Greenberg Traurig Miami Shareholders Jed E. Dwyer and Seth J. Entin spoke at the Florida Institute of Certified Public Accountants (FICPA) 42nd Annual International Tax Conference (ITC), which took place Thursday, January 18, 2024 - Friday, January 19, 2024 at the JW Marriott in Miami, FL. The FICPA and Florida Bar Tax Section's International Tax Conference is tailored specifically for international tax professionals to assist them in the various challenges they will face in this dynamic field.
Jed spoke on the "Piecing it Together: An Inside Look into the IRS Whistleblower Program and Criminal Tax Investigations" presentation. In this presentation, panelists discussed the process of criminal investigations, including how cases are assembled and scrutinized, as well as how the government utilizes whistleblowers to amass evidence from foreign sources, the relevance of tax treaties, strategies employed to encourage witness cooperation, the contribution of whistleblowers, and future expectations in the global sphere of tax enforcement.
Seth spoke on the "Moore and More: Current Challenges to Statutes and Regulations" presentation. This presentation addressed the arguments in and the broader implications of the Moore case that is pending before the United States Supreme Court, as well as other current challenges to international tax statutes and regulations, such as those relating to downward attribution, deemed paid foreign tax credits, and FBAR (and other) filing requirements for dual-resident taxpayers.