
Wednesday, November 1
1:00 p.m. – 1:05 p.m. | Opening Remarks
Speaker:
- Amy Spivey, Incoming Chair of the Taxation Executive Committee
1:05 p.m. – 2:05 p.m. | At Both Ends: Overcoming Burnout in Legal Practice
MCLE: 1.0 Hour Credit, 1.0 Competence Issues
Long hours, deadlines, and the adversarial system all contribute to making lawyers more susceptible to burnout than some other professions. This panel will talk about the signs of burnout and discuss how lawyers can mitigate or overcome burnout in their careers.
Speaker:
- Amy Spivey, Incoming Chair of the Taxation Executive Committee
2:15 p.m. – 3:15 p.m. | Spotlight on California’s State Controller
MCLE: 1.0 Hour Taxation Credit
As California’s chief fiscal officer, the State Controller has broad superintending authority over the accounting and disbursement of state and local government finances. Join us as State Controller, Malia Cohen, provides insight into the activities and programs administered by the Office of the Controller, as well as recent trends in California finance.
Speaker:
- Malia Cohen, State Controller
3:30 p.m. – 4:30 p.m. | Taxpayer Perspectives: Tax Director Panel
MCLE: 1.0 Hour Taxation Credit
Tax Directors share their perspectives on the latest tax issues impacting their companies.
Speakers:
- Latoya Edwards, Vice Present, North America Tax Operations, Visa
- Jairaj Guleria, Deloitte
- Carlos Anguiano, Tax Director
4:45 p.m. – 5:45 p.m. | Considerations Raised by Broad Use of AI Tools in Practice
MCLE: 1.0 Hour Taxation; 1.0 Ethics
As technology advances, the ethical use of Artificial Inteligence (“AI”) in the legal profession is a looming question. Join us as our panelists discuss emerging technologies, their uses in legal practice, where we might be going, and necessary considerations for integration of these tools.
5:45 p.m. – 6:30 p.m. | Standing Committee Happy Hour
Are you interested in learning more about the Tax Section and its Subcommittees? Join and meet with our standing committee leaders to learn more about the work of the Tax Section. Light refreshments will be provided.
Standing Committees to Connect with:
- Estate & Gift Tax
- SALT
- Income & Other
- Women in Tax
- Young Tax Lawyers
- Corporate & Pass-Through Entities
- Tax Practice & Litigation
- International
- Exempt Organizations
6:30 p.m. – 8:30 p.m. | Opening Night Cocktail and YTL Reception
Connect with conference speakers and government attendees at our opening evening cocktail event. Enjoy light appetizers, a variety of beverages and participate in fun activities – a perfect way to kick off the conference! This event is complimentary.
Please RSVP on your conference registration form.
Thank you to our Opening Night Cocktail and YTL Reception Sponsors: Apheta and UC Irvine Graduate Tax Program.
Thursday, November 2
8:30 a.m. – 9:30 a.m.
Everything you Wanted To Know About Estate and Gift Tax Audits and Then Some
MCLE: 1.0 Hour Taxation; Estate Planning Credit
Presenters 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:
- Anna Soliman
- Nicholas Hulwi
Federal Legislation Update
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.
Get to Know Local Tax Law: A Primer and Current Developments
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
- Jeff Phang, Pillsbury
- Troy Van Dongen, McDermott
9:40 a.m. – 10:40 a.m.
The Art and Science of Advanced Fiduciary Elections Fiduciaries and Advisors Are Faced With
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
Breaking New Ground: Equitable Tolling in Tax Cases Post-Boechler
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.
Sourcing Income from Passthrough Entities & Developments Since Metropoulos
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
10:50 a.m. – 11:50 a.m.
What You May Not Realize About GST But Need to Know
MCLE: 1.0 Hour Taxation
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
Tax Court Roundtable
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!
