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eConference

2025 Taxation eConference

Contains material from Feb 2026
2025 Taxation eConference
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UT Law CLE’s 73rd 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.

Highlights and Learning Outcomes:
  • Gain insights into recent federal and state tax legislative, regulatory, and judicial developments and their implications for tax planning and compliance.
  • Learn how to apply current IRS guidance and best practices to the taxation of cryptocurrency, digital assets, and data-driven substantiation of tax positions.
  • Assess ethical considerations and professional responsibilities under Circular 230 and IRS enforcement procedures, including administrative summonses and grand jury subpoenas.
  • Develop strategies for handling refund claims, including navigating procedural requirements, forum selection, and common pitfalls in litigation.
  • Integrate insights from expert practitioners to enhance tax advisory services and advocacy in a rapidly evolving regulatory environment.

Includes: Video Captions Audio Transcript Paper Slides

  • Total Credit Hours:
  • 14.50 | 1.50 ethics
  • Credit Info
  • TX, CA, OK, PA
  • TX MCLE credit expires: 2/28/2027
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Sessions

Credit
1. Advanced Section 1031 Problems (Feb 2026)

Todd Keator

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Slides (pdf) – 25 pgs

Session 1 —68 mins 1.00

Advanced Section 1031 Problems (Feb 2026)

Current strategies for addressing the most challenging problems when planning for and structuring Section 1031 transactions, including partnership split ups, exchanges of underwater properties, and a comparison of the pros and cons of drop and swaps versus Delaware Statutory Trusts.

Originally presented: Dec 2025 Taxation Conference

Todd Keator, Deloitte Tax LLP - Dallas, TX

2. Startup Financing: The Tax Aspects of SAFEs and Convertible Notes (Feb 2026)

Lesley P. Adamo, Daniel Mayo

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Slides (pdf) – 34 pgs

Session 2 —62 mins 1.00

Startup Financing: The Tax Aspects of SAFEs and Convertible Notes (Feb 2026)

Startup companies often need to raise capital between priced financing rounds. Doing so by entering into convertible notes or a Simple Agreement for Future Equity ("SAFE") is popular, but comes with substantial uncertainty regarding tax treatment and outcomes. This presentation covers common structures for SAFEs and convertible notes, key tax considerations, strategies to mitigate adverse outcomes, and other related matters.  

Originally presented: Dec 2025 Taxation Conference

Lesley P. Adamo, Lowenstein Sandler LLP - New York, NY
Daniel Mayo, Withum - Red Bank, NJ

3. Taxation of Cryptocurrency and Digital Assets (Feb 2026)

Joshua Smeltzer

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Slides (pdf) – 18 pgs

Session 3 —62 mins 1.00

Taxation of Cryptocurrency and Digital Assets (Feb 2026)

A review of the tax considerations and concerns associated with acquiring, holding, and transacting in cryptocurrency and digital assets.  

Originally presented: Dec 2025 Taxation Conference

Joshua Smeltzer, Gray Reed - Dallas, TX

4. Federal Tax Legislative Update (Feb 2026)

Marc J. Gerson

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Slides (pdf) – 36 pgs

Session 4 —58 mins 1.00

Federal Tax Legislative Update (Feb 2026)

Hear about the current tax policy landscape, including recently enacted legislation and the prospects for additional legislation.

Originally presented: Dec 2025 Taxation Conference

Marc J. Gerson, Miller & Chevalier Chartered - Washington, DC

5. Into the Depths of Grayness: Navigating State Income Taxation of Nonresident Individuals (Feb 2026)

Debra Silverman Herman

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Slides (pdf) – 70 pgs

Session 5 —61 mins 1.00

Into the Depths of Grayness: Navigating State Income Taxation of Nonresident Individuals (Feb 2026)

Under well-established constitutional principles, states are allowed to tax resident taxpayers on all of their income, wherever derived, whereas nonresident taxpayers are subject to tax only on their income derived from sources in the nonresident state. But it's not as simple as that. The scope of nonresident taxation can be surprisingly broad. Address a number of potential challenges that nonresident taxpayers face.

Originally presented: Dec 2025 Taxation Conference

Debra Silverman Herman, Hodgson Russ LLP - New York, NY

6. What You Need to Know About the IRS Office of Professional Responsibility and Circular 230 (Feb 2026)

Sharyn Fisk

1.00 1.00 0.00 1.00 | 1.00 ethics
Downloadable Materials
Transcript (txt)
Slides (pdf) – 50 pgs

Session 6 —58 mins 1.00 | 1.00 ethics

What You Need to Know About the IRS Office of Professional Responsibility and Circular 230 (Feb 2026)

Join Sharyn Fisk, the former Director of the IRS Office of Professional Responsibility, for an insider’s view of OPR, including a discussion of recent developments, current trends, and how these changes will affect your practice.

Originally presented: Dec 2025 Taxation Conference

Sharyn Fisk, Cal Poly Pomona - Los Angeles, CA

7. Partnership Taxation: New Rules Governing the Allocation of Debt Among Partners (Feb 2026)

Mark Melton

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Slides (pdf) – 21 pgs

Session 7 —59 mins 1.00

Partnership Taxation: New Rules Governing the Allocation of Debt Among Partners (Feb 2026)

Discuss recently issued final regulations regarding the allocation of debt among partners, including the changes made to the core rules governing recourse liabilities.

