84th Institute on Federal Taxation 2025 (presented by NYU School of Professional Studies)

Jennifer Acuña, Esq., Principal | KPMG

Jennifer Acuña has joined KPMG LLP, the audit, tax and advisory firm, as a principal in the federal legislative and regulatory services group of the firm’s Washington National Tax (WNT) practice. Most recently, she served as chief tax counsel for the Committee on Finance in the U.S. Senate and previously was tax counsel for the Committee on Ways and Means in the U.S. House of Representatives. She will be based in Washington, D.C.

During her time in committee positions with both the House and the Senate, from January 2015 to January 2019, Acuña played a critical role in developing federal tax reform proposals for the Tax Cuts and Jobs Act (TCJA) of 2017.

“Jennifer’s role in helping shape the TCJA in both the House and Senate, as well as the knowledge and experience that she gained on Capitol Hill, will further bolster KPMG’s thought leadership and insights on tax policy and will be essential as we help our clients navigate both U.S. and global tax reforms,” said Manal Corwin, principal-in-charge of KPMG’s WNT practice. “We’re looking forward to having Jennifer become part of our Washington National Tax practice and our firm.”

In her new position, Acuña will advise companies on federal tax legislative and regulatory developments on Capitol Hill, working with John Gimigliano, the principal-in-charge of KPMG’s federal tax legislative and regulatory group, Corwin added.

“Jennifer played a key role at every stage of tax reform, in the House and in the Senate,” said Gimigliano. “I’m thrilled to have her bring that insight to our team and to our clients.”

Earlier in her career, Acuña was oversight counsel for the House Committee on Ways and Means, from 2011 to 2015. She also served as a competent authority analyst with the IRS’ tax treaty group in the Large Business and International Division and worked for the law firms of White & Case, LLP and Morgan Lewis & Bockius in their tax controversy and litigation groups.

Acuña earned a Bachelor of Arts degree from the University of Central Florida, a Juris Doctor degree from UCLA School of Law, and a Master of Laws in Taxation from New York University School of Law.

Daniel J. Winnick, Esq., Principal, International Tax | KPMG

Principal at KPMG, Washington National Tax—International Tax

Cory Stigile, Esq., Principal | Hochman Salkin Toscher Perez, PC

Cory J. Stigile is a Principal at Hochman Salkin Toscher Perez, P.C., where he focuses on tax controversies, business tax issues, and international tax matters. He has represented clients in civil tax examinations, administrative appeals, and tax collection proceedings, and has argued matters in U.S. Tax Court, U.S. District Court, the Court of Federal Claims, and the 9th Circuit. Mr. Stigile is both a licensed attorney (California) and a CPA (California). He also holds a B.S. in Accounting (cum laude) from California Lutheran University, a J.D. from Emory University School of Law, and an LL.M. in Taxation from NYU. Recently, he was elected as a Fellow of the American College of Tax Counsel, a recognition of his standing in the tax bar.

Chad D. Nardiello, Esq., Partner | Nardiello Turanchik Tompkins

Chad Nardiello specializes in civil and criminal tax controversy and litigation matters. He represents clients at all phases of the tax controversy process, including before the Internal Revenue Service (“IRS”) Examination Division (a.k.a. the audit stage) and Appeals Office, during the criminal investigation process, as well as in litigation in the US Tax Court, US Court of Federal Claims, US District Courts, US Bankruptcy Courts and US Courts of Appeal. Mr. Nardiello also represents taxpayers involved in state tax controversy matters, including disputes involving the California Franchise Tax Board, the California Department of Tax & Fee Administration and the Employment Development Department. He also represents clients undergoing anti-money laundering examinations by the IRS and investigations by the Financial Crimes Enforcement Network, and in litigation of such matters.

David B. Porter, Esq. | Law Offices of David B. Porter, PC

Dave Porter has represented individuals and businesses in federal and state tax controversies, business and corporate matters, white collar criminal defense, civil litigation, collection matters, and tax and estate planning since 1991. Dave served as the Chair of the Bar Association of San Francisco (BASF), Tax Section, and served on its Executive Committee for 5 years. He started his own law firm in 2011.

Brian A. Sullivan, CPA/ABV, President & CEO | Sullivan & Company CPA

Brian A. Sullivan CPA/ABV has been a forensic accountant for more than 20 years. He is well qualified as a business appraiser & expert witness. He holds specialty designations, including: Accredited in Business Valuation; Certified Valuation Analyst; Certified Fraud Examiner; and Certified Business Appraiser. He also holds a Series 7 and Series 79 license. He has testified in federal Tax Court and numerous state courts on a variety of civil shareholder disputes, business & investor fraud, personal injury and other matters. He has also been recognized by the court as a court appointed referee.

Sharyn M. Fisk, Esq., former Director | IRS Office of Professional Responsibility

Sharyn M. Fisk was named Director of the IRS Office of Professional Responsibility (OPR) in January 2020. As Director, she is responsible for the IRS’ oversight of tax professionals who practice before the IRS as set out in Treasury Circular 230. Sharyn’s extensive background in the tax community brings over 20 years of tax experience to the OPR position. Before coming to the IRS, Sharyn was Professor of Tax at Cal Poly Pomona and Director of the University’s VITA program. Prior to teaching, Sharyn was in private practice specializing in tax controversies. As a private practitioner, Sharyn represented hundreds of individuals, businesses, and corporate taxpayers before the IRS, the Department of Justice Tax Division, federal and state courts, and state taxing authorities. These matters involved civil examinations and appeals, criminal investigations, and tax collection issues. Before becoming a private practitioner, Sharyn clerked for the Honorable Maurice Foley, Judge, U.S. Tax Court.

Elizabeth Thomas Dold, Esq., Principal | Groom Law Group

Elizabeth Thomas Dold’s practice focuses on the Internal Revenue Code and related compensation matters, including employment taxes and other reporting and withholding requirements. She has considerable experience with all types of employee benefits, including qualified plans, IRAs, governmental plans, nonqualified deferred compensation plans, and health and welfare plans.

J. Rose Zaklad, Esq., Principal; Tax Practice Leader | Groom Law Group

Rosie Zaklad’s practice involves the design, implementation and ongoing administration of retirement plans, including defined benefit, defined contribution, and tax-deferred annuity plans. She focuses on tax-qualified plan compliance issues, including Internal Revenue Service audits, rulings, and corrections.

Steven P. Johnson, Esq., Partner | Morgan, Lewis & Bockius

With experience gained as a trial lawyer in the Tax Division of the US Department of Justice (DOJ), Steven P. Johnson advises clients on tax controversies and litigation matters involving complex tax issues. Before joining Morgan Lewis and working for the DOJ, Steven served as a law clerk to Judge Tucker L. Melancon of the US District Court for the Western District of Louisiana. He holds a Masters in Tax Law (LL.M.) from Georgetown Law School.

