72^nd Annual

Taxation Conference: Day 1 - Focus on Business Planning

Wednesday: Focus on Business Planning

Austin Dec 4, 2024 AT&T Conference Center
$450 Individual

$415 Group rate per person (5 registrants minimum)

$380 Group rate per person (10 registrants minimum)

Live Webcast Dec 4, 2024
$450 Individual

$415 Group rate per person (5 registrants minimum)

$380 Group rate per person (10 registrants minimum)

$75 Add-on rate for in-person registrants

Register

Related products: Materials

PREMIER SPONSOR
Chamberlain Hrdlicka

EVENT SPONSORS
ABIP, P.C.
Holland & Knight LLP
Miller & Chevalier
Porter Hedges LLP

CONFERENCE SPONSORS
Clark Hill, PLC
Gray Reed
McDonald & Adkins, LLP

SUPPORTER SPONSORS
Cook Brooks Johnson PLLC
Martens Law

Overview

UT Law CLE’s 72nd 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. 4, 2024
Presiding Officer:
Maxine Aaronson, Attorney at Law - Dallas, TX
8:30 am

Welcoming Remarks
8:45 am

1.00 hr

The Meaning of “as such”: Imposing SECA Tax on Limited Partners

Discuss the current state of examinations and litigation surrounding the limited partner exception to the Self-Employment Contributions Act (SECA). The speakers provide an overview of the history and circumstances in which the limited partner exception applies and also address approaches that can be taken when encountering this issue in an audit.

Lee Meyercord, Holland & Knight - Dallas, TX
Anthony Sacco, IRS, Office of Chief Counsel - Washington, DC
9:45 am

1.00 hr

Navigating the NIL Landscape: Contracts, Cash, and Compliance

Delve into the evolving landscape of Name, Image, and Likeness (NIL) rights, focusing on the legal complexities of contracts, financial management, and tax implications for athletes, their advisors and collectives. Gain insights into crafting compliant NIL agreements, understanding the latest regulatory changes, and effectively navigating the financial and tax challenges associated with these deals. Also, examine recent case studies and current events to illustrate the practical application of these principles in today's dynamic sports environment.

Luke A. Fedlam, Porter Wright Morris & Arthur LLP - Columbus, OH
10:45 am

15-Minute Break
11:00 am

1.00 hr

What’s a Trade or Business for Tax Purposes? Interpreting Varying Guidance for Real Estate Businesses and Family Offices

The term “trade or business” is a critical tax determination in multiple areas but it is not defined in either the Internal Revenue Code or Regulations. The speaker addresses the differing interpretations of this term under the Code, focusing on Sections 162, 469(c)(7)(C), 199A, and 163(j) and divisions of real estate corporations.

Bradley T. Borden, Brooklyn Law School - Brooklyn, NY
12:00 pm
Austin Only

Pick Up Lunch (in Austin)

Included in registration.
Wednesday Afternoon, Dec. 4, 2024
Presiding Officer:
Craig M. Bergez, Porter Hedges LLP - Houston, TX
LUNCHEON PRESENTATION
12:30 pm

1.00 hr

Federal Tax Legislative Outlook

Hear a perspective on the current tax policy landscape, including a review of recently enacted legislation and prospects for tax legislation in 2025. Discuss the impact of the November presidential and congressional elections on the tax policy landscape, as well as how the pending expiration of significant provisions of the Tax Cuts and Jobs Act may be addressed.

Marc J. Gerson, Miller & Chevalier Chartered - Washington, DC
Thank You to Our Wednesday Luncheon Sponsor
1:30 pm

15-Minute Break
1:45 pm

1.00 hr

Economic Substance and Liberty Global: Are There Limitations to the ESD?

The district court's decision in Liberty Global, combined with various statements from government officials, appears to indicate an expansion of the economic substance doctrine (ESD). Explore the history, application and limitations on the ESD, with Liberty Global serving as the background for discussion.

Richard M. Lipton, Baker McKenzie LLP - Dallas, TX
2:45 pm

1.00 hr ethics

Who’s Your Client?

Identifying your client seems like a simple issue, but it is frequently complicated, for instance in matters involving organizational clients such as partnerships, LLCs, corporations or trusts, or even simply joint return filers. The client’s identity in turn bears on all sorts of ethical and practical issues, including conflicts, where your duties lie, how to advise organizational clients, client confidences and privileges, communications with others, common interest agreements, etc. This presentation covers many of these issues and discusses guidelines to be followed when they arise.

