2024 Speakers and Topics

Wednesday, February 14, 2024

7:00 - 7:55amBreakfast
7:55amOpening Remarks
8:00 - 10:00amProf. 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 - 10:30amVisiting With Sponsors
10:30 - 11:30amPanel Discussion, Prof. Yariv Brauner
University of Florida Levin College of Law
Roberto Duque Estrada, LLB
Brigagao Duque Estrada (Brazil)
Michael Hirschfeld, J.D., LL.M
Andersen Tax
Sean J. Tevel, J.D., LL.M. (taxation)
Holland & Knight
Fred F. Murray (Moderator)
Tax Planning for Foreign Investment in the United States: Current Structures, Legislative Updates and Potential Future Tax Reform
Law changes resulting from recent legislation, changes in treaties and developments at the OECD (the MLI and the new Pillar 1 digital income project special taxing rights and the new Pillar 2 worldwide minimum tax), and recent regulations including the US rules on foreign currencies and section 987, limitation of the interest deduction under section 163(j), and foreign tax credits, make it mandatory for investors and their counsel to review their structures. This is further reinforced by the coming expiration in the not-so-distant future of important provisions enacted in 2017. Both the Biden Administration and Congressional leaderships have proposed changes to the applicable rules. This panel will discuss current planning structures for inbound investments (and relevant outbound issues) 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.
11:30amGet Lunch and Visit with Sponsors
12:00pm - 1:00pmLuncheon Speaker - Prof. Steven J. Willis
University of Florida Levin College of Law
Traps for the Unwary in Charitable Contributions
This presentation will discuss contribution restrictions via donor restricted funds, directed funds, and advised funds. The focus is on sponsoring organizations and advised funds, with collateral coverage of supporting organizations. There are three audiences: 1) experts who will hear my viewpoint; 2) those who seek to become experts and need to know where to start; and 3) the unwary who occasionally deal with charities and donors. Group three will learn how easy it is to create restricted and advised funds with their many complications and pitfalls, even when one is not seeking to do so.
1:10 - 2:10pmIan M. Comisky
Fox Rothschild
Jackie Perczek
Black Srebnick
Corporate Transparency Act
This program will review the now effective Corporate Transparency Act. This statute was enacted by way of the Anti-Money Laundering Act of 2020. The Financial Crimes Enforcement Network has issued multiple regulations dealing with the Corporate Transparency Act, along with FAQ's and a Small Business Compliance Guide. The Corporate Transparency Act raises substantial issues for attorneys and accountants (including their own required registration) and raises ethical issues with respect to client intake and monitoring after the act's effective date.
2:15 - 3:15pmPanel Discussion, Eric P. Cirelli
LB&I Division, IRS
Niles Elber
Caplin & Drysdale
Judith A. McNamara
Michel R. Stein
Hochman Salkin Toscher Perez P.C.
Fred F. Murray (Moderator)
Audits and Tax Controversy Update
The IRS continues to prioritize examinations of high-wealth individuals and inbound and outbound investment and business transactions, as well as collection of outstanding tax liabilities of these taxpayers. 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. The IRS also has reaffirmed its interest in cross-border activities with the announcement of 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. Examination of partnerships and other flow-through entities are in themselves a focus of a number of examinations. The panel will discuss current developments and their implications for high wealth foreign and domestic taxpayers.
3:15 - 3:45pmVisiting With Sponsors
3:45 - 4:45pmCharles P. Rettig
Former Commissioner of IRS
IRS: Looking Back and Looking Ahead
The Inflation Reduction Act of 2022 appropriated almost $80 billion to the IRS to be expended over 10 years, mostly for Taxpayer Services, Enforcement, Operations Support, and Business Systems Modernization. Former IRS Commissioner Chuck Rettig will discuss the importance of these funds to support meaningful, effective tax administration for your clients, you and our country.
4:45 - 6:00pmCulinary Trip Around the World on the Love Boat
Visit with your fellow attendees in a speed dating style event featuring unique small plate and beverage pairings.
Each attendee will "travel" to 4 pre-assigned tables with 10 different attendees at each.
Table "captains" will ask ice breaker questions to get the conversation started.

