SUNDAY EVENING, OCTOBER 26, 2025

5:30-7:30

Registration Begins

MONDAY MORNING, OCTOBER 27, 2025
Farhad Aghdami, Presiding
Sponsored by: Womble Bond Dickinson

7:15-9:00

Registration

8:00-9:00

Breakfast

9:00-10:30

Recent Federal Income Tax Developments
This session highlights significant changes affecting taxpayers over the past twelve months, addressing significant court decisions, rulings, and statutory and regulatory developments.
Bruce A. McGovern, South Texas College of Law, Houston, TX
Cassady V. “Cass” Brewer, Georgia State University College of Law, Atlanta, GA

10:30-10:45

Break

10:45-12:00

Recent Federal Income Tax Developments (cont'd)

12:15-1:05

Mid-Day Program: Opportunity Knocks - Resolving Tax Issues in the Current IRS Environment
DOGE and the Trump Administration have made large cuts to IRS’ budget and personnel. These can present opportunities for you and your client. This presentation will address the recent cuts, how those cuts are impacting IRS enforcements efforts, where we see the future of enforcements, and how you can use the current environment to help your clients resolve ongoing tax disputes.
Sponsored by Chamberlain, Hrdlicka, White, Williams & Aughtry and presented byTom Cullinan, John Hackney and Charles Rettig

MONDAY AFTERNOON, OCTOBER 27, 2025
Michael J. Desmond, Presiding
Sponsored by: Womble Bond Dickinson

1:15-2:15

Tax Policy and Legislative Update: The View from Washington
This presentation will cover the current state of play in tax policy. Whatever that may be come October. The presentation will address the ongoing discussions and/or enacted provisions in the anticipated Republican-led tax legislation, as well as what those changes will mean for taxpayers, how Treasury and the Administration will play a role in implementation, and what the rest of the year may hold for legislative and regulatory prospects.
Tom West, Capitol Tax Partners, Washington, DC

2:15-3:15

International Tax Landscape:  Global (BEPS Pillar 2) and U.S. Tax Update
While much of the world is in the second year of adopting the minimum tax regime (OECD’s BEPS Pillar 2), limiting the ability of countries to compete using income tax rates alone, the U.S. is looking to use tax carrots and sticks to encourage investment in the U.S. We will discuss the status of the OECD BEPS Pillar 2 initiative, the changing views of the U.S. towards the BEPS project, and actions the U.S. is taking to retain and increase investment into the U.S. This will include a legislative update of U.S. tax laws that could impact the international tax landscape.
Aaron Topol, Ernst & Young LLP, Atlanta, GA

3:15-3:30

Break

3:30-4:30

Understanding and Using IRS and State DOR e-Services
The presentation will address the features, functionality, and benefits of using IRS and state DOR e-services and web-based platforms. Specific topics will include registering for IRS e-Services, IRS Tax Pro, Transcript Delivery System (TDS), TIN Matching, and similar applications offered by state revenue departments.
James Pickett, Bennet Thrasher LLP, Atlanta, GA
Chris Stephens, Bennet Thrasher LLP, Atlanta, GA

4:30-5:30

Recapping Decades of Service at the IRS and Navigating the Enforcement Environment Going Forward
Each new Administration puts its stamp on all federal agencies, including the Internal Revenue Service (IRS). With reduced headcount and budget, there have been (and will be more) changes to tax administration and tax enforcement priorities. Drawing on his decades of service, from revenue agent to Acting Commissioner, Doug O’Donnell will provide historic perspective and thoughts on the path forward for taxpayers and advisors in navigating a dynamic new enforcement and compliance environment.
Douglas O’Donnell, [invited], former Acting IRS Commissioner and former Commission of the IRS’s Large Business & International (LB&I) Division, Washington, DC

