University of Florida Tax Institute   Florida Tax Institute  
    February 28 - March 2, 2018, Tampa, Florida — Tampa Marriott Waterside    
  UF UF UF  

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Conference Agenda

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Speakers and Draft Topics

The speakers and topics for the 2018 Florida Tax Institute will be announced soon. For an idea of what to expect, view the 2017 Florida Tax Institute agenda below.

Wednesday, March 29, 2017

7:00 - 8:15am Breakfast
8:15 - 8:30am Welcome and Opening Remarks
8:30 - 10:30am Prof. Martin J. McMahon
University of Florida Levin College of Law
Prof. Bruce A. McGovern
South Texas College of Law
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 Charles J. Lavelle
Bingham Greenebaum Doll LLP
Captive Insurance for Small Businesses
This session discusses the tax requirements, and recent statutory, regulatory and court developments affecting small captive insurance companies electing section 831(b), including the PATH Act and the IRS naming most of them as "Transactions of Interest."
11:45am - 1:15pm Luncheon Speaker: Nina Olson
Taxpayer Advocate Services
Current Issues in Tax Administration
1:15 - 2:15pm Summer Ayers LePree
Bilzin Sumberg
Prof. Lawrence Lokken
University of Florida Levin College of Law
From Treasury with Love: The Use of Tax Treaties in Inbound Tax Planning
This session will examine US income tax treaties, their basic structure and operation (including residency and limitation of benefits), and how to best utilize treaties in inbound US income tax planning.
2:15 - 3:00pm Break with Exhibitors
3:00 - 4:00pm Ronald A. Levitt
Sirote & Permutt, PC
Hot Topics for S Corporations
With S Corporations retaining its spot as a highly used type of business entity, especially in the closely-held and family owned business arenas, attendees will learn about recent developments in the Tax law that impacts S corporations and their shareholders and how compensation issues and planning for SE Tax and (at least for now) the 3.8% Net Investment Income Tax (the so-called Medicare Tax) are still relevant.
4:00 - 5:00pm James B. Sowell
SECA or Employment Taxes for Partners: The World is Changing
This session will involve a discussion of the potential treatment of partners as employees and the application of the self-employment tax to a partner's share of partnership income. After many years of quiet regarding guidance on both issues, the dam seems to have broken. Recent case law as well as recent and projected administrative guidance are changing the way these issues must be considered.
5:00 - 7:00pm Welcome Reception
Open to All Conference Attendees

Thursday, March 30, 2017

7:00 - 8:15 am Breakfast with Exhibitors
8:15 - 8:30am Opening Remarks
8:30 - 9:30am Gregg Polsky
University of Georgia School of Law
Equity Based Compensation
This session will discuss the taxation of equity compensation instruments, including stock options, restricted stock, phantom stock, stock appreciation rights, and partnership profits interests.
9:30 - 10:30am Robert Keatinge
Holland & Hart LLP
Adjusting to the New Partnership Representative and Partnership and Deficiency Rules
This session will review the evolving partnership audit rules that for most partnerships will take effect in 2018 and will discuss alternatives that partnerships may consider now in anticipation of the new rules.
10:30 - 10:45am Break with Exhibitors
10:45 - 11:45am C. Wells Hall, III
Nelson Mullin
Tax Issues Arising in Connection with Dividends and Redemptions by Closely Held Corporations
A discussion of the basic operation of the dividend provisions of section 301 and when section 302 results in sale or exchange treatment in redemption transactions, including potential traps and opportunities, as well as opportunities, including the operation of the attribution rules and constructive dividend issues.
11:45am - 1:15pm Luncheon Speaker: George Yin
University of Virginia
Evolution of the Tax Legislative Process
1:15 - 2:30pm Prof. Samuel A. Donaldson
Georgia State University College of Law
Current Developments in the Transfer Tax Arena
This informative and entertaining session will recap discuss 2017 Tax Reform and the important federal income, estate, gift tax cases, rulings, regulations, and legislation from the past 12 months of interest to estate planning practitioners and advisors to individuals with a high net worth.
2:30 - 3:00pm Break with Exhibitors
3:00 - 4:00pm Lauren Y. Detzel
Dean Mead
Bruce Stone
Goldman Felcoski & Stone
Ethical Challenges in Representing Multiple Parties: Case Studies and Suggested Solutions
Representing multiple family members and their many related entities can present advisers with a quagmire of ethical problems. Using case studies, the speakers will explore these challenges and suggest approaches to minimize liability and ethical conflicts.
4:00 - 5:00pm Cristin C. Keane
Carlton Fields PA
Jason E. Havens
Holland & Knight
Charitable Gifting of Business Interests
Charitable giving of business interests can be a powerful planning tool for the philanthropically inclined. This presentation will focus on the opportunities and pitfalls that exist for donating various types of business entity interests, including S corporations and LLCs, to charities.
5:30 - 8:00pm Cocktails and Dinner Honoring Mike Friel
We are thrilled to honor, celebrate, and thank Prof. Mike Friel for his many years of service as Dean of the UF Graduate Tax Program and for all that he did to make our lives better. Please join our celebration of Mike and his tenure with the UF Graduate Tax Program.
(This is an optional event. A ticket is required, and can be purchased via the online registration form.)

