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February 16-17th, 2026
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2026 International Tax Conference
International Tax Conference
Where to Stay
Tours
2026 Agenda
Monday, February 16, 2026
| Time | Panel |
| 8:00-8:50 | Registration & Continental Breakfast |
| 9:00-10:00 | 1-A: Use of local anti-abuse rules in the International Context |
| 10:10-11:10 | 2-A: International Transactions and Latest in Crypto Enforcement- The Tax Man — 2-B: Migration, Expatriation, and Citizenship by Investment: The New Global Landscape with a Trump Gold Card |
| 11:10-11:30 | Break (Snacks & Refreshments) |
| 11:30-12:20 | 3-A: World Cup, World Taxes: International Tax Challenges for the Sports and Entertainment Industry — 3-B: H.R. 1: A Comprehensive Review of New International Statutory Law and Impact for Outbound Investments to Mexico |
| 12:30-13:20 | 4-A: Probate Litigation at the Border: U.S. & Mexico Estate and Probate Issues, Jurisdiction & Enforcement — 4-B: State Tax Storm for Mexican Exports to the U.S.: SALT Trends, Revenue Strategies & Cross‑Border Impact |
| 13:30-14:50 | Lunch |
| 15:00-16:00 | 5-A: When Tax Regulations Fail: Federal Courts, Partnerships, and Untimely Assessments – JM Assets, LP v. Commissioner (2025) — 5-B: PFIC Planning for Multi-National Families (Not all USC Spouses) |
| 16:10-17:10 | 6-A: Valuation Battles in the U.S. Tax Court (Foreign Assets on the Horizon): Lessons from the Estate of Cecil v/ Commissioner |
Tuesday, February 17, 2026
| Time | Panel |
| 8:00-8:50 | Breakfast |
| 9:00-9:50 | 7-A: Where There is Tariff Evasion, Tax Fraud is not Far Behind |
| 10:00-10:50 | 8-A: Tariff Turbulence: Are We Leaving the Global Era — U.S.–Mexico Opportunities in Commerce and Investment — 8-B: Tax Reporting Obligations for Assets Held in U.S. (“foreign”) Trusts |
| 10:50-11:15 | Break (Snacks & Refreshments) |
| 11:15-12:05 | 9-A: Invalid Regulations? – What does it mean in the International Tax Planning and Controversy World — 9-B: U.S.-Mexico Corporate Restructuring with H.R. 1: Exploiting the Tax Incentives and Lowered Rates |
| 12:15-13:05 | 10-A: Investor Visas, Immigration, and U.S. Tax and Immigration Violations Exposure in the Age of Enforcement |
| 13:15-14:15 | 11-A: Fireside Chat with Former Secretary of Treasury and Central Bank Governor Agustin Carstens and Luis Urrutia |
2026 Panels & Speakers
| Panel | Description | Speaker |
|---|---|---|
| Fireside Chat with Former Secretary of Treasury and Central Bank Governor Agustin Carstens and Luis Urrutia | Luis Urrutia is a leading global expert in financial law and regulation, having served as President of the Financial Action Task Force (FATF), General Counsel of the Central Bank of Mexico, and Deputy General Counsel at the International Monetary Fund. Agustín Carstens is a globally respected economic leader and former Secretary of the Treasury and Central Bank Governor of Mexico, with a distinguished career in monetary policy and global financial stability. | Agustin Carstens Luis Urrutia Corral Patrick W. Martin |
| 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. | Wazirah Allen Jeffrey Adam Neiman Steven Toscher |
| Migration, Expatriation, and Citizenship by Investment: The New Global Landscape with a Trump Gold Card | The panelists will explore and discuss 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. | Héctor González Legorreta Dr. Kristin Surak Patrick W. Martin |
| Investor Visas, Immigration, and U.S. Tax and Immigration Violations Exposure in an Age of Enforcement | This panel will cover 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 in Mexico and the United States. | Luz E. Villegas Matthew Meyers Elizabeth González Gasca |
| Valuation Battles in the U.S. Tax Court (Foreign Assets on the Horizon): Lessons from the Estate of Cecil v/ Commissioner | This presentation will examine in detail the decision in 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. | David Aughtry Patrick W. Martin Carsten Hoffmann |
| When Tax Regulations Fail: Federal Courts, Partnerships, and Untimely Assessments – JM Assets, LP v. Commissioner (2025) | This panel will focus 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. | Alejandro Torres Jaime Vasquez Samuel T. Kuzniewski |
| 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. | Otto Timm – Moderator Professor Bret Wells (The University of Houston Law Center) Sebastien Chain |
| 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. | Roberto Perez Teuffer – Moderator Gloria Estrada Anton (Presidenta del comité de comercio exterior del colegio de contadores) |
| 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. | Robin Klinghagen Bryan Dotson José Manuel Velderrain Sáenz |
| 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. | Jaime Vasquez Professor Bret Wells (The University of Houston Law Center) |
| 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. | Zachary Cruz – Moderator Sebastien Chain Alejandro Diener Anuar Estefan |
| 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. | Luz E. Villegas – Moderator Bernardo Rivadeneyra (Notario #25 Merida) Patrick W. Martin |
| Use of Local Anti-Abuse Rules in the International Tax Context. | This session examines how domestic anti-abuse doctrines—such as substance-over-form, business purpose, and other similar principles—are increasingly being invoked in the international tax context. Panelists will discuss key cases, administrative guidance, and the practical implications for cross-border planning and dispute resolution. | Tiernan Kane Jorge Narváez Hasfura Anuar Estefan |
| 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. | Oscar Cunto Andre Enric Ripoll Gonzalez Clarissa Cole Jorge R. Uriza González |
| Tax Reporting Obligations for Assets held in U.S. (“foreign”) 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. | Sebastien Chain Eugenio Grageda Luz E. Villegas |
| 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. | Josh Smeltzer Carolyn Schenck Jeffrey Adam Neiman |
| 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. | Anuar Estefan Arturo Garza Matar Luis Michel Sanchez O’Sullivan |
2026 Speaker Gallery
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
Meet Vice Presidents of
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