Joshua Odintz, Esq., Partner | Holland & Knight

Joshua D. Odintz is a tax attorney in Holland & Knight’s Washington, D.C., office. Mr. Odintz focuses on tax policy, tax controversy and tax planning matters. He is a co-leader of the Public Policy & Regulation Group’s Tax Policy Team. Mr. Odintz represents clients before the U.S. Department of the Treasury, Internal Revenue Service (IRS), U.S. Congress and the Organisation for Economic Co-operation and Development (OECD). He assists clients in seeking legislative and regulatory changes to tax laws, as well as monitoring key legislative and regulatory developments. Significant issues include OECD Pillars One and Two, global intangible low-taxed income (GILTI), base erosion and anti-abuse tax (BEAT), foreign-derived intangible income (FDII), foreign tax credits, debt versus equity, the deductibility of research expenses, interest limitations, mark-to-market on financial products, Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard, Build Back Better Act and Inflation Reduction Act.

Alan I. Appel, Esq., Professor of Law | New York Law School

Alan I. Appel specializes in international and domestic tax planning involving taxation of mergers and acquisitions, partnerships, joint ventures, and limited liability companies, as well as tax controversy matters. Prior to joining New York Law School, Professor Appel began his career as a trial attorney in the Office of Chief Counsel, Internal Revenue Service in Washington, D.C. and New York City. On behalf of the American Bar Association (ABA) Tax Section, Professor Appel had the primary responsibility for drafting and submitting comments to the U.S. Treasury Department and IRS concerning the scope of the guidance provided by proposed regulations under Section 1446 of the Internal Revenue Code. He was also asked by the Office of the Chief Counsel to train its attorneys on this issue. Professor Appel published four articles on the Section 1446 regulations in The Journal of International Taxation,Tax Management Memorandum, and the Tax Management International Journal.

Michael J. Miller, Esq., Partner | Roberts & Holland

Working with foreign clients, he has structured inbound U.S. investments and operations to avoid the creation of a U.S. permanent establishment and developed structures designed to take advantage of U.S. income tax treaties, the withholding tax exemption for portfolio interest, and other special rules for minimizing U.S. tax. This includes consideration of various anti-abuse rules, such as earnings-stripping limitations and restrictions on the ability to engage in treaty shopping or earn income through hybrid entities. He has worked with U.S. multinationals to structure their foreign investments and operations so as to minimize the impact of certain restrictions on outbound transfers and anti-deferral rules applicable to shareholders of controlled foreign corporations and passive foreign investment companies, as well as maximize the utilization of foreign tax credits.

Joseph M. Calianno, JD, LLM, MBA, CPA, Managing Director; National Tax Practice | Andersen Tax

Joe Calianno is a managing director in the US National Tax practice in the Washington D.C. office and serves as the USNT leader for international tax. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act and cross-border restructuring. Before joining Andersen, Joe was a partner at both BDO and Grant Thornton, where he served as the International Technical Tax Practice Leader in both firm’s national tax offices.

William S. Dixon, Esq., Managing Director, Mergers and Acquisitions | Citigroup Global Markets

Will is an investment banker and Managing Director at Citigroup Global Markets Inc., where he focuses on tax-advantaged domestic and cross-border M&A transactions, capital structure solutions and financings for public and private companies, including mergers, acquisitions, spin-offs and other divestitures, buy-outs, and SPAC transactions. He also is a member of the firm’s Fairness Opinion Committee.

Sam K. Kaywood, Esq., Senior Counsel | Alston & Bird

Sam Kaywood is senior counsel in the Federal & International Tax Group and a co-chair of the International Team. Sam concentrated his practice on federal income tax and international tax, including cross-border M&A and joint ventures, as well as in-bound investments into the U.S. Sam worked on virtually all forms of cross-border investments, with substantial experience in Canada, Europe, China, and Latin America. He was particularly active in structuring investments and acquisitions in Latin America, including Brazil, Mexico, Argentina, and Chile.

William B. Sherman, Esq., Partner | Holland & Knight

William B. Sherman is a partner in Holland & Knight’s Miami and Fort Lauderdale offices. Mr. Sherman concentrates his practice in the area of domestic and international taxation. He provides sophisticated tax planning for mergers and acquisitions, restructurings, joint ventures and investments for clients in diverse industries, such as private equity, healthcare, hospitality, petrochemicals, aluminum, real estate, transportation, telecommunications, retailing, investment management, pharmaceuticals and numerous others. In addition, Mr. Sherman has experience in a broad range of transactions involving United States investment overseas, foreign investment in the U.S., as well as international, federal, state and local taxation issues involving structuring investment management funds, corporate reorganizations, partnerships, equipment leasing, Subchapter S, executive compensation, stock options, and trusts and estates.

David M. Rievman, Esq., Partner | Skadden, Arps, Slate, Meagher & Flom

David Rievman advises U.S. and international clients with respect to the tax aspects of complex transactions, including U.S. and cross-border mergers and acquisitions, financings, divestitures (including spin-offs), financial restructurings and recapitalizations, joint ventures and other business transactions.

Alexander Lee, Esq., Partner | Cooley

Xander is regularly recognized by publications such as Chambers Global and The Legal 500 as one of the top US practitioners for international tax issues. He is described by clients as “very detailed in his descriptions and his explanations, very thorough, he anticipates the types of issues we need to be aware of.” In addition, Xander is ranked highly for his domestic corporate taxation work by Chambers USA and The Legal 500 US. The Los Angeles County Bar Association’s Taxation Section selected Xander as the recipient of its 2021 Dana Latham Memorial Award for his outstanding contribution to the community and to the legal profession in the taxation field, making him the youngest practitioner to receive the prestigious award.

Trevor R. Allen, Esq., Partner | Skadden, Arps, Slate, Meagher & Flom

Trevor Allen is the head of Skadden’s New York Tax Group. He advises clients on a broad range of U.S. tax matters, including the tax aspects of mergers and acquisitions, spin-offs, joint ventures, investment fund formations, foreign investments in the U.S., transactions involving REITs, and IPOs, including “UP-C” IPOs. He also has experience with tax controversies and obtaining private letter rulings from the IRS.

Joe Soltis, Esq., Partner | Freshfields

Joe is a tax partner based in our New York office. Joe represents clients across multiple industries on US tax aspects of transactional deals, including domestic and cross-border taxable and tax-free mergers and acquisitions, spin-offs, recapitalizations, financing arrangements, investments, partnerships and joint ventures, bankruptcy reorganizations, and securities issuances.

Myra A. Sutanto Shen, Esq., Partner | Wilson Sonsini

Myra Sutanto Shen is a tax partner in the Palo Alto office of Wilson Sonsini and the head of the firm’s tax practice group. Myra represents technology and life science companies in connection with all aspects of U.S. federal income tax planning. She has extensive experience advising public and private companies in all corporate transactions, including domestic and cross-border mergers and acquisitions, equity and debt financings, IPOs and convertible note offerings, and corporate restructurings. Myra also advises founders, investors, and companies regarding the “qualified small business stock” exemption under Section 1202 of the Internal Revenue Code.

Timothy Shapiro, Esq., Partner | Cooley

Tim Shapiro advises public and private companies on tax aspects of a variety of domestic and cross-border transactional matters, including mergers and acquisitions, reorganizations, debt and equity financings, and the formation and operation of limited liability companies and other passthrough entities.

