University of Texas School of Law
64th Annual
Taxation Conference
Austin Nov 30 - Dec 1, 2016 Radisson Hotel and Suites, Austin-Downtown
Conference Concluded
SPONSORS
Bessemer Trust Company, N.A.
Martens, Todd, Leonard, Taylor & Ahlrich
 

UT Law CLE

2016 Taxation Conference

Program Features
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.

UT Law CLE

2016 Taxation Conference

7/18/18
Schedule

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

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

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

10:30 am
Break

10:45 am

1.00 hr

Traps and Pitfalls of the New Section 385 Regulations

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.

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

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

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.

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

 
1:05 pm
Break

1:20 pm

1.00 hr

Distinguishing and Planning around Individual Goodwill

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.

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

2:20 pm

1.00 hr

Civil and Criminal Employment Tax EnforcementEmployers Beware

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.

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

3:20 pm
Break

3:30 pm

1.00 hr

Welcome to America… Now What? U.S. Income Taxation and Other Reporting Requirements

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.

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

4:30 pm
Adjourn

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

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.

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

9:30 am

1.00 hr

New Partnership Audit Rules

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.

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

10:30 am
Break

10:45 am

1.00 hr
0.75 hr ethics

Crime and Marriage

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.

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

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

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.

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

 
1:05 pm
Break

1:20 pm

1.00 hr

Cancellation of Debt

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.

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

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

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.

Jerome M. Hesch Esq., Aventura, FL

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

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?

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

4:30 pm
Adjourn

UT Law CLE

2016 Taxation Conference

Faculty

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

UT Law CLE

2016 Taxation Conference

Credit Information

MCLE Credit

Texas
14.00 hrs  |  2.00 hrs Ethics
Legal Specialization(s): Estate Planning and Probate Law, Tax Law
Additional Information
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.  
California
14.00 hrs  |  2.00 hrs Ethics
Additional Information
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.  
Oklahoma
17.00 hrs  |  2.50 hrs Ethics
Additional Information
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.
Other States
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

Certified Financial Planner (CFP)
20.50 hrs
National Accounting CPE
16.50 hrs
Additional Information
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.

UT Law CLE

2016 Taxation Conference

Key Dates

Austin

  • Last day for Individual early registration: Nov 23, 2016
    Add $50 for registrations received after this time
  • Last day for cancellation (full refund): Nov 18, 2016
  • Last day for cancellation (partial refund): Nov 28, 2016
    $50 processing fee applied

UT Law CLE

2016 Taxation Conference

Hotel / Venue

Austin

Radisson Hotel and Suites, Austin-Downtown

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

UT Law CLE

2016 Taxation Conference

Sponsors