2019 SESSION TOPICS
October 26-30, 2020
October 25-29, 2021
SCHEDULES : Business Taxation
TUESDAY MORNING, OCTOBER 22, 2019
James B. Sowell, Presiding
7:00-8:00 – Breakfast
Important Tax Developments Affecting Partnerships and Real Estate, Including Bonus Depreciation, Excess Business Loss Limitations, and Carried Interests – This presentation explores crucial TCJA and more recent developments affecting partnerships and real estate. Topics include Section 168(k) 100% bonus depreciation and its impact on partnership allocations (including book-tax disparities), the new limitation on “excess business losses” under Section 461(l), new limitations under Section 1031, and the new holding period rule for carried interests under Section 1061.
Julie Sassenrath, Shareholder – Winstead PC, Dallas, TX
Exiting a Partnership – This back-to-basics presentation explores common issues encountered upon exiting a partnership. Our speaker highlights the differences between sale and redemption transactions. Planning opportunities, including installment sales and leveraged distributions, also are considered.
John J. Rooney, Director – Washington National Tax Office, KPMG LLP, Washington, D.C.
10:30-10:45 – Break
Let’s Get Practical with the Interest Deduction Limitation Under Section 163(j) – Perhaps one of the most annoying and burdensome new rules imposed by TCJA is Section 163(j)’s limitation on deductions for business interest. Although not a concern for non-tax-shelter businesses with $25 million or less of average annual gross receipts, the new provision is proving to be a nightmare for those advising larger businesses with significant debt. Our expert conveys practical tips and planning tools that you can use to make complying with Section 163(j) (or qualifying for exemption) as painless as possible for you and your clients.
Brian Knudson, Partner and Principal – Ernst & Young LLP, Minneapolis, MN
Mid-Day Program: Capitalizing On Qualified Opportunity Zones – This timely and informative session focuses on the federal Qualified Opportunity Zones (QOZs) program, particularly benefits to investors. QOZs have received tremendous attention and press but a host of questions remain. What are the benefits of QOZs? How can I defer capital gains with an QOZ? What are my options to participate in QOZs by either creating my own fund, or investing in a larger fund?
Sponsors Mike Fields, COO of The Strategic Group, Michael Lemanski of Rivermont Capital and Craig Mason, Partner of RSM US LLP will offer their insights and observations on these and other questions.
TUESDAY AFTERNOON, OCTOBER 22, 2019
Reginald J. Clark, Presiding
1:15-2:15 – Key Tax Developments and Planning Opportunities for "C" and "S" Corporations – TCJA drastically lowered the rate on C corporations to a flat 21%, but S corporations still offer flow-through tax treatment with the added potential for a Section 199A deduction. This presentation examines how these and other recent developments create tax planning opportunities for your corporate clients. The presentation also provides a detailed look at the potential benefits that may be available to holders of stock in a domestic C corporation that constitutes a “qualified small business” under Section 1202.
David Strong, Partner – Morrison Foerster LLP, Denver, CO
The Alphabet Soup of “AET,” “PHCs,” and “PSCs”: The Accumulated Earnings Tax, Personal Holding Companies, and Personal Service Corporations – Do you know your way around Subchapter G (Sections 531-565)? How about Section 269A? For our C corporation clients, what’s old is new again due to the unique rules concerning the accumulated earnings tax, personal holding companies, and personal service corporations. This presentation refamiliarizes us with longstanding rules that have new relevance for C corporations today.
C. Wells Hall, III, Partner – Nelson Mullins Riley & Scarborough, LLP, Charlotte, NC
3:15-3:30 – Break
Transactions Involving S Corporations: Relevant Rules And The Impact Of Tax Reform – TCJA changed certain key dynamics in M&A, such as the dramatic reduction in the corporate tax rate, the availability of 100% bonus depreciation, and the impact of new NOL rules. More subtle changes, such as the new limit on deducting business interest, also impact how corporate acquisitions are structured. And yet, many rules remain the same. Our speaker reviews what’s changed and what hasn’t in planning M&A deals involving S corporations.
Aaron P. Nocjar, Partner – Steptoe & Johnson LLP, Washington, D.C.
Practical Workshop and Insights Relating to Monday and Tuesday Sessions – Selected Topics – We heard you! Responding to attendee feedback, this panel of knowledgeable SFTI Trustees will use real-life examples to highlight the important lessons and practical takeaways discussed over the past two days.
Cameron N. Cosby, Partner – Fried, Frank, Harris, Shriver & Jacobson LLP, Washington, D.C.
Peter J. Genz, Retired Partner – King & Spalding LLP, Atlanta, GA
James B. Sowell, Partner – KPMG LLP, Washington, D.C.
R. David Wheat, Partner – Kirkland & Ellis LLP, Dallas, TX