Southern Federal Tax Institute Southern Federal Tax Institute 2107 North Decatur Road, PMB 521, Decatur, Georgia 30033
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Business Taxation
Accounting, Benefits, Ethics
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WEDNESDAY MORNING, OCTOBER 22, 2014
Michael A. Laing, Presiding

7:30-8:30 Breakfast
8:30-9:30 PAYROLL TAX AND FRINGE BENEFIT AUDIT UPDATE – This session will focus on the latest worker classification, reporting, and payroll tax issues affecting taxpayers, including the effect of Windsor and Quality Stores on payroll tax refunds, developments in the fringe benefit and business expense areas, and other issues being raised by the IRS and Congress that affect employment tax liabilities.
Mary B. (“Handy”) Hevener, Morgan, Lewis & Bockius LLP, Washington, DC
9:30-10:45 CLAIMS OF ESOP PROMOTERS: PEELING THE ONION – This presentation will examine the use of an ESOP to finance the acquisition of a company, the parties to the transactions, the need for the ESOP to have its own legal, tax, financial and valuation advisors, and special governance, valuation, and operational issues relating to an ESOP company.
Gregory K. Brown, Holland & Knight LLP, Chicago, IL
W. Dennis Summers, Taylor English Duma LLP, Atlanta, GA
10:45-11:00 Break
11:00-12:00 NEW ISSUES AND OPPORTUNITIES IN THE EVER CHANGING WORLD OF ACCOUNTING METHODS – A discussion of what every practitioner needs to know about current issues and opportunities available to taxpayers when adopting or changing their methods of accounting; about the questions being raised by the IRS at the National Office and on audit and how those questions and the issues they present are being resolved; and how to use accounting methods to avoid issues from being raised in the future.
John C. (Jack) Donovan, Ernst & Young LLP, Washington, DC
12:15 -1:05 Mid-day Program: AN ADVISOR’S GUIDE TO LIFE INSURANCE - The speakers will have a Q&A discussion focusing on recent trends in the affluent life insurance marketplace. Topics that will be covered include: funding strategies for affluent families and business owners; evaluating policy performance and benchmarking to the current marketplace; and options to consider with policies when goals and objectives have changed. Sponsored by MCGUIREWOODS LLP and NEASE, LAGANA, EDEN & CULLEY, INC. and presented by Dennis I. Belcher and Lawton M. “Mac” Nease, III

WEDNESDAY AFTERNOON, OCTOBER 22, 2014
David D. Aughtry, Presiding

1:15-2:15 TRICKLE DOWN AUDIT PROCEDURES – The IRS continues to revamp the LB&I audit process to increase coverage and collections. Beyond static IDR/summons procedures, how will the IRS do it? And what does it mean for small and mid-size taxpayers who have dealt with IRS audits informally in the past or avoided them altogether? This program will explore recent changes to the IRS audit process for large and mid-size taxpayers and where the changes may lead.
Elizabeth Tucker, PricewaterhouseCoopers LLP, Dallas, TX
Colin E. Blalock, Jones & Kolb, Atlanta, GA
2:15-3:15 APPEALING ALTERNATIVES FOR DEALING WITH APPEALS – Trial can be expensive, time-consuming, and uncertain, but your client can't accept the IRS audit team's position. When does docketed status improve settlement prospects? What are the options short of trial that your client can use to resolve disputes with the IRS without appearing in court? This program will look at the options adopted by the IRS to resolve issues—fast fast track, post-appeals mediation, and post-appeals arbitration—and how to use them effectively.
Sheldon M. “Shelly” Kay, Sutherland Asbill & Brennan LLP, Atlanta, GA
3:15-3:30 Break
3:30-4:30 IT STILL TAKES A VILLAGE: BALANCING PROFESSIONALISM, PRIVILEGES, AND ADVOCACY IN TAX CONTROVERSIES – How do you balance civility and the aspirational goals of professionalism against the duty of zealous tax advocacy, a Kovel accountant’s role in a tax defense, and the client’s expectations in an era of change at the IRS? We will focus upon several reported cases and current developments to demonstrate how that balance can be maintained or collapsed.
(Submitted for 1.0 hours of Ethics and Professionalism Credit)
Larry A. Campagna, Chamberlain, Hrdlicka, White, Williams & Aughtry, Houston, TX
4:30-5:30 GETTING COMFORTABLE WITH YOUR LEVELS OF COMFORT AND DETERMINING WHAT LEVEL OF COMFORT YOU NEED TO GET COMFORTABLE WITH – These days it seems that no call with a client on a tax issue can end without a pointed “what is your comfort level” type of question. This presentation will attempt to provide a framework for understanding the morass of opinion levels and their consequences, including ethical standards, Circular 230, the preparer penalty, section 6662 substantial understatement penalty, section 6662A reportable transaction understatement penalty, reasonable cause penalty waivers, section 6694 preparer penalty, reportable transactions, material advisor disclosures, FIN 48, UTP and how to handle sensitive “deal buster” type issues and work effectively with other advisors whose risk assessment differs from your own.
(Submitted for 1.0 hours of Ethics and Professionalism Credit)
Anita C. Soucy, Deloitte Tax LLP, Washington, DC
Matthew D. Lerner, Sidley Austin LLP, Washington, DC
5:30-6:30 Exhibitor´s Cocktail Hour
 
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