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2020 SESSION TOPICS

Virtual Program

UPCOMING INSTITUTES

October 26-27, 2020
October 25-29, 2021

Southern Federal Virtual Tax Institute – October 26 & 27, 2020

Day I:
MONDAY, OCTOBER 26, 2020

8:30-9:30 – Current Developments in Partnership and Real Estate Taxation –This presentation will address recent partnership and real estate tax developments, including the partnership reporting requirements for “tax basis capital;” tax issues and planning relating to “qualified improvement property” in light of CARES Act technical corrections and Revenue Procedure 2020-23; recently proposed regulations defining real property under Section 1031; expected proposed regulations under Section 1061 (carried interests); and recently proposed regulations under Section 512(a)(6) (unrelated business income and loss of tax-exempt organizations).

Panelists:
Cameron N. Cosby, Partner – Fried, Frank, Harris, Shriver & Jacobson LLP, Washington, D.C.
Peter J. Genz, Retired Partner – King & Spalding LLP, Atlanta, Georgia
Moderator:
James B. Sowell, Partner – KPMG LLP, Washington D.C.

9:40-10:40 – What You Need to Know About Debt Workouts and Bankruptcy Tax Planning for Partnerships – Tenant defaults are on the rise in leveraged real estate partnerships, and many other debt-laden businesses are experiencing financial distress. Partnerships facing economic challenges likely will restructure existing debt arrangements. This presentation will review the cancellation of indebtedness (“COD”) rules in the partnership context, including treatment of foreclosures; potential exclusion of COD income; partnership equity-for-debt exchanges; tax consequences of debt modifications; allocation of COD income among partners; actions to consider in advance of a debt workout; and other workout-related tax issues.

Speaker:
James B. Sowell, Partner – KPMG LLP, Washington, D.C. 
Moderator:
Peter J. Genz, Retired Partner – King & Spalding LLP, Atlanta, Georgia

10:50-11:50 – Section 163(j) Update and Related CARES Act Changes – This presentation will address numerous topics, including expected final regulations under Section 163(j); tax planning under the CARES Act Section 163(j) relief provisions and Revenue Procedure 2020-22; and when (and when not) to make (or revoke) a real property trade or business election. 

Panelists
L. Wayne Pressgrove, Jr., Partner – King & Spalding, LLP, Atlanta, Georgia
Peter J. Genz, Retired Partner – King & Spalding LLP, Atlanta, Georgia 
Moderator
James B. Sowell, Partner – KPMG LLP, Washington, D.C.

11:50-1:00 – Lunch Break

1:00-2:00 – Hot Topics in C and S Corporation Tax Planning This program will cover COD income and Section 382 planning in the troubled C- and S-corporation context; Notice 2020-32 and the deductibility of expenses funded by a forgiven PPP loan in the C- and S-corporation context; Section 163(j) issues for corporate taxpayers; CARES Act modifications to the NOL rules; and other late-breaking corporate developments.

Panelists:
R. David Wheat, Partner – Kirkland & Ellis LLP, Houston, Texas
Reginald J. Clark, Partner – Eversheds Sutherland (U.S.) LLP, Atlanta, Georgia 
Moderator:
Zachary (Zack) M. Leder, Partner – Bennett Thrasher LLP, Atlanta, Georgia

2:10-3:10 – How Will the IRS Implement Important Taxpayer Rights Protections Under the “Taxpayers First Act” while Coping with Pandemic-Related Stimulus Programs and Its Own Shutdown? – The IRS is facing unprecedented challenges -- providing guidance on new legislation designed to stimulate the economy as a result of the pandemic and managing backlogs from the pandemic work stoppage. In the midst of this, the IRS must implement important taxpayer rights protections enacted in the Taxpayers’ First Act: modernizing, improving customer service, and updating information technology. What does all this mean for the treatment of taxpayers and protection of taxpayer rights? If things go awry, how do you help your client? What role can the Taxpayer Advocate Service play in fixing the problem? Our expert panelists, including the former National Taxpayer Advocate, Nina Olson, will provide their thoughts and recommendations based upon her first-hand experience with the last IRS reorganization in 1998.

