67^th Annual

Taxation Conference

Austin Dec 4-5, 2019 AT&T Conference Center
Conference Concluded

Overview

UT Law CLE’s 2019 Taxation Conference presents the expertise and in-depth analysis essential to understanding where tax law is, where it came from, and where it is going. With a renowned slate of regional and national speakers, the conference is a must attend event for those looking to keep current amidst a dramatically changing tax landscape.

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 4, 2019
Day 2 December 5, 2019

Time

Credit

Subject

Speaker
Wednesday Morning, Dec. 4, 2019
Presiding Officer:
Jimmy Martens, Martens, Todd, Leonard & Ahlrich - Austin, 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.

Stanley L. Blend, Clark Hill Strasburger - San Antonio, TX

Stanley L. Blend, Clark Hill Strasburger - San Antonio, TX
10:30 am

Break
10:45 am

1.00 hr

Partnership Audits

George Hani, Miller & Chevalier Chartered - Washington, DC

George Hani, Miller & Chevalier Chartered - Washington, DC
11:45 am

0.75 hr

Law and Order: STC (State Tax Cases)

Hear opposing views from two lawyers whose practices focus on Texas franchise and sales tax cases. Jack Hohengarten, Chief of the Tax Division representing the Comptroller, explains the Comptroller’s litigating positions from significant 2018 and 2019 state tax cases. Lacy Leonard, a law partner in an Austin, Texas firm focusing exclusively on the trials and related appeals of the same cases, explains the taxpayers’ positions. They can’t both be correct. So, you be the judge.

Jack Hohengarten, Office of the Attorney General - Austin, TX
Lacy Leonard, Martens, Todd, Leonard & Ahlrich - Austin, TX

Jack Hohengarten, Office of the Attorney General - Austin, TX
Lacy Leonard, Martens, Todd, Leonard & Ahlrich - Austin, TX
12:30 pm

Pick Up Lunch

Included in registration.
Wednesday Afternoon, Dec. 4, 2019
Presiding Officer:
Catherine C. Scheid, Attorney at Law - Houston, TX
LUNCHEON PRESENTATION
12:50 pm

0.75 hr

Tax After 2017: Requiem for Ability to Pay

Enactment of the TCJA was followed by a mad dash to understand its effects; the speed and process of enactment left no time for serious attempts to analyze whether the TCJA transformed the income tax system in any fundamental way. But it has, and Professor Abreu explains how.

Professor Alice G. Abreu, Temple University Beasley School of Law - Philadelphia, PA

Professor Alice G. Abreu, Temple University Beasley School of Law - Philadelphia, PA
1:35 pm

Break
1:50 pm

0.75 hr

A Multistate View of SALT

Learn about the latest legislation, cases, and developments in other states and at the federal level affecting state and local tax responsibilities and enforcement. Address practical state and local tax issues for businesses operating in a changing multistate and international environment.

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

Christina A. Mondrik, Mondrik & Associates - Austin, TX
Nancy L. Prosser, Texas Comptroller of Public Accounts - Austin, TX
2:35 pm

1.00 hr

Voluntary Disclosure Practice and Hot Topics in IRS Enforcement

This presentation discusses both the IRS and practitioner views of the revised voluntary disclosure practice, as well as hot topics and trending issues in IRS enforcement. Explore the key ethical considerations in navigating the decision between making voluntary disclosures, using the Streamlined Filing Compliance Procedures, and making quiet disclosures.

Charles J. "Chad" Muller III, Chamberlain, Hrdlicka, White, Williams & Aughtry - San Antonio, TX
Daniel N. Price, Internal Revenue Service - Austin, TX

Charles J. "Chad" Muller III, Chamberlain, Hrdlicka, White, Williams & Aughtry - San Antonio, TX
Daniel N. Price, Internal Revenue Service - Austin, TX
3:35 pm

Break
3:45 pm

1.50 hrs ethics

Obligation to Report Tax-Related Misconduct

Is there an ethical or legal obligation upon attorneys and/or judges to report tax misconduct such as fraud, false verification, etc. of the parties? Explore the obligations imposed upon the courts and the attorneys when there is evidence of tax-related misconduct and developing trends in that area.

Moderator:
Frank Agostino, Agostino & Associates, P.C. - Hackensack, NJ
Panelists:
Daniel Fannin, Internal Revenue Service, Criminal Investigation - Austin, TX
Marilea W. Lewis, Duffee + Eitzen - Dallas, TX

Moderator:
Frank Agostino, Agostino & Associates, P.C. - Hackensack, NJ
Panelists:
Daniel Fannin, Internal Revenue Service, Criminal Investigation - Austin, TX
Marilea W. Lewis, Duffee + Eitzen - Dallas, TX
5:15 pm

Adjourn

Time

Credit

Subject

Speaker
Thursday Morning, Dec. 5, 2019
Presiding Officer:
Maxine Aaronson, Attorney at Law - Dallas, TX
7:30 am

Conference Room Opens

Includes continental breakfast.
9:00 am

1.00 hr

Qualified Opportunity Zones

Established by the Tax Cuts and Jobs Act to generate development and growth in low-income communities, this presentation focuses on the tax benefits of investing in a qualified opportunity fund and the statutory requirements, including formation, funding, testing, and ongoing compliance considerations of the program.

