eConference

2024 Taxation eConference: Day 1 - Focus on Business Planning

Contains material from Jan 2025
2024 Taxation eConference: Day 1 - Focus on Business Planning
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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.

Includes: Video Audio Slides

  • Total Credit Hours:
  • 6.75 | 1.00 ethics
  • Credit Info
  • TX, CA, PA
  • Specialization: Estate Planning and Probate Law | Tax Law
  • TX MCLE credit expires: 1/31/2026

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1. The Meaning of “as such”: Imposing SECA Tax on Limited Partners (Jan 2025)

Lee Meyercord, Anthony Sacco

1.00 0.00 0.00 1.00
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(mp4)
67 mins
(mp3)
67 mins
Slides
(pdf)
16 pgs
Session 1 —67 mins 1.00
The Meaning of “as such”: Imposing SECA Tax on Limited Partners (Jan 2025)

An update on the current state of examinations and litigation surrounding the limited partner exception to the Self-Employment Contributions Act (SECA), with  an overview of the history and circumstances in which the limited partner exception applies and how to approach this issue during an audit.

Originally presented: Dec 2024 Taxation Conference: Day 1 - Focus on Business Planning

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

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2. Navigating the NIL Landscape: Contracts, Cash, and Compliance (Jan 2025)

Luke A. Fedlam

1.00 0.00 0.00 1.00
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(mp4)
60 mins
(mp3)
60 mins
Slides
(pdf)
14 pgs
Session 2 —60 mins 1.00
Navigating the NIL Landscape: Contracts, Cash, and Compliance (Jan 2025)

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, the latest regulatory changes, and how to effectively navigate the financial and tax challenges associated with these deals through case studies and current events to demonstrate the practical application of these principles in today's dynamic sports environment.

Originally presented: Dec 2024 Taxation Conference: Day 1 - Focus on Business Planning

Luke A. Fedlam, Porter Wright Morris & Arthur LLP - Columbus, OH

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3. What’s a Trade or Business for Tax Purposes? Interpreting Varying Guidance for Real Estate Businesses and Family Offices (Jan 2025)

Bradley T. Borden

1.00 0.00 0.00 1.00
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(mp4)
59 mins
(mp3)
59 mins
Slides
(pdf)
25 pgs
Session 3 —59 mins 1.00
What’s a Trade or Business for Tax Purposes? Interpreting Varying Guidance for Real Estate Businesses and Family Offices (Jan 2025)

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. Learn 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.

Originally presented: Dec 2024 Taxation Conference: Day 1 - Focus on Business Planning

Bradley T. Borden, Brooklyn Law School - Brooklyn, NY

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4. Federal Tax Legislative Outlook (Jan 2025)

Marc J. Gerson

0.75 0.00 0.00 0.75
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(mp4)
45 mins
(mp3)
45 mins
Slides
(pdf)
18 pgs
Session 4 —45 mins 0.75
Federal Tax Legislative Outlook (Jan 2025)

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.

Originally presented: Dec 2024 Taxation Conference: Day 1 - Focus on Business Planning

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

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5. Economic Substance and Liberty Global: Are There Limitations to the ESD? (Jan 2025)

Richard M. Lipton

1.00 0.00 0.00 1.00
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(mp4)
54 mins
(mp3)
54 mins
Slides
(pdf)
18 pgs
Session 5 —54 mins 1.00
Economic Substance and Liberty Global: Are There Limitations to the ESD? (Jan 2025)

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 of the doctrine, with Liberty Global serving as the background for discussion.

Originally presented: Dec 2024 Taxation Conference: Day 1 - Focus on Business Planning

Richard M. Lipton, Baker McKenzie LLP - Dallas, TX

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6. Who’s Your Client? (Jan 2025)

Christopher S. Rizek

1.00 1.00 0.00 1.00 | 1.00 ethics
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(mp4)
60 mins
(mp3)
60 mins
Slides
(pdf)
19 pgs
Session 6 —60 mins 1.00 | 1.00 ethics
Who’s Your Client? (Jan 2025)

Identifying your client seems like a simple issue, but it is frequently complicated, particularly with 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, protect client confidences and privileges, handle communications with others and common interest agreements, etc.

Originally presented: Dec 2024 Taxation Conference: Day 1 - Focus on Business Planning

Christopher S. Rizek, Holland & Knight - Washington, DC

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7. S Corporation Issues in M&A (Jan 2025)

Joan C. Arnold

1.00 0.00 0.00 1.00
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(mp4)
62 mins
(mp3)
62 mins
Slides
(pdf)
17 pgs
Session 7 —62 mins 1.00
S Corporation Issues in M&A (Jan 2025)

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, as well as dealing with state tax items.

Originally presented: Dec 2024 Taxation Conference: Day 1 - Focus on Business Planning

Joan C. Arnold, Troutman Pepper Hamilton Sanders, LLP - Philadelphia, PA