12^th Annual

Higher Education Taxation Institute

Austin Jun 13-14, 2024 The Otis Hotel Austin
Conference Concluded

Buy

Related products: eConference Materials

EXCLUSIVE RECEPTION SPONSOR
KPMG LLP
LUNCHEON SPONSOR
Crowe LLP
INSTITUTE SPONSOR
BLX Group LLC
PwC
RSM US LLP

Download Brochure (PDF)

Overview

The Higher Education Taxation Institute (HETI) provides a unique forum for college and university tax professionals from around the country to examine and discuss federal tax issues and compliance, as well as legislative, judicial, regulatory, and administrative changes affecting colleges and universities. This year's conference will be held on a Thursday - Friday date pattern.

Highlights :

Recent Developments in College and University Tax Law reviews recent tax law developments that affect the higher education community, such as Congressional legislation, IRS enforcement measures and pronouncements as well as judicial decisions.
Legislative and Policy Update; Playing Defense for 2024 and Preparing for 2025, provides insight into what has been and will be occurring in 2024 regarding taxation of universities, their endowments, and examinations of school conduct and governance policies.
Managing UBTI to Infinity and Beyond discusses Form 990-T reporting for both alternative investments and other university operations, including additional issues and forms that have arisen during the post pandemic period, such as debt from lines of credit, rent from unused office space, income from tech transfer, income from investments, and energy tax credits, among others.
International Jeopardy is an interactive game of Jeopardy with topics highlighting international issues including; BEPS 2.0, indirect and digital taxes, nexus and triggering permanent establishment, NSPM33, 117 compliance, audit notices, and more!

Plus, join faculty, planning committee, and attendees at the Thursday Evening Reception.

Event Schedule

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

Day 1 June 13, 2024
Day 2 June 14, 2024

Time

Credit

Subject

Speaker
Thursday Morning, June 13, 2024
Presiding Officer:
Jodi R. Kessler, Massachusetts Institute of Technology - Cambridge, MA
7:30 am

Registration Opens

Includes continental breakfast.
8:20 am

Welcoming Remarks
8:30 am

1.25 hrs

Recent Developments in College and University Tax Law

Review recent tax law developments that affect the higher education community, such as Congressional legislation, IRS enforcement measures and pronouncements as well as judicial decisions. Discuss the impact on prevalent tax issues, including unrelated business taxable income, compensation and fringe benefits, charitable contributions, international activities, endowments, and reporting requirements.

Benjamin A. Davidson, The University of North Carolina at Chapel Hill - Chapel Hill, NC
Edward J. Jennings, University of Michigan - Ann Arbor, MI
9:45 am

1.00 hr

Charitable Giving in a Changing World

This session addresses key tax issues relating to charitable giving currently faced by colleges and universities (and their donors). How should your institution handle donor requests for involvement in scholarship selections, or for race- or gender-based scholarship criteria? As sophisticated donors increasingly turn to strings-attached philanthropy, what opportunities and pitfalls are there in the qualified sponsorship UBTI rules and rules relating to completion of a gift? How can your institution’s donation acknowledgment and Form 8283/8282 practices impact your donors’ likelihood of successfully taking tax deductions for their gifts? Will your institution feel the impact of the newly proposed donor-advised fund regulations? The session discusses both the theory and practice of tackling these questions in the higher education environment.

Brittany Cvetanovich, The Ohio State University - Columbus, OH
Alexandra O. Mitchell, RSM US LLP - Seattle, WA
Sean P. Scally, Vanderbilt University - Nashville, TN
10:45 am

15-Minute Break
11:00 am

1.00 hr

IRA Energy Tax Credits

A discussion of available credits and tips on working with campus partners to identify and quantify projects. The discussion is from the university perspective to highlight experiences and challenges we’ve encountered in working with the tax credits.

Susan P. Clark, Emory University - Atlanta, GA
Jodi R. Kessler, Massachusetts Institute of Technology - Cambridge, MA
Kimberly A. Maxwell, University Of Illinois - Urbana, IL
12:00 pm

Pick Up Lunch (in Austin)

Included in registration.
Thursday Afternoon, June 13, 2024
Presiding Officer:
Edward J. Jennings, University of Michigan - Ann Arbor, MI
LUNCHEON PRESENTATION
Thank You to Our Luncheon Sponsor
12:20 pm

1.00 hr

Legislative and Policy Update; Playing Defense for 2024 and Preparing for 2025

Gain insight into what has been and will be occurring in 2024 regarding taxation of universities, their endowments, and examinations of school conduct and governance policies. Discuss the upcoming 2024 elections and the impact on tax policy, including the expected rewrite of the 2017 tax bill and related issues.

