Southern Federal Tax Institute Southern Federal Tax Institute 2107 North Decatur Road, PMB 521, Decatur, Georgia 30033
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WEDNESDAY MORNING, OCTOBER 21, 2015
Michael A. Laing, Presiding

7:30-8:30 Breakfast
8:30-9:30 HEALTH CARE REFORM: THE RUBBER FINALLY MEETS THE ROAD – Health care reform (the “Patient Protection and Affordable Care Act”) poses a number of challenges during 2015 and 2016 for employers as they consider the application of new pay-or-play penalties as well as the tax Code reporting obligations. This presentation will focus on how employers are dealing with the employer mandate issues and preparing to distribute and file PPACA reports in January 2016. The presentation will also focus on what employers are doing now to plan for the “Cadillac” tax which will be imposed in 2018 on plans that are determined to be too generous. Topics discussed will include compliance with PPACA pay or play rules, IRS reporting rules and cost containment measures that plan sponsors are considering as a way of dealing with a possible excise tax for 2018.
Paul M. Hamburger, Proskauer Rose LLP, Washington, DC
9:30-10:45 ACCOUNTING METHODS: WHAT'S NEW? WHAT'S OLD (BUT LITTLE KNOWN)? WHAT'S SCARY? - A presentation of various means of resolving accounting method issues from more than 40 years of experience, including the effects of the new procedures for requesting method changes, an identification of generally unknown techniques for obtaining goals through method changes, and the issues about which practitioners must continue to worry.
Stephen F. Gertzman, Miller & Chevalier Chartered, Washington, DC
George A. Hani, Miller & Chevalier Chartered, Washington, DC
10:45-11:00 Break
11:00-12:00 DEALING WITH ATYPICAL ASSETS IN IRAS AND QUALIFIED PLANS– This presentation will address the legal and practical issues and concerns that arise from investing in atypical investments through an IRA or a qualified plan including hedge funds, private equity, real estate, or interest in closely held businesses. The presentation will address valuation issues and concerns about cost, especially when an individual purchases a business with his account or plan. Areas of concern identified by the Department of Labor and IRS also will be discussed. Finally, the presentation will address how to unwind a problematic investment and the issues that can arise in that setting.
Pamela D. Perdue, Summers Compton Wells LLC, St. Louis, MO
12:15 -1:05 Mid-day Program:

WEDNESDAY AFTERNOON, OCTOBER 21, 2015
William M. Blume, Jr., Presiding

1:15-2:15 THIS ISN'T JUST WHISTLING IN THE WIND: REPRESENTING WHISTLEBLOWERS AND DEFENDING AGAINST THEM – From the now fortified traditional bounty provisions in the Code through the burgeoning arena of qui tam claims, we as tax representatives need to understand how to represent whistleblowers and how to defend our clients against whistleblowers and other informants who may carry an incentive to embellish the facts.
Bryan C. Skarlatos, Kostelanetz & Fink, LLP, New York, NY
2:15-3:15 CUTTING THE ABUSE OUT OF IDRS AND SUMMONSES: EVERY CONCEIVABLE DEFENSE – The convergence of the IRS automated IDR-Summons sequence, the risk of waiving privilege as to the entire subject matter, and the Supreme Court’s summons restraint in Clark heightens the importance of how we as tax representatives respond to abusive IDRs and summonses that can be burdensome and overreaching. This topic will cover every defense and most strategies.
Philip Karter, Chamberlain, Hrdlicka, White, Williams & Aughtry, Philadelphia, PA
3:15-3:30 Break
3:30-4:30 KEY CHANGES IN OUR FEDERAL TAX SYSTEM OVER THE LAST FIFTY YEARS, AND THE ROLE AND IMPACT OF PRACTITIONER PROFESSIONALISM – Through an on-stage dialogue with William Elliott, former IRS Commissioner Larry Gibbs will draw upon his decades of experience in the private and public sectors to highlight significant changes in the development and administration of our federal tax laws. In doing so, Messrs. Gibbs and Elliott will discuss the interplay between these changes and the evolution of the role of professionals in, and their obligations to the integrity of, the federal tax system. This presentation will afford attendees the opportunity to consider in the context of their individual practices their obligations to the administration of our nation's tax laws.
Lawrence B. Gibbs, Miller & Chevalier Chartered, Washington, D.C.
William D. Elliott, Elliott, Thomason & Gibson, LLP, Dallas, TX
(Submitted for 1.0 hours of Professionalism Credit)
4:30-5:30 THE ETHICAL OBLIGATIONS OF A TAX PRACTITIONER: HAS THE DUST FINALLY SETTLED? AND DO I STILL NEED A DISCLAIMER? – The 2004 amendments to Circular 230 represented a seismic shift in the ethical obligations of a tax practitioner. Mercifully, Treasury and the IRS replaced the stringent rules applicable to “covered opinions” and opted for more flexible standards to be applied to written tax advice through amendments finalized in 2014. This presentation will examine where matters currently stand, while also addressing the breadth of the preparer penalty under Section 6694 and the promoter penalty under Section 6701.
Todd Welty, McDermott Will & Emery, Dallas, TX
(Submitted for 1.0 hours of Ethics Credit)
5:30-6:30 Exhibitor´s Cocktail Hour
 
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