other inbound investment issues, the CFC and PFIC anti-deferral regimes for outbound investments, tax aspects of M&A transactions, and tax information reporting regimes.

Holland & Knight LLP
Sean Tevel is a private wealth services and international tax attorney in Holland & Knight’s Miami office. He advises foreign and domestic clients on U.S. federal income, gift, and estate tax matters associated with their cross-border investments and businesses. His international tax practice includes advising on multinational trust and business structures, including the controlled foreign corporation rules, the Passive Foreign Investment Company (PFIC) rules, and international tax treaties.

Cahill Gordon & Reindel
Jason Schwartz is a tax partner in CahillNXT, Cahill’s premier practice for Digital Assets and Emerging Technology, based in Washington, D.C. He specializes in tax issues relating to digital assets, financial products, securitizations, funds, treaties, and lending.

EY
Matthew Stevens is a Principal in EY’s International Tax and Transaction Services practice in Washington, D.C. He advises multinational corporations, financial institutions, and investment clients on complex U.S. and cross-border tax matters, with a particular focus on international taxation, financial products, capital markets transactions, and tax controversy. Throughout his career, he has built a distinguished reputation for his work in international tax, financial products, and tax policy, combining experience in private practice, government service, academia, and the financial services industry.

Caplin & Drysdale
Leila Carney is a seasoned tax lawyer focused on resolving disputes with the IRS. Her core practice involves providing a surgical defense to IRS audits, assessments, and penalties, including litigation against the IRS and the Department of Justice in the U.S. Tax Court, federal district court, and the D.C. Circuit. She is adept at handling multifaceted issues involving global business and investing structures for individuals, corporate clients, and complex trusts, and has handled sensitive IRS exams, administrative appeals, criminal matters, voluntary disclosures, ruling requests, and comment letters on proposed regulations.

Procopio
Jorge Oben-Cuadros is a Partner in Procopio’s Washington, D.C. office, where he advises clients on planning, controversy and litigation, and policy matters involving tax and trade. He represents multinational corporations, defense contractors, investment funds, high-net-worth individuals, and family offices — particularly from Latin America, Puerto Rico, and Europe — on complex U.S. and international matters. His practice centers on inbound structuring into the United States, cross-border planning, tariff exposure and mitigation, tax and trade litigation, and strategic guidance on tax and trade policy developments affecting global operations.

Pillsbury Winthrop Shaw Pittman
Lawrence “Larry” Sannicandro is a partner in Pillsbury’s New York office. He focuses his practice on a broad range of federal and state tax disputes affecting individual private clients as well as their estates, trusts, and businesses, both public and private. These disputes span the full range of civil and criminal tax matters, including audits and examinations, administrative appeals, collection matters, summons proceedings, grand jury subpoenas, criminal tax investigations and prosecutions, and litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, federal district and appellate courts, and state tax tribunals.

Kostelanetz
Michael Sardar is a partner in Kostelanetz LLP’s New York City office with extensive experience across a wide range of tax controversy and white-collar criminal defense matters. He represents clients in all stages of civil and criminal tax controversies before the IRS, state tax authorities, the Department of Justice, and local prosecutors, and advises taxpayers facing audits and investigations of noncompliance with foreign bank and asset reporting requirements.

Andersen Tax
Joe Calianno is a Managing Director in Andersen’s US National Tax practice in the Washington, D.C. office, where he serves as the USNT leader for international tax. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act, the One Big Beautiful Bill Act, and cross-border restructurings.

Andersen Tax
Sean Dokko is a Managing Director in the Private Client Services practice at Andersen. He advises high-net-worth individuals, families, closely held businesses, family offices, and fiduciaries on sophisticated estate, gift, income, and generation-skipping transfer tax planning. Sean’s practice focuses on developing customized wealth transfer strategies, business succession planning, trust and estate planning, and charitable planning designed to preserve and efficiently transfer wealth across generations. He works closely with clients and their advisors to create integrated tax and estate planning solutions that address both personal and business objectives.

