SUNDAY EVENING, OCTOBER 18, 2026 |
5:00-7:00 |
Registration Begins |
MONDAY MORNING, OCTOBER 19, 2026
Zachary M. Leder, Presiding
Sponsored by: Miller & Chevalier Chartered |
7:15-9:00 |
Registration |
8:00-9:00 |
Breakfast |
9:00-10:30 |
Recent Federal Income Tax Developments
This session highlights important 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, Carlton Fields, P.A., 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: The End of Information Asymmetry: Handling Tax Controversy in the Information Age
Tax examinations and investigations are increasingly conducted in an environment where expanded information reporting and AI‑driven analytics give tax authorities a detailed factual background before the audit begins. The traditional information asymmetry that once favored taxpayers has significantly narrowed at both the state and federal levels, increasing the likelihood that examinations are framed with potential litigation in mind. Data aggregation and analytics reshape audit dynamics, escalation risk, and the development of enforcement theories that can carry civil, criminal, or litigated consequences. Early involvement of counsel experienced in tax controversy and litigation is increasingly critical to shaping the record, managing narrative risk, and positioning cases for successful resolution—or defense—if disputes advance.
Sponsored by Chamberlain, Hrdlicka, White, Williams & Aughtry, P.C. and presented by Patrick McCann, Larry A. Campagna and Bryan J. Dotson |
MONDAY AFTERNOON, OCTOBER 19, 2026
Lisa M. Zarlenga, Presiding
Sponsored by: Miller & Chevalier Chartered |
1:15-2:15 |
Taxation of Digital Assets: How Did We Get Here and Where Are We Going?
This presentation will begin with a brief overview of the history of digital assets. With this context, the presentation will discuss the prevailing tax landscape as it applies to digital property before considering potential tax issues on the horizon in this setting.
Navin Sethi, Eisner Advisory Group LLC, San Francisco, CA |
2:15-3:15 |
Tax Legislative and Regulatory Outlook
This presentation will address the impact of the One Big Beautiful Bill Act and the current tax legislative environment. In addition, the presentation will include a preview of the 2026 mid-term elections and their potential impact on the tax legislative agenda.
Marc J. Gerson, Miller & Chevalier Chartered, Washington, DC |
3:15-3:30 |
Break |
3:30-4:30 |
Felix and Oscar, Lucy and Ethel, Federal and State Income Tax Systems, and Other Odd Couples
Federal and state income tax systems both share the same foundation, but the differences can be profound. This presentation discusses the critical, often non-intuitive, distinctions between federal and state income taxation and explores the fault lines where national and subnational tax systems part ways: from conformity gaps and state-specific subtractions and addbacks to the treatment of pass-through entities, apportionment disputes, and the evolving landscape of digital taxation. Attendees will gain practical insight into how states decouple from federal provisions like bonus depreciation and qualified opportunity zone exclusions, the strategic implications of varying state NOL rules, and the multiplicity of other compliance traps for the unwary.
Jaye Calhoun, Kean Miller, New Orleans, LA |
4:30-5:30 |
Using Lessons Learned to Navigate the Complexities of the BBA Partnership Audit Regime
IRS exams continue even as resources shrink, and partnership exams under the BBA audit regime are no exception. Drawing on seven years of experience since BBA examinations began in 2019, this presentation spotlights some of the recurring procedural and strategic challenges with BBA and taxpayer choices that can shape how matters are resolved. This presentation will provide attendees with practical insights to help them assist clients in navigating the complex rules of the BBA partnership audit regime.
Rochelle Hodes, Crowe LLP, Washington, DC |
5:30-7:00 |
Cocktail Reception |
TUESDAY MORNING, OCTOBER 20, 2026
Kendal A. Sibley, Presiding
Sponsored by: Asbury Gardner Tax Counsel |
7:30-8:25 |
Breakfast |
8:25-9:15 |
Current Developments in the Partnership Tax Arena
This presentation will review the partnership-related items in the administration’s priority guidance plan, including the proposed regulations that would reverse the “transaction of interest” designation for basis-shifting transactions. The presentation then will turn to the latest decisions on the limited partner exclusion from the SECA tax base, including the Sirius Solutions, LLLP case from the Fifth Circuit and possibly the appeal of the Tax Court’s decision in Soroban Capital Partners, LP from the Second Circuit (if decided by then). Additional cases to be covered include the Tax Court’s decisions in Otay Project LP and Continental Grand Limited Partnership, as well as any other developments in the field that may arise in the interim.
