Overview

The 64th 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. Highlights include:

  • Gain insight into The Traps and Pitfalls of the New Section 385 Regulations, including its impact on debt pushdown strategies.
  • The 2016 Election and Prospects for Tax Reform with Dr. Leonard E. Burman, Robert C. Pozen Director of the Tax Policy Center, Washington DC.
  • Explore the implications of crime on the family tax return – what is the impact of criminal gain by one partner in a marriage?
  • Review the new partnership audit rules, with an emphasis on drafting considerations for partnership and LLC agreements and other related documents.
  • Examine the federal income tax and information reporting provisions that may apply to non-resident aliens, resident liens, and U.S. persons receiving gifts from foreign persons.
  • Explore recent developments in federal income taxation with Professor Bruce McGovern.
  • Earn up to 2.00 hours of ethics credit, including an hour on Data Security, Client Confidences, and Ethics Rules Applicable to the Protection of Client Information.
Continue on Friday with Professor Stanley M. Johanson’s popular one-day Estate Planning Workshop offering lively discussion, practical advice and updates.

Event Schedule

  • Time
    Credit
    Subject
    Speaker
  • Wednesday Morning, Nov. 30, 2016
    Presiding Officer:
    Catherine C. Scheid, Attorney at Law - Houston, TX
  • 7:30 am
    Registration Opens

    Includes continental breakfast.
  • 8:20 am
    Welcoming Remarks

  • 8:30 am
    2.00 hrs
    Recent Developments in Federal Income Taxation

    Bruce A. McGovern, Houston College of Law - Houston, TX

    Review significant court decisions, rulings, and statutory and regulatory developments of the past year.
  • 10:30 am
    Break

  • 10:45 am
    1.00 hr
    Traps and Pitfalls of the New Section 385 Regulations

    Bret Wells, University of Houston Law Center - Houston, TX

    The Section 385 regulations are a sea-change event that will have profound impact given the three-year presumptions contained in the regulations and that they broadly apply to many deleveraging transactions and create a presumption of linkage. Explore the impact of Section 385 on debt pushdown strategies, potential workarounds to those impacts, scope limitations of the Section 385 regulations that define “tainted” debt versus “clean” debt, and the collateral damage of the Section 385 regulations to unanticipated situations.
  • 11:45 am
    Pick Up Lunch

    Included in registration.
  • Wednesday Afternoon, Nov. 30, 2016
    Presiding Officer:
    Maxine Aaronson, Attorney at Law - Dallas, TX
  • LUNCHEON PRESENTATION
  • 12:05 pm
    1.00 hr
    The 2016 Election and Prospects for Tax Reform

    Leonard E. Burman, Tax Policy Center - Washington, DC

    The presidential election could radically shape tax policy in the United States because the two candidates have starkly different proposals. Explore the implications of the election for tax policy over the short and long run.
  • 1:05 pm
    Break

  • 1:20 pm
    1.00 hr
    Distinguishing and Planning around Individual Goodwill

    Bruce A. Johnson, Munroe, Park & Johnson, Inc. - San Antonio, TX
    Kenton E. McDonald, Branscomb | PC - Corpus Christi, TX

    Practitioners and appraisers once dismissed distinguishing and planning around "individual goodwill" as far from serious. Now the practice is increasingly accepted and is in widespread use in ways which are, in fact, only a step or two away from negligence, if not fraud. Review these concepts and their limits, especially as they relate to structuring and restructuring around corporate lockup of built-in gains.
  • 2:20 pm
    1.00 hr
    Civil and Criminal Employment Tax EnforcementEmployers Beware

    Josh O. Ungerman, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P. - Dallas, TX

    The Department of Justice Tax Division and the IRS have once again elevated employment tax non-compliance to the top of their priority lists. Examine the government’s approach to businesses and individuals that fail to pay employment tax. Hear a discussion about IRS early action employment tax initiative, including often unexpected consequences of early IRS contact. Explore Professional Employer Organization certification, as well as the major risks and traps for the unwary in trust fund recover penalty investigations that may lead to and support a criminal prosecution. In addition to criminal investigations regarding employment tax matters, learn about injunctions which can actually result in a much shorter path to jail than a traditional criminal prosecution.
  • 3:20 pm
    Break

  • 3:30 pm
    1.00 hr
    Welcome to America… Now What? U.S. Income Taxation and Other Reporting Requirements