Richard A. Grafmeyer, Capitol Tax Partners - Washington, DC
1:20 pm

15-Minute Break
1:35 pm

0.75 hr

NIL Updates

Where are we today when it comes to Name, Image & Likeness? This session discusses the background and current state of NIL legislation from NCAA, Federal and State levels with a focus on institutional compliance.

Tyrone P. Thomas, Holland & Knight LLP - Washington, DC
Alexander L. Reid, Baker & Hostetler LLP - Washington, DC
Kyle R. ZumBerge, The University of Texas - Tax Services - Austin, TX
2:20 pm

0.75 hr

Joint Ventures with For-Profits

Walk through specific examples of operating agreements for joint ventures structured as a partnership. Learn what language you should include, what to watch out for and some common approaches to ensuring the joint venture will further tax-exempt purposes. This session is intended to provide a practical approach to joint ventures based upon real-world examples.

Colby Rogers, Ropes & Gray LLP - Boston, MA
Thomas C. Schroeder, Davis Wright Tremaine LLP - Seattle, WA
3:05 pm

15-Minute Break
3:20 pm

1.00 hr

Tax-Exempt Bond Compliance Overview

This session provides an overview of the IRS rules and regulations applicable to tax-exempt bonds, including arbitrage rebate, private business use, and change in use of bond financed facilities, and provides an update on IRS enforcement and oversight in these areas. In addition, our university representative provides insight on how her organization manages its post-issuance tax compliance responsibilities.

Alan Bond, BLX Group - New York, NY
Kirsten Muller, University of Minnesota - Minneapolis, MN
Sandee Stallings, BLX Group - Dallas, TX
4:20 pm

1.00 hr

Managing UBTI to Infinity and Beyond

The new tax landscape with recent legislation and a significant budget increase for the IRS raises the risks and stakes in managing unrelated business taxable income (UBTI). This session discusses reporting UBTI for both alternative investments and other university operations, including issues that have arisen during the post pandemic period, such as debt from lines of credit, rent from unused office space, and the use of energy resources. Also, hear best practices, tips and planning strategies (including considerations for using a corporate blocker structure), to identify, quantify and minimize UBTI liabilities while maximizing tax savings. Proper management of these emerging UBTI challenges and concerns will provide executive management with awareness, avoiding unnecessary surprises, which may result in an increase in needed resources and support.

Robert W. Friz, PwC - Philadelphia, PA
Edward J. Jennings, University of Michigan - Ann Arbor, MI
Thank You to Our Reception Sponsor
5:20 pm

Adjourn

Time

Credit

Subject

Speaker
Friday Morning, June 14, 2024
Presiding Officer:
Brittany Cvetanovich, The Ohio State University - Columbus, OH
7:45 am

Conference Room Opens

Includes continental breakfast.
8:00 am

1.00 hr

Preparing Your Institution Today for Tomorrow's Audits

This session addresses navigating the shifting tax landscape of audits due to the increased IRS budget and innovative information technology and discusses current issues in higher education that are being audited by the IRS and state taxing agencies. This session also explores best practices to prepare your institution for examinations, inquiries and compliance checks in the near future, including managing additional risks from new or emerging issues, bolstering files, communicating compliance to campus units and updating executive management on risks and resources.

Preston J. Quesenberry, KPMG LLP - Washington, DC
Kyle R. ZumBerge, The University of Texas - Tax Services - Austin, TX
9:00 am

1.00 hr

People Payment Puzzles: Decoding Payments to Individuals and Related Tax Implications

Highlight and discuss some of the hot topics higher education institutions are facing in the accounts payable and payroll spaces.

Meghan McCollum, University of Central Florida - Orlando, FL
Rebecca Menin, Massachusetts Institute of Technology - Cambridge, MA
Paula T. Torres, KPMG LLP - Houston, TX
10:00 am

1.00 hr

International Jeopardy

An interactive game of Jeopardy with topics highlighting international issues including; BEPS 2.0, indirect and digital taxes, nexus and triggering permanent establishment, NSPM33, 117 compliance, audit notices, and more!

