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Approved for 16.00 Hours of Certified Financial Planner (CFP) CE

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59th Annual

Taxation Conference

Austin Dec 7-8, 2011 AT&T Conference Center
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Overview

The 2011 Taxation Conference covers the latest in tax regulations and policy, including the annual Recent Developments in Federal Income Taxation with Marty McMahon and Daniel L. Simmons and Texas State Tax Current Developments with Jesse Ancira, General Counsel, Office of the Speaker of the Texas House.

Additional topics include: Amazon and the changing landscape of state tax nexus laws, the tax consequences of selling or dissolving closely-held businesses, international tax-withholding, offshore account reporting requirements, protecting the client and the tax preparer, the IRS's increased application of transferee liability, and much more.

On Friday, Stanley Johanson presents his popular one-day Estate Planning Workshop. Don’t miss up-to-date materials, lively discussion and practical advice.

Register for both the Taxation Conference and Estate Planning Workshop and save $50!

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Event Schedule

Program is subject to change.
All times are Central Time Zone.

  • Day 1 December 7, 2011
  • Day 2 December 8, 2011
  • Time
    Credit
    Subject
    Speaker
  • Wednesday Morning, Dec. 7, 2011
    Presiding Officer:
    Ira B. Shepard, University of Houston Law Center - Houston, TX
  • 8:00 am
    Registration Opens
    Includes continental breakfast.

  • 8:50 am
    Welcoming Remarks

  • 9:00 am
    2.00 hrs
    Recent Developments in Federal Income Taxation
    A discussion of the significant court decisions, rulings, and statutory and regulatory developments of the past twelve months.

    Martin J. McMahon Jr., University of Florida, Fredric G. Levin College of Law - Gainesville, FL
    Daniel L. Simmons, UC Davis School of Law - Davis, CA

  • 11:00 am
    Break

  • 11:15 am
    0.75 hr
    Texas State Tax Current Developments
    A report on recent developments affecting Texas state taxes.

    Jesse Ancira, Office of the Speaker of the House - Austin, TX

  • 12:00 pm
    Break to Pick Up Lunch
    Included in conference registration fee.

  • Wednesday Afternoon, Dec. 7, 2011
    Presiding Officer:
    Bret Wells, University of Houston Law Center - Houston, TX
  • Luncheon Presentation

  • 12:15 pm
    0.50 hr
    Scams that Hit Lawyers
    A discussion of what motivates seemingly honest people to commit fraud (the "fraud triangle") and employee embezzlement and client/prospective client schemes hitting lawyers and law firms recently.

    Alan D. Westheimer, Houston, TX

  • 12:45 pm
    Break

  • 1:00 pm
    1.00 hr
    Practical Tips on Drafting Tax Provisions in Partnership Agreements
    This session is designed to help you do a better job of representing your clients in transactions involving partnerships. Partnership agreements contain numerous tax-related provisions, some of which are quite subtle and tricky. Discussed are ways to draft language in these agreements in order to provide your clients with both procedural and substantive advantages, whenever possible, and to avoid being taken advantage of by the other side. 

    Thomas L. Evans, Kirkland & Ellis LLP - Chicago, IL

  • 2:00 pm
    1.00 hr
    Solving M&A Issues Using LLCs and the Check-the-Box Regulations
    This session provides an overview of innovative techniques using flexible corporate statutes and the check-the-box regulations to solve deal point issues while preserving the intended tax consequences, and to solve tax issues while not affecting the "business deal."

    Stephen A. Kuntz, Fulbright & Jaworski LLP - Houston, TX
    Robert William Phillpott Jr., Fulbright & Jaworkski L.L.P. - Houston, TX

  • 3:00 pm
    Break

  • 3:15 pm
    1.00 hr
    Tax Considerations in the Disposition of Privately Held Businesses
    This presentation addresses a number of issues that arise in the sale of a closely held business, including the ability to allocate a portion of the purchase price to the personal goodwill of the owners, application of the installment sale provisions in the context of earn-out agreements, and the tax treatment of covenants not to compete and agreements to provide future consulting services.

