William and Mary Law School

Tax Planning for Entrepreneurs (and Their Advisors) in 2015 and Beyond: The Good, The Bad and The Ugly

Wednesday, November 11, 2015
William & Mary Law School
613 South Henry Street

4:30-6:30 p.m.
Hot Topics in Partnership and Real Estate Taxation (and more)

Speakers: Robert G. McElroy, Stefan F. Tucker and Stephen L. Owen

Description: The focus of this program will be on fundamental tax issues involving partnerships and LLCs as well as on more advanced fact patterns. Real estate issues such as 1031 exchanges will also be discussed. A significant part of this session will be devoted to “Shop Talk” and the attendees will be encouraged to bring their real life issues for the group to discuss.

Thursday, November 12, 2015
Kingsmill Resort

8:00-8:20 a.m. - Registration and Coffee

8:20-8:35 a.m.
Introductory Remarks - Stephen L. Owen

8:35-10:05 a.m.
Planning Closely Held Business Succession

Speaker: Stefan F. Tucker

Description: This program will focus on a variety of tax (and non-tax) issues presented in planning the succession of a closely held business. Topics will include structuring a buy/sell agreement for a pass through entity, life insurance planning, using grantor trusts and other trusts to shift value, valuation discounting and Section 6166 estate tax deferral.

10:05-10:20 a.m. - Refreshment Break

10:20–11:50 a.m.
Employee Benefits in Acquisitions

Speaker: Paul M. Hamburger

Description: This program will address the special employee benefits issues presented in the M&A context including the Affordable Care Act, ESOPs and qualified and nonqualified plans. Due Diligence for buyers will also be discussed.

11:50 a.m.-12:00 p.m. - Refreshment Break

12:00-1:15 p.m.
Lunch Session – Virginia Hot Topics

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

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

1:15-1:30 p.m. - Refreshment Break

1:30-3:00 p.m.
Multi State Tax Planning
Speaker: French Slaughter

Description: This program will address the planning opportunity (and pitfalls) in the operation and sale of closely held businesses that do business in multiple states and/or that have nonresident equity owners. Topics will include nexus, apportionment, and non-resident withholding, with a view to minimizing state taxes.

3:00-3:15 p.m. - Refreshment Break

3:15-4:30 p.m.
Special Family and Lifestyle Tax Issues

Speakers: Helena S. Mock and Edith E. Weiss

Description: This program will focus on a variety of family planning and “lifestyle” tax issues, including an update on divorce taxation and special challenges presented by long-term care, disability and incapacity.

4:30-5:45 p.m.
Handling Partnership Basis Rules

Speaker: James B. Sowell

Friday, November 13, 2015

8:00-8:30 a.m. - Registration and Coffee

8:30-10:00 a.m.
Traps All Tax Practitioners Should Know and Avoid

Speakers: Christopher S. Rizek, Craig D. Bell (moderator)

Description: This panel will discuss recent cases, regulatory changes and other develop.m.ents dealing with the standards of practice for lawyers, accountants, enrolled agents and tax return preparers. Practitioners will learn about the traps and potential issues presented, including changes relating to tax opinions and tax return preparation.

10:00-10:15 a.m. Refreshment Break

10:15-11:45 p.m.
M&A Update

Speakers: Lisa M. Zarlenga and Andrew F. Gordon, William M. Richardson (moderator)


11:45 a.m.-Noon - Break

12:00 -1:00 p.m.
Lunch – The Administration’s Tax Reform Targets

Speakers: Lisa M. Zarlenga and Stephen L. Owen, William M. Richardson (moderator)

Description: This panel will discuss a variety of tax areas that are vulnerable to repeal or limitations as a result of any comprehensive tax reform plan. These topics will include 1031 exchanges, carried interests, self-employment tax, LIFO inventory, Buffett Rule, valuation discounting and carryover basis/gain on death.

1:00-2:15 p.m.
International Tax Planning For the U.S. Pass Through Entity

Speaker: Seth Green


2:15-3:30 p.m.

Dealing with Installment Sales 35 Years after the Installment Sales Revision ACt of 1980

Speakers:  Robert D. Schachat and Stephen L. Owen

Description:  This program will focus on a variety of issues including contingent payments, related party transactions, additional interest/imputed interest, acceleration events, non-recognition transactions.

3:30-3:45 p.m. - Refreshment Break

Federal Tax Update

Speaker: Stephen L. Owen

Description: A look at the most meaningful developments in recent tax law. Rather than reciting a litany of holdings and pronouncements, this session will focus on the key cases, rulings and administrative pronouncements and what their likely impact will be for both clients and tax practitioners.

5:00 p.m. - Adjourn