2026 Speakers and Topics (subject to change)

Wednesday, April 8, 2026
8:00 - 8:45 am	Breakfast
8:45 - 10:15 am	Yariv Brauner University of Florida Levin College of Law Debora Correa Talutto Marriott Vacations Worldwide Matthew M. Mauney Goodwin Fred F. Murray IRS Doron Narotzki The University of Akron, George W. Daverio School of Accountancy Carlos Vaca Valverde DLA Piper LLP (US) Alvaro Villegas Villegas Aldazosa Opening Remarks & Current International Tax Developments - Effects on International Tax Planning The international tax regime is in turmoil. This panel will address some of the most salient recent international tax developments and discuss their potential implications for the practice of tax law in the United States. It will discuss inter alia the OECD’s global minimum tax, the side-by-side agreement excepting U.S. corporations from some implications of Pillar Two, the recent U.S. tariffs, contemporary transfer pricing challenges, and Latin American tax developments.
10:30 - 11:30 am	Scott A. Bowman McDermott Will & Schulte Bernadette Carey Carey Olsen Patrick Harney Mishcon de Reya LLP Ricardo Leon Santacruz Garrigues *Cross-Border Collaboration* This panel will evaluate core comparisons in property, succession and tax law across common law and civil law traditions, and their impact on cross-border estate plans. In a fireside chat style format, our panelists will explore challenges and opportunities in working collaboratively across jurisdictions.
11:30 am - 12:00 pm	Get Lunch and Visit with Sponsors
12:00 - 1:00 pm	Prof. Cassady V. Brewer Georgia State University College of Law Prof. Bruce A. McGovern South Texas College of Law Houston *Recent Developments in Federal Income Taxation - Part 1* This session highlights important changes affecting taxpayers over the past twelve months, addressing significant court decisions, rulings, and statutory and regulatory developments.
1:00 - 1:30 pm	Visiting With Sponsors
1:30 - 2:30 pm	Prof. Cassady V. Brewer Georgia State University College of Law Prof. Bruce A. McGovern South Texas College of Law Houston *Recent Developments in Federal Income Taxation - Part 2* This session highlights important changes affecting taxpayers over the past twelve months, addressing significant court decisions, rulings, and statutory and regulatory developments.
2:35 - 3:35 pm	James B. Sowell KPMG LLP *Understanding and Drafting Partnership Allocation Provisions* This program is intended to promote an understanding of concepts necessary for the effective drafting of partnership allocation provisions. The differences between "safe harbor," waterfall and "target" allocations will be explained. Drafting allocation provisions that are valid and understandable for the relevant audience (i.e., investors, operators of the business, and accountants) will be a focus.
3:35 - 4:00 pm	Visiting With Sponsors
4:00 - 5:00 pm	Samuel A. Donaldson, JD, LL.M., AEP® (Distinguished) Georgia State University College of Law *Federal Wealth Transfer Tax Update* This session will recap important cases, rulings, regulations, and legislation from the past 12 months in the federal estate and gift tax laws.
5:00 - 6:00 pm	Welcome Reception
Thursday, April 9, 2026
8:00 - 8:45 am	Samuel C. Ullman Memorial Breakfast and Visit with Sponsors Sponsored by The Florida Bar Tax Law Section
8:45 am	Opening Remarks
8:50 - 9:50 am	Alexander L. Reid, JD, LL.M. BakerHostetler *No Good Deed Goes Unpunished: Charitable Giving, Chapter 42, and Traps for the UnWary* A family office has extra space and decides to rent it to the family's private foundation. The family patriarch buys an auction item at a charitable fundraiser and sends the bill to the foundation. The foundation holds a board meeting in Turks and Caicos and invites spouses, grandkids, and a few friends. It charters a plane to fly everyone, because it is more convenient than flying commercial. The CEO of the foundation has some expense reimbursements that are a few years old. Also, she wants a raise and a loan to help her with a downpayment on her new home. Fortunately, the family patriarch has some great investment opportunities for the foundation in the company he owns with his brother.
9:55 - 11:25 am	Judge John Antoon II United States District Court, Middle District of Florida Steven Gremminger The Gremminger Law Firm Benedict P. Kuehne Law Offices of Benedict P. Kuehne, P.A. A. Brian Phillips A. Brian Phillips, P.A. *It Is Dangerous To Be Right When the Government Is Wrong* Accusations of misconduct (especially baseless ones) by government personnel present unique challenges to tax practitioners. To deal with these situations requires a deft mix of skill, courage, and character. The panel will address the impact of these challenges from the practitioner and judicial perspectives.
11:25 am - 12:25 pm	Student Networking Luncheon and Visit with Sponsors Sponsored by A. Brian Phillips, P.A.
