60th Annual Southern Federal Tax Institute
2025 Materials
Monday:
Download all the Monday MaterialsMONDAY MORNING, OCTOBER 27, 2025
9:00-12:00
Recent Federal Income Tax DevelopmentsThis session highlights significant changes affecting taxpayers over the past twelve months, addressing significant court decisions, rulings, and statutory and regulatory developments.
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12:15-1:05
Mid-Day Program:
Opportunity Knocks - Resolving Tax Issues in the Current IRS Environment
DOGE and the Trump Administration have made large cuts to IRS' budget and personnel. These can present opportunities for you and your client. This presentation will address the recent cuts, how those cuts are impacting IRS enforcements efforts, where we see the future of enforcements, and how you can use the current environment to help your clients resolve ongoing tax disputes.
Sponsored by Chamberlain, Hrdlicka, White, Williams & Aughtry and presented by Tom Cullinan, John Hackney and Charles Rettig
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MONDAY AFTERNOON, OCTOBER 27, 2025
1:15-2:15
Tax Policy and Legislative Update: The View from WashingtonThis presentation will cover the current state of play in tax policy. Whatever that may be come October. The presentation will address the ongoing discussions and/or enacted provisions in the anticipated Republican-led tax legislation, what those changes will mean for taxpayers, how Treasury and the Administration will play a role in implementation, and what the rest of the year may hold for legislative and regulatory prospects.
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2:15-3:15
International Tax Landscape: Global (BEPS Pillar 2) and U.S. Tax UpdateWhile much of the world is in the second year of adopting the minimum tax regime (OECD's BEPS Pillar 2) limiting the ability of countries to compete using income tax rates alone, the U.S. is looking to use tax carrots and sticks to encourage investment in the U.S. This presentation will discuss the status of the OECD BEPS Pillar 2 initiative, the changing views of the U.S. towards the BEPS project, and actions the U.S. is taking to retain and increase investment into the U.S. This discussion will include a legislative update of U.S. tax laws that could impact the international tax landscape.
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3:30-4:30
Understanding and Using IRS and State DOR e-ServicesThe presentation will address the features, functionality, and benefits of using IRS and state DOR e-services and web-based platforms. Specific topics will include registering for IRS e-Services, IRS Tax Pro, Transcript Delivery System (TDS), TIN Matching, and similar applications offered by state revenue departments.
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4:30-5:30
Navigating the Current Tax Enforcement EnvironmentEach new Administration puts its stamp on all federal agencies, including the Internal Revenue Service (IRS). With reductions in headcount and budget, there have been (and will be more) significant changes to tax administration and tax enforcement priorities in the coming years. We are inviting a current or recently retired senior IRS official to draw on their years of service at the IRS to provide their historic perspective and thoughts on the path forward for taxpayers and advisors in navigating a dynamic new enforcement and compliance environment.
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Tuesday:
Download all the Tuesday MaterialsTUESDAY MORNING, OCTOBER 28, 2025
8:30-9:20
Current Trends in Real Estate Debt WorkoutsThis presentation will provide an overview of the fundamentals of the federal tax aspects of discharge of real estate indebtedness and related transactions, followed by discussion of recent trends in the market. Topics include the application of Sections 108 (CODI) and 165 (losses) and the regulations under Section 1001 to discharges or modifications of real estate debt, transactions that constitute foreclosures, and equity-for-debt exchanges involving debtors that are partnerships or disregarded entities.
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9:20-10:10
Exiting a Partnership the "Right" Way: How to Exit a Partnership in a Tax Efficient MannerThis presentation will describe the various exceptions to nonrecognition treatment when receiving a liquidating partnership distribution. It also will cover transactions that allow a partner to effectively redeem its interest from an economic perspective when a normal liquidating distribution would fall under one of the exceptions.
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10:25-11:15
Current Developments for Real Estate Partnerships and InvestorsThis panel will address recent developments impacting real estate partnerships and investors. Topics will include final regulations relating to partnership "basis shifting" transactions and partnership debt allocations, and the treatment of so-called "hot assets." This panel will also provide an update on the status of litigation relating to the limted partner exception to the SECA tax base.
