Session: International Tax ComplianceBio:
Hill James M
John Apuzzo is an international tax senior director at the Los Angeles office of PricewaterhouseCoopers LLP (PwC). He has over 18 years of experience in assisting his clients with international tax planning, compliance and financial reporting. Apuzzo’s experience has predominantly been related to international tax issues on developing and implementing global supply chain and intellectual property strategies for U.S.-based multinationals. He has also assisted numerous non-US based multinationals restructure their supply chain into the U.S. Apuzzo has significant experience in cross-border M&A including pre-acquisition structuring, due diligence, and post-merger integration. He has served clients in numerous industries, and of various types such as individuals, public companies, and privately-held companies. He has assisted clients in various stages of the corporate lifecycle such as from start-up enterprises assisting them in getting organized through to mature enterprises and assisting these with liquidating some or all of their activities. Apuzzo has assisted numerous families with respect to international transfer tax matters (trust, estate, gift and generation skipping taxes). He is well versed in value chain transformation and prides himself in taking a holistic view to tax planning.
Apuzzo is an Certified Public Accountant (CPA) licensed in California and Illinois. He is also a Chartered Professional Accountant (CPA) in Canada (he earned his Charted Accountant (CA) and Certified Management Accountant (CMA) before the Canadian profession merged into CPA)). In addition, he is a Chartered Business Valuator (CBV), a Trust and Estate Practitioner (TEP) with the Society of Trust and Estate Practitioners (STEP), and a Certified Global Management Accountant (CGMA). Apuzzo earned his graduate diploma in public accountancy from McGill University, has a master of U.S. taxation from William Howard Taft University, and earned a master of international taxation from Regent University. He is a member of the AICPA, CalCPA, Illinois CPA Society (ILCPA), Canadian Institute of Chartered Business Valuators (CICBV), and Chartered Professional Accountant (CPA Canada).
Session: Managing Transfer Pricing Issues and OpportunitiesBio:
Hodgen Philip D.W.
Jim Hill, Esq. CPA is the Director of Transfer Pricing at Grant Thornton LLP’s Southern California tax practice, covering the West Coast. Hill has practiced in the areas of transfer pricing and international taxation at Big Four accounting firms for the last 14 years, and has more than 23 years of experience working on tax and business matters in public accounting and law firms. With a broad background in law and business, Hill approaches transfer pricing as a business consulting. His economic, accounting and tax advice is practical, maximizes clients’ business goals and objectives, and complies with U.S. and foreign transfer pricing and tax rules and regulations. His recent engagements include completing transfer pricing planning and documentation studies, intangible migration projects, advance pricing agreement requests, assisting clients in resolving IRS and foreign tax authority examinations, and performing ASC 740/FIN 48 analyses for financial statement disclosures. He also assists clients with due diligence, and post- merger integration, in merger and acquisition transactions. Hill has worked with clients in a variety of industries, including technology, consumer products, real estate, retail, entertainment, tax-exempt hospitals, business services, mining and manufacturing. He is a member of AICPA, CalCPA, the American Bar Association, and the California State Bar.
Session: How to Handle an Expatriation ClientBio:
Philip D. W. Hodgen is the principal attorney for HodgenLaw PC, which specializes in the international tax arena. He earned his bachelor’s degree from Claremont McKenna College and his juris doctor degree from the School of Law at the University of California, Los Angeles. He went on to earn a master of laws in taxation from the University of San Diego School of Law. For six years as a youth, he lived in Rhodesia, South Africa and New Zealand.
Admitted to the California Bar in 1982, Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. He is a past chair of the International Tax Committee of the State Bar of California’s Tax Section, and was a member of the Executive Committee of the State Bar of California’s Tax Section from 2004-07. He is on the Organizing Committee for CalCPA’s International Tax Conference and its annual Tax Update and Planning Conference. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, bankers, and real estate professionals.
Session: Pre-Arrival Tax Planning for High Net-Worth Families and ExecutivesBio:
Mattson Andrew Marcus
Cindy Hsieh joined Crowe Horwath LLP as a tax director in 2017. She was previously with Rowbotham International since 2001. Her experience includes providing tax consulting and compliance services for domestic and international businesses, and high net worth individuals. Hsieh specializes in tax planning and estate tax planning for multinational families and has clients in the venture capital, high technology, and real estate sectors. She received her bachelor’s degree from the University of California, Berkeley and is continuing her studies for her master’s degree in taxation at Golden Gate University. Hsieh has been an active member of the AICPA International Taskforce since 2008 as well as committee member of CalCPA’s Annual International Tax Conference. She speaks fluent Mandarin.
