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2026 International Tax Conference
There will be 17 international tax panels, including the following:
| Panel | Description |
|---|---|
| Where There is Tariff Evasion, Tax Fraud is not Far Behind | Tariff fraud often creates ripples beyond customs enforcement — leading directly into income tax fraud cases. This panel dissects real-world patterns where undervaluation, false invoicing, and transshipment schemes in customs filings lead to mismatched income declarations and base erosion on both sides of the U.S.–Mexico border. Experts will explore coordinated enforcement between customs, SAT, and IRS investigators. |
| Migration, Expatriation, and Citizenship by Investment: The New Global Landscape with a Trump Gold Card | Explores the movement of capital and people across borders: investment-based residency, “golden visa” programs, and citizenship through investment. Covers U.S. expatriation tax rules (§877A), Mexican residency planning, EU programs, and Caribbean models. Emphasis on both immigration (“I”) and emigration/expatriation (“E”) with global fiscal consequences. |
| Investor Visas, Immigration, and U.S. Tax and Immigration Violations Exposure in an Age of Enforcement | Covers EB-5, E-2, and other investor visas and the tax implications of relocating to the U.S. under the enforcement climate of ICE/IRS. Includes residency tests, pre-immigration planning, and compliance challenges for families and businesses. |
| Valuation Battles in the U.S. Tax Court (Foreign Assets on the Horizon): Lessons from the Estate of Cecil v/ Commissioner – | Examines Cecil v. Commissioner, involving Vanderbilt constructed Biltmore Estate -related valuation disputes. Highlights the lead trial counsel and connects valuation controversies to partnerships, offshore companies, and tax-affecting of pass-throughs. Focus on strategic litigation and methodology. |
| When Tax Regulations Fail: Federal Courts, Partnerships, and Untimely Assessments – JM Assets, LP v. Commissioner (2025) | Focuses on the U.S. Tax Court’s July 2025 decision invalidating partnership regulations, with echoes of Valley Ranch. Discussion of courts striking down IRS/Treasury regulations, implications for statute of limitations, partnership audits, and cross-border entities. |
| H.R. 1: A Comprehensive Review of New International Statutory Law and Impact for Outbound Investments to Mexico | This panel will analyze the international tax provisions enacted in the newly adopted H.R. 1, and their implications for U.S. investors entering or expanding operations in Mexico. Speakers will discuss key statutory changes, planning considerations for outbound investments, and related compliance obligations. |
| Tariff Turbulence: Are We Leaving the Global Era — U.S.–Mexico Opportunities in Commerce and Investment | This session examines how U.S.–Mexico trade and investment flows are evolving and what businesses should anticipate in a shifting tariff environment. Experts will evaluate supply-chain re-routing, relocation incentives, tariff-driven cost pressures, and emerging opportunities amid ongoing uncertainty. |
| State Tax Storm for Mexican Exports to the U.S.: SALT Trends, Revenue Strategies & Cross‑Border Impact | This panel explores how U.S. state tax authorities are increasingly expanding sales tax bases, and targeting Mexican exports. Panelists will discuss key SALT trends, enforcement strategies, litigation, and planning techniques to mitigate risk while navigating an evolving landscape of state-level revenue demands. |
| Invalid Regulations? – What does it mean in the International Tax Planning and Controversy World | This session analyzes which Treasury regulations are most likely to be challenged and the potential consequences for international tax planning, compliance, and controversy. |
| PFIC Planning for Multi-National Families (Not all USC Spouses) | This panel addresses complex PFIC considerations for multinational families, particularly where not all spouses or beneficiaries are U.S. citizens. Panelists will discuss compliance burdens and planning opportunities to avoid punitive outcomes. |
| Probate Litigation at the Border: U.S. & Mexico Estate and Probate Issues, Jurisdiction & Enforcement | This panel will explore the complex landscape of cross‑border probate litigation involving estates that span the United States and Mexico. As individuals increasingly own property, reside partly in one country and partly in another, or have heirs or assets on both sides of the border, practitioners face unique jurisdictional, substantive, procedural and enforcement challenges that don’t arise in purely domestic estates. |
