2021 Speakers and Topics

Wednesday, March 10, 2021

8:15 - 8:30amWelcome Remarks
8:30 - 10:30amProf. Cassady V. Brewer
Georgia State University College of Law
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 - 11:00amVisiting With Sponsors
11:00am - 12:00pmJames B. Sowell
Partnership and Real Estate Debt Workouts
With the current economic turmoil brought about by COVID-19, debt workouts are occurring with increasing frequency. This presentation will review the cancellation of indebtedness ("COD") rules in the partnership context, including treatment of foreclosures; potential exclusion of COD income; partnership equity-for-debt exchanges; tax consequences of debt modifications; allocation of COD income among partners; actions to consider in advance of a debt workout; and other workout-related tax issues.
12:00 - 12:45pmVisiting With Sponsors
12:45 - 1:45pmProf. Charlene Luke
University of Florida Levin College of Law
Proposed Partnership Regulation Projects: Where Do They Stand? How Should They Be Handled?
This presentation will provide an overview of the current state of U.S. Treasury partnership regulation projects and consider potential future approaches in light of a new tax administration.
1:50 - 2:50pmProf. Lee-ford Tritt
University of Florida Levin College of Law
Business Trusts
This presentation will discuss how business trusts have come to develop and why they have recently been overlooked by entrepreneurs as an organization form. In addition, the presentation will explore the business uses of trusts in our time.
2:50 - 3:20pmVisiting With Sponsors
3:20 - 4:20pmStephen R. Looney
Dean Mead
Stock Sales of S Corporations
This presentation will focus on transactions that the parties want to be taxed as a sale of assets, and compare effectuating the transaction with a 338(h)(10) election, a 336(e) election or an F Reorg/Qsub Election under 2008-18 followed by a conversion to an LLC and sale of the membership interests to the purchaser.
4:20pmClosing Remarks

Thursday, March 11, 2021

8:15 - 8:20amOpening Remarks
8:20 - 9:20amRoberto Duque Estrada
Brigagao Duque Estrada
Michael Hirschfeld
Andersen Tax
Fred Murray (Moderator)
Sean Tevel
Holland & Knight LLP
TCJA Makes it Imperative to Review Inbound Investment Structures
Law changes resulting from the TCJA of 2017, changes in treaties and developments like the OECD MLI project, recent regulations including the US rules on limitation of the interest deduction under section 163(j), have required investors to review their structures. 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.
9:25 - 10:25amCaroline D. Ciraolo
Kostelanetz & Fink, LLP
Fred Murray (Moderator)
Deborah Palacheck
Clifford Scherwinski
Steven Toscher
Hochman Salkin Toscher Perez P.C.
Increased IRS Exam Activity on High Wealth Taxpayers and Their Investment Structures
The IRS has again increased its focus on examinations of high-wealth individuals. Each review is expected to include the individual tax return of the sophisticated taxpayer as well as related returns such as partnerships, foundations, trusts, and other business entities. Similarly, the IRS has recently announced a number of other new audit campaigns and initiatives, including one on October 5, 2020, that will examine Nonresident Aliens who receive rental income from U.S. real property, and on September 14, 2020, one intended to increase FIRPTA voluntary compliance in connection with the withholding of tax and reporting obligations on the disposition of U.S. real property interests through issue-based examinations and external education. The panel will discuss these and other current developments and also discuss the IRS new Office of Fraud Enforcement and their implications for high wealth foreign and domestic taxpayers.
10:25 - 10:55amVisiting With Sponsors
11:00am - 12:00amSummer Ayers LePree
Baker & McKenzie LLP
Jeffrey L. Rubinger
Baker & McKenzie LLP
An Epidemic of CFCs: Implications of the Repeal of Section 958(b)(4)
This panel will illustrate the impact of the repeal of Section 958(b)(4) on many common inbound structures, highlight a series of examples in which a CFC (“Controlled Foreign Corporation”) exists despite a lack of US control, and explain why this is significant in the context of inbound tax structuring. The panel will also review recent guidance in this area and discuss planning to minimize adverse consequences of CFC classification.
12:00 - 12:45pmVisiting With Sponsors
12:50 - 1:50pmJohn Bates
Deloitte Tax LLP
Amanda Pedvin Varma
Steptoe & Johnson LLP
Cross-border Hybrid Instruments and Transactions
The panel will discuss recent U.S. tax guidance with respect to cross-border hybrid instruments and transactions, including regulations under sections 245A(e) and 267A.
1:55 - 2:55pmCarlton Huntley
Frazier & Deeter
State and Local Tax Update
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.
2:55 - 3:25pmVisiting With Sponsors
3:30 - 4:30pmProf. Nancy A. McLaughlin
University of Utah S.J. Quinney College of Law
Trying Times: Conservation Easements and Federal Tax Law
Since 2006, the courts have decided more than 90 cases involving challenges to deductions claimed with respect to conservation easement donations. This program will discuss some of the more recent court decisions and the practical lessons that can be learned from them.
4:30pmClosing Remarks

Friday, March 12, 2021

8:15 - 8:20amOpening Remarks
8:20 - 9:20amProf. Samuel A. Donaldson
Georgia State University College of Law
Transfer Tax Update
Stay up to date with this informative and entertaining recap of the important cases, rulings, regulations, and legislation from the past 12 months related to federal income, estate, and gift taxes.
9:25 - 10:25amThomas J. Pauloski
Leaning Into Social Distancing: A Perfect Storm for Wealth Transfer Background
Should estate planners focus on the possibility of a near-term reduction to the $11.7 million basic exclusion amount? Or are other factors, such as low valuations and low interest rates, more important?
10:25 - 10:55amVisiting With Sponsors
11:00am - 12:00amProf. Phyllis Taite
Florida A&M University College of Law
Estate Tax Inclusion and FLP Planning
A Family Limited Partnership (FLP) is a versatile tool for asset protection and estate planning. Understanding how FLPs operate, lifetime transfers and retained interests are all vital in determining whether an ownership interest will cause estate tax inclusion.
12:00 - 12:45pmVisiting With Sponsors
12:45 - 1:45pmA. Stephen McDaniel
Williams McDaniel
Fiduciary & Estate Cases – Significant, Curious, Fascinating & Just Stupid
This session will look at the primary reasons that trustees are successfully sued and steps that can be taken by trustees to avoid liability. We will look at several court cases which generally show what a trustee should not do.
1:50 - 3:20pmPaul S. Lee
Northern Trust
Conquering Subchapter K(ryptonite): Fundamentals of Partnership Taxation for Estate Planners
The taxation of partnerships (and limited liability companies) can be downright confounding, confusing, complicated, and cryptic for estate planners. This presentation will provide the basics of partnership income taxation (from formation, in operation, and to termination) that all estate planners should know, including traps for the unwary and interesting planning opportunities.
3:20 - 3:35pmVisiting With Sponsors
3:40 - 4:40pmRonald D. Aucutt
Bessemer Trust
Capital Report
An up-to-the-minute survey of the new Administration and the resulting 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.
4:40pmClosing Remarks