71^st Annual

Taxation Conference: Day 1 - Focus on Business Planning

Wednesday: Focus on Business Planning

Austin Dec 13, 2023 AT&T Conference Center
Conference Concluded

Live Webcast Dec 13, 2023
Conference Concluded

Overview

UT Law CLE’s 71st Annual 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.

We're continuing the 2-day agenda format from last year! The topics will be grouped according to the subject matter and each day will have a cohesive theme. Join us on Wednesday: Focus on Business Planning and/or Thursday: Focus on Tax Controversy.

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

Event Schedule

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

Time

Credit

Subject

Speaker
Wednesday Morning, Dec. 13, 2023
Presiding Officer:
T. Charles Parr III, ABIP, P.C. - San Antonio, TX
7:30 am
Austin Only

Conference Room Opens

Includes continental breakfast.
8:20 am

Welcoming Remarks
8:30 am

1.00 hr

Buy-In, Buy Out and Operational Considerations for Professional Practices and Closely held Businesses

Examine buy-in, buy-out, and operational issues related to a sole proprietorship, c-corporation, s-corporation, and partnership. Discuss buy-in, buy-out, and operational alternatives for an existing shareholder or partner to admit a new shareholder or partner or have one be bought out. Gain insight into operational issues, including new and existing partner compensation allocations, decisions requiring unanimous consent, and general operational issues.

Robb A. Longman, Longman & Van Grack, LLC - Bethesda, MD

Robb A. Longman, Longman & Van Grack, LLC - Bethesda, MD
9:30 am

1.00 hr

The Conservation Easement Controversy: IRS Attacks, Taxpayer Victories, and New Guidance

The IRS has been attacking partnerships that make easement donations in many ways, including making them listed transactions, launching a Compliance Campaign, seeking injunctions, placing them on the “dirty dozen” list, litigating numerous Tax Court cases, and more. Things have started to change, though, with several taxpayer victories, issuance of proposed regulations, enactment of a new law taking effect in 2023, and release of safe harbors for deeds. This presentation, made by an attorney who defends hundreds of easement disputes, explores IRS attacks, taxpayer defenses, important court decisions, and what to expect next.

Hale E. Sheppard, Chamberlain Hrdlicka - Atlanta, GA

Hale E. Sheppard, Chamberlain Hrdlicka - Atlanta, GA
10:30 am

15-Minute Break
10:45 am

1.00 hr ethics

Work Product and Attorney-Client Privilege after In Re Grand Jury: Where Do We Go From Here?

The law regarding when privileges and protections apply to tax advice was anything but clear leading up to the Supreme Court oral argument in In re: Grand Jury; the Court’s decision to dismiss the case as “improvidently granted” dashed the hopes of tax professionals hoping for a nationwide standard! Hear a review of the current state of the law post-In re: Grand Jury with an emphasis on the Fifth Circuit and how the law there differs from others around the country.

Melissa L. Wiley, Lowenstein Sandler LLP - Washington, DC

Melissa L. Wiley, Lowenstein Sandler LLP - Washington, DC
11:45 am
Austin Only

Pick Up Lunch (in Austin)

Included in registration.
Wednesday Afternoon, Dec. 13, 2023
Presiding Officer:
Maxine Aaronson, Attorney at Law - Dallas, TX
LUNCHEON PRESENTATION
Thank You to Our Luncheon Sponsor
12:15 pm

0.75 hr

Property Tax 2023: Where We Are, How We Got Here, and What’s Ahead

Recap the successes and failures of the 88th Texas Legislature on property tax relief, tax incentives, and tax administration and discuss the most pressing challenges for the property tax system in Texas.

Jennifer Rabb, Texas Taxpayers and Research Association - Austin, TX

Jennifer Rabb, Texas Taxpayers and Research Association - Austin, TX
1:00 pm

15-Minute Break
1:15 pm

1.00 hr

Deceptively Simple: Targeted Allocations in Private Equity Deals

Examine practical issues associated with the use of targeted income allocations in private equity transactions. In particular, provide an overview of allocations in respect of carried interests and how such allocations can be impacted by clawback provisions and fee waivers.

Mark Dundon, Kirkland & Ellis LLP - Houston, TX

Mark Dundon, Kirkland & Ellis LLP - Houston, TX
2:15 pm

1.00 hr

Correcting Partnership Capital Accounts

In the wake of mandatory tax basis reporting of capital accounts, BBA revisions to the partnership audit and litigation rules, and a renewed IRS focus on auditing partnerships, fixing prior period mistakes in partnership capital accounts has become a much more fraught exercise. Examine common causes of capital account errors, as well as possible resolutions.