Karen Gilbreath Sowell, Esq., Principal | Ernst & Young

Karen is a Principal in Ernst & Young LLP National Tax Department. Based in Washington, D.C., she serves as EY Global Transaction Advisory Leader and Co-leader of the National Tax Mergers and Acquisitions Group. She also served as the US Treasury Department’s Deputy Assistant Secretary for Tax Policy from 2007 to 2009, during the global financial crisis and Associated Tax Legislative Counsel for Tax Policy and Attorney Advisor from 1997-2001. Her primary responsibility for corporate tax legislative and regulatory matters. Karen served as the Chair of the New York State Bar Association Tax Section in 2018.

Jodi J. Schwartz, Esq., Partner | Wachtell, Lipton, Rosen, and Katz

Jodi J. Schwartz focuses on the tax aspects of corporate transactions, including mergers and acquisitions, joint ventures, spin-offs and financial instruments. Ms. Schwartz has been the principal tax lawyer on numerous domestic and cross-border transactions in a wide range of industries. She was elected partner in 1990. Ms. Schwartz received her B.S. in Economics magna cum laude from the University of Pennsylvania in 1981, her M.B.A. from the University of Pennsylvania (Wharton School) in 1984, her J.D. magna cum laude from the University of Pennsylvania Law School in 1984 and her LL.M. in taxation from the New York University Law School in 1987.

Lulu Ma, Esq., Principal, National Tax M&A Group | Ernst & Young

Lulu Ma is a Principal in Ernst & Young LLP’s National Tax Department. Based in Los Angeles, Lulu provides services related to the federal income taxation of corporations, including mergers, acquisitions, spin-offs, corporate restructurings, consolidated return issues, and cross-border transactions. Lulu received a B.A. from the University of Virginia, a J.D. from Emory University School of Law, and a LL.M. from the Georgetown University Law Center.

Isaac J. Wheeler, Esq., Partner | Sullivan & Cromwell

Isaac Wheeler is Co-Head of the Firm’s Tax Group. He represents a wide range of clients, including financial institutions and other multinational corporations, asset managers, real estate developers, and private individuals. Mr. Wheeler works on M&A, real estate, joint venture, hedge fund, private equity, and partnership transactions. He also regularly works with S&C’s Estates and Personal Group in advising families and individuals in connection with their estate planning transactions and their worldwide investments, including potential redomiciliation and the attendant tax consequences.

William Alexander, Esq., Of Counsel | Skadden, Arps, Slate, Meagher & Flom

Mr. Alexander formerly served as associate chief counsel (corporate) of the Internal Revenue Service’s Office of Chief Counsel. He had been with the Office of Chief Counsel since 1990, serving as associate chief counsel (corporate) since November 2001. In this role, he was the chief adviser to the IRS on interpretations of the corporate tax laws, such as provisions dealing with corporate mergers and acquisitions, spin-offs, corporate-shareholder relationships, the use of corporate losses and consolidated returns of corporate groups. Mr. Alexander played a major role in the government’s development of published and private guidance, and in developing and implementing the IRS’ enforcement positions in these areas.

Lewis R. Steinberg, Esq.

Lew Steinberg retired as a Managing Director-Mergers and Acquisitions and Head of Structured Solutions in the Global Corporate and Investment Bank of BofA Securities in March 2023. Lew joined Bank of America in May 2015, focusing on tax, legal and accounting structuring with respect to mergers and acquisitions and selected capital markets transactions. Prior to May 2015, Lew was Managing Director and Head of Strategic Advisory in the Mergers and Acquisitions group of Credit Suisse (USA) LLC, which he joined in

July 2010. Prior to Credit Suisse, Lew was Managing Director and Global Head of the Strategic Solutions Group in the Investment Banking Department at UBS Securities LLC, which he joined in January 2005.

Anne Kim, Esq., Partner | Kirkland & Ellis

Anne Kim is a tax partner in the Los Angeles office of Kirkland & Ellis LLP. Anne’s practice focuses on advising public and private companies in both taxable and tax-free mergers and acquisitions, divestitures, cross-border transactions, recapitalizations and formation of joint ventures. She has significant experience representing private equity firms and asset managers in all aspects of transactions, including secondaries transactions, liquidity solutions for private fund sponsors and asset management M&A. She also advises clients on the tax aspects of capital markets transactions and debt restructurings.

Andrea M. Whiteway, Esq., Principal | Ernst & Young

Over 30 years of experience in sophisticated tax planning involving the use of partnerships, including in the dispositions and acquisitions of real estate and operating businesses, complex partnership transactions, real estate investment trust (REIT) tax status and tax structured dispositions of real estate involving REITs, corporate acquisitions and mergers, corporations and structuring private REITs. She has extensive experience advising clients on bankruptcy related tax issues, workouts and restructurings.

Ryan P. McCormick, Esq., Senior Vice President & Counsel | The Real Estate Roundtable

Ryan McCormick is Senior Vice President and Counsel at The Real Estate Roundtable, where he is responsible for managing the organization’s tax policy activities. Ryan coordinates the Roundtable’s Tax Policy Advisory Committee, a group of 150 leading real estate tax experts, including in-house tax directors, general counsel, and chief financial officers of Roundtable members and senior partners from national law and accounting firms.

Robert D. Schachat, Esq., Managing Director | BDO USA

Bob has more than 40 years’ experience advising clients in all federal income tax aspects of real estate, including REIT, partnership, limited liability company and S corporation formations, acquisitions, like-kind exchanges, development, leases, financings, workouts, dispositions and liquidations. He has also advised clients on a regular basis in monitoring federal legislative and regulatory activity in the real estate area.

Lou Weller, Esq. | Weller Partners

Lou Weller leads firm’s real estate, transactions and tax practice. He previously served as National Director of Real Estate Transaction Planning and National Director, Like Kind Exchange Services at Deloitte Tax LLP and was Of Counsel to the national law firm, Bryan Cave LLP. Lou has practiced tax and business law for more than 40 years. He has extensive experience designing and implementing strategies for real estate and business asset acquisitions, transfers, exchanges, leases, financing, work-outs, business start-ups, limited liability companies, partnership and joint venture formations, transactions involving REITs, capital raising through placement of partnership interests and stock, as well as counseling clients on achieving business and personal tax planning objectives. He also owned and for more than 20 years operated a like kind exchange qualified intermediary business.

Andrew Weiner, Esq., Counsel | Kostelanetz

Andy has handled a wide diversity of matters in such areas as partnership taxation, corporate taxation and reorganizations, taxation of S corporations, tax accounting methods, income tax, gift and estates taxes, and collections. He combines a deep knowledge of tax law with extensive litigation and administrative practice experience.

James O. Lang, Esq., Shareholder | Greenberg Traurig

James O. Lang focuses his tax and corporate project finance practice on tax incentive programs, Qualified Opportunity Zone and Qualified Opportunity Fund financing, tax credits, and related state and federal incentive programs. Jim is closing over $15 billion of Qualified Opportunity Funds and ancillary Qualified Opportunity Zone deployment of funds and has closed or is structuring several billion dollars in tax credit incentivized transactions. Jim and his team have accomplished more than 750 QOZ deployments and more than 300 captive QOF formations for high-net-worth individuals and family offices.