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11:15-12:15
Structuring Considerations for 1031 ExchangesThis presentation will discuss structuring considerations for Section 1031 exchanges in various contexts. Topics to be covered include Section 1031 exchanges out of foreclosure, exchanges involving options, interesting partnership situations, critical issues in oil & gas exchanges, and other recent developments in the field.
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12:15-1:05
Mid-Day Program:
The Future of Taxation
This presentation will highlight federal income tax policy direction, relationship with trade and tariff policy, and how practitioners and clients can navigate extended periods of uncertainty.
Sponsored by Alliant Insurance Services and presented by James Chenoweth
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TUESDAY AFTERNOON, OCTOBER 28, 2025
1:15-2:15
Corporate Tax and Cross-Border Hot TopicsThis presentation will cover the latest developments in corporate and international tax including the proposed Section 899 regulations relating to "unfair foreign taxes," recent regulations addressing spin offs, Section 367(d), and PTEP. This presentation will also address possible issues in a world where the U.S. and GloBE systems live in relative harmony.
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2:15-3:15
Sales of Closely Held Businesses: Avoiding Pitfalls and Planning Ahead for the Best OutcomeThis presentation will address issues that (unfortunately) often do not arise until the due diligence stage of the sale of a privately held business. Specific topics to be addressed include qualification as an S corporation and steps that can be taken to address defects, qualification for the Section 1202 exclusion of gain on the sale of qualified small business stock and the related basis determination matters.
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3:30-4:30
Why Do We Roll This Way?: Tax Deferred Transactions in the Private ContextThis presentation will address common tax deferral strategies in transactions involving private companies. In the process, the presentation will compare and contrast different approaches applicable in different scenarios, highlighting challenges and opportunities based on target and equityholder structures and identities. The presentation will specifically highlight some of the uncertainties in the intersection of Subchapters C and K, and challenges based on special circumstances such as S corporations and non-U.S. persons.
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4:30-5:30
Structuring Investments in Tech, Life Sciences and Other Private CompaniesThis presentation will cover key tax considerations for investments in SAFEs, convertible notes and other traditional convertible preferred investments used for startup and other similar investments in traditional C Corporations and LLCs. Specific topics include tax characterization questions, QSBS considerations, minimizing phantom dividend income, and investments in connection with secondary transactions.
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Wednesday:
Download all the Wednesday MaterialsWEDNESDAY MORNING, OCTOBER 29, 2025
8:30-9:45
Employee Benefits: Updates to Laws, Regulations, and IRS Operations in the New AdministrationThis panel will cover a dozen wide-ranging "hot topics" in payroll taxes, fringe benefits and other employee benefits, covering audits, worker classification guidance, proposed regulations, and proposed legislative changes. The panel will cover a list of issues commonly raised in both state and Federal payroll tax audits (ranging from company cafeterias and payroll tax deposit penalties, through the last Administration's "campaign" to audit company aircraft), and will discuss how those audits might be affected by the IRS's surprising recent guidance limiting the "Section 530" Federal Moratorium. The panel will discuss how fringe benefits and third-party payments may dramatically affect the selection of the additional 5 executives who, starting in 2027, must be added to the deduction-disallowance list under Section 162(m). The panel also will cover tax considerations for employers with overfunded pension and medical plans. Finally, the panel will address 2025 pending and enacted legislation affecting employee benefits, the new Administration's "Green Book" proposals, and developments in "Taxpayer Advocate" filings intended to expedite return processing, penalty abatements and release of levies.
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9:45-10:45
Income Tax Accounting Methods: More Than Just TimingThis presentation will provide participants with a comprehensive overview of income tax accounting methods, including when a method of accounting is established, when timing changes are (and are not) treated as a change in method of accounting, and key procedures for changing a method of accounting. The presentation will also explore the importance of income tax accounting methods under various provisions of the Code, including Section 59A (base erosion and anti-abuse tax), Section 163(j) (business interest expense limitation), and Section 951A (global intangible low-taxed income), and will identify common situations in which income tax accounting methods can provide taxpayers with a permanent benefit.
