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Explore the Institute Agenda
View the conference sessions below to plan your Tax Institute experience.
Recent Developments in Corporate Taxation
- Availability:
- Jan 25, 2027 @ 09:00 AM (PST)
- Duration:
- 1 Hour 10 Minutes
- Speaker:
-
Julie A. Divola — Partner, Pillsbury Winthrop Shaw Pittman LLP | Nicole Field — Principal, National Tax M&A Group, Ernst & Young LLP | Eric Solomon — Partner, Ivins, Phillips & Barker, Chartered
- Description:
- This panel will discuss recent events relating to corporate taxation, such as developments regarding the Treasury/IRS published guidance program and the IRS private letter ruling process, including matters relating to spinoffs. The panel will also discuss zero basis issues and litigation about the economic substance doctrine.
Morning Networking Break presented by McGuireWoods LLP
- Availability:
- Jan 25, 2027 @ 10:10 AM (PST)
- Duration:
- 20 Minutes
- Speaker:
Corporate Tax Issues in Recent Deals
- Availability:
- Jan 25, 2027 @ 10:30 AM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Alexander Lee — Partner, Cooley LLP | Lewis R. Steinberg — Adjunct Professor, New York University School of Law
- Description:
- Learn about recent interesting and high-profile public deals from nationally-known experts as they focus on each transaction’s structural and commercial features and analyze its tax treatment, with particular emphasis on novel tax issues.
Passing Period
- Availability:
- Jan 25, 2027 @ 11:30 AM (PST)
- Duration:
- 10 Minutes
- Speaker:
Distressed M&A
- Availability:
- Jan 25, 2027 @ 11:40 AM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Sheila Giuliani — Principal, M&A Tax, PwC | Alyssa Kollmeyer — Partner, Ropes & Gray LLP | Benjamin Rogers — Partner, Ropes & Gray LLP | Lucas M. Rachuba — Partner, Paul Hastings LLP
- Description:
- This panel will cover complex tax issues arising in the context of acquisitions of distressed targets and acquisitions from distressed targets. Topics include debt modifications, recapitalizations, stock acquisitions, Bruno’s transactions and related CODI and gain issues as well as 382 attribute preservation and successor liability concerns.
Edward Kleinbard Memorial Lecture
- Availability:
- Jan 25, 2027 @ 01:20 PM (PST)
- Duration:
- 30 Minutes
- Speaker:
-
H. David Rosenbloom — Director, International Tax Program & James S. Eustice Visiting Professor of Taxation, New York University School of Law
- Description:
- In the world of so-called international taxation we have not yet reached a kumbaya moment. Nations have national interests and those interests will be served, however much some might believe in the primacy of shared values and goals. It is in this very real world that conventions to avoid double taxation – tax treaties – loom large. With no other viable game in town, countries would be well advised to pay attention to, and if possible improve, the dispute resolution mechanisms these instruments offer.
Passing Period
- Availability:
- Jan 25, 2027 @ 01:50 PM (PST)
- Duration:
- 10 Minutes
- Speaker:
Section 1202 Unlocked: Maximizing Tax-Free Gains Post-OBBBA
- Availability:
- Jan 25, 2027 @ 02:00 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Shahrooz Shahnavaz — Partner, McGuireWoods LLP | Gerald V. Thomas II — Partner, McGuireWoods LLP
- Description:
- Section 1202's qualified small business stock exclusion has become one of the most powerful resources in a tax advisor's toolkit — and the 2025 One Big Beautiful Bill Act just rewrote the playbook. This session will unpack the new tiered holding periods, expanded exclusion caps, and higher gross-asset thresholds, while spotlighting the structuring pitfalls that can turn a multimillion-dollar tax benefit into a costly mistake. Attendees will leave with a practical framework for navigating QSBS in M&A exits and deal structuring, plus a roadmap through the open issues the IRS has yet to resolve.