12:25 pm - 1:25 pm	Senator George S. LeMieux Gunster Gerardo Nout Bessemer Trust *2026 Macro Outlook & Florida Economic Trends* This presentation features a conversation between Gerard Nout and Senator LeMieux integrating Bessemer’s 2026 macro outlook with Florida’s evolving economic landscape. The discussion explores resilient growth, earnings expansion, policy trends, valuations, and private market momentum, and connects those themes to Florida’s population gains, income migration, corporate relocations, and expanding finance and technology ecosystem. Together, the conversation highlights how broader macroeconomic forces are increasingly concentrated in Florida, positioning the state as a structural beneficiary of sustained growth and long-term capital formation.
1:30 - 2:30 pm	Gregg D. Polsky, JD, LL.M. New York University School of Law *The Qualified Small Business Stock Exclusion* This presentation will discuss section 1202, which excludes from gross income certain gains from the sale of qualified small business stock. Besides describing the technical rules, including important changes in the 2025 tax legislation, the presentation will discuss planning opportunities and traps for the unwary.
2:30 - 3:00 pm	Visiting With Sponsors
3:00 - 4:00 pm	Claudia Ray, JD Kirkland & Ellis LLP *Generative AI: Ethical Pitfalls* The presentation will provide a brief overview of how generative AI works, provide examples of situations where counsel and others have been sanctioned or otherwise suffered negative consequences as a result of relying on gen AI in connection with their professional work, and discuss various ethics rules and standards that practitioners should bear in mind when using gen AI for client-related work. The presentation will also provide takeaways to help attendees manage the ethical and other risks posed by gen AI tools.
4:05 - 5:05 pm	Gregg D. Polsky, JD, LL.M. New York University School of Law *Taxable & Tax-Free Mergers and Acquisitions* This presentation will discuss the tax consequences of corporate mergers and acquisitions. It will cover taxable deals and tax-free reorganizations, as well as other common reorganization-like structures.
5:05 - 6:30 pm	Tax Masters Mingle Mingle, munch, and make new connections. Enjoy delicious bites and lively conversation as you hop from table to table—every 20 minutes, you’ll rotate to a new group of friendly faces and fresh perspectives. It’s a fun, fast-paced way to meet people and spark great ideas. Sponsored by Evercore Wealth Management and Evercore Trust Company
Friday, April 10, 2026
8:00 - 8:45 am	Breakfast with Sponsors
8:45 am	Opening Remarks
8:50 - 9:50 am	Tandilyn Cain University of Washington School of Law Stephanie Loomis-Price Perkins Coie LLP *Scary Stories of IRS Claims and Collection Powers* The IRS has significant power as a creditor against estates when federal taxes are owed. And executors, fiduciaries, and beneficiaries should understand their varying levels of potential liabilities. This session will explore relevant case law and provide practical advice to avoid pitfalls.
9:55 - 10:55 am	Paul S. Lee, JD, LL.M. (taxation) Consiglio Advisors *The Great Unknown: What Really Happens When Partners Die?* They say the only certainties in life are death and taxes. If that has always been true, then why do we know so little about what really happens when a partner dies? This presentation unveils the real truth about the “step-up” in basis when a partner dies and what’s left behind for the partnership and its partners. It will discuss planning opportunities before and after death, pitfalls to avoid, and unanswered questions, with a focus on “negative basis” and “negative capital” assets.
11:00 am - 12:00 pm	Benetta Y. Park, JD Bessemer Trust Matthew J. Scheer Gunster *Family Office Structuring: Overview of Different Models & Their Tax and Non-tax Considerations* What is a family office? What kind of family office does a client need? This program will provide an overview of various family office structures and the tax and non-tax considerations for each one. The presenters will provide a framework for advisors to use when helping clients determine the best option to achieve the family’s goals over time. When is a “Lender-style” profits interest structure appropriate for a family? When should a family consider a private trust company? How do these structures fit within a family’s other family enterprises, entities, and trusts? What role does family governance play? The presenters will answer commonly asked questions and address the important issues when advising ultra-high net worth families in structuring their family office.
12:00 - 12:45 pm	Get Lunch and Visit with Sponsors
12:45 - 1:45 pm	Brant J. Hellwig, JD, LL.M. (taxation) New York University School of Law *Tax Consequences of Termination of Grantor Trust Status* The presentation will examine the tax consequences when the grantor trust status of an irrevocable trust terminates, whether during the grantor's lifetime or by reason of the grantor's death. Specific topics to be covered include the prospect of realizing gain as a result of the deemed transfer occurring to the nongrantor trust, as well as the effect of the termination on the basis of the trust property.
1:50 - 2:50 pm	Lauren Y. Detzel, JD Dean Mead *Trust Modifications and Decantings* With the trend of Irrevocable Trusts being drafted to last for decades (even centuries), it is crucial to be able to modify those Trusts to account for changes in circumstances and laws. This presentation will look at the different ways to accomplish this and practical applications of those methods.
3:00 pm	Dennis Calfee's Birthday Party Come celebrate with us! Join fellow attendees in wishing Professor Calfee a very Happy Birthday — let’s make it a moment to remember! Sponsored by Cypress Row Advisors