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International Tax Conference 2025 IN PERSON

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W Bellevue

10455 NE 5th Pl
Bellevue, WA 98004

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8.5 Credits

Member Price $399.00

Non-Member Price $499.00

Overview

This event is available in-person or virtually. Join us at the 2025 International Tax Conference – the premier event for global tax professionals!

Dive into comprehensive sessions covering critical topics such as Canada/US tax law, the latest updates on foreign trust regulations, and effective planning strategies with US trustees. Benefit from expert insights on Subpart F, Form 5471, inbound and outbound real estate, and detailed case studies tackling complex scenarios like 338G and the PE vs. EGI debate.

Stay ahead of emerging trends with discussions on state and local tax issues, international tax considerations, and the latest expat planning strategies.

Special Offer: Bundle your registration for both the Washington State Tax and International Tax Conferences and save $100! This is your opportunity to enhance your expertise, stay informed on evolving regulations, and network with industry leaders—all at an unbeatable value. Don’t miss out! Use code TAX100—promo code valid until May 13, 2025.
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Highlights

  • Stay informed on the latest developments in foreign trust regulations and planning with U.S. trustees.
  • Gain in-depth knowledge of Subpart F and strategies for navigating complex international tax issues.
  • Explore Form 5471 filing requirements and best practices for compliance.
  • Understand Canada/US tax law issues and cross-border planning strategies.
  • Delve into inbound and outbound real estate tax considerations for global clients.
  • Analyze case studies on complex tax scenarios like 338G and PE vs. EGI.
  • Stay updated on state and local tax issues for international tax professionals.
  • Explore the latest expat planning strategies and updates affecting global taxation.

Prerequisites

None.

Designed For

CPAs, tax advisors, attorneys, financial officers, and other tax professionals working in international tax practice.

Objectives

Stay ahead of emerging trends with discussions on state and local tax issues, international tax considerations, and the latest expat planning strategies.

Preparation

None.

Notice

Exclusive Discounted Room Rate for Conference Attendees

We’re pleased to have secured a special discounted room rate at the W Bellevue, the same hotel hosting the conference.

  • Rate: $459 per night
  • Valid: Wednesday, May 14, 2025
  • Booking Deadline: Monday, April 14, 2025

To secure your room at this exclusive rate, click HERE to be directed to the WSCPA booking page.

Don’t miss out—reserve your stay today!

Thursday, May 15

General Session

- Registrations, Sign-in, and Breakfast

General Session

- Welcome and Announcements

General Session

- Trust Planning for Non-Resident Aliens

Christopher Saddock, Shields Legal Group

Christopher Saddock

Chris Saddock, JD, LLM Taxation, practices business and individual tax planning for high-net-worth individuals and closely-held corporations and partnerships. Chris has an extensive history serving private clients as a tax and business adviser by preparing and implementing complex business and holding structures, as well as maximizing tax efficiencies and ensuring compliance. His areas of practice include U.S. passthrough entity planning, U.S. trust and estate tax planning, mergers and acquisitions, fund formation, startups, cryptocurrency, and international income and estate tax planning.

This session will explore the intricacies of trust planning for Non-Resident Aliens (NRAs) with US-based beneficiaries or US-source income and real estate holdings. Attendees will gain insights into key strategies for effectively structuring trusts to meet tax, legal, and estate planning objectives.

General Session

- Break

General Session

- Subpart F: Key Changes and Future Considerations

Roy Deaver III, Partner, Moss Adams LLP (Consulting Group)

Roy Deaver III

Roy Deaver is a Partner in Moss Adams’ Seattle office. He has over 14 years experience in providing tax services to his clients, the last eight focusing on international tax matters. Roy has worked in both public accounting and in industry allowing him to provide practical tax advice to his clients. Roy has worked closely with his clients to optimize the worldwide effective tax rate and to reduce foreign taxes through, tax-efficient financing, efficient cash management, repatriation of earnings to the U.S., and transfer pricing analysis. Roy has assisted clients in both acquisition and divestiture structuring and in entry into new markets. Additionally, Roy has an extensive background in FAS 109 and its application to foreign subsidiaries.