John M. Kelleher, Crowe LLP - Dallas, TX
Jodi R. Kessler, Massachusetts Institute of Technology - Cambridge, MA
Artemis Velahos Koch, University of Pennsylvania - Philadelphia, PA
Bob Lammey, Ernst & Young LLP - Boston, MA
11:00 am

15-Minute Break
11:15 am

1.00 hr

Public Policy Issues and Concerns

Congress views tax exemption of colleges and universities as a subsidy to produce charitable goods and services for the benefit of society. Recently, some members of Congress have expressed the view that the subsidy entitles them to demand that schools adopt certain policies and procedures. Executive Branch agencies from the IRS and Treasury to Department of Education and Department of Labor are actively pursuing various regulatory agendas as well. These range from prohibiting investments in Chinese companies, attacks on endowments, setting tuition rates, requiring campus speech and antisemitism policy, regulating name image and likeness payments to student athletes, dictating what donor advised funds can do, granting authority to executive branch agencies to enact regulations furthering these and other positions. The federal government’s actions will impact your university. The question is: how will you respond?

Alexander L. Reid, Baker & Hostetler LLP - Washington, DC
Kyle R. ZumBerge, The University of Texas - Tax Services - Austin, TX
12:15 pm

1.00 hr ethics

Ethical Issues for Tax Practitioners in Privileged Communications

Brittany Cvetanovich, The Ohio State University - Columbus, OH
Benjamin A. Davidson, The University of North Carolina at Chapel Hill - Chapel Hill, NC
1:15 pm

Adjourn

Day 1 June 13, 2024
Day 2 June 14, 2024

Download Schedule

Conference Faculty

Alan Bond

BLX Group
New York, NY

Susan P. Clark

Emory University
Atlanta, GA

Brittany Cvetanovich

The Ohio State University
Columbus, OH

Benjamin A. Davidson

The University of North Carolina at Chapel Hill
Chapel Hill, NC

Robert W. Friz

PwC
Philadelphia, PA

Richard A. Grafmeyer

Capitol Tax Partners
Washington, DC

Edward J. Jennings

University of Michigan
Ann Arbor, MI

John M. Kelleher

Crowe LLP
Dallas, TX

Jodi R. Kessler

Massachusetts Institute of Technology
Cambridge, MA

Artemis Velahos Koch

University of Pennsylvania
Philadelphia, PA

Bob Lammey

Ernst & Young LLP
Boston, MA

Kimberly A. Maxwell

University Of Illinois
Urbana, IL

Meghan McCollum

University of Central Florida
Orlando, FL

Rebecca Menin

Massachusetts Institute of Technology
Cambridge, MA

Alexandra O. Mitchell

RSM US LLP
Seattle, WA

Kirsten Muller

University of Minnesota
Minneapolis, MN

Preston J. Quesenberry

KPMG LLP
Washington, DC

Alexander L. Reid

Baker & Hostetler LLP
Washington, DC

Colby Rogers

Ropes & Gray LLP
Boston, MA

Sean P. Scally

Vanderbilt University
Nashville, TN

Thomas C. Schroeder

Davis Wright Tremaine LLP
Seattle, WA

Sandee Stallings

BLX Group
Dallas, TX

Tyrone P. Thomas

Holland & Knight LLP
Washington, DC

Paula T. Torres

KPMG LLP
Houston, TX

Kyle R. ZumBerge

The University of Texas - Tax Services
Austin, TX

Planning Committee

Brittany Cvetanovich—Co-Chair

The Ohio State University
Columbus, OH

Jodi R. Kessler—Co-Chair

Massachusetts Institute of Technology
Cambridge, MA

April Rogers—Director

The University of Texas School of Law
Austin, TX

Mary M. Bachinger

National Association of College and University Business Officers (NACUBO)
Washington, DC

Alan Bond

BLX Group
New York, NY

Susan P. Clark

Emory University
Atlanta, GA

Benjamin A. Davidson

The University of North Carolina at Chapel Hill
Chapel Hill, NC

Robert W. Friz

PwC
Philadelphia, PA

Andrew J. Gray

Crowe LLP
Dallas, TX

Bertrand M. Harding Jr.

