Southern Federal Tax Institute Southern Federal Tax Institute 2107 North Decatur Road, PMB 521, Decatur, Georgia 30033
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Business Taxation
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What's New In The Income Tax World?
Joyce A. Waterbury, Presiding

7:15 Registration Desk Opens
8:00-9:00 Breakfast
9:00-10:30 Recent Federal Income Tax Developments – This session will highlight significant court decisions, rulings, and statutory and regulatory developments affecting taxpayers over the past twelve months.
Martin J. McMahon, Jr., James J. Freeland Eminent Scholar and Professor of Law, University of Florida Levin College of Law, Gainesville, FL
Bruce A. McGovern, Professor of Law, Houston College of Law, Houston, TX
10:30-10:45 Break
10:45-12:00 Recent Federal Income Tax Developments (Con´t)
12:15 -1:05 Mid-day Program: Protecting People Against Penalties – How do you convince someone who disagrees with your position on the merits that you possessed substantial authority, a reasonable belief that you were more likely than not correct, or good faith reasonable cause? While Congress and traditional constitutional principles contemplated that penalties should only be imposed upon a clear violation of a clear standard, the IRS now presumes the application of penalties and often measures them by way of hindsight. And trial courts facing an appeal may not be inclined to undermine their ruling on the merits. In addition to the law of penalties, we will focus on every imaginable factual defense.
Sponsored by Chamberlain, Hrdlicka, White, Williams & Aughtry and presented by Chad J. Muller, John W. Hackney, and David D. Aughtry

Jeffery S. Drummonds, Presiding

1:15-2:30 What’s New in the Southeast? A SALT Update – State and local taxation is a growing area of concern and controversy for business taxpayers. This session will highlight current issues and trends in Southern states. Topics that will be covered include: statutory and regulatory developments, trends toward alternative apportionment, nexus issues, and changes in sales and use tax bases.
Bruce P. Ely, Bradley Arant Boult Cummings LLP, Birmingham, AL
Brett R. Carter, Bradley Arant Boult Cummings LLP, Nashville, TN
Kelly W. Smith, PricewaterhouseCoopers, Atlanta, GA
2:30-3:30 Tax Issues for Entities with Foreign Owners – The market is truly global even for non-public companies. As a result, more and more businesses have foreign owners. This session will highlight some of the transactional, documentation, and reporting items to be addressed by entities that have foreign ownership.
Patrick Williams, Bennett Thrasher LLP, Atlanta, GA
Jenna Walker, Bennett Thrasher LLP, Atlanta, GA
3:30-3:45 Break
3:45-4:45 Optimizing Capital Gains Tax Rates in Sales Transactions – There has been an uptick in property and business sales over the past two years as the economy has slowly come out of its long recession. As a result, tax advisors must find creative ways to maximize long-term capital gains and minimize capital losses. This session will focus on rates, holding periods, netting rules, and the investor/dealer distinction. It will explore possible ways to convert high rate gain into low rate gain, and low rate losses into high rate losses.
Charles H. Egerton, Dean, Mead, Egerton, Bloodworth, Capouano & Bozarth, PA, Orlando, FL
4:45-5:30 Back to the Basics on Installment Sales – This program will review the basic mechanics of the installment sale rules, with a particular focus on the types of property and income (such as depreciation recapture) that cannot be reported under the installment method. It also will cover installment sales to related parties; contingent payment installment sales; imputed interest; electing out of the installment method in contingent payment sales; installment sales of partnership interests and the interface with section 751(a), as addressed in the Mingo case in the 5th Circuit; the interplay with section 1031; and the interest charge rules under section 453A.
David A. Schneider, Skadden, Arps, Slate, Meagher & Flom LLP, Washington, DC
5:30-7:00 Cocktail Party
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