Sessions

March 21-22, 2024 | San Francisco

15 hours MCLE plus Taxation & Estate Planning, Trust and Probate Law

2024 Estate and Gift Tax Conference
UC Law San Francisco
200 McAllister St
San Francisco, CA 94102

Thursday, March 21

Practical Case Studies for the Multinational Client:Ā  The Lessons We Have Learned | 8:30 amĀ – 9:30 amĀ 

1 Hour MCLE; Taxation & Estate Planning, Trust and Probate Law

This session will cover real life examples of the complexities that unknowingly can arise in estate planning both for US persons and/or nonresident/non-citizens when assets or family are here or abroad.  These studies will touch on treaties, income and transfer tax, situs, reporting rules and expatriation.  The case studies the panel will examine include the accidental foreign trust; blown foreign account/entity/trust reporting requirements and what to do about them, such as, inbound money transfers; buying vacation homes in a corporation in another country, conflicting international requirements; and limitations on planning when a spouse is a non-US citizen. 

Speakers:

  • Steve Walker
  • Yulissa Zulaica
The Art and Science of Advanced Fiduciary Elections Fiduciaries and Advisors Are Faced With | 9:45 amĀ – 10:45 amĀ 

1 Hour MCLE; Taxation & Estate Planning, Trust and Probate Law

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 importantā€”and even obscureā€”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.

Speakers:

  • Justin Miller
  • John Prokey
Simple(ish) Yet Elegant Planning for High Net Worth Clients | 10:45 amĀ – 11:45 amĀ 

1 Hour MCLE; Taxation & Estate Planning, Trust and Probate Law

We will explore sophisticated planning strategies to address the unique needs of this type of clientele. Attendees will leave equipped with the knowledge and tools to implement the best top planning strategies, leverage family bank structures and private trust companies, navigate charitable planning, optimize non-California situs, and engage in advanced income tax planning.  

Speakers:

  • Bryan Kirk
  • David Oh
  • Anna Soliman
From Wall Street Banquet to The Night Of The Poor: Ā Inflation, Poverty, Polarization, and Demographics – The Potential Tax Revolution Every Estate Planner, Trustee and Family Office Must Prepare For | 12:00 pmĀ – 12:40 pmĀ 

0.5 Hours MCLE; Taxation & Estate Planning, Trust and Probate Law

The world has just experienced the highest level of inflation in forty years, causing a rate hiking cycle which has rattled financial markets and has added to the economic fragility in this debt driven world.  However, inflation has been running hot for years, as the Bureau of Labor Stats has under reported the inflation rate for the bottom half of America for two decades now.  Add in the recent inflation surge and we have placed a vast swath of the population into poverty or very close to it. The younger generations have a different set of views on nearly all subjects, relative to the older generations, on everything from climate change to labor unions to other important subjects, like taxation.  With more than 50% of the US fiscal budget going to people over 65, a group that controls most of the wealth.  This imbalance won’t last and we don’t see it ending with the voting majority staying poor and receiving the crumbs of the federal budget.  A tax revolution could be on its way, and it will make things really interesting for practitioners, family offices, private trust companies and their ecosystem of advisors.

Speaker: Brendan MacMilan 

Ouch Those Interest Rates Hurt-Or Do They-Planning In a High Interest Rate Environment | 12:40 pmĀ – 1:25 pmĀ 

0.5 Hours MCLE; Taxation & Estate Planning, Trust and Probate Law

The speaker will discuss important techniques to use in our current high interest environment. Certain approaches may need to be modified and certain planning techniques are more advantageous than others. Learn what planning strategies are best employed in a high-interest rate environment and which techniques and strategies should be shelved until rates come down.

