Global Mobility: Changing Work Locations and Tax Jurisdictions

Nov 15, 2021 4:05pm ‐ Nov 15, 2021 5:20pm

Identification: NTA2116



In recent years there has been a trend to employ individuals to work remotely. More recently with shifting global trends companies are increasingly employing individuals that are not only remote, but working remotely from a different country. In this session we will address the common tax concerns with a workforce that is spread out through out the globe as well as address some planning opportunities and treaty issues.

Learning Objectives:
  • Identify the US tax implications of a US company employing individuals that are physically outside of the US
  • Identify the US tax implications of a Non-US company employing individuals that are physically present within the US
  • Understand the impact of relevant tax treaties on the movement of employees
Category: Concurrent Session Onsite and Online

Estate Planning Nuggets in a Changing Tax World

Nov 15, 2021 4:05pm ‐ Nov 15, 2021 5:20pm

Identification: SOP2106



The income, gift, and estate tax systems face, at the time that this description is being written, incredible uncertainty. Van Hollen, Biden, Sanders, and others have put forth proposals that would dramatically change tax planning. Deemed realization on gift, transfer, or death could change estate planning, asset protection, gain/loss harvesting, and more. Perhaps by the date of the conference, we will know the outcome of these proposals. But whatever the status of the tax proposals, this program will provide a current, practical analysis of planning nuggets practitioners can recommend to clients in the changing tax world. 

In addition to major tax bills, there are always significant tax planning developments. For example, in July the court’s holding in the Morrissette case has valuable lessons about the importance of business purpose in estate planning transactions, the use of split-dollar insurance planning, and valuation. This and other current developments will be reviewed with an eye to gleaning practical planning nuggets for practitioners.

This will be a fast-paced program focused on practical planning tips.

Learning Objectives:
  • Instruct practitioners on practical gift, estate and GST planning steps they can advise clients to take in the current environment.
  • Identify possible steps to unwind planning that clients determine is not viable in light of legislative developments.
Category: Concurrent Session Onsite and Online

AICPA Tax Advocacy Update

Nov 16, 2021 8:00am ‐ Nov 16, 2021 8:50am

Identification: NTSP21201

Jan Lewis (Chair of the AICPA's Tax Executive Committee) and the AICPA Tax Policy & Advocacy team will discuss how the AICPA's advocacy efforts resulted in guidance helpful to taxpayers and CPAs.

Category: Concurrent Session Onsite and Online

Sponsored Session: The Emergence of Analytics for Tax Positions

Nov 16, 2021 8:00am ‐ Nov 16, 2021 8:50am

Identification: NTSP21202

While you usually know what tax position would be preferred by your client, it can be hard to formulate tax positions in a way that makes the strongest possible argument for the client’s position, mitigates the risk of the position being successfully challenged and provides time- and cost-effective service for your client.

Join us as we discuss how leading tax professionals are using advanced analytics tools to structure and document client positions by:
- Using artificial intelligence to identify the strength of a position with greater than 90% accuracy
- Testing the effect of various changes to the facts on the strength of the position
- Gaining a comprehensive view of the law by identifying authorities and guidance that may pose a risk to the position or can be used to support it
- Providing independent, 3rd party reports to document client positions

Category: Concurrent Session Onsite and Online

Sponsored Session: Nuts & Bolts of Cryptocurrency Taxation

Nov 16, 2021 8:00am ‐ Nov 16, 2021 8:50am

Identification: NTSP21203

46 million Americans now own bitcoin. Yet, only a few tax professionals understand how to help individuals and businesses dealing with cryptocurrency. This session walks you through the tax implications of common cryptocurrency-related transactions and how to successfully service clients affiliated with cryptocurrency. We will also cover current developments surrounding this topic, such as the inclusion of the virtual currency question on the front of Form 1040, how to successfully navigate through tax notices (CP2000, Letter 6173, Letter 6174 & Letter 6174-A), and tax planning opportunities.

Learning Objectives:
  • Understand the tax implications of investing in cryptocurrency, running a mining operation, using NFTs, and using cryptocurrency as a payment method
  • Learn about challenges in dealing with cryptocurrency related clients
  • Apply tax planning opportunities
  • How to service clients with cryptocurrency transactions using a tool like CoinTracker.io
Category: Concurrent Session Onsite and Online

Sponsored Session: Selling Your Brain NOT Your Time: Subscription Pricing for tax Professionals

Nov 16, 2021 8:00am ‐ Nov 16, 2021 8:50am

Identification: NTSP21204

This session is dedicated to the possibility that a tax practice will be more effective for its customers if it begins to sell not hours or even services, but access to the brains of the professionals. Creating subscriptions for access is hard work and not for everyone because it requires tax professionals to think differently than they have in the past about what it is they really do and sell. If you think you have what it takes to make this shift or are just curious about it, you are hereby invited to open a dialogue about how best to alter this language by Ed Kless, Sage’s senior director of partner development and strategy, who will facilitate this session.

Learning Objectives:
  • Understand the difference between selling inputs, outputs, and outcomes
  • Choose from three models of implementing subscriptions
  • See multiple examples of subscription in action
Category: Concurrent Session Onsite and Online

IRS Executive Updates

Nov 16, 2021 9:05am ‐ Nov 16, 2021 11:10am

Identification: NTSP2102

Category: General Session Onsite and Online

Learning Lab - How Accounting Technology broke Public Accounting sponsored by BaCo Tech

Nov 16, 2021 11:10am ‐ Nov 16, 2021 11:30am

Identification: NTSP21LL02


Identifying and Targeting Tax Shelters: Microcaptives, Conservation Easements and Beyond

Nov 16, 2021 11:40am ‐ Nov 16, 2021 12:30pm

Identification: NTA2120



In recent years the IRS has focused considerable resources on enforcement activities in two areas: captive insurance and conservation easements. These campaigns present challenges not just to the IRS, but to taxpayers and taxpayer advisors and representatives. The presenters on this panel have been in the thick of these actions, on both sides. They will discuss the IRS’s activities and settlement initiatives, strategies for dealing with them, and lessons that can be applied to future similar enforcement efforts by the IRS.  Discussion topics will include:


• IRS campaign initiatives, staffing, and coordination

• IRS focus on abusive schemes and penalties, including the civil fraud penalty

• Settlement initiatives

• Appeals and litigation

Learning Objectives:
  • Describe how IRS identifies certain transactions or planning for further scrutiny and possible identification as a tax shelter
  • Identify current status of two recent high profile tax shelter targets: microcaptive insurance companies and conservation easements
Category: Concurrent Session Onsite and Online

Passthrough Arrangements: Partnership Tune-up Update

Nov 16, 2021 11:40am ‐ Nov 16, 2021 12:30pm

Identification: NTA2121

A year of constant changes. This session will bring us back to important fundamentals that are easy to overlook among the complex issues passthroughs commonly encounter. What is a partnership for federal tax purposes? What is drafted in the operating agreement that should be looked over before certain elections are made? Why is a tune-up good practice given the intricacies and consequences of the centralized partnership audit regime? This session will cover these common threshold questions to ensure starting 2022 off on the right foot.

Learning Objectives:
  • Understand what is and is not a “partnership” for federal tax purposes
  • Understand common drafting issues in limited liability company (LLC) agreements
  • Understand implications of the centralized partnership audit regime (BBA) in the “tune-up”
Category: Concurrent Session Onsite and Online