Explore the impact of the Tax Cuts and Jobs Act (TCJA) on Subpart F, including anticipated changes to Subpart F rules for the 2025 tax year. Attendees will also learn about the application of Section 962 in the context of Subpart F and its relevance to pass-through entities and individuals, focusing on key compliance and planning strategies.

General Session

- Break

Breakout Session

- Concurrent Session A01 | Cross-Border Taxation: Navigating the Canada/US Landscape

Namir Hallak, Andersen LLP

Namir Hallak

Namir Hallak, CPA, CA, CPA (Kansas), CGMA, is a Vancouver, BC-based Tax Partner at Andersen with over 20 years of experience in cross-border tax compliance and planning for multinational Canadian and U.S. corporations. He specializes in advising businesses through international expansion, providing strategic tax insights on cross-border operations, investments, and mergers & acquisitions.

This session provides a strategic overview of key Canada-U.S. tax considerations in cross-border entity structuring, covering tax implications, compliance requirements, and planning strategies to optimize efficiency and mitigate risks for businesses and individuals.

- Concurrent Session A02 | State and Local Tax Considerations in International Tax Planning

Aaron Johnson, Shareholder, Tax Attorney & Professor, Ballard Spahr

Aaron Johnson

Aaron is a partner at Ballard Spahr Lane Powell in Seattle, WA, where he co-leads the firm’s SALT team and represents multinational, U.S., and regional businesses in SALT matters including tax litigation, audit defense, appeals, planning and structuring tax efficient transactions. Previously, he was an experienced tax manager at PwC where he managed a multistate practice and tax controversies, a judicial law clerk, stockbroker and financial advisor, and an enlisted U.S. Army Soldier. He is the WA Bar SALT Committee Chair, a member of the Legislative and founder of the Tax DEI committee; on the ABA SALT Executive Committee; and teaches tax at UW School of Law. He previously taught corp. tax at UW Foster and fed. tax at SPU (20-21 prof. of the year). Aaron is an appointed member of the WA DOR’s Business Advisory Council and an advisory member to the Assoc. of WA Bus. (AWB).

Delve into the complexities of State and Local Tax (SALT) issues in the realm of international tax planning. This session offers a high-level exploration of how state and local tax regulations intersect with cross-border transactions, global business structures, and international tax strategies. Attendees will gain valuable insights into the impact of SALT considerations on multinational operations and the strategic decisions that drive global tax planning.

General Session

- Break

General Session

- Inbound Real Estate: Tax Strategies and Traps for Cross-Border Investments

Mehrdad Ghassemieh, Harlowe & Falk LLP

Mehrdad Ghassemieh

Mehrdad Ghassemieh is a partner at Harlowe & Falk LLP. Mehrdad’s practice includes assisting clients of all sizes on domestic and international matters. This includes consulting with international business owners regarding the tax implications related to establishing new business entities, succession planning, and mergers and acquisitions. His clients include both U.S. based companies that have expanded abroad and foreign companies with U.S. ties. While helping clients in the setup of international structures, Mehrdad routinely helps clients find solutions to Subpart F and taxation on CFCs, taxation of PFICs, foreign tax credit planning, cross border withholding tax and attaining tax treaty benefits. Mehrdad also consults with U.S. based exporting companies to determine whether they qualify for IC-DISC tax incentive benefits, and assists in both implementation and maintenance of IC-DISC structures. Mehrdad is an adjunct professor at the University of Washington School of Law, where he teaches a class in advanced international taxation planning in the law school’s masters in tax program. He is also an adjunct professor at Golden Gate University, in the Masters in Tax Program.

Explore the key considerations and strategies for inbound real estate investments. This session will provide practical insights into navigating the complexities of cross-border real estate transactions and maximizing opportunities for foreign investors.