Speakers:

  • Kristin Capritto
  • Wayne Johnson
The Supercharger QDOT | 1:25 pmĀ – 2:10 pmĀ 

0.75 Hours MCLE; Taxation & Estate Planning, Trust and Probate Law

Many practitioners simply draft basic QDOT provisions into their trusts, but we may wish to ensure flexibility between income distributions versus unitrust treatment.  For example, what type of planning can be implemented to reduce U.S. estate tax on an appreciating, closely-held entity?  Practitioners may also want the flexibility to allocate capital gains to income, noting that capital gains are taxed at 40% when distributed.   In certain events, capital gains may be taxed in the trust and then taxed again when distributed out of the QDOT.   It is important to tee-up options for the trustee to reduce U.S. estate tax overall.   Importantly:   It may be that allowing the surviving spouse to create a self-settled QDOT would have preferable tax attributes over time.   The surviving grantor can build into a self-settled trust options that the decedent spouse cannot.   Further, if the surviving spouse is non-U.S. citizen, non-U.S. resident, it may be preferable for the trust to be characterized and taxed as a foreign trust.   Several options provide opportunities for U.S. income tax efficiency and U.S. estate tax mitigation, especially when coupled with unitrust treatment.

Speaker: Cynthia Brittain

The Tip of the Iceberg:Ā  How Not to Muck Up An Estate Plan | 2:25 pmĀ – 3:00 pmĀ 

0.5 Hours MCLE; Taxation & Estate Planning, Trust and Probate Law

The speaker will focus on important tips planners can use to better avoid the ugly ā€œLā€-litigation. Learn what to do and what not to do before it’s too late.

Speaker: Jenni Harmon

And the Saga of Life Insurance Continues | 3:00 pmĀ – 4:00 pmĀ 

1 Hour MCLE; Taxation & Estate Planning, Trust and Probate Law

Learn what a planner should do and not do when utilizing life insurance. The panel will discuss valuable techniques that can be used  when planning a clientā€™s estate.  Also, what cases are in the tax court pipeline since Estate of Levine and what tricks are up IRSā€™ sleeve to attack life insurance. 

Speakers:

  • Brian Gartner
  • Lalat Pattanaik
Planning with Inter-Vivos QTIP Trusts ā€“ The Best Way to Use All Transfer Tax Exemptions?Ā  | 4:00 pmĀ – 5:00 pmĀ 

1 Hour MCLE; Taxation & Estate Planning, Trust and Probate Law

With 2026 quickly approaching, practitioners are scrambling to identify the best methods for the use of their clientsā€™ transfer tax exemptions.  Portability is wonderful, but it only ports the applicable exclusion amount and not the generation-skipping transfer tax exemption.  This presentation will focus on the use of the Inter-Vivos QTIP Trust and ways in which such trusts can fully utilize a less wealthy spouseā€™s applicable exclusion amount AND the generation-skipping transfer exemption by explaining the basics of the Inter-Vivos QTIP Trust and then explaining how and why the use of such trusts involving inter-spousal transfers is the best approach for planning.  Further, the presentation will discuss the importance of such planning for a terminally ill spouse whose death is imminent. 

Speaker: George Karibjanian

Friday, March 22

Better Late Than Never: Directed Trusts Are Now A Reality | 8:30 amĀ – 9:30 amĀ 

1 Hour MCLE; Taxation & Estate Planning, Trust and Probate Law

With 2026 quickly approaching, practitioners are scrambling to identify the best methods for the use of their clientsā€™ transfer tax exemptions.  Portability is wonderful, but it only ports the applicable exclusion amount and not the generation-skipping transfer tax exemption.  This presentation will focus on the use of the Inter-Vivos QTIP Trust and ways in which such trusts can fully utilize a less wealthy spouseā€™s applicable exclusion amount AND the generation-skipping transfer exemption by explaining the basics of the Inter-Vivos QTIP Trust and then explaining how and why the use of such trusts involving inter-spousal transfers is the best approach for planning.  Further, the presentation will discuss the importance of such planning for a terminally ill spouse whose death is imminent. 

