Session: U.S. International Tax ComplianceBio:
Dellinger Arthur J.
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).
(Cooper, Moss, Resnick, Klein & Co., LLP)
Session: FIN 48 R/Transfer PricingBio:
Kaplan Gary P.
As senior tax partner at Cooper Moss Resnick Klein & Co. LLP, Kip Dellinger provides services as an expert in the areas of CPA tax practice regulatory discipline and malpractice matters; this includes his engagement by Big 4 CPA firms as an expert pertaining to conduct matters and substantive technical issues in several tax shelter malpractice cases. He also represents clients in tax controversy matters and provides services to tax counsel in civil tax matters. He has written several dozen articles and is a nationally recognized speaker in the areas of tax standards and tax procedure and technical tax matters. Dellinger is a recipient of the Saul Braverman Memorial Award of the CalCPA’s Committee on Taxation for distinguished service in tax practice. He is the recipient of the CalCPA Education Foundation’s 2013-2014 Award for Instructor Excellence, and is a recipient of a 2015 APEX Award for Publication Excellence for Feature Writing. He wrote the “Policy and Practice” column for Tax Notes magazine for several years, is the former columnist for tax practitioner conduct standards and ethics for TAXES (CCH) magazine, and is quoted multiple times in As Sure As Death (2015 edition), a leading compendium of quotations about taxes.
Dellinger serves on the AICPA Tax Division’s Tax Executive Committee and is a past chair of the AICPA Tax Division’s Tax Practice Responsibilities Committee and is the author of the Practical Guide to Federal Tax Practice Standards (CCH, 2007). He developed and teaches full-day courses on tax practice standards, conduct and quality control for California CPAs and quality control in a tax practice for the CalCPA Education Foundation. He also co-authors and teaches courses in avoiding tax malpractice and tax practice and procedure for California CPAs for the Foundation. Dellinger has spoken before the USC Law School Institute on Federal Taxation, the AICPA National Tax Conference, the UCLA Tax Controversy Institute, the Illinois Society of CPAs, the Florida Institute of CPAs, the Tennessee Society of CPAs and the California Tax Bar on multiple occasions. He is frequent speaker before other CPA and tax attorney conferences, meetings and discussion groups and has presented several national webcasts for CCH on the topics of FIN 48 for private companies, federal tax practice standards, and tax practice quality control matters and foreign income tax reporting and disclosure. Dellinger joined Cooper Moss Resnick Klein & Co. LLP in the San Fernando Valley in January 2012. He continues to maintain an office in Santa Monica.
Session: Dealing with PFICs and Related Reporting ProblemsBio:
Rhoades Rufus von Thülen
GARY P. KAPLAN, ESQ.
Gary P. Kaplan is a partner in the firm's Tax group. He focuses his practice on international taxation and business transactions, representing US and international clients in connection with cross-border taxation and mergers, acquisitions, joint ventures and other strategic relationships, and developing structures for conducting their global business and investment activities.
Mr. Kaplan has structured operations of US multinationals including developing tax-efficient international expansion plans, setting up international holding companies, establishing foreign representative offices, branches and subsidiaries, advising on Subpart F and passive foreign investment company issues and preparing intellectual property cost-sharing and buy-in agreements. He has created transfer pricing strategies including the use of favorable jurisdictions, tax holidays and special enterprise zones, as well as foreign tax credit utilization and profit repatriation plans. For families and family office clients, he has established offshore investment funds, foreign estate and asset protection plans, foreign registered charities and foundations, foreign insurance and annuity programs, and has advised on expatriation and non-US trust planning.
Mr. Kaplan also represents non-US companies engaged in US business and investment activities. Many of these companies have listed or are planning to list shares in the United States. Mr. Kaplan also undertakes FIRPTA planning for non-US real estate developers and investors.
Mr. Kaplan taught for many years as an adjunct professor in the graduate tax program at New York University School of Law and has served as guest lecturer in tax at Stanford Law School and University of California at Berkeley. He has taught foreign tax, tax treaties, tax accounting, real estate planning and taxation of debt discharge; has written numerous articles in many of these areas; and is a frequent lecturer at national and international tax seminars.
