UT Law CLE

63^rd Annual

Taxation Conference

Austin Dec 2-3, 2015 Radisson Hotel and Suites, Austin-Downtown
Conference Concluded

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SPONSORS
Bracewell & Giuliani LLP
Branscomb | PC
Chamberlain, Hrdlicka, White, Williams & Aughtry
KPMG LLP
Martens, Todd, Leonard, Taylor & Ahlrich

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Overview

The 63rd Annual Taxation Conference features an impressive slate of topics with regionally and nationally renowned speakers covering current trends, updates in tax regulation and policy, and much more.

Gain insight into corporate taxation, reform efforts, and the state of the tax world with Mark Prater, Deputy Staff Director and Chief Tax Counsel for the United States Senate Finance Committee
Get the latest on Texas State and Local tax law changes, including the impact of recent legislative and judicial developments
Hear from Glenn A. Hegar, new Texas Comptroller of Public Accounts, on his plans for the office
Collect practical tips for working with foreign partnerships and real estate investments
Explore recent developments in federal income taxation with Professor Bruce McGovern
Earn up to 2.25 hours of ethics credit, including an hour on Ethics Landmines for 2015

Continue on Friday with Professor Stanley M. Johanson’s popular one-day Estate Planning Workshop offering lively discussion, practical advice and updates.

Event Schedule

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

Day 1 December 2, 2015
Day 2 December 3, 2015

Time

Credit

Subject

Speaker
Wednesday Morning, Dec. 2, 2015
Presiding Officer:
James F. Martens, Martens, Todd, Leonard, Taylor & Ahlrich - Austin, TX
7:30 am

Registration Opens

Includes continental breakfast.
8:35 am

Welcoming Remarks
8:45 am

2.00 hrs

Recent Developments in Federal Income Taxation

Review significant court decisions, rulings and statutory and regulatory developments of the past year.

Bruce A. McGovern, South Texas College of Law - Houston, TX
10:45 am

Break
11:00 am

1.00 hr

Texas State Tax Update

Assess the Texas sales and use tax and franchise tax legislative amendments, recent court cases, administrative developments, and trending issues. Specific topics include: sales tax legislation for aircraft leases, ongoing franchise tax apportionment litigation, the impact of the Texas Supreme Court’s denial of Petition in Titan Transportation, the Third Court of Appeals’ decision in Ryan, LLC regarding refund prerequisites, and Texas’s attempt to create taxing nexus through software licensing.

Danielle Ahlrich, Martens, Todd, Leonard, Taylor & Ahlrich - Austin, TX
12:00 pm

Pick Up Lunch

Included in registration.
Wednesday Afternoon, Dec. 2, 2015
Presiding Officer:
Christina A. Mondrik, Mondrik & Associates - Austin, TX
LUNCHEON PRESENTATION
12:20 pm

0.50 hr

Report from the CFO of Texas

Comptroller Hegar will discuss the trends and issues affecting the Texas economy and its regions. Understanding where we are today can help all of us ensure that we remain prosperous tomorrow.

Glenn A. Hegar, Comptroller, Texas Comptroller of Public Accounts - Austin, TX
12:50 pm

Break
1:05 pm

1.00 hr
0.25 hr ethics

S Corporation Opportunities and Pitfalls

S Corporation elections are popular, especially among small business owners. However, many business owners who have made the election are unaware of potential risks related to assignment of income, reasonable compensation requirements, and other lurking issues. Uncover common audit issues related to S Corporations, how businesses may avoid them, and considerations to discuss with taxpayers related to their choice of entity and whether it continues to make sense as time progresses.

Christina A. Mondrik, Mondrik & Associates - Austin, TX
2:05 pm

1.00 hr

Crossing the State Tax Nexus Line—To Which States Must Tax Be Paid and How Much Is Owed?

Economic nexus (being subject to tax due to the mere presence of customers in a state) has been adopted by numerous states. Single-sales-factor market-based apportionment has similarly been adopted by numerous states. The intersection of these two developments means that virtually all businesses must be prepared to determine to what states income and other business activity taxes must be paid and how much tax may be due. Explore these issues and concerns so businesses can decide whether to pay, reserve, and/or fight.

Arthur R. Rosen, McDermott Will & Emery - New York, NY
3:05 pm

Break
3:15 pm

1.00 hr ethics

Ethics Landmines for 2015

Hear observations from the Former Director of the Office of Professional Responsibility as panelists discuss and apply the ethical standards to current and recurring fact patterns typical to a 2015 Federal tax practice.

