2022 Annual Meeting of the Tax Bar and Tax Policy Conference Schedule



Wednesday, November 2


1:00 p.m. – 1:05 p.m. | Opening Remarks

Speaker: Jackie Zumaeta, Chair of the Taxation Executive Committee

1:05 p.m. – 2:05 p.m. | In Re Grand Jury
MCLE: 1.0 Hour Taxation Credit, 1.0 Ethics

When Attorney-Client Communications May Not Be Privileged. In re Grand Jury is a cautionary tale of the limits of the attorney-client privilege in the context of dual purpose communications. While dual purpose communications, communications that have both a non-privileged and a privileged purpose, may arise in the context of any field of law, tax law is fraught with instances when those take place. Practitioners need to be aware of those situations, how to best safeguard the privilege and be aware of potential changes in the law that may come out of In re Grand Jury.

Speakers:

  • Laura Buckley, Buckley Tax Law, APC
  • Evan J. Davis, Hochman Salkin Toscher Perez P.C.
  • Adria Price, Price & Associates, LLC

2:15 p.m. – 3:15 p.m. | Gender and Racial Inequities in Our Tax Systems
MCLE: 1.0 Hour Taxation Credit, 1.0 Elimination of Bias

Much has been written over past decades on tax inequities in our tax systems that disfavor middle and low income taxpayers, women and minorities. On his first day in office, President Biden created the Equitable Data Working Group to gather better data on race, ethnicity, gender, disability, income, veteran status and other key demographic variables. This program will describe various tax rules that result in inequities that tend to favor one group of taxpayers over another such as sales tax exemptions, exclusions available or more valuable to higher income individuals, tax breaks based on age rather than need, not considering poverty levels in tax system design, inequities in some areas between spending done via the tax system versus direct spending programs, exam selection, and rules designed without consideration of past discrimination. Panelists will offer suggestions to make our federal and state tax systems more equitable.

Speakers:

  • Julie A. Divola, Partner Pillsbury Winthrop Shaw Pittman LLP
  • Francine J. Lipman, William S. Boyd Professor of Law, UNLV
  • Professor Michelle D. Layser, University of San Diego School of Law
3:30 p.m. – 4:30 p.m. | Taypayer Perspectives
MCLE: 1.0 Hour Taxation Credit

California business taxpayers share their perspectives on the latest tax issues impacting their companies.

Speakers:

  • Mike Shaikh, Partner, Baker McKenzie
4:45 p.m. – 5:45 p.m. | Tax Bootcamp Part I: Administrative Opportunities to Resolve a Tax Case Before Trial
MCLE: 1.0 Hour Taxation; Estate Planning Credit

This panel will feature speakers with federal, state and estate focused backgrounds to provide a comprehensive look at the administrative remedies that exist to resolve a tax dispute prior to litigation. Tried and true remedies as well as new developments in administrative procedural practice will be discussed.

Speakers:

  • Cindy Ho, Founder and Managing Attorney, Cindy Ho Law, APC
  • Sheri Wight, Senior Attorney, Internal Revenue Service
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:

  • Compensation & Benefits
  • Estate & Gift Tax
  • SALT
  • Income & Other
  • Women in Tax
  • Young Tax Lawyers
  • Corporate & Pass-Through Entities
  • Tax Policy Procedure & Litigation
  • 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 3


8:30 a.m. – 9:30 a.m. | Concurrent Sessions

529 Plans: A Compelling Tax and Estate Planning Tool
MCLE: 1.0 Hour Taxation; Estate Planning Credit

The speaker will discuss 529 Plans from a tax planning and estate perspective. He will review the rules of qualified tuitions plans under IRC §529 and opportunities to consider when establishing an account. 529 Plans will also be contrasted with other gifting vehicles to make the case as to why the 529 Plan is such a powerful planning tool.

Speaker:

  • David Oh, Managing Director, Fiduciary Trust

What’s the Final Word? A How-To Guide on Navigating IRS Written Guidance
MCLE: 1.0 Hour Taxation Credit

The IRS issues a variety of documents within broad categories of binding and non-binding guidance. Learn what can be relied on to avoid penalties, when disclosure is needed on a return, and when you should encourage your client to obtain a PLR. Recent decisions, such as Mann Construction, are covered which raised APA questions as to whether certain IRS documents, even though published in the IRB, were binding on taxpayers. Are such rulings applicable in other circuits? What about the Kellett case where the Tax Court denied a taxpayer application of a favorable revenue procedure? What guidance is a tax attorney to rely upon?  These issues and more will be discussed. 