EY
Enrica Ma is a Principal in the National Tax practice at Ernst & Young LLP in Washington, D.C. She advises multinational corporations on complex U.S. and international tax matters, with a practice focused on cross-border acquisitions and divestitures, internal restructurings, intellectual property planning, supply chain planning, and tax-efficient repatriation strategies. Enrica regularly counsels clients on the international tax provisions enacted under the Tax Cuts and Jobs Act of 2017, including foreign tax credits, expense apportionment, BEAT, FDII, and GILTI planning. She also has significant experience advising pharmaceutical, medical device, and life sciences companies on corporate and international tax issues, including licensing and collaboration transactions.

EY
Brandon C. Svetcov is an attorney with Ernst & Young LLP in New York, where he advises clients on complex tax and legal matters. His practice focuses on helping businesses navigate sophisticated legal and regulatory issues through strategic planning and practical solutions. As part of EY’s tax practice, Brandon works with clients on matters involving corporate and transactional tax issues, drawing on his legal background to provide integrated business and tax advice.

Greenberg Glusker
Thomas Giordano-Lascari is a Partner in Greenberg Glusker’s Private Client Services Group with nearly two decades of experience counseling high-net-worth individuals and closely held businesses on international income tax and estate planning matters. Well known for his work with global families whose holdings span multiple jurisdictions, he helps clients structure worldwide assets to advance family objectives while minimizing income and transfer taxes, and regularly handles pre-immigration planning, foreign investment in the United States, U.S. residency planning and management, and expatriation planning. He is a sought-after advisor on foreign trusts, guiding foreign fiduciaries, U.S. beneficiaries, and grantors through compliance obligations and tax consequences.

Holland & Knight
Michael J.A. Karlin is a private wealth services and tax attorney in Holland & Knight’s Century City office. He advises corporate and individual clients on tax, estate planning, and business matters that involve a cross-border element. For more than 45 years, his practice has centered on private client work: he counsels individuals and families from abroad who invest in or move to the United States, as well as U.S. individuals and families investing or moving abroad, including on the ever-increasing regulatory and reporting obligations these activities carry. Pre-immigration and expatriation planning form an important part of his practice.

Citigroup Global Markets
Will Dixon is a Managing Director at Citigroup Global Markets Inc., where he advises clients on complex tax-advantaged domestic and cross-border mergers and acquisitions, capital structure solutions, and financings. His practice encompasses public and private company transactions, including mergers, acquisitions, spin-offs, divestitures, buyouts, and SPAC transactions. In addition to his transactional practice, Will serves on the firm’s Fairness Opinion Committee and is widely recognized for his extensive knowledge of U.S. federal income taxation, combining experience in investment banking, legal practice, and academia.

Alston & Bird LLP
Sam Kaywood is Senior Counsel in Alston & Bird’s Federal & International Tax Group and a co-chair of the firm’s International Team. Over a career spanning more than 30 years, he concentrated his practice on federal income tax and international tax, including cross-border M&A and joint ventures and inbound investment into the United States, offering an innovative approach to complicated federal and international tax issues wherever his clients’ global business objectives took them. He worked on virtually all forms of cross-border investment, with substantial experience in Canada, Europe, China, and Latin America, and was particularly active structuring investments and acquisitions in Latin America, including Brazil, Mexico, Argentina, and Chile.

Holland & Knight
William B. Sherman concentrates his practice on domestic and international taxation, providing sophisticated tax planning for mergers and acquisitions, restructurings, joint ventures, and investments for clients in industries as diverse as private equity, healthcare, hospitality, petrochemicals, aluminum, real estate, transportation, telecommunications, retailing, investment management, and pharmaceuticals. His experience spans U.S. investment overseas, foreign investment in the U.S., and international, federal, state, and local tax issues involving investment fund structuring, corporate reorganizations, partnerships, equipment leasing, Subchapter S, executive compensation, stock options, and trusts and estates.

PwC
Adam Bair is a Principal in PwC’s National Tax Services practice, where he advises high-net-worth individuals, family offices, and closely held businesses on sophisticated tax planning strategies. With deep expertise in partnership taxation, estate and gift tax, and income-shifting techniques, Adam works closely with clients and advisors to structure tax-efficient solutions aligned with wealth preservation and succession goals. He is a licensed attorney with extensive experience navigating the intersection of legal strategy and federal tax law.