Karen L. Hawkins, Former Director, Office of Professional Responsibility - Washington, DC
Charles J. "Chad" Muller, Chamberlain, Hrdlicka, White, Williams & Aughtry - San Antonio, TX
Fred F. Murray, Grant Thornton LLP - Washington, DC
4:15 pm

Adjourn

Time

Credit

Subject

Speaker
Thursday Morning, Dec. 3, 2015
Presiding Officer:
Dennis B. Drapkin, Southern Methodist University Dedman School of Law - Dallas, TX
7:30 am

Conference Room Opens

Includes continental breakfast.
8:30 am

1.00 hr ethics

Circular 230 Update

Consider the recent court decisions and regulatory changes that have reshaped Circular 230, including implications for practitioners.

Dennis B. Drapkin, Southern Methodist University Dedman School of Law - Dallas, TX
9:30 am

1.00 hr

Investment in United States Real Property by Non-U.S. Investors

Many foreign individuals, pension plans and governments are looking at investments in U.S. real estate. Taxation is a major part of any investment decision, and if such an investment is properly structured, the foreign investor could pay little or no U.S. tax. Learn how to structure foreign investment in U.S. real estate to minimize U.S. taxation and withholding.

Richard M. Lipton, Baker & McKenzie - Chicago, IL
10:30 am

Break
10:45 am

1.00 hr
0.50 hr ethics

Eggshell Audits: Handling IRS Examinations When There Are Potential Criminal Issues

Review issues that arise during IRS civil audits of individuals and businesses in which the revenue agent is unaware of material errors and possible fraudulent conduct with respect to the returns. Topics include: the role of IRS Fraud Technical Advisors; the client decision between cooperation and remaining silent to avoid self-incrimination; the use of Kovel accountants; the government’s use of administrative summonses; the problems presented by large corporate investigations and parallel proceedings; and the signs that a case may have been referred for criminal investigation.

Larry A. Campagna, Chamberlain, Hrdlicka, White, Williams & Aughtry - Houston, TX
11:45 am

Pick Up Lunch

Included in registration.
Thursday Afternoon, Dec. 3, 2015
Presiding Officer:
Susan C. Morse, The University of Texas School of Law - Austin, TX
LUNCHEON PRESENTATION
12:05 pm

1.00 hr

State of the Tax World

An update on Federal Tax Legislation, including developments on corporate and international tax issues.

Christopher Hanna, Southern Methodist University Dedman School of Law - Dallas, TX
1:05 pm

Break
1:20 pm

1.00 hr

Partnership Equity Compensation—Crescent Holdings and Related Issues

Review the implications of the failure to make a Section 83(b) election with respect to an unvested compensatory partnership interest and how such implications may differ depending upon whether the partnership interest is a capital interest or a profits interest.

Bahar A. Schippel, Snell & Wilmer LLP - Phoenix, AZ
2:20 pm

1.00 hr

The Final Tangible Property Regulations: Practical Considerations in the Post-Implementation Period

The final tangible property regulations became effective for tax years beginning in 2014 and required most business taxpayers to file one or more changes in method of accounting to implement the new rules for acquisitions costs, material and supplies, de minimis expenses, repairs vs. improvements, and property dispositions. Many businesses implemented these regulations in some fashion, but due to the comprehensive impact of the rules and the heavy reliance on facts and circumstances, many businesses have more to do to evaluate their tax accounting methods for tangible property, including offices buildings, retail properties, manufacturing facilities and equipment, and other capital assets. This session will discuss the practical steps that businesses are taking to consider whether additional accounting method changes or the election of safe harbors could better optimize the tax accounting for tangible property costs going forward.

Carol Conjura, KPMG LLP - Washington, DC
3:20 pm

Break
3:30 pm

1.00 hr

The State of Section 1031 Drop-and-Swaps Thirty Years After Bolker and Magneson

Thirty years ago, the Ninth Circuit decided Bolker and Magneson. These cases became the foundation of Section 1031 drop-and-swap jurisprudence, and they remain relevant today. Reassess the Section 1031 law derived from these and other cases and rulings, identify various types of drop-and-swap transactions, and explore other legal concepts that could affect the tax treatment of intended drop-and-swaps. The coverage will lay the groundwork for considering various tax-planning strategies and recognizing potential pitfalls that drop-and-swaps present.