Friday, March 31, 2017

7:00 - 8:15am Breakfast with Exhibitors
8:15 - 8:30am Opening Remarks
8:30 - 9:30am Robert Keebler
Keebler & Associates
Retirement Plan Beneficiary Disasters – How to Avoid & Fix Them
Presentation will discuss options to avoid common mistakes in establishing/funding/managing a qualified retirement plan.
9:30 - 10:30am Ronald D. Aucutt
McGuire Woods LLP
Stephanie Loomis-Price

Did Proposed 2704(b) Regulations get Trumped?
A look at the proposed regulations released in August 2016, including their history, authority, public reaction, likely future, apparent scope, and effect on planning.

10:30 - 10:45am Break with Exhibitors
10:45 - 11:45am Paul Lee
Northern Trust
Putting It On & Taking It Off: Tax Basis Management in the New Paradigm
Under the current law (and even more so, if any of the "tax reform" proposals come to pass), the management of tax basis is the most important issue in planning for high net worth clients, during lifetime and at death. This presentation will discuss the top tax basis management techniques to consider today and in the future.
11:45am - 1:15pm Luncheon Speaker: Ronald D. Aucutt
McGuire Woods LLP
Capital Report
Proposed section 2704 regulations released by the IRS on August 2, 2016, quickly became very controversial. What is the current thinking about the scope, effect, prospects, and timing of those proposed regulations? What did we learn from the IRS public hearing on December 1, 2016? What will be the likely planning implications and recommendations after the regulations are finalized, and while we wait for them? (If the proposed regulations are withdrawn or blocked by legislation or Trump Administration executive action, the panelists will discuss the general lessons to be learned for addressing valuation issues in the future.)
1:15 - 2:15pm Barry Nelson
Nelson & Nelson PA
Integrating Estate Planning and Asset Protection Planning
Estate planning and asset protection techniques should be integrated to minimize estate taxes and maximize protection of assets. This presentation will discuss the use of inter vivos QTIP trusts, state exemptions, tenants by the entirety, partnerships, domestic asset protection trusts and other third party trusts; as well as the benefits and drawbacks of using common asset protection techniques in order to maintain estate tax savings.
2:15 - 2:30pm Break
2:30 - 3:30pm John Porter
Baker Botts LLP
Current Issues in Estate and Gift Tax Audits and Litigation
This presentation will address a number of current audit and litigation issues from the perspective of a seasoned litigator who deals with the IRS on a daily basis. The discussion will include issues related to the transfer of hard to value assets, formula clauses, GRATs, promissory notes, tax return preparation issues, and the avoidance of penalties.
3:30 - 4:30pm David Pratt
Estate Planning in a Low Interest Rate Environment
We have been planning in a low interest rate environment for quite some time but it appears that, amongst other things, interest rates will rise with the new administration. Because some estate planning techniques are more effective than others when interest rates are low, it is important for planners to be aware of how changes in interests rates affect the techniques they propose to clients. From GRATs to CLATs, to SCIN's to Private Annuities, this presentation will explore which techniques are the most effective in a low interest rate environment, as well as how to modify existing plans to take advantage of lower interest rates.
4:30pm Closing Remarks