63rd Annual Tax Conference

63rd Annual

William and Mary Tax Conference

November 8-10, 2017

Tax Planning in an Era of Uncertainty

Wednesday, November 8

William & Mary Law School

613 South Henry Street, Williamsburg, VA

(Free Parking – No parking passes required)

5:00-7:00 p.m.           

Fundamentals of Partnership Taxation

Speakers:  Robert G. McElroy and William M. Richardson

This program will focus on the fundamentals of partnership taxation and specific situations that unexpectedly accelerate or increase taxable income – often to a partner’s surprise, such as partnership formations (including "disguised sales"), sale and distribution of contributed property, allocations of partnership profits and losses, guaranteed payments, the creation and payment of partnership liabilities, sales and liquidations of partnership interests, distributions of partnership assets and terminations of partnerships.  Audience participation will be encouraged.

Thursday, November 9

Kingsmill Resort

Williamsburg, VA


8:00-8:20 a.m.

Registration and Continental Breakfast

8:20-8:30 a.m.

Introductory Remarks

Mark C. Van Deusen

8:30-10:00 a.m.

Deferred Compensation Arrangements for Closely Held Business:  Trouble Shooting and Problem Solving

Speakers:       Robert O. Johnson and Richard C. Mapp, III

Moderator:   John M. Peterson

10:00-10:15 a.m.

Networking Break

10:15-11:45 a.m.

Impact of Tax Reform on Partnerships/Recent Changes to Rules Governing Disguised Sale and Debt Allocations

Speaker:       Andrea M. Whiteway and Maximilian Pakaluk

Moderator:   Mark C. Van Deusen

This panel will discuss how tax reform may impact partnerships and recently issued final, temporary, and proposed regulations concerning partnership debt allocations and disguised sales, and proposed regulations under Section 704(b) related to when deficit restoration obligations are to be disregarded, exploring what planning opportunities remain after these changes.

11:45-11:55 a.m.

Networking Break

11:55 a.m.-1:00 p.m.

Lunch Session:  Virginia Hot Topics

Speakers:     Craig D. Bell and William L.S. Rowe

A panel-led discussion surveying recent cases, rulings, legislation and developments of interest in the area of Virginia taxation.

1:00-1:15 p.m.

Networking Break

1:15-2:45 p.m.

Discounting in the Estate Tax

Speakers:       Michael H. Barker and William I. Sanderson

2:45-3:00 p.m.

Networking Break

3:00-4:15 p.m.

Partnership Character Planning Before and After the Audit

Speakers:       Steven R. Schneider and Brian J. O’Connor

Moderator:   Mark C. Van Deusen

4:15-4:30 p.m.

Networking Break

4:30-6:00 p.m.

C&S Corporations/Tax Reform/Business Acquisitions

Speakers:     Lisa M. Zarlenga and Cameron Arterton

Moderator:   William M. Richardson

Friday, November 10

Kingsmill Resort

Williamsburg, VA


8:00-8:20 a.m.

Registration and Continental Breakfast

8:20-10:00 a.m.

Resolving Identity Theft Issues

Speakers:     T. Keith Fogg and Special Trial Judge Diana Leyden

Moderator:   Craig D. Bell

Since 2010 Identity Theft has been the single largest issue bringing taxpayers into the office of the taxpayer advocate.  This panel will discuss the types of identity theft, the impact and how to best resolve the issue with the IRS or with the Tax Court when your client suffers from this problem.  Although most identity theft involves individuals, the panel will also discuss business identity theft and strategies for resolving the theft of a business identity with the Court or with the IRS.

10:00-10:15 a.m.

Networking Break

10:15 a.m.-Noon

Tax Reform:  Technical Summary, with especially for tax individuals

Speaker:       Evan M. Migdail

12:00-12:15 p.m.

Networking Break

12:15-1:15 p.m.

Lunch Session:   Politics of Tax Reform

Speaker:       Evan M. Migdail

1:15-1:30 p.m.

Networking Break

1:30-3:00 p.m.

Dealer versus Investor/1031 Exchange

Speaker:     Robert D. Schachat

Moderator:   Stephen L. Owen

3:00-3:15 p.m.

Networking Break

3:15-4:45 p.m.

Federal Tax Update

Speaker:       Stephen L. Owen

This session will include a discussion of the “Top 15” current developments and tax planning opportunities.  The primary focus will be on transactions involving S corporations and limited liability companies.