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
Estate Planning
Upcoming Institutes
Accounting, Erisa, Ethics Et cetera
WEDNESDAY MORNING, OCTOBER 25, 2017
Peter J. Genz,
Presiding

8:30-
9:30
Tax Considerations for Landlords and Tenants – Special tax rules applicable to lessors and lessees of real property are commonly overlooked and present both opportunities and pitfalls. This session provides a general review of tax considerations in the context of leasing, including Section 467, accounting for tenant allowances, and the rules concerning tenant improvements.
Robert D. Schachat, Ernst & Young LLP, Washington, DC, Retired
9:30-
10:45
Tax-Exempts as Partners in Your Transactions – This panel covers income and excise tax concerns that tax-exempt organizations, including qualified plans and private foundations, often encounter in their investments, joint ventures, and other major transactions. Topics include investment structuring via partnerships, blocker entities, REITS, and other vehicles; complying with the joint venture rules; avoiding UBTI; and reporting such transactions and the income therefrom on Form 990.
Kendi E. Ozmon, Ropes & Gray LLP, Boston, MA
Brittany Cvetanovich, Ropes & Gray LLP, Boston, MA
10:45-
11:00
Break
11:00-
12:00
Implications of Section 409A on Common Compensation Arrangements – This presentation discusses common compensation arrangements that seemingly do not involve deferred compensation, but nonetheless implicate Section 409A, including annual bonuses, separation pay, severance benefits, short- and long-term performance-based compensation, and equity-based awards.
Daniel L. Hogans, Groom Law Group Chartered, Washington, DC
12:15-
1:05
Mid-day Program: Captive Clarity: 831(b) and Beyond – Congress recently increased the incentives in the Tax Code and the IRS increased scrutiny. Learn how to properly form a conservative, compliant Captive- for 831(b) or other types.
Sponsored by River Oak Risk and presented by Doug MacGinnitie.

WEDNESDAY AFTERNOON, OCTOBER 25, 2017
David D. Aughtry,
Presiding

1:15-
2:15
The Cure May Kill You: How to Cope with the Conflicts Raised by the Hydra-Headed Repeal of TEFRA – Virtually everyone in the tax controversy world recognizes that TEFRA’s attempt to “streamline” partnership audits became a complex nightmare. Just when we thought matters couldn’t get worse, Congress enacted a new regime effective in 2018 with partnership level taxes (imposed in the year of change, not the year in dispute) that will impact most partnerships, including FLPs and others with flow-through partners (possibly including disregarded single-member LLC partners). Virtually every LLC and partnership agreement must be amended now to deal with the embedded conflicts these rules will inject into almost every partnership tax dispute.
Michael Hauswirth, PricewaterhouseCoopers, Washington, DC
2:15-
3:15
Making Professionalism Work in Protecting Clients from Audit through Appeals to Litigation – To defend an audit today, a practitioner must understand the Service’s more aggressive summons approach, reflexive penalty assertions, and the perils of privilege waiver. After conclusion of the audit phase, practitioners involved in appeals must take into account the National Office’s transition away from face-to-face meetings toward detached “campus” video conferences and telephone calls. This panel explains effective ways to resolve today’s audits and appeals, including a discussion of ways to seek vindication in Tax Court. Professionalism remains the best antidote for these challenges.
Sheldon M. Kay, Crowe Horwath LLP, Atlanta, GA
Colin E. Blalock, Jones and Kolb, Atlanta, GA
(Submitted for 1.0 hour of professionalism credit)
3:15-
3:30
Break
3:30-
4:30
The U.S. Reporting, Penalty, and Prosecution of Foreign Holdings: A Renewable Tax Controversy Resource? – After scores of initiatives and geometric growth in filing requirements, the flow of foreign tax controversies still seems constant. Every tax practitioner must know what filing obligations exist, what opportunities for correction remain, and what prospect of civil and/or criminal punishment a wayward client (and the advisor) face.
Mark E. Matthews, Caplin & Drysdale, Chartered, Washington, DC
Timothy M. Kelly, Bennett Thrasher LLP, Atlanta, GA
4:30-
5:30
Ethical Issues Raised by “Transaction of Interest” Classifications – In the waning hours of the Obama administration, the IRS published two retroactive “transaction of interest” notices that arguably thwart two statutory inducements: Section 831(b) small captive insurance companies, and syndications of Section 170(h) conservation easements. Do these notices administratively contract, if not repeal, enabling statutes? What do we as practitioners tell our clients about coping with past and ongoing participation in captives and conservation easements? Further, what are our ethical obligations in advising a client if we may be considered a “material advisor” obligated to disclose the identity of the client and the subject matter of what we thought was privileged advice?
Bryan C. Skarlatos – Kostelanetz & Fink, LLP, New York, NY
(Submitted for 1.0 hour of ethics credit)
5:30-
6:30
Exhibitor's Cocktail Hour
 
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