Sanford C. Presant, Esq., Shareholder | Greenberg Traurig

Sanford C. Presant, Co-Chair of the firm’s Global Real Estate Fund Practice, focuses his practice on providing fund and joint venture best practice business and tax structuring advice to sponsors of the leading real estate private equity funds, qualified opportunity zone (QOZ) funds, REITs, and their local partners and investors in the U.S. and internationally.

Adam S. Feuerstein, Esq., Principal | PwC US Tax

Adam is the National Real Estate Tax Technical Leader at PricewaterhouseCoopers, LLP and, in that role, he helps clients navigate the complicated tax world in which we live. Adam brings his experience and passion (yes, passion for tax) to help clients see the big picture from a tax perspective, while at the same time keeping an eye on the important details necessary to achieve the client’s particular objectives. Clients often comment that Adam has a keen ability to convey complicated tax concepts and that he is approachable and easy to work with.

Kelsey Lemaster, Esq., Partner | Goodwin Procter

Kelsey Lemaster is Co-Chair of Goodwin’s Tax practice. His practice includes mergers and acquisitions, fund formations, private equity and venture capital investment structuring, QSBS, transactions and tax planning matters for blockchain companies, real estate and venture capital fund formations, private equity and venture capital investment structuring, REITs, real estate and related transactions, and joint venture and other partnership transactions.

Larry J. Brant, Esq., Shareholder | Foster Garvey PC

Larry is Chair of the Foster Garvey Tax & Benefits practice group. He is licensed to practice in Oregon and Washington. Larry’s practice focuses on assisting public and private companies, partnerships, and high-net-worth individuals with tax planning and advice, tax controversy, and business transactions. He regularly advises clients in entity selection and formation, structuring mergers and acquisitions, joint ventures and other business transactions.

Ronald A. Levitt, Esq., Shareholder | Dentons Sirote

Ronald Levitt is a shareholder in Dentons Sirote’s Birmingham, Alabama office, where he is a member of the Tax practice group and leads the Dentons Sirote Conservation Easement team. His practice focuses on federal and state controversy matters, including planning and defending conservation easements. Additionally, his practice focuses on business and tax planning, particularly for closely-held and family-owned businesses. Specifically, he counsels clients in business, succession, estate, and charitable deduction planning; entity formation; representation of S corporations, limited liability companies, and other flow-through entities; mergers and acquisitions; purchases and sales of businesses; and healthcare law by representing physician practices. Ronald frequently speaks at numerous tax clinics, conferences, forums, institutes, programs, seminars, and societies across the nation.

Stephen R. Looney, Esq., Shareholder | Dean Mead

Steve is the Chair of the firm’s Corporate and Tax Department. He represents clients in a variety of business and tax matters including entity formation (S and C corporations, partnerships, and LLCs), acquisitions, dispositions, redemptions, liquidations, reorganizations, tax-free exchanges of real estate and tax controversies. His clients include closely held businesses, with an emphasis on medical and other professional practices. He is a former Chair of the S Corporations Committee of the American Bar Association’s Tax Section. He is Board Certified in Tax Law by The Florida Bar, as well as being a Certified Public Accountant (CPA).

Stephen M. Breitstone. Esq., Partner | Meltzer. Lippe, Goldstein & Breitstone

Stephen M. Breitstone is Chair of the firm’s Private Wealth and Taxation Practice Group. His approach combines business planning and income, estate and gift tax planning with a special emphasis on real estate. His clients include domestic and international real estate owners and developers, closely held businesses, public companies, private equity funds, trusts and estates, and charitable organizations. His combination of skills as a transactional and income tax attorney and as an estate planner enables him to effectively advise clients on their individual needs and those of their businesses.

Jerome M. Hesch, Esq., Counsel | Meltzer, Lippe, Goldstein & Breitstone

Jerome M. Hesch is Counsel to the firm’s Business & Real Estate Taxation, Trusts & Estates, Tax Exempt Organizations and Private Wealth & Taxation Practice Groups. Prior to joining the firm, Jerry served as an income tax and estate planning consultant for lawyers and other tax planning professionals throughout the country. Jerry was a consultant for Meltzer, Lippe, Goldstein & Breitstone, LLP, Dorot & Bensimon PL, Jeffrey M. Verdon Law Group and Oshins & Associates LLC.

Terence Floyd Cuff, Esq., Of Counsel | Loeb & Loeb

Terry Cuff has more than 44 years of experience in the areas of partnership taxation, real estate taxation, and taxation of real estate investment trusts. Terry is also the author of a treatise on tax problems related to drafting partnership agreements, partnership tax, and related issues, Drafting and Understanding Partnership and LLC Allocation and Distribution Provisions, 2022 ed. (Thomson Reuters). Additionally, Terry is experienced in utilizing Excel to solve advanced tax and finance problems.

Jerald David August. Esq., Shareholder | August Tax Law, PC

Mr. August has served as chair and co-chair of the tax law departments of two Am Law 200 law firms and as a partner in both national and regional tax law firms and in a tax litigation boutique. He now announces the opening of August Tax Law, P.C., located in Blue Bell, PA, a suburb of Philadelphia located near Valley Forge, PA. For the past five years, Mr. August served as Co-Chair of the International Tax and Wealth Planning Group for Fox Rothschild, LLP. Before Fox, he was a partner at two national tax law firms: Houston- based Chamberlain Hrdlicka and Kostelanetz & Fink in New York City. Mr. August was the majority shareholder in the tax law firm of August, Kulunas, Dawson & Siegel, P.A., in West Palm Beach, Florida, which he started in 1988 after serving as co-chair of the Tax Department of the Miami-based firm of Steel Hector & Davis. In 2005, he merged his firm with Fox Rothschild and worked from the firm’s Philadelphia and West Palm Beach locations. He spent 10 years as a partner and co-chair of the Taxation and Wealth Planning Department and chair of the firm’s Tax Opinions Committee of Fox Rothschild before joining Kostelanetz & Fink. Per the photos on the home page, Mr. August continues to represent major clients from South Florida, the Philadelphia tri-state area, and New York.

C. Wells Hall, Ill, Esq., Partner | Nelson Mullins Riley & Scarborough

Wells advises clients on the federal, state, and multi-state tax aspects of acquisitions, reorganizations, restructuring of business entities, and private equity transactions, and estate and gift tax planning in connection with such transactions.

Bryan C. Skarlatos, Esq., Partner | Kostelanetz

For more than thirty-five years, Bryan C. Skarlatos has represented corporations and individuals in sensitive matters, many of which involve negotiation or litigation with government agencies. He is internationally recognized for his work on tax controversies, audits, appeals and litigation, criminal tax investigations, and white-collar criminal prosecutions. Bryan also has an active practice providing tax and estate planning advice.

Michel R. Stein, Esq., Principal | Hochman Salkin Toscher Perez

MICHEL R. STEIN is a principal at Hochman Salkin Toscher Perez P.C. specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters.

