OCTOBER 21-25, 2019 - Sfti

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The Southern Federal Tax Institute continues its proud tradition of excellence in continuing education by offering its annual Institute.This program provides the most in -depth coverage of recent developments and cutting-edge topics in tax and estate planning.The 2019 Institute will be held in Atlanta’s thriving and exciting Buckhead district at the elegant and luxurious Grand Hyatt Atlanta.Take advantage of this excellent opportunity to learn and network with your colleagues and associates.BOARD OF TRUSTEESOF F ICE RSBOARDCHAIRMAN OF THE BOARDChristopher J.C. JonesMoore & Van Allen PLLCCharlotte, North CarolinaFarhad AghdamiWilliams MullenRichmond, VirginiaPRESIDENTKimberly H. StognerWomble Bond Dickinson LLPWinston-Salem, North CarolinaVICE PRESIDENTR. David WheatKirkland & Ellis LLPHouston, TexasTiffany A. AltizerKeith Altizer & Co. P.A.Maitland, FloridaDavid D. AughtryChamberlain, Hrdlicka, White,Williams & AughtryAtlanta, GeorgiaReginald J. ClarkEversheds Sutherland (US) LLPAtlanta, GeorgiaSECRETARYJames B. SowellKPMG LLPWashington, DCCameron N. CosbyFried, Frank, Harris,Shriver & Jacobson LLPWashington, DCTREASURERMartha Louise R. LewisRamage Lewis LLCGreenville, South CarolinaJeffery S. DrummondsLBMC, PCBrentwood, TennesseeSPECIAL ADVISOR TO THE BOARDProfessor Cass BrewerGeorgia State UniversityCollege of LawAtlanta, GeorgiaPeter J. GenzKing & Spalding, Retired PartnerAtlanta, GeorgiaMichael A. LaingTaft Stettinius & Hollister LLPCincinnati, OhioZack LederBennett Thrasher LLPAtlanta, GeorgiaFrank S. MacgillHunterMacleanSavannah, Georgia2Pamela F. OlsonPricewaterhouseCoopers LLPWashington, DCAlan F. Rothschild, Jr.Page, Scrantom, Sprouse,Tucker & Ford, P.C.Columbus, GeorgiaDavid C. Sojourner, Jr.Sojourner Caughman & Thomas, LLCColumbia, South CarolinaADVISORYJean Taylor CoxDurham, North CarolinaGeorge S. BaileyColumbia, South CarolinaScott Y. BarnesCharleston, South CarolinaHerschel M. BloomAtlanta, GeorgiaWilliam M. Blume, Jr.Mount Pleasant, South CarolinaThomas A. CaldwellSignal Mountain, TennesseeThomas N. Carruthers, Jr.Birmingham, AlabamaMark S. DrayRichmond, VirginiaH. Mitchell Dunn, Jr.Savannah, GeorgiaCharles H. EgertonOrlando, FloridaRichard E. FoggFree Union, VirginiaWilliam C. FowlerAtlanta, GeorgiaStephen F. GertzmanWashington, DCLawrence B. GibbsWashington, DCJames C. GoochNashville, TennesseeHarry V. Lamon, Jr.Atlanta, GeorgiaLauch M. Magruder, Jr.Highlands, North CarolinaNeill G. McBrydeCharlotte, North CarolinaMark J. SilvermanWashington, DCKenneth L. ThrasherAtlanta, GeorgiaJ. Kenneth TomlinsonColumbia, South CarolinaRobert C. WalthallBirmingham, AlabamaJoyce A. WaterburyCarrboro, North CarolinaEXECUTIVE DIRECTORMallory L. DeckerDecatur, Georgia

PRESIDENT’S LETTERDear Colleagues,I, along with the other Trustees of the Southern Federal Tax Institute (“SFTI”), invite you to join us this yearat the Grand Hyatt in Buckhead, Atlanta, Georgia for the 54th Annual Institute. SFTI assembles the finestspeakers in the country to present timely topics that explore fundamental tax principles in depth. We haveplanned an excellent program scheduled for October 21st through October 25th .Our program includes 29 topics presented over five days by leading tax and estate planning practitioners.The five-day conference is offered in four flexible registration packages: the full five-day package, the initialthree-day package (which includes both the income tax and ethics sessions), the final three-day package(which includes the estate planning and ethics sessions), and the two-day package (which includes theestate planning sessions only). There is a 50% discount offered this year to first-time attendees.This year’s Institute focuses on examining in depth the practical planning opportunities that are availableto our clients as a result of the Tax Cuts and Jobs Act (“TCJA”) and other recent developments. Monday’spresentations will begin with a substantive review of federal income tax developments. That afternoon,the speakers will address the important aspects of Section 199A and “qualified business income”; SALTworkarounds and Qualified Opportunity Zones. Tuesday’s morning program focuses on tax issues for realestate and partnerships, including interest deduction limitations and redemptions of partnership interests.The afternoon presentations will address corporate tax planning opportunities. On Wednesday, we willconsider how the TCJA has effected fringe benefits and tax accounting, and we also will examine tax issuesrelating to Bitcoin and other digital assets. The afternoon program offers several interesting presentationsrelated to audits and tax controversy. Thursday and Friday are focused on estate planning topics, includingbasis issues and planning in uncertain times after TCJA. The Institute will end early Friday afternoonfeaturing Professor Sam Donaldson covering recent estate and gift planning developments.A vital part of the Institute is the networking opportunities it provides. Please join us at our receptionson Monday, Wednesday and Thursday evenings. The cocktail parties are a wonderful venue for renewingfriendships with colleagues and connecting with the region’s leading tax practitioners. We also encourageyou to introduce yourself to our sponsors. Their generous support enables us to produce this top notchInstitute at exceptional value.We look forward to seeing you at the 54th Annual Southern Federal Tax Institute.Kimberly H. StognerPresidentSouthern Federal Tax Institute3