Katherine Noll, Chamberlain, Hrdlicka, White, Williams & Aughtry - San Antonio, TX

Katherine Noll, Chamberlain, Hrdlicka, White, Williams & Aughtry - San Antonio, TX
10:00 am

1.00 hr

New Rules on Section 461(l): Limitations on Excess Business Losses

While partnerships and LLCs are “flow-through” entities, a series of rules restrict the “flow” of losses. Examine the latest restriction—Section 461(l)—and the loss limiters before it—Sections 704(d)(basis), 465 (at-risk) and 469 (PALs).

R. Brent Clifton, Winstead PC - Dallas, TX

R. Brent Clifton, Winstead PC - Dallas, TX
11:00 am

Break
11:15 am

1.00 hr

Analysis of the Financial and Income Tax Aspects When an Earnout is Used for the Sale of a Business

When a buyer and seller cannot agree upon a price for a business, an earnout is used and may result in selling the business for less than its true value. The materials discuss how earnout formulas can be adjusted to ensure that true value is paid. Because earnouts can result in adverse income tax treatment to the seller, the materials apply the installment sale and OID rules to illustrate the income tax treatment of earnouts and how to eliminate these adverse income tax results.

Jerome M. Hesch Esq., Adjunct Professor of Law - Miami, FL

Jerome M. Hesch Esq., Adjunct Professor of Law - Miami, FL
12:15 pm

Pick Up Lunch

Included in registration.
Thursday Afternoon, Dec. 5, 2019
Presiding Officer:
Patrick L. O'Daniel, Norton Rose Fulbright - Austin, TX
LUNCHEON PRESENTATION
12:35 pm

0.75 hr ethics

Ethical Issues Relating to the Use of Social Media and Blogging by Lawyers and Law Firms

Social media is a great new tool—we are bombarded with messages about the benefits for us as lawyers in credentialing and marketing ourselves, and educating the public with our blogs on legal issues. Many lawyers and judges use it successfully. Of course, it’s so easy to use these tools that we sometimes don’t remember that we can also make missteps. Also, our clients use (misuse) their accounts to talk about us. And when we or others do, social media is also there to show the resulting gaffe to (potentially) thousands if not millions of people.

Fred F. Murray, Washington, DC

Fred F. Murray, Washington, DC
1:20 pm

Break
1:35 pm

1.00 hr

Is Time Up On Auer? The Application of Authority in the Changing World of Deference

Courts continue to consider whether and to what extent agencies are entitled to deference with respect to their interpretation of statutory provisions and legislative intent. Review the history of the Administrative Procedure Act, various forms of agency guidance, and key judicial decisions addressing deference. Against this backdrop, discuss how the current landscape and recent developments may impact tax administration and enforcement.

Caroline D. Ciraolo, Kostelanetz & Fink, LLP - Washington, DC
Abbey B. Garber, Thompson & Knight LLP - Dallas, TX

Caroline D. Ciraolo, Kostelanetz & Fink, LLP - Washington, DC
Abbey B. Garber, Thompson & Knight LLP - Dallas, TX
2:35 pm

0.75 hr

Section 199A: Nuts and Bolts

Learn about the Section 199A qualified business income deduction, from the statutory basics to the recently issued Treasury and IRS guidance. Discuss qualified trade or business income, rental real estate and the safe harbor, the various limitations on the 199A deduction, the aggregation rules under the regulations, and other key practical aspects of 199A.

Jessica L. Kirk, Thompson & Knight LLP - Dallas, TX

Jessica L. Kirk, Thompson & Knight LLP - Dallas, TX
3:20 pm

1.25 hrs

Section 199A: Planning

Hear a brief overview of Section 199A concepts and discuss how to structure existing and new businesses to maximize the deduction and offer a comparison to operating a business as a C corporation.

Daniel H. McCarthy, Wick, Phillips, Gould & Martin, LLP - Fort Worth, TX

Daniel H. McCarthy, Wick, Phillips, Gould & Martin, LLP - Fort Worth, TX
4:35 pm

Adjourn

Day 1 December 4, 2019
Day 2 December 5, 2019

Download Schedule

Conference Faculty

Professor Alice G. Abreu

Temple University Beasley School of Law
Philadelphia, PA

Frank Agostino

Agostino & Associates, P.C.
Hackensack, NJ

Stanley L. Blend

Clark Hill Strasburger
San Antonio, TX

Caroline D. Ciraolo

Kostelanetz & Fink, LLP
Washington, DC

R. Brent Clifton

Winstead PC
Dallas, TX

Daniel Fannin

Internal Revenue Service, Criminal Investigation
Austin, TX

Abbey B. Garber

Thompson & Knight LLP
Dallas, TX

George Hani

Miller & Chevalier Chartered
Washington, DC

Jerome M. Hesch Esq.