    T. Charles Parr III, Parr & Associates - San Antonio, TX

    Identify the federal income tax and information reporting provisions that may apply to non-resident aliens, resident aliens, and U.S. persons receiving gifts from foreign persons.
  • 4:30 pm
    Adjourn

  • Time
    Credit
    Subject
    Speaker
  • Thursday Morning, Dec. 1, 2016
    Presiding Officer:
    Robert J. Peroni, The University of Texas School of Law - Austin, TX
  • 7:30 am
    Conference Room Opens

    Includes continental breakfast.
  • 8:30 am
    1.00 hr
    0.25 hr ethics
    Personal Liability for Corporate Tax Assessments

    James F. Martens, Martens, Todd, Leonard, Taylor & Ahlrich - Austin, TX

    It’s your client’s worst nightmare. After serving as an officer, a director, or in some cases, an employee of a failed business, there’s a knock on the door. It’s from a sheriff serving a lawsuit alleging the client is personally liable for his or her employer's unpaid Texas taxes. Learn the laws that impose personal liability and how best to defend against it.
  • 9:30 am
    1.00 hr
    New Partnership Audit Rules

    Todd Keator, Thompson & Knight LLP - Dallas, TX
    Mary A. McNulty, Thompson & Knight LLP - Dallas, TX

    Recently, Congress repealed the current TEFRA regime and replaced it with new audit and collection procedures at the partnership level. Hear an overview of the new partnership audit rules, with an emphasis on drafting considerations for partnership and LLC agreements, and other related documents.
  • 10:30 am
    Break

  • 10:45 am
    1.00 hr
    0.75 hr ethics
    Crime and Marriage

    Ian M. Comisky, Fox Rothschild LLP - Philadelphia, PA
    William Cotter, Internal Revenue Service, Criminal Investigation - San Antonio, TX
    Mary T. Vidas, Blank Rome LLP - Philadelphia, PA

    What are the tax implications of crime on the family tax return? What is the impact of criminal gain by one partner in a marriage? Should a spouse have known the money was tainted? Is there an innocent spouse aspect to this? Consider these questions and more.
  • 11:45 am
    Pick Up Lunch

    Included in registration.
  • Thursday Afternoon, Dec. 1, 2016
    Presiding Officer:
    Christina A. Mondrik, Mondrik & Associates - Austin, TX
  • LUNCHEON PRESENTATION
  • 12:05 pm
    1.00 hr
    Avoiding Tax Malpractice

    Arthur J. "Kip" Dellinger, Cooper, Moss, Resnick, Klein & Co., LLP - Sherman Oaks, CA

    Tax practitioners are continuously confronted with potential potholes and landmines when preparing tax returns for and advising a client with regard to tax matters. Hear a discussion of the malpractice landscape for attorney and CPA tax practitioners with a focus on identifying risks and steps that may be taken to avoid exposure.
  • 1:05 pm
    Break

  • 1:20 pm
    1.00 hr
    Cancellation of Debt

    Crawford Moorefield, Strasburger & Price, LLP - Houston, TX

    Explore how the downturn in the energy industry has made COD issues of more frequent concern, as have issues arising in connection with restructuring of debt obligations of partnerships and LLCs.
  • 2:20 pm
    1.00 hr
    Using Your Estate Planning Family Limited Partnership for Income Tax Planning, Both at Death and While One is Living

    Jerome M. Hesch Esq., Aventura, FL

    Discover how to use the partnership income tax rules to transfer appreciated assets, currently owned by irrevocable trusts, either directly or through partnerships, to an individual who can obtain an income tax-free step-up in basis at death. Learn how to use partnerships to increase the basis in appreciated assets that a partnership or an irrevocable trust intends to sell while the senior family member is living.
  • 3:20 pm
    Break

  • 3:30 pm
    1.00 hr ethics
    Data Security, Client Confidences, and Ethics Rules Applicable to the Protection of Client Information

    Leslie C. Thorne, Haynes and Boone, LLP - Austin, TX
    Emily Westridge Black, Haynes and Boone, LLP - Austin, TX

    Tax practitioners hold the keys—literally and figuratively—to some of their clients' most sensitive personal and financial information. Protecting this information has always been of paramount concern for practitioners and for the IRS. Explore the legal and regulatory context for the issue of data security from an ethics perspective. What do the ethics rules, including ABA Model Rule 1.6, require of practitioners in the area of data security and what are the consequences of violating those rules?
  • 4:30 pm
    Adjourn

Conference Faculty

Leonard E. Burman

Tax Policy Center
Washington, DC

Ian M. Comisky

Fox Rothschild LLP
Philadelphia, PA

William Cotter

Internal Revenue Service, Criminal Investigation
San Antonio, TX

Arthur J. "Kip" Dellinger

Cooper, Moss, Resnick, Klein & Co., LLP
Sherman Oaks, CA

Jerome M. Hesch Esq.

