2023 TAX ANNUAL MEETING

MCLE: 1.0 Hour Taxation, Estate Planning Credit

Two of the panelists, Anna Soliman and Nicholas Hulwi started their legal careers as Estate and Gift Tax Attorneys for the Internal Revenue Service SB/SE Division. With their experience, they will provide insight on estate and gift tax audits and will walk you through the different phases of the audit process. Their presentation will focus on: Understanding how estate and gift tax returns are processed and classified; What to expect from an estate and gift tax audit; Tips on what the IRS looks for regarding specific audit issues; and Post-audit next steps.

Speakers:

• David Oh-David
• Nicholas Hulwi
• Anna Soliman

MCLE: 1.25 Hour Taxation; Estate Planning Credit

MCLE: 1.0 Hour Taxation Credit

Join this panel in a review of this year’s legislation and other pertinent issues related to legislation.  Panelists will also address pending and anticipated Federal legislative proposals and IRS guidance.

Speakers:

• Lisa Sperow
• Charles Hall
• Chad Nardiello
• Stuart Simon

MCLE: 1.0 Hour Taxation Credit

What is local sales and use tax law? Join this panel to learn about California’s Bradley-Burns Uniform Local Sales and Use Tax Law, Proposition 1A, and how the law is administered in this state. The panelists will also address important updates in the local sales and use tax arena, developments in local government taxes, such as the Cultiva la Salud v. State of California case, and provide insight into burgeoning topics in the field.

Speakers:

• Scott Claremon, CDTFA
• Troy Van Dongen, McDermott
• Nikki Dobay

MCLE: 1.0 Hour Taxation; Estate Planning Credit

The panel will discuss the  numerous tax elections in estate and trust administration. You already may have heard about the marital deduction, alternate valuation, and section 6166. Those are all too common for this program. Here we will discuss some of the important—and even obscure—elections that you might not see on a regular basis. Join us on a journey through the depths of the Internal Revenue Code and the Treasury Regulations as we explore tips and traps for fiduciary income and estate tax elections John Prokey, Partner – Ramsbacher Prokey Leonard Justin Miller, Partner – Evercore Wealth Management.

Speakers:

• John Prokey
• Justin Miller

MCLE: 1.0 Hour Taxation Credit

This panel will first discuss the Boechler v. Commissioner Supreme Court case in which the Supreme Court held that the Collection Due Process filing date was not jurisdictional, and thus subject to equitable tolling, then discuss subsequent cases in which petitioners seek to apply equitable tolling to other areas of the tax code.

Speakers:

• Michael Desmond
• John Colvin
• Judge Copeland

MCLE: 1.0 Hour Taxation Credit

This panel will focus on the interplay between the California personal income tax law and the tax law for entities in the context of sourcing income—namely, income from derived from an ownership interest in a passthrough entity or the sale of that ownership interest. While complex questions have always surrounded this topic, new life was breathed into the issue for California tax practitioners when the Office of Tax Appeals published its Metropolous decision in 2019. Specific items discussed in this panel will include new developments in the case law (both of California and other states), the apportionment rules for flowthrough entities, and considerations from other areas of tax law such as unity and business vs. non-business income.

Speakers:

• Ellen Swain, FTB
• Christopher Campbell, Deloitte
• Justin Hepworth, Sheppard Mullin
• John Ormonde, Eversheds
• Jeff Phang

MCLE: 1 Hour Taxation; Estate Planning Credit

An analysis of the obstacles and available alternatives in passing ownership of a family business on to the next generation when the senior family member desires to treat all the children equally, but some of the children will not take an active role in running the family business or key employees are needed to assist in management. The speaker will discuss planning ideas such as selling a business to key employees without reporting any gain using the preferred partnership structure or using a private annuity for a healthy individual to pass the family business on to the next generation without any estate tax exposure

Speaker:

• Cameron Hess

MCLE: 1.0 Hour Taxation

What better way to learn what is going on with the Tax Court than from the Tax Court itself. This panel of esteemed United States Tax Court judges will discuss new developments, hot topics and provide practitioner tips. Whether you are a Tax Court novice or a frequent flier, this panel is a must!

Speakers:

• Judge Holmes
• Judge Copeland

MCLE: 1.0 Hour Taxation

This panel brings together well-known speakers from the Franchise Tax Board, California Department of Tax and Fee Administration, and private practice to discuss a candid overview of the important developments of SALT litigation on a national and state level. The panel covers both key cases in California tax litigation and cases outside of the state that should be on your radar.

Speakers:

• Ray Rouse, FTB
• Marty Dakessian, Dakessian Law Ltd.
• Robert Merten, Pillsbury
• Nicole Johnson, Blank Rome
• Scott Chavez, CDTFA
• Roger Royse

MCLE: 1.5 Hour Taxation; Estate Planning Credit

Many challenges that clients face involve problematic asset assessments, Estate planners must ensure asset valuations are complete and use federally accepted methods. They further require qualified and credible appraisers to complete the assessments and appraisals for unique assets. This, the panel who are seasoned in asset valuation will discuss how to avoid many problems.