Passing Period
- Availability:
- Jan 25, 2027 @ 03:00 PM (PST)
- Duration:
- 10 Minutes
- Speaker:
Restricted, Clawed Back, and Confused: Compensation Tax Issues in M&A (Concurrent Session, Corporate A)
- Availability:
- Jan 25, 2027 @ 03:10 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Janet Andolina — Partner, Chair, New York Office, Goodwin | Brian Hamano — Partner, DLA Piper LLP (US) | Edward S. Wei — Partner, Gibson Dunn
- Description:
- This panel will explore transaction structures that blur the line between merger consideration and compensatory arrangements, with a particular focus on Revenue Ruling 2007-49 and its application in modern M&A transactions. We will examine restricted stock vs. delayed equity issuance structures, the impact of forfeiture and clawback provisions, Section 83(b) election considerations, and the related withholding implications. The session will also address personal goodwill transactions and post-closing profits interest arrangements. Throughout, the panel will highlight practical structuring considerations, areas of uncertainty, and current market approaches.
Hot Tax Topics for Closely-Held Businesses (Concurrent Session, Corporate B)
- Availability:
- Jan 25, 2027 @ 03:10 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Howard Wagner — Managing Director, Washington National Tax, Forvis Mazars
- Description:
- Join this rapid-fire session on recent developments and important trends that affect closely-held corporations and partnerships and their owners.
Afternoon Networking Break
- Availability:
- Jan 25, 2027 @ 04:10 PM (PST)
- Duration:
- 20 Minutes
- Speaker:
QSBS: Advanced Structuring around Section 1202 (Concurrent Session, Corporate A)
- Availability:
- Jan 25, 2027 @ 04:30 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Lily H. Kim — Partner, Gunderson Dettmer | Myra A. Sutanto Shen — Partner, Wilson Sonsini Goodrich & Rosati
- Description:
- This session examines advanced planning, structuring and techniques to maximize and preserve Section 1202. It covers key changes following OBBBA, along with key technical pitfalls to avoid to maintain "qualified small business" status. Attendees will leave with a greater appreciation of the tools every practitioner should have in their QSBS planning toolkit.
Navigating the SALT Mine: Litigation Updates and Emerging Trends (Concurrent Session, Corporate B)
- Availability:
- Jan 25, 2027 @ 04:30 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Douglas H. Andersen — Partner, Holthouse Carlin & Van Trigt LLP | Mardiros Dakessian — Founder, Dakessian Law, Ltd. | Joshua Lin — Associate, Dakessian Law, Ltd.
- Description:
- With thousands of state and local tax jurisdictions and a multitude of tax types, state and local tax matters can certainly lead you to a dark place. But this session is here to light the way. Join Marty Dakessian (Dakessian Law), Douglas Andersen (HCVT), and Joshua Lin (Dakessian Law) for this session exploring the latest critical developments in state and local taxation. This session will cover ongoing disputes in corporate income and franchise tax, personal income and trust taxation, sales and use tax (including the taxation of SaaS and digital products), and other novel, emerging tax trends across various jurisdictions. These are hot issues currently impacting clients across all industries and sectors.
Recent Developments in Partnership and Real Estate Guidance
- Availability:
- Jan 26, 2027 @ 09:00 AM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Eric B. Sloan — Partner and Co-Chair of Tax, Gibson Dunn | James Jennings — Partner, Gibson Dunn
- Description:
- Learn about up-to-the minute legislative, regulatory, and judicial developments in partnership and real estate tax from two of our country’s leading experts.
Morning Networking Break presented by McGuireWoods LLP
- Availability:
- Jan 26, 2027 @ 10:00 AM (PST)
- Duration:
- 20 Minutes
- Speaker:
Partnership Restructurings and Bankruptcy Considerations
- Availability:
- Jan 26, 2027 @ 10:20 AM (PST)
- Duration:
- 1 Hour
- Speaker:
-
C. Timothy Fenn — Partner, Latham & Watkins LLP | Arash Lotfi — Associate, Latham & Watkins LLP | Eric Matuszak — Principal, EY
- Description:
- This panel will cover the tax consequences of partnership debt restructurings to the partnership as well as its partners, its lenders, and the partners’ and lenders’ affiliates (including blocker corporations affiliated with private fund sponsors). It will also cover certain strategies intended to mitigate the adverse consequences of such restructurings as well as the benefits, the drawbacks, and certain risks associated with such strategies.