Bradley Borden, Brooklyn Law School - Brooklyn, NY
4:30 pm

1.00 hr

That Life Insurance Policy May Be Worth More Than You Think!

Review the various types of policies—whole life, term, group term, universal, variable universal, index universal and no lapse guarantee—and how they are used. This is followed by the often unclear policy valuation rules for each type of policy for income, gift, estate and GST purposes. Valuation issues constantly come up for planners in sales of policies, distributions from qualified plans, executive compensation and transfer tax purposes.

Donald O. Jansen, The University of Texas System - Austin, TX
5:30 pm

Adjourn

Day 1 December 2, 2015
Day 2 December 3, 2015

Download Schedule

Conference Faculty

Danielle Ahlrich

Martens, Todd, Leonard, Taylor & Ahlrich
Austin, TX

Bradley Borden

Brooklyn Law School
Brooklyn, NY

Larry A. Campagna

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

Carol Conjura

KPMG LLP
Washington, DC

Dennis B. Drapkin

Southern Methodist University Dedman School of Law
Dallas, TX

Christopher Hanna

Southern Methodist University Dedman School of Law
Dallas, TX

Karen L. Hawkins

Former Director, Office of Professional Responsibility
Washington, DC

Glenn A. Hegar

Comptroller, Texas Comptroller of Public Accounts
Austin, TX

Donald O. Jansen

The University of Texas System
Austin, TX

Richard M. Lipton

Baker & McKenzie
Chicago, IL

Bruce A. McGovern

South Texas College of Law
Houston, TX

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Charles J. "Chad" Muller

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

Fred F. Murray

Grant Thornton LLP
Washington, DC

Arthur R. Rosen

McDermott Will & Emery
New York, NY

Bahar A. Schippel

Snell & Wilmer LLP
Phoenix, AZ

Planning Committee

Joe Hull—Chair

Bracewell & Giuliani LLP
Austin, TX

Robert J. Peroni—Vice-Chair

The University of Texas School of Law
Austin, TX

Maxine Aaronson

Attorney at Law
Dallas, TX

Stephen R. Akers

Bessemer Trust
Dallas, TX

R. Gordon Appleman

Thompson & Knight LLP
Fort Worth, TX

Stanley L. Blend

Strasburger & Price, LLP
San Antonio, TX

Michael L. Cook

Cook Brooks Johnson PLLC
Austin, TX

Mickey R. Davis

Davis & Willms, PLLC
Houston, TX

Dennis B. Drapkin

Southern Methodist University Dedman School of Law
Dallas, TX

Donald O. Jansen

The University of Texas System
Austin, TX

Stanley M. Johanson

The University of Texas School of Law
Austin, TX

Calvin H. Johnson

The University of Texas School of Law
Austin, TX

James F. Martens

Martens, Todd, Leonard, Taylor & Ahlrich
Austin, TX

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Susan C. Morse

The University of Texas School of Law
Austin, TX

Charles J. "Chad" Muller

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

Patrick L. O'Daniel

Norton Rose Fulbright US LLP
Austin, TX

T. Charles Parr III

Parr & Associates
San Antonio, TX

Robert D. Probasco

The Probasco Law Firm
Dallas, TX

Catherine C. Scheid

Attorney at Law
Houston, TX

Kelli H. Todd

Martens, Todd, Leonard, Taylor & Ahlrich
Austin, TX

Bret Wells

University of Houston Law Center
Houston, TX

Credit Info

Austin

MCLE Credit

Texas – 14.50 hrs | 2.75 hrs Ethics
Legal Specialization(s): Estate Planning and Probate Law, 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 Monday. 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

California – 14.50 hrs | 2.75 hrs Ethics

At the conference, you will need to sign in on the Record of Attendance form at the registration desk. Self-report your CLE credit directly to the State Bar of California at calbar.ca.gov. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. UT Law CLE will maintain Attendance Records for four years.

Ohio – 14.50 hrs | 2.50 hrs Ethics

UT Law CLE will report credit on your behalf to The Supreme Court of Ohio within 30 days after the conference. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. You may also need to sign in at the registration desk if you are attending the live conference - please see staff for details.

Oklahoma – 17.50 hrs | 3.50 hrs Ethics

At the conference, you will need to sign in on the Record of Attendance form at the registration desk. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. UT Law CLE will report credit on your behalf to the Oklahoma Bar Association within 30 days after the conference.