Christopher S. Rizek, Holland & Knight - Washington, DC
3:45 pm

15-Minute Break
4:00 pm

1.00 hr

S Corporation Issues in M&A

Buying or selling an S corporation comes with big opportunities and potentially big problems. Starting with Subchapter S election diligence, the result of which often drives the structure of the deal, learn how to handle “bad” (or missing) facts, ways to balance the seller’s desire to maximize after-tax purchase price proceeds with the buyer’s desire for tax attributes to support the deal, and the common private equity buyer’s desire for sellers to roll over some equity, and as well as dealing with state tax items.

Joan C. Arnold, Troutman Pepper Hamilton Sanders, LLP - Philadelphia, PA
5:00 pm

Adjourn
Austin Only

Meet the Speakers Reception (in Austin from 5:00 p.m. - 6:00 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

Joan C. Arnold

Troutman Pepper Hamilton Sanders, LLP
Philadelphia, PA

Bradley T. Borden

Brooklyn Law School
Brooklyn, NY

Luke A. Fedlam

Porter Wright Morris & Arthur LLP
Columbus, OH

Marc J. Gerson

Miller & Chevalier Chartered
Washington, DC

Richard M. Lipton

Baker McKenzie LLP
Dallas, TX

Lee Meyercord

Holland & Knight
Dallas, TX

Christopher S. Rizek

Holland & Knight
Washington, DC

Anthony Sacco

IRS, Office of Chief Counsel
Washington, DC

Planning Committee

Maxine Aaronson—Chair

Attorney at Law
Dallas, TX

Craig M. Bergez—Vice-Chair

Porter Hedges LLP
Houston, TX

R. Gordon Appleman

Holland & Knight LLP
Fort Worth, TX

Stanley L. Blend

Clark Hill, PLC
San Antonio, TX

Michael L. Cook

Cook Brooks Johnson PLLC
Austin, TX

Dennis B. Drapkin

Southern Methodist University Dedman School of Law
Dallas, TX

Lawrence B. Gibbs

Miller & Chevalier
Washington, DC

Donald O. Jansen

The University of Texas System
Austin, TX

Aparna Koneru

EY
Houston, TX

Jimmy Martens

Martens Law
Austin, TX

Kenton E. McDonald

McDonald & Adkins, LLP
Corpus Christi, TX

Lee Meyercord

Holland & Knight
Dallas, TX

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Charles J. "Chad" Muller III

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

Fred F. Murray

Gainesville, FL

Patrick L. O'Daniel

Norton Rose Fulbright US LLP
Austin, TX

T. Charles Parr III

ABIP, P.C.
San Antonio, TX

Robert D. Probasco

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

Catherine C. Scheid

Attorney at Law
Houston, TX

MCLE Credit

Texas – 7.00 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 Monday. 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

California – 7.00 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 – 8.50 hrs | 1.00 hrs Ethics

At the conference, you will need to sign in on the Record of Attendance form at the registration desk. You must claim your credit online in Your Briefcase, and 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 – 7.00 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 – 7.00 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.

At the conference, you will need to sign in on the Record of Attendance form at the registration desk. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records.

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

Other Credit

National Accounting CPE – 8.25 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. If you need Accounting credit in any state other than Texas, please review the self-reporting guidelines on the NASBA website to confirm your ability to self-report credit from the live webcast.)

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 – 8.25 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 – 7.00 hrs | 1.00 hrs Ethics
Legal Specialization(s): Estate Planning and Probate Law, Tax Law

UT Law CLE will report credit to the State Bar of Texas on your behalf. If you are claiming credit in the last week of your birth month, self-report your credit directly to the State Bar of Texas at texasbar.com. A Certificate of Completion will be emailed to you upon claiming credit.

California – 7.00 hrs | 1.00 hrs Ethics

Oklahoma – 8.50 hrs | 1.00 hrs Ethics

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. 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 Oklahoma MCLE credit, Oklahoma credit option must be selected PRIOR to viewing the live webcast. 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 – 7.00 hrs | 1.00 hrs Ethics

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.

Other States – 7.00 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 your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records.