Sarah Ritchey Haradon, PwC, Washington, DC |
9:15-10:05 |
It’s All Relative: Timing and Characterization of Deferred Payments
Deferred payments sit at the intersection of when value is realized and how it is taxed. This presentation explores how timing and characterization principles apply across a range of transactional settings, highlighting how similar economic arrangements can produce materially different tax results. By examining common structures and variations, the discussion will focus on where deferral is respected, where it is challenged, and how planning choices can influence outcomes for both buyers and sellers.
Julie A. Divola, Pillsbury Winthrop Shaw Pittman LLP, San Francisco, CA
Eric Solomon, Ivins, Phillips & Barker, Chartered, Washington, DC |
10:05-10:20 |
Break |
10:20-11:10 |
Navigating Individual-Level Passthrough Loss Limitations: Basis, At-Risk, Passive Activity, and Excess Business Loss Rules
This presentation explores the complex web of partner-level / S corporation shareholder-level loss limitations that govern the deductibility of passthrough losses for non-corporate taxpayers. Focusing on Sections 704(d) / 1366(d) (basis limitations), 465 (at‑risk rules), 469 (passive activity loss limitation), and 461(l) (excess business loss limitation), this presentation walks through ordering rules for applying various loss limitations and reviews the manner in which such loss limitation regimes interact, and also includes a discussion on practical implications for planning for passthrough losses.
Robert S. Keller, KPMG LLP, Washington, DC |
11:10-12:00 |
Opportunities and Pitfalls under the Partnership Disguised Sale Rules
This presentation provides a broad overview of the partnership disguised sale regulations under Section 707(a)(2)(B). These regulations, among the most important in partnership tax, provide helpful guidance on avoiding the pitfall of disguised sale treatment. The regulations also contain a number of important exceptions that can give rise to several potentially useful planning opportunities.
John J. Rooney, KPMG LLP (retired), Washington, DC |
12:15-1:05 |
Mid-Day Program: Rethinking IRS Collections: How Collections Cases Go Off the Rails and How to Keep Them on Track
Some IRS collections cases don't turn out the way they should because of how practitioners approach them. This panel breaks down a proven framework for analyzing collection cases, exposes the most common mistakes that send even experienced practitioners off course, and tackles the complex situations where standard strategies fall short. Walk away with sharper instincts, a cleaner process, and the confidence to keep your toughest cases on track.
Sponsored by Wiggam Law and presented by Jason Wiggam and Judson Mallory |
TUESDAY AFTERNOON, OCTOBER 20, 2026
Gerald V. Thomas, II, Presiding
Sponsored by: Asbury Gardner Tax Counsel |
1:15-2:15 |
Current Developments in the Corporate Tax Arena
This presentation will cover a variety of recent developments in corporate taxation. Particular emphasis will be placed on the rules applicable to Section 355 transactions after the withdrawal of proposed regulations in 2025, the modifications to the QSBS rules as part of the OBBBA, and the recent guidance under the corporate alternative minimum tax.
Andrew Davis, Paul Hastings LLP, New York, NY |
2:15-3:15 |
Navigating Section 382: Practical Insights on Ownership Changes and NOL Limitations
This presentation provides a practical overview of Section 382 and its impact on a corporation’s ability to utilize net operating losses following an ownership change. The presentation will address key concepts, including identifying ownership changes, evaluating equity transaction implications, and calculating ownership shifts, with a focus on monitoring 5% shareholders and stock classifications.
Todd Reinstein, Forvis Mazars, Washington, DC |
3:15-3:30 |
Break |
3:30-4:30 |
Opportunity Zones: Statutory Changes, OZ 2.0 Designations, Recent Guidance, Mandatory Reporting and Market Trends
This presentation will examine the current statutory and regulatory framework governing Opportunity Zones, including changes enacted by the One Big Beautiful Bill Act and their effects on capital raising. The presentation will also review the status of Opportunity Zone 2.0 designations and related transition rules, including outstanding interpretive questions and timing considerations for businesses, investors, and sponsors. Emphasis will be placed on recent guidance, unresolved questions, and practical planning considerations in light of evolving legislative and regulatory developments.
