Southern Federal Tax Institute Southern Federal Tax Institute 2107 North Decatur Road, PMB 521, Decatur, Georgia 30033
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Save the Date October 1-5-2007rabd Hyatt Atlantain Buckhead Atlanta, georgia
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Session Topics
What's New
Bussiness Taxation
Accounting, Benefits, Ethics
Estate Planning
Estate Planning
DAY 1
THURSDAY MORNING, SEPTEMBER 25, 2008

07:30-08:30 Breakfast sponsored by MOORE & VAN ALLEN PLLC
07:30-08:15 Special Early Morning Presentation: LEGISLATIVE DEVELOPMENTS, PLEASE! -- The estate and gift tax laws are unstable in their current form and changes seem inevitable. Estate planners are anxious for rules of some kind, whatever form they may take. The Panel will discuss the prospects for legislation, the likely shape of such legislation and suggestions for advising clients in the meantime.

Panel: Stephen R.S. Akers, Bessemer Trust, Dallas, TX
             Diana S.C. Zeydel, Greenberg Traurig, P.A., Miami, FL
             Dennis I. Belcher (moderator), McGuireWoods LLP, Richmond, VA

08:15-09:45 EFFECTIVELY USING DEFECTIVE TRUSTS: PUTTING GRANTOR TRUSTS TO WORK -- Proper drafting and administration of grantor trusts is essential to achieving your clients’ goals. How to achieve grantor trust status, the pro’s and con’s of toggling on and off, how to avoid estate tax traps and more will be covered in this high-powered presentation on an indispensable estate planning tool.

Diana S.C. Zeydel
, Greenberg Traurig, P.A., Miami, FL
Stephen R. Akers, Bessemer Trust, Dallas, TX

09:45-10:00 Break
10:00-11:00

SHOW ME THE MONEY: DISTRIBUTIONS FROM TRUSTS OR ESTATES
Beneficiaries of trusts and estates are typically interested in receiving their respective shares sooner rather than later, and the trustee or executor may feel pressure to make distributions quickly. However unexpected results can occur under complex income tax rules applicable to decedents, estates and trusts if proper planning is not done before assets are distributed; failure to carefully consider such rules may lead to litigation and even personal fiduciary liability. This presentation will guide you through such rules and equip you with planning strategies to assist your clients in their fiduciary roles.

Theodore B
. Atlass, Atlass Professional Corporation, Denver, CO

11:00-12:00 SECTION 6694 AND CIRCULAR 230 PRESENT YOUR NEW ESTATE PLANNING CLIENT: THE IRS – Estate planners regularly give routine tax advice and counsel that is reflected on estate, gift and income tax returns that are filed by their clients. Circular 230 and §6694 impose responsibilities on practitioners who are providing tax advice.
Circular 230 and §6694 are not limited to the tax shelter world and clearly apply to tax practitioners working in the estate planning area. This presentation will examine the requirements of Circular 230 and §6694 and discuss the duties they impose on estate planners and the ways they may change or affect traditional tax practice in this area. (1 hour of ethics and professionalism)

Mickey R. Davis
, Bracewell & Giuliani LLP, Houston, TX
12:15-01:05 Mid-day Program on a topic to be announced. Sponsored and presented by WILMINGTON TRUST FSB, GEORGIA
THURSDAY AFTERNOON, SEPTEMBER 25, 2008
01:15-02:15 TAX PLANNING FOR TAX EXEMPT ORGANIZATIONS –Private foundations and public charities are engaging in an expanding variety of business and charitable activities these days and the tax rules with which they must comply have changed and now impose increased duties on these organizations. This presentation will review the tax rules that apply to private foundations and public charities (including supporting organizations) and offer practice suggestions for practitioners who are creating and advising tax exempt charitable organizations.

Turney P. Berry
, Wyatt, Tarrant & Combs, LLP, Louisville, KY
02:15-03:30 ESTATE PLANNING DURING TURBULENT TIMES - When interest rates drop (or rise) and when market volatility increases, the estate planner must utilize the techniques best suited for these times. The discussion will address financial issues associated with traditional planning, such as sales to defective grantor trusts, GRATs, CRTs and CLTs, as well as other techniques that are less frequently used except in these turbulent times.  