PwC
Steven Burns, CPA, is a tax professional with an extensive career at PwC, where he served as a Tax Partner for more than 19 years. His professional background includes significant experience in tax services and a long-standing tenure with the firm, culminating in his retirement from PwC on December 31, 2020.

New York Law School
Alan I. Appel specializes in international and domestic tax planning involving the taxation of mergers and acquisitions, partnerships, joint ventures, and limited liability companies, as well as tax controversy matters. He is a Professor of Law at New York Law School and Director of its International Tax Program.

Alston & Bird
Heather Ripley is a partner in Alston & Bird’s Federal & International Tax Group and a member of the firm’s REITs and Real Estate Funds tax team. She helps U.S. and foreign business entities and high-net-worth individuals navigate U.S. federal and international tax law, counseling on tax-efficient structuring of U.S. and cross-border investments and activities, U.S. tax and compliance obligations and risks, and the correction of noncompliance. Her advisory work covers income tax treaty application, FATCA, FIRPTA, and other inbound investment issues, the CFC and PFIC anti-deferral regimes for outbound investments, tax aspects of M&A transactions, and tax information reporting regimes.

Holland & Knight LLP
Sean Tevel is a private wealth services and international tax attorney in Holland & Knight’s Miami office. He advises foreign and domestic clients on U.S. federal income, gift, and estate tax matters associated with their cross-border investments and businesses. His international tax practice includes advising on multinational trust and business structures, including the controlled foreign corporation rules, the Passive Foreign Investment Company (PFIC) rules, and international tax treaties.

Cahill Gordon & Reindel
Jason Schwartz is a tax partner in CahillNXT, Cahill’s premier practice for Digital Assets and Emerging Technology, based in Washington, D.C. He specializes in tax issues relating to digital assets, financial products, securitizations, funds, treaties, and lending.

EY
Matthew Stevens is a Principal in EY’s International Tax and Transaction Services practice in Washington, D.C. He advises multinational corporations, financial institutions, and investment clients on complex U.S. and cross-border tax matters, with a particular focus on international taxation, financial products, capital markets transactions, and tax controversy. Throughout his career, he has built a distinguished reputation for his work in international tax, financial products, and tax policy, combining experience in private practice, government service, academia, and the financial services industry.

Caplin & Drysdale
Leila Carney is a seasoned tax lawyer focused on resolving disputes with the IRS. Her core practice involves providing a surgical defense to IRS audits, assessments, and penalties, including litigation against the IRS and the Department of Justice in the U.S. Tax Court, federal district court, and the D.C. Circuit. She is adept at handling multifaceted issues involving global business and investing structures for individuals, corporate clients, and complex trusts, and has handled sensitive IRS exams, administrative appeals, criminal matters, voluntary disclosures, ruling requests, and comment letters on proposed regulations.

Procopio
Jorge Oben-Cuadros is a Partner in Procopio’s Washington, D.C. office, where he advises clients on planning, controversy and litigation, and policy matters involving tax and trade. He represents multinational corporations, defense contractors, investment funds, high-net-worth individuals, and family offices — particularly from Latin America, Puerto Rico, and Europe — on complex U.S. and international matters. His practice centers on inbound structuring into the United States, cross-border planning, tariff exposure and mitigation, tax and trade litigation, and strategic guidance on tax and trade policy developments affecting global operations.

Pillsbury Winthrop Shaw Pittman
Lawrence “Larry” Sannicandro is a partner in Pillsbury’s New York office. He focuses his practice on a broad range of federal and state tax disputes affecting individual private clients as well as their estates, trusts, and businesses, both public and private. These disputes span the full range of civil and criminal tax matters, including audits and examinations, administrative appeals, collection matters, summons proceedings, grand jury subpoenas, criminal tax investigations and prosecutions, and litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, federal district and appellate courts, and state tax tribunals.

Kostelanetz
Michael Sardar is a partner in Kostelanetz LLP’s New York City office with extensive experience across a wide range of tax controversy and white-collar criminal defense matters. He represents clients in all stages of civil and criminal tax controversies before the IRS, state tax authorities, the Department of Justice, and local prosecutors, and advises taxpayers facing audits and investigations of noncompliance with foreign bank and asset reporting requirements.
Requirements
The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.
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