International Taxation Conference Webcast

Mitchell Sorkin, CPA, MBA, PFS, CEA is a Tax Partner with over 45 years of expertise in wealth and business management, as well as personal financial, corporate, individual, trust, estate, partnership, investment, and international planning. His clients include high net worth individuals, import and export businesses, personal service firms, distributors, and manufacturers. Prior to joining the firm, Mitchell was a Tax Partner at Raich Ende Malter & Co. LLP (REM), a leading full-service accounting and auditing firm providing a wide variety of accounting, tax, and business advisory services to organizations of all sizes, emerging businesses, and high net worth individuals. As an active member of the American Institute of Certified Public Accountants (AICPA), Mitchell holds a Certificate in Educational Achievement in Business Evaluations, as well as the AICPA Personal Financial Specialist designation. He is the former Chair of the New York State Society of Certified Public Accountants (NYSSCPA) International Taxation Committee. Mitchell is a frequent writer and lecturer on domestic and international taxation, business management, and wealth management topics.

Chaim Kofinas has over 40 years experience in accounting and taxation specializing in state and local taxation issues. He has spent the last 35 years advising clients on income tax and sales tax matters as well as representing clients before the IRS and State on exams and on appeals. Chaim has also advised clients in the construction field as well as Not-For-Profit clients. Chaim is a frequent lecturer for this and other conference in the past and has written articles on a variety of tax issues. At Goldstein Lieberman & CO LLC Chaim is a Tax Director who advises high net worth clients as well a working small business clients regarding U. S. and state and local taxation. Chaim also works with the tax group to set tax policy for the firm. Prior to joining Goldstein Lieberman & CO LLC Chaim was a senior tax manager at WithumSmith+Brown PC, and later at Beacon CPA PC, where he advised multistate businesses and individual clients on federal and state and local tax matters including representation before the IRS and other taxing agencies. Chaim has also worked with foreign individual sand businesses making inbound investments into the US . Chaim is currently the immediate Past Chair of the New York State Society CPA New York, Multistate & Local Taxation Committee as well as being active with the New York State Society CPA International Committee. During his tenure as Chair Chaim initiated a dialogue with the NYS Commissioners office and lead a delegation to meet the Commissioner in Albany

Jonathan E. Gopman, Esq., is a Partner at Akerman LLP, with a practice that focuses on sophisticated wealth accumulation and preservation planning strategies for entrepreneurs. He is the originator of the idea for the statutory tenancy by the entireties trust (commonly referred to as a “STET,” a termed he coined) that is set forth in Section 3574(f) of Title 12 of Chapter 35 of the Delaware Statutes. This statute was enacted into law in Delaware in July 2010 and became effective on August 1, 2010. His articles, commentaries, and presentations have also served as the impetus for changes to the trust laws of several states. In 2011 and 2012, he assisted the government of Nevis in revising its trust laws (including the Nevis Rule Against Perpetuities) set forth in the Nevis International Exempt Trust Ordinance by rewriting almost the entire ordinance. He was the only attorney in the United States selected by the government of Nevis to work and consult on this project.

Tim Larson has nearly 30 years of professional experience, including public accounting and private industry, and is currently based in his firm’s New York City office. He formerly held senior partner leadership positions at a Big 4 firm as well as other national and regional accounting firms. His extensive and diverse set of skills makes him uniquely adept at understanding the cross-border issues facing complex privately-owned businesses, multinational entities and individuals and providing them with strategic international tax advisory services and creative solutions. Tim specializes in advising multinational corporations on the U.S. tax aspects of cross-border direct and indirect taxation, repatriation and foreign tax credit planning, as well restructuring, acquisition & disposition planning, intellectual property migration, supply chain planning, and transfer pricing. In addition, he assists individuals with inbound tax structuring of investments in U.S. real property and pre-immigration planning, as well as with cross-border tax issues and filings for FINCEN 114 compliance. He is a Certified Public Accountant in the states of New York, New Jersey, and Texas and is also an adjunct tax and financial accounting professor.

As a Co-Chair of the International Taxation & Wealth Planning Practice, Christopher provides wealth management and international tax planning advice to high-net-worth clients, funds and businesses. In recognition of his dedication to developing cutting-edge tax strategies for his clients, Christopher has been named as one of the leading tax attorneys in Florida by Chambers USA. In his practice, he handles a full range of international taxation and wealth issues, including: Foreign pension planning and compliance for individuals and active companies with U.S. employees Domestic and international tax planning for partnerships (e.g., private equity and real estate funds) Domestic and international income tax planning, including Subpart F, GILTI and FDII planning, for closely-held corporations Advice regarding U.S. income and estate tax treaties Tax planning for non-resident individuals, including wealth and estate planning (e.g., trust planning), FIRPTA withholding and pre-immigration tax planning Formation of foreign grantor trusts by foreign settlors (particularly redomiciling Panama Foundations to the United States) Tax compliance and disclosure matters (e.g., submissions to the Streamlined Offshore Procedures, Delinquent FBAR Procedures, Delinquent International Information Return Procedures, etc.) Tax planning for non-resident executives of U.S. companies (e.g., how to minimize exposure to U.S. estate tax regarding their ownership of company stock and stock options as well as other U.S. situs assets such as U.S. portfolios and U.S. real estate) Cross-border employment tax planning for publicly traded corporations.

Michael J. Miller has provided U.S. tax advice to domestic and international clients for more than 25 years. Working with foreign clients, he has structured inbound U.S. investments and operations to avoid the creation of a U.S. permanent establishment and developed structures designed to take advantage of U.S. income tax treaties, the withholding tax exemption for portfolio interest, and other special rules for minimizing U.S. tax. This includes consideration of various anti-abuse rules, such as earnings-stripping limitations and restrictions on the ability to engage in treaty shopping or earn income through hybrid entities. He has worked with U.S. multinationals to structure their foreign investments and operations so as to minimize the impact of certain restrictions on outbound transfers and anti-deferral rules applicable to shareholders of controlled foreign corporations and passive foreign investment companies, as well as maximize the utilization of foreign tax credits. Michael is currently President of the International Tax Institute. He also is co-Chair of the New York University Summer Institute in Taxation: Introduction to International Taxation and Advanced International Taxation. Michael is a former Chair of the U.S. Activities of Foreign Taxpayers Committee of the American Bar Association Tax Section and the Taxation of Business Entities Committee of the New York City Bar. Michael is designated as a leading tax professional in numerous publications, including Chambers USA, Super Lawyers, and Legal Media Group's Expert Guides: Tax Advisors.