Menu includes: Ceviche & Lobster Empanada paired with a Margarita
Caprese Bite & Mushroom Asiago Arancini paired with a Tuscan Red Wine
Deviled Egg & Bacon Wrapped Scallop paired with a craft beer
Tuna Tataki & Beef Tenderloin Yakitori paired with a White Wine
Crudite, Dip and Charcuterie Displays
An assortment of other beverages will be available

Thursday, February 15, 2024

7:00 - 7:55amBreakfast With Sponsors
7:55amOpening Remarks
8:00 - 9:00amBrad Bedingfield
Hemenway & Barnes LLP
Charitable Planning Opportunities and Risks Pre-Sale
We often tell donors to identify their “tax-heavy” assets for their philanthropic gifts, allowing them the double benefit of income tax deductions and avoidance of taxable income. Highly appreciated assets that are soon to be sold are perfect in this regard. However, recent federal tax cases have demonstrated that, if done incorrectly, pre-sale charitable planning can backfire badly. Brad will discuss these recent cases and provide an overview of how donors should approach gifts of assets prior to a sale.
9:05 - 10:05amAndrew R. Comiter
Comiter, Singer, Baseman & Braun
Transfer Tax - Planning for the Sale of the Family Business
The presentation will focus on pre-transaction tax planning techniques for family-owned businesses. The speaker will discuss the importance of integrating a family's estate plan with the operation and future exit of the business; strategies for implementing interfamily transfers; and estate, gift, and income tax considerations.
10:05 - 10:30amVisiting With Sponsors
10:30 - 11:30amBradley Kay
Houlihan Lokey
State and Local Tax Issues in M&A - The Forgotten Tax
Discussion of common state and local tax issues identified during tax diligence, focusing on recent trends and changes made by state legislatures.
11:30am - 12:30pmStudent Networking Luncheon and Visit with Sponsors
Sponsored by A. Brian Phillips, P.A.
12:40pm - 1:40pmCristin C. Keane
Carlton Fields, P.A.
Qian (Bonita) Wang
Bush Ross, P.A.
Executive Compensation Issues, Including 409A
This program will address commonly asked questions that plague drafters of any contract relating to compensation, such as: What is a “non-qualified deferred compensation plan? Is this agreement really subject to Section 409A? What the heck does Section 409A require? How do I value equity for Section 409A purposes? Can I get out of Section 409A? HOW do I get out of Section 409A? Does “substantial risk of forfeiture” seriously mean something different for purposes of Section 409A and Section 83 and Section 457?? Did I inadvertently mess with my Section 409A compliance with my non-tax provisions? What happens if this agreement or plan doesn’t comply with Section 409A? If my agreement or plan doesn’t comply with Section 409A, can I just change or replace the agreement to fix it?
1:45 - 2:45pmDan Edelman
Heritage Capital Group
Gardner F. Davis
Foley & Lardner LLP
Structuring and Executing an Acquisition (Going Through an APA/SPA)
This presentation will cover the primary aspects of structuring and executing the acquisition of a privately held business, including (i) current market conditions and trends, (ii) alternative transaction structures, including asset sale, stock sale, merger and use of an F-reorg., (iii) letter of intent, (iv) drafting elements of the purchase agreement, and (v) the lawyer’s negotiating techniques and effective deal management.
2:45 - 3:15pmVisiting With Sponsors
3:15 - 4:15pmCarla DeLoach
DeLoach, P.L.
David M. Doll
Sequent Asset Management
Jordan DeLoach Hurlburt
DeLoach, P.L.
Michael L. Kohner
Alvarez & Marsal Tax
Structuring the Family Office
The panel will review the following case study: Kit Tomas wants to enlist his son, Nat, to start a family office. A recent graduate of Blue Blood Business school, Nat is anxious to join his father in managing the Tomas family fortune. Nat has little “real world” experience. Kit has significant business experience. But, following his 2021 company sale, Kit realizes that he needs more than his business knowledge and his son to manage the family wealth. Kit is considering numerous solutions for structuring the Tomas Family Office. Specifically, Kit wants to install nimble and tax efficient governance and institutions to manage the family investments. However, he does not know where to start.
4:15 - 5:15pmSamy Dwek
The Family Office Doctor
Trouble Shooting Family Office Issues
Family offices are not a new concept and are growing in numbers everyday. Watching this phenomenon has been interesting as in many cases the founders of these family offices, ran large businesses in a very professional and productive manner. However when we look at many of the major family offices that exist in the world today, they are staffed with 4-6 people. We will review some of the main issues facing family offices and what measures can be taken to remedy them.
5:15 - 6:30pmUF Law Tax Program 50th Anniversary Reception
Sponsored by Johnson Pope Bokor Ruppel & Burns, LLP
6:30 - 8:30pmTicketed Dinner Celebrating the 50th Anniversary of the UF Levin College of Law Graduate Tax Program
Sponsored by Gunster
Join Professors Dennis Calfee, Stephen A. Lind, Lawrence Lokken, Michael Oberst, Steven J. Willis and more to celebrate 50 years of excellence in tax education!