Speakers:

• Sid Luckenbach
• John Prokey

MCLE: 1.5 Hour Taxation Credit

The panelists will discuss recent developments in the world of international tax, including new Foreign Tax Credit regulations and guidance, the Supreme Court in Bitner, Subpart F developments and more.

Speakers:

• Patrick Martin
• Daniel Silva

MCLE: 1.5 Hour Taxation Credit

This panel will discuss California’s alternative apportionment rules with a focus on the Substantial and Occasional Sale rule (18 CCR section 25137(c)(1)(A)). The discussion will include an overview of California’s alternative apportionment system – including the CCR section 25137 regulations providing special apportionment formulas for certain situations (e.g., a substantial and occasional sale) and the Taxpayers or FTB’s ability to request alternative apportionment when warranted in specific instances. Panelists can also discuss FTB’s proposed 25137 regulations for alternative apportionment petition procedures, recent Office of Tax Appeals decisions on 25137 issues, and compare/contrast how other states implement their Substantial and Occasional Sale rules.

Speakers:

• Brian Beck, FTB
• Saba Shatara, Deloitte
• Shail Shah, Greenberg Traurig 
• Jeff Vesely, Pillsbury

MCLE: 1.00 Hour Taxation; Estate Planning Credit

The speakers will provide a general overview of the GST tax. This will include a discussion of some complex issues that will assist planners when dealing with these issues. They will also cover available planning options that will assist any practitioner.

Speaker:

• Michael Gerson

MCLE: 1.25 Hour Taxation Credit

Starting January 1, 2024, corporations, LLCs, and other business entities must file certain information with the Financial Crimes Enforcement Network (FinCEN) to comply with the Corporate Transparency Act. This panel will discuss the requirements and provide best practices.

Speakers:

• Robert Russell
• Michael Villa
• Arthur Moore
• Charles Hall

MCLE: 1.25 Hour Taxation Credit

Questions regarding the tax treatment of cryptocurrency and digital assets have created uncertainty for tax practitioners. A growing body of guidance on cryptocurrency from the IRS and other tax authorities has begun to point towards answers and offer a clearer picture for practitioners about how to best advise their clients. This panel will discuss the tax treatment of cryptocurrency and other digital assets at the federal level, what implications may arise for state practitioners therefrom, and examine other developments in this area of tax law at the state and local levels.

Speaker:

• Elle Kaiser, McDermott

MCLE: 1.25 Hours Taxation; Taxation; Estate Planning, Trust and Probate Law

The speakers will discuss various issues that arise with entities and real estate that practitioners need to be aware of. This will include a discussion on QSST/ESBT, ESOP’s, redemptions to pay estate tax, OZ’s, 1031’s and other issues not seen every day.

Speakers:

• Minna Yang
• Belan Wagner

MCLE: 1.25 Hour Taxation Credit

This panel will discuss the new trend of American companies settling manufacturing facilities in Mexico, and steering way from China. The panelist will discuss key international tax issues from both sides of the border, including choice of entity, GILTI considerations, Mexican VAT and more.

Speaker:

• Professor Rafael Fernández de Castro

MCLE: 1.25 Hour Taxation Credit

Join this panel in a review of this year’s legislation and other pertinent issues related to legislation. Panelists will also address pending and anticipated California legislative proposals and other states’ legislative policy differences.

Speakers:

• Denis Armstrong, FTB
• David Ruff, Assembly Committee on Rev and Tax
• Colin Grinell, Senate Governance and Finance Committee
• Michele Linton, CDTFA

MCLE: 1.25 Hour Taxation; Estate Planning Credit

As a result of the changes that were made permanent under ATRA, and in light of the recent statistic that only .02% of taxpayers will pay estate taxes, income taxes have become a greater focus in recent years. The speaker will examine income tax basis rules (including section 1014(e)), explore basis adjustment mechanisms, the benefits of using grantor trusts (and some of the open income tax basis adjustment issues, including issues with “swap powers”), and the basis consistency and reporting requirements. In addition, the Speaker will discuss California’s recent legislative attempt to end incomplete gift non-grantor trusts (NINGs, DINGS, WINGS, etc.), the Internal Revenue Service’s increased focus on stomping out what it views as abusive tax planning techniques, and the potential ramifications of Charles G. Moore v. United States, a case the Supreme Court granted certiorari for next year. Moore v. United States focuses on whether the United States’ direct taxation of “unrealized gains” and has the potential to eliminate Federal Taxes on expatriation, repatriation, GILTI, estates, gifts, and more.

Speakers:

• Jeb Burton

MCLE: 1.25 Hour Taxation Credit

An overview of the federal Employee Retention Credits, plus a primer on audits and other issues related to these credits.

Speakers:

• Michele Weiss
• Laurie Downs
• Sally Reddy

MCLE: 1.25 Hour Taxation Credit

This panel will focus on the seemingly ever-increasing gap between the federal and California tax regimes. The panel will touch on topics such changes stemming from the new IRC § 174, and the impacts of California only election, debt cancellation/forgiveness, and more.