Law Offices of Bertrand M. Harding Jr.
Alexandria, VA

Joseph R. Irvine

The Ohio State University
Columbus, OH

Edward J. Jennings

University of Michigan
Ann Arbor, MI

Donna Kepley

Arctic International LLC
Austin, TX

Artemis Velahos Koch

University of Pennsylvania
Philadelphia, PA

Bob Lammey

Ernst & Young LLP
Boston, MA

Joel Levenson

University of Central Florida
Orlando, FL

Ruth M. Madrigal

KPMG LLP
Washington, DC

Alexandra O. Mitchell

RSM US LLP
Seattle, WA

Kendi Ozmon

Ropes & Gray LLP
Boston, MA

Alexander L. Reid

Baker & Hostetler LLP
Washington, DC

Sean P. Scally

Vanderbilt University
Nashville, TN

Kyle R. ZumBerge

The University of Texas - Tax Services
Austin, TX

Credit Info

Austin

MCLE Credit

Texas – 12.75 hrs | 1.00 hrs Ethics
Legal Specialization(s): 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 – 12.75 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.

Illinois – 12.75 hrs | 1.00 hrs Ethics

Within 10 days of the conference you must claim and certify your credit online in Your Briefcase, then you will be provided a Certificate of Attendance for your records. UT Law CLE will verify the number of Illinois attorneys in attendance within 10 days after the conference and will report your credit to the MCLE Board of the Supreme Court of Illinois. Failure to submit your credit within 10 days may result in attendance not being reported or may result in additional fees being assessed to you for credit reporting. UT Law CLE will maintain Attendance Records for four years.

Minnesota – 12.75 hrs | 1.00 hrs Ethics

This course has been approved by the Minnesota State Board of Continuing Legal Education for the credit hours indicated in the following category or categories of credit:
(a) standard continuing legal education;
(b) ethics or professional responsibility continuing legal education

You must claim and certify your credit online in Your Briefcase, then you will be provided a Certificate of Attendance for your records. Self-report your CLE credit directly to the Minnesota State Board of Continuing Legal Education. UT Law CLE will maintain Attendance Records for four years.

Ohio – 12.75 hrs | 1.00 hrs Ethics

You must claim and certify your credit online in Your Briefcase, you will then be provided a Certificate of Attendance for your records. UT Law CLE will report credit on your behalf to The Supreme Court of Ohio within 30 days after the conference.

Oklahoma – 15.50 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 – 12.50 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 – 12.75 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

National Accounting CPE – 15.00 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 – 15.00 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 – Jun 13-14, 2024 – The Otis Hotel Austin

Conference Concluded

Buy

Austin

Individual
Last day for $575.00 Early Bird pricing: Jan 26, 2024
Last day for $625.00 Regular pricing: May 29, 2024

$725.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $515.00 Early Bird pricing: Jan 26, 2024
Last day for $565.00 Regular pricing: May 29, 2024

$665.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $450.00 Early Bird pricing: Jan 26, 2024
Last day for $500.00 Regular pricing: May 29, 2024

$600.00 for registrations received after this time

Last day for cancellation (full refund): Jun 7, 2024

$50 processing fee applied after this date

Last day for cancellation: Jun 10, 2024

Venue

The Otis Hotel Austin

1901 San Antonio St.
Austin, TX 78705
512-473-8900
Map

Accommodations

$209 room rate good through May 22, 2024 (subject to availability). Please follow this link to book your reservation online.

Parking Information

Daily self-parking: $35

Daily overnight self-parking: $45

Valet Parking: $55

Our Sponsors

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

KPMG LLP

KPMG LLP, the audit, tax and advisory firm, is the U.S. member firm of KPMG International Cooperative ("KPMG International"). KPMG International's member firms have over 256,000 professionals in 143 countries. KPMG has a national network of exempt organization tax professionals providing tax consulting and compliance services to colleges, universities, healthcare providers and many other types of tax-exempt organizations.
tax.kpmg.us/services/development-exempt-organizations.html
Crowe LLP

Crowe LLP (www.crowe.com) is a public accounting, consulting and technology firm that uses its deep industry expertise to provide audit services to public and private entities. The firm and its subsidiaries also help clients make smart decisions that lead to lasting value with its tax, advisory and consulting services.

