eConference
2023 Taxation eConference: Day 1 - Focus on Business Planning
Contains material from Feb 2024
2023 Taxation eConference: Day 1 - Focus on Business Planning
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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.
Includes: Video Audio Paper Slides
- Total Credit Hours:
- 7.75 | 1.00 ethics
- Credit Info
- TX, CA
- TX MCLE credit expires: 1/31/2025
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1.
Buy-In, Buy Out and Operational Considerations for Professional Practices and Closely held Businesses (Feb 2024)
Robb A. Longman
1.00
0.00
0.00
1.00
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Session 1
—65 mins
1.00
Buy-In, Buy Out and Operational Considerations for Professional Practices and Closely held Businesses (Feb 2024)
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.
Originally presented: Dec 2023 Taxation Conference: Day 1 - Focus on Business Planning
Robb A. Longman,
Longman & Van Grack, LLC - Bethesda, MD
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2.
The Conservation Easement Controversy: IRS Attacks, Taxpayer Victories, and New Guidance
(Feb 2024)
(Feb 2024)
Hale E. Sheppard
1.00
0.00
0.00
1.00
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Session 2
—55 mins
1.00
The Conservation Easement Controversy: IRS Attacks, Taxpayer Victories, and New Guidance
(Feb 2024)
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.
Originally presented: Dec 2023 Taxation Conference: Day 1 - Focus on Business Planning
Hale E. Sheppard,
Chamberlain Hrdlicka - Atlanta, GA
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3.
Work Product and Attorney-Client Privilege after In Re Grand Jury: Where Do We Go From Here? (Feb 2024)
Melissa L. Wiley
1.00
1.00
0.00
1.00 | 1.00 ethics
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Session 3
—61 mins
1.00 | 1.00 ethics
Work Product and Attorney-Client Privilege after In Re Grand Jury: Where Do We Go From Here? (Feb 2024)
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.
Originally presented: Dec 2023 Taxation Conference: Day 1 - Focus on Business Planning
Melissa L. Wiley,
Lowenstein Sandler LLP - Washington, DC
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4.
Property Tax 2023: Where We Are, How We Got Here, and What’s Ahead (Feb 2024)
Jennifer Rabb
0.75
0.00
0.00
0.75
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Session 4
—44 mins
0.75
Property Tax 2023: Where We Are, How We Got Here, and What’s Ahead (Feb 2024)
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.
Originally presented: Dec 2023 Taxation Conference: Day 1 - Focus on Business Planning
Jennifer Rabb,
Texas Taxpayers and Research Association - Austin, TX
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5.
Deceptively Simple: Targeted Allocations in Private Equity Deals (Feb 2024)
Mark Dundon
1.00
0.00
0.00
1.00
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Session 5
—57 mins
1.00
Deceptively Simple: Targeted Allocations in Private Equity Deals (Feb 2024)
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.
Originally presented: Dec 2023 Taxation Conference: Day 1 - Focus on Business Planning
Mark Dundon,
Kirkland & Ellis LLP - Houston, TX
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6.
Correcting Partnership Capital Accounts (Feb 2024)
John Colvin
1.00
0.00
0.00
1.00
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Session 6
—62 mins
1.00
Correcting Partnership Capital Accounts (Feb 2024)
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.
Originally presented: Dec 2023 Taxation Conference: Day 1 - Focus on Business Planning
John Colvin,
Colvin + Hallett, P.S. - Seattle, WA
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7.
Transferable Energy Tax Credits (Feb 2024)
Maher Haddad
1.00
0.00
0.00
1.00
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Session 7
—61 mins
1.00
Transferable Energy Tax Credits (Feb 2024)
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.
Originally presented: Dec 2023 Taxation Conference: Day 1 - Focus on Business Planning
Maher Haddad,
Baker & McKenzie LLP - Chicago, IL
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8.
QSBS: Quest for Quantum Exclusions (Queries, Qualms, Qualifications & QOZ) (Feb 2024)
Paul S. Lee
1.00
0.00
0.00
1.00
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Session 8
—61 mins
1.00
QSBS: Quest for Quantum Exclusions (Queries, Qualms, Qualifications & QOZ) (Feb 2024)
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.
Originally presented: Dec 2023 Taxation Conference: Day 1 - Focus on Business Planning
Paul S. Lee,
Northern Trust - New York, NY