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2023 Estate and Gift Tax Conference

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March 9 March 10

I15.50 Hours MCLE, Taxation & Estate Planning, Trust and Probate Law Specialization Credit

UC College of the Law, San Francisco
(formerly UC Hastings)
200 McAllister Street
San Francisco, CA 94102

  • Member Price: $305
  • Non-Member Price: $395

Thursday, March 9

529 Plans: Too Cool for School and Estate Planning? | 8:30-9:30 a.m.

This session will focus on the basics of the tax qualification and operating rules of 529 Plans and explore advanced planning techniques. Learn how to select qualified tuitions plans under Section 529, how to maximize the benefits, leverage gifting and design a flexible plan as part of a thoughtful wealth transfer plan. This session will also discuss the differences between a 529 Plan and other gifting options.

Speaker: David Oh, Managing Director, Fiduciary Trust International

Estate Planning for Multi-National Families with Global Assets | 9:45-11:15 a.m.

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, International Tax – Shareholder, Chamberlain Hrdlicka
  • Anuar Estefan, Associate, Chamberlain Hrdlicka
  • Luz Villegas-Banuelos, Chamberlain Hrdlicka
  • Thomas Giordano-Lascari, Partner, Karlin & Peebles, LLP
IRS Target List – Avoiding Audit: How the Transfer Tax Spaghetti is Made | 11:15-12:15 p.m.

Learn how to plan for an audit while in the midst of preparing and executing on the client’s wealth transfer strategies. Explore how 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 and most importantly, the IRS’s target list, all in the context of the client’s goals and risk appetite. Time permitting, this session will also provide practical tips for entity formation in light of the IRS’s areas of concern.

Speakers:

  • Stephanie Loomis-Price, Perkins Coie LLP
  • Robin Klomparens, Partner, Wagner Kirkman Blaine, Klomparens & Youmans LLP
  • Lisa Piehl, Estate and Gift Tax Attorney, Internal Revenue Service
Don’t Guess and Make a Mess with QSBS | 12:30-1:30 p.m.

This presentation will cover the basics of qualified small business stock (QSBS) under section 1202, show you how founders can “stack” multiple capital gain exclusions among family members, address how non-grantor trusts can be the ultimate tool for QSBS planning to protect family members and minimize state income taxes, and discuss the challenges in non-grantor trust drafting compared to the more commonly used irrevocable grantor trusts.  

Speaker: Justin Miller, Partner and National Director of Wealth Planning, Evercore Wealth Management and Managing Director at Evercore Trust Company

Conquering Subchapter K(ryptonite): Fundamentals of Partnership Taxation for Estate Planners | 1:30-3:30 p.m.

The taxation of partnerships (and limited liability companies) can be downright confounding, confusing, complicated, and cryptic for estate planners. This presentation will provide the basics of partnership income taxation (from formation, in operation, and to termination) that all estate planners should know, including traps for the unwary and interesting planning opportunities.

Speaker: Paul Lee, Chief Tax Strategist, Wealth Management and Global Family & Investment Offices Group

Back End SLAT | 3:45-5:00 p.m.

As 2026 quickly approaches, the SLAT once again becomes the dominant planning vehicle of choice for married couples. As the basic exclusion amount has seemingly exponentially increased, wealthier spouses are becoming a bit more hesitant to engage in a SLAT for two reasons: divorce and the unanticipated death of the donee spouse. These issues become relevant because, should either occur, the wealthier spouse would lose all access to the SLAT funds. To combat that risk, creative planners developed the “Back End SLAT” under which it is possible for the donor spouse to retain an interest in the SLAT if the donee spouse predeceases the donor spouse and, in some jurisdictions, if a divorce occurs. In 2022, Florida became the 9th jurisdiction to adopt a specific statute authorizing the Back End SLAT and hopefully CA will follow. Even if state law blesses the approach, does it really work to avoid estate taxation upon the death of the donor spouse? The answer is unclear. This presentation will explore the genesis of the Back End SLAT and the associated potential transfer tax pitfalls.

Speaker: George Karibjanian, Franklin Karibjanian & Law PLLC

Friday, March 10

Dealing With Difficult Entity and Real Estate Issues | 8:30-9:30 a.m.

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, Wagner Kirkman Blaine Klomparens & Youmans LLP
  • Belan Wagner, Wagner Kirkman Blaine Klomparens & Youmans LLP
Current Developments | 9:45-11:15 a.m.

