Tax & International Business Planning Seminar

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 The Fruits of a Lifetime: Protecting Cross-Border Family Wealth Before Conflict Takes Root 
Patrick W. Martin and Luz E. Villegas-Banuelos

This presentation examines the most common and costly legal, tax, and succession planning mistakes facing Mexican families with wealth, businesses, and family members on both sides of the U.S.-Mexico border. The session explores the intersection of family governance, tax planning, trust structures, and wealth transfer strategies in a cross-border environment. Attendees will learn how disputes often arise from the absence of a shared family vision, inadequate planning for succession or divorce, and the complexities created by differing legal systems in the United States and Mexico. The presentation will also address U.S. tax exposure, information reporting requirements, trust planning considerations, and practical lifetime planning strategies designed to preserve family wealth, minimize tax risks, and promote family harmony across generations.

Top Employee Benefit Issues in Retirement and Welfare Plans for Plan Sponsors 
Joshua A. Sutin

This presentation offers plan sponsors a comprehensive update on the most pressing legal and regulatory developments affecting employee benefit plans in 2026. The session covers welfare plan issues including ACA affordability requirements, COBRA compliance litigation, mental health parity rules and NQTL comparative analysis obligations, HIPAA updates, and emerging gender and family planning coverage disputes, alongside qualified retirement plan topics such as recent ERISA fiduciary duty litigation, 401(k) fee and forfeiture account class actions, SECURE 2.0 mandatory and optional plan amendments, and best practices for fiduciary committees. Drawing on recent case law, DOL and IRS guidance, and regulatory updates, the presentation equips plan sponsors, HR professionals, and their advisors with practical strategies to manage compliance risk and strengthen plan governance in a rapidly evolving benefits landscape.

Coming in from the Cold: Options for Non-Compliant Taxpayers 
Jaime Vasquez and Luis Reyna

Non-filers and other non-compliant taxpayers have a number of potential pathways to resolve their issues with the IRS. This presentation will discuss: the newly revised voluntary disclosure program, streamlined filing procedures, qualified amended returns, and other corrective measures. The focus will be on recent enforcement trends and practical considerations for the strategic decisions applicable to a taxpayer's specific facts and exposure.  

Join us over lunch for a relaxed conversation with the attorneys behind this year's program. In place of a traditional keynote, we're hosting an open forum where you set the agenda. Bring your questions and hear perspectives straight from the practitioners who navigate these issues every day.

 

Tax Consequences of Cross-Border Corporate Distributions 
Anuar Estefan 

This panel will review the income tax consequences of cross-border corporate distributions by a Mexican corporation to its U.S. shareholders and by a U.S. corporation to its Mexican resident shareholders, including treaty reduced rates of withholding, the rules governing the taxation of corporate distribution in the cross-border context and reporting requirements.

Tax Controversy and IRS Enforcement Update 
Jaime Vasquez and Leo Unzeitig 

Topics will include the current state of IRS enforcement, latest IRS audit practices, dealing with documents requests and demands for taxpayer interviews, and best practices in representing clients before the IRS collections division.

Texas Sales and Use Franchise Tax Updates 
Bryan J. Dotson and Zachary Milliken 

This session discusses recent developments in the Texas sales and use and franchise taxes. The discussion will cover key legislative changes, recent court decisions, and amendments to Texas Comptroller regulations.

Tax Treaties and Residency: Oops, Did I Accidentally Expatriate? – The Significance of Aroeste v. United States
Patrick W. Martin and Andres Berdugo 

This presentation will explore how U.S. income tax treaty residency tie-breaker rules apply when an individual has connections to more than one country, with a particular focus on the landmark decision in Aroeste v. United States. We will examine how treaty-based residency determinations can affect the tax status of green card holders and, in some cases, trigger an unintended expatriation under IRC §877A. The program will cover the resulting exit tax regime, compliance and reporting obligations, planning opportunities to avoid unintended consequences, and the long-term impact of the 40% tax imposed on certain covered gifts and bequests from covered expatriates.