Friday, February 16, 2024

7:00 - 7:55amBreakfast with Sponsors
7:55amOpening Remarks
8:00 - 9:00amProf. Samuel A. Donaldson
Georgia State University College of Law
Transfer Tax Update

This informative and entertaining presentation recaps the important cases, ruling, regulations, and legislation from the past 12 months related to federal estate and gift taxes. Special emphasis is on items of interest to estate planning professionals.
9:05 - 10:05amScott A. Bowman
McDermott Will & Emery
Breaking Up Is Hard To Do - The Challenges for Americans Seeking Jurisdictional Diversification
As we continue to navigate uncertain political and economic times, many wealthy Americans seek to diversify out of the United States. This presentation will unpack the tax and non-tax challenges that confront these individuals.
10:05 - 10:30amVisiting With Sponsors
10:30 - 11:30amJoanna B. Lardin
Bessemer Trust
Jorja M. Williams
The Kelley Law Firm, PL
Planning Pitfalls: A Panel Discussion with a Corporate Trustee and Estate Litigator
Estate planning from a Corporate Trustee and Litigator's point of view. A Corporate Trustee's Fiduciary Counsel and an Estate Planner and Litigator discuss areas of consideration, concern, and contention in the administration of trusts, which may be resolved by careful planning.
11:30amGet Lunch and Visit with Sponsors
12:00pm - 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.
1:10 - 2:10pmJustin Miller
Evercore Wealth Management and Evercore Trust Company, N.A.
Don't Guess and Make a Mess with QSBS
This presentation will cover the basics of qualified small business stock (QSBS) under section 1202, show you how founders can "stack" multiple capital gain exclusions among family members, address how non-grantor trusts can be the ultimate tool for QSBS planning to protect family members and minimize state income taxes, and discuss the challenges in non-grantor trust drafting compared to the more commonly used irrevocable grantor trusts.
2:15 - 3:15pmPanel Discussion,
Lawrence J. Chastang, CPA, TEP

Chastang & Partners, LLC
Michael Lampert, J.D., LL.M.
Law Offices of Michael A. Lampert, P.A.
A. Brian Phillips
A. Brian Phillips, P.A.
Shawn P. Wolf
Bilzin Sumberg Baena Price & Axelrod LLP
Fred F. Murray (Moderator)
Multijurisdictional Ethics Issues - Working with Inbound Investors & Businesses - Some Things You May Not Think About May Hurt You
Practitioners who represent foreign (and domestic) clients face problems that not only raise ethics issues (like practicing in more than one jurisdiction – e.g., license issues, language issues, as well as knowledge of other jurisdictions), but importantly may also involve them and their clients in a number of reporting requirements and even scrutiny under federal money laundering and other statutes that impose criminal liability. These situations require thought about due diligence on accepting clients from other jurisdictions who may have needs or motives besides having a house in Florida – tax evasion, reporting of income and assets, etc. This panel will discuss matters you really need to consider and actions you need to take to represent inbound clients.
3:15pmClosing Remarks

Thank you to our Sponsors!

Diamond Sponsor

UF Law Tax Program 50th Anniversary Dinner Sponsor

UF Law Tax Program 50th Anniversary Reception Sponsor

Gold Sponsors

Student Networking Luncheon Sponsor

A. Brian Phillips, P.A.