G. Michelle Ferreira, Esq., Managing Shareholder | Greenberg Traurig

Michelle Ferreira is Executive Vice President, Co-Chair of the Global Tax Practice, and Co-Managing Shareholder of the San Francisco and Silicon Valley offices. She counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the California Department of Tax and Fee Administration, the Employment Development Department and county assessment appeals boards.

Joshua E. Husbands, Esq., Partner | Holland & Knight

Joshua E. Husbands is the executive partner of Holland & Knight’s Portland office and a member of the firm’s Private Wealth Services Group. He often serves as outside general counsel for private companies and their owners, representing clients in an array of business, tax, philanthropy, business succession and estate planning matters, including business reorganizations, acquisitions and divestitures. He frequently writes and speaks on business, tax, life insurance and asset protection matters concerning businesses and high-net-worth individuals.

Gary L. Fletcher, Esq., Senior Partner | Frazer Ryan Goldberg & Arnold

Gary L. Fletcher joined Frazer Ryan Goldberg & Arnold LLP as a Senior Partner in 2024 after 35 years practicing at Nystedt & Fletcher PLLC. He is both an Attorney and a CPA.

Gary is a Fellow of the American College of Trust and Estate Counsel (ACTEC), where he serves as a member of the Asset Protection and Fiduciary Income Tax Committees. His practice focuses on estate, gift, and income taxation, with a concentration in wealth and estate planning and preservation, tax, trust formation and administration, charitable gift planning, complex business transactions and trust, probate, and select commercial litigation, including mediation, alternative dispute resolution and representation before state and federal courts and administrative agencies.

Brian G. Smith, Esq., Shareholder | Greenberg Traurig

Brian G. Smith advises ultra-high-net-worth clients on estate and tax planning, trust administration, litigation, family law, and charitable giving. With deep insight into complex tax planning strategies, Brian advises his clients on dynasty trusts, grantor retained annuity trusts, qualified personal residence trusts, and life insurance trusts. Brian counsels clients with the goal of lessening the wealth transfer tax involved when transferring wealth to the next generation. He also creates traditional wills, revocable trusts, and limited liability companies in accordance with his clients’ estate plans.

Stacia C. Kroetz, Esq., MBA, CPA, Managing Director; Senior Wealth Planner | Brown Brothers Harriman & Co.

Stacia Kroetz leads the Wealth Planning team in the New York Multi-Family Office of BBH, advising families and business owners on matters relating to tax and estate planning, philanthropy, business succession, and the preservation of wealth for future generations. Prior to joining the firm, Stacia was in private legal practice in the Trusts and Estates department at Seward & Kissel LLP, where she focused on estate, gift, and generation-skipping transfer tax planning. Earlier in her career, she was an auditor at KPMG.

Elizabeth Garlovsky, Esq., Partner | Harrison

Elizabeth (“Lizzy”) Garlovsky represents clients in matters related to estate planning and wealth transfer, probate, and estate and trust administration. She brings over 25 years of combined experience in private practice, the public sector, and as a wealth advisor for JPMorgan. Lizzy assists clients in preparing and implementing estate plans for a wide range of individuals and families. She also helps both individual and corporate executors and trustees administer trusts and estates at any stage, including through controversies both inside and outside of court. In addition, Lizzy frequently counsels heirs, legatees, and beneficiaries of estates and trusts of all sizes to advocate for their rights under will and trust documents or when no documents exist.

Keri D. Brown, Esq., Partner | Baker Botts, Houston

A trusted advisor to some of the nation’s most prominent individuals, Keri Brown assists her clients on complex federal estate, gift and income tax litigation and controversy matters, including disputes and litigation with the Department of Justice and the Internal Revenue Service. She counsels high net worth individuals and families in a variety of courts, including in the United States Tax Court, United States District Courts and United States Courts of Appeals. She represents taxpayers in federal tax audits and administrative appeals, and represents fiduciaries and beneficiaries of trusts and estates in state courts with respect to administration and fiduciary duty issues. She also assists businesses and individuals in preparing for and navigating the litigation process in tax matters.

DAY 1: SUNDAY, NOVEMBER 16, 2025

CURRENT DEVELOPMENTS | 1:45pm – 2:00pm

Chair: Jennifer Acuña, Esq., Principal, Federal Tax Legislative and Regulatory Services, KPMG, Washington, DC

LEGISLATIVE UPDATE | 2:00pm – 3:15pm
A review of legislation enacted, considered and pending in the current congressional session.

Jennifer Acuña, Esq., Principal, Federal Tax Legislative and Regulatory Services, KPMG, Washington, DC
Daniel J. Winnick, Esq., Principal, International Tax, KPMG, Washington, DC

THE TREASURY AGENDA | 3:15pm – 4:05pm
A review of recently issued and pending Treasury guidance.

US Department of the Treasury Representatives will be invited to attend

Break | 4:05pm – 4:15pm

CURRENT IRS ENFORCEMENT EFFORTS AND THE PATH AHEAD | 4:15pm – 5:45pm

Overview of current IRS enforcement priorities, defensive strategies and dispute resolution opportunities.

The IRS is at a historic crossroads facing significant budget reductions and declining staff levels. Practical “in the tax trenches” advice on current and anticipated future IRS enforcement efforts providing context for the many challenges ahead focusing on various IRS Compliance Campaigns, high-income and high-wealth individuals and their related entities, digital assets, corporations, partnerships, other current IRS priorities.

Moderator: Cory Stigile, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA
Chad D. Nardiello, Esq., Partner, Nardiello Turanchik Tompkins, Los Angeles, CA
David B. Porter, Esq., Law Offices of David B. Porter, PC, San Francisco, CA
Brian A. Sullivan, CPA/ABV, President & CEO, Sullivan & Company CPA, Burlingame, CA

FROM THE FORMER OPR DIRECTOR: PROFESSIONAL RESPONSIBILITY ISSUES IN YOUR TAX PRACTICE | 5:45pm – 6:45pm

An open discussion with meaningful, practical advice regarding the many ethical and professional challenges that arise when representing taxpayers in a dispute with the IRS. Learn how to protect yourself . . . and your client.

Sharyn M. Fisk, Esq., former Director, IRS Office of Professional Responsibility; Associate Professor, Cal Poly Pomona, Pomona, CA

Break | 6:45pm – 6:55pm

UNDERSTANDING TRUMP ACCOUNTS | 6:55pm – 8:00pm

This topic is an overview of Trump Accounts, added by the One Big Beautiful Bill Act, that are a new form of IRA that is available for children for tax-free savings. The overview includes a discussion of the key features of the account and how they are established. This focuses on a review of the parameters for establishing an account (including investment restrictions), the types of contributions that can be made to the account (including employer contributions), and distributions permitted under the accounts. The presenters also take a look at IRS private letter ruling 202434006 that permits employees to allocate an employer contribution among various benefits outside of a cafeteria plan. Specifically, this ruling permits a choice between a DC plan contribution, a retiree HRA contribution, a health savings account contribution, and a student loan payment under a qualified educational assistance program.

