This two-part session is a townhall format for participants to ask the pressing questions associated with choosing the appropriate entity structure in which to operate a business.

At the end of this session, the participant should be able to:

• Recognize double taxation doesn’t apply to all C corporation shareholders
• Identify business types and scenarios which might benefit from filing as C corporations
• Recognize the inherent difficulties of a changing tax environment in entity planning services
• Describe scenarios in which flow-through taxation is more favorable than C corporation taxation

This session will address how to improve the quality of life of an individual with special needs without reducing or eliminating any means-tested government benefits which the individual is entitled to. The speaker will give an overview of the various government benefits available and the different types of trusts that may be used to supplement those benefits.

• Determine the basics of government benefits available to individuals with special needs.
• Recognize how to use trusts to supplement those benefits.

During this session, four privileges will be covered:

1) Attorney/Client
2) Work product
3) IRC 7525 Taxpayer Communications
4) Kovel Arrangements

After this session, you will understand:

• the various privileges
• the limits on the use of privileges by the CPA
• how to protect the CPA's clients (sometimes from the CPA)

This class will discuss the collection methods the IRS is using in the new enforcement environment. When clients are faced with IRS enforcement representatives need a wide array of skills to protect their clients. This class is for the IRS collection representatives. You will learn of the proper way to appeal IRS enforcement actions. You will learn:

• IRS Levies
• Seizures
• Lien procedures
• Advanced concepts in liens: Subordination, subrogation, discharge and non-filing of liens
• The newest IRS initiatives and the best way to protect your client
• Installment agreements
• Offers in compromise
• Currently not collectible
• Other collection alternatives

1. Recognize successful negotiation strategies
2. Identify IRS collection procedures
3. Determine how to appeal adverse IRS determinations

The business interest expense limitations of section 163(j) have been the subject of significant debate since the enactment of the TCJA. The application of these rules to partnerships presents novel issues, some of which remain unresolved. After a brief overview of the operative rules, this session will focus on the Treasury and IRS guidance issued to date and the remaining open issues and uncertainties, as illustrated through a series of examples.

• Discuss the interest expense limitation in Section 163(j) and the key terms used in the Code Section.
• Identify which taxpayers are not subject to Section 163(j) and which taxpayers may elect out of Section 163(j).
• Discuss how Section 163(j) applies to partnerships and partners and uncertainties in the law.

Each day the Internal Revenue Service asserts millions of dollars in tax penalties against taxpayers. Many of those penalties are subsequently abated because of quality representation by experienced practitioners. This session will cover the basics of supporting reduction of IRS tax penalties. You will learn about:

Reasonable Cause
Ordinary Business Care and Prudence
Internal Revenue Service Preferred Reasons for Abatement of Penalties
A practical approach to seeking abatement of penalties

• After this session, you should be able to substantially reduce many tax penalties asserted by the Internal Revenue Service against your clients. Additionally, you will:
  • identify IRS rules for reasonable cause abatement of penalties
  • be able to identify first time abatement situations

We will discuss emerging trends in financial issues affecting divorce including valuation methods, computation of support and tax effects.

• Identify issue spotting for clients with complex financial impacts of a divorce.
• Recognize capacity to assist clients (and their business entities) in making their best case through counsel.

Looks can be deceiving: gift tax returns are not as easy as they appear. This session will be an eye-opener as to the pitfalls and challenges of preparing a complete and accurate return.

Armed with this knowledge, you will protect both you and your client from future liability and audit risk. The following will be addressed:

• Identify when should a gift tax return be filed
• Gift-splitting: Recognize when to split or not to split
• Adequate disclosure of gifts: Are you covered?

P.L. 115-97, commonly referred to as the Tax Cuts and Jobs Act (TJCA) contains provisions which may dramatically impact (1) what constitutes UBTI (2) how and at what rate tax is calculated in the current and future years. TJCA also imposes an excise tax on investment income of certain private colleges and universities. This session will explain these provisions of the TJCA, discuss the impact on affected tax-exempt organizations, and review current and expected IRS compliance guidance.

• Recognize the provisions of TJCA that may impact tax-exempt organizations.
• Analyze the impact of provisions on affected tax-exempt organizations.
• Evaluate how these tax law changes impact their organizations or their clients.