California Litigation Update
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
12:00 p.m. – 1:30 p.m. | Lunch / Klein & Garvey Federal Keynote
Klein & Garvey Federal Lunch Keynote: This luncheon showcases the presentation of the prestigious V. Judson Klein Award and the distinguished Joanne M. Garvey Award. The luncheon program will feature a keynote address. Purchase tickets in advance on your Conference registration form. Onsite ticket sales are limited.
1:45 p.m. – 3:15 p.m.
Valuation of Hard To Value Assets
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
International Hot Topics
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.
Substantial and Occasional Developments in Alternative Apportionment for Corporate Income Tax
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
3:45 p.m. – 5:00 p.m.
Top Tax and Estate Planning Techniques Today
MCLE: 1.25 Hour Taxation; Estate Planning Credit
TCJA has changed everything we know as planners. This presentation 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 tax law, with an eye toward anticipated changes to the future planning landscape.
Speaker:
- Paul Lee
Corporate Transparency Act
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.
Cryptocurrency – Federal Guidance & Implications for California
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.
Speakers:
- Carolyn Schneck, IRS
- Priscilla Parrett, Vellejo Antolin
- Mike O’Brien, EY
- Elle Kaiser, McDermott
5:30 p.m. – 6:30 p.m. | A Toast to Women in Tax
This year’s Toast to Women in Tax will feature women who have achieved professional success, exemplify what it means to be a leader and help shape the leaders of the future.
The speakers will discuss what being a leader means to them and provide insight on how we can all strive to be leaders in all that we do.
6:30 p.m. – 8:30 p.m. | Dinner and Entertainment
Annual conference dinner and entertainment provided by comedian, Collin Moulton.
8:30 p.m. – 10:30 p.m. | Casino Night and Networking Event
All conference attendees are welcome to attend the Toast! There will be valuable time to network, get involved with the Women in Tax Standing Committee and to meet women attorneys and tax practitioners who have achieved professional excellence in their field of practice.
Friday, November 3
8:30 a.m. – 9:45 a.m.
The Supercharged QDOT
MCLE: 1.25 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
Nearshoring: US-Mexico International Tax Issues
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.
Legislative Updates
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
9:55 a.m. – 11:10 a.m.
Dealing With Difficult Entity and Real Estate Issues
MCLE: 1.25 Hour Taxation; Estate Planning Credit
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
Keeping up with the Credits: Employee Retention Credit
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.
California Conformity in a Post-Pandemic State
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
11:20 a.m. – 12:50 p.m. | Lunch/Miller Award/State Keynote
Join us to honor the 2023 Benjamin F. Miller Award. This luncheon will also feature a keynote speaker.
1:00 p.m. – 2:00 p.m.
Estate Planning for Multi-National Families with Global Assets
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
- Caroline Cielo
- Kurt Kawafuchi
One Year Later: The IRS War on Conservation Easements
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.
Are you Qualified for 3-Factor Apportionment?
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
2:10 p.m. – 3:10 p.m.
Dealing With Difficult Entity and Real Estate Issues
MCLE: 1.0 Hour Taxation; Estate Planning Credit
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
The Administrative Record Rule
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.
Refresh on Withholding Concepts & the New Form 592-PTE
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
3:30 p.m. – 5:00 p.m.
Why Every Practitioner Should Understand About the Two D’s: Directing and Decanting
- Tara Morris
MCLE: 1.5 Hour Taxation; Estate Planning Credit
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.
Speaker:
The Long and Confusing History of the Use of Section 6751(b) to Defend the IRS Assertion of Penalties
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.
Speaker:
- Monica Gianni
Associate Professor, California State University, Northridge
Of Counsel, Davis Wright Tremaine LLP
Chief Counsel Roundtable
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
- Jozel Brunett, Chief Counsel, Franchise Tax Board
- 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
5:00 p.m. – 7:00 p.m. | Post-Conference Reception
Stick around to mingle and network with speakers and attendees at this informal gathering. Your RSVP is requested.