University of Florida Tax Institute   Florida Tax Institute  
    March 30 - April 1, 2016, Tampa, Florida — Tampa Marriott Waterside    
  UF UF UF  

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Conference Agenda

Continuing Education



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Speakers and Draft Topics

Wednesday, March 30, 2016

7:00 - 8:15am Breakfast
8:15 - 8:30am Welcome and Opening Remarks
8:30 - 10:30am Prof. Martin J. McMahon
University of Florida Levin College of Law
Prof. Bruce A. McGovern
South Texas College of Law
Recent Developments in Federal Income Taxation
This session will review the most significant statutory enactments, judicial decisions, IRS rulings, and Treasury regulations promulgated during the last twelve months that affect general domestic income taxation, corporate taxation, partnership taxation, and tax procedure.
10:30 - 10:45am Break with Exhibitors
10:45 - 11:45am Charles Egerton
Dean Mead
Tax Planning for Disposition of Real Estate
A case study for a sale of undeveloped real estate that is ripe for development. The presentation will focus on alternative sale structures including an installment sale with the payoff or assumption of existing mortgages; an installment sale with a wraparound mortgage; an installment sale with a partial contingent purchase price feature; and a rolling option sale, with an emphasis on the tax advantages and disadvantages of each structure.
11:45am - 1:15pm Luncheon Speaker: Lawrence Gibbs
Miller & Chevalier
The IRS and Our Tax System: Yesterday, Today, and Tomorrow
Seven former IRS Commissioners, who have served presidents back to John F. Kennedy over 50 years ago, told Congress recently that the IRS and our tax system are in trouble. Learn what they said, why it should concern you and your clients, and what you can do about it.
1:30 - 2:30pm Christopher S. Rizek
Caplin & Drysdale
It's Not Black & White: Uncertainties in Tax Practitioner Regulation & Ethics
Recent cases have undercut the ability of the IRS to regulate tax practitioners, yet simultaneously the IRS promulgated changes to Circular 230 and has stepped up enforcement of penalties against practitioners under the Internal Revenue Code. Add this to the uncertainties that already existed regarding the regulation of tax practice, and it's very unclear what practitioners can, and cannot, do. The speaker will discuss these developments and suggest how some of these uncertainties can be resolved.
2:30 - 3:00pm Break with Exhibitors
3:00 - 4:00pm Terrence J. Cuff
Loeb & Loeb
How to Foul Up Partnership Agreements
This segment will discuss ways in which partnership and LLC agreement drafters have managed to foul up economic and tax provisions in their agreements—and ways to avoid those problems.
4:00 - 5:00pm Larry J. Brant
Garvey Schubert Barer
Employee Versus Independent Contractor – Another Look at Worker Classification
A look at the worker classification rules at both the federal and the state levels, and a review of the risks associated with worker misclassification.
5:00 - 7:00pm Welcome Reception
Open to All Conference Attendees

Thursday, March 31, 2016

7:00 - 8:15 am Breakfast with Exhibitors
8:15 - 8:30am Opening Remarks
8:30 - 9:30am Stephen R. Looney
Dean Mead
Hot Topics in Subchapter S Corporation Taxation
This presentation will focus on a select number of recent developments regarding S corporations, including, among other topics, the final back-to-back loan regulations, reclassification of S corporation distributions as wages subject to social security taxes, the application of the NII tax to S corporations (including sales of stock of an S corporation), determination of material participation by trusts (including QSSTs and ESBTs), Representative Camp's proposed changes to the taxation of S corporations, and S corporation provisions included in the Tax Increase Prevention Act of 2014.
9:30 - 10:30am Summer Ayers LePree
Bilzin Sumberg
Pre-Immigration Tax Planning
The US income and transfer tax issues facing the increasingly significant number of persons immigrating to or spending significant time in the US to help such persons minimize the adverse tax impact of taking up US residency will be offered.
10:30 - 10:45am Break with Exhibitors
10:45 - 11:45am James B. Sowell
Prof. Karen Burke
University of Florida Levin College of Law
Hot Asset Distributions and New Rules Under Section 751(b)
Recently issued proposed regulations under Section 751(b) dramatically change the analysis of hot asset distributions under Section 751(b). The proposed regulations, portions of which may be applied currently, provide a regime that, in many situations, will reduce the circumstances in which partners will recognize hot asset gain. But the rules are complicated and often will increase administrative burdens related to partnership reporting and record keeping.
11:45am - 1:15pm Luncheon Speaker: Tamara W. Ashford
United States Tax Court
A View From the Bench
1:15 - 2:30pm Prof. Samuel A. Donaldson
Georgia State University College of Law
Current Developments in the Transfer Tax Arena
This informative and entertaining session will recap important recent federal income, estate, and gift tax cases, rulings, regulations, and legislation of interest to estate planning professionals.
2:30 - 3:00pm Break with Exhibitors
3:00 - 4:00pm Stacy Eastland
Goldman, Sachs & Co.
Putting It All Together: Some of the Best Estate Planning Strategies We See in the New Frontier That Reduce Both Income And Estate Taxes©
When foreign The presentation will focus on planning strategies that lower the taxpayer's potential transfer taxes and also reduce the net tax effect a sale of any assets subject to estate planning may have, including: various borrowing, location, disregarded entity, grantor trust, QSST, DSUE, mixing bowl and charitable planning strategies. The presentation will also explore various strategies that reduce a complex trust's income taxes, indirectly benefit grantor GST trusts with a Roth IRA conversion, and enhance the basis of a surviving spouse's assets.
4:00 - 5:00pm Prof. Lawrence Lokken
University of Florida Levin College of Law
Jeffrey L. Rubinger
Bilzin Sumberg
U.S. Income and Estate Tax Planning For Resident Aliens
The panel will focus on income and estate planning opportunities (and pitfalls) for resident aliens, with a focus on the differences between income tax residence and domicile, and relevant income and estate tax treaty issues.
5:00 - 7:00pm University of Florida Foundation Reception
Co-Sponsored by Florida Bar Tax Section
Open to All Conference Attendees