Crowe is recognized by many organizations as one of the best places to work in the U.S. As an independent member of Crowe Global, one of the largest global accounting networks in the world, Crowe serves clients worldwide. The network consists of more than 200 independent accounting and advisory services firms in more than 130 countries around the world. Crowe’s Exempt Organization Tax Services practice includes experienced professionals dedicated to serving the higher education industry, working with more than 175 institutions. Crowe is aware that to properly serve higher education institutions, professionals within the firm must concentrate a significant portion of their time serving college, university and other education-focused clients to maintain a high level of industry specialization. The development of this practice provides exciting challenges for our staff relative to the complex issues and ever-changing needs of higher education entities. Crowe is also proud to be the author of NACUBO’s web-based guide to the Form 990. www.crowe.com/
BLX Group LLC

Since 1989, BLX has offered a comprehensive range of financial and consulting services to the public finance community. In addition to arbitrage rebate and continuing disclosure services, BLX provides tailored post-issuance compliance services including: private business use analyses (accompanied by an opinion from Orrick, one of the nation’s leading public finance law firms and our parent company), bond proceeds expenditure analyses and final allocation services, and IRS Schedule K review and completion services. BLX also recently started providing ESG/Sustainable Finance consulting and monitoring services. BLX is a Registered Observer of the International Capital Market Association’s (ICMA) Green and Social Bond Principles and an Approved Verifier with the Climate Bonds Initiative (CBI).

With approximately 40 public finance professionals in offices throughout the country, BLX can assemble a team of consultants with the appropriate skills and experience to formulate solutions to even the most demanding projects.

blxgroup.com
PwC

PwC’s higher education practice is built to help address the opportunities and challenges faced by higher education institutions today. With dedicated professionals working with colleges and universities across the nation, PwC assists our higher education clients in tax compliance and planning and in identifying opportunities to increase accountability, transparency, and help to transform to align resources to support their missions.
pwc.com/
RSM US LLP

RSM US LLP is the leading provider of assurance, tax and consulting services focused on the middle market, with 16,600 professionals in 81 cities, six locations in Canada, one in El Salvador and four in India. It is a licensed CPA firm and the U.S. member of RSM International, a global network of independent audit, tax and consulting firms with 64,000 people across 120 countries.

The clients we serve are the engine of global commerce and economic growth, and we are focused on developing leading professionals and services to meet their evolving needs in today’s ever-changing business landscape. Our purpose is to instill confidence in a world of change, empowering our clients and people to realize their full potential.

RSM professionals have extensive experience serving the tax needs of public and private colleges and universities. By staying attuned to the latest trends and developments in the education sector, we can offer timely, practical solutions to proactively meet the needs of our clients.

rsmus.com

12th Annual

Higher Education Taxation Institute

Austin Jun 13-14, 2024 The Otis Hotel Austin Conference Concluded

Buy

Related products: eConference Materials

Overview

Event Schedule

Thursday Morning, June 13, 2024

Thursday Afternoon, June 13, 2024

Friday Morning, June 14, 2024

Conference Faculty

Alan Bond

Susan P. Clark

Brittany Cvetanovich

Benjamin A. Davidson

Robert W. Friz

Richard A. Grafmeyer

Edward J. Jennings

John M. Kelleher

Jodi R. Kessler

Artemis Velahos Koch

Bob Lammey

Kimberly A. Maxwell

Meghan McCollum

Rebecca Menin

Alexandra O. Mitchell

Kirsten Muller

Preston J. Quesenberry

Alexander L. Reid

Colby Rogers

Sean P. Scally

Thomas C. Schroeder

Sandee Stallings

Tyrone P. Thomas

Paula T. Torres

Kyle R. ZumBerge

Planning Committee

Brittany Cvetanovich—Co-Chair

Jodi R. Kessler—Co-Chair

April Rogers—Director

Mary M. Bachinger

Alan Bond

Susan P. Clark

Benjamin A. Davidson

Robert W. Friz

Andrew J. Gray

Bertrand M. Harding Jr.

Joseph R. Irvine

Edward J. Jennings

Donna Kepley

Artemis Velahos Koch

Bob Lammey

Joel Levenson

Ruth M. Madrigal

Alexandra O. Mitchell

Kendi Ozmon

Alexander L. Reid

Sean P. Scally

Kyle R. ZumBerge

Credit Info

MCLE Credit

Other Credit

Key Dates

Venue

The Otis Hotel Austin

Accommodations

Parking Information

Our Sponsors

Stay in the loop with UT Law CLE

12^th Annual

Austin Jun 13-14, 2024 The Otis Hotel Austin
Conference Concluded