    R. David Wheat, Thompson & Knight LLP - Dallas, TX

  • 4:15 pm
    1.00 hr
    The Nexus Hokey Pokey: Are You In? Are You Out? Do You Shake It All About?
    This panel discusses federal and state laws governing taxing authority across state and local borders, including a discussion of Amazon laws and how new developments are changing the landscape of state tax nexus laws and how they apply to modern businesses.

    Christina A. Mondrik, Mondrik & Associates - Austin, TX
    Nancy L. Prosser, Texas Comptroller Of Public Accounts - Washington, DC

  • 5:15 pm
    Adjourn

  • Time
    Credit
    Subject
    Speaker
  • Thursday Morning, Dec. 8, 2011
    Presiding Officer:
    Maxine Aaronson, Attorney at Law - Dallas, TX
  • 8:00 am
    Conference Room Opens
    Includes continental breakfast.

  • 8:30 am
    1.00 hr ethics
    When Owners of a Closely Held Business Must Go Their Separate Ways
    Whether due to a need for liquidity, disagreement over operation of the business, or tension between employee and nonemployee owners of the entity, owners of closely held businesses frequently come to an impasse that requires the owners to part company. This presentation explores the tax consequences of structuring such separations, including split-ups of the business accomplished on a nonrecognition basis, taxable distributions of assets, redemptions of shareholder stock, cross-purchases of stock, liquidations, and other options.

    Rudolph R. Ramelli, Jones Walker - New Orleans, LA

  • 9:30 am
    0.75 hr
    International Tax: Focus on Withholding
    Withholding remains a Tier 1 issue for the IRS. This session focuses on withholding of tax on nonresident aliens and foreign corporations, and touches on the newly enacted Foreign Account Tax Compliance Act (FATCA) provisions.

    Amy K. T. Contreras, Ernst & Young LLP - San Antonio, TX

  • 10:15 am
    Break

  • 10:30 am
    1.25 hrs ethics
    Offshore Account Reporting Requirements
    The panelists have developed this session to assist professional advisors and taxpayers to comply with the filing obligations for U.S. individuals holding interests in foreign accounts. Topics include the Foreign Bank and Financial Accounts Report (FBAR), various IRS forms, recent developments in the area of offshore tax compliance and enforcement including criminal and civil enforcement actions, voluntary disclosures, the Foreign Account Tax Compliance Act, and other related developments.

    Moderator:
    Charles J. Muller III, Chamberlain, Hrdlicka, White, Williams & Martin - San Antonio, TX
    Panelists:
    Scott D. Michel, Caplin & Drysdale - Washington, DC
    Panelists:
    Mark Elliott Osborne, Osborne, Helman, Knebel & Deleery, L.L.P. - Austin, TX

  • 11:45 am
    Break to Pick Up Lunch
    Included in conference registration fee.

  • Thursday Afternoon, Dec. 8, 2011
    Presiding Officer:
    Kelli H. Todd, Martens, Seay & Todd - Austin, TX
  • Luncheon Presentation

  • 12:00 pm
    0.50 hr
    Federal Budget Discussion

    George K. Yin, University of Virginia School of Law - Charlottesville, VA

  • 12:30 pm
    Break

  • 12:45 pm
    1.00 hr
    Contribution among Responsible Persons under Section 6672(d)
    When more than one person is responsible for the Trust Fund Recovery Penalty, Section 6672(d) creates a right of contribution. But Congress left several unresolved issues when the Code was amended. Who should be liable for contribution? How should the contributions be apportioned by the court? Three exerienced practitioners discuss and debate these and related issues.

