International Tax Conference | 5151315A

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Globalization isn't just a buzzword describing our modern economy, it impacts the work of businesses and individuals, and the tax professionals who advise them. Whether your clients are individuals with international holdings, U.S. citizens working in foreign countries, multinational families, families with international business interests, or foreign nationals working in the U.S., you need an understanding of the forms, reporting requirements, standards and regulations required for international tax. This conference offers concurrent sessions to allow you to tailor your education to meet your needs. Clear overviews, insightful discussions and best practices from international tax experts are the hallmarks of this event.

All CalCPA Education Foundation conferences include:

  • Free WiFi
  • Discounted parking
  • Continental breakfast
  • Networking lunch (Plated lunch provided)
  • Afternoon refreshments



  • Outline practical ways to advise foreign individuals or families who are entering or leaving the United States, or who have dual status.
  • Identify new requirements, standards and regulations that impact your international clients and domestic clients with global business interests.
  • Recognize and understand tax, legal and other business matters pertaining to foreign investments.


Major Subjects:

2015 subjects will be updated soon. 2014 major subjects included:

  • Penalties with respect to international tax transactions
  • The government’s carrot and stick approach to Foreign Income and Account Reporting
  • International tax compliance
  • Inbound income tax compliance for individuals
  • Income tax treaties
  • Structuring foreign investment in the U.S.
  • Cross border Social Security and retirement issues
  • Outbound income tax compliance for individuals
  • Pre-immigration tax planning
  • How to prepare and file the disclosures of foreign financial assets: Forms FinCEN 114 and 8938
  • Brains across borders (intellectual property issues)
  • Estate and gift tax compliance for non-citizens
  • Foreign tax credits for U.S.persons
  • Buying real estate and doing business in Mexico



Advanced Prep:


Misc. Information:

Wireless Internet access, continental breakfast and plated lunch will be provided at this event and are included in your registration fee.

Pay the lowest price and save up to 60% with the CalCPA Education Foundation’s discount programs.

To ensure that all credit is properly recorded, please review your information and update your CPA, CFP, CTEC or Bar license number(s).

Level of Difficulty:
Field of Interest:

Basic knowledge of taxation.

Designed For:

CPAs, attorneys and other tax or finance professionals who advise nonresidents with U.S. investments, U.S. citizens living or doing business abroad, as well as individuals and families moving across borders.


John Apuzzo, CBV, CGMA, CMA, CPA, TEP

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).

Gareth Davis, CA

Gareth Davis is a U.K.-qualified Chartered Accountant based in Fitzgerald and Law (F&L)’s San Francisco office, having previously spent six months on assignment at a U.S. CPA firm in Denver. There, Davis immersed himself in the local U.S. regulatory and tax landscape in order to better “translate” the differences between the U.S. and Europe. Having joined F&L in 2007 from PwC in Central London, Davis is able to provide advice on the full spectrum of global expansion issues, with an emphasis on taxation.

Davis has significant experience of advising North American companies in relation to European expansion, and is able to take a uniquely practical and direct approach to everything from tax and accounting through to HR and global mobility. He has become a key point of contact for clients with complex needs – with specific experience advising companies in the high-tech, life sciences, energy, extractives, and retail sectors.

Pamela J. Drucker, Esq.
Pam Drucker is a director at Andersen Tax LLC. She has over 15 years of experience advising clients on domestic and international tax matters. Her clients have included closely-held businesses, middle-market companies and high net worth individuals. Drucker’s practice covers a full-range of domestic and international transactions, including inbound and outbound international structuring and compliance; income and estate tax planning for inbound investments in U.S. real estate; U.S. withholding tax and reporting matters; foreign trust compliance and planning for distributions to U.S. beneficiaries; cross-border structuring and U.S. tax compliance issues for film finance and production companies; planning and compliance for pre-immigration, expatriation and multi-jurisdictional families within U.S. connections; and income tax treaty issues. Before joining Andersen Tax, Drucker worked for Loeb & Loeb LLP and clerked for a U.S. Tax Court judge. She has also worked at national and local accounting and tax firms. Drucker is an adjunct professor for Golden Gate University School of Taxation, teaching Principles of International Taxation. She has also been a co-author of Tax Management U.S. Income Portfolio Civil Tax Penalties. She has been a speaker at seminars on various international tax topics, including those sponsored by Society of Trust and Estate Practitioners (STEP), Los Angeles Bar Association, CalCPA, State Bar of California Taxation Section, Italy-America Chamber of Commerce West, and Los Angeles Chapter of the Tax Executives Institute. She holds her master of laws in taxation from New York University School of Law; her juris doctor degree from Arizona State University College of Law; master of science in taxation from Arizona State University; and her bachelor’s degree in accounting from Arizona State University. She is a member of the Society of Trust and Estate Practitioners (STEP), American Bar Association (ABA), State Bar of California, and the Los Angeles County Bar Association.
Britta M. Eriksson
Britta Eriksson co-founded Euro VAT Refund, Inc. (EuroVAT), in 1992, and has been the company’s president and CEO since the start. EuroVAT is a leading U.S. financial services company specializing in assisting North American companies with value added tax (VAT) management, registration and refund when they do business internationally. Eriksson is today one of the most knowledgeable VAT experts within the United States, frequently informing and working with tax managers within small to medium-sized companies, as well as Fortune 500 companies, the United States Department of Commerce, Revenue Canada, and many of the European embassies, consulates and trade offices in the United States. In addition, Eriksson frequently provides VAT information for articles in newspapers and trade magazines, such as Consumer Report, The Wall Street Journal, The World Academy, Beyond Borders and other trade publications. Among Euro VAT Refund’s 400+ clients are several Fortune 500 companies, as well as small to medium-size companies, event planners, movie production companies and major entertainment companies.
Janet Lynn Everson, Esq.

