Friday, October 20
1:30PM - 3:30PM
U.S. Activities of Foreigners and Tax Treaties Committee
Chair: William S. Dixon, Citigroup Global Markets Inc., New York, NY.
1:30pm Home Sweet Home Away From Home. The panel will examine
and discuss US federal income, estate and gift tax and associated
practical issues for non-US persons who purchase homes in the
United States. Fact patterns considered will include a foreigner''s
purchase for own use either as a visitor or temporary resident,
purchase for use by relatives visiting or living in the United States
and for rental. Among other important subjects, the panel will
explore the tension between securing preferential treatment for
long-term capital gains and resolving US estate tax issues.
Moderator: Michael Karlin, Law Office of Michael Karlin,
Beverly Hills, CA. Panelist: Stanley Ruchelman, The Ruchelman
Law Firm, New York, NY.
2:05pm Shadow Presence in the United States. This panel will examine
the US tax consequences when a foreign corporation (i) establishes
a headquarters in the United States, (ii) has a senior executive
based in the United States that has overall responsibility
for a worldwide line of business, (iii) engages in a contract
manufacturing arrangement and (iv) has an agent in the United
States. Moderator: Alan W. Granwell, Ivins Phillips & Barker
Chartered, Washington, DC. Panelists: Joseph Calianno,
Grant Thornton LLP, Washington, DC; Danielle E. Rolfes,
Ivins Phillips & Barker Chartered, Washington, DC; Jeffrey L.
Rubinger, Holland & Knight LLP, Fort Lauderdale, FL; William M.
Sharp Sr, Sharp & Associates PA, Tampa, FL.