Speakers:

• Erin Dendorfer, FTB
• Josh Grossman, Grant Thorton
• Mike Shaikh, Armanino
• Geoffrey Way, KPMG

MCLE: 1.0 Hour Taxation; Estate Planning Credit

So many practitioners simply put QDOT provisions into their trust, but we want to ensure unitrust treatment, for flexibility and to allow the allocation of gains to “income” since capital gains are taxed at 40 percent otherwise. While those concepts are not “new”, it’s important to understand what gives us the right to do the above…even if those provisions are absent from the trust. But importantly: It may be that, creating self-settled QDOTS are preferable. The surviving grantor can build into the self-settled trust options that the deceased spouse could not. Plus, if the surviving spouse is foreign, we may want the trust which is as required US situated to be taxed as a foreign trust….that option provides many opportunities.

Speaker:

• Cynthia Brittain

MCLE: 1.0 Hour Taxation Credit

This panel will discuss conservation easements and the invalidation of Notice 2017-10 under the Administrative Procedure Act by the Tax Court.

Speakers:

• David Foster
• Kimberly Mattonen
• Steven Toscher

MCLE: 1.0 Hour Taxation Credit

This panel will review California’s statutory equally-weighted three-factor scheme under California Revenue and Taxation Code section 25128. Join us to learn if your business activity could qualify for California’s 3-factor “qualified business activity.” This panel will review the rules for extractive, banks and financial, savings and loans, and agricultural activities. Further, we will explore the applicability of these rules beyond the “typical” taxpayer.

Speakers:

• Laura Wingert, FTB
• Campbell McLaren, Deloitte
• Craig Fields, Blank Rome
• Yoni Fix, Reed Smith

MCLE: 1.0 Hour Taxation; Estate Planning Credit

Learn how to plan for an audit while in the midst of analyzing and preparing wealth transfer strategies. It is important in the process to accomplish the client’s planning and tax goals, and assess the client’s risk tolerance, all while minimizing audit risk. This session will address recent case law, IRS developments and most importantly, the IRS’s target list.

Speakers:

• Robin Klomparens
• Lisa Piehl

MCLE: 1.0 Hour Taxation Credit

The administrative record rule is a key rule applicable to certain tax cases, the two key areas discussed in this panel are Collection Due Process and Innocent Spouse Relief cases. This panel will cover the basics of the administrative record, provide practical practice tips to ensure the administrative record is complete at the administrative level, and how to approach tax litigation cases where you may have additional evidence to that is outside of the administrative record.

Speakers:

• Joseph Broyles
• Jonathan Kalinski
• Judge Halpern
• Amy Ulmer, Senior Attorney, Small Business/Self-Employed

MCLE: 1.0 Hour Taxation Credit

Withholding can too often present challenging and arcane problems for tax practitioners and taxpayers alike. This panel will offer a refresh on California’s withholding scheme as it relates to nonresidents and passthrough entities, and compare the California system with the approach taken in other jurisdictions. A discussion of the interplay between withholding and California’s newly implemented passthrough entity elective tax (PTET) will also be provided. Finally, the panel will walk through the mechanics of the Franchise Tax Board’s new Form 592-PTE for passthrough entities, as well as waivers and exemptions to withholding requirements.

Speakers:

• Leah Thyberg, FTB
• Brandee Tilman, Armanino
• Jenica Wilkins, EY
• David Muradyan, FTB

MCLE: 1.0 Hour Taxation; Estate Planning Credit

The panel will discuss the issues when dealing with an estate with assets held outside of the US. Learn what every planner should know regarding cross-border trust administration, trust litigation, and planning matters.

Speakers:

• Patrick Martin
• Anuar Estefan
• Thomas Giordano-Lascari
• Kurt Kawafuchi

MCLE: 1.5 Hour Taxation Credit

IRC 6751(b) requires written supervisory approval before asserting certain penalties. Enacted in 1998 with the IRS Restructuring and Reform Act, the code section was essentially untested until a series of cases examining the code and and regulations starting with Graev v. Commissioner in 2013. Since then, many cases have followed to interpret the various aspects of the section, from which penalties must comply to the timing of supervisory approval and much more.

Speakers:

• Monica Gianni
  Associate Professor, California State University, Northridge
  Of Counsel, Davis Wright Tremaine LLP
• Kimberly Mattonen
• Judge Holmes
• Jonathan Amitrano

MCLE: 1.5 Hour Taxation Credit

Join the Chief Counsels from Board of Equalization, California Department of Tax and Fee Administration, Franchise Tax Board and Office of Tax Appeals to listen in on updates from the past year and insights on what is coming up next.

Speakers:

• Charles Moll, Partner, McDermott Will & Emery
• Henry Nanjo, Chief Counsel, California State Board of Equalization
• Kristen Kane, Chief Counsel, Office of Tax Appeals
• Chris Schutz, Chief Counsel, California Department of Tax and Fee Administration
• Shane Hofeling