Janet L. Everson is a civil litigation attorney with a practice emphasizing professional liability defense and general business litigation. She is a shareholder at Murphy Pearson Bradley Feeney (MPBF). She Everson is recognized by the California State Bar as a certified specialist in legal malpractice law. She counsels individual lawyers and accountants, law firms, accounting firms and small to mid-sized businesses, and serves as her law firm’s general counsel. Everson routinely deals directly with the federal and state tax authorities correcting late elections, reducing or eliminating penalties or otherwise mitigating damages before litigation is commenced. Prior to joining Murphy Pearson Bradley Feeney, she served as an adjunct professor at Thomas Jefferson School of Law as the law school’s assistant coach for its 2000-2001 mock trial team.

Everson is a member of the American Bar Association, California State Bar Association, Alameda County Bar Association, and Women Lawyers of Alameda County. She is the founding member of the Association for Professional Women, MPBF; is on the board of the Proctor Elementary School Science Boosters; and is vice chair of the Castro Valley Municipal Advisory Council. Everson is a former vice chair of the Accountants Specialized Litigation Group for DRI. Everson is admitted to practice before all federal and state courts in California as of December 2000; the 9th Circuit Court of Appeals; the 7th Circuit Court of Appeals; the U.S. Tax Court; and the Supreme Court of the United States. She earned her master of laws in taxation from Golden Gate University; her juris doctor degree from Thomas Jefferson School of Law; and her bachelor’s degree from San Diego State University.

Devan Friday, CPA

Devan Friday is a senior tax accountant at Spott, Lucey & Wall, Inc. CPAs in San Francisco. Since 2007, He has been providing accounting and tax compliance services to cross-border individuals and businesses of all types and sizes. He has also developed specific expertise in the U.S. tax implications and compliance of controlled foreign corporations, expatriation implications under IRC Section 877A, and also the U.S. tax treatment of foreign pension and retirement plans. In 2009, Friday was awarded the CalCPA San Francisco Chapter’s Young and Emerging Professional Award for Excellence.

Friday is a CPA and holds a bachelor’s degree in accounting from Pacific Union College and a master’s degree in taxation from Golden Gate University, where his thesis centered around U.S. taxation of foreign retirement plans. Active in the business community, he holds memberships with CalCPA, the Business Association Italy America, and the German American Chamber of Commerce.

Paul C Hoberg, CPA
Paul Hoberg has provided transfer pricing services to clients on the West Coast since 1996. He has assisted numerous clients with analyzing, planning, documenting, and defending their transfer pricing policies and procedures. He has experience in dealing with transfer pricing issues facing companies in various industries including technology, consumer products, manufacturing, and services. Prior to joining Moss Adams in 2010, Hoberg undertook a 22‐month expatriate assignment in Beijing, China, where his responsibilities included advising foreign multinational companies on all aspects of China’s new transfer pricing rules. He is a member of the AICPA, the Washington Society of Certified Public Accountants (WSCPA), and CalCPA.
Philip D.W. Hodgen, Esq, Esq.

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.

E.J. Hong, Esq.
E.J. Hong’s passion for estate planning comes from her heart. She wants to protect families because her own mother died when she was 17 years old. She knows what it's like not to have an estate plan in her own family. Hong approaches each client with the same care and compassion that she brings to her own family. She has been practicing law since 1990 and has been a member of the State Bar of California since 2006. Hong earned her law degree at Washington College of Law, American University. Her professional experience includes serving as clerk to the Honorable Stephen M. Daniels, now chief Judge of the Civilian Board of Contract Appeals; associate attorney (civilian attorney) at the Department of the Navy; and associate attorney at Brand, Lowell and Ryan (litigation firm). While at the Navy, one of the programs she worked on was the procurement contracts for the presidential helicopters, Marine One. She enjoys estate planning the most of all the different types of law she has practiced.
Courtney A. Hopley, Esq.