Other Credit

Certified Financial Planner (CFP) – Expected – 0.00 hr

This course has been approved for Certified Financial Planner (CFP) credit. UT Law CLE will report your credit for you, but we do require your CFP license number and other information in order to do so. Accreditation Coordinator Laura Tolin will follow up with you to obtain this information within 7 days of the conference.

You can learn more at: http://www.cfp.net/

IRS Enrolled Agent – 17.00 hrs

The University of Texas School of Law is an IRS Approved Continuing Education (CE) Provider for Return Preparers and Enrolled Agents. Attendees claiming IRS CE credit must sign in with your Preparer Tax Identification Number (PTIN) to verify attendance. Attendance sign-in sheets will be available at the registration desk. A Certificate of Completion with the program number will be provided at the conclusion of the conference to keep for your records.

Reporting: UT Law will report credit to the IRS on your behalf. For programs that occur during the first nine months of the year, credit will be reported on a quarterly basis (by March 31, June 30, and September 30). For programs that occur during the fourth quarter (October 1 - December 31), credit will be reported within ten (10) days of the last day of the conference. UT Law CLE will maintain Attendance Records for four years.

National Accounting CPE – 17.00 hrs

The University of Texas School of Law is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

Delivery Method: Group-Live

To comply with NASBA Standards, attendees claiming CPE credit must sign in to verify attendance for each segment. Attendance sign-in sheets will be available at the registration desk. You will need your CPA license number to sign in. A CPE Certificate of Completion will be provided at the conclusion of the conference.

Reporting: CPAs are responsible for reporting CPE credits earned to their state's accountancy board, and must retain appropriate documentation of their participation in learning activities. Visit your state’s reporting website for more information or www.nasba.org.

Key Dates

Austin – Dec 2-3, 2015 – Radisson Hotel and Suites, Austin-Downtown

Conference Concluded

Buy

Austin

Last day for Individual early registration: Nov 24, 2015

Add $50 for registrations received after this time

Last day for Group (5 registrants minimum) early registration: Nov 24, 2015

Add $50 for registrations received after this time

Last day for Group (10 registrants minimum) early registration: Nov 24, 2015

Add $50 for registrations received after this time

Last day for cancellation (full refund): Nov 27, 2015

$50 processing fee applied after this date

Last day for cancellation: Nov 30, 2015

Venue

Radisson Hotel and Suites, Austin-Downtown

111 E. Cesar Chavez Street
Austin, TX
512.478.9611 (reservations)

Accommodations

$149 room rate good through November 1, 2015 (subject to availability).
Reserve your room online.

Parking Information

Daily Self-Parking: $4
Overnight Self-Parking: $10
Daily Valet Parking: $25

Our Sponsors

Thank you to our sponsors! Click each logo below to learn more.

Bracewell & Giuliani LLP

Bracewell & Giuliani’s tax group has significant experience with the tax issues arising in transactions in all aspects of the energy industry including upstream and midstream oil and gas, oil field services, power generation and transmission and renewables. We also render critical tax advice in transactions including acquisitions and dispositions, reorganizations, debt and equity financing and financial transactions including hedging arrangements. Additionally, members of our team have a tremendous depth of experience in estate tax planning. Understanding that estate planning is a very personal process, we treat our attorney-client relationships as paramount. Our experience enables us to pursue a variety of sophisticated strategies to assist our clients in protecting their wealth for future generations in the most tax-efficient manner possible. No matter what the tax issue, Bracewell attorneys are committed to the relationship and understanding of each client's goals and concerns.
bgllp.com
Branscomb | PC

Branscomb | PC’s tax group provides comprehensive tax planning and advice to individuals, business entities, trustees, and personal representatives of estates. We have substantial experience in tax-free reorganizations and sales of businesses, tax-free spin-offs of branches or divisions of businesses, planning for investment in and divestment of oil and gas, planning with respect to settlements and jury awards in tax litigation, and planning for infusion of capital into existing businesses. Our estate tax planning group specializes in helping clients minimize the transfer tax cost of passing wealth on to subsequent generations. Our tax lawyers regularly handle Internal Revenue Service audits, protest letters contesting tax adjustments and penalties, administrative proceedings, appeals, and estate and gift tax disputes that include the valuation of closely-held businesses. We have long history of helping clients resolve issues with Internal Revenue Service and know how to work within the tax system to achieve our clients’ tax goals.

