Representatives from the government and private practitioners will gather for discussions on the most important issues facing tax and trust and estate lawyers, including the 2017 Tax Act and other initiatives, regulations, legislative forecasts and planning ideas.
Chip Harter, deputy assistant secretary for International Tax Affairs at the U.S. Department of the Treasury, will deliver the keynote address at a ticketed joint section luncheon at noon Saturday at the Hyatt Regency Atlanta.
Program highlights:
-"Cross-Species Mergers: Key U.S. Federal Income Tax Considerations" -- Over the last half a century, state corporate laws have evolved and become more sophisticated to facilitate business. States have added the permissible entity forms through which business can be conducted. State laws also permit mergers of legal entities within the same legal form, and across different legal forms. This panel will piece together the relevant authorities and guidance and highlight some interesting, unresolved questions in this space.
-"Section 1202: Tax Planning in Light of the 2017 Tax Act" -- Following the 2017 Tax Act, C Corporations are slowly being introduced into the tax planning mix again to allow taxpayers to benefit from lower tax rates. Hidden within the volumes of the Internal Revenue Code is a little-known provision that permits shareholders of closely held businesses to defer gain on small business stock to the tune of $10 million. This panel will discuss the mechanics of Section1202 and planning techniques that business owners can leverage when looking prospectively to sell their company.
-"Trusts and the Transition Tax: Everything You Didn't Want to Know" -- Section 965 (the "transition tax") added new complexity to the Internal Revenue Code for taxpayers with interests in foreign corporations. Trusts face unique challenges when approaching transition tax issues. This session will provide a brief primer on section 965 and address trustee considerations for the current year and going forward: reporting issues, paying the tax, and transferring property that is subject to 965(h) installment payments or 965(i) deferral.
Published: Thu, Sep 27, 2018