WHAT’S NEW IN THEINCOME TAX WORLD?SUNDAY EVENING, OCTOBER 20, 20195:30-8:00Registration BeginsMONDAY MORNING, OCTOBER 21, 2019Christopher J.C. Jones, Presiding7:15Registration Desk Opens8:00-9:00Breakfast9:00-10:30RECENT FEDERAL INCOME TAX DEVELOPMENTS – This session highlights significant changes affecting taxpayers over the past twelve months, including court decisions,rulings, and statutory and regulatory developments.Bruce A. McGovern, Professor of Law and Director – Tax Clinic, South Texas College of Law, Houston, TXCassady V. “Cass” Brewer, Associate Professor of Law – Georgia State University College of Law, Atlanta, GA10:30-10:45 Break10:45-12:00 RECENT FEDERAL INCOME TAX DEVELOPMENTS (CONT’D)12:15-1:05Mid-Day Program: HOW TO SUCCEED IN TAX PRACTICE – AND AVOID LIVING IN A VAN DOWN BY THE RIVER – Over the course of a year, Pete Genz conductedscores of interviews and studied the difference between success and failure in tax practice. With Ken providing a CPA perspective and David providing a litigation perspective,this panel will focus upon the practical, detailed strategies for tax practitioners of all ages in dealing with strengths and weaknesses, opportunities and challenges,victories and mistakes, and the always urgent client needs. Sponsored by Chamberlain, Hrdlicka, White Williams & Aughtry and presented by Peter J. Genz,Kenneth L. Thrasher and David D. AughtryMONDAY AFTERNOON, OCTOBER 21, 2019Peter J. Genz, Presiding1:15-2:45SECTION 199A AND PRACTICAL IMPLICATIONS – A key component of the Tax Cuts and Jobs Act of 2017 (“TCJA”) was Section 199A which provided a new 20%deduction for “qualified business income.” Last year, we and our clients had more questions than answers about the new law. Now, almost two years after tax reform, what havewe learned about Section 199A, the practical implications, and the planning opportunities? Do we still have more questions than answers after the guidance issued thus far? Thispanel addresses the most important aspects of Section 199A and “qualified business income.”Todd D. Golub, Principal – Ernst & Young LLP, Chicago, ILLynn T. Kawaminami, Partner – Deloitte Tax LLP, Atlanta, GA2:45-4:00INTENDED AND UNINTENDED FEDERAL INCOME TAX CONSEQUENCES OF SALT “WORKAROUNDS” – This presentation highlights the complexities surroundingstate and local tax and small business “workarounds” to the 10,000 limit on the deduction for personal state and local taxes. Our speaker also explores the increasingly complexinterplay between SALT incentives and credits and federal income taxation.Christopher Benner, Partner – Bennett Thrasher, LLP, Atlanta, GA4:00-4:15Break4:15-5:30THE WIZARDS OF “QOZ”! QUALIFIED OPPORTUNITY ZONES – Another key component of TCJA was new Sections 1400Z-1 and -2, “Qualified Opportunity Zones.”Intended to spur investment in low-income communities, Sections 1400Z-1 and -2 can defer and in some circumstances eliminate capital gains. Proposed regulations issuedin April would substantially broaden the availability of this significant benefit. Our expert panel explores the numerous planning “opportunities” as well as pitfalls surroundingQualified Opportunity Zone investments.Lisa M. Starczewski, Shareholder – Buchanan Ingersol & Rooney PC, Washington, D.C.Robert Cassanos, Partner – Fried, Frank, Harris, Shriver & Jacobson LLP, New York, NY5:30-7:00Cocktail Party4

