Thursday, June 8
Registration begins at 8:00 a.m.
Morning Session (8:50am - 12:00pm)
|8:55||Latest Federal Tax Developments
Professor McGovern will highlight the latest federal tax legislation, cases, rulings, and regulations having the greatest impact on individuals and domestic businesses.
|10:55||Latest Federal Tax Developments (cont'd)|
|12:00||Lunch (included with program)|
Afternoon Session (1:00pm - 5:15pm)
|1:00||1. Multistate and Virginia Hot Tax Topics
Craig D. Bell
A lively discussion surveying recent cases, rulings, legislation, and developments of interest in the area of Virginia taxation
|2. International Tax
Diane P. Mimmo
Discussion on tax implications of inbound mergers/acquisitions including a deep dive on business traveler implications of globally mobile employees.
|3. Selling the Successful Business: An Overview of Transactional Tax Issues Applicable to Flow-Through Entities
J. Conrad Garcia
Jenny H. Connors
Sales of closely held businesses that are organized as S corporations present many tax challenges, particularly when selling shareholders want rollover equity. This discussion will focus on transaction structures that achieve optimal tax results, as well as potential tax traps for unwary advisors. Further, it will cover partnership tax issues that arise post-closing and the manner in which such issues should be addressed in the parties’ governing documents.
|3:15||1. Accounting Methods Update
Colleen M. O’Connor
This session will highlight a variety of recent developments in the area of tax accounting methods, including the impact of revised financial accounting standards for reporting revenue and leasing transactions, significant revisions to the procedures for requesting accounting method changes for taxpayers under IRS examination, and a discussion of the recent tax reform proposals as they pertain to accounting methods.
|2. CPE Ethics (Regulatory)
VSCPA Speaker: Jim Cole
|5:15||Adjourn and Cocktail Party|
Friday, June 9
Morning Session (8:45am - 12:15pm)
|8:45||Target Allocations Revisited: Watch How the Accountants Clean Up After the Elephants
Lawyers love target allocations because they think such language is largely boilerplate and low risk, but somebody (usually an accounting firm) still has to interpret the allocations in light of the partnership’s actual year-end facts and put numbers on a tax return. This session will focus on target allocations from the perspective of the accounting firm that must interpret them in light of the partnership’s distribution waterfall, using real-world examples. The panelists will walk through each step in the process, starting with analyzing relevant partnership provisions and ending with the Form 1065 allocations, and highlight commonly encountered drafting ambiguities.
|10:00||Optimizing Capital Gains in Real Estate Transactions
Charles H. Egerton
There has been an uptick in real estate transactions in the past few years as the economy has slowly emerged from the depths of the “Great Recession.” As a result, tax advisors must find creative ways to maximize long-term capital gains and minimize capital losses. This session will focus on rates, holding periods, character-freezing provisions, and the often-litigated dealer vs. investor distinction. It will also explore possible ways to convert high-rate gain into lower-rate gain.
|11:15||Politics, Elections, and Tax Policy Observations in the New Congress
|12:15||Lunch (included with program)|
Afternoon Session (1:00pm - 4:30pm)
|1:00||1. The Top Ten Ethics Issues that Get Tax Professionals in Trouble (MCLE Ethics)
John L. Norman, Jr.
A discussion of a framework for professional ethical decision making followed by 10 case scenarios of ethical issues confronting an attorney in his or her tax practice and how the issue (or issues) could be addressed under the framework in the context of the rules of professional conduct and other relevant guidance.
|2. Compensatory Partnership Arrangements
Deborah A. Fields
This session will include a discussion of the various forms of partnership compensation and relevant recent guidance. The discussion will include hot topics related to partnership compensation including the recent “fee waiver” regulations, the ability to treat a partner as an employee for employment tax purposes, developments related to SECA, an update on carried interest, and the implications of potential tax reform.
|3. Proper Handling of an Audit Tax Controversy, to Include What to Do Today with the New Partnership (and LLC) Audit Rules
Craig D. Bell
Bradley A. Ridlehoover
This presentation will start with a discussion of the ABC’s of representing a taxpayer during a disputed audit, and highlight a number of principles the tax practitioner must consider including setting and planning audit goals, settlement principles and tactics, analyzing the factors that influence a protest decision and subsequent appeal to the IRS Appeals Division. The panel will then tackle the uncertain and new partnership audit rules resulting from the repeal of TEFRA. The new partnership audit rules fundamentally change how the IRS will audit and collect tax from partnerships (and LLCs). The panel will discuss areas such as rules to “opt out” of the new audit requirements and issues created by the new “partnership representative” and their ability to bind partners to audit decisions. How the IRS decides imputed underpayments, and how to implement a new regime of assessment, collection, and payment rules will be covered, as well as statute of limitations applications.
|3:15||Capital Update: Prospects for Federal Transfer Tax Changes
Ronald D. Aucutt