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IFA USA Miami Chapter Luncheon Presentation
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Miami Florida - September 12 - International Tax Planning with Section 962

When: 9/12/2019
11:00 a.m. - 1:30 p.m.
Where: Bilzin Sumberg LLP
1450 Brickell Avenue
23rd Floor
Miami, Florida  33131
United States
Contact: IFA USA

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 IFA USA Branch, Miami Chapter
Luncheon Presentation
Thursday, September 12, 2019
11:00 a.m. – 1:30 p.m.
CLE/CPE Credits Available



Bilzin Sumberg LLP
1450 Brickell Avenue
23rd Floor
Miami, Florida 33131


Dress Code: Business Casual



Miami Chapter
Regional Council

James H. Barrett
Baker & McKenzie LLP


Devon M.  Bodoh

Weil, Gotshal & Manges LLP


Patricia A. Brown

University of Miami

School of Law


Alfonso J. Dulcey**

Weil, Gotshal & Manges LLP


Lily Garcia-Roberto
Royal Caribbean Cruises Ltd.


Steven Hadjilogiou

McDermott Will & Emery LLP


Jose Leiman
PricewaterhouseCoopers LLP


Alfonso A. Pallete



Jeffrey L. Rubinger

Bilzin Sumberg LLP


William B. Sherman

Holland & Knight LLP


Steve A Stoffel



Richard L. Winston*

Winston Legal Group LLC


*IFA Regional Vice President

** YIN Chair

 11:00 a.m. - 11:45 a.m.               Check-In and Networking Opportunity  
Noon - 1:30 p.m.                                       International Tax Planning with Section 962  


The presentation will focus on the increasing relevance of Section 962 elections to U.S. individual shareholders of CFCs after U.S. Tax Reform with respect to their Subpart F, Section 956, and GILTI inclusions. The presentation will also examine how the recently proposed GILTI regulations impact a U.S. individual’s decision on whether to make a Section 962 election or rely on the GILTI high-tax exception.  Moreover, the panel will compare the tax treatment of taxpayers who make Section 962 elections with those taxpayers who own CFCs indirectly through actual C corporations.



Barbara Rasch, KPMG, Director, International Tax—Los Angeles, California

Jeffrey Rubinger, Bilzin Sumberg LLP, Partner—Miami, Florida

Steven Hadjilogiou, McDermott Will & Emery LLP, Partner—Miami, Florida







Financial Hardship Policy

Scholarships are available in the event of financial hardship. An individual wishing to obtain a scholarship should apply in writing at least 2 weeks in advance of the program date, explaining the circumstances of such person's financial hardship. The amount of the scholarship generally depends on salary as follows:

Unemployed – Full Scholarship; Income up to $15,000 – 75% discount;
Income $15,000–$30,000 – 50% discount; Income above $30,000 – no discount

Cancellation Policy:

Speakers, content and panel order are subject to change without notice, and registrations may be limited due to space or other constraints.

This seminar is subject to cancellation due to insufficient registration or other reasons, in which case refunds will be made free of processing fees. All other refund requests are subject to a $10 processing fee and must be received in writing at the above address on or before September 2, 2019; no refunds will be given with respect to requests received after that date. All refunds are limited to the amount of registration fees previously paid less applicable processing fees. Substitutions are welcome at any time (including by walk-in registration).



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