General Session

- Lunch Break

General Session

- Foreign Corporations and the Check the Box Rules

Philip Hodgen, HodgenLaw PC

Philip Hodgen

Philip D. W. Hodgen is the principal attorney for Hodgen Law Group, which specializes in the international tax arena. He earned his undergraduate degree from Claremont McKenna College and his law degree from the School of Law at the University of California, Los Angeles. He then went on to earn a Master of Laws degree with a specialty in taxation from the University of San Diego School of Law.

Admitted to the California bar in 1982, Mr. Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. For six years of his youth, he lived in Rhodesia, South Africa and New Zealand. Mr. Hodgen 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 for 2004-2007.

Mr. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, real estate professionals and other groups.

Gain an overview of the complex regulations surrounding when you should and should NOT consider check the box regulations for a foreign corporation.  The session will highlight key tax considerations, common pitfalls, and strategies for navigating the intricacies of these regulations.  Attendees will leave with a clearer understanding of how these regulations affect their foreign corporate structures and their tax obligations.

General Session

- Break

General Session

- Mastering Schedule J of Form 5471: Key Insights and Compliance Strategies

Jordan Reichelt, Partner, Spott Lucey & Wall Seattle

Jordan Reichelt

Jordan Reichelt, CPA, is a Partner at Spott, Lucey & Wall, a CPA firm specializing in international tax and cross-border issues. His clients include many investors and entrepreneurs in the real estate, technology, and creative sectors and businesses from around the world. Jordan has developed a special focus on state and local compliance services for multinational businesses and issues involving international trusts and estates. He leads Spott, Lucey & Wall’s Seattle office and is a frequent speaker on international tax topics including GILTI, subpart F, and other CFC issues.

This session will provide an overview of Schedule J of Form 5471, focusing on the reporting of earnings and profits (E&P) for controlled foreign corporations (CFCs). Attendees will gain a high-level understanding of the key compliance requirements, common challenges, and best practices for accurate E&P reporting, along with an update on recent changes to the form.

General Session

- Break

General Session

- TBA

General Session

- Break

General Session

- Expatriation: Key Tax Considerations and Compliance

Jordan Reichelt, Partner, Spott Lucey & Wall Seattle

Jordan Reichelt

Jordan Reichelt, CPA, is a Partner at Spott, Lucey & Wall, a CPA firm specializing in international tax and cross-border issues. His clients include many investors and entrepreneurs in the real estate, technology, and creative sectors and businesses from around the world. Jordan has developed a special focus on state and local compliance services for multinational businesses and issues involving international trusts and estates. He leads Spott, Lucey & Wall’s Seattle office and is a frequent speaker on international tax topics including GILTI, subpart F, and other CFC issues.

Examine the critical tax issues surrounding expatriation, including the legal and financial implications of renouncing U.S. citizenship or long-term residency. This session will cover compliance requirements, tax strategies, and the long-term impact of expatriation decisions.

General Session

- Adjourn

General Session

- Networking Reception

Leader(s):

Leader Bios

Aaron Johnson, Shareholder, Tax Attorney & Professor, Ballard Spahr

Aaron is a partner at Ballard Spahr Lane Powell in Seattle, WA, where he co-leads the firm’s SALT team and represents multinational, U.S., and regional businesses in SALT matters including tax litigation, audit defense, appeals, planning and structuring tax efficient transactions. Previously, he was an experienced tax manager at PwC where he managed a multistate practice and tax controversies, a judicial law clerk, stockbroker and financial advisor, and an enlisted U.S. Army Soldier. He is the WA Bar SALT Committee Chair, a member of the Legislative and founder of the Tax DEI committee; on the ABA SALT Executive Committee; and teaches tax at UW School of Law. He previously taught corp. tax at UW Foster and fed. tax at SPU (20-21 prof. of the year). Aaron is an appointed member of the WA DOR’s Business Advisory Council and an advisory member to the Assoc. of WA Bus. (AWB).

