University of Florida Tax Institute   Florida Tax Institute  
    February 27 - March 1, 2019, Tampa, Florida — Tampa Marriott Waterside    
  UF UF UF  

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Conference Agenda

Continuing Education



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Speakers and Topics

Wednesday, February 27, 2019

7:00 - 8:15am Breakfast
8:15 - 8:30am Welcome and Opening Remarks
8:30 - 10:30am Prof. Cassidy V. Brewer
Georgia State University College of Law
Prof. Bruce A. McGovern
South Texas College of Law Houston
Recent Developments in Federal Income Taxation
This session will review the most significant statutory enactments, judicial decisions, IRS rulings, and Treasury regulations promulgated during the last twelve months that affect general domestic income taxation, corporate taxation, partnership taxation, and tax procedure.
10:30 - 10:45am Break with Exhibitors
10:45 - 11:45am James B. Sowell
Navigating Section 199A in the Real World
A key component of the tax reform legislation is section 199A and the 20% deduction for qualifying business income. But do you qualify? The new provision contains numerous limitations for qualification making the deduction unavailable to many. This session will address all of the important details relating to this complex provision.
11:45am - 1:15pm Luncheon Speaker: Awaiting Confirmation
1:15 - 3:15pm Cristin Keane
Carlton Fields
John F. Lyle III
Adams and Reese
Thomas E. Rutledge
Stoll Keenon Ogden
From Birth to Death - Representing a Business Throughout the Life Cycle
This experienced panel will walk through the life cycle of a closely held business, from the many considerations impacting choice of entity at inception through operational issues including funding, management, equity compensation, potential spinning off into separate business lines, and varied relationships among owners, and progressing to issues relating to cashing out or business succession. Tax advisors can use this insight to guide business owners in understanding the implications of setting up the right type of entity to meet the owners' initial goals while providing sufficient flexibility as the business evolves and the owners' needs change.
3:15 - 4:00pm Break with Exhibitors
4:00 - 5:00pm Professor Gregg D. Polsky
University of Georgia School of Law
Taxation of Litigation Settlements
This session will discuss the federal tax concerns of personal injury plaintiffs and the lawyers who represent them. It will address when plaintiffs' recoveries are taxable for income and employment tax purposes, whether and how those recoveries are required to be reported by defendants to the IRS, whether plaintiffs may deduct attorney's fees and costs, and other tax issues that arise in the litigation context.
5:00 - 7:00pm Welcome Reception

Thursday, February 28, 2019

7:00 - 8:15 am Breakfast with Exhibitors
8:15 - 8:30am Opening Remarks
8:30 - 10:00am

Scott A. Harty
Alston & Bird
Summer Ayers LePree
Bilzin Sumberg
Jeff Rubinger
Bilzin Sumberg
Outbound Tax Planning for Closely Held Businesses After the Tax Reform Act
This panel will focus on post-reform outbound planning and structuring opportunities and pitfalls for US owners of cross-border businesses, including a discussion of the impact of the FDII rules, GILTI, Section 962 elections, and tax-efficient exit and repatriation strategies.

10:00 - 10:15am Break with Exhibitors
10:15 - 11:45am Michael Hirschfeld
Andersen Tax
Philip R. Hirschfeld
Cole Schotz
Professor Fred F. Murray
University of Florida Levin College of Law
Foreign Investment in U.S. Real Estate
This panel will provide tax advisers with a practical look at the opportunities and challenges for foreign investors in U.S. real estate seeking to minimize or eliminate the impact of US income, gift and estate taxes in the wake of the passage of the 2017 tax reform law. After exploring basic concerns such as FIRPTA, the panel will illustrate structures to implement direct ownership of real estate and investments in US real estate funds and REITs as well as the alternative of lending into the US real estate market. Despite tax law changes that may limit the value of interest deductions, use of debt in conjunction with equity ownership is another valuable tax planning strategy that will be explored along with other planning concerns and opportunities.
11:45am - 1:00pm Luncheon Panel:
Crain Bernstein
OPZ Capital
Brian R. Gaister
Pennington Partners & Co.
Steve Hadjilogiou
McDermott Will & Emery
Opportunity Zone Tax Incentives
The new Opportunity Zone tax incentive, intended to spur investments in distressed areas throughout the United States and its possessions, was included in the 2017 tax reform legislation. The incentive permits temporary and sometimes permanent deferral of a taxpayer's gains from any sale or exchange if the taxpayer invests the gain amount in a "qualified opportunity fund" that invests in businesses in low-income areas specifically designated as "qualified opportunity zones."
1:30 - 2:30pm Kelly L. Hellmuth
McGuireWoods LLP
Terminating Private Foundations: Staying Out of Trouble While Shutting Down
When donors no longer need or want their private foundation, they can terminate it but must comply with a number of technical federal tax and state rules. This guide to the termination process will address the various methods of properly terminating a private foundation, the federal tax consequences, and practical tips on the state level.
2:30 - 3:30pm Joel D. Maser
Greenberg Traurig
Guy E. Whitesman
Henderson, Franklin, Starnes & Holt, P.A.
Tips and Traps in Drafting the Operating Agreement - Part I
A review of common tax, economic and governance issues in the formation, operation and winding-up of an LLC with suggested operating agreement provisions to address concerns.
3:30 - 4:00pm Break with Exhibitors
4:00 - 5:00pm Joel D. Maser
Greenberg Traurig
Guy E. Whitesman
Henderson, Franklin, Starnes & Holt, P.A.
Tips and Traps in Drafting the Operating Agreement - Part II
A review of common tax, economic and governance issues in the formation, operation and winding-up of an LLC with suggested operating agreement provisions to address concerns.
5:00 - 6:30pm Reception

