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WEDNESDAY MORNING, OCTOBER 23, 2013
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| 7:30-8:30 |
Breakfast |
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| 8:30-9:45 |
MY CLIENT IS SENDING AN EMPLOYEE ABROAD. HELP! – This presentation explores the myriad tax issues that arise in connection with an expatriated employee.
Hale E. Sheppard, Chamberlain, Hrdlicka, White, Williams & Aughtry, Atlanta, GA
Brant Ferrell, PricewaterhouseCoopers LLP, Atlanta, GA |
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| 9:45-10:00 |
Break |
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| 10:00-11:00 |
IMPROVING THE REPAIR REGULATIONS – This presentation will address the recent tangible personal property regulations, highlighting the provisions that have changed and stressing the provisions that are likely of greatest importance to your clients.
Brandon Carlton, Ernst & Young, Washington, DC
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| 11:00-12:00 |
WHAT’S NEW IN THE WORLD OF RETIREMENT PLANS – This presentation will focus on changes available to assist the small business owner in maximizing retirement savings while minimizing risk including: new plan design options; areas to look for on the corporate or plan return that might draw interest from the IRS; what you should know and look out for if your client is advised to fund that new business with IRA or retirement plan money; and other changes and issues.
Pamela D. Perdue, Summers Compton Wells, PC, St. Louis, MO
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| 12:15 -1:05 |
Mid-day Program |
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WEDNESDAY AFTERNOON, OCTOBER 23, 2013
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| 1:15-2:15 |
BROAD ISSUES RAISED BY HIGH NET WORTH AUDITS – Discussion of the new quasi-LB&I team format, summons and IDR defense, interviews, international aspects (including foreign bank accounts), entity and trust recognition issues, and income tax fallout from estate/gift planning.
Charles P. Rettig, Hochman, Salkin, Rettig, Toscher & Perez, P.C., Los Angeles, CA
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| 2:15-3:15 |
DIFFERENT GAME DIFFFERENT RULES: ETHICS IN RETURN PREPARATION VS. ETHICS IN RETURN DEFENSE – Ethical obligations vary dramatically between a practitioner’s disclosure role as a preparer and advocacy role in defense of a return. This topic will cover the wide range of ethical differences and obligations to the client in dealing with delinquent returns, discovery of prior return errors, representations vs. nonrepresentations vs. misrepresentations, audit production obligations, witness interview preparation, the conflict between the duty to the client and the duty to the Service in the instance an IRS settlement error, and the like.
Matthew D. Lerner, Steptoe & Johnson, LLP, Washington, DC
Peter S. Wilson, McGladrey LLP, Raleigh, NC
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| 3:15-3:30 |
Break |
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| 3:30-4:30 |
BASIC CRIMINAL TAX WORKSHOP FOR THE UNINIATED – To protect themselves and their clients when an unexpected criminal investigation arises, every practitioner needs to possess a basic understanding of criminal tax charges, investigation, firs responses, and how to avoid waiving privileges without appearing complicit. Discussion will include failure to previously report foreign bank accounts and the implications of enhanced foreign reporting of such accounts under FACTA.
Mark E. Matthews, Caplin & Drysdale, Chtd., Washington, DC
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| 4:30-5:30 |
ETHICAL HAZARDS AND PROFESSIONAL CONSIDERATIONS IN ASSERTING A RELIANCE DEFENSE ON BEHALF OF YOUR CLIENT – Ethical and professional problems abound for tax advisors who prepare returns or provide advice, and then need to assert a reliance defense for their client under audit. What’s left of reliance, reasonable cause and ordinary care? A successful reliance defense raises professionalism challenges in persuading the reliance witness to support the defense, potential conflict issues for the firm which handled the transaction or the return, and sometimes a collision between zealous advocacy, waiver of privileges, and principles of professionalism in dealing with an adversary who accuses your client and his or her representatives of misconduct.
Todd Welty, SNR Denton, Dallas, TX
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| 5:30-6:30 |
Exhibitor´s Cocktail Hour |
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