5:30-7:00

Cocktail Reception

TUESDAY MORNING, OCTOBER 28, 2025
Cameron N. Cosby, Presiding

7:30-8:30

Breakfast

8:30-9:20

Current Trends in Real Estate Debt Workouts
This presentation will provide an overview of the fundamentals of the federal tax aspects of discharge of real estate indebtedness and related transactions, followed by discussion of recent trends in the market. Topics include the application of Sections 108 (CODI) and 165 (losses) and the regulations under Section 1001 to discharges or modifications of real estate debt, transactions that constitute foreclosures, and equity-for-debt exchanges involving debtors that are partnerships or disregarded entities.
David L. Friedline, Deloitte Tax LLP, New York, NY

9:20-10:10

Exiting a Partnership the “Right” Way: How to Exit a Partnership in a Tax Efficient Manner  
This presentation will describe the various exceptions to nonrecognition treatment when receiving a liquidating partnership distribution.  It also will cover transactions that allow a partner to effectively redeem its interest from an economic perspective when a normal liquidating distribution would fall under one of the exceptions.
Bryan A. Rimmke, KPMG LLP, Washington, DC

10:10-10:25

Break

10:25-11:15

Current Developments for Real Estate Partnerships and Investors
This session will address recent developments impacting real estate partnerships and investors. Topics will include final regulations relating to partnership “basis shifting” transactions and partnership debt allocations, and the treatment of so-called “hot assets.” This session will also provide an update on the status of litigation relating to the limted partner exception to the SECA tax base.
Karen Lohnes, PricewaterhouseCoopers LLP, Washington, DC
Stephen Giordano, KPMG LLP, Washington, DC

11:15-12:15

Structuring Considerations for 1031 Exchanges
This panel will discuss structuring considerations for Section 1031 exchanges in various contexts.  Topics to be covered include Section 1031 exchanges out of foreclosure, exchanges involving options, interesting partnership situations, critical issues in oil & gas exchanges, and other recent developments in the field.
Todd Keator, Deloitte Tax LLP, Dallas, TX

12:15-1:05

Mid-Day Program: TBD

TUESDAY AFTERNOON, OCTOBER 28, 2025
R. David Wheat, Presiding

1:15-2:15

Corporate Tax and Cross-Border Hot Topics
Scott M. Levine, Baker McKenzie, Washington DC

2:15-3:15

Sales of Closely Held Businesses:  Avoiding Pitfalls and Planning Ahead for the Best Outcome
This presentation will address issues that (unfortunately) often do not arise until the due diligence stage of the sale of a private held business. Specific topics to be addressed include qualification as an S corporation and steps that can be taken to address defects, qualification for the Section 1202 exclusion of gain on the sale of qualified small business stock and the related basis determination matters.
Tony Nitti, Ernst & Young LLP, Denver, CO

3:15-3:30

Break

3:30-4:30

Why Do We Roll This Way?:  Tax Deferred Transactions in the Private Context
This presentation will address common tax deferral strategies in transactions involving private companies. In the process, the presentation will compare and contrast different approaches applicable in different scenarios, highlighting challenges and opportunities based on target and equityholder structures and identities. The presentation will specifically highlight some of the uncertainties in the intersection of Subchapters C and K, and certain challenges based on special circumstances such as S corporations and non-U.S. persons.
Sara B. Zablotney, Kirkland & Ellis LLP, New York, NY

4:30-5:30

Structuring Investments in Tech, Life Sciences and Other Private Companies
This session will cover key tax considerations for investments in SAFEs, convertible notes and other traditional convertible preferred investments used for startup and other similar investments in traditional C Corporations and LLCs. Specific topics include tax characterization questions, QSBS considerations, minimizing phantom dividend income, and investments in connection with secondary transactions.
William R. Skinner, Fenwick & West LLP, Silicon Valley, CA

WEDNESDAY MORNING, OCTOBER 29, 2025
Michael A. Laing, Presiding
Sponsored by: Miller & Chevalier Chartered

