Southern Federal Tax Institute Southern Federal Tax Institute 2107 North Decatur Road, PMB 521, Decatur, Georgia 30033
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Business Taxation
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WEDNESDAY MORNING, SEPTEMBER 21, 2016
Michael A. Laing, Presiding

7:30-8:30 Breakfast
8:30-9:30 The Incredible Shrinking De Minimis Fringe Benefit – The catchall provision of the section 132 regime, the exclusion for de minimis fringe benefits, is under siege. Taxpayers tend to rely on it too much and the IRS resists attempts to expand its application. As a result, this exclusion has become the focus of IRS scrutiny, including a recent challenge to an employer’s tax-free offering of bagels on Wednesdays. This presentation will focus on the IRS’s parsimonious view of de minimis fringe benefits -- particularly with regard to gift cards, employee prizes and awards, and anything that has to do with free or discounted food -- and discuss strategies for surviving an IRS examination.
Marianna G. Dyson, Miller & Chevalier Chartered, Washington, DC
9:30-10:45 The IRS Attack on Small Captive Insurance Companies: Administrative Repeal of a Statute? – After the three captive insurance taxpayer victories in Rent-A-Center, Securitas, and RVI, the IRS placed “abusive” small captive insurance companies on its “dirty dozen” list and initiated an audit project. Meanwhile, Congress expanded the deductible amount for captives to $2.2 million starting in 2017 (though it imposed anti-estate planning ownership and premium restrictions). In the face of expanded Congressional encouragement, does the IRS recognize any “non-abusive” small captives or is this just an attempt to repeal section 831(b) administratively? How do you advise and defend clients in today’s environment? This program will address these and other captive issues.
Val J. Albright, Gardere Wynne Sewell LLP, Dallas, TX
Matthew J. Howard, Moore Ingram Johnson & Steele LLP, Atlanta, GA
10:45-11:00 Break
11:00-12:00 Small Employer Qualified Plans: From 401(k)s to Modern Defined Benefit Pension Plans – This presentation will focus on traditional as well as new opportunities in the design and operation of small business and professional practice qualified retirement plans, including innovative ideas to meet specific employer and owner needs.
Alex G. Kuhel, October Three Consulting, LLC, Chicago, IL
John Lowell, October Three Consulting, LLC, Atlanta, GA
12:15 -1:05 Mid-day Program: Health Care Reform: Employer Tax Penalty Impacts of Employees Enrolling on Exchanges – With the availability of Exchange health coverage (often heavily subsidized with federal premium tax credits), employers should now receive a notice from the Exchange when an employee enrolls in subsidized Exchange coverage. Since a full-time employee’s receipt of tax credits is the trigger for employer penalties under section 4980H, employers and advisors should understand the Exchange notification process and how it relates to penalty assessment. This presentation will explain how Exchange notification works along with the separate IRS process for assessing employer penalties, and suggest strategies for managing compliance.
Sponsored by Thomson Reuters and presented by Gita K. Sharma

WEDNESDAY AFTERNOON, SEPTEMBER 21, 2016
Pamela F. Olson, Presiding

1:15-2:15 Overview of the New Partnership Audit Rules – And you thought TEFRA was bad! There’s no waking up from this nightmare. The first hour on this subject will provide a technical overview of the new partnership audit rules, with particular focus on the opt-out election and push-out election. It will also address the many issues, glitches and unanswered questions that the IRS (or Congress) hopefully will address before the rules take effect, such as issues relating to special types of partners (e.g., REITs); how the rules apply to tiered partnerships; one-way adjustments that merely shift partnership items among partners; and the effect of partnership adjustments on a partner's basis and capital accounts (and other consequences under subchapter K).
Christian Brause, Sidley Austin LLP, New York, NY
Glenn E. Dance, Office of Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service, Washington, DC
2:15-3:15 Changes to Partnership Agreements and M&A Agreements in the Wake of the New Partnership Audit Rules – This segment will focus on drafting and negotiating partnership provisions to deal with the new audit rules. It will also cover important ethical and business issues stemming from the differing economic interests of partners, former partners, and future partners, and potential conflicts between the general partner/LLC manager, acting as partnership representative, and the rest of the partners. Topics will include the sharing of the economic burden of imputed underpayments among partners and former partners; tax disclosure issues in preparing offering memoranda; and dealing with inherited potential entity-level tax liability in M&A transactions involving partnerships.
Karen F. Turk, Goodwin Procter LLP, Boston, MA
Nancy L. Mehlman, Simpson Thacher & Bartlett LLP, New York, NY
(Submitted for 1.0 hour of Ethics Credit)
3:15-3:30 Break
3:30-4:30 The Cutting Edge Issues in Valuation – Valuation represents one out of every five tax disputes. Be it the built-in gains tax, contributions, or an estate & gift dispute for your anchor client, every practitioner needs to know how to dissect the client’s appraisal and, where possible, shred the opposing appraisal. Here, some of the leading valuation experts in the country will not only cover those questions but also where business valuation law is heading, from S corporation tax-affecting, through USPAP Standards Rule 9-3, to the latest on discounts.
Dennis I. Belcher, McGuireWoods LLP, Richmond, VA
David P. Adams III, Adams Capital, Inc., Atlanta, GA
William H. Frazier, Stout Risius Ross, Inc., Dallas, TX
4:30-5:30 Time to Circle the Wagons: What to do When You Find Out You or Your Firm Has Given Bad Tax Advice – Everyone knows the feeling (or knows someone who knows the feeling) of finding a missed issue or a blown election after the fact, or having the IRS find the issue on audit. This program will focus on practical advice on how to deal with the aftermath of a mistake, including how to handle your partners; how to handle firm’s management and malpractice carrier; how to manage the client; how to handle an ensuing IRS controversy; and how to properly prepare a penalty defense. The program will also cover issues relating to the determination of tax-related damages in the event that malpractice litigation follows or is threatened.
Larry A. Campagna – Chamberlain, Hrdlicka, White, Williams & Aughtry, Houston, TX
M. Robert Thornton – King & Spalding, LLP, Atlanta, GA
(Submitted for 1.0 hour of Ethics Credit)
5:30-6:30 Exhibitor´s Cocktail Hour
 
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