University of Texas School of Law

eConference

2016 Taxation eConference

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The Taxation eConference features an impressive slate of topics with regionally and nationally renowned speakers covering current trends, updates in tax regulation and policy, and much more.

Highlights include:
  • Gain insight into The Traps and Pitfalls of the New Section 385 Regulations, including its impact on debt pushdown strategies.
  • The 2016 Election and Prospects for Tax Reform with Dr. Leonard E. Burman, Robert C. Pozen Director of the Tax Policy Center, Washington DC.
  • Explore the implications of crime on the family tax return – what is the impact of criminal gain by one partner in a marriage?
  • Review the new partnership audit rules, with an emphasis on drafting considerations for partnership and LLC agreements and other related documents.
  • Examine the federal income tax and information reporting provisions that may apply to non-resident aliens, resident liens, and U.S. persons receiving gifts from foreign persons.
  • Explore recent developments in federal income taxation with Professor Bruce McGovern.

Total Credit Hours:
13.75 | 2.00 ethics     Credit Info

TX MCLE credit expires: 1/31/2019

Includes: Audio Paper Slides Slideshow

$445  

Preview Sessions
Credit Hours
1. Recent Developments in Federal Income Taxation

Bruce A. McGovern

2.00 0.00 0.00 2.00  

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Audio (mp3) 122 mins
Paper (pdf) 98 pgs
Slides (pdf) 19 pgs

SESSION 1 — 122 mins, credit 2.00

Session 1:

Recent Developments in Federal Income Taxation

Review significant court decisions, rulings, and statutory and regulatory developments of the past year.

Originally presented at: Nov 2016 Taxation Conference

Bruce A. McGovern, Houston College of Law - Houston, TX

2. Traps and Pitfalls of the New Section 385 Regulations

Bret Wells

0.75 0.00 0.00 0.75  

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Audio (mp3) 44 mins
Slides (pdf) 12 pgs

SESSION 2 — 44 mins, credit 0.75

Session 2:

Traps and Pitfalls of the New Section 385 Regulations

The Section 385 regulations are a sea-change event that will have profound impact given the three-year presumptions contained in the regulations and that they broadly apply to many deleveraging transactions and create a presumption of linkage. Explore the impact of Section 385 on debt pushdown strategies, potential workarounds to those impacts, scope limitations of the Section 385 regulations that define “tainted” debt versus “clean” debt, and the collateral damage of the Section 385 regulations to unanticipated situations.

Originally presented at: Nov 2016 Taxation Conference

Bret Wells, University of Houston Law Center - Houston, TX

3. The 2016 Election and Prospects for Tax Reform

Leonard E. Burman

1.00 0.00 0.00 1.00  

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Audio (mp3) 57 mins
Paper (pdf) 72 pgs
Slides (pdf) 8 pgs

SESSION 3 — 57 mins, credit 1.00

Session 3:

The 2016 Election and Prospects for Tax Reform

The presidential election could radically shape tax policy in the United States because the two candidates have starkly different proposals. Explore the implications of the election for tax policy over the short and long run.

Originally presented at: Nov 2016 Taxation Conference

Leonard E. Burman, Tax Policy Center - Washington, DC

4. Distinguishing and Planning around Individual Goodwill

Bruce A. Johnson, Kenton E. McDonald

1.00 0.00 0.00 1.00  

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Audio (mp3) 65 mins
Paper (pdf) 46 pgs
Slides (pdf) 18 pgs

SESSION 4 — 65 mins, credit 1.00

Session 4:

Distinguishing and Planning around Individual Goodwill

Practitioners and appraisers once dismissed distinguishing and planning around "individual goodwill" as far from serious. Now the practice is increasingly accepted and is in widespread use in ways which are, in fact, only a step or two away from negligence, if not fraud. Review these concepts and their limits, especially as they relate to structuring and restructuring around corporate lockup of built-in gains.

Originally presented at: Nov 2016 Taxation Conference

Bruce A. Johnson, Munroe, Park & Johnson, Inc. - San Antonio, TX
Kenton E. McDonald, Branscomb | PC - Corpus Christi, TX

5. Civil and Criminal Employment Tax EnforcementEmployers Beware

Josh O. Ungerman

1.00 0.00 0.00 1.00  

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Audio (mp3) 60 mins
Paper (pdf) 25 pgs
Slides (pdf) 30 pgs

SESSION 5 — 60 mins, credit 1.00

Session 5:

Civil and Criminal Employment Tax EnforcementEmployers Beware

The Department of Justice Tax Division and the IRS have once again elevated employment tax non-compliance to the top of their priority lists. Examine the government’s approach to businesses and individuals that fail to pay employment tax. Hear a discussion about IRS early action employment tax initiative, including often unexpected consequences of early IRS contact. Explore Professional Employer Organization certification, as well as the major risks and traps for the unwary in trust fund recover penalty investigations that may lead to and support a criminal prosecution. In addition to criminal investigations regarding employment tax matters, learn about injunctions which can actually result in a much shorter path to jail than a traditional criminal prosecution.

Originally presented at: Nov 2016 Taxation Conference

Josh O. Ungerman, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P. - Dallas, TX

6. Welcome to America… Now What? U.S. Income Taxation and Other Reporting Requirements

T. Charles Parr III

1.00 0.00 0.00 1.00  

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Audio (mp3) 56 mins
Paper (pdf) 23 pgs
Slides (pdf) 13 pgs

SESSION 6 — 56 mins, credit 1.00

Session 6:

Welcome to America… Now What? U.S. Income Taxation and Other Reporting Requirements

Identify the federal income tax and information reporting provisions that may apply to non-resident aliens, resident aliens, and U.S. persons receiving gifts from foreign persons.