John Colvin, Colvin + Hallett, P.S. - Seattle, WA

John Colvin, Colvin + Hallett, P.S. - Seattle, WA
3:15 pm

15-Minute Break
3:30 pm

1.00 hr

Transferable Energy Tax Credits

The Inflation Reduction Act provides two new opportunities to monetize energy tax credits in addition to traditional tax equity. Discuss those options and guidance issued by Treasury and the IRS and address when taxpayers should use transferability, direct pay or tax equity.

Maher Haddad, Baker & McKenzie LLP - Chicago, IL

Maher Haddad, Baker & McKenzie LLP - Chicago, IL
4:30 pm

1.00 hr

QSBS: Quest for Quantum Exclusions (Queries, Qualms, Qualifications & QOZ)

Qualified Small Business Stock (QSBS) under Section 1202 is not just for tech companies anymore. It’s time to reconsider QSBS because Tax Cuts and Jobs Act paved the way for closely-held companies to benefit “bigly.” Hear a discussion of planning opportunities and other issues including how QSBS can be combined with QOZ Investments, complications with SPAC mergers, unanswered questions, potential pitfalls, and best practices in the quest for quantum QSBS exclusions.

Paul S. Lee, Northern Trust - New York, NY

Paul S. Lee, Northern Trust - New York, NY
5:30 pm

Adjourn
Austin Only

Meet the Speakers Reception (in Austin from 5:30 p.m. - 6:30 p.m.)

Join us for drinks and hors d'oeuvres with program faculty and attendees.

Thank You to Our Reception Sponsor

Download Schedule

Conference Faculty

John Colvin

Colvin + Hallett, P.S.
Seattle, WA

Mark Dundon

Kirkland & Ellis LLP
Houston, TX

Maher Haddad

Baker & McKenzie LLP
Chicago, IL

Paul S. Lee

Northern Trust
New York, NY

Robb A. Longman

Longman & Van Grack, LLC
Bethesda, MD

Jennifer Rabb

Texas Taxpayers and Research Association
Austin, TX

Hale E. Sheppard

Chamberlain Hrdlicka
Atlanta, GA

Melissa L. Wiley

Lowenstein Sandler LLP
Washington, DC

Planning Committee

T. Charles Parr III—Chair

ABIP, P.C.
San Antonio, TX

Maxine Aaronson—Vice-Chair

Attorney at Law
Dallas, TX

R. Gordon Appleman

Holland & Knight LLP
Fort Worth, TX

Craig M. Bergez

Porter Hedges LLP
Houston, TX

Michael L. Cook

Cook Brooks Johnson PLLC
Austin, TX

Barbara Spudis de Marigny

Baker Botts
Houston, TX

Dennis B. Drapkin

Southern Methodist University Dedman School of Law
Dallas, TX

Lawrence B. Gibbs

Miller & Chevalier
Washington, DC

Christopher Hanna

Southern Methodist University Dedman School of Law
Dallas, TX

Donald O. Jansen

The University of Texas System
Austin, TX

Calvin H. Johnson

The University of Texas School of Law
Austin, TX

Jimmy Martens

Martens, Todd, & Leonard
Austin, TX

Kenton E. McDonald

McDonald & Adkins, LLP
Corpus Christi, TX

Lee Meyercord

Holland & Knight
Dallas, TX

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Patrick L. O'Daniel

Norton Rose Fulbright
Austin, TX

Robert D. Probasco

Texas A&M University School of Law
Fort Worth, TX

Dawn Rhea

Weaver and Tidwell, LLP
Austin, TX

Catherine C. Scheid

Attorney at Law
Houston, TX

MCLE Credit

Texas – 7.75 hrs | 1.00 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 – 7.75 hrs | 1.00 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 – 9.50 hrs | 1.00 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.

Pennsylvania – 7.50 hrs | 1.00 hrs Ethics

UT Law CLE is an approved provider of Pennsylvania credit, sponsor #236. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. Attorney attendance will be reported to Pennsylvania within 2 weeks after credit is claimed and submit. Attorneys are not able to report this credit on their own, and UT Law CLE pays all associated fees for the credit hours. Contact us at accreditation@utcle.org if you have additional questions.

Other States – 7.75 hrs | 1.00 hrs Ethics

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 to ensure it will qualify for self-reporting your credits.

You must claim and certify your credit online in Your Briefcase, you will then be provided a Certificate of Attendance for your records and to provided to other licensing authorities as needed.

MCLE credit is presented based on a 60-minute credit hour.

Other Credit

Certified Financial Planner (CFP) – 9.00 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 – 9.50 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.

TX Accounting CPE – 9.50 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.