7:30-8:30

Breakfast and Registration

8:30-9:45

Employee Benefits:  Updates to Laws, Regulations, and IRS Operations in the New Administration
This session will cover a dozen wide-ranging “hot topics” in payroll taxes, fringe benefits and other employee benefits, covering audits, worker classification guidance, proposed regulations, and proposed legislative changes. The presenters will cover a list of issues commonly raised in both state and Federal payroll tax audits (ranging from company cafeterias and payroll tax deposit penalties, through the last Administration’s “campaign” to audit company aircraft), and will discuss how those audits might be affected by the IRS’s surprising recent guidance limiting the “Section 530” Federal Moratorium. The presenters will discuss how fringe benefits and third-party payments may dramatically affect the selection of the additional 5 executives who, starting in 2027, must be added to the deduction-disallowance list under Section 162(m). The program also will cover and tax considerations for employers with overfunded pension and medical plans. Finally, the program will cover 2025 pending and enacted legislation affecting employee benefits, and the new Administration’s “Green Book” proposals (which may replace the prior proposals affecting both “on-demand pay” and proposed Section 409A tax withholding with totally new ideas), and will discuss developments in “Taxpayer Advocate” filings intended to expedite return processing, penalty abatements and release of levies.
Mary B. Hevener, Morgan, Lewis & Bockius LLP, New York, NY
Jonathan Zimmerman, Morgan, Lewis & Bockius LLP, Washington, DC

9:45-10:45

Income Tax Accounting Methods:  More Than Just Timing
This presentation will provide participants with a comprehensive overview of income tax accounting methods, including when a method of accounting is established, when timing changes are (and are not) treated as a change in method of accounting, and key procedures for changing a method of accounting. The presentation will also explore the importance of income tax accounting methods under various provisions of the Internal Revenue Code, including Section 59A (base erosion and anti-abuse tax), Section 163(j) (business interest expense limitation), and Section 951A (global intangible low-taxed income), and will identify common situations in which income tax accounting methods can provide taxpayers with a permanent benefit.
Timothy Powell, Ernst & Young LLP, New York, NY

10:45-11:00

Break

11:00-12:00

ESOP as an Option for Ownership Transition: What You and Your Clients Need to Know
This presentation will identify factors necessary to place owners of a business in the best position to use an ESOP as an exit strategy and, if desired, to accomplish charitable giving goals. The presentation also will highlight issues the owners and the business can expect to encounter before closing the many transactions that will result in the ESOP owning the stock of the business, before turning to the obligations of the business and the owners’ involvement in the business following the ESOP transaction. Lastly, the presentation will discuss the parties and advisors needed to properly close an ESOP transaction and to operate and administer the ESOP following the closing.
Castles (Cass) R. Hollis, Bryan Cave Leighton Paisner LLP, Atlanta, GA
Blake Head, BDO Capital Advisors, LLC, Atlanta, GA
Andrew J. Kulesza, JP Morgan Chase, Cincinnati, OH

12:15-1:05

Mid-Day Program: TBD

WEDNESDAY AFTERNOON, OCTOBER 29, 2025
John W. Hackney, Presiding
Sponsored by: Miller & Chevalier Chartered

1:15-2:30

Partnership Audit Rules:  Traps for the Unwary
This presentation will explore some of the more counterintuitive aspects and quirks of the BBA centralized audit procedures that seem particularly prone to misstep, even for a wary tax advisor. Topics will include the bewildering tax consequences of non-income adjustments (“that can’t be right?!”); issues relating to administrative adjustment requests (AARs), including the “stranded overpayment” problem; pros and cons of making the Section 6226 push-out election; situations where the push-out election may not be possible; making sure your partnership’s BBA elections and statements furnished to partners and filed with the IRS are timely and complete; and surprising BBA consequences that can emanate from partnership M&A transactions and partnership terminations, including under the “cease to exist” rules and Section 6232(f).
Kate Kraus, Convington & Burling LLP, Los Angeles, CA
Peter J. Genz, King & Spalding LLP (Retired), Atlanta, GA

