2025 Speakers and Topics

Wednesday, February 5, 2025
7:00 - 7:55 am	Breakfast
7:55 am	Opening Remarks
8:00 - 10:00 am	Prof. 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.
10:00 - 10:45 am	Visiting With Sponsors
10:45 - 11:45 am	Sarah B. Jacobson Day Pitney LLP *Planning for the Modern International Family* The "modern family" has become increasingly international. As wealthy families become more mobile and the reach of their wealth more global, it is inevitable that US tax issues will arise. Even for couples where the US has become their home base, international tax issues often remain key to a successful estate plan. International estate planning for these clients raises a variety of US federal income, gift and estate tax issues that routinely must be squared with foreign property ownership, succession and inheritance regimes. Using our hypothetical, international couple, we will explore the host of US income, gift and estate tax issues which commonly arise in practice and planning opportunities when advising these complex cross-border clients. Topics will include planning for non-citizen spouses (including joint ownership and QDOTs), inheritance strategies for US persons, avoiding anti-deferral rules (CFC and PFICs) and accidental foreign trusts.
11:45 am - 12:15 pm	Get Lunch and Visit with Sponsors
12:15 - 1:15 pm	Luncheon Speaker - Samuel A. Donaldson, JD, LL.M., AEP® (Distinguished) Georgia State University College of Law *Federal Wealth Transfer Tax Update* This informative and entertaining session will recap the important cases, rulings, and regulations from 2024, together with a preview of what we might expect from Congress in 2025 or 2026.
1:20 - 2:20 pm	James C. Trainor Aon *Navigating the Cyber Threat Landscape: Insights and Strategies for 2025* In 2022, global losses due to cybercrime reached a staggering $8.4 trillion, with projections indicating this figure could soar to $23.8 trillion by 2027, according to the World Economic Forum. As cyber threats continue to escalate, they remain a critical concern for organizations and individuals alike. Join us for an enlightening session with Jim Trainor, a retired Special Agent, and former Assistant Director of the FBI’s Cyber Division, now serving as Senior Vice President at Aon. With his extensive experience and expertise, Jim will provide a comprehensive update on the current Cyber Threat Landscape, emphasizing the increasing role of Artificial Intelligence. In this presentation, you will gain valuable insights into: • The evolving nature of cyber threats and their potential impact on global security. • The integration of Artificial Intelligence in cybersecurity, governance, and insurance. • Practical strategies and best practices for organizations to better mitigate and manage cyber risks. • The critical role of cyber insurance in providing a financial safety net and its evolving landscape. • The increasing responsibilities of board of directors in overseeing cyber risk management and ensuring organizational resilience. Don't miss this opportunity to learn from a leading expert in the field and equip your organization with the knowledge to navigate the complex world of cyber threats more effectively.
2:25 - 3:00 pm	Visiting With Sponsors
3:00 - 4:00 pm	Paul M. Caspersen, CFP®, MS (Financial Planning & Taxation), AEP® Planned Giving Interactive, LLC *Recent Cases in Complex Charitable Planning* Join us for a compelling session where we dive into recent complex cases to transform assets into impactful charitable contributions. You'll work through real-life scenarios involving closely held companies, real estate with debt, and undivided interest donations, gaining practical insights on navigating intricate financial, estate, and tax considerations. Paul will bring his most challenging client cases to the table, fostering a collaborative environment to optimize gifts for the benefit of donors, their families, and charities.
4:00 - 5:00 pm	Charles Levun Levun, Goodman & Cohen, LLP *Partnership Planning & Structuring Techniques That Every Professional Dealing with Business Transactions and Estate Planning Should Know* Get prepared to experience tax, fun and "I didn't think about that" in the same presentation, as Chuck Levun discusses in his transactional format essential partnership/LLC planning devices of which every professional should be aware. Chuck will discuss insurance partnership planning to negate the Supreme Court's "insurance inclusion in value" decision in Connelly, how to structure a business to maximize the benefits of Section 199A and a "simple" (okay, nothing is simple) structuring device that coordinates Sections 704(c) and 743(b) to facilitate the sale and partial rollup of the assets of a business.
5:00 - 6:00 pm	Welcome Reception
Thursday, February 6, 2025
7:00 - 7:55 am	Samuel C. Ullman Memorial Breakfast and Visit with Sponsors Sponsored by The Florida Bar Tax Law Section
7:55 am	Opening Remarks
8:00 - 9:00 am	Stephanie Loomis-Price Perkins Coie LLP *IRS's Top Targets on Transfer Tax Returns* This session will begin with a discussion of the IRS’s enforcement objectives with regard to transfer tax returns involving closely held entities. We will then explore the creation, maintenance, and defense of family entities, providing practical tips at each stage. Throughout the discussion, we will address recent developments in Tax Court jurisprudence and its valuation approaches, all with an eye toward minimizing audit risk.
9:05 - 10:05 am	Jeffrey H. Paravano Baker Hostetler *Tax Implications of the Supreme Court's Decisions in Moore, Loper Bright, and Corner Post* Jeff Paravano, counsel for the taxpayer in Moore v. United States, and co-panelists will discuss the Supreme Court's Decisions in Moore, Loper Bright, and Corner Post, and provide an analysis of the federal, state and international tax implications of those cases.