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11:00-12:00
ESOP as an Option for Ownership Transition: What You and Your Clients Need to KnowThis presentation will identify factors necessary to place owners of a business in the best position to use an ESOP as an exit strategy and, if desired, to accomplish charitable giving goals. The presentation also will highlight issues the owners and the business can expect to encounter before closing the many transactions that will result in the ESOP owning the stock of the business, before turning to the obligations of the business and the owners' involvement in the business following the ESOP transaction. Lastly, the presentation will discuss the parties and advisors needed to properly close an ESOP transaction and to operate and administer the ESOP following the closing.
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12:15-1:05
Mid-Day Program:
Sales Tax Considerations in Asset and Equity Acquisitions
This presentation examines the critical sales tax considerations tax advisors must evaluate in asset and equity acquisitions, highlighting key differences in sales tax obligations based on the transaction structure. It offers practical tips for drafting purchase agreements to ensure clear sales tax compliance and minimize risks.
Sponsored by McGuireWoods LLP and presented by Laura Grace Mezher
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WEDNESDAY AFTERNOON, OCTOBER 29, 2025
1:15-2:30
Partnership Audit Rules: Traps for the UnwaryThis presentation will explore some of the more counterintuitive aspects and quirks of the BBA centralized audit procedures that seem particularly prone to misstep, even for a wary tax advisor. Topics will include the bewildering tax consequences of non-income adjustments ("that can't be right?!"); issues relating to administrative adjustment requests (AARs), including the "stranded overpayment" problem; pros and cons of making the Section 6226 push-out election; situations where the push-out election may not be possible; making sure your partnership's BBA elections and statements furnished to partners and filed with the IRS are timely and complete; and surprising BBA consequences that can emanate from partnership M&A transactions and partnership terminations, including under the "cease to exist" rules and Section 6232(f).
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2:30-3:25
Resolving Tax Controversies with the IRS Independent Office of Appeals: What's New and What's NextThis presentation will address the final Section 7803 regulations and how they may impact your clients' rights at Appeals, navigating the Appeals process, understanding your options if you get "stuck" and are having difficulty reaching a resolution, and the recently established Alternative Dispute Resolution Program Management Office.
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3:40-4:35
International Information Return Penalties: Current Developments and Effective StrategiesThis presentation will answer the following questions: What are common international information returns (IIRs) and penalties the IRS may assess? How does the IRS enforce compliance and impose IIR penalties? What are some of the most common triggers for IIR penalties? What options and strategies are available when the IRS assesses penalties and when past compliance issues are identified?
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4:35-5:35
Safeguarding Privilege: Navigating Kovel EngagementsJoin our panel of seasoned attorneys and tax advisors as they delve into the essentials of the Kovel doctrine, explore strategic scenarios for initiating Kovel engagements, discuss key engagement terms, and share expert insights on preserving privilege in communications and documentation. (Submitted for 1.0 hour ethics credit.)
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Thursday:
Download all the Thursday MaterialsTHURSDAY MORNING, OCTOBER 30, 2025
8:00-9:30
Recent Federal Wealth Transfer Tax DevelopmentsThis presentation will review significant judicial decisions, administrative guidance, and statutory developments relating to wealth transfer taxation over recent months, providing a thorough update on the current estate planning landscape.
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9:30-10:30
Four Weeks and a Funeral: Considerations for the Two Weeks Before Death and the Two Weeks After DeathThis presentation seeks to answer the questions that professionals often receive from a client's family members: "Client is about to die–what should I do?" and/or "Client has just died–what do I need to do?" The presentation addresses issues that occur in the final two weeks of life, including incapacity and tax planning. Further, the presentation discusses the immediate aftermath of a client's death and what can and should be done during that time.
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10:45-12:00
SECURE-ly Planning for Retirement AssetsThe SECURE Act and SECURE 2.0 overhauled the required minimum distribution (RMD) rules for inherited retirement accounts. This presentation will help you confidently navigate the most common scenarios advisors face in this new planning environment. The discussion will especially focus on options for the account owner's surviving spouse and children under the final and proposed RMD regulations issued in July 2024.