Elizabeth Thomas Dold, Esq., Principal, Groom Law Group, Chartered, Washington, DC
J. Rose Zaklad, Esq., Principal; Tax Practice Leader, Groom Law Group, Chartered, Washington, DC

TAX DEDUCTIONS FOR QUALIFIED OVERTIME COMPENSATION, AND THE COMPLICATIONS FOR EMPLOYER REPORTING AND WITHHOLDING | 8:00pm – 9:00pm

This topic covers one of the cornerstone provisions in the One Big Beautiful Bill Act, and provides both an overview and detailed explanation of how the QOC Deduction may impact payroll processes, and proactive steps to ensure compliance with the new Internal Revenue Code Section 225. This session will help anyone looking to navigate the nuances of the QOC Deduction and avoid employee confusion and potential penalties for noncompliance. Topics covered include an overview of the QOC Deduction standards (including eligibility criteria and deduction limitations), suggested employee communication strategies for human resources and payroll departments, regulatory guidance, including future guidance on QOC reporting from the IRS and state tax authorities, and implementation of payroll and tax reporting systems updates for Form W-2 reporting of QOC to employees in 2026 and beyond.

Steven P. Johnson, Esq., Partner, Morgan, Lewis & Bockius, Washington, DC

DAY 2: MONDAY, NOVEMBER 17, 2025

THE INTERNATIONAL TAX CHANGES IN THE OBBB | 11:25am – 1:00pm

This segment provides an overview of the international tax changes contained in the OBBB, including modifications to GILTI, FDII, and the BEAT. Also, while depreciation and amortization were restored to Section 163(j), other changes to adjusted taxable income make the limitation potentially worse for global businesses. We discuss provisions that did not make it into the bill (e.g., Section 899, high tax exception to the BEAT) and the status of Pillar Two in light of the G7 announcement.

Joshua Odintz, Esq., Partner, Holland & Knight, Washington, DC

Break | 1:00pm – 1:15pm

PLANNING FOR FOREIGN INVESTMENT IN US REAL ESTATE IN THE POST-OBBB ERA | 1:15pm – 2:45pm

The session includes a special focus on planning for investment in US real estate by foreigners following the enactment of the OBBB. It addresses the US income tax rules and “FIRPTA” regime applicable to foreign persons who invest in and dispose of US real property interests (USRPIs). The topics covered include the definition of USRPI, the withholding rules applicable to purchasers of USRPIs, additional requirements for tax-free treatment for exchanges that otherwise qualify for nonrecognition, and treaty planning, as well as various exceptions and other special rules. The special rules discussed include exceptions for interests in publicly traded companies and domestically controlled REITs, as well as for investments by qualified foreign pension funds and foreign sovereign investors.

Alan I. Appel, Esq., Professor of Law, New York Law School, New York, NY
Michael J. Miller, Esq., Partner, Roberts & Holland, New York, NY

Lunch | 2:45pm – 4:00pm

CONTROLLED FOREIGN CORPORATION PLANNING: WHAT’S NEW AFTER THE OBBB | 4:00pm – 5:45pm

The OBBB made substantial changes to the rules that impose US taxation of US shareholders of CFCs. This session addresses how those changes affect planning opportunities and traps for the unwary. Some of the topics discussed include changes made to the rules relating to how US shareholders determine their pro rata share of subpart F income and GILTI (renamed net CFC tested income under the OBBB), the reinstatement of Section 958(b)(4) which prohibits downward attribution from a foreign person to a US person under the constructive ownership rules, a new provision, Section 951B, which provides for CFC inclusions in the case of certain ownership structures, and the various changes to the GILTI regime, including corresponding foreign tax credit changes. This session also discusses how the subpart F and GILTI rules apply in certain partnership structures. Finally, the session explores the application of certain exceptions to subpart F income (e.g., the CFC look through rule of Section 954(c)(6), the active rent and royalty exception, and the high-tax exception) as well as certain exceptions relating to GILTI regime (e.g., the high tax exception).

Joseph M. Calianno, JD, LLM, MBA, CPA, Managing Director; National Tax Practice, Andersen Tax, Washington, DC

Break | 5:45pm – 6:00pm

INTERNATIONAL MERGERS AND ACQUISITIONS: US TAX CONSIDERATIONS AND PLANNING TECHNIQUES | 6:00pm – 8:00pm

The OBBB made significant changes to the CFC rules and other rules that affect cross border mergers and acquisitions. This session covers the US tax considerations for taxable and tax-free stock acquisitions of foreign companies, CFC issues, tax-free acquisitions of US companies, planning for the use of holding companies, inversion transactions, debt-equity regulations, use of hybrid instruments, OECD BEPS issues, in view of the OBBB changes.

William S. Dixon, Esq., Managing Director, Mergers and Acquisitions, Citigroup Global Markets, New York, NY
Sam K. Kaywood, Esq., Senior Counsel, Alston & Bird, Atlanta, GA
William B. Sherman, Esq., Partner, Holland & Knight, Fort Lauderdale, FL

Break | 8:00pm – 8:15pm

FUNDAMENTALS OF CORPORATE TAX | 8:15pm – 9:55pm

This session provides useful background that is helpful for attendees who do not have extensive experience in corporate taxation.

David M. Rievman, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom, New York, NY
Alexander Lee, Esq., Partner, Cooley, Los Angeles, CA

DAY 3: TUESDAY, NOVEMBER 18, 2025

OPPORTUNITIES AND CHALLENGES IN SUB-C / SUB-K HYBRID STRUCTURES | 11:25am – 1:00pm

This panel focuses on the significant planning opportunities to use partnerships in corporate transaction planning, including in structuring and integrating mergers and acquisitions, capital markets transactions and compensation arrangements.

Trevor R. Allen, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom, New York, NY
Joe Soltis, Esq., Partner, Freshfields, New York, NY

Break | 1:00pm – 1:15pm

SECTION 1202 QUALIFED SMALL BUSINESS STOCK – PLANNING POST- OBBBA | 1:15pm – 2:30pm

Qualified Small Business Stock (QSBS) can be a powerful planning tool when used correctly. Our panelists discuss the benefits and requirements of Section 1202 including important changes introduced by the 2025 OBBBA.

Myra A. Sutanto Shen, Esq., Partner, Wilson Sonsini, Palo Alto, CA
Timothy Shapiro, Esq., Partner, Cooley, Palo Alto, CA

Lunch | 2:30pm – 4:00pm

DEVELOPMENTS IN TAX FREE SPIN-OFFS | 4:00pm – 5:15pm

Section 355 of the Internal Revenue Code provides an intricate and complex framework for separating businesses owned by a single corporation on a tax-free basis. These rules recently have been the subject of significant changes and proposed changes, leaving practitioners and the IRS to find their way through the thicket. With the number of spinoff transactions continuing to accelerate, our panelists discuss the latest developments in this important market.

Karen Gilbreath Sowell, Esq., Principal, EY, Washington, DC
William S. Dixon, Esq., Managing Director, Mergers and Acquisitions, Citigroup Global Markets, New York, NY
Jodi J. Schwartz, Esq., Partner, Wachtell, Lipton, Rosen, and Katz, New York, NY
Lulu Ma, Esq., Principal, National Tax M&A Group, EY, Los Angeles, CA

CORPORATE TAX PLANNING IN THE NEW JUDICIAL, REGULATORY AND ENFORCEMENT ENVIRONMENT | 5:15pm – 6:30pm

Over the past few years, there have been historically significant changes in the tax law emanating from the courts, the Treasury department and the IRS. Our panelists explore the impact of these changes and an uncertain regulatory climate on corporate tax planning.

