University of Florida Tax Institute   Florida Tax Institute  
    February 12 - 14, 2020, Tampa, Florida — Tampa Marriott Waterside    
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Speakers and Topics

Wednesday, February 12, 2020

7:00 - 8:15am Breakfast
8:15 - 8:30am Welcome Remarks
8:30 - 10:30am Prof. Bruce A. McGovern
South Texas College of Law Houston
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 James B. Sowell
KPMG LLP
Continuing Impact of Tax Reform on Partnerships
This session will focus on a number of topics relevant to partnership taxation, including the new interest limitation rules under section 163(j), rules applicable to carried interest under section 1061, and the expensing rules under section 168(k) as they relate to basis adjustments and other items.
11:45am - 1:15pm Luncheon Speaker: Andrew J. Keyso, Jr.
IRS Independent Office of Appeals
Update from the IRS Independent Office of Appeals
A review of recent developments in the IRS Independent Office of Appeals.
1:15 - 2:15pm Henry P. Alden, II
Everest Ito Group
Kevin E. Packman

Holland & Knight
The Exciting World of Informational Tax Returns
The presentation will review many of the filing obligations required when a U.S. taxpayer has a connection to foreign assets and/or activities as well as the associated penalties. The speakers will address the unique impact that international tax accounting principles and foreign entity classifications have on filing obligations. Additionally, the speakers will touch on key ethical considerations for this practice area.
2:15 - 3:15pm Prof. Fred F. Murray
Attorney
James H. Barrett
Baker & McKenzie LLP
Michael Hirschfeld
Andersen Tax
Seth J. Entin
Holland & Knight
The Evolving Landscape of Financing U.S. Investment and Business Operations from Abroad: TCJA, BEPS & Beyond
This session will examine the financing of investments into the United States by multinationals and other foreign investors. Panelists will look at the implications to such structures of the complex and uncertain tax environment caused by tax reforms in the U.S. and elsewhere under recent developments resulting from various O.E.C.D. initiatives. The panel will consider questions of where multinationals should locate their external and internal debt within their organizational structures, how that debt should be structured in consideration of the many rules that limit the tax benefits of using debt or increase exposures under various regimes because of the debt. For example, the panelists will consider changes to section 163(j), the expense allocation rules, the hybrid rules, and the BEAT and their effects. All of this requires nuanced multijurisdictional approaches to the initial structuring, operation and maintenance, and unwinding of such structures.
3:15 - 4:00pm Break with Exhibitors
4:00 - 5:00pm Jasper L. Cummings, Jr.
Alston & Bird
Corporate M&A Toolkit
This session will cover the primary techniques used by corporations in buying and selling stock and assets, both taxable and nontaxable. It will include bonus depreciation, section 338 elections, and reorganizations, all limited to domestic transactions.
5:00 - 6:30pm Welcome Reception

  
Thursday, February 13, 2020

7:00 - 8:15 am Breakfast with Exhibitors
8:15 - 8:30am Opening Remarks
8:30 - 9:30am Stephen R. Looney
Dean Mead
New Section 199A: Where are We Now?
This session will examine the Section 199A deduction available to pass-through entities and sole proprietorships, and its application to both qualified trades or businesses and specified service trades or businesses. The program will also include a discussion of the Final Regulations under new Section 199A, how the Final Regulations differ from the Proposed Regulations and the open issues that still remain following the issuance of the Final Regulations. Finally, the program will briefly address the effect Section 199A, as well as the reduction in the corporate tax rate to a flat 21%, could have on choice of entity decisions.
9:30 - 10:30am Gregg D. Polsky
University of Georgia School of Law
Tax Aspects of Private Equity Compensation
This session covers the taxation of private equity compensation, including compensation structures at both the fund and portfolio company levels.
10:30 - 10:45am Break with Exhibitors
10:45 - 11:45am Jeanette Moffa
Moffa, Sutton, Donnini, P.A.
Sales Tax: 1 Tax + 45 State interpretations = The Big Problem You Can't Ignore
In 2018, the Supreme Court of the United States opened the flood gates for states to impose sales and use tax on out-of-state businesses based upon economic standards for the first time. Nearly two years later, states still don't agree on what those economic nexus standards exactly are, let alone how to implement them. The result is multistate businesses at risk not only where they reside, but in every state in which they do business.
11:45am - 1:30pm Luncheon Speaker: Steve Locke
Northern Trust
Be a Better Partner: Strategies for Securing Your Communication with Trusted Advisors
We live in an interconnected world with our clients and service providers. In an age of cyber crime, we must work together to reduce the threat of these essential interactions being compromised. This session will provide an introduction to the threat, look at at what financial institutions are doing to address cyber crime, explain what we are seeing, and answer what you can do to protect your business.
1:30 - 2:30pm J. Grier Pressly III
Pressly, Pressley, Randolph & Pressley, P.A.
Fiduciary Surcharge and Removal
This lecture will provide an overview of the cases that have shaped the law of fiduciary surcharge and removal both nationally and in Florida. The presentation will offer guidance to personal representatives and trustees, and to their advisors, in identifying areas of exposure and avoiding liability in the administration of trusts and estates.
2:30 - 3:30pm Justin Miller
BNY Mellon
Top Tax Tips for Making Divorce Less Taxing
Recent tax reform could make divorce a whole lot more taxing, and understanding the tax implications of divorce may be extremely helpful to tax, estate planning, and financial advisors—not just family law attorneys. Whether it is child tax credits, transfers of securities, dividing retirement accounts or determining spousal support, this program will provide essential tax tips that can assist every practitioner.
3:30 - 4:00pm Break with Exhibitors
4:00 - 5:00pm Brian R. Harris
Akerman, LLP
David Springsteen
Clifton Larson Allen, LLP
Cryptocurrencies: IRS Guidance and Enforcement
An introduction to blockchain and cryptocurrency technologies and their practical applications. The panel will also examine the tax implications of cryptocurrency transactions, potential foreign disclosure obligations (e.g. FBARs/8938s, etc.), consideration of cryptocurrencies in estate plans, and recent IRS cryptocurrency enforcement initiatives.
5:00 - 6:30pm Reception