10:05 - 10:30 am	Visiting With Sponsors
10:30 - 11:30 am	Charles M. Ruchelman Caplin & Drysdale Sebastian Voth Hochman Salkin Toscher Perez P.C. *Recent Developments in Tax Court Litigation - What You Need to Know* Tax litigation has seen a series of changes in recent years disrupting rules that seemed beyond dispute, including whether court deadlines are jurisdictional, whether deference is still afforded to administrative regulations, and how penalties must be approved, calculated, and assessed. This panel will discuss challenges presented by recent cases, the current state of these evolving standards, and how it could impact you if you are selected for examination and cannot resolve a tax issue without litigation. What materials should you have and maintain, what mistakes should you avoid, and how do you help your trial counsel if the case is litigated?
11:30 am -12:30 pm	Student Networking Luncheon and Visit with Sponsors Sponsored by A. Brian Phillips, P.A.
12:35 pm - 1:35 pm	Stephen R. Looney, JD, LL.M. (taxation) Dean Mead A "Sirius" Issue: Application of the Self-Employment Tax and Social Security Taxes to Limited Partnerships, LLCs and S Corporations This presentation will review the state of the law with respect to the imposition of the self-employment tax and social security taxes on LLC members, S corporation shareholders and limited partners of a limited partnership. The discussion will include a review of the history of the self-employment tax and the development of the "functional analysis" test adopted by the Tax Court in applying the self-employment tax to members of an LLC, as well as the effect of the Sirius Solutions case which applied the functional analysis test to limited partners.
1:40 - 2:40 pm	Matthew J. Scheer Gunster *Building at 30,000 Feet: Structuring Family Offices and Family Trust Companies* This presentation will address the nuts and bolts of putting together a family office and family trust company, covering estate planning, tax planning, and securities considerations as well as some of the "softer" issues that families and their professional advisers encounter.
2:45 - 3:30 pm	Visiting With Sponsors
3:30 - 4:30 pm	Andew R. Comiter, Esq. Comiter, Singer, Baseman & Braun *Navigating Choppy Waters: Effective Succession Planning for Challenging Business Transitions* The presentation will focus on dealing with difficult circumstances while planning for business succession. The topics will focus on family dynamics, income and estate tax concerns, and the continuity and future growth of the business.
4:30 - 6:00 pm	Super Bowl Mingle Reception Sponsored by Evercore Wealth Managment Visit with your fellow attendees in a Super Bowl themed event featuring unique "game day" food. At 10-minute intervals, each attendee will move to 4 pre-assigned tables with 10 different attendees at each. Table "coaches" will ask ice breaker questions to get the conversation started.
Friday, February 7, 2025
7:00 - 7:55 am	Breakfast with Sponsors
7:55 am	Opening Remarks
8:00 - 9:00 am	Mark Prater PricewaterhouseCoopers LLP *Impending Changes to Tax Policy* Mr. Prater will present an update on federal tax legislative issues. His presentation will cover the relevant parts of the federal budget process, including budget reconciliation. Also the implications of provisions in the individual, business, and internation titles of the Tax Cuts and Jobs Act which are set to expire or change on January 1, 2025.
9:00 - 10:15 am	Paul Lee, JD, LL.M. (taxation) Northern Trust *Stump the Strategist - A Q&A with Paul Lee*
10:15 - 10:45 am	Visiting With Sponsors
10:45 - 11:45 am	Jolyon D. Acosta, Esq. Bush Ross, P.A. Carla A. DeLoach, Esq., LL.M. (taxation) Cypress Row Advisors *The Uniform Fiduciary Income and Principal Act & Its Intersection with Tax Law - A Survey* The session will outline sections of the Uniform Fiduciary Income and Principal Act and the intersection of those sections with tax law impacting trusts and estates professionals. The session will provide helpful observations and introduce practical examples which highlight planning opportunities.
11:45 am - 12:15 pm	Get Lunch and Visit with Sponsors
12:15 - 1:15 pm	Luncheon Speaker - Philip S. English ArentFox Schiff LLP *Prospects for Tax Legislation in the New Congress* Can a polarized Congress forestall tax increases and deliver on promises in the face of record federal deficits? The former lead House Republican on the tax policy Subcommittee assesses expiring provisions, cost recovery, international tax competition, and populist tax demands on the brink of a major overhaul of the federal tax code.
1:20 - 2:20 pm	Thomas J. Pauloski, JD Bernstein *To Halve or Have Not: Would a Potential Reduction to the Basic Exclusion Amount Really Matter All That Much?* As interest rates have surged, the generous gift and estate tax exclusion amount - currently, $13.99 million - has overtaken leveraged strategies, like grantor retained annuity trusts (GRATs) and installment sales, as the primary driver of lifetime wealth transfer strategies. With the exclusion scheduled to be halved next year, should estate planners urge clients to rush to make gifts in 2025? Or would it be better to wait and see what, if anything, Congress may do? Using the case study method, this presentation will show that current use of the extension isn't nearly as important as many people believe.
2:25 - 3:25 pm	A. Stephen McDaniel, JD Williams McDaniel, PLLC *Ethical Considerations in Estate Planning and Estate & Tax Trust Administration* Attorneys, CPAs and Financial Planners face substantial issues in dealing with families in planning estates. The issues are magnified when an estate or trust is being administered. Family conflicts in the estate world are increasing at an alarming rate. This session will address the pitfalls to be encountered and how to avoid them, in working with clients in the estate world.
3:25 pm	Closing Remarks