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

CPA - Other States – 8.25 hrs

You may use this accounting certificate to self-report your CPA credit to various states. Use this handy registry guide for state-by-state rules: https://www.nasbaregistry.org/cpe-requirements

TX Accounting CPE – 8.25 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 4, 2024 – AT&T Conference Center

Live Webcast – Dec 4, 2024

Austin
Live Webcast

Individual
Last day for $450.00 Regular pricing: Dec 4, 2024

$450.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $415.00 Regular pricing: Dec 4, 2024

$415.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $380.00 Regular pricing: Dec 4, 2024

$380.00 for registrations received after this time

Last day for cancellation (full refund): Nov 27, 2024

$50 processing fee applied after this date

Last day for cancellation: Dec 2, 2024

Individual
Last day for $450.00 Regular pricing: Dec 4, 2024

$450.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $415.00 Regular pricing: Dec 4, 2024

$415.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $380.00 Regular pricing: Dec 4, 2024

$380.00 for registrations received after this time

Add-on
Last day for $75.00 Regular pricing: Dec 4, 2024

$75.00 for registrations received after this time

Venue

AT&T Conference Center

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

Accommodations

$204 room rate good through November 4, 2024 (subject to availability). Please follow this link to book your reservation online.

Parking Information

Parking is available in the conference center'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 rates are subject to change without notice.

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
Lost ticket, $42

Valet Parking Rates:
Daily valet: $21
Overnight valet: $38

Additional Information

The Conference will take place in Classroom 203, which is located on level M2 of the conference center

Our Sponsors

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

Chamberlain Hrdlicka

Chamberlain Hrdlicka

www.chamberlainlaw.com
ABIP, P.C.

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.
www.abipcpa.com
Holland & Knight LLP

Established in 1887, Thompson & Knight is a full-service law firm with more than 300 attorneys and nine offices worldwide. Our Firm has been at the forefront of groundbreaking litigation and transactions that have historically shaped the legal and business communities in Texas and the Southwest.

Our robust Tax Practice offers comprehensive tax planning and compliance advice to individuals and all types of business entities and organizations. Our attorneys provide creative and seasoned tax advice in corporate and business tax, international and cross-border tax, employee benefits and executive compensation, estate planning, family office tax, nonprofit tax, oil and gas tax, real estate tax, and tax controversies. We represent clients in tax audits, administrative appeals and proceedings, and in tax litigation in both federal and state courts.
www.hklaw.com
Miller & Chevalier

www.millerchevalier.com
Porter Hedges LLP

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.
www.porterhedges.com
Clark Hill, PLC

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.
www.clarkhill.com
Gray Reed

Gray Reed
McDonald & Adkins, LLP

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.
mcdonaldadkins.com

72nd Annual

Taxation Conference: Day 1 - Focus on Business Planning

Wednesday: Focus on Business Planning

Austin Dec 4, 2024 AT&T Conference Center $450 Individual $415 Group rate per person (5 registrants minimum) $380 Group rate per person (10 registrants minimum)

Live Webcast Dec 4, 2024 $450 Individual $415 Group rate per person (5 registrants minimum) $380 Group rate per person (10 registrants minimum) $75 Add-on rate for in-person registrants

Register

Related products: Materials

Overview

Related Conference

Taxation Conference: Day 2 - Focus on Tax Controversy

Taxation Conference: Day 2 - Focus on Tax Controversy

Event Schedule

Wednesday Morning, Dec. 4, 2024

Wednesday Afternoon, Dec. 4, 2024

Conference Faculty

Joan C. Arnold

Bradley T. Borden

Luke A. Fedlam

Marc J. Gerson

Richard M. Lipton

Lee Meyercord

Christopher S. Rizek

Anthony Sacco

Planning Committee

Maxine Aaronson—Chair

Craig M. Bergez—Vice-Chair

R. Gordon Appleman

Stanley L. Blend

Michael L. Cook

Dennis B. Drapkin

Lawrence B. Gibbs

Donald O. Jansen

Aparna Koneru

Jimmy Martens

Kenton E. McDonald

Lee Meyercord

Christina A. Mondrik

Charles J. "Chad" Muller III

Fred F. Murray

Patrick L. O'Daniel

T. Charles Parr III

Robert D. Probasco

Catherine C. Scheid

Credit Info

MCLE Credit

Other Credit

MCLE Credit

Other Credit

Key Dates

Venue

AT&T Conference Center

Accommodations

Parking Information

Additional Information

Our Sponsors

Chamberlain Hrdlicka

Gray Reed

Stay in the loop with UT Law CLE

72^nd Annual

Austin Dec 4, 2024 AT&T Conference Center
$450 Individual

$415 Group rate per person (5 registrants minimum)

$380 Group rate per person (10 registrants minimum)

Live Webcast Dec 4, 2024
$450 Individual

$415 Group rate per person (5 registrants minimum)

$380 Group rate per person (10 registrants minimum)

$75 Add-on rate for in-person registrants