    Panelists:
    Larry A. Campagna, Chamberlain, Hrdlicka, White, Williams & Martin - Houston, TX
    Panelists:
    Robert Burford Jackson, The Roberts Law Firm - Dallas, TX
    Panelists:
    Larry Jones, Townsend & Jones, L.L.P. - Dallas, TX

  • 1:45 pm
    1.50 hrs ethics
    Protecting Your Clients and Practice, and Canal's Impact on Both
    This presentation reviews the various types of tax opinions and the requirements for each, taking into consideration the obligations imposed by Circular 230, and the usefulness of tax opinions in protecting the client from the accuracy-related penalty after Canal. The presentation also addresses the return preparer penalty and those individuals who may be surprised to find that they are subject to it.

    William Paul Bowers, Fulbright & Jaworski L.L.P. - Dallas, TX
    David G. Glickman, Baker & McKenzie - Dallas, TX

  • 3:15 pm
    Break

  • 3:30 pm
    0.75 hr
    Worker Classification Audits by the IRS
    A review of worker classification exams and developments.

    Heather M. Pesikoff, Chamberlain, Hrdlicka, White, Williams & Martin LLP - Houston, TX

  • 4:15 pm
    1.00 hr
    The New Application of Transferee Liability
    Transferee liability has long been part of the IRS collection arsenal. This session examines how its use has increased dramatically in recent years as the best alternative for intermediary, or "midco," transactions.

    Robert Dale Probasco, Thompson & Knight LLP - Dallas, TX

  • 5:15 pm
    Adjourn

  • Day 1 December 7, 2011
  • Day 2 December 8, 2011
Download Schedule

Conference Faculty

Jesse Ancira

Office of the Speaker of the House
Austin, TX

William Paul Bowers

Fulbright & Jaworski L.L.P.
Dallas, TX

Larry A. Campagna

Chamberlain, Hrdlicka, White, Williams & Martin
Houston, TX

Amy K. T. Contreras

Ernst & Young LLP
San Antonio, TX

Thomas L. Evans

Kirkland & Ellis LLP
Chicago, IL

David G. Glickman

Baker & McKenzie
Dallas, TX

Robert Burford Jackson

The Roberts Law Firm
Dallas, TX

Larry Jones

Townsend & Jones, L.L.P.
Dallas, TX

Stephen A. Kuntz

Fulbright & Jaworski LLP
Houston, TX

Martin J. McMahon Jr.

University of Florida, Fredric G. Levin College of Law
Gainesville, FL

Scott D. Michel

Caplin & Drysdale
Washington, DC

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Charles J. Muller III

Chamberlain, Hrdlicka, White, Williams & Martin
San Antonio, TX

Mark Elliott Osborne

Osborne, Helman, Knebel & Deleery, L.L.P.
Austin, TX

Heather M. Pesikoff

Chamberlain, Hrdlicka, White, Williams & Martin LLP
Houston, TX

Robert William Phillpott Jr.