branscombpc.com
Chamberlain, Hrdlicka, White, Williams & Aughtry

Chamberlain, Hrdlicka, White, Williams & Aughtry marks its fourth decade as a diversified law practice focused on the highest level of client service. Although we have grown to a firm of more than 100 attorneys with a wide variety of practice areas, personalized attention to our clients’ needs remains a hallmark of our heritage. We have built our reputation working with established businesses as well as entrepreneurs and individuals with sophisticated legal needs. Today, our tradition of personalized service continues to be valued by clients from the smallest start-up ventures to the largest multinational companies. chamberlainlaw.com
Martens, Todd, Leonard, Taylor & Ahlrich

Martens, Todd, Leonard, Taylor & Ahlrich

Martens, Todd, Leonard & Taylor focuses its practice on trials, appeals and administrative hearings involving the Texas franchise tax and Texas sales & use tax. We also represent clients in challenging assessments of federal income/estate and gift tax in the U.S. Tax Court, federal appeals courts, and U.S. Supreme Court. Our appellate practice includes all types of appeals. Our recent cases include:
Combs v. Roark Amusement & Vending, LP, 422 S.W.3d 632 (Tex. 2013); In Re: AllCat Claims Service, LP, 356 S.W.3d 455 (Tex. 2011); Combs v. Newpark Resources, Inc., 422 S.W.3d 46 (Tex. App.—Austin 2013, no pet.); Titan Transportation, LP v. Combs, 433 S.W.3d 625 (Tex. App.—Austin 2014, pet. filed); CGG Veritas Services (U.S.), Inc. v. Combs, No. D-1-GN-12-001316 (353rd Dist. Ct. Sept. 17, 2014), appeal docketed, No. 03-14-00713-CV (Tex. App.—Austin Nov. 10, 2014) and Graphic Packaging Corp. v. Combs, No. D-1-GN-12-003038 (353rd Dist. Ct. Mar. 18, 2014), appeal docketed, No. 03-14-00197-CV (Tex. App. – Austin Apr. 2, 2014).
textaxlaw.com
KPMG LLP

KPMG LLP, the audit, tax and advisory firm, is the U.S. member firm of KPMG International Cooperative ("KPMG International"). KPMG is a global network of professional firms providing Audit, Tax and Advisory services. We operate in 155 countries and have more than 162,000 people working in member firms around the world.

KPMG delivers a globally consistent set of multidisciplinary services based on deep industry knowledge. Our industry focus helps KPMG professionals develop a rich understanding of clients' businesses and the insight, skills, and resources required to address industry-specific issues and opportunities.
kpmg.com

63rd Annual

Taxation Conference

Austin Dec 2-3, 2015 Radisson Hotel and Suites, Austin-Downtown Conference Concluded

Buy

Related products: Materials

Overview

Event Schedule

Wednesday Morning, Dec. 2, 2015

Wednesday Afternoon, Dec. 2, 2015

Thursday Morning, Dec. 3, 2015

Thursday Afternoon, Dec. 3, 2015

Conference Faculty

Danielle Ahlrich

Bradley Borden

Larry A. Campagna

Carol Conjura

Dennis B. Drapkin

Christopher Hanna

Karen L. Hawkins

Glenn A. Hegar

Donald O. Jansen

Richard M. Lipton

Bruce A. McGovern

Christina A. Mondrik

Charles J. "Chad" Muller

Fred F. Murray

Arthur R. Rosen

Bahar A. Schippel

Planning Committee

Joe Hull—Chair

Robert J. Peroni—Vice-Chair

Maxine Aaronson

Stephen R. Akers

R. Gordon Appleman

Stanley L. Blend

Michael L. Cook

Mickey R. Davis

Dennis B. Drapkin

Donald O. Jansen

Stanley M. Johanson

Calvin H. Johnson

James F. Martens

Christina A. Mondrik

Susan C. Morse

Charles J. "Chad" Muller

Patrick L. O'Daniel

T. Charles Parr III

Robert D. Probasco

Catherine C. Scheid

Kelli H. Todd

Bret Wells

Credit Info

MCLE Credit

Other Credit

Key Dates

Austin

Venue

Radisson Hotel and Suites, Austin-Downtown

Accommodations

Parking Information

Our Sponsors

Martens, Todd, Leonard, Taylor & Ahlrich

Sign-Up for Our Hooked on CLE Monthly Newsletter

63^rd Annual

Austin Dec 2-3, 2015 Radisson Hotel and Suites, Austin-Downtown
Conference Concluded