Speaker:

  • Phil Hayes
  • Michael Rosen-Prinz 
International Estate and Tax UpdatesĀ  | 9:30 am – 10:45 am

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

Things are changing so fast! There are many recent judicial developments that make timing very interesting for international estates, global gifts and foreign trust matters.  This includes Aroeste v. United States, who one of the panelists who practices at Chamberlain Hrdlicka handled. Aroeste and other cases have tremendous implications for estate, gift and trust matters at so many different levels; in Subtitle B planning with global assets (including the anticipated 2801 regulations regarding covered inheritances and covered gifts) and Subtitle A income tax planning, including accidental “tax expatriation” consequences.  The speakers will also make sure you understand what are the governmentā€™s hot buttons in this area today – including 877 and 877A.

Speakers:

  • Jeb Burton
  • Kurt Kawafuchi
  • Luz E. Villegas-Banuelos
Understanding Proposition 19 and Parent to Child Transfers, Tax Base Transfers and How to Effectively Submit Claims to the County Assessor | 11:00 am – 12:00 pm

1 Hour MCLE; Taxation & Estate Planning, Trust and Probate Law

The panel will discuss how to qualify for the personal residence  and farming exclusion, the use of LLCā€™s,  step transaction and other important guidance.  The panel will also discuss escape assessments and what you need to know when filing a property tax appeal. 

Speakers:

  • Michael Lebeau
  • Assessor – Phong La
The Lifecycle of an Art Collection – from Acquisition to AuctionĀ  | 12:15 pm – 12:45 pm

0.5 Hours MCLE; Taxation & Estate Planning, Trust and Probate Law

The speaker will discuss what practitioners need to know about a clientā€™s art collection. How is disposition on death prepared for and when it makes sense to sell at auction

Speaker: Victoria Gray

Tax Court Panel-ValuationĀ  | 12:45 pm – 2:15 pm

1.5 Hours MCLE; Taxation & Estate Planning, Trust and Probate Law

A Tax Court Judge, government counsel, a private practitioner, and appraisers will discuss each of their views and perspectives on valuation in the estate and gift tax arena.  This session will discuss how valuation discounts are used in planning, what happens if challenged and how courts evaluate the use of valuation discounts. The panel will also cover hot litigation topics and what everyone should learn from the most recent valuation case decisions. The panel will also provide practical solutions to managing valuation issues.

Speakers:

  • John Prokey
  • Sid Luckenbach
  • David Eckstein
Wake Up Your Professional ResponsibilitiesĀ  | 2:15 pm – 3:00 pm

0.75 Hours MCLE; Taxation & Estate Planning, Trust and Probate Law

The Director of the Office of Professional Responsibility will discuss the responsibilities of all wealth transfer tax practitioners, tax preparers and other third parties in the tax system who practice before the IRS.  This will include how to adhere to the professional standards,  follow the law and avoid explaining their actions to OPR.

Speaker: Sharyn Fisk

Fiduciaries And Practitioners Canā€™t Run From Corporate Transparency | 3:15 pm – 4:15 pm

1 Hour MCLE; Taxation & Estate Planning, Trust and Probate Law

This session will address the implications and impact of the Corporate Transparency Act on financial institutions and advisors. Corporate trustees are often sought when there are family conflicts or family dynamics issues, potential or actual litigation, complex or unusual assets or trust structures. Fiduciary relationships are like marriages ā€“ the relationship may start off well, but it can be difficult to extricate yourself if things do not work out. All practitioners need to know what fiduciaries must understand what they are accepting, the parties they are dealing with, the assets they are accepting responsibility for, and ultimately decide if the reward outweighs the risk. Similarly, advisors and clients need to evaluate potential corporate trustees for security and longevity. This session will analyze AML/KYC issues in working with high-risk clients, non-traditional assets and concentrated positions, due diligence, time constraints in acceptance and determining which trust company, if a corporate trustee is being used, is the right match for your client.

Speakers:

  • Todd Hammond
  • Karen Sugihara
From Death to DistributionĀ  | 4:15 pm – 5:00 pm

0.75 Hours MCLE; Taxation & Estate Planning, Trust and Probate Law

This session will address how to avoid the land mines when a taxpayer dies.  The panel will focus on federal tax filing requirements, procedures, processing and issues that can arise during an administration.

Speakers:

  • Robin Klomparens
  • Lisa M. Piehl

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