Mr. Kaplan is currently listed in The Best Lawyers in America in the field of Tax Law. Most recently, he was ranked in the 2012 and 2011 editions of Chambers USA as a leading practitioner of tax law. He was also selected for inclusion in Northern California Super Lawyers in 2004, 2006 through 2008, 2010 and 2011, and is an AV-rated attorney, a peer-awarded honor given by Martindale-Hubbell.
(Law Offices Rufus v. Rhoades)
Session: Recent DevelopmentsBio:
Robbins Edward M.
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.
(Hochman Salkin Toscher & Perez)
Session: Offshore Voluntary Disclosure InitiativeBio:
Edward Robbins is a principal at Hochman, Salkin, Rettig, Toscher & Perez, P.C. He has considerable experience handling sensitive issue civil examinations and administrative appeals, civil trials and appeals defending complex criminal tax investigations, civil trials and appeals, and defending criminal tax prosecutions (jury and non-jury). He has successfully handled literally hundreds of matters involving previously undeclared interests in foreign financial accounts and assets. Representation currently includes federal and California civil tax and criminal tax litigation together with civil tax and criminal tax controversy administrative matters before the Internal Revenue Service, the California Franchise Tax Board, the California State Board of Equalization, California Employment Development Department and various state taxing authorities of individuals, business enterprises, partnerships, limited liability companies, and corporations. Representation also includes individuals and organizations involved as targets, subjects, or witnesses in Federal and California criminal investigations and related grand jury and pre-trial proceedings, trials and appeals.
In the world of civil tax and criminal tax investigations, Robbins has truly touched every conceivable issue during his lengthy and successful career. His awards and honors include IRS Criminal Investigations Outstanding National Criminal Tax Prosecutor, 2004; U.S Department of Justice, Employee Volunteer Service Award, 2002; IRS Criminal Investigations Award, 2002; Law Enforcement Award, Internal Revenue Service, Criminal Investigation, Los Angeles Field Office, 2001; Trial Instructor, Attorney General’s Advocacy Institute, 1988-2004; U.S. Department of Justice, Special Commendation Award, 1990; U.S. Department of Justice, Special Commendation Award, 1986; and IRS Chief Counsel Special Achievement Award, 1982. He is also certified as a Certified Specialist in Taxation Law by The State Bar of California, Board of Legal Specialization.
Robbins served as Assistant United States Attorney, Central District of California, Tax Division, Office of the United States Attorney; Chief of Tax Division, 1994-2004; Assistant Division Chief, 1988-1994; and Assistant United States Attorney, 1983-2004. As Chief of the Tax Division, Central District of California’s United States Attorney’s Office, he handled a full caseload specializing in complex civil and criminal tax litigation. In addition to his litigation duties he was responsible for the management and coordination of the Tax Division’s tax cases and supervised the Special AUSAs in bankruptcy matters and worked with the Assistant Attorney General (Tax) to develop and ensure uniform national tax policy. Robbins represented the government in a variety of federal criminal tax prosecutions and civil tax actions and proceedings before the United States District Court, the United States Bankruptcy Court, the United States Bankruptcy Appellate Panel and the state courts. He handled numerous civil and criminal tax cases and matters. He served as a Senior Trial Attorney for the Internal Revenue Service from 1978-1983.
Robbins earned his bachelor’s degree from Ohio State University with honors in 1971; his juris doctor degree with honors from Golden Gate University in 1978; and his master of laws in taxation from the University of San Diego, magna cum laude, in 1984. He is admitted to practice before the U.S. Court of Appeals, Eighth Circuit, Ninth Circuit, D.C. Circuit; U.S. District Court, Central, Eastern, Northern and Southern Districts of California, District of Hawaii; U.S. Claims Court; U.S. Tax Court; State Bar of California; State Bar of Hawaii; and the District of Columbia Bar. Robbins is a frequent speaker on civil and criminal tax practice, procedure, controversy and litigation matters, appearing before government agencies and professional organizations, including the American Bar Association, the State Bar of California, UCLA Annual Tax Controversy Institute, Los Angeles County Bar and the Tax Executives Institute.