Fulbright & Jaworkski L.L.P.
Houston, TX

Robert Dale Probasco

Thompson & Knight LLP
Dallas, TX

Nancy L. Prosser

Texas Comptroller Of Public Accounts
Washington, DC

Rudolph R. Ramelli

Jones Walker
New Orleans, LA

Daniel L. Simmons

UC Davis School of Law
Davis, CA

Alan D. Westheimer

Houston, TX

R. David Wheat

Thompson & Knight LLP
Dallas, TX

George K. Yin

University of Virginia School of Law
Charlottesville, VA

Planning Committee

Stanley M. Johanson—Chair

The University of Texas School of Law
Austin, TX

Ira B. Shepard—Chair

University of Houston Law Center
Houston, TX

Maxine Aaronson—Co-Chair

Attorney at Law
Dallas, TX

Stephen R. Akers

Bessemer Trust Company NA
Dallas, TX

R. Gordon Appleman

Thompson & Knight LLP
Fort Worth, TX

Carol A. Cantrell

Briggs & Veselka Co.
Bellaire, TX

Michael L. Cook

Cook Brooks Johnson PLLC
Austin, TX

Mickey R. Davis

Bracewell & Giuliani LLP
Houston, TX

Robert E. Davis

K&L Gates LLP
Dallas, TX

Dennis B. Drapkin

Jones Day
Dallas, TX

Joe Hull

Bracewell & Giuliani LLP
Austin, TX

Calvin H. Johnson

The University of Texas School of Law
Austin, TX

James F. Martens

Martens, Seay & Todd
Austin, TX

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Charles J. Muller III

Chamberlain, Hrdlicka, White, Williams & Martin
San Antonio, TX

Bernard B. Nelson

Internal Revenue Service
Houston, TX

Patrick Lewis O'Daniel

Fulbright & Jaworski L.L.P.
Austin, TX

T. Charles Parr III

Parr & Associates
San Antonio, TX

Elsbeth T. Peshel

Graves, Dougherty, Hearon & Moody, P.C.
Austin, TX

Jerry M. Scroggins Jr.

Fizer Beck Webster Bentley & Scroggins
Houston, TX

Jasper G. Taylor III

Fulbright & Jaworski L.L.P.
Houston, TX

Kelli H. Todd

Martens, Seay & Todd
Austin, TX

Bret Wells

University of Houston Law Center
Houston, TX

R. David Wheat

Thompson & Knight LLP
Dallas, TX

Credit Info

  • Austin
MCLE Credit
Toggle view Texas – 15.00 hrs  |  3.75 hrs Ethics
Legal Specialization(s): Tax Law
You may claim your credit online in Your Briefcase, and UT Law CLE will report credit on your behalf to the State Bar of Texas. A Certificate of Attendance will be provided in Your Briefcase for your records. The system reports Texas CLE credit every Tuesday. If you are claiming credit in the last week of your birth month, self-report your CLE credit directly to the State Bar of Texas at texasbar.com, using the course number  provided on your certificate of attendance.
Toggle view California – 15.00 hrs  |  3.75 hrs Ethics
You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. UT Law CLE is required to provide the State Bar with electronic attendance records for any MCLE participatory activity within 60 days of completion of the activity. The California licensee is responsible for reporting their compliance/credit hours earned to the State Bar at the end of their reporting period directly to the State Bar of California at calbar.ca.gov.  UT Law CLE will maintain Attendance Records for four years.  
Other Credit
Toggle view TX Accounting CPE – 18.00 hrs
The University of Texas School of Law (Provider #250) live conferences are presumptively approved by The Texas State Board of Public Accountancy for Texas Accounting CPE credit based on a 50-minute credit hour. Approved for general CPE credit only.

At the conference, you are welcome to sign in on the Accounting CPE Record of Attendance form at the registration desk, but we are now reporting all credit online. You will receive a Texas Accounting Certificate of Completion in Your Briefcase. Self-report your CPE credit directly to TSBPA. UT Law CLE will maintain Attendance Records for four years.  

Contact us at accreditation@utcle.org if you have additional questions.

Key Dates

Austin – Dec 7-8, 2011 – AT&T Conference Center
Conference Concluded
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  • Austin
Standard Registration
Last day for $460.00 Regular pricing: Dec 2, 2011

$510.00 for registrations received after this time

Green Registration - USB Key ONLY
Last day for $455.00 Regular pricing: Dec 2, 2011

$505.00 for registrations received after this time

Last day for cancellation (full refund): Dec 2, 2011

$50 processing fee applied after this date

Last day for cancellation: Dec 5, 2011

Venue

speaker

AT&T Conference Center

The University of Texas at Austin
1900 University Avenue
Austin, TX
877.744.8822 (reservations)
Map

Accommodations

$159.00 good through Nov 4, 2011

Parking Information

Free Daily Self-Parking at UT garages. Separate fees apply for valet and overnight parking.

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