2018 SESSION TOPICS
October 21-25, 2019
October 26-30, 2020
SCHEDULES : Accounting, Erisa, Ethics Et cetera
WEDNESDAY MORNING, OCTOBER 24, 2018
Michael A. Laing, Presiding
7:30-8:30 – Breakfast
International Tax Reform Topics That We All Need to Understand – After the TCJA, it’s literally a new world in international taxation. What was expected to be a simplified environment for international tax planners has become just the opposite--a world of increased complexity requiring analysis of many more varied facts and circumstances. This session covers the most important aspects of the new rules, including the transition tax for deferred foreign income, the changes to subpart F, the Global Intangible Low Taxed Income (‘GILTI”) rules, the Base Erosion and Anti-Abuse Tax (“BEAT”), the changes to the earnings stripping rules, and many others.
William B. Sherman, Partner, Holland & Knight LLP, Fort Lauderdale, FL
New § 83(i) and Other Tax Aspects of Private Equity Compensation– In addition to all the other changes enacted by TCJA, modifications were made to the familiar rules under § 83. These modifications will affect how private equity compensation is structured. This session covers the taxation of equity compensation structures, including stock options; restricted stock; phantom stock; stock appreciation rights; fee waivers; carried interest waivers; and partnership profit interests, with a focus on the interplay with new § 83(i).
Gregg D. Polsky, Francis Shackelford Distinguished Professor in Taxation Law, University of Georgia School of Law, Athens, GA
10:45-11:00 – Break
Tax Accounting and Cost Recovery Update – As in other areas, TCJA has made significant changes in tax accounting and cost recovery rules. Expensing will be available for numerous classes of assets through 2023, although questions exist with respect to the scope of the expensing provisions. In many situations, new § 451(b) will accelerate income inclusion by reference to "applicable financial statements" under financial accounting standards. In addition, the availability of exemptions for small businesses with respect to the use of cash method accounting has expanded, along with exemption from UNICAP and qualification for the completed contract method. These various changes and additions to the rules will be discussed.
George A. Hani, Member, Miller & Chevalier Chartered, Washington, D.C.
Mid-day Program: A Year into Tax Reform, How has the Landscape Changed for Tax Credit Investments? – This presentation will cover a number of new considerations in evaluating federal and state tax credit investments created by the 2017 federal tax law changes. Learn from a veteran tax expert — the Managing Director of Tax Credit Investments for the most diversified tax credit investment provider — how the changes in tax reform have impacted federal and state ITCs. The presenter will discuss changes as it relates to rates, depreciation, and interest expense limitations. Changes to the ITCs, namely historic and solar also will be discussed.
Sponsored by Monarch Private Capital and presented by George L. Strobel II.
WEDNESDAY AFTERNOON, OCTOBER 24, 2018
Pamela F. Olson, Presiding
Reading Body Language to Evaluate Truthfulness – Professionalism requires candor which, in turn, requires that you know whether you have been misled. Ever wonder whether and when your opposition, a witness, or even your client is not being truthful? Develop an eye for truthfulness by learning the telltale signs from the body language expert.
Susan Constantine, MPsy, Principal, The Human Behavior Lab, LLC, Apopka, FL
Submitted for 1.0 hour of professionalism credit.
Negotiating in Appeals with Exam Present – The structure of Appeals has moved from opposing face-to-face conferences to inviting Exam to sit in on negotiations. Learn the best approach for handling this new obstacle and reaching the best result, in both an LB&I and SBSE context, from the most effective ADR office in the country.
Brian W. Kittle,Partner, Mayer Brown, New York, NY
3:15-3:30 – Break
International Tax Violations and Rising IRS Enforcement: Successfully Defending Taxpayers in Global Disputes – Despite budget constraints and key vacancies, the IRS continues to target international issues and assert large penalties. The IRS is focused on FBAR violations, expanded foreign asset reporting duties, taxpayers who ceased participation in voluntary disclosure programs, implementation of multiple FATCA weapons, deprivation of passports for tax debtors, automatic penalties for late international information returns, compliance initiatives targeting foreign investors with U.S. rental property, and more. This presentation reviews the latest issues, penalties, cases, rulings, and defense strategies in the international arena.
Hale E. Sheppard, Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, Atlanta, GA
The Accidental Felon: When Does Return Presentation and Advocacy Become a § 7212 Criminal Obstruction Offense? – A pending § 7212 criminal obstruction case suggests that failing to maintain adequate records, structuring transactions and return presentation to reduce audit exposure, and resisting document requests may cross the fuzzy line between civil advocacy and criminal conduct. This expert panel explores this alarming new case to help tax advisors avoid the previously unimaginable—jail time!
Ian M. Comisky–Partner, Fox Rothschild LLP, Philadelphia, PA
Elizabeth P. Askey, Managing Director, Grant Thornton LLP, Washington, D.C.
(Submitted for 1.0 hour of ethics credit)
5:30-6:30 – Exhibitor’s Cocktail Hour