Michael J. Novogradac, Novogradac & Company LLP, San Francisco, CA |
4:30-5:30 |
QSBS: Transactional Planning and Strategies
Qualified small business stock (“QSBS”) tax incentives have sometimes been described as the holy grail of tax planning, and for good reason. QSBS rules, where applicable, can provide a complete federal income tax exemption for large portions (and potentially all) of the otherwise taxable gains recognized by founders, employees and early-stage investors from the sale of stock in many technology and other companies. This presentation will address strategies and techniques for maximizing QSBS benefits at formation and throughout holding periods, transactional structures for realizing/preserving these benefits in M&A, IPO, and other exit events, as well as critical advance planning steps that are needed post-exit in order to preserve and defend these benefits during audits by taxing authorities.
Peter Elias, Orrick Herrington & Sutcliffe LLP, Santa Monica, CA |
5:30-6:30 |
Exhibitors' Cocktail Hour |
WEDNESDAY MORNING, OCTOBER 21, 2026
Michael A. Laing, Presiding
Sponsored by: Womble Bond Dickinson |
7:30-8:30 |
Breakfast and Registration |
8:30-9:45 |
Employee Benefits: An Annual Update to Laws, Regulations, Litigation, and IRS Staffing
This presentation will cover updates in prior SFTI coverage of “hot topics” in payroll taxes, fringe benefits and other employee benefits, as well as 2026 IRS guidance on fringe benefit provisions both in the OBBBA, and in delayed-effective date legislation predating 2025. The 2026 IRS guidance is expected to cover five topics: (1) the new 2026 rules that disallow many deductions for company cafeterias; (2) the disallowed compensation deduction for the five highest compensated non-officers of public companies; (3) W-2 reporting and deduction of overtime pay and tip income; and (4) Trump accounts. The presenter also will discuss continuing state and local tax audits (including Philadelphia’s attempt to impose city income taxes on amounts credited under nonqualified deferred compensation plans), several pending tax cases of first impression (including the long-awaited test case on the payroll tax exclusion for company cafeteria meals, and an appeal of a class action claiming $120 million in damages for the reporting of a Form W-2 settlement that complied with the instructions for reporting contained in IRS rulings), and help provided by the IRS’s Taxpayer Advocate program to resolve long-stalled refund claims and penalty abatement requests.
Mary “Handy” B. Hevener, Morgan, Lewis & Bockius LLP, New York, NY |
9:45-10:45 |
Employee Equity Compensation Granted by Privately Held Business Entities
This presentation will cover various types of nonqualified deferred compensation arrangements that employers may implement. A review of the Internal Revenue Code and the Employee Retirement Income Security Act will highlight key compliance requirements and common traps practitioners should be aware of while still allowing employers to achieve their retention and incentive objectives. The discussion will also examine how the taxation of the entity providing the benefits affects the design and operation of nonqualified deferred compensation plans. The presentation will conclude with a discussion of ethical considerations relevant to these arrangements.
Joshua A. Sutin, Chamberlain, Hrdlicka, White, Williams & Aughtry, San Antonio, TX |
10:45-11:00 |
Break |
11:00-12:00 |
Accounting Methods Considerations in 2026: Navigating a Post-TCJA, OBBBA, and IRA Landscape
As key provisions from TCJA sunset and new rules under the OBBBA take effect for 2026 and beyond, taxpayers must reassess core accounting method positions. This panel will explore emerging considerations across interest limitation, R&D expensing versus capitalization (and credit interplay), and fixed asset strategies—including bonus depreciation, qualified production property, and the elimination of QBAI.
April Estes, PwC, Atlanta, GA
Sandra Nashif, PwC, Birmingham, AL |
12:15-1:05 |
Mid-Day Program: Resolving Family Trust and Estate Disputes – Start-to-Finish Considerations
This presentation will discuss positioning trust and estates disputes for settlement and where litigation may still be required. It will cover special considerations that are unique to trust and estate settlements such as virtual representation, trust modifications, other administrative changes, court approval, and tax matters.
Sponsored by McGuireWoods LLP and presented by Meghan Gehr Hubbard |
WEDNESDAY AFTERNOON, OCTOBER 21, 2026
George A. Hani, Presiding
Sponsored by: Womble Bond Dickinson |
1:15-2:15 |
Managing an IRS Audit: Best Practices in Responding to IDRs and Strategic Considerations for Practitioners
This panel will cover the do’s and don’ts for practitioners responding to Information Document Requests issued by the IRS. It will also explore strategic considerations in managing an examination in the current IRS environment including managing client expectations around longer timelines, evaluating whether to extend statutes of limitations, and considering interest-mitigating deposits.
