2022 Speakers and Topics

Wednesday, February 2, 2022

7:00 - 7:45amBreakfast
7:45 - 8:00amOpening Remarks
8:00 - 10:00amProf. 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.
10:00 - 10:30amVisiting With Sponsors
10:30 - 11:30amProf. Gregg Polsky
University of Georgia School of Law
The Qualified Small Business Stock Exclusion and Rollover Rules
This presentation will discuss the qualified small business stock exclusion in section 1202 and the related rollover rules in section 1045. In addition to a technical analysis of the rules, the presentation will address planning opportunities, traps for the unwary, and related tax policy issues.
11:30am - 1:00pmLuncheon Speaker - Charles P. Rettig
IRS Commissioner
IRS Presentation
An update on current enforcement topics, which may include, high wealth exams, cryptocurrency transactions, and issues involving cross-border investments and transactions will be given. Other recent developments may also be discussed.
1:00 - 2:00pmCristin C. Keane
Carlton Fields
Navigating the Minefield: Business and Individuals Interacting with Charitable Organizations
The relationship between private persons - individuals and businesses - and charitable organizations can be incredibly productive and rewarding, but also fraught with traps for the unwary. To avoid taxpayers’ being punished for their good deeds, this presentation focuses on the interplay between for profit and charitable persons, including discussions of excess benefit transactions, self-dealing rules, public charity & private foundation ownership of business entities (including disregarded entities), and joint ventures involving charitable organizations.
2:00 - 3:00pmJames B. Sowell
Understanding and Drafting Partnership Allocation Provisions
The economics of a partnership can be complicated, and understanding drafting conventions and the related tax rules is important in documenting and interpreting the arrangement. This program will discuss how to account for various economic arrangements in partnership agreements, with a focus on supporting the allocations under the tax rules and clearly reflecting the arrangement for the benefit of those who will report the results.
3:00 - 3:30pmVisiting With Sponsors
3:30 - 4:30pmRonald A. Levitt
Dentons Sirote
Stephen R. Looney
Dean Mead
New IRS Attacks on Trade or Business Status of Closely Held Businesses…
This presentation will discuss new IRS attacks on the trade or business status of closely held businesses.
4:30pmClosing Remarks
4:30 - 5:30pmWelcome Reception

Thursday, February 3, 2022

7:00 - 7:45amBreakfast With Exhibitors
7:45 - 8:00amOpening Remarks
8:00 - 9:30amProf. Yariv Brauner
University of Florida Levin College of Law
Roberto Duque Estrada
Brigagao Duque Estrada (Brazil)
Michael Hirschfeld
Andersen Tax
Fred Murray (Moderator)
Sean Tevel
Holland & Knight LLP
Tax Planning for Foreign Investment in the United States post-TCJA: Current Structures, Legislative Updates and Potential Future Tax Reform
Law changes resulting from the TCJA of 2017, changes in treaties and developments like the OECD MLI and digital income projects (including new special taxing rights and the new worldwide minimum tax developments), and recent regulations including the US rules on limitation of the interest deduction under section 163(j), make it mandatory for investors and their counsel to review their structures. Further, both the Biden Administration and Congressional leaders have proposed significant changes to the applicable rules. This panel will discuss current planning structures for inbound investments while highlighting planning opportunities that foreign investors should consider to avoid negative consequences from a U.S. federal income tax and U.S. federal estate and gift tax perspective.
9:30 - 10:00amVisiting With Sponsors
10:00 - 11:30amCaroline D. Ciraolo
Kostelanetz & Fink, LLP
Carol Madison
Fred Murray (Moderator)
Deborah Palacheck
Clifford Scherwinski
Steven Toscher
Hochman Salkin Toscher Perez P.C.
Audits and Tax Controversy Panel
The IRS continues to prioritize examinations of high-wealth individuals and inbound and outbound investment and business transactions. The reviews are expected to include the individual tax return of the sophisticated taxpayer as well as related partnerships, foundations, trusts, retirement plans, and other business structures. In the past year, the IRS also reaffirmed its interest in cross border activities with the announcement of three new campaigns targeting Nonresident Aliens who receive rental income from U.S. real property; FIRPTA compliance in connection with the withholding of tax and reporting obligations on the disposition of U.S. real property interests; and the U.S. activities of financial service entities and whether foreign investors participating in “inbound” lending transactions were engaged in a U.S. trade or business and generated income effectively connected with a U.S.-situs lending trade or business. The panel will discuss these and other current developments and their implications for high wealth foreign and domestic taxpayers.
11:30am - 1:00pmLuncheon Speaker - Michael Greenwald
Tiedemann Advisors
The New Era of Digital Asset Foreign Policy
How the future of the digital asset transition will reshape the future of money in the United States and globally. The world has entered a new era of a basket of currencies where the United States has a vital decision in front of them whether to remain in an era of dollar dominance or begin to transition to an era of dollar innovation. The debate over digital assets will shape the future of every marketplace moving forward.
1:00 - 1:45pmSteven McClain
University of Florida
Compensating College Athletes
Starting in 2021, college athletes were given the right to make money off the commercial use of their name, image, and likeness (NIL). Having once outlawed college athletes from receiving any form of compensation from their NIL, the NCAA's hand was forced by state laws and political pressure, and on June 30, 2021, the NCAA voted to waive Bylaw 12 so that athletes in all states could receive compensation for their NIL without losing their eligibility. By the first week of August 2021, eighteen states had effective NIL laws or gave universities a right to opt-in. Per the guidelines, athletes in states with effective laws (like Florida) must follow state law and university policies concerning NIL. Conferences may draft their own guidelines. There is no federal college athlete NIL law. College athlete NIL has been hyped and discussed at length but what are the realities? And now one full college football season has come and gone with the new NIL laws and rules in place. Has the reality matched the hype? In this presentation, the basics, hype, and realities of college athlete NIL laws and rules will be discussed.
1:45-2:30pmRichard B. Comiter
Comiter, Singer, Baseman & Braun, LLP
Louis Nostro
Lessons Learned: How the Proposed 2021 Tax Law Changes Would Have Impacted Grantor Trust Planning & What Advisors Should Do Going Forward
This session will discuss how the proposed 2021 tax law changes would have impacted grantor trust planning. Practical tools for future estate planning will be discussed.
2:30 - 3:00pmMarshall Jones and Burns M. Lowry
Jones Lowry
Funding Grantor Trusts with Life Insurance – an Overview
What do you do when your clients want to acquire Trust Owned Life Insurance (TOLI) without making taxable gifts? This session will discuss several Grantor Trust alternatives including annual exclusion gifts, grantor sales, grantor loans, and grantor split-dollar loans.
3:00 - 3:30pmVisiting With Sponsors
3:30 - 4:30pmHale E. Sheppard
Chamberlain Hrdicka
Understanding the Real Conservation Easement Controversy Through the Lens of Recent IRS Enforcement Actions
The IRS is attacking partnerships that make charitable donations of conservation easements in many ways, such as labeling them as “listed transactions” and launching an aggressive compliance campaign. This presentation, by an attorney who is currently defending hundreds of taxpayers in easement disputes and who has published dozens of articles on the topic, explains (i) the major rules applicable to easement donations, (ii) historical Congressional support for this tax benefit, (iii) over 30 specialized IRS enforcement actions unique to this area, (iv) terms of the Settlement Initiative, (v) recent cases, and (vi) anticipated future developments.
4:30pmClosing Remarks
4:30 - 5:30pmReception Co-Sponsored by Tax Section of the Florida Bar and UF Advisor Network