Robbins has served as an adjunct faculty member of Loyola Law School since 2000, where he has taught classes on federal civil tax procedure and federal criminal tax and criminal tax procedure. From 1996 to 2000, he was an adjunct faculty member of the Golden Gate University School of Law where he taught federal civil tax procedure. He is a member of the American College of Tax Counsel (2012) and the UCLA Extension Annual Tax Controversy Institute, and has been an advisory board member and panelist of the Association of Tax Counsel since 1998. He is also a member of the State Bar of California, Taxation Section; the Beverly Hills Bar Association, Taxation Section; the Los Angeles County Bar Association, Taxation Section; and the American Bar Association, Taxation Section. He is also a delegate to the California State Bar Conference. Robbins is frequently quoted in the national press on tax issues; Google “Edward Robbins Tax.”
Session: Using Foreign Trusts for Fun and ProfitBio:
Wall Charlotte D
Peter Trieu, Esq., LLM, is a Tax Director at Rowbotham & Company. His practice focuses on advising clients regarding domestic and international tax planning and compliance. He also assists clients with estate planning and asset preservation using trusts- foreign and domestic. Mr. Trieu's clients include entrepreneurs, multi-national families, high net-worth individuals and businesses. He is an attorney licensed to practice law in California. He earned a Bachelor of Arts in Business-Economics with a minor in Accounting from University of California, Los Angeles. Mr. Trieu graduated cum laude from University of California, Hastings College of Law. His concentration at Hastings was in taxation, where he received numerous awards, including the American Jurisprudence Award for Taxation of Family Wealth Transfers and for Federal Income Taxation. Mr. Trieu also received his Master of Laws (LL.M.) in Taxation with honors from Golden Gate University. Also a writer, Mr. Trieu co-authored "Doing Business in India" published in the May/June 2009 issue of CalCPA magazine. Prior to joining his current firm, Mr. Trieu worked for several years as a Trusts and Estates attorney.
(Spott Lucey & Wall Inc CPAs)
Session: Controlled Foreign Corporations (CFCs)Bio:
Wright Douglas W.
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.
Session: Nuts and Bolts of International ExpansionBio:
Douglas Wright is partner-in-charge, international tax and transfer pricing services at Burr Pilger Mayer, Inc. He has over 30 years of experience as an international tax and transfer pricing specialist servicing global clients from start-ups to Fortune 50 companies in a wide range of industries, including technology, life sciences, e-commerce, agriculture, and traditional manufacturing and distribution. Some of Wright’s more notable clients have included Hewlett-Packard, Oracle, Electronic Arts, McKinsey & Co., Johns Manville, Polycom, Varian, Applied Materials, and Greater Omaha Packing. Wright was previously a PricewaterhouseCoopers (PwC) international tax partner, where he served in various Bay Area and national practice leadership roles. Prior to PwC, he was European tax director for Levi Strauss in Brussels. Wright began his career and spent eight years with Exxon Corporation, including three years as European tax counsel in London.
Wright’s international tax expertise includes international IP exploitation, including development and implementation of outbound U.S. IP migration structures; complex outbound and inbound corporate and supply-chain structuring; international joint ventures and M&A transactions; earnings repatriation planning; and the U.S. Subpart F, PFIC, and foreign tax credit rules. He is also a widely-recognized expert on the IC-DISC U.S. export tax incentive regime. His IC-DISC clients include several top-10 U.S. commodities exporters, as well as small-to-large closely held companies throughout the United States in a wide range of industries, including agriculture growers and processors, high-tech, software, consumer goods, and engineering and architectural services. Wright’s extensive transfer pricing experience includes development and implementation of global transfer pricing strategies; U.S. and foreign transfer pricing studies and documentation; and negotiation of U.S. and foreign advance pricing agreements. He was principal draftsperson of U.S. oil industry comments to an IRS transfer pricing task force, and of American Electronics Association comments to then-proposed U.S. R&D “cost sharing” regulations. Wright was instrumental in negotiating the first U.S./Belgium bilateral APA and a historically-favorable Dutch transfer pricing ruling.
Wright has been an adjunct international tax professor at UCSF Hastings Law School and the San Jose State University MST program, and speaks frequently at seminars throughout the United States. He serves on the board of directors of NorCal World Trade Center, and is a former director of the Santa Clara County Special Olympics. Wright holds his bachelor’s degree from Santa Clara University; his juris doctor degree from Boston College Law School; and his master of laws in taxation from New York University.