Southern Federal Tax Institute Southern Federal Tax Institute 2107 North Decatur Road, PMB 521, Decatur, Georgia 30033
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What's New In The Income Tax World?
Pamela F. Olson, Presiding

7:15 Registration Desk Opens
8:00-9:00 Breakfast
9:00-10:30 RECENT FEDERAL INCOME TAX DEVELOPMENTS – This session will delve into significant court decisions, rulings, and statutory and regulatory developments over the past twelve months. These three experts will provide insights into the implications of recent events.
Martin J. McMahon, Jr., James J. Freeland Eminent Scholar and Professor of Law, University of Florida Levin College of Law, Gainesville, FL
Ira B. Shepard, Professor Emeritus of Law, University of Houston Law Center, Houston, TX
Bruce A. McGovern, Professor of Law, South Texas College of Law, Houston, TX
10:30-10:45 Break
12:15 -1:05 Mid-day Program: DEFENDING CAPTIVES, CONSERVATION EASEMENTS, AND OTHER CONGRESSIONAL INDUCEMENTS - The tax incentives Congress enacts to further non-tax public policies seem to draw hostility from those charged with enforcement of all tax laws – both those laws that favor the citizen and those that favor the fisc. By focusing upon defense, this panel will shed light on planning precautions. Sponsored by CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & AUGHTRY and presented by Philip Karter, William O. Grimsinger and Hale E. Sheppard

R. David Wheat, Presiding

1:15-2:15 LEGISLATIVE UPDATE AND THE PROSPECTS FOR TAX REFORM – This presentation will review recently enacted tax legislation and provide insight into the potential for comprehensive tax reform.
Marc J. Gerson, Miller & Chevalier Chartered., Washington, DC
2:15-3:15 STAYING ABREAST OF THE EVER-GROWNG LABYRINTH OF US TAX REPORTING AND COMPLIANCE REQUIREMENTS FOR INBOUND FOREIGN CLIENTS – This program will cover a variety of tax reporting and compliance headaches faced by foreign-owned U.S. enterprises and foreign investors in U.S. real estate, including maintenance of proper transfer pricing documentation; FATCA compliance; filing section 6114 disclosures of treaty-based return positions; complying with section 6038A reporting for related party transactions (Form 5472); FIRPTA compliance issues, including notices of nonrecognition transfers, withholding certificates, and statements provided by a U.S. corporation as to its non-USRPHC status when foreign shareholder sells the corporation’s shares; and selected issues relating to U.S. obligations of withholding agents as to FDAP income, including securing and updating W9-BENs from foreign lenders.
James E. Croker, Jr., Alston & Bird LLP, Washington, DC
3:15-3:30 Break
3:30-4:30 ANALYZING TAX-RELATED PROVISIONS OF PARTNERSHIP AGREEMENTS FROM THE PERSPECTIVE OF THE LAWYER WHO DRAFTS THEM AND THE ACCOUNTANT WHO HAS TO LIVE WITH THEM- Issues to consider when drafting the tax-related provisions of partnership agreements, including avoiding or managing phantom income issues; choice of section 704(c) methods; covenants regarding section 752 debt allocation methodology; choice of profit and loss allocation methodology; provisions regarding preparation and review of tax returns; TEFRA provisions; making sure that the person or entity that the parties intend to be the return signer and TMP can, in fact, act in those capacities; and commonly encountered fractions rule issues for partnerships with tax-exempt investors.
Gary R. Huffman, Vinson & Elkins LLP, Washington, DC
Lynn T. Kawaminami, Deloitte Tax LLP, Atlanta, GA
4:30-5:30 UPDATE ON THE 3.8% NET INVESTMENT INCOME TAX AND RELATED DEVELOPMENTS UNDER SECTION 469 - This program will focus on tax planning opportunities and traps in light of the final net investment income (NII) tax regulations and proposed regulations issued in the fall of 2013. Topics covered will include changes from the original proposed NII regulations; the interaction of the NII tax with the passive loss rules; meaning of “trade or business” concept and particularly as it relates to rental real estate; treatment of guaranteed payments and section 736 payments; dispositions of interests in partnerships and S corporations; application of the NII tax to estates and trusts; recent developments in the section 469 area; and tax strategies for minimizing/avoiding the NII tax.
Jeanne M. Sullivan, KPMG LLP, Washington, DC
5:30-7:00 Cocktail Party
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