Adjunct Professor of Law
Miami, FL

Jack Hohengarten

Office of the Attorney General
Austin, TX

Jessica L. Kirk

Thompson & Knight LLP
Dallas, TX

Lacy Leonard

Martens, Todd, Leonard & Ahlrich
Austin, TX

Marilea W. Lewis

Duffee + Eitzen
Dallas, TX

Daniel H. McCarthy

Wick, Phillips, Gould & Martin, LLP
Fort Worth, TX

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Charles J. "Chad" Muller III

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

Fred F. Murray

Washington, DC

Katherine Noll

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

Daniel N. Price

Internal Revenue Service
Austin, TX

Nancy L. Prosser

Texas Comptroller of Public Accounts
Austin, TX

Planning Committee

Catherine C. Scheid—Chair

Attorney at Law
Houston, TX

Patrick L. O'Daniel—Vice-Chair

Norton Rose Fulbright
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

Clark Hill Strasburger
San Antonio, TX

Michael L. Cook

Cook Brooks Johnson PLLC
Austin, TX

Joel N. Crouch

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

Jimmy Martens

Martens, Todd, Leonard & Ahlrich
Austin, TX

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Charles J. "Chad" Muller III

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

T. Charles Parr III

Parr & Associates
San Antonio, TX

Credit Info

Austin

MCLE Credit

Texas – 14.50 hrs | 2.25 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 – 14.50 hrs | 2.25 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 – 17.50 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) – 17.50 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 – 17.50 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

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 once you claim and certify your credits in your UTCLE.org Briefcase 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.

TX Accounting CPE – 17.50 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 4-5, 2019 – AT&T Conference Center

Conference Concluded

Buy

Austin

Individual
Last day for $575.00 Regular pricing: Dec 4, 2019
$625.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $520.00 Regular pricing: Dec 4, 2019
$570.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $460.00 Regular pricing: Dec 4, 2019
$510.00 for registrations received after this time

Cancellation Policy
Last day for full refund cancellation: Nov 25, 2019
$50 processing fee applied after this date
Last day for cancellation: Dec 2, 2019

Venue

AT&T Conference Center

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

Accommodations

$189 room rate good through November 4, 2019 (subject to availability).

Book your room online here or call the reservations department at 877-744-8822 and reference the Taxation & Estate Planning Conference. The reservations link will be active until the room block is full or the cutoff date of 11/4/19, whichever comes first.

Parking Information

Daily self-parking will be validated for the AT&T Conference Center Garage or surrounding UT garages. Please note Dobie is not a UT garage and parking cannot be validated. Separate fees apply for valet and overnight parking.

Our Sponsors

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

BBVA

BBVA
www.bbvausa.com

Since 1964, BBVA has offered customized personal trust services. Dating back to Central Bank & Trust in Birmingham and River Oaks Bank & Trust in Houston, the rich heritage of domestic trust services for wealthy clients has been passed down to clients and prospects across our growing footprint. Today, we combine the strength and reach of a global bank with the same boutique service that clients and beneficiaries have enjoyed for over 50 years. We work closely with your tax and legal advisors to provide a comprehensive, team approach to protecting family wealth for multiple generations.

Your will or trust agreement will express your wishes and the manner in which your assets should be managed by a trustee or executor, whether the named fiduciary is BBVA or an individual. In cases in which an individual is appointed as a fiduciary, BBVA can offer support and expertise through an agency relationship with the individual.
Martens, Todd, Leonard & Ahlrich

Martens, Todd, Leonard & Ahlrich
www.texastaxlaw.com

A boutique law firm located in downtown Austin, Texas. We limit our practice to handling Texas tax controversies and litigation. We represent clients in all stages: including audits, administrative hearings, trials, and appeals. We have successfully tried numerous Texas sales tax and franchise tax cases and handled the ensuing appeals: Combs v. Roark Amusement & Vending, L.P.; Taylor & Hill, Inc. v. Combs; Combs v. Newpark Resources, Inc.; Titan Transportation, LP v. Combs; Hegar v. CGG Veritas Services (U.S.), Inc.; Garriott v. Combs; Hegar v. Gulf Copper and Manufacturing Corp.; and Pointsmith Point-of-Purchase Management Services, LP v. Hegar.
Thompson & Knight LLP

Thompson & Knight LLP
www.tklaw.com

Taxation Conference

Overview

Event Schedule

Wednesday Morning, Dec. 4, 2019

Wednesday Afternoon, Dec. 4, 2019

Thursday Morning, Dec. 5, 2019

Thursday Afternoon, Dec. 5, 2019

Conference Faculty

Planning Committee

Credit Info

MCLE Credit

Other Credit

Key Dates

Venue

AT&T Conference Center

Accommodations

Parking Information

Our Sponsors

BBVA

Martens, Todd, Leonard & Ahlrich

Thompson & Knight LLP

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