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Christopher Saddock, Shields Legal Group

Chris Saddock, JD, LLM Taxation, practices business and individual tax planning for high-net-worth individuals and closely-held corporations and partnerships. Chris has an extensive history serving private clients as a tax and business adviser by preparing and implementing complex business and holding structures, as well as maximizing tax efficiencies and ensuring compliance. His areas of practice include U.S. passthrough entity planning, U.S. trust and estate tax planning, mergers and acquisitions, fund formation, startups, cryptocurrency, and international income and estate tax planning.

Return to Top

Jordan Reichelt, Partner, Spott Lucey & Wall Seattle

Jordan Reichelt, CPA, is a Partner at Spott, Lucey & Wall, a CPA firm specializing in international tax and cross-border issues. His clients include many investors and entrepreneurs in the real estate, technology, and creative sectors and businesses from around the world. Jordan has developed a special focus on state and local compliance services for multinational businesses and issues involving international trusts and estates. He leads Spott, Lucey & Wall’s Seattle office and is a frequent speaker on international tax topics including GILTI, subpart F, and other CFC issues.

Return to Top

Mehrdad Ghassemieh, Harlowe & Falk LLP

Mehrdad Ghassemieh is a partner at Harlowe & Falk LLP. Mehrdad’s practice includes assisting clients of all sizes on domestic and international matters. This includes consulting with international business owners regarding the tax implications related to establishing new business entities, succession planning, and mergers and acquisitions. His clients include both U.S. based companies that have expanded abroad and foreign companies with U.S. ties. While helping clients in the setup of international structures, Mehrdad routinely helps clients find solutions to Subpart F and taxation on CFCs, taxation of PFICs, foreign tax credit planning, cross border withholding tax and attaining tax treaty benefits. Mehrdad also consults with U.S. based exporting companies to determine whether they qualify for IC-DISC tax incentive benefits, and assists in both implementation and maintenance of IC-DISC structures. Mehrdad is an adjunct professor at the University of Washington School of Law, where he teaches a class in advanced international taxation planning in the law school’s masters in tax program. He is also an adjunct professor at Golden Gate University, in the Masters in Tax Program.

Return to Top

Namir Hallak, Andersen LLP

Namir Hallak, CPA, CA, CPA (Kansas), CGMA, is a Vancouver, BC-based Tax Partner at Andersen with over 20 years of experience in cross-border tax compliance and planning for multinational Canadian and U.S. corporations. He specializes in advising businesses through international expansion, providing strategic tax insights on cross-border operations, investments, and mergers & acquisitions.

Return to Top

Philip Hodgen, HodgenLaw PC

Philip D. W. Hodgen is the principal attorney for Hodgen Law Group, which specializes in the international tax arena. He earned his undergraduate degree from Claremont McKenna College and his law degree from the School of Law at the University of California, Los Angeles. He then went on to earn a Master of Laws degree with a specialty in taxation from the University of San Diego School of Law.

Admitted to the California bar in 1982, Mr. Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. For six years of his youth, he lived in Rhodesia, South Africa and New Zealand. Mr. Hodgen 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 for 2004-2007.

Mr. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, real estate professionals and other groups.

Return to Top

Roy Deaver III, Partner, Moss Adams LLP (Consulting Group)

Roy Deaver is a Partner in Moss Adams’ Seattle office. He has over 14 years experience in providing tax services to his clients, the last eight focusing on international tax matters. Roy has worked in both public accounting and in industry allowing him to provide practical tax advice to his clients. Roy has worked closely with his clients to optimize the worldwide effective tax rate and to reduce foreign taxes through, tax-efficient financing, efficient cash management, repatriation of earnings to the U.S., and transfer pricing analysis. Roy has assisted clients in both acquisition and divestiture structuring and in entry into new markets. Additionally, Roy has an extensive background in FAS 109 and its application to foreign subsidiaries.

Return to Top

Non-Member Price $499.00

Member Price $399.00