Anson H. Asbury, Asbury Gardner Tax Counsel, Atlanta, GA
Brian Gardner, Asbury Gardner Tax Counsel, Atlanta, GA |
2:15-3:15 |
The Eye of the Storm: Bracing for Tax Enforcement in Uncertain Times
Notwithstanding a more than 30% decrease in the federal workforce, reduced morale, and substantial budget cuts, the IRS and U.S. Department of Justice is doubling down on enforcement using advanced automation and AI, leveraging its relationships with other federal agencies, and expanding existing programs to bring taxpayers into compliance. This presentation will review the current leadership within the IRS and the Justice Department’s tax sections, discuss current enforcement priorities, targets, and methods, analyze recent court decisions, and identify best practices in representing clients in current tax disputes.
Caroline D. Ciraolo, Kostelanetz LLP, Washington, DC |
3:15-3:30 |
Break |
3:30-4:30 |
Back to Basics on Research and Development Expenditures
Statutory changes, recent caselaw, technology advances, changes to the IRS examination process, anticipated guidance, and other administrative changes have practitioners re-thinking the nature and treatment of research and development expenditures. This presentation will discuss how these developments may impact established paradigms and reevaluate the essential concepts of Sections 41 and 174 while looking to the future for Sections 41 and 174A.
Alexa Claybon, Ernst & Young LLP, Washington, DC |
4:30-5:30 |
Ethical Guardrails for AI in Tax Practice: Competency, Standard of Care, and Malpractice Risk
Tax attorneys, CPAs, financial planners, and wealth managers all face the same deceptively complex question: when AI tools enter the practice, what do professional ethics obligations actually require? This presentation introduces a practical framework for determining which tax and estate planning tasks are appropriate for AI assistance, what competent and ethically sound use of those tools requires, and how misjudgments at either extreme — over-reliance or underutilization — translate into professional conduct violations and liability exposure. Drawing on Circular 230, emerging professional conduct opinions, and evolving malpractice doctrine, attendees will leave with concrete, practice-ready guidance applicable across tax disciplines. (Submitted for 1.0 hour ethics credit.)
Sharyn M. Fisk, Cal Poly Pomona, Pomona, CA |
THURSDAY MORNING, OCTOBER 22, 2026
David C. Sojourner, Jr., 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 |
Demystifying Retirement Benefit Planning: Navigating the Post-2024 Rules
For many clients, retirement accounts represent their largest asset. With significant changes introduced by the SECURE Act, SECURE 2.0, and the final 2024 regulations, planning in this area has become increasingly complex. This presentation will demystify these provisions and explore how to effectively integrate them into the estate planning process. Attendees will gain practical guidance on optimizing tax outcomes, aligning planning strategies with client goals, and addressing common concerns related to qualified retirement benefits and IRAs.
Kathleen R. Sherby, Bryan Cave Leighton Paisner LLP, St. Louis, MO |
10:30-10:45 |
Break |
10:45-12:00 |
Don’t Guess and Make a Mess with QSBS
This presentation will cover the basics of QSBS under Section 1202, address changes after the OBBBA, show how founders can “stack” multiple capital gain exclusions among family members, examine how non-grantor trusts can be the ultimate tool for QSBS planning to protect family members and minimize state income taxes, and discuss the challenges in non-grantor trust drafting compared to the more commonly used irrevocable grantor trusts.
Justin Miller, Evercore Wealth Management, LLC, San Francisco, CA |
12:15-1:05 |
Mid-Day Program: Hot Topics at the Intersection of Estate Planning and Business Valuation
This presentation will discuss the latest valuation cases to be decided by the 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 22, 2026
Alan F. Rothschild, Jr., Presiding
Sponsored by: Bessemer Trust |
1:15-2:15 |
A View from the Front Lines: Current Issues in Estate and Gift Tax Audits and Litigation
This presentation highlights current issues and trends in transfer tax cases at the audit level, at Appeals, and in litigation. The discussion will include the IRS’s current darlings (GRATs, formula clauses, QTIP terminations, and penalties), the old standbys (Section 2036, valuation, privileges, and adequate disclosure), and more. The presentation also will address the most recent cases (including Elcan and McDougall), the IRS’s positions, and how to best position clients at the planning level.