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12:15-1:05
Mid-Day Program:
Hot Topics at the Intersection of Estate Planning and Business Valuation
This presentation will discuss the latest valuation cases to be decided by the Tax Court and the valuation impact of any meaningful changes to transfer tax and income tax laws.
Sponsored by MPI and presented by Todd G. Povlich
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THURSDAY AFTERNOON, OCTOBER 30, 2025
1:15-2:15
IRS Transfer Tax Targets and Trials: What Were They Thinking?This session will begin with a discussion of the IRS's enforcement objectives with regard to transfer tax returns involving closely held entities. The discussion will address recent developments in Tax Court jurisprudence and its valuation approaches, all with an eye toward minimizing audit risk.
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2:15-3:15
Expecting the Unexpected: Flexible Planning for 2025 and BeyondFor the past few years, most estate planners were warning clients that current transfer tax exemptions are scheduled to be cut in half at the end of 2025. That looming sunset, however, was eliminated by the One Big Beautiful Bill Act. Nonetheless, if the last twenty years have taught us anything, it is to expect the unexpected. This presentation will review the vast array of tools estate planners have to assist their clients in uncertain times, with a particular emphasis on drafting that maximizes optionality.
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3:30-4:30
It's English to Me: Non-U.S. Trust Law for U.S. LawyersMany U.S. clients are beneficiaries of trusts administered in countries other than the United States. Non-U.S. trust law and administrative practices in other countries, however, differ considerably from U.S. trust law. This presentation will address important differences between non-U.S. trust law and U.S. trust law to allow you to better advise clients on tax and nontax implications of being a beneficiary of a non-U.S. trust.
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4:30-5:30
Using Generative AI Ethically & Responsibly In An Estate Planning PracticeArtificial Intelligence is not a new concept for lawyers who have been applying some forms of it for years. However, the recent emergence of many low-cost and accessible generative AI tools that can offer various benefits in a short time has changed the landscape. But before lawyers can take advantage of these AI assistants, they need to be aware of the ethical and practical implications. How can they ensure that using GAI for client work is secure and appropriate? The existing rules, as well as a new ethics opinion, provide guidance and some best practices. In this presentation, we will discuss what you need to consider when using GAI in your practice. (Submitted for 1.0 hour ethics credit.)
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Friday:
Download all the Friday MaterialsFRIDAY MORNING, OCTOBER 31, 2025
8:00-9:00
Planning with Life Insurance LLCs after Connelly and HuffmanConnelly increases risk for any life insurance-funded redemption, and Huffman increases risk of IRS disrespecting any buy-sell agreement that is subject to Section 2703. Learn how to use a life insurance LLC to reduce these risks and reduce or avoid income tax risk when transferring policies as business ownership changes. We will also discuss fairness among owners when funding life insurance premiums.
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9:00-10:00
Review of the Past Year's Significant, Curious, or Downright Fascinating Fiduciary CasesThis presentation will review selected reported fiduciary litigation decisions from 2024 and 2025 that relate to multiple areas of estate planning, estate and trust administration, the fiduciary duties of agents, administrators, trustees, and other fiduciaries, related trial practice, and identifying and navigating contemporary fiduciary challenges.
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10:15-11:30
Tax Consequences of Trust Modifications and Early TerminationsThis presentation will review transfer tax issues and surprising income tax ramifications of early trust terminations highlighted in recent PLRs and the McDougall case. Importantly, the presentation will address how to avoid these adverse results with more flexible drafting provisions as well as alternative methods of termination.
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11:30-1:00
The Great Unknown: What Really Happens When Partners Die?They say the only certainties in life are death and taxes. If that has always been true, then why do we know so little about what really happens when a partner dies? This presentation unveils the real truth about the "step-up" in basis when a partner dies and what's left behind for the partnership and its partners. It will discuss planning opportunities before and after death, pitfalls to avoid, and unanswered questions, with a focus on "negative basis" and "negative capital" assets.
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