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2021 Annual Income Tax Seminar
July 15 @ 9:00 am – 1:25 pm
Welcome to the 2021 Annual Income Tax Seminar! Earn 4.0 Hours of MCLE, which includes Legal Specialization in Taxation Law.
9:00 a.m. – 9:10 a.m. | Opening Remarks from Matthew Carlson
Matthew will kick off the program with opening remarks.
Speaker: Matthew Carlson, Counsel, Boutin Jones, Inc.
9:10 a.m. – 10:10 a.m. | California Controversy Trends
The speakers will discuss a variety of recent California tax controversy trends and current developments.
- Gina M. Rodriguez, State and Local Tax Director, KPMG
- Oksana G. Jaffe, Managing Director, KPMG
10:15 a.m – 11:15 a.m. | Unraveling Metropoulos and Sourcing Sales of Intangibles under California’s Personal Income Tax Law
The speakers will discuss California’s personal income tax rules for characterizing income and sourcing sales of intangibles, with a heavy focus on the Office of Tax Appeals’ controversial Metropoulos decision holding that flow-through gain from an S corporation’s sale of goodwill should be sourced under California Code of Regulations, title 18, section 17951-4 rather than California Revenue and Taxation Code section 17952.
- Robert P. Merten III, Counsel, Pillsbury Winthrop Shaw Pittman LLP
- Lexi Louderback, Associate, Pillsbury Winthrop Shaw Pittman LLP
11:20 a.m. – 12:20 p.m. | Current Developments in International Penalties
This speaker will discuss the current state of International Information Return Penalties. The IRS continues to enforce filing compliance for international information returns, including Forms 3520, 3520-A, 5471, 8938, FBARs, and others. The speaker will discuss current trends in IRS enforcement efforts, challenges that taxpayers face in disputing civil penalties, procedural matters, and other current developments.
Speaker: Jon Feldhammer, Partner, Baker Botts LLP
12:25 p.m. – 1:25 p.m. | Déjà Vu All Over Again? Syndicated Conservation Easement Challenges Reflect Lessons of Prior “Tax Shelter” Wars
Pursuing a variety of strategies on multiple fronts, the IRS is advancing challenges to charitable contribution deductions claimed for conservation easements. This discussion will review the scope and status of these disputes with a nod towards the substantive and procedural tools that evolved from previously marketed transactions focused on tax incentives.
Speaker: Wendy Abkin, Partner, Morgan, Lewis & Bockius LLP
- Gina Rodriguez
- Oksana Jaffe
- Robert P. Merten III
- Lexi Louderback
- Jon Feldhammer
- Wendy Abkin
- CLA Member: $70
- Non Member: $100