Cassady V. Brewer, Georgia State University College of Law / Atlanta, GA
Bruce McGovern, South Texas College of Law Houston / Houston, TX

Cassady V. Brewer, Georgia State University College of Law / Atlanta, GA
Bruce McGovern, South Texas College of Law Houston / Houston, TX

The passage of the 1998 IRS Restructuring Act signed by President Clinton was a landmark piece of legislation in the United States that drastically and dramatically changed taxpayers’ rights in dealings in collection cases with the IRS. For the first time in the over 125+ year history of the IRS, taxpayers were provided fundamental collection due process appeal rights prior to levy with an opportunity for a hearing to be heard before an impartial hearing officer. This presentation will focus on the tools that are available in the tax practitioner's toolbox after the 1998 Act and provide an outline of various rights and remedies that are available since the Act was passed as well as other collection avenues to consider in the collection process. Additionally, we will examine recent developments under the current administration, including efforts to streamline tax procedures and their potential impact on practitioners and taxpayers alike.

Guy Crowgey, Crowgey & Associates / Richmond

This session will explore in real-time the tax policy state-of-play in Washington, DC, including where Republicans stand in their effort to extend the expiring components of the Tax Cuts and Jobs Act of 2017 and to enact elements of the tax agenda laid out by President Trump during his campaign. This session will also provide insight into the political, economic, budgetary, and procedural factors that are shaping the fiscal policy debate.

Alex Brosseau, Deloitte Tax LLP / Washington, DC

This session will discuss current trends with real examples of SALT issues in M&A transactions and how they are being solved by Buyer and Seller.

Nick Harrison, KPMG / Richmond

This presentation will discuss ways to modify or terminate irrevocable trusts and explore various reasons why trusts need to be modified or terminated, different mechanisms that can be utilized, and tax considerations.

Christine Piersall, Williams Mullen / Richmond

Many partnerships are now under attack. The IRS claims that they have incorrectly treated their owners as “limited partners,” thereby allowing them to escape self-employment taxes on their distributions. Partnerships base their positions on a law enacted way back in 1977, which has never been updated. The broad scope of the “limited partner” exception, governmental inaction over the next five decades, and the IRS’s recent Compliance Campaign have led to chaos. This presentation will chronicle the major events culminating in the current court disputes.

Hale E. Sheppard, Eversheds Sutherland (US) LLP / Atlanta, GA

Tax lawyers and accountants are of course subject to the ethics rules in the jurisdictions where they are licensed. But everyone who practices before the IRS is also subject to the rules of conduct set forth in Treasury’s “Circular 230.” This presentation will review the applicable rules and specifically focus on Treasury’s proposed changes to the Circular 230 regulations, which are currently awaiting final approval.

Christopher Rizek, Holland & Knight / Washington, DC

It’s 2025 and we’re implementing most of the SECURE 2.0 retirement plan changes. What is now operational, and what particularly is new in 2025 that we need to know about? Let’s talk about changes like Mandatory Automatic Enrollment, Long-Term Part-Time Employees, changes to plan correction procedures, new distribution options, and all of the reporting needed for participants who decided to elect to have their employer contributions made to their accounts as Roth amounts. And, next year, we’ve got the new Catch-up-Contributions-Have-to-Be-Roth rules coming into play. Yikes!

Join ERISA Attorney Ilene Ferenczy for an overview of what’s going on in 2025 and what’s in store for us in 2026, including the guidance the regulatory agencies have provided—or failed to provide—to help plan sponsors react and make decisions.

Ilene Ferenczy, Ferenczy Benefits Law Center / Atlanta, GA

This session will provide an overview of the partnership audit rules under the Bipartisan Budget Act of 2015 (“BBA”). It will address the role of the partnership representative and strategic considerations that often come into play in a BBA audit.

Adriana Wirtz, Vinson & Elkins / New York, NY

This presentation will discuss the future of PTET post-election, consideration when making a PTET election, and SALT updates for local states.

Ryan Young, PBMares, LLP / Norfolk

This presentation will start with updates on what individuals moving to or from the U.S. need to know, including U.S. individuals moving overseas, foreign nationals moving to the U.S., and foreign ownership of U.S. real property. It will conclude by examining incentives and traps for cross-border companies.

Lynn Eller, PBMares, LLP / Fairfax/em>