MCLE Credit

Texas – 7.75 hrs | 1.00 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 Completion will be emailed to you upon claiming credit. 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 – 7.75 hrs | 1.00 hrs Ethics

To claim California MCLE credit, California credit option must be selected PRIOR to viewing the live webcast. This accreditation requires attendance verification. UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. Verification pop-ups will NOT display when the webcast video player is in "full screen" mode. Furthermore, the notification sound effect alerting pop-ups, will NOT play on mobile devices. We recommend viewing from a computer, as opposed to a mobile device, should MCLE credit, other than Texas, be needed. The response record is detailed on the Certificate of Completion.
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.

MCLE credit is presented based on a 60-minute credit hour.

Oklahoma – 9.50 hrs | 1.00 hrs Ethics

To claim Oklahoma MCLE credit, Oklahoma credit option must be selected PRIOR to viewing the live webcast. This accreditation requires attendance verification. UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. Verification pop-ups will NOT display when the webcast video player is in "full screen" mode. Furthermore, the notification sound effect alerting pop-ups, will NOT play on mobile devices. We recommend viewing from a computer, as opposed to a mobile device, should MCLE credit, other than Texas, be needed. The response record is detailed on the Certificate of Completion.

The University of Texas School of Law (Provider #169) live webcast presentations meet the requirements and are presumptively approved by the Oklahoma Bar Association for MCLE credit based on a 50-minute credit hour. Upon claiming credit, a Certificate of Completion will be emailed to you. UT Law CLE will report credit on your behalf to the Oklahoma Bar Association within 30 days after the webcast.

Pennsylvania – 7.50 hrs | 1.00 hrs Ethics

To claim Pennsylvania MCLE credit, Pennsylvania credit option must be selected PRIOR to viewing the live webcast. This accreditation requires attendance verification. UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. Verification pop-ups will NOT display when the webcast video player is in "full screen" mode. Furthermore, the notification sound effect alerting pop-ups, will NOT play on mobile devices. We recommend viewing from a computer, as opposed to a mobile device, should MCLE credit, other than Texas, be needed. The response record is detailed on the Certificate of Completion.

UT Law CLE is an approved provider of Pennsylvania credit, sponsor #236. Attorney attendance will be reported to Pennsylvania within 2 weeks after credit is claimed and submitted. Attorneys are not able to report this credit on their own, and UT Law CLE pays all associated fees for the credit hours. Contact us at accreditation@utcle.org if you have additional questions.

MCLE credit is presented based on a 60-minute credit hour.

Other States – 7.75 hrs | 1.00 hrs Ethics

Note on Self-Reporting Your Credits in Another State

To claim Other States MCLE credit, Other States credit option must be selected PRIOR to viewing the live webcast. You must claim and certify your credit online in Your Briefcase, you will then be provided a Certificate of Attendance for your records and to provide to other licensing authorities as needed.

This accreditation requires attendance verification. UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. The response record is detailed on the Certificate of Completion.

MCLE credit is presented based on a 60-minute credit hour.

Other Credit

Certified Financial Planner (CFP) – 9.00 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/

TX Accounting CPE – 9.50 hrs

The University of Texas School of Law (Provider #250) live webcast presentations meet the requirements and 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.

This accreditation requires attendance verification. In compliance with the rules, UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. The response record is detailed on the Certificate of Completion.

To claim Texas Accounting CPE credit, the Texas Accounting CPE credit option must be selected PRIOR to viewing the live webcast. Upon claiming credit, a Certificate of Completion will be emailed to you. Self-report your CPE credit directly to the Texas State Board of Public Accountancy.

Contact us at accreditation@utcle.org if you have additional questions.

Key Dates

Austin – Dec 13, 2023 – AT&T Conference Center

Conference Concluded

Live Webcast – Dec 13, 2023

Conference Concluded

Buy

Austin
Live Webcast

Individual
Last day for $350.00 Regular pricing: Nov 29, 2023
$450.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $315.00 Regular pricing: Nov 29, 2023
$415.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $280.00 Regular pricing: Nov 29, 2023
$380.00 for registrations received after this time

Cancellation Policy
Last day for full refund cancellation: Dec 6, 2023
$50 processing fee applied after this date
Last day for cancellation: Dec 8, 2023

Venue

AT&T Conference Center

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

Accommodations

$199 room rate good through November 12, 2023 (subject to availability).

Parking Information

Parking is available in the hotel's attached garage, as well as Rowling Hall Garage. Both garage entrances are located on W 20th St. Guests may self-park or use the hotel's valet services at the University Avenue entrance. Parking charges are subject to changes without notification.