David Pratt
, Proskauer Rose LLP, Boca Raton, FL
03:30-03:45 Break sponsored by TRUSTS & ESTATES MAGAZINE
03:45-04:45 SOMETHING FOR NOTHING? –Your mature high net worth client has been (or is soon likely to be) presented with an opportunity to use his or her insurability in ways that may benefit third-party investors, insurance companies and their agents, as well as the client, with the prospect of little or no cost to the client. These new techniques being offered include debt financed insurance (with no or little collateral and no recourse, as well as with collateral and recourse), stranger owned life insurance, and the use of secondary markets. This presentation will discuss the tax and non-tax issues associated with these new strategies.

John T. Adney
, Davis & Harmon LLP, Washington, DC
04:45-05:45

GOOD KNIGHT TO §67(e) AND OTHER TOPICS IN INCOME TAXATION OF TRUSTS– How to handle fees paid by trusts and estates in light of the 2007 proposed regulations under §67(e), the Knight decision, and the IRS indication that “bundled fiduciary fees” may have to be unbundled in the future. Other significant subchapter J developments.

Ron Aucutt
, McGuireWoods, McLean, VA

05:45-07:15 Cocktail Party sponsored by MANAGEMENT PLANNING, INC.
 
DAY 2
FRIDAY MORNING, SEPTEMBER 26, 2008

07:00-08:00 Breakfast
08:00-09:15 ESTATE AND GIFT TAX PLANNING FOR ANTICIPATED LIQUIDITY EVENTS – The big day is on the horizon and your client is headed toward a sale of the family business or the major real estate holding. Guiding that client through the menu of opportunities for tax effective transfer of wealth that arise in conjunction with a liquidity event, and steering clear of the minefields, poses an exciting challenge for an estate planner. You will leave this presentation armed with a deeper understanding of the relevant valuation, income and transfer tax issues and a new array of techniques to bring to the table.

George F. Albright, Jr.
, J.P. Morgan, Arlington, VA
09:15-10:15 TAX APPORTIONMENT: BOILERPLATE CAN BROIL YOU – Tax payment decisions -- apportioning the tax burden – often are addressed by “boilerplate” provisions in wills and trusts and rarely given the substantive, individuated consideration that they require. Failure to tailor tax apportionment has dispositive consequences that can materially alter or even defeat an estate plan. This presentation will identify a vast panoply of issues and suggest options for resolving them. It will persuade you that a one-to-three paragraph provision is completely inadequate to the task, and provide an alternative for consideration in well-drafted documents.

Jeffrey N. Pennell
, Richard H. Clark Professor of Law, Emory University School of Law, Atlanta, GA
10:15-10:30 Break
10:30-11:45 FAMILY LIMITED PARTNERSHIPS: HOW LONG WILL THIS BE GOING ON? – The battle over the use of family limited partnerships and family limited liability companies has been going on for years now and the issues remain unresolved. Still, estate planners routinely recommend the use of these business structures to their clients with the expectation that the desired tax and non tax objectives will be achieved. Once again, a leading expert will provide an update on the status of the developing law in this area to help you properly advise your clients about the effective use of these entities.

John W. Porter
, Baker Botts L.L.P., Houston, TX
12:00-12:50 Mid-day Program on a topic to be announced. Sponsored and presented by
BNY MELLON WEALTH MANAGEMENT
FRIDAY AFTERNOON, SEPTEMBER 26, 2008
01:00-03:30 RECENT ESTATE PLANNING DEVELOPMENTS - Significant court decisions, rulings and statutory and regulatory developments relating to federal trust and wealth transfer taxes.

Stanley M. Johanson, Distinguished Teaching Professor and Fannie Coplin Regents Chair in Law, University of Texas School of Law, Austin, TX
03:30 Adjourn
   
 

TOTAL COURSE HOURS*
35.25 (60-minute hours)
42 (50-minute hours)
4 hours ethics
4 hours professionalism
2 hours ethics for North Carolina CPAs only

COURSE HOURS FOR MONDAY - WEDNESDAY*
21.50 (60-minute hours)
25 (50-minute hours)
3 hours ethics
3 hours professionalism
2 hours ethics for North Carolina CPAs only



COURSE HOURS FOR WEDNESDAY - FRIDAY
*
21 (60-minute hours)
25 (50-minute hours)
4 hours ethics
4 hours professionalism
2 hours ethics for North Carolina CPAs only (on Tuesday evening)



COURSE HOURS FOR THURSDAY AND FRIDAY
*
13.75 (60-minute hours)
16 (50-minute hours)
1 hour ethics
1 hour professionalism


 
*Not including Early Morning and Mid-day presentations
 
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