| Analysis of recent court cases related to the interpretation of PPT (under MLI) | This panel provides an in-depth review of recent judicial decisions interpreting the Principal Purpose Test under the OECD’s Multilateral Instrument, highlighting how courts across jurisdictions are shaping the boundaries of anti-abuse standards. Attendees will gain practical guidance on evaluating treaty-based positions, and risk considerations in today’s more aggressive anti-abuse environment. |
| Use of local anti-abuse rules to interpret double tax treaties | This session examines how domestic anti-abuse doctrines—such as substance-over-form, business purpose, and other similar principles—are increasingly being invoked to interpret and apply tax treaties. Panelists will discuss key cases, administrative guidance, and the practical implications for cross-border planning and dispute resolution. |
| World Cup, World Taxes: International Tax Challenges for the Sports and Entertainment Industry | With the 2026 World Cup and other major global sporting and entertainment events on the horizon, this session explores the international tax challenges facing athletes, teams, production companies, and event organizers. Panelists will review sourcing rules, residency issues, withholding obligations and cross-border compliance considerations critical to navigating a complex international tax environment for high-profile performers and events. |
| Tax Reporting Obligations for Assets held in U.S. Trusts | This panel breaks down the U.S. and international reporting requirements applicable to assets held in U.S. trusts, as well as key considerations for foreign beneficiaries. Experts will discuss common compliance pitfalls, information-exchange considerations, and planning opportunities for multinational families with global assets. |
| International Transactions and Latest in Crypto Enforcement – The Tax Man | This session examines the growing intersection of international taxation, digital assets, and increasing global enforcement initiatives. Panelists will discuss cross-border crypto transactions, information-reporting developments, and recent enforcement trends, providing guidance for taxpayers, advisors, and institutions navigating rapidly expanding regulatory scrutiny. |
| U.S.-Mexico Corporate Restructuring with H.R. 1: Exploiting the Tax Incentives and Lowered Rates | This panel analyzes the corporate restructuring opportunities arising from the newly enacted H.R. 1, with a focus on U.S.–Mexico structures. Speakers will review entity classifications, supply-chain redesign, and tax-efficient repatriation alternatives, offering a practical insight into optimizing cross-border corporate models. |
| … | … |
Esteemed Speaker upcoming
2026 Conference in Mérida
Dr. Agustín Carstens
Former Mexican Secretary of Treasury of México, Former Chair of the Mexican Central Bank, and former General Manager of the Bank of International Settlements in Switzerland.
February 16th and 17th, 2026
Mérida, México
SAVE THE DATE
February 16-17th, 2026
Meet Vice Presidents of
Global Tax navigating postelection
changes.
Network with International
Tax Professionals
specializing in Latin
American / U.S. cross
border clients.
Connect with Tax Litigation
Attorneys who handle IRS
litigation.
Identify and engage Heads
of Transfer Pricing from
major multinational
corporations.
Access High-Net-Worth
Family Office Tax Advisors
focused on cross-border
wealth planning.
Find the expertise needed to
navigate cross-border
entity selection and
financing.
Join the Event That’s Changing International Tax
This is more than a conference; it’s the crucible of global tax transformation. The international tax landscape is undergoing its most radical overhaul in decades. By joining us, you aren’t just hearing about the changes—you’re getting the practical blueprint to navigate them.
You will connect directly with the policymakers, technical experts, and industry leaders who are defining the new rules. Walk away with actionable strategies and the foresight needed to manage risk, optimize your global tax structure, and position your organization for growth in this complex new era.
This is where the future of international tax is written. Be a part of it.
2025
International Tax Conference
“It’s a Wrap”
February 17th and 18th, 2025
Mérida, México
THE UNIVERSITY OF SAN DIEGO SCHOOL OF LAW – CHAMBERLAIN INTERNATIONAL TAX INSTITUTE
“It’s A Wrap!” The 2025 International Tax Conference, an amazing two-day journey event.
Save the Date for 2026!
Elevate your expertise at the International Tax Conference! Stay Tuned for the 2026 University of San Diego School of Law – Chamberlain International Tax Institute.
The University of San Diego School of Law - Chamberlain International Tax Institute 