Self-parking fees:

Hourly Parking:
0-30 minutes, $3
31-60 minutes, $4
1– 2 hours, $6
2– 3 hours, $9
3– 4 hours, $12
4– 5 hours, $15
5– 8 hours, $18
8– 24 hours, $21

Overnight Guests:

Hotel guests may obtain a parking card at the front desk for $21 per night.

Valet Parking Rates:
Daily valet: $21
Overnight valet: $35

Our Sponsors

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

ABIP, P.C.

ABIP, P.C.
www.abipcpa.com

ABIP is a Texas-based CPA and advisory firm with offices in San Antonio and Houston. ABIP’s client service approach is to seek and assist with value contributions as organizations grow. This approach is collaborative and technical to achieve the desired and unique goals of each client.

While each client has different needs, ABIP’s services help clients focus on their core business. The available services are robust and include access to an international network of member firms. Their clients include privately held businesses, family legacy offices, start-up companies, high-net-worth individuals, non-profits, and government entities. To learn more, please reach us at 210.341.2581.
Clark Hill, PLC

Clark Hill, PLC
www.clarkhill.com

Clark Hill is a full service international law firm with 27 offices in the United States, Ireland, and Mexico. In Texas, Clark Hill has offices in Austin, Beaumont, Collin County, Dallas, Houston, and San Antonio. While Clark Hill is full service, it has a significant practice in tax and estate planning. To establish its presence in Texas, Clark Hill merged with the Strasburger firm in 2018, which seven years earlier had merged with Oppenheimer, Blend, Harrison and Tate, a San Antonio firm with a strong presence in tax and estate planning. Clark Hill is pleased to be a sponsor of the University of Texas Annual Tax program.
Martens, Todd, & Leonard

Martens, Todd, & Leonard
texastaxlaw.com

Martens, Todd & Leonard focuses its law practice exclusively on challenging audit assessments and refund claim denials pertaining to the Texas sales tax, Texas franchise tax and other Texas taxes. Martens, Todd & Leonard works with clients during audits, and undertakes challenges at administrative hearings, in the state trial and appellate courts, as well as in the Texas supreme court.

We have successfully tried these Texas sales tax and franchise tax cases: Combs v. Roark Amusement & Vending, L.P.; Hegar v. Gulf Copper and Manufacturing Corp.; Titan Transportation, L.P. v. Combs; Combs v. Newpark Resources, Inc.; Hegar v. CGG Veritas Services (U.S.), Inc.; Pointsmith Point-of-Purchase Management Services, L.P. v. Hegar; Garriott v. Combs; L.P.; Taylor & Hill, Inc. v. Combs.
McDonald & Adkins, LLP

McDonald & Adkins, LLP
mcdonaldadkins.com

Significant businesses throughout Texas rely on McDonald & Adkins, LLP, for experienced counsel and representation.

With over 44 years of experience, Kenton McDonald’s practice is focused on helping clients structure their businesses and transactions in a tax-advantaged manner; structure their estates to minimize estate taxes; and contest unfavorable actions proposed by the IRS.

With 30 years’ experience as a trial attorney, Alissa Adkins has a broad civil litigation practice involving contested matters in state and federal trial and appellate courts, including the U.S. Bankruptcy Court.

McDonald & Adkins, LLP, has been selected by U.S. News and World Report as a top tier law firm for Tax Law.
Porter Hedges LLP

Porter Hedges LLP
www.porterhedges.com

Founded in 1981, Porter Hedges is a full-service Houston-based law firm with an office in Oklahoma City. We provide the highest quality work across a range of industries, with particular preeminence in the energy sector. As leading practitioners, we are committed to excellence across our firm and favor an efficient, value-minded approach to serving our clients. We develop practical and integrated solutions to complex challenges that we approach with a business-oriented mindset.

Porter Hedges tax lawyers help businesses, exempt organizations, and individuals plan and achieve their financial objectives while maximizing their tax advantages. We integrate tax planning, transactional assistance, and tax controversy resolution in advising clients on all aspects of federal, state, local, and international taxation. Our tax lawyers regularly assist company owners and executives, chief financial officers, tax directors, bankers, outside accountants, and other advisors in creating sophisticated solutions for complex tax challenges.

Taxation Conference: Day 1 - Focus on Business Planning

Overview

Event Schedule

Wednesday Morning, Dec. 13, 2023

Wednesday Afternoon, Dec. 13, 2023

Conference Faculty

Planning Committee

Credit Info

MCLE Credit

Other Credit

MCLE Credit

Other Credit

Key Dates

Venue

AT&T Conference Center

Accommodations

Parking Information

Our Sponsors

ABIP, P.C.

Clark Hill, PLC

Martens, Todd, & Leonard

McDonald & Adkins, LLP

Porter Hedges LLP

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