Friday, February 4, 2022

7:00 - 7:45amBreakfast with Exhibitors
Special Student Networking Opportunity
7:45 - 8:00amOpening Remarks
8:00 - 10:00amJeffrey A. Baskies
Katz Baskies Wolf
Paul S. Lee
Northern Trust
Hot Topics in Estate Planning
COVID-19, Congress, and the new administration have and will change everything we know as planners. Significant tax code changes are on the horizon. This presentation will discuss straightforward and innovative planning opportunities for families that best take advantage of both the “expiring” and “permanent” provisions of the tax law, with an eye toward anticipated changes to the future planning landscape. We will attempt to address some of the best and most effective estate planning techniques to utilize in this time of uncertainty...focusing on flexibility where possible.
10:00 - 10:30amVisiting With Sponsors
10:30 - 11:30amA. Stephen McDaniel
Williams McDaniel
The New Florida Community Property Trust Law
Effective July 2021 Florida joined Tennessee, Kentucky, and Alaska to allow residents of Florida to opt into community property rules by creating a community property trust. This new law will open up substantial estate planning opportunities.
11:30am - 1:00pmLuncheon Speaker - Ronald D. Aucutt
Bessemer Trust
Capital Report
This presentation will be an up-to-the-minute status of changes in federal tax law affecting estate planning. The primary focus will be on significant changes proposed by the Biden Administration, particularly the proposal to tax unrealized capital gains at death and upon gifts and other events. Other topics will include the status of the 2026 “sunset” of 2017 changes, the contemplated “anti-abuse” exception to the “anti-clawback” regulations for gifts that trigger inclusion in the gross estate, and the possible relaxation (or expansion) of the 2015 “consistent basis” rules.
1:00 - 2:00pmAndrew Comiter
Comiter, Singer, Baseman & Braun, LLP
Estate Planning for Digital Assets
The presentation will focus on recent regulatory and legislative updates associated with digital assets; an overview of key terms associated with digital assets; tax considerations of holders, purchasers, and sellers of digital assets; and tax considerations of issuers of digital assets.
2:00 - 2:20pmBreak
2:20 - 3:50pmMichael Booth
National Christian Foundation
Michael L. Kohner
HBK CPAs & Consultants
Jeanne McMains
National Christian Foundation
Top Charitable Strategies for Gifting Alternative Assets
The convergence of several trends in 2021 has created some unique giving opportunities, including gifting business interests that are often overlooked as a source of charitable giving. This seminar will examine the technical considerations, the tax and legal aspects, as well as the opportunities that arise when business interests are used to fund charitable gifts.
3:50pmClosing Remarks