  
Friday, February 14, 2020

7:00 - 7:45am Breakfast with Exhibitors
7:45 - 8:00am Opening Remarks
8:00 - 9:30am Prof. Samuel A. Donaldson
Georgia State University College of Law
Current Developments in the Transfer Tax Arena
This informative and entertaining session will recap the important cases, rulings, regulations, and legislation of interest to estate planning professionals in the areas of income, estate, and gift taxation.
9:30 - 10:30am Jennifer J. Wioncek
Bilzin Sumberg
Shawn P. Wolf
Packman, Neuwahl & Rosenberg
Common Misnomers and Mistakes for International Trust and Estate Tax Planning Clients
This session will explore some of the most common tax traps or mistakes when handling international private client matters and ways to mitigate or correct the problems after they arise. It will include topics ranging from typical planning situations, drafting issues, basis issues, trust administration items, property ownership, and reporting and compliance matters.
10:30 - 10:45am Break with Exhibitors
10:45 - 11:45am Jonathan G. Blattmachr
Pioneer Wealth Partners, LLC
Curbing Litigation in Estates & Trusts
Options are always good. One that individuals now have is whether to use the enhanced standard deduction or to itemize. But choosing to use the standard deduction means losing all income tax benefit for charitable contributions and keeping the benefit of state and local taxes to a deduction of $10,000 a year. But this loss of these tax deductions can be regained, at least in part, by using the income tax deductions for estates and trusts. Everyone, including those who do not otherwise itemized their deductions, can benefit from the income tax deductions allowed to estates and trusts. This presentation will discuss how those deductions work and how they can benefit you and virtually all your clients.
11:45am - 1:15pm Luncheon Speaker: Ronald D. Aucutt
Bessemer Trust
Why I'm Glad I Moved to Florida: Recollections from the Last Half Century by a Washington, D.C. Refugee
A look at how developments of the last 50 years shaped today's Washington environment and what that might mean for the future.
1:15 - 2:15pm David E. Bowers
Jones Foster P.A.
How Safe is Your Retirement (estate) Planning after the Secure Act
The longstanding tax deferral technique known as the "Stretch IRA" has been eliminated from the tax professional's arsenal with Congress' recent passage of the SECURE Act. This new legislation overhauls much of what we know on retirement benefit planning and how we approach estate planning for our client's retirement accumulations. The presenter will discuss the legislation, how it affects existing estate plans and what we can do today to advise our clients.
2:15 - 2:30pm Break
2:30 - 3:30pm Robert K. Kirkland
Kirkland Woods & Martinsen, LLP
Dawn of the Dead - The Planning Continues Beyond the Grave
The estate planner's job does not end upon the client's death. Trust modifications, timely actions and tax reduction planning with respect to qualified retirement plans and IRAs, managing, securing and disposing of the decedent's digital presence, possible disclaimers, and income, gift and estate compliance should all be on your checklists.
3:30 - 4:30pm Paul S. Lee
Northern Trust
QSBS: Quest for Quantum Exclusions (Queries, Qualms, Qualifications & QOZ)
Qualified Small Business Stock (QSBS) under Section 1202 is not just for tech companies anymore. It's time to reconsider QSBS because the new tax act has paved the way for closely-held companies to benefit "bigly." QSBS provides an exciting array of benefits (and a surprising alternative) for owners of new and pre-existing business (large and small): (i) 100% gain exclusion on sale; (ii) tax-free rollover of gains; and (3) a chance to "stack" (multiply) and "pack" the exclusion by 10 times (maybe more). While the benefits of QSBS are straightforward, the qualifications and questions surrounding QSBS planning are far from it. This presentation will discuss planning opportunities including how QSBS can be combined with Qualified Opportunity Zone Investments, unanswered questions, potential pitfalls, and best practices in the quest for quantum QSBS exclusions.
   
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