Originally presented: Dec 2025 Taxation Conference

Mark Melton, Holland & Knight - Dallas, TX

8. Recent Developments (Feb 2026)

Cassady V. Brewer

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Paper (pdf) – 116 pgs
Slides (pdf) – 48 pgs

Session 8 —59 mins 1.00

Recent Developments (Feb 2026)

A review of significant court decisions, rulings, and statutory and regulatory developments from the past year.  

Originally presented: Dec 2025 Taxation Conference

Cassady V. Brewer, Carlton Fields, P.A. - Atlanta, GA

9. Texas Tax Update (Feb 2026)

Karey Barton

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Paper (pdf) – 34 pgs
Slides (pdf) – 39 pgs

Session 9 —59 mins 1.00

Texas Tax Update (Feb 2026)

An update on Texas tax cases, new legislation, and rulings from the past year.

Originally presented: Dec 2025 Taxation Conference

Karey Barton, KPMG - Austin, TX

10. What to Do With All the Data? Substantiating Tax Positions in the Face of Tidal Waves of Data (Feb 2026)

Melissa L. Wiley

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Slides (pdf) – 24 pgs

Session 10 —62 mins 1.00

What to Do With All the Data? Substantiating Tax Positions in the Face of Tidal Waves of Data (Feb 2026)

In 2025, daily data creation is projected to increase to 495.89 million terabytes, with annual data generation reaching 181 zettabytes. Data is created through every digital process – electronic transactions, smart phones, social media, and live video feeds. All of this is “big data.” Explore how the rise in big data has revolutionized interactions and the exchange of information between taxpayers and tax authorities, and how to best advocate for your client in the Digital Age.

Originally presented: Dec 2025 Taxation Conference

Melissa L. Wiley, Kostelanetz LLP - Washington, DC

11. How the IRS is Using AI and Other Advanced Tools to Improve Compliance and Increase Efficiency (Feb 2026)

Charles P. Rettig

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Slides (pdf) – 79 pgs

Session 11 —70 mins 1.00

How the IRS is Using AI and Other Advanced Tools to Improve Compliance and Increase Efficiency (Feb 2026)

Former IRS Commissioner Charles P. Rettig will discuss how the IRS is leveraging artificial intelligence and sophisticated data analytics to curtail abuse, drive innovation, and increase efficiency at all levels of the IRS.

Originally presented: Dec 2025 Taxation Conference

Charles P. Rettig, Chamberlain Hrdlicka - Los Angeles, CA

12. Responding to Administrative Summonses and Grand Jury Subpoenas (Feb 2026)

Guinevere M. Moore, R. Damon Rowe

1.00 0.50 0.00 1.00 | 0.50 ethics
Downloadable Materials
Transcript (txt)
Slides (pdf) – 18 pgs

Session 12 —60 mins 1.00 | 0.50 ethics

Responding to Administrative Summonses and Grand Jury Subpoenas (Feb 2026)

Learn best practices for minimizing adverse consequences to your client’s business and personal life when faced with one of these investigative tools. Explore what to do both before and after an IRS Special Agent shows up with a summons or grand jury subpoena; the ethical implications surrounding representing a client who has received one of these notices, and responding when one of these documents has been issued to the client’s business, related parties, and third party contacts.

Originally presented: Dec 2025 Taxation Conference

Guinevere M. Moore, Moore Tax Law Group - Chicago, IL
R. Damon Rowe, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P. - Dallas, TX

13. You Can’t Always Get What You Want… But You Can Try Sometimes: The Latest Tax Court Jurisdictional Disputes and Other Rolling Topics (Feb 2026)

Michel R. Stein

1.00 0.00 0.00 1.00
Downloadable Materials
Transcript (txt)
Slides (pdf) – 100 pgs

Session 13 —59 mins 1.00

You Can’t Always Get What You Want… But You Can Try Sometimes: The Latest Tax Court Jurisdictional Disputes and Other Rolling Topics (Feb 2026)

Tax Court litigation continues to evolve. Discuss challenges created by recent developments including the effect of Jarkesy v. SEC on penalty assessments and the National Tapayer Advocate's recent recommendations to subject assessable penalties to the deficiency procedures and to extend the Court's jurisdiction to refund cases.

Originally presented: Dec 2025 Taxation Conference

Michel R. Stein, Hochman Salkin Toscher Perez P.C. - Beverly Hills, CA

14. Refund Claims: A Field Guide (Feb 2026)

Michael W. May, Shawn O'Brien

1.50 0.00 0.00 1.50
Downloadable Materials
Transcript (txt)
Slides (pdf) – 19 pgs

Session 14 —92 mins 1.50

Refund Claims: A Field Guide (Feb 2026)

A practical guide to the rules, strategies, and best practices for handling a refund claim with an emphasis on avoiding traps for the unwary. Address the administrative prerequisites to filing suit, choice of forum, the variance doctrine, the full payment rule, offsets, abatements, statutes of limitations, and other common pitfalls. 

Originally presented: Dec 2025 Taxation Conference

Michael W. May, Department of Justice - Dallas, TX
Shawn O'Brien, McDermott Will & Schulte - Houston, TX