BUSINESS TAXATIONTUESDAY MORNING, OCTOBER 22, 2019James B. Sowell, Presiding7:00-8:00Breakfast8:00-9:15IMPORTANT TAX DEVELOPMENTS AFFECTING PARTNERSHIPS AND REAL ESTATE, INCLUDING BONUS DEPRECIATION, LOSS LIMITATIONS, ANDCARRIED INTERESTS – This presentation explores crucial TCJA and more recent developments affecting partnerships and real estate. Topics include Section 168(k) 100%bonus depreciation and its impact on partnership allocations (including book-tax disparities) and distributions, the new limitation on “excess business losses” under Section461(l), new limitations under Section 1031, and the new holding period rule for carried interests under Section 1061.Julie Sassenrath, Shareholder – Winstead PC, Dallas, TX9:15-10:30EXITING A PARTNERSHIP – This back-to-basics presentation explores common issues encountered upon exiting a partnership. Our speaker highlights the differencesbetween sale and redemption transactions. Planning opportunities, including installment sales and leveraged distributions, also are considered.John J. Rooney, Director – Washington National Tax Office, KPMG LLP, Washington, D.C.10:30-10:45 Break10:45-12:00 LET’S GET PRACTICAL WITH THE INTEREST DEDUCTION LIMITATION UNDER SECTION 163(J) – Perhaps one of the most annoying and burdensome new rulesimposed by TCJA is Section 163(j)’s limitation on deductions for business interest. Although not a concern for non-tax-shelter businesses with 25 million or less of averageannual gross receipts, the new provision is proving to be a nightmare for those advising larger businesses with significant debt. Our expert conveys practical tips and planningtools that you can use to make complying with Section 163(j) (or qualifying for exemption) as painless as possible for you and your clients.Brian Knudson, Partner and Principal – Ernst & Young LLP, Minneapolis, MN12:15-1:05Mid-Day Program: CAPITALIZING ON OPPORTUNITY ZONES – This timely and informative session focuses on the federal Opportunity Zones (OZs) program. OZshave received tremendous attention and press but a host of questions remain. What are the benefits of OZs? How can I defer capital gains with an OZ? What are my options toparticipate in OZs by either creating my own fund, or investing in a larger fund? Sponsors Ricky Novak, Co-Managing Partner of The Strategic Group, and Craig Mason,Partner of RSM US LLP will offer their insights and observations on these and other questions.TUESDAY AFTERNOON, OCTOBER 22, 2019Reginald J. Clark, Presiding1:15-2:15KEY TAX DEVELOPMENTS AND PLANNING OPPORTUNITIES FOR C AND S CORPORATIONS – TCJA drastically lowered the rate on C corporations to a flat21%, but S corporations still offer flow-through tax treatment with the added potential for a Section 199A deduction. This presentation examines how these and other recentdevelopments create tax planning opportunities for your corporate clients.David Strong, Partner – Morrison Foerster LLP, Denver, CO2:15-3:15THE ALPHABET SOUP OF “ACE,” “PHCS,” AND “PSCS”: ACCUMULATED EARNINGS TAX, PERSONAL HOLDING COMPANIES, AND PERSONAL SERVICECORPORATIONS – Do you know your way around Subchapter G (Sections 531-547)? How about Section 269A? For our C corporation clients, what’s old is new again dueto the unique rules concerning accumulated earnings tax, personal holding companies, and personal service corporations. This presentation refamiliarizes us with longstandingrules that have new relevance for C corporations today.C. Wells Hall, III, Partner – Nelson Mullins Riley & Scarborough, LLP, Charlotte, NC3:15-3:30Break3:30-4:30BUYING AND SELLING S CORPS AFTER TCJA – TCJA changed certain key dynamics in M&A, such as the dramatic change in the corporate tax rate, the availability of100% bonus depreciation, and the impact of new NOL rules. More subtle changes, such as the new limit on deducting business interest, also impact how corporate acquisitionsare structured. And yet, many rules remain the same. Our speaker reviews what’s changed and what hasn’t in planning M&A deals involving S corporations.Aaron P. Nocjar, Partner – Steptoe & Johnson LLP, Washington, D.C.4:30-5:30PRACTICAL WORKSHOP AND INSIGHTS RELATING TO MONDAY AND TUESDAY SESSIONS – We heard you! Responding to attendee feedback, this panel ofknowledgeable SFTI Trustees will use real-life examples to highlight the important lessons and practical takeaways discussed over the past two days.Cameron N. Cosby, Partner – Fried, Frank, Harris, Shriver & Jacobson LLP, Washington, D.C.Peter J. Genz, Retired Partner – King & Spalding LLP, Atlanta, GAJames B. Sowell, Partner – KPMG LLP, Washington, D.C.R. David Wheat, Partner – Kirkland & Ellis LLP, Dallas, TX5

ACCOUNTING, ERISA, ETHICS, ET CETERAWEDNESDAY MORNING, OCTOBER 23, 2019Tiffany A. Altizer, Presiding7:30-8:30Breakfast8:30-9:45TRAINS, PLA