64^th Annual

Taxation Conference

Austin Nov 30 - Dec 1, 2016 Radisson Hotel and Suites, Austin-Downtown
Conference Concluded

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

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

Day 1 November 30, 2016
Day 2 December 1, 2016

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

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

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

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

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

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

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 Enforcement—Employers 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

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

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

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

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

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

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

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

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

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

Leslie C. Thorne, Haynes and Boone, LLP - Austin, TX
Emily Westridge Black, Haynes and Boone, LLP - Austin, TX
4:30 pm

Adjourn

Day 1 November 30, 2016
Day 2 December 1, 2016

Download Schedule

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

Austin

MCLE Credit

Texas – 14.00 hrs | 2.00 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 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.

California – 14.00 hrs | 2.00 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.

Oklahoma – 17.00 hrs | 2.50 hrs Ethics

You must claim and certify your credit online in Your Briefcase, then you 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) – 20.50 hrs

This course has been approved for Certified Financial Planner (CFP) credit. UT Law CLE will report your credit for you, but we do require that you claim the credit in your Briefcase and ensure your CFP number is add in your account. Contact us at accreditation@utcle.org if you have additional questions.

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

National Accounting CPE – 16.50 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 (UT Law CLE is a provider of NASBA Group-Live credit only, which excludes online offerings.

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

Individual
Last day for $495.00 Regular pricing: Nov 23, 2016
$545.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $445.00 Regular pricing: Nov 23, 2016
$495.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $395.00 Regular pricing: Nov 23, 2016
$445.00 for registrations received after this time

Cancellation Policy
Last day for full refund cancellation: Nov 18, 2016
$50 processing fee applied after this date
Last day for cancellation: Nov 28, 2016

Venue

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

Our Sponsors

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

Bessemer Trust Company, N.A.

Bessemer Trust Company, N.A.
www.bessemer.com

Privately owned and independent, Bessemer Trust is a multifamily office that has served individuals and families of substantial wealth for more than 100 years. Through comprehensive investment management, wealth planning, and family office services, we help clients achieve peace of mind for generations.
We believe that our firm is truly like no other. Our unique strengths include: Private Ownership for long-term thinking, which enables better decision making; Singular Focus, with over 109 years of direct wealth management experience leading to comprehensive advice; Alignment of Interests, means owners’, employees’, and clients’ assets managed side-by-side; Proactive Wealth Management, with a client–to-employee ratio of 3:1; Exceptional Client Satisfaction: 10-year client asset retention rate of 98%.
To learn more about Bessemer Trust, please contact Scott Deke, Senior Vice President, at 214- 981-9400, or visit bessemer.com. Minimum relationship $10 million.
Martens, Todd, Leonard, Taylor & Ahlrich

Martens, Todd, Leonard, Taylor & Ahlrich
Martens, Todd, Leonard, Taylor & Ahlrich

A boutique law firm located in Austin, Texas. We focus our practice on tax controversies and civil appeals. On the tax side, we represent clients in all stages of state and federal tax controversies, including audits, administrative hearings, trials, and appeals. We also handle tax litigation in Louisiana, Oklahoma, New Mexico, and Colorado. Our appellate practice extends beyond tax and includes a wide range of commercial and high-asset divorce disputes. And, because appellate success is greatly influenced by trial court proceedings, we provide critical trial and dispositive motion support and strategy in advance of any interlocutory order or final judgment.

Taxation Conference

Overview

Event Schedule

Wednesday Morning, Nov. 30, 2016

Wednesday Afternoon, Nov. 30, 2016

Thursday Morning, Dec. 1, 2016

Thursday Afternoon, Dec. 1, 2016

Conference Faculty

Planning Committee

Credit Info

MCLE Credit

Other Credit

Key Dates

Venue

Radisson Hotel and Suites, Austin-Downtown

Accommodations

Parking Information

Our Sponsors

Bessemer Trust Company, N.A.

Martens, Todd, Leonard, Taylor & Ahlrich

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