Session: Expatriate and Alien TaxationBio:
McBride Gary R.
Andy Mattson, CPA is a partner with the Silicon Valley office of Moss Adams. He has been providing tax solutions to start-ups and other technology companies in Silicon Valley since 1985. His specialties include corporate, partnership, and individual tax and compensation planning; stock option taxation and planning; and international taxation. He has worked with IBM, Siemens, LSI Logic, Juniper Networks, and National Semiconductor. He had been with Mohler, Nixon & Williams since 1989, which in 2013 merged into Moss Adams, and before that was with Price Waterhouse in San Jose. Mattson has been nationally recognized for his involvement with and contributions to the AICPA to help shape tax policy and rules. He is a member of CalCPA and of the AICPA, and serves as an appointed member of the AICPA’s IRS Practices & Procedures Committee. He previously served on the AICPA’s Tax Executive Committee and the AICPA's International Taxation Technical Resource Panel, and was its chair for three years.
Mattson has had numerous international taxation articles published, including “FATCA Withholding on Payments to Nonfinancial Foreign Entities: A Broad New Requirement” (The Tax Advisor, October 2013); “FATCA Adds Layer of Complexity, Penalty Exposure to Offshore Asset Reporting” (The Tax Advisor, April 2012); and “Codification of Economic Substance Affects All Tax Practitioners” (The Tax Advisor, August 2011). His speaking engagements include the AICPA Doing Business in Brazil Conference (July 2013); AICPA Tax Planning Compliance & Controversy Conference (May 2013); AICPA Small Business Practitioners Tax Conference (May 2012); CalCPA International Tax & Business Conference (December 2011); and CalCPA Tax Update & Planning Conference (November 2011). He holds a bachelor’s degree in business administration with emphases in finance and accounting from the University of Southern California.
Session: International Tax Pitfalls and PenaltiesBio:
Neff Thomas Edward
Gary R. McBride is a principal in Summit Accountancy Group, Inc.; a professor emeritus at California State University, East Bay; and former director of the Graduate Tax Program. He is a licensed attorney and certified public accountant. He worked for the Internal Revenue Service as a revenue agent, special agent, and technical advisor at the IRS National Office. He is author and presenter of four CPE courses for the CalCPA Education Foundation: Federal and California Tax Update for Individuals (with professor Annette Nellen); Federal and California Tax Update for Businesses and Estates (with professor Annette Nellen); Partnerships and LLCs Part I: Formation, Operation, and Allocations; and Federal Taxation of Partnerships and LLCs Part II: Sales, Distributions, Redemptions, and Liquidations. McBride earned his master of laws in taxation degree in 1987 from Georgetown University; his juris doctor degree in 1981 from Hastings College of Law, and his bachelor’s degree (emphasizing accounting and finance) in 1975 from the University of California, Berkeley.
Session: Fundamentals of U.S. International TaxBio:
Redko Elena N
Thomas Neff, CPA, has been with RINA accountancy corporation for 12 years and has been a tax stockholder since 2009. He is currently head of the Oakland office and chair of the firm’s international tax group. His career began in New York, working for five years with a large Wall Street law firm; since then he has had over 20 years of experience working in international tax with accounting firms in San Francisco, New York and the U.S. Virgin Islands. His specialties are transfer pricing, inbound and outbound tax planning for businesses, and IC-DISC planning. Neff received a bachelor’s degree in accounting from the University of Dayton and a master’s degree in taxation from Golden Gate University. He is a frequent speaker and has been collaborating for several years with the U.S. Department of Commerce as a speaker and sponsor of their export trade events.
Session: Passive Foreign Investment Companies (PFICs) for Experienced ProfessionalsBio:
Rhoades Rufus von Thülen
Elena Redko, CPA graduated from UCLA with a degree in global studies and accounting. She was recruited by Ernst & Young during her junior year and started working there as a staff tax accountant shortly after graduation. After a year of contemplating her career choice, Redko discovered HodgenLaw PC and has been working there happily for the past four years. Redko is a CPA and loves solving the kind of problems that make other CPAs slowly back away. International tax is her passion, and is something that she has heavily pursued from her very first days in professional accounting, and which she continues to thoroughly enjoy every day.