Keri D. Brown, Baker Botts, L.L.P., Houston, TX |
2:15-3:15 |
Why Is Everybody Split on Whether Split Dollar Works?
Clients are looking for opportunities for tax-effective strategies to invest and transfer their wealth. If they decide to use life insurance, a pressing issue quickly arises: What is the most tax-effective way to pay the premiums? This panel will discuss the benefits and drawbacks of financing life insurance premiums through loans, split-dollar arrangements, and gifting.
Mary Ann Mancini, Loeb & Loeb LLP, Washington, DC
Walter L. Helms, Winged Keel Group, Atlanta, GA |
3:15-3:30 |
Break |
3:30-4:30 |
Current Developments Affecting Nonprofit Organizations and Charitable Giving
Donors and charities are weathering tremendous changes in the philanthropic environment. This presentation will provide an overview of how recent changes in tax laws, federal policy, IRS compliance initiatives, legal challenges, and other factors are affecting the way our clients give and the way charities are furthering their missions.
Brad Bedingfield, Hemenway & Barnes LLP, Boston, MA |
4:30-5:30 |
When Trusts Own the Company: Navigating Tax, Estate, and Succession Planning While Keeping the Family Peace
Family business succession planning frequently places business interests into trusts, but doing so brings together several different legal regimes—tax, estate planning, fiduciary law, and corporate law. Using a detailed case study involving an S corporation owned by various trusts with different beneficiaries, this panel examines how common estate planning structures interact with corporate control, trustee duties, and family dynamics. The discussion highlights practical planning considerations including recapitalization strategies, voting control, trustee and trust advisor structures, and the fiduciary conflicts that can arise when trustees, beneficiaries, directors, and family members occupy overlapping roles. The presentation concludes with practical drafting and governance strategies — ranging from shareholder agreements to trust provisions — that can help planners anticipate and mitigate disputes while preserving both tax efficiency and family harmony.
Andrea C. Chomakos, Pendleton Square Trust Company, Inc., Charlotte, NC
Gene Wolf, Kemp Smith LLP, El Paso, TX |
5:30-7:00 |
Cocktail Reception |
FRIDAY MORNING, OCTOBER 23, 2026
Farhad Aghdami, Presiding
Sponsored by: Censeo Advisors |
7:00-8:00 |
Breakfast |
8:00-9:00 |
Looking for Basis in All the Right Places: Income Tax Basis Adjustments in Estate Planning and Administration
High estate and gift tax exclusion amounts and high income tax rates make income tax planning an important consideration in estate planning and administration. Basis adjustment planning is a key component. Learn cutting-edge techniques and tips to maximize basis while still giving effect to your client’s estate planning goals.
Mickey R. Davis, Davis & Willms, PLLC, Houston, TX |
9:00-10:00 |
Succession Planning for Estate/Tax Planning Professionals
This panel will explore succession planning for estate and tax professionals through both a practical and ethical lens. Drawing on their varied experiences, the panelists will examine key considerations in transitioning a practice, including client communication, confidentiality, continuity of representation, and common ethical challenges that arise during transitions. (Submitted for 1.0 hour ethics credit.)
David J. Estes, Estes & Madine, PLLC, Scottsdale, AZ
J. Lee E. Osborne, Woods Rogers Vandeventer Black PLC, Roanoke, VA |
10:00-10:15 |
Break |
10:15-11:30 |
Family Office and Private Trust Company Design: Overview of Different Models & Their Tax and Non-tax Considerations
What is a family office? What kind of family office does a client need? What is a private trust company? This panel will provide an overview of various family office and private trust company structures and the tax and non-tax considerations for each. The panelists will provide a framework for advisors to use when helping clients determine the best option to achieve the family’s goals over time.
Elise J. McGee, McDermott Will & Schulte LLP, Chicago, IL
Benetta Y. Park, Bessemer Trust, West Palm Beach, FL |
11:30-1:00 |
Own Nothing, Control Everything
Like the paintings of Picasso’s Blue Period, a good estate plan is a layered masterpiece that reflects the client’s financial circumstances and ever-evolving emotional state. One of the layers often consists of planning to protect the client’s assets – from the client’s own creditors and those of the client’s beneficiaries. This presentation will cover various asset protection strategies that can help a client’s planning masterpiece stay off the auction block and in the family gallery.
Amy K. Kanyuk, McDonald & Kanyuk, PLLC, Concord, NH |