Speakers:

  • Robert J. Kovacev, Miller & Chevalier Chartered
  • Hon. Mark V. Holmes, Judge, United States Tax Court

Just Passing Through: Developments and Updates for Pass-Through Entity Taxes
MCLE: 1.0 Hour Taxation Credit

In the wake of the SALT deduction cap, California and other states passed pass-through entity tax workarounds. Now that the PTETs are up and running, join our panelists in a discussion of what has worked, what needs fixing, and where the PTETs are heading next.

9:40 a.m. – 10:40 a.m. | Concurrent Sessions

Interesting Issues and Ideas for the Sophisticated Estate Planner
MCLE: 1.0 Hour Taxation; Estate Planning Credit

The speaker will cover various estate tax planning techniques that every estate planner should have on the shelf for the client that may need to reduce his or her estate.  There will be a discussion on Upgen Gifting, FLPs/LLC’s and how to shore up family entities in light of new IRS attacks and avoiding 2036.  Also learn about other techniques in the tool box such as gift stacking, QTIP’s, GRAT’s, IDGITs, SLAT’s etc. and what to advise clients in light of the sundown.

Speakers:

• Mark E. Powell, Mark E. Powell, Law Corporation
• Andrea Kushner Ross, Alliance Bernstein, L.P.


The Virtual Space is Real – Are You Prepared to Help Your Clients?
MCLE: 1.0 Hour Taxation Credit

Bitcoin has been around over 10 years, now joined by over 9000 cryptocurrencies. Billions of dollars are transacted in the defi space and metaverse. It is past time to be familiar with these realities and what due diligence attorneys must consider in serving clients in a variety of transactions. The latest in digital asset and blockchain developments are covered with an emphasis on federal and state tax relevance. Whether you help clients with financing, creating new entities and businesses, estate and gift planning, cross-border and multijurisdictional transactions, you’ll want to know what tax opportunities and traps exist in these areas involving digital assets as broadly defined.

Speakers:

  • Annette Nellen, CPA, Esq.; Professor, and Director, MST Program at SJSU
  • Christopher Wrobel, Special Counsel to the Associate Chief Counsel, Income Tax and Accounting

California Litigation Update
MCLE: 1.0 Hour Taxation Credit

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.

10:50 a.m. – 11:50 a.m. | Concurrent Sessions

What Advisors Need to Know About Bitcoin & Digital Assets
MCLE: 1.0 Hour Taxation

As the world evolves estate planners must learn how to deal with more unusual digital assets such as cryptocurrency (e.g., Bitcoin) and nonfungible tokens. There are many unanswered questions but certain tax and non-tax rules are clear. Help lead clients and fiduciaries down the right path.


BBA Partnership Audit Rules – Hot Topics
MCLE: 1.0 Hour Taxation

This panel will address key issues to consider in partnership transactions, audits, and administrative adjustment requests. Topics to be covered include calculation of imputed underpayment, when and how a partnership may avoid paying an imputed underpayment, as well as key reporting and procedural issues, including administrative adjustment requests. Learn from the experts: Jennifer Black, from the IRS Office of Chief Counsel, is one of the principal authors of the BBA regulations; Kate Kraus is the author of the BNA Tax Management Portfolio, The Partnership Audit Rules Under the Bipartisan Budget Act. Q&A welcome.

Speakers:

  • Kate Kraus, Partner, Allen Matkins
  • Jennifer M. Black, Senior Counsel, Associate Office of Chief Counsel (Procedure and Administration), Internal Revenue Service

California Source Income: Current Developments in Sourcing Income for PIT Taxpayers, including Nonresident Individuals, Partners, and Trusts
MCLE: 1.0 Hour Taxation

This panel will focus on the personal income tax laws governing sourcing income—income from a business trade or profession, income from intangibles, pass-through income, including the interaction of the Subchapter K, S-Corporation, and Subchapter J rules with the sourcing rules, and resulting impacts on the application of the other state tax credit among other things.  The panel will discuss recent developments in the application of these rules including Legal Ruling 2022-02, Legal Ruling 2021-01, and the Metropoulos case, including observations from audit activity, and procedural issues that arise after an audit of a flow-through entity.

Speaker:

  • Chris Campbell, Principal, Deloitte Tax LLP
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 to Andrea Kushner Ross, Director – Wealth Strategies Group, Alliance Bernstein L.P.; and the distinguished Joanne M. Garvey Award to Robert Horowitz, Hochman Salkin Toscher Perez, P.C.. The luncheon program will feature a keynote address by Russell Hancock, President & Chief Executive Officer, Joint Venture Silicon Valley. Purchase tickets in advance on your Conference registration form. Onsite ticket sales are limited.