Courtney A. Hopley serves as Of Counsel at Greenberg Traurig, LLP. She represents clients in federal and state tax controversies before the IRS and the California Franchise Tax Board at the audit, collection, appeals and litigation stages. She works on tax controversy matters involving partnerships, corporations, individuals, real estate and penalty disputes. Hopley also has experience in tax planning involving entity formation, mergers and acquisitions, and reorganization transactions.

Brenda Colburn Jemmott, CPA

Brenda Colburn Jemmott joined RINA in 2006 as a stockholder in the Oakland office. She has provided tax consultation and compliance services to businesses and high-net worth individual for over 13 years. From 2003 to 2006, she worked as a revenue agent for the IRS in their large to mid-size business division. While at the IRS, she audited large corporations from the government perspective. She gained experience with complex corporate transactions and in international taxation.

Jemmott specializes in the area of international tax compliance and consultation, real estate taxation and tax planning for corporate ownership changes. She is the co-chair of RINA’s international tax group and is the head of the tax controversy group. She is skilled at complex corporate tax transactions, planning and analyses. With clients reaching out to global markets, Jemmott provides advice on the U.S. tax consequences of foreign transactions, both inbound and outbound. In the tax controversy area, she knows the procedures of the IRS and can successfully represent taxpayers in tax agency examinations. She provides presentations on commercial real estate tax incentives as well as income tax and legislative updates.

Jemmott’s service specialties include corporate tax transactions, real estate partnerships, tax controversy, international tax compliance and consulting, and multi-state taxation. Her industry specialties include real estate, manufacturing – food and technology based product design, professional services, and management service providers. She earned her bachelor’s degree in accounting from the State University of New York at Plattsburgh in 1995, her California CPA License in 1999, her master of science in taxation from Golden Gate University in 2003, and is the process of earning her international certificate from Golden Gate University. She is a member of the AICPA, on the board of the YMCA of the East Bay, and a member of the San Francisco Bay Area Planning and Urban Research Association (SPUR).

Richard S. Kinyon, Esq.

Richard Kinyon is a partner in the family wealth planning practice group at Shartsis Friese LLP. He specializes in the design and implementation of complex domestic and international estate plans for high-net-worth U.S. resident and nonresident individuals, including the establishment of various sophisticated irrevocable trusts and family investment companies. He also represents fiduciaries and beneficiaries in connection with the administration of estates and trusts, including litigation. Kinyon advises closely held business owner clients how to pass interests in their businesses to younger-generation family members and others in a tax-advantaged and creditor-protected manner. He also advises wealthy individuals on how to similarly transfer their real estate and other investment assets to the objects of their bounty via a family investment company.

Kinyon has lectured for numerous educational institutions, various local estate planning councils, and other organizations. He has authored chapters in California CEB treatises on drafting business buyout agreements, tax planning for the prospective retiree, using family partnerships as an estate planning tool, and the income tax aspects of estates and trusts. He is the author of “Overview of Estate Planning Practice” and “Family Investment Companies” (in California Estate Planning), “Dynasty Trusts” (in Drafting California Irrevocable Trusts), and “Family Investment Companies” (in Business Succession Planning). He also has written a number of articles for the CEB Estate Planning & California Probate Reporter, for which he also has served as guest editor, Estate Planning, Trust & Probate News, ACTEC Law Journal, California Trusts and Estates Quarterly, and other professional publications. Kinyon has been a contributor to, and longtime member of, the advisory board of the UCLA-CEB Estate Planning Institute and a contributor to the University of Santa Clara Jerry A. Kasner Estate Planning Symposium. In 2015, he received the Spirit of CEB Award in recognition of outstanding contributions to the legal profession.

Kinyon has been active in a number of professional organizations for which he has served as chairman, including the Committee on Tax Legislation & Regulations: Income Taxation of Trusts and Estates of the Real Property, Probate & Trust Law Section of the American Bar Association; the Subcommittee on State Inheritance and Gift Taxes of the Estate Planning Committee of the Estate Planning, Probate, and Trust Law Section of the State Bar of California; and the Estate Planning, Trust, and Probate Law Section of the San Francisco Bar Association. Kinyon is a member of the American Law Institute, American College of Trust and Estate Counsel, International Academy of Estate and Trust Law, and Society of Trust and Estate Practitioners (STEP). Kinyon has been certified as a Specialist in Taxation Law by the California Board of Legal Specialization since 1973. He earned his bachelor’s degree, cum laude, from the University of Minnesota, Minneapolis in 1961; and his juris doctor degree, cum laude, from the University of Minnesota Law School in 1965, where he was a member of the Minnesota Law Review from 1963-65 and its editor-in-chief from 1964-65. Kinyon is admitted to the California State Bar, and has been recognized as a leading lawyer by Best Lawyers in America since 1987 and a Super Lawyer by Super Lawyers Magazine since 2004.