2:30-3:25

Resolving Tax Controversies with the IRS Independent Office of Appeals:  What’s New and What’s Next
This presentation will address the final Section 7803 regulations and how they may impact your Appeals’ rights, navigating the Appeals process, understanding your options if you get “stuck” and are having difficulty reaching a resolution, and the recently established Alternative Dispute Resolution Program Management Office and how it functions.
Sheri A. Dillon, Morgan, Lewis & Bockius LLP, Washington, DC

3:25-3:40

Break

3:40-4:35

International Information Return Penalties:  Current Developments and Effective Strategies
This presentation will answer the following questions: What are common international information returns (IIRs) and penalties the IRS may assess? How does the IRS enforce compliance and impose IIR penalties? What are some of the most common triggers for IIR penalties? What options and strategies are available when the IRS assesses penalties and when past compliance issues are identified?
Daniel N. Price, Daniel N. Price PLLC, San Antonio, TX

4:35-5:35

Safeguarding Privilege: Navigating Kovel Engagements
Join our panel of seasoned attorneys and tax advisors as they delve into the essentials of the Kovel doctrine, explore strategic scenarios for initiating Kovel engagements, discuss key engagement terms, and share expert insights on preserving privilege in communications and documentation.
James Parks, Bennett Thrasher LLP, Atlanta, GA
Brian C. McManus, Latham & Watkins LLP, Boston, MA

5:35-6:35

Exhibitor’s Cocktail Hour

THURSDAY MORNING, OCTOBER 30, 2025
Kimberly H. Stogner, Presiding
Sponsored by: Bessemer Trust

7:00-8:00

Breakfast and Registration

8:00-9:30

Recent Federal Wealth Transfer Tax Developments
This presentation will review significant judicial decisions, administrative guidance, and statutory developments relating to wealth transfer taxation over recent months, providing a thorough update on the current estate planning landscape.
Stephen R. Akers, Bessemer Trust, Dallas, TX

9:30-10:30

Four Weeks and a Funeral: Considerations for the Two Weeks Before Death and the Two Weeks After Death
This presentation seeks to answer the questions that professionals often receive from a client’s family members: “Client is about to die–what should I do?” and/or “Client has just died–what do I need to do?” The presentation addresses issues that occur in the final two weeks of life, including incapacity and tax planning. Further, the presentation discusses the immediate aftermath of a client’s death and what can and should be done during that time.
Thomas D. Yates, Yates Campbell LLP, Fairfax VA
Shane Kelley, Kelley & Kelley, P.L., St. Augustine, FL

10:30-10:45

Break

10:45-12:00

SECURE-ly Planning for Retirement Assets
The SECURE Act and SECURE 2.0 overhauled the required minimum distribution (RMD) rules for inherited retirement accounts. This session will help you confidently navigate the most common scenarios advisors face in this new planning environment. The discussion will especially focus on options for the account owner’s surviving spouse and children under the final and proposed RMD regulations issued in July 2024.
Jennifer E. Shirkey, Flora Pettit PC, Charlottesville, VA

12:15-1:05

Mid-Day Program:  Hot Topics at the Intersection of Estate Planning and Business Valuation
This session will discuss the latest valuation cases to be decided by the United States Tax Court and the valuation impact of any meaningful changes to transfer tax and income tax laws.
Sponsored by MPI and presented by Todd G. Povlich

THURSDAY AFTERNOON, OCTOBER 30, 2025
Christopher J.C. Jones, Presiding
Sponsored by: Bessemer Trust

1:15-2:15

IRS Transfer Tax Targets and Trials: What Were They Thinking?
This session will begin with a discussion of the IRS’s enforcement objectives with regard to transfer tax returns involving closely held entities. The discussion will address recent developments in Tax Court jurisprudence and its valuation approaches, all with an eye toward minimizing audit risk.
Stephanie Loomis-Price, Perkins Coie LLP, Austin, TX