Panelists:
Nina E. Olson, former National Taxpayer Advocate, Internal Revenue Service, Washington, D.C.
Pamela F. Olson, Partner – PwC, Washington, D.C.
Moderator:
John W. Hackney, Shareholder – Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Atlanta, Georgia

3:20-4:20 – Ethical Considerations in Representing Business Owners and Their Families Concerning Their Estate Plans and Related Matters – This presentation will discuss some of the ethical issues that can arise in the context of representing business owners and their families in their estate and succession planning. Our speaker will explore the initial considerations when undertaking the engagement of a business owner and the potential conflicts and confidentiality issues when that engagement expands to include other family members. The presentation also will cover some of the ethical challenges that arise in the context of family succession planning when multiple generations are involved. Finally, using several hypotheticals, our speaker will discuss the role of the attorney as the advisor for the primary owner, the business, and successor generations, as well as the attorney’s role as a fiduciary for one or more of these clients, and the ethical concerns that may arise in these various contexts. (Submitted for 1 hour of ethics credit.)

Speaker:
J. Lee E. Osborne – Partner, Woods Rogers PLC, Roanoke, Virginia
Moderator:
Alan F. Rothschild, Jr., Partner – Page, Scrantom, Sprouse, Tucker & Ford, P.C., Columbus, Georgia


DAY II
TUESDAY, OCTOBER 27, 2020

8:30-9:30 – Using Accounting Method Changes and Elections to Manage Your Client’s Taxable Income and Tax Liabilities – Of course, all taxpayers have adopted accounting methods, and most businesses are familiar with the procedural rules for adopting and changing accounting methods. As companies adapt to more tax complexity post-TCJA, including their non-U.S. based items, they are using accounting methods as levers to manage the otherwise permanent impacts of GILTI and BEAT as well as other long-term and temporary items such as the Section 163(j) limitation. This presentation will explore the use of available accounting methods to strategically manage taxable income and optimize total tax liabilities. 

Speaker:
April L. Estes, Partner – PwC, Atlanta, Georgia
Moderator:
George A. Hani, Member – Miller & Chevalier Chartered, Washington, D.C.

9:40-10:40 – What Side Effects Has the Pandemic Had on Your Benefit Plans? – An analysis of various COVID-19 and CARES Act-related tax effects on qualified and nonqualified employee benefit plans, welfare plans, and fringe benefit arrangements (Section 132(d) exclusion); extension of COBRA elections and special HIPAA enrollment rights; and other late-breaking employee compensation developments. 

Speaker:
Michael A. Laing, Partner – Taft Stettinius & Hollister LLP, Cincinnati, Ohio

10:40-12:30 – Lunch Break

12:30-2:00 – Recent Estate and Gift Tax Developments – In an always lively and informative fashion, this presentation details significant court decisions, rulings, and statutory and regulatory developments relating to trust and wealth transfer taxes over the past 12 months.

Speaker:
Samuel A. Donaldson, Professor of Law – Georgia State University College of Law, Atlanta, Georgia 
Moderator:
Alan F. Rothschild, Jr., Partner – Page, Scrantom, Sprouse, Tucker & Ford, P.C., Columbus, Georgia

2:10-3:40 – The SECURE (“Sending Everyone Cowering Under Reduced Expectations”) Act and Other Recent Developments in Estate Planning for Retirement Assets – The area of estate planning for retirement assets is always busy with recent developments. At the end of 2019, Congress gave us the SECURE Act, which represents a sea change in this area. Then, in the spring of 2020, Congress then gave us the CARES Act, responding to the pandemic. This presentation will provide in-depth coverage of these Acts and their practical ramifications, and also will address other aspects of retirement estate planning where there have been significant new developments.

Speaker:
Robert K. Kirkland, Partner – Kirkland Woods & Martinsen LLP, Liberty, Missouri 
Moderator:
Martha Louise R. Lewis, Member – Ramage Lewis LLC, Greenville, South Carolina

3:50-4:50 – Don’t Get Taken Down in a Zombie Ethics Apocalypse – Tax disputes and controversies typically resolve without the tax professional shedding much blood. But when an accountant or a lawyer gets a little too close to an ethical breach, their risk changes dramatically. Just another day at the office can turn into a cataclysmic disaster. This presentation will help you spot and avoid ethics traps, and the zombie clients who sometimes lay them, especially situations that potentially could eviscerate your career. (Submitted for 1 hour of ethics credit.)

Speaker:
Johannes S. Kingma, Partner – Copeland, Stair, Kingma & Lovell, Atlanta, Georgia 
Moderator:
John W. Hackney, Shareholder – Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Atlanta, Georgia