Aventura, FL

Bruce A. Johnson

Munroe, Park & Johnson, Inc.
San Antonio, TX

Todd Keator

Thompson & Knight LLP
Dallas, TX

James F. Martens

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

Kenton E. McDonald

Branscomb | PC
Corpus Christi, TX

Bruce A. McGovern

Houston College of Law
Houston, TX

Mary A. McNulty

Thompson & Knight LLP
Dallas, TX

Crawford Moorefield

Strasburger & Price, LLP
Houston, TX

T. Charles Parr III

Parr & Associates
San Antonio, TX

Leslie C. Thorne

Haynes and Boone, LLP
Austin, TX

Josh O. Ungerman

Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
Dallas, TX

Mary T. Vidas

Blank Rome LLP
Philadelphia, PA

Bret Wells

University of Houston Law Center
Houston, TX

Emily Westridge Black

Haynes and Boone, LLP
Austin, TX

Planning Committee

Robert J. Peroni—Chair

The University of Texas School of Law
Austin, TX

Christina A. Mondrik—Vice-Chair

Mondrik & Associates
Austin, TX

Deborah Salzberg—Director

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

Timothy J. Devetski

Sidley Austin LLP
Houston, TX

Dennis B. Drapkin

Southern Methodist University Dedman School of Law
Dallas, TX

Joe Hull

Bracewell
Austin, 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

Kenton E. McDonald

Branscomb | PC
Corpus Christi, TX

Charles J. "Chad" Muller

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

Patrick L. O'Daniel

Norton Rose Fulbright
Austin, TX

T. Charles Parr III

Parr & Associates
San Antonio, TX

Catherine C. Scheid

Attorney at Law
Houston, TX

Kelli H. Todd

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

Amanda Traphagan

Seay & Traphagan, PLLC
Austin, TX

Bret Wells

University of Houston Law Center
Houston, TX

Credit Info

MCLE Credit
A Texas MCLE Reporting Form will be included in your course materials. Please complete and return to the registration desk and UT Law CLE will report credit on your behalf to the State Bar of Texas, or you can self-report your credit directly to the State Bar of Texas at texasbar.com. A Certificate of Attendance will be provided at the conference to keep for your records.  
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 will receive a Certificate of Attendance at the conference to keep for your records. UT Law CLE will maintain Attendance Records for four years.  
At the conference, you will need to sign in on the Record of Attendance form at the registration desk. You will receive a Certificate of Attendance at the conference to keep for your records. UT Law CLE will report credit on your behalf to the Oklahoma Bar Association within 30 days after the conference.
Note on Self-Reporting Your Credits in Another State
If you wish to satisfy MCLE or other professional education requirements in another state for a program offered by the University of Texas School of Law, please check with the state bar or other licensing authority in that state before taking the program to ensure it will qualify for self-reporting your credits.
Other Credit
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 – Nov 30 - Dec 1, 2016 – Radisson Hotel and Suites, Austin-Downtown
Conference Concluded
Buy
Austin
Last day for Individual early registration: Nov 23, 2016

Add $50 for registrations received after this time

Last day for Group (5 registrants minimum) early registration: Nov 23, 2016

Add $50 for registrations received after this time

Last day for Group (10 registrants minimum) early registration: Nov 23, 2016

Add $50 for registrations received after this time

Last day for cancellation (full refund): Nov 18, 2016

$50 processing fee applied after this date

Last day for cancellation: Nov 28, 2016

Venue

speaker

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

Accommodations

$159 room rate good through October 30, 2016 (subject to availability). 
Reserve your room online

Parking Information

Daily Self-Parking: $6
Overnight Self-Parking: $10
Daily Valet Parking: $26

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