Session: Portfolio Interest: A Congressional Gift to PractitionersBio:
Wall Charlotte D
Rufus von Thülen Rhoades practices all facets of federal and state income tax matters, involving controversy work with the IRS and the California Franchise Tax Board on a wide variety of issues, and tax planning on an equally-wide variety of transactions. He earned his law degree from Stanford University School of Law in 1959, where he was a member of the Stanford Law Review, and his bachelor’s degree from Stanford University in 1954. He was admitted to the California Bar in 1962 and the New York Bar in 1960. His prior associations include Cravath, Swaine & Moore, New York; Lillick, McHose, Wheat, Adams & Charles (Los Angeles), where he was head of the tax department; Retla Steamship Co., a Liberian corporation, where he was vice president and general counsel; and the U.S. Navy (Reserve) where he served as a Lieutenant (junior grade) (LTJG). His professional affiliations include the State Bar of California, the Los Angeles County Bar Association Section on Taxation and Real Estate, the New York Bar Association, and the American Bar Association. He is a past chairman of the Los Angeles County Bar Section on Taxation, and the Foreign Tax Committee. He is a past member of the executive committee of the Section on Real Estate of the International Fiscal Association, and the International Tax Forum. He is co-author with Marshall J. Langer of Rhoades & Langer, U.S. International Taxation and Tax Treaties, a six-volume treatise published by Matthew Bender & Co. that is revised four times a year (now in its 143rd revision) with over 2,500 copies sold worldwide. He is also co-editor with Richard Chernick and Daniel Kolkey of A Practitioner’s Guide to International Arbitration and Mediation published by Juris Publishing (March 2005). For a number of years he was co-author of the “International Tax Notes” column for California Tax Lawyer, a regular publication of the California State Bar Section on Taxation, and he has written numerous articles and outlines in the field of U.S. taxation on all aspects of international taxation for various law journals, law reviews and institutes.
Rhoades is recipient of the Dana Latham Memorial Award for Lifetime Achievement in Taxation presented by the Los Angeles County Bar Association Section on Taxation (presented by the honorable Pamela A. Rymer, U.S. Ninth Circuit), and the Joanne Garvey Award presented by the California State Bar Section on Taxation for substantial lifetime contributions to the field of tax law. He has also received the Distinguished Professor Richard C. Pugh International Tax Award, presented by the University of San Diego School of Law/Procopio Tax Institute. He has drafted a gross income tax law for the Island of Palau at the request of the United States Department of Interior, and drafted various resolutions for adoption by local agencies. He has also drafted a part of the Internal Revenue Code dealing with the U.S. Virgin Islands. He served as an adjunct professor of law at the University of San Diego, teaching courses dealing with international tax issues (2006-2009), and previously served as an adjunct professor of law at the University of Southern California School of Law, teaching courses on corporate taxation and on international taxation; a lecturer for the Practicing Law Institute, New York on international tax matters; and also taught Medical College Aptitude Test (MCAT) preparatory courses on the subjects of clear writing and critical thinking for a number of years. He has also taught various seminars on specific subjects of international taxation. He is a pilot (IFR-rated), a duplicate bridge (bronze life master), and was appointed by the IRS as one of four Californians to the 30-member IRS panel of arbitrators. He is a member of the Pasadena Rotary; Athenaeum/CalTech (since 1984); American Contract Bridge League; and Aircraft Owners and Pilots Association. His charitable activities include service as a volunteer pilot for Angel Flight and as chair of foundation giving for the Five Acres Homes for Abused Children. He is also a judge for the Moot Court Program and an attorney advisor to participant schools for the Constitutional Rights Foundation, and active fundraising for Stanford Law School. He is AV-rated by the Martindale-Hubbell Bar Register of Preeminent Lawyers.
Session: Foreign Business Investment in the U.S.: What you need to know!Bio:
Charlotte Wall is a shareholder of the firm Spott, Lucey & Wall, Inc. The firm works with foreign corporations investing in or owning U.S. businesses, U.S. businesses investing in or owning foreign businesses, foreign citizens working in the U.S., as well as U.S. citizens and residents working abroad. Currently over 85 percent of the firm’s clients have international issues. She is in charge of all of the firm’s real estate clients (landlords, developers, brokers, etc). In addition, Wall handles all of the firm’s multi-state consulting and technology companies. Her foreign clients are from about 25 different countries – predominately Germany, England, Australia, Sweden, and Canada.
Wall serves as vice president of the board of the San Francisco chapter of CalCPA; on the board of the Swedish American Chamber of Commerce; and on the scholarship committee of the Financial Women’s Association (FWA). She graduated from California State University, Hayward (1990) with a bachelor’s degree in business administration with an option in accounting. She completed her master’s degree in taxation (2000) and certificate in international taxation (2003) from Golden Gate University.