Isaac J. Wheeler, Esq., Partner, Sullivan & Cromwell, New York, NY

Break | 6:30pm – 6:45pm

HOT TOPICS IN CORPORATE TAX | 6:45pm – 8:00pm

The panelists discuss recent developments in corporate taxation over the past year.

William Alexander, Esq., Of Counsel, Skadden, Arps, Slate, Meagher & Flom, Washington, DC
Alexander Lee, Esq., Partner, Cooley, Los Angeles, CA
Lewis R. Steinberg, Esq., New York, NY
Anne Kim, Esq., Partner, Kirkland & Ellis, Los Angeles, CA

Break | 8:00pm – 8:15pm

FUNDAMENTALS OF PARTNERSHIP AND REAL ESTATE TAXATION | 8:15pm – 9:55pm

This session provides useful background that is helpful for attendees who do not have extensive experience in the taxation of partnerships and real estate.

Andrea M. Whiteway, Esq., Principal, EY, Washington, DC

DAY 4: WEDNESDAY, NOVEMBER 19, 2025

HOT TOPICS IN PARTNERSHIP AND REAL ESTATE TAXATION: LEGISLATIVE AND REGULATORY DEVELOPMENTS | 11:25am – 1:15pm

An overview of the recently enacted One Big Beautiful Bill and other recent and pending developments

Ryan P. McCormick, Esq., Senior Vice President & Counsel, The Real Estate Roundtable, Washington, DC
Andrea M. Whiteway, Esq., Principal, EY, Washington, DC

Break | 1:15pm – 1:30pm

HOT LIKE-KIND EXCHANGE ISSUES | 1:30pm – 2:30pm

Related party exchanges; build to suits, reverse exchanges and parking arrangements within and outside the safe harbor; exchanges involving partnerships and trusts; exchanges of property into and out of foreclosure; recent developments on what constitutes “like kind”; other current issues including legislative outlook.

Robert D. Schachat, Esq., Managing Director, BDO USA, Washington, DC
Lou Weller, Esq., Weller Partners, Sausalito, CA

MERGERS IN A BUBBLE | 2:30pm – 3:30pm

This panel explores the partnership merger rules where taxpayers attempt to combine business lines, assets, or partners. The panel analyzes fact patterns where the merger tax treatment may be impacted by subsequent transactions.

Andrea M. Whiteway, Esq., Principal, EY, Washington, DC

Lunch | 3:30pm – 4:45pm

NUTS AND BOLTS OF A PARTNERSHIP BBA AUDIT | 4:45pm – 5:45pm

IRS audits under the BBA partnership audit rules are well underway. This panel discusses how the BBA rules are being implemented by the IRS, considerations associated with whether to make a Section 6226 push out election, and administrative adjustment requests.

Andrew Weiner, Esq., Counsel, Kostelanetz, Washington, DC

QUALIFIED OPPORTUNITY FUNDS: NEW AND EXPANDED OPPORTUNITIES | 5:45pm – 6:45pm

This panel discusses current tax planning for investments in qualified opportunity funds as well as explores the changes made to the program under the new qualified opportunity fund legislation.

James O. Lang, Esq., Shareholder, Greenberg Traurig, Tampa, FL
Sanford C. Presant, Esq., Shareholder, Greenberg Traurig, Los Angeles, CA

Break | 6:45pm – 7:00pm

STRUCTURING FOR INBOUND INVESTMENT IN US REAL ESTATE | 7:00pm – 8:00pm

This presentation discusses structures to own US real estate in a tax efficient manner, special concerns when a non-US person becomes a partner in a partnership or investment fund owning US real estate or mortgage debt and use of related party debt to reduce US tax exposure.

Adam S. Feuerstein, Esq., Principal, PwC US Tax, Washington, DC
Kelsey Lemaster, Esq., Partner, Goodwin Procter, San Francisco, CA

DAY 5: THURSDAY, NOVEMBER 20, 2025

SUBCHAPTER S: A MAGICAL MYSTERY TOUR THROUGH SUBCHAPTER S REVISITED | 11:25am – 12:40pm

This discussion covers many of the not so obvious provisions of the Code and Regulations that impact Subchapter S corporations and their Shareholders, including late or unfiled elections, eligibility, conversions, and tax allocations.

Larry J. Brant, Esq., Shareholder, Foster Garvey PC, Portland. OR

Break | 12:40pm – 12:50pm

ENTITY CONVERSIONS UNDER CHECK THE BOX, STATE LAW CONVERSION STATUTES, STATE LAW MERGER STATUTES AND MANUAL CONVERSIONS | 12:50pm – 2:00pm

With the advent of the check the box regulations, state formless conversion statutes and state cross-entity merger statutes, converting from one type of entity to another can be easily accomplished. However, this ease of conversion from one type of entity to another can be a trap for the unwary. This presentation examines the tax consequences of changing from one form of entity to another under the various methods available, including conversions of sole proprietorships into corporations, the incorporation of a partnership, the conversion of a corporation into a sole proprietorship or a single-member LLC that is a disregarded entity, the conversion of a corporation into a partnership, the conversion of a disregarded entity into a partnership, the conversion of a partnership into a disregarded entity and the conversion of a C corporation into an S corporation. In addition to highlighting the tax consequences of each of these transactions, the specific pitfalls associated with such transactions are also discussed.

Ronald A. Levitt, Esq., Shareholder, Dentons Sirote, Birmingham. AL
Stephen R. Looney, Esq., Shareholder, Dean Mead, Orlando, FL

DEMYSTIFYING TAX PLANNING WHEN USING CARRIED INTERESTS FOR FUND MANAGERS, PROMOTERS AND DEVELOPERS | 2:00pm – 3:30pm

The materials address the income tax treatment upon formation, such as grants of a profits interest for providing past services in putting the deal together or providing future services in the daily operations of the activity, and other items such as the treatment of property rights created by providing prior services, fee waivers and partnership tax allocations for property contributions. The materials address the income tax impact for distributions to investors as a return of their capital contributions and a later shift in profit allocations. For investors and service providers who transfer their interests for estate planning, the materials address valuation issues and the impact of Code Section 2701 using vertical slice planning.

Stephen M. Breitstone. Esq., Partner, Meltzer. Lippe, Goldstein & Breitstone. Mineola, NY & New York, NY
Jerome M. Hesch, Esq., Counsel, Meltzer, Lippe, Goldstein & Breitstone, Boca Raton. FL

Lunch | 3:30pm – 4:45pm

SECTION 1031 EXCHANGES INVOLVING PARTNERSHIPS | 4:45pm – 6:00pm

The speaker addresses current issues of drop and swap exchanges, swap and drop exchanges, 1031/721 transactions, partnerships divisions and exchanges, partnership installment redemptions in connection with exchanges, partnership allocations in connection with exchanges, and Delaware statutory trusts and exchanges, and effects of BBA partnership audit rules on exchanges.

