ESTATE PLANNING COUNCIL OF NORTHERN NEVADA

Daniel C. Silva

Daniel C. Silva is a shareholder at Buchalter, where he represents businesses and individuals in criminal, civil, and regulatory matters, with depth in complex financial crimes, enforcement actions, and advising financial institutions with anti-money laundering compliance, internal investigations, and digital currencies. He brings the strength of a former federal prosecutor and an in-house global risk counsel at a fintech startup. Danny has been the architect and quarterback of hundreds of investigations, with multi billions of dollars in play. Danny’s vast experience with regulatory authorities include the SEC, FinCEN, IRS, OFAC, CFPB, CFTC, Federal Reserve Board, OCC, FDIC, and the Department of Defense. In addition to his J.D., Danny has an LL.M. in taxation and an MBA with a concentration in international business.

As part of its commitment to safeguarding the U.S. financial system, the Departments of Justice and Treasury investigate financial institutions, professional tax and financial advisers, and other “enablers” of international tax evasion. In the wake of increasing media scrutiny, U.S. laws and law enforcement have strengthened in the past few years, making it easier to prosecute or financially punish those who exploit tax loopholes or participate in international fraud. Daniel C. Silva will explore the impact of the Corporate Transparency Act, Foreign Account Tax Compliance Act, and recent enhancements to America’s anti-money laundering laws. The conversation will cover how these developments, individually and combined, increase the risks for anyone advising on, or benefitting from, complex trust, corporate, and international tax vehicles.

Michelle Rizzo

Michelle Rizzo is an international tax advisor and certified public accountant. She is the founding member of Rizzo Tax LLC. Michelle works with both individual taxpayers and businesses that have international tax aspects to their situations. She also works frequently with other accounting firms that have clients with international tax issues.

She provides international tax compliance and consulting services and works regularly with controlled foreign corporations, foreign controlled US corporations, foreign partnerships, passive foreign investment companies, foreign disregarded entities, subpart f, GILTI, and the transition tax. She also assists taxpayers with various structuring needs, foreign asset reporting, and IRS amnesty programs.

She graduated with a Master’s in Business Administration from LaSalle University in 2008 and with a Master of Studies in Law (Taxation) from New York University in 2020.

Today, more so than ever, international tax issues pop up in every day tax return preparation.  If practitioners aren’t aware of what to look out for, they can find themselves in a field of landmines.  We will cover the Top 10 international tax issues to look out for when preparing returns, and we’ll do it David Letterman style.

We want to thank our sponsors: Whittier Trust, Morgan Stanley, Dickson Realty, Aguirre Riley, Dunham Trust, Alliance Trust, Prunty Law, Elaine Jenks, CPA, Navolio & Tallman LLP