1:45 p.m. – 3:15 p.m. | Concurrent Sessions

Tax Court Panel-Valuation
MCLE: 1.5 Hour Taxation; Estate Planning Credit

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
  • Hon. James S. Halpern, Judge, United States Tax Court
  • Jenny Casey, Senior Attorney, Internal Revenue Service

Tax Bootcamp Part II: Successful Litigation Strategies and Techniques
MCLE: 1.5 Hour Taxation Credit

If the techniques you learned in part I of the bootcamp are unsuccessful, part II is a must. This panel will tackle litigation strategies and pitfalls from all angles: state and federal, government and private practice, estate litigation, refund litigation and the U.S. Tax Court. The panelists will review well-established trial practice and introduce new opportunities to successfully litigate a tax case at trial.

Speakers:

  • Mitchell Newmark, Blank Rome
  • G. Michelle Ferreira, Shareholder, Greenberg Traurig
  • Hon. Mark V. Holmes, Judge United States Tax Court
  • Kevan McLaughlin, Managing Partner, McLaughlin Legal
  • Michael Hensley, Senior Counsel, Internal Revenue Service

Trends In California Corporate Income Tax
MCLE: 1.5 Hour Taxation Credit

Join this lively discussion on recent developments in market-based sourcing, the future of Public Law 86-272, and other important updates in the world of corporate income tax.

3:45 p.m. – 5:00 p.m. | Concurrent Sessions

Estate Planning for Multi-National Families with Global Assets
MCLE: 1.25 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.


Criminal Tax Bootcamp – How to Represent Clients in Criminal Tax Matters
MCLE: 1.25 Hour Taxation Credit

If you have ever had a client investigated for tax crimes, or if you would like to expand your practice to include criminal tax defense, this program is for you! The panelists will discuss important defense tactics before a client is charged with a tax crime, how to advise a client on matters such as search warrants and indictments, sentencing guidelines and plea agreements, and civil considerations regarding compliance and assessment of tax, penalties and interest. Government panelists will provide insight into the general investigative process, the IRS Criminal Investigation’s role in leading the investigation before a criminal referral is made for prosecution, as well as how they assist in the prosecutorial phase.

Speakers:

  • Betty Williams, Managing Shareholder, Law Offices of Williams & Associates, P.C.
  • Sandra Brown, Principal, Hockman Salkin Toscher Perez, P.C.
  • Darren Lian, Assistant Special Agent in Charge (ASAC), IRS Criminal Investigation

Trends in M&A
MCLE: 1.25 Hour Taxation Credit

This SALT/federal crossover panel will explore the changes implemented by tax agencies as a result of COVID-19 and provide practice pointers for advising clients through a merger and acquisition. The panel will provide perspectives on their experiences working through M&A hurdles and will consider some improvements that can be made to ease the strain on taxpayers.

Speaker:

  • Myra Sutanto Shen, Wilson Sonsini Goodrich & Rosati, P.C.
5:30 p.m. – 6:30 p.m. | A Toast to Women in Tax

A Toast to Women in Tax: Inspiring Leadership

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.

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.

6:30 p.m. – 8:30 p.m. | Dinner and Entertainment

Annual conference dinner and entertainment. Onsite ticket sales are limited. We encourage you to purchase your dinner tickets ahead of time.

8:30 p.m. – 10:30 p.m. | Casino Night and Networking Event

Join us for an after-hours event with entertaining activities. And if you’re not a gambler or decide to fold ‘em early, you can catch up with old friends and make new ones under the San Diego stars at an adjacent outdoor networking event. This event is complimentary; however, your RSVP is required on your conference registration form.


Friday, November 4


8:30 a.m. – 9:45 a.m. | Concurrent Sessions

Estate CRT’s-Safe and Dangerous
MCLE: 1.25 Hour Taxation; Estate Planning Credit

Charitable Remainder Trusts continue to be an integral part of tax planning (despite the current market environment). Although IRS provides sample forms and other guidance, dangers lurk for the unwary practitioner.  The panel will provide an overview of forming, funding, and operating charitable remainder trusts while highlighting certain unsettled issues and dangerous.


Tax Court Roundtable
MCLE: 1.25 Hour Taxation Credit

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 frequent flier, this panel is a must!


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.

9:55 a.m. – 11:10 a.m. | Concurrent Sessions

Helping IRA Plan His IRA from the IRA – Testamentary Planning with Individual Retirement Accounts Including Under the New Proposed Regs
MCLE: 1.25 Hour Taxation; Estate Planning Credit

This presentation provides a thorough overview of estate planning with IRA’s.  Building from the basics of IRA’s and RMD’s, the presentation graduates to the complexities of understanding payouts to beneficiaries under the SECURE Act (taking into consideration the SECURE Act’s Proposed Regulations from February 2022), and ends with a dissection of testamentary trust planning with IRA’s, comparing and explaining conduit and accumulation trusts and giving some advice for deciding which to use and when.