Crista M Lucey, CPA
Russell Theodore Mansky, CPA
Russ Mansky has been with Spott, Lucey & Wall, Inc. CPAs since 1997 and is their lead specialist on controlled foreign corporations and expatriation. He provides income tax compliance services to a variety of entities including professional corporations, closely-held corporations and foreign companies. He has extensive experience with Dept. of Commerce filings for international investors and foreign corporations owned by US taxpayers. He is a frequent speaker on US taxation of assets outside the US for various international organizations. Mr. Mansky holds Masters in Taxation with a Certificate in International Taxation from Golden Gate University and a B.S. degree in Accounting from California State University, Hayward.
Rufus von Thülen Rhoades, Esq.

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.

Debra Rudd, CPA

Debra Rudd is a CPA at HodgenLaw PC, a boutique international tax law firm in Pasadena. She has a bachelor’s degree in philosophy from Columbia University and is pursuing a master’s degree in taxation at Golden Gate University.

In addition to managing the firm’s day-to-day operations, she prepares complex tax returns for high net worth individuals and various entities. Focus areas include passive foreign investment companies, controlled foreign corporations, foreign trusts, and foreign investment in U.S. real estate. Russ frequently writes and speaks on various crossborder tax topics for HodgenLaw and CalCPA.

Brett Sipes, CPA
Brett Sipes’ clients suspect he reads tax codes for enjoyment. They may not be far from the truth because he prides himself on understanding the technicalities of complex international tax issues. Sipes has more than 17 years of experience in international tax services. He joined Global Tax Network in 2006 and serves as a director of GTN's Southern California practice. He is responsible for providing tax compliance and consulting to international assignees and their employers. Prior to GTN, Sipes worked in the global mobility area with Ernst & Young, and in international executive services at KPMG. Clients appreciate Sipes for his detail-oriented approach to digging for the right answer, his ability to see the big picture, helping HR directors minimize the costs of an international assignment, and his straightforward answers to complicated tax issues. He earned his bachelor’s degree from Northwestern College in 1997 and is a CPA. Away from work, Sipes enjoys spending as much time as possible outdoors including biking and going to the beach with his wife and four kids.
Kiki Stannard, CTA
Kiki Stannard is a Chartered Tax Advisor (CTA) and is responsible for employment tax issues, international payroll and human resources. Her expertise includes employee reward and incentives, employer tax, and human resource issues. Stannard qualified with PwC in the Thames Valley and has also been awarded the Advanced Certificate in Reward Management with the CIPD. This evidences her particular specialism of providing a perfect mix of both the human resource and taxation expertise required for effective employee reward planning and communication. Her clients range from start-ups, large privately-owned businesses and international groups in a variety of sectors.
Carole J. Trent, CA, CPA

Carole Trent (known as Jodi) joined Kieckhafer Schiffer & Company, LLP in November 2012, bringing 20 years of experience in public accounting. She is an active member of the firm’s family financial services and expatriate tax practices, dividing her time between offices in the Bay Area, Orange County, and Portland. She has extensive knowledge in both compliance and consulting for individuals with inbound and outbound international taxation issues. The experience she gained from a five-plus year rotation in Europe enhances her ability to relate to her clients and help them navigate through the unknown.

Trent’s experience includes assistance structuring inbound and outbound operations for small and middle market clients moving individuals abroad to take advance of the global economy; structuring and implementation of expatriate programs and policies; international payroll consulting and compliance; development of a network of U.S. service providers that can assist with immigration, banking, re-location, insurance, legal structuring and/or compensation services; and compliance and consulting for individuals and their closely held investments. Trent received her bachelor’s degree in accounting from the State University of New York, Binghamton. She also studied public administration at the University of New Orleans where she received her master of public administration degree.

Randy R. Werner, CPA, Esq, Esq.

Randy Werner responds to CAMICO loss prevention hotline inquiries and speaks to CPA groups on various topics. Werner has Big Four public accounting experience in federal and state tax as well as regional accounting firm experience. She has practiced as a sole practitioner in estate planning since 1984.

Werner has been a member of the California State Bar since 1983 and is a member of its Taxation Section as well as the Taxation Section’s Procedure and Litigation Committee. She earned a bachelor’s degree in commerce, majoring in finance with an emphasis in marketing, from the Santa Clara University School of Business. She also earned a juris doctor degree from the Santa Clara University School of Law in 1983, a master of laws in taxation from Golden Gate University, and a master of science in accounting from San Jose State University.


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