Things are still evolving so fast! Learn about the significant changes in wealth transfer taxes that have occurred under the Inflation Reduction Act of 2022 (“Tax Act”), recent developments during 2022 and 2023 and pending legislation for wealth transfer taxation. This session will focus on how planning has fundamentally changed with the new Tax Act, what unique outcomes have occurred under the new Tax Act, and what potential new benefits are available to taxpayers under the new Tax Act. A discussion of the latest regulations, rulings and cases involving what is included in the federal gross estate, estate tax martial and charitable deductions, gifts, premature termination of a QTIP Trust, split-dollar insurance arrangements, valuation for estate and gift purposes, GRATs and methods for using the historically high estate and gift tax exemption before it takes a huge nosedive.

Speakers:

  • Robin Klomparens, Partner, Wagner Kirkman Blaine, Klomparens & Youmans LLP
  • John Prokey, Partner, Ramsbacher Prokey Leonard LLP
Next-Gen Planning: What Advisors are Discussing with Gen X, Y & Z Clients | 11:15 a.m. -12:15 p.m.

If you haven’t heard of the Bored Ape Yacht Club, this presentation is for you! Gen X/Y/Z clients have different goals and objectives, and their assets often look vastly different than that of their parents. Planning for assets such as cryptocurrency, non-fungible tokens (NFTs), digital assets, and Qualified Small Business Stock (QSBS) – while providing maximum flexibility for circumstances that are likely to change over the clients’ remaining lifetimes – will be addressed. Be prepared to learn about the planning and tax implications and fiduciary considerations of navigating the virtual currency ecosystem and metaverse, and planning considerations unique to next-generation clients.

Speakers:

  • Matt Brady, Managing Director, Regional Market Manager Citi Global Wealth
  • Karen Sugihara, Regional Fiduciary Manager, BNY Mellon Wealth Management
  • Michael Rosen-Prinz, Loeb & Loeb
Art Market Report | 12:30-1:00 p.m.

Bonham’s will present an analysis of the trends that were seen in the art market in 2022 and what is anticipated for 2023, that every estate planner should be aware of when dealing with art in a client’s estate. The discussion will focus on the strengths and weaknesses that are evident in the market today. Learn what practitioners can tell their clients about their art collections, including valuation and sales.

Speaker: Leslie Wright, Bonhams

Tax Court Panel-Valuation | 1:00-2:30 p.m.

A Tax Court Judge, government counsel, a private practitioner, and appraiser will discuss each of their views and perspectives on valuation in the estate and gift tax arena. The panel will also cover hot litigation topics such as defined value formulas, step transaction, family entity issues, 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, Partner, Ramsbacher Prokey Leonard LLP
  • Mark Higgins, President, Higgins Marcus & Lovett, Inc.
  • Judge Halpern, United States Tax Court
  • Jenny Casey, Senior Attorney, Internal Revenue Service
Beyond Term Insurance | 2:30-3:30 p.m.

The panel will discuss planning with life insurance and how to position a client in case of a post gift or death attack. Also learn what a planner should do and not do. Split dollar life insurance, Estate of Levine and other relevant law will be discussed.

Speakers:

  • Michelle Ferreira, Shareholder, Greenberg Traurig
  • Lalat Pattanaik, Managing Partner, PH Robb Legacy Alliance
  • Brian Gartner, Principal, Winged Keel Group
Tax Treaties for the Estate Planner | 3:45-5:00 p.m.

The panel will discuss important issues under income, and estate and gift tax treaties. This will include covering the exchange of information under such treaties and/or FATCA agreements and other associated issues. Of course they will also make sure you understand what are the government’s hot buttons in this area today.

Speakers:

  • Marsha Dungog, Partner, Withers Bergman LLP
  • Caroline Ciraolo, Partner, Kostelanestz & Fink LLP
  • Kurt Kawafuchi, Principle, Law Offices of Kurt Kawafuchi

Pre-Registration Deadline: The deadline to pre-register is March 2, 2023.


Cancellations/Refunds: 
Requests must be received in writing no later than March 2, 2023. A $50 processing fee will be charged for requests received after date. For more information, call 916-516-1757. Refunds will not be available after March 8, 2023.

On-Site Registration: On-site registration is subject to availability. Call to confirm space availability.

Special Assistance: For special assistance, please contact Taxation@calawyers.org

Questions: For registration information call 916-516-1757. Telephone registrations will not be accepted. For program content and/or Section information call 916-516-1760.

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.

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CLA Membership is $99 and includes one section. Additional sections are $99 each.

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