2:15-3:15

Expecting the Unexpected:  Flexible Planning for an Uncertain Sunset  
For the past few years, most estate planners were warning clients that current transfer tax exemptions are scheduled to be cut in half at the end of 2025. Today that seems significantly less likely. If the last twenty years have taught us anything, it is to expect the unexpected. This presentation will review the vast array of tools estate planners have to assist their clients in these uncertain times, with a particular emphasis on drafting that maximizes optionality.
Kim Kamin, Gresham Partners LLC, Chicago, IL

3:15-3:30

Break

3:30-4:30

It’s English to Me:  Non-U.S. Trust Law for U.S. Lawyers
Many U.S. clients are beneficiaries of trusts administered in countries other than the United States. Non-U.S. trust law and administrative practices in other countries, however, differ considerably from U.S. trust law. This presentation will address important difference between of non-U.S. trust law and U.S. trust law to allow you to better advise clients on tax and nontax implications of being a beneficiary of a non-U.S. trust.
M. Read Moore, McDermott Will & Emery LLP, Chicago, IL
Bernadette Carey, Carey Olsen, Grand Cayman, Cayman Islands

4:30-5:30

Using Generative AI Ethically & Responsibly In An Estate Planning Practice
Artificial Intelligence is not a new concept for lawyers, who have been applying some forms of it for years. However, the recent emergence of many low-cost and accessible generative AI tools that can offer various benefits in a short time has changed the landscape. But before lawyers can take advantage of these AI assistants, they need to be aware of the ethical and practical implications. How can they ensure that using GAI for client work is secure and appropriate? The existing rules, as well as a new ethics opinion, provide guidance and some best practices. In this session, we will discuss what you need to consider when using GAI in your practice.
Catherine Sanders Reach, North Carolina Bar Association, Cary, NC

5:30-7:00

Cocktail Reception

FRIDAY MORNING, OCTOBER 31, 2025
David C. Sojourner, Jr., Presiding
Sponsored by: Synovus Trust Company, N.A.

7:00-8:00

Breakfast

8:00-9:00

Planning with Life Insurance LLCs after Connelly and Huffman
Connelly increases risk for any life insurance-funded redemption, and Huffman increases risk of IRS disrespecting any buy-sell agreement that is subject to Section 2703.  Learn how to use a life insurance LLC to reduce these risks and reduce or avoid income tax risk when transferring policies as business ownership changes. We will also discuss fairness among owners when funding life insurance premiums.
Steven B. Gorin, Thompson Coburn LLP, St. Louis, MO

9:00-10:00

Review of the Past Year’s Significant, Curious, or Downright Fascinating Fiduciary Cases
This session will review selected reported fiduciary litigation decisions from 2024 that relate to multiple areas of estate planning, estate and trust administration, the fiduciary duties of agents, administrators, trustees, and other fiduciaries, related trial practice, and identifying and navigating contemporary fiduciary challenges.
Dana G. Fitzsimons Jr., Bessemer Trust, Atlanta GA

10:00-10:15

Break

10:15-11:30

Tax Consequences of Trust Modifications and Early Terminations
This session will review transfer tax issues and surprising income tax ramifications of early trust terminations highlighted in recent PLRs and the McDougall case. Importantly, the presentation will address how to avoid these adverse results with more flexible drafting provisions as well as alternative methods of termination.
Edwin P. Morrow III, Kelleher + Holland, LLC, Cincinnati, OH

11:30-1:00

The Great Unknown: What Really Happens When Partners Die?
They say the only certainties in life are death and taxes. If that has always been true, then why do we know so little about what really happens when a partner dies? This presentation unveils the real truth about the “step-up” in basis when a partner dies and what’s left behind for the partnership and its partners. It will discuss planning opportunities before and after death, pitfalls to avoid, and unanswered questions, with a focus on “negative basis” and “negative capital” assets.
Paul S. Lee, Northern Trust Corporation, New York, NY