Earn up to 15.50 hours of MCLE credit, includes legal specialization
Thursday-Friday, March 14-15, 2019
University of San Francisco School of Law, LL.M. Tax Program
101 Howard St.
San Francisco, CA 94105
Register Online Here
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7:30 a.m. to 4:45 p.m.
7:30 a.m. to 8:30 a.m.
The tax court, government counsel, a private practitioner, and appraiser will discuss each of their views and perspectives on valuation and other disputed transfer tax issues. The panel will also cover recent litigation topics in appeals and tax court, such as defined value formulas, family entity issues, and what everyone should learn from the most recent valuation case decisions. Any updates on laws affecting valuation will be covered, as well as valuation pointers when appraising all types of assets.
Specialty Credit: Tax: Individual Income Tax; CA Taxes; Estate, Gift Tax and Estate Planning
Trust & Estates: Estate Planning; Estate and Gift Tax Preparation & Audit
8:30 a.m. to 10:30 a.m.
10:30 a.m. to 10:45 a.m.
Qualified Small Business Stock (QSBS) under Section 1202 is not just for tech companies anymore. It’s time to reconsider QSBS because the new tax act has paved the way for closely-held companies to benefit “bigly.” QSBS provides an exciting array of benefits (and a surprising alternative) for owners of new and pre-existing business (large and small): (i) 100% gain exclusion on sale; (ii) tax-free rollover of gains; and (3) a chance to “stack” (multiply) and “pack” the exclusion by 10 times (maybe more). While the benefits of QSBS are straightforward, the qualifications and questions surrounding QSBS planning are far from it. This presentation will discuss planning opportunities, unanswered questions, potential pitfalls, and best practices for estate planners in the quest for quantum QSBS exclusions.
Speaker: Paul Lee
10:45 a.m. to 12:15 p.m.
12:15 p.m. to 12:30 p.m.
The panel will address why directed trusts are more popular than ever and why they protect the trustee from liability. The panel will also address decanting trusts and why this is such a powerful tool. The panel will walk through the nuts and bolts of directed trusts and the notice requirements, IRS positions, federal, state and local tax consequences and safe harbor issues involved in decanting. The panel will not forget to mention where the pitfalls lie and how to avoid them in using both of these techniques.
12:30 p.m. to 1:45 p.m.
From an estate and income tax planning perspective, this session will discuss straightforward and innovative planning opportunities for families (and their businesses) that best take advantage of both the “expiring” and “permanent” provisions of the new tax act. These will make the planners life easier and allow an enhancement of value to everyone’s clients.
1:45 p.m. to 2:45 p.m.
2:45 p.m. to 3:00 p.m
Recent tax reform nearly doubled the standard deduction for individuals and families. While that simplifies the filing process for millions of Americans, it also complicates giving strategies for many who have made a habit of deducting their charitable contributions. Using actual client experiences, this presentation explores practical solutions and innovative ways to help donors evaluate their options and make good decisions about taxeffective giving. During the program, you’ll get an in-depth look at charitable IRA rollovers, legacy IRAs, lifetime CRATs, charitable gifts from trusts and estates, private foundation investment tax, donor advised fund distribution requirements, program related and SRI investments, and charitable LLCs.
Speaker: Justin T. Miller
3:00 p.m. to 4:00 p.m.
As with many large tax overhauls, sometimes lesser publicized changes also have a significant impact on taxpayers. With the 2017 tax act, some of these lesser publicized changes involve the income tax impact of divorce, which, in 2019 and beyond, will have far-reaching effects as a result of the elimination of alimony as an income/deduction item and the post-divorce continued grantor trust status of certain spousal trusts.
Speaker: George D. Karibjanian
4:00 p.m. to 5:00 p.m.
Rising and falling transfer tax exclusions, the wave of income tax changes, and an aging population, what is a transfer tax practitioner to do? This program will review the latest developments rocking the transfer tax boat. This review will include the most significant cases, rulings and other authority. The goal of this program is to help practitioners better identify and manage transfer tax issues in these stormy waters.
8:30 a.m. to 10:00 a.m.
10:00 a.m. to 10:15 a.m.
After a decade of offshore voluntary disclosures, increased exchanges of information among treaty partners, and substantial assessments of international tax penalties, the IRS expects tax professionals to be aware, to properly advise their clients, of their international tax and reporting obligations. It no longer is a matter of if, but when the government will discover a client’s foreign assets and income sources. This panel will discuss what every estate planner should know about international compliance, how to navigate the current enforcement landscape, and what to do with a client who wants to come in from the cold.
10:15 a.m. to 12:15 p.m.
The speaker will walk the audience through the hidden mine field when dealing with the rules of construction. What do we do when there is an ambiguous document or maybe it is simply void? Learn when extrinsic evidence can be introduced and used. But most importantly learn the to do’s and not to do’s.
Speaker: Tara M. Morris
12:30 p.m. to 1:30 p.m.
Dealing with foreign assets is never easy and invariably entails multiple issues and complexities. The panel consisting of a US and British practitioner will cover issues that every planner should be aware of and provide tools to better enable the practitioner to deal with foreign trusts and entities.
Speaker: Wayne Johnson
1:30 p.m. to 2:30 p.m.
In 1999, Jerry Kasner prepared an outline entitled “Community Property and Estate Planning,” which has been a critical resource for countless California attorneys. Using an updated version of Jerry’s piece, Andrea Kushner Ross will review notable developments in California community property law since Jerry prepared his outline. The presentation will have a specific emphasis on community property issues affecting estate planning practice and what every practitioner should know.
Speaker: Andrea L. Kushner
2:30 p.m. to 3:30 p.m.
3:30 p.m. to 3:45 p.m.
The panel, including a prior IRS branch chief, will address current estate and gift tax audit issues including how technology has improved coordination between the income and gift/estate tax divisions requiring the planning to be correct from all tax angles. The discussion will also include a discussion of ruling requests and 9100 relief, when and how to use these, including the nuts and bolts of preparation and procedural tips as well as other options.
3:45 p.m. to 5:00 p.m.
**Onsite registration for section members $375 and non-section members $495
A printable brochure is available for your convenience.
Register online by clicking here.
Print the registration form and mail to:
California Lawyers Association
400 Capitol Mall Way, Suite 650
Sacramento, CA 95814
On-site registration will be on a space available basis. Call to confirm space availability.
Early-bird pre-registration ends March 7, 2019.
Cancellations and requests for refunds must be received in writing no later than Thursday, March 7, 2019 and are subject to a $50 service charge. Refunds will not be available after March 7, 2019.
For special assistance please call (916) 516-1757.
For registration information please call (916) 516-1757. For information regarding the program please call (916) 516-1754.
This event may be recorded. By attending this event, you consent to be photographed, filmed, and/or otherwise recorded, and to any use, by the CLA, of your likeness, voice, and name in any and all media including social media. If you do not want your name or photo to be used, please let us know in advance. We cannot, however, honor requests to opt out of the use of your image or voice if you choose to ask a question during one of the event sessions.