Speaker:

  • George Karibjanian, Member, Franklin Karibjanian & Law PLLC

Planning with our Neighbors: U.S.-Mexico-Canada a Multinational Case Study
MCLE: 1.25 Hour Taxation Credit

The panelists will present a fact pattern involving Canada, Mexico and the United States. A discussion will follow highlighting the traps and planning opportunities when dealing with taxpayers with connections in multiple jurisdictions, with an emphasis on our contiguous neighbors.


What’s New In Local Taxes?
MCLE: 1.25 Hour Taxation Credit

This panel will highlight California’s local tax developments and shed light on what future developments are in store for local jurisdictions, taxpayers, and local tax law.

11:20 a.m. – 12:50 p.m. | Lunch/Miller Award/State Keynote

1:00 p.m. – 2:00 p.m. | Concurrent Sessions

Reminiscing on 2022 And Planning For 2023 As Audits Heat Up
MCLE: 1.0 Hour Taxation; Estate Planning Credit

The panel will discuss what is new from the government as well as newly released regulations and guidance, including IRC 2053.  The discussion will include case law, the most important take-aways from 2022, what to expect in 2023, including IRS’ latest hot buttons and audit issues.

Speakers:

  • James Hogan, Managing Director, Anderson Tax
  • Robin Klomparens, Partner, Wagner Kirkman Blaine Klomparens & Youmans LLP
  • Lisa Piehl, Estate and Gift Tax Attorney, Internal Revenue Service

International Hot Topics
MCLE: 1.0 Hour Taxation Credit

The panelists will discuss recent developments in the world of international tax. From the final foreign tax credit regulations to the OECD’s pillars 1 and 2, and everything in-between, the program will provide the audience with an overview of the changes affecting cross-border transactions.


A Land of Opportunity: Credits and Incentive
MCLE: 1.0 Hour Taxation Credit

This crossover panel will discuss the many opportunities for credits and incentives available to taxpayers at the federal, state, and local levels. The panel will dive into recent legislative updates and the incentive landscape in the wake of COVID-19.

2:10 p.m. – 3:10 p.m. | Concurrent Sessions

Beyond Term Insurance
MCLE: 1.0 Hour Taxation; Estate Planning Credit

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:

• G. Michelle Ferreira, Shareholder, Greenberg Traurig
• Lalat Pattanaik, Managing Partner, PH Robb Legacy Alliance
• Nick Nilan, Senior Counsel, Internal Revenue Service


Nuts and Bolts of Non-Profits
MCLE: 1.0 Hour Taxation Credit

Nonprofits need tax practitioners from inception to compliance to controversy. With the IRS recently designating charities an audit focus, it is imperative that nonprofits are created correctly, remain current and are prepared in the event of an examination. This program will cover the basics of establishing a non-profit in California and gaining tax exempt status from the IRS, discuss common estate planning techniques utilizing non-profits, explore all entities that fall under the 501(c) umbrella, and provide practical pointers on how to navigate and assist a nonprofit facing a noncompliance issue with the IRS, FTB and/or California DOJ.

Speaker:

  • Jonathan A. Grissom, Higgs Fletcher & Mack, LLP

Responsible Persons Liability
MCLE: 1.0 Hour Taxation Credit

Whether you’re a practitioner providing advice or an individual working for a taxpayer, there are potential landmines that are lingering. The federal/state crossover panel will discuss potential responsible personal liability for federal withholding, state sales tax, and other relevant areas. The panel will discuss recent legal developments and provide tips on how to best act to avoid potential liabilities.

3:30 p.m. – 5:00 p.m. | Concurrent Sessions

Tax Treaties for the Estate Planner
MCLE: 1.5 Hour Taxation; Estate Planning Credit

The panel will discuss important issues under income, and estate and gift tax treaties. They will also cover the exchange of information under such treaties and/or FATCA agreements and other associated issues.

Speakers:

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

Countdown of the Greatest and Latest Income Tax Hot Topics
MCLE: 1.5 Hour Taxation Credit

This panel will delve into the key income tax topics expected to be relevant to taxpayers and their tax advisers in 2023 and beyond. We don’t want to divulge the entire list now, but it will include such words as $80 billion of funding, pillars, 174, energy, PTET, WFH, 2026, expiring, and digital assets.

Speaker:

  • Annette Nellen, CPA, Esq.; Professor, and Director, MST Program at SJSU

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.


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