Terence Floyd Cuff, Esq., Of Counsel, Loeb & Loeb, Los Angeles, CA

Break | 6:00pm – 6:15pm

MERGERS AND ACQUISITIONS OF CLOSELY-HELD S AND C CORPORATIONS IN PRIVATE EQUITY, UP-C, AND DOMESTIC AND CROSS BORDER SPAC TRANSACTIONS | 6:15pm – 8:00pm

This presentation reviews the general patterns where a privately owned company is acquired by another privately owned company in either an all stock, all asset or stock sale treated as a “deemed asset sale” under Sections 338 or 336(e). This discussion focuses on the tax outcomes to the buyer and the seller and important characterization and timing issues. Use of equity rollovers and other contingent consideration methods are discussed as well as private equity acquisitions of US based target companies. Discussion also addresses the benefits for the Section 1202 gain exclusion provisions for qualified small business stock, as further enhanced by the OBBBA legislation.

Jerald David August. Esq., Shareholder, August Tax Law, PC, Philadelphia, PA
C. Wells Hall, Ill, Esq., Partner. Nelson Mullins Riley & Scarborough, Charlotte. NC

Break | 8:00pm – 8:15pm

THE ROLE OF THE TAX ADVISOR IN THE TAX SYSTEM: ETHICAL AND PENALTY STANDARDS FOR ADVISING CLIENTS | 8:15pm – 9:55pm

This presentation analyzes the functions and roles of transactional tax lawyers and tax advisors when advising clients and providing a degree of insurance, or penalty protection, to their clients. How sure do advisors have to be before they can tell a client that it is okay to take a deduction or defer or report income as capital gain, etc.? What should an advisor be thinking about as they approach difficult tax questions for their clients? This panel addresses the role of tax advisors in the tax system and uses real-world hypotheticals to illustrate issues that tax advisors must consider when providing tax advice.

Bryan C. Skarlatos, Esq., Partner, Kostelanetz, New York, NY
Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA
G. Michelle Ferreira, Esq., Managing Shareholder, Greenberg Traurig, San Francisco, CA

DAY 6: FRIDAY, NOVEMBER 21, 2025

CURRENT DEVELOPMENTS IN ESTATE PLANNING AND TAXATION | 11:25am – 12:30pm

The One Big Beautiful Bill Act (OBBB) introduced significant changes to the United States Tax Code impacting private clients, family offices, and closely-held companies. This session addresses the provisions of the 2017 Tax Act that will expire this year and the new, permanent $15 million estate and gift tax exemption and planning opportunities, as well as business income provisions for individuals and companies, and related planning opportunities.

Joshua E. Husbands, Esq., Partner, Holland & Knight, Portland, OR

OBBB FIREWORKS–PLANNING OPPORTUNITIES AND CHALLENGES OF THE ONE BIG BEAUTIFUL BILL ACT | 12:30pm – 1:30pm

The One Big Beautiful Bill Act (“OBBB”), enacted amidst the Independence Day celebrations on July 4, 2025, included some fireworks displays specifically directed at the Tax, Trust & Estate Planning community. This session explores planning opportunities arising from the OBBB revisions to the Qualified Small Business Stock provisions of IRC §1202. The expansion of the QSBS exemption is addressed, along with planning opportunities to address business exits, conversions of existing entities from LLC and/or S Corporation structures to C Corporations, stacking 1202 exemptions via irrevocable trusts and trust reformations, modifications and decanting in the context of such planning. The session also addresses planning challenges arising out of OBBB in the Charitable Trust area, including the interaction of IRC §642(c) and new §68 (with no replacement of §68(e)), the 2/37ths deduction haircut, and potential planning techniques to address the new OBBB challenges.

Gary L. Fletcher, Esq., Senior Partner, Frazer Ryan Goldberg & Arnold, Tucson, AZ

Break | 1:30pm – 1:45pm

INTRODUCTION TO INCOME TAXATION OF TRUSTS | 1:45pm – 3:00pm

This session explores the fundamentals of federal income taxation for estates and trusts. What are the essential components of the IRS Form 1041? How is fiduciary income tax computed? Other essentials covered include “simple” vs. “complex” trusts, treatment of capital gains and losses, distributable net income (DNI), income tax charitable deduction rules, and other itemized deductions and limitations.

Brian G. Smith, Esq., Shareholder, Greenberg Traurig, New York, NY
Stacia C. Kroetz, Esq., MBA, CPA, Managing Director; Senior Wealth Planner, Brown Brothers Harriman & Co., New York, NY

Lunch | 3:00pm – 4:15pm

PLANNING FOR LARGER ESTATES POST-OBBB | 4:15pm – 5:15pm

This session offers an overview of planning approaches and techniques for clients whose assets exceed the federal estate/gift/GST exemptions which are slated to increase under the OBBB. The session encompasses the importance of a solid core plan and moves along the continuum to the use of advanced techniques to accomplish successful generational wealth transfer. Various illustrations show the impact of the implementation of the specific techniques. This session also includes a discussion of some of the unique non-tax related factors to consider as part of the process.

Elizabeth Garlovsky, Esq., Partner, Harrison, Chicago, IL

Break | 5:15pm – 5:30pm

HOW TO USE FINANCIAL MODELING TO HELP YOUR CLIENTS AND YOURSELF | 5:30pm – 6:30pm

By using modeling to illustrate the financial impact of an estate planning proposal, clients can better understand the four factors that shift wealth to future generations without exposure to estate and gift tax, as well as the financial impact these factors have on the client’s retained assets that will be needed to support the clients for the remainder of their lives. The material uses spreadsheet modeling that can help understand the four primary wealth shifting factors that contribute to successful wealth transfer, including which factors are more and less important and mitigate the “burn” caused by the grantor paying the income taxes on trust income. Modeling a strategy provides tangible numerical data deep insights into the strategy proposed. The materials hopefully provide readers with practical planning tips to help their clients make better decisions around their planning and make decisions that alight more closely with their client’s spending needs and financial goals.

Jerome M. Hesch, Esq., Counsel, Meltzer, Lippe, Goldstein & Breitstone, Boca Raton. FL
Stephen M. Breitstone. Esq., Partner, Meltzer. Lippe, Goldstein & Breitstone. Mineola, NY & New York, NY

THE ARTHUR D. SEDERBAUM MEMORIAL LECTURE | 6:30pm – 7:30pm
FAMILY LIMITED PARTNERSHIPS AND OTHER CLOSELY-HELD ENTITIES – THE CONTINUING SAGA

This discussion addresses current issues and trends in the transfer tax controversy arena involving family limited partnerships and other closely-held entities at the audit level, IRS Appeals, and in litigation. It includes issues related to the valuation and transfer of interests in closely-held entities, the use of formula clauses, Section 2036, split-dollar life insurance, valuation of promissory notes, GRAT audits, adequate disclosure, recent caselaw, positions taken by the IRS and practical ways to address them at the planning level.

Keri D. Brown, Esq., Partner, Baker Botts, Houston, TX