Originally presented at: Nov 2016 Taxation Conference

T. Charles Parr III, Parr & Associates - San Antonio, TX

7. Personal Liability for Corporate Tax Assessments

James F. Martens

1.00 0.25 0.00 1.00 | 0.25 ethics  

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Audio (mp3) 62 mins
Paper (pdf) 24 pgs
Slides (pdf) 23 pgs

SESSION 7 — 62 mins, credit 1.00 | 0.25 ethics

Session 7:

Personal Liability for Corporate Tax Assessments

It’s your client’s worst nightmare. After serving as an officer, a director, or in some cases, an employee of a failed business, there’s a knock on the door. It’s from a sheriff serving a lawsuit alleging the client is personally liable for his or her employer's unpaid Texas taxes. Learn the laws that impose personal liability and how best to defend against it.

Originally presented at: Nov 2016 Taxation Conference

James F. Martens, Martens, Todd, Leonard, Taylor & Ahlrich - Austin, TX

8. New Partnership Audit Rules

Todd Keator, Mary A. McNulty

1.00 0.00 0.00 1.00  

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Audio (mp3) 58 mins
Slides (pdf) 33 pgs

SESSION 8 — 58 mins, credit 1.00

Session 8:

New Partnership Audit Rules

Recently, Congress repealed the current TEFRA regime and replaced it with new audit and collection procedures at the partnership level. Hear an overview of the new partnership audit rules, with an emphasis on drafting considerations for partnership and LLC agreements, and other related documents.

Originally presented at: Nov 2016 Taxation Conference

Todd Keator, Thompson & Knight LLP - Dallas, TX
Mary A. McNulty, Thompson & Knight LLP - Dallas, TX

9. Crime and Marriage

Ian M. Comisky, William Cotter, Mary T. Vidas

1.00 0.75 0.00 1.00 | 0.75 ethics  

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Audio (mp3) 62 mins
Slides (pdf) 9 pgs

SESSION 9 — 62 mins, credit 1.00 | 0.75 ethics

Session 9:

Crime and Marriage

What are the tax implications of crime on the family tax return? What is the impact of criminal gain by one partner in a marriage? Should a spouse have known the money was tainted? Is there an innocent spouse aspect to this? Consider these questions and more.

Originally presented at: Nov 2016 Taxation Conference

Ian M. Comisky, Fox Rothschild LLP - Philadelphia, PA
William Cotter, Internal Revenue Service, Criminal Investigation - San Antonio, TX
Mary T. Vidas, Blank Rome LLP - Philadelphia, PA

10. Avoiding Tax Malpractice

Arthur J. "Kip" Dellinger

1.00 0.00 0.00 1.00  

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Audio (mp3) 58 mins
Paper (pdf) 7 pgs
Slides (pdf) 9 pgs

SESSION 10 — 58 mins, credit 1.00

Session 10:

Avoiding Tax Malpractice

Tax practitioners are continuously confronted with potential potholes and landmines when preparing tax returns for and advising a client with regard to tax matters. Hear a discussion of the malpractice landscape for attorney and CPA tax practitioners with a focus on identifying risks and steps that may be taken to avoid exposure.

Originally presented at: Nov 2016 Taxation Conference

Arthur J. "Kip" Dellinger, Cooper, Moss, Resnick, Klein & Co., LLP - Sherman Oaks, CA

11. Cancellation of Debt

Crawford Moorefield

0.75 0.00 0.00 0.75  

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Audio (mp3) 44 mins
Slides (pdf) 20 pgs

SESSION 11 — 44 mins, credit 0.75

Session 11:

Cancellation of Debt

Explore how the downturn in the energy industry has made COD issues of more frequent concern, as have issues arising in connection with restructuring of debt obligations of partnerships and LLCs.

Originally presented at: Nov 2016 Taxation Conference

Crawford Moorefield, Strasburger & Price, LLP - Houston, TX

12. Using Your Estate Planning Family Limited Partnership for Income Tax Planning, Both at Death and While One is Living

Jerome M. Hesch Esq.

1.25 0.00 0.00 1.25  

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Audio (mp3) 72 mins
Paper (pdf) 31 pgs
Slides (pdf) 27 pgs

SESSION 12 — 72 mins, credit 1.25

Session 12:

Using Your Estate Planning Family Limited Partnership for Income Tax Planning, Both at Death and While One is Living

Discover how to use the partnership income tax rules to transfer appreciated assets, currently owned by irrevocable trusts, either directly or through partnerships, to an individual who can obtain an income tax-free step-up in basis at death. Learn how to use partnerships to increase the basis in appreciated assets that a partnership or an irrevocable trust intends to sell while the senior family member is living.

Originally presented at: Nov 2016 Taxation Conference

Jerome M. Hesch Esq., Aventura, FL

13. Data Security, Client Confidences, and Ethics Rules Applicable to the Protection of Client Information

Leslie C. Thorne, Emily Westridge Black

1.00 1.00 0.00 1.00 | 1.00 ethics  

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Audio (mp3) 61 mins
Slides (pdf) 21 pgs
Slides (pdf) 10 pgs

SESSION 13 — 61 mins, credit 1.00 | 1.00 ethics

Session 13:

Data Security, Client Confidences, and Ethics Rules Applicable to the Protection of Client Information

Tax practitioners hold the keys—literally and figuratively—to some of their clients' most sensitive personal and financial information. Protecting this information has always been of paramount concern for practitioners and for the IRS. Explore the legal and regulatory context for the issue of data security from an ethics perspective. What do the ethics rules, including ABA Model Rule 1.6, require of practitioners in the area of data security and what are the consequences of violating those rules?

Originally presented at: Nov 2016 Taxation Conference

Leslie C. Thorne, Haynes and Boone, LLP - Austin, TX
Emily Westridge Black, Haynes and Boone, LLP - Austin, TX