Friday, April 1, 2016

7:00 - 8:15am Breakfast with Exhibitors
8:15 - 8:30am Opening Remarks
8:30 - 9:30am Diana Zeydel
Greenburg Traurig LLP
Changing the Unchangeable: Modifying Irrevocable Trusts – An Analysis of Methods and Tax Consequences
We know that the only constant is change. With the advent of long term trusts now becoming the norm, it is imperative to know how to make changes to these trusts. We will explore different methods to do so, including modification, early termination and decanting of trusts and the use of trust protectors to make changes, and discuss the income, gift, estate and generation skipping tax consequences of each method.
9:30 - 10:30am Paul Lee
Northern Trust
Exploring The Space-Time Continuum (Multi State Trust Issues)
It doesn't take much for a trust to implicate the tax laws of multiple jurisdictions. For instance, a client funds a trust while a resident of State A but moves to State B, the beneficiaries reside in States C and D, the agreement provides that the laws of State E will govern, but the trust is being administered primarily in State F with co-trustees in State G. Double, triple taxation or more is possible. In truth, why should any taxable trust ever pay state income tax? This presentation will review the variety of multi-state tax complications that arise in the trust context, with suggestions on how to minimize or eliminate them.
10:30 - 10:45am Break with Exhibitors
10:45 - 11:45am Scott A. Bowman
George D. Karibjanian

Proskauer Rose LLP
Trustee Selection
Selecting a fiduciary is often one of the most difficult estate planning decisions our clients face, presenting complex tax and non-tax issues. This presentation will explore several options to help clients work through this challenge.
11:45am - 1:15pm Luncheon Speaker: Ronald D. Aucutt
McGuire Woods LLP
Capital Report
An up-to-the-minute survey of the political climate in Washington, with a view to identifying the legislative and administrative developments to expect and assessing the effect of those developments on our practices.
1:15 - 2:45pm Steven B. Gorin
Thompson Coburn LLP
Thomas J. Pauloski
AB Bernstein
Putting "Success" Into Business Succession Planning
Will explore legal, tax, and financial implications for a potpourri of topics, including income tax exit strategies, life insurance issues, planning for businesses that produce minimal current cash flow, and financing the payment of estate tax.
2:45 - 3:15pm Break with Exhibitors
3:15 - 3:45pm John J. Scroggin
Scroggin & Company, P.C.
Unexpected Basis Considerations
ATRA 2012 created a 180 degree shift in the tax planning component of estate planning. Income tax and basis planning trump federal estate tax planning for 99.8% of Americans. This presentation will discuss a few unexpected tax basis traps and opportunities in this new environment and discussion on how the IRS may respond to the changed rules.
3:45 - 4:45pm Prof. Jeff Pennell
Emory University School of Law
Income Taxation of Estates and Trusts
The income taxation of trusts, estate, grantors, and beneficiaries (Subchapter J) is an odd backwater for estate planners because it is at once the tax that affects most estate plans, the one the government seems to ignore in the main, and (perhaps therefore) the one that we hardly ever teach or study. This session will focus first on a few basics of Subchapter J and then delve a bit more into specifics of planning with intentionally defective grantor trusts, especially including the myths and hype surrounding them.
3:45pm Closing Remarks