Friday, March 1, 2019

7:00 - 8:15am Breakfast with Exhibitors
8:15 - 8:30am Opening Remarks
8:30 - 9:30am Professor Sam Donaldson
Georgia State University College of Law
Current Developments in the Transfer Tax Arena
This informative and entertaining session will recap the important cases, rulings, regulations, and legislation from the past 12 months related to federal income, estate, and gift taxes. Specific topics to be addressed include proposed regulations related to clawback and developments related to the marital deduction.
9:30 - 10:30am

Richard B. Comiter
Comiter, Singer, Baseman & Braun
Mark R. Parthemer

Bessemer Trust
Trust Drafting From the Theoretical To the Practical: In Theory There is No Difference Between In Practice and In Theory. In Practice, There Is
This presentation is drawn directly from experiences with the fiduciary side of the trusts and estates practice. The session's panel will compare "standard" form language with an emphasis on tax and non-tax issues to analyze how drafting efforts can substantially facilitate (or frustrate) the trustee in achieving a client's goals. The issues addressed are all matters that have been encountered, both good and not so good, and addressed from the drafting practitioner and trust administrator perspectives."

10:30 - 10:45am Break with Exhibitors
10:45 - 11:45am

Jonathan G. Blattmachr
Pioneer Wealth Advisors
Top Estate Planning Techniques After Tax Reform
Although there is no longer the frantic emphasis on estate tax reduction and avoidance, those taxes still must be considered whenever an estate plan is being designed. But greater emphasis must be placed on income tax basis enhancement, retention of income tax losses, income shifting, avoidance of state income taxes, preservation of deductions, asset protection, and protection against loss of a family's heritage and wealth. This presentation will discuss over a dozen important steps planners need to take for their clients to effect a solid estate plan.

11:45am - 1:15pm Luncheon Speaker: Ronald D. Aucutt
McGuireWoods LLP
Capital Report - Tax Reform and Partnerships
This presentation will discuss the current status of changes in the tax law affecting estate planning, including an update on whether the changes made at the end of 2017 will be abandoned, altered, or made permanent. It will also discuss pending administrative changes, including regulations affecting "clawback," consistent basis, and valuation.
1:15 - 2:15pm Paul S. Lee
Northern Trust

"Winding Up" with "Pass-Through" Entities (Exploring Parallel Universes)
"Winding up" with a "pass-through" entity can take many forms. "Winding up" can include a full liquidation of the entity, a complete redemption of an owner of the entity, and the death of an owner. A "pass-through" entity can be a disregarded entity, an S corporation, or a partnership. Each "winding up" event poses different planning issues, and each "pass-through" taxes the owners differently. This presentation discusses the planning and tax aspects of winding up pass-through entities, with an emphasis on the stark differences among each transaction and entity.

2:15 - 2:30pm Break
2:30 - 3:30pm A. Stephen McDaniel
Williams McDaniel
Income Tax Considerations in Estate/Trust Settlements and Modifications
Increased levels of conflict in estate and trust administration result in court rulings and settlements that often do not take into account the tax consequences of the matters resolved. This session will look at the tax consequences of estate/trust settlements to help us avoid the morning after comment: "We did not think about the tax consequences."
3:30 - 4:30pm John C. Bovay
Salter Feiber
Carla DeLoach
DeLoach P.L.
Jordan Hurlburt

DeLoach P.L.
Steven M. Rosenbloom
Sheldrick, McGehee & Kohler
Steven R. Smith

Sheldrick, McGehee & Kohler
Clay B. Tousey, Jr.

Fisher, Tousey, Leas, & Ball
Functional Planning for the (sometimes dysfunctional) Family Business
For richer, for poorer, in good times and bad, what governance, structure and valuation considerations do we have for old dad and/or mom transitioning a family business? This panel will explore how family dynamics affect business valuation; and will discuss third party buyers, the interests and perspectives of key non-family employees and the IRS (not to mention the next spouse); likely outcomes when former spouses, and/or estranged children remain business partners; choice of fiduciary; elective share; undue influence; portfolio diversification and other pertinent issues.