Passing Period
- Availability:
- Jan 26, 2027 @ 11:20 AM (PST)
- Duration:
- 10 Minutes
- Speaker:
Hot Topics in Accounting Methods
- Availability:
- Jan 26, 2027 @ 11:30 AM (PST)
- Duration:
- 1 Hour
- Speaker:
-
James Gergurich — Tax Principal, KPMG LLP | Greg Rivers — Managing Director, Tax - Credits and Property Incentives, Weaver
- Description:
- Accounting methods continue to offer some of the most powerful and often overlooked tax planning opportunities. This course highlights hot topics, recent developments, and new strategies that can accelerate deductions, defer income, and improve cash taxes. We will examine emerging opportunities involving capitalization, depreciation and amortization, method changes, and the interaction of accounting methods with other significant tax provisions. Attendees will leave with practical ideas for identifying opportunities and starting planning conversations with clients.
Passing Period
- Availability:
- Jan 26, 2027 @ 12:30 PM (PST)
- Duration:
- 10 Minutes
- Speaker:
The Fundamentals of the United States Tax Court
- Availability:
- Jan 26, 2027 @ 01:20 PM (PST)
- Duration:
- 30 Minutes
- Speaker:
-
Hon. Elizabeth A. Copeland — United States Tax Court
- Description:
- This session will provide an overview of the United States Tax Court. It will discuss the makeup of the Court, its expanding jurisdiction, how trials are conducted, the types of opinions issued by the Court and their importance, as well as practical information for litigating a tax matter.
Passing Period
- Availability:
- Jan 26, 2027 @ 01:50 PM (PST)
- Duration:
- 10 Minutes
- Speaker:
Section 1202: Considerations for Partners and Partnerships (Concurrent Session, Partnerships & Real Estate Tax Planning)
- Availability:
- Jan 26, 2027 @ 02:00 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Victoria Glover — Managing Director, Deloitte Tax LLP | Yuval Ruppin — Managing Director, A&M Tax
- Description:
- Since the enactment of the 2025 One Big Beautiful Bill legislation, partners and partnerships have been re-considering whether an investment in qualified small business stock makes sense. This session will examine the rules of section 1202, the changes enacted by the One Big Beautiful Bill (including new IRS guidance, if issued) and structuring considerations for partners and partnerships. Attendees will leave with a better understanding of the opportunities, the open questions and the potential pitfalls when a partnership acquires qualified small business stock.
Crypto Taxation (Concurrent Session, High-Net-Worth Individuals & Families)
- Availability:
- Jan 26, 2027 @ 02:00 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Tom Geraghty — Partner, Holland & Knight LLP | Lawrence J. Zlatkin — Vice President, Tax, Coinbase
- Description:
- As cryptocurrency moves further into the financial mainstream, tax compliance and reporting obligations continue to grow more complex. This session will provide attorneys and accountants with a practical overview of cryptocurrency taxation, evolving IRS guidance, and key considerations affecting digital-asset issuers and holders.
Handling an IRS Collection Matter in the AI World and Avoiding Passport Revocation – What’s Changed-What Hasn’t (Concurrent Session, Ethics Compliance & Enforcement)
- Availability:
- Jan 26, 2027 @ 02:00 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Cory Stigile — Principal, Hochman Salkin Toscher Perez P.C.
- Description:
- AI is changing how we all do business including how the IRS operates in this new environment. Join a discussion of experts on how AI can impact and the best practices for handling an IRS collection matter. The panel will also provide valuable insight on how to avoid having your clients passport revoked for the non-payment of taxes.
Passing Period
- Availability:
- Jan 26, 2027 @ 03:00 PM (PST)
- Duration:
- 10 Minutes
- Speaker:
Beyond Boilerplate: Considering Provisions for “What If” Scenarios Under the BBA Centralized Partnership Audit Regime (Concurrent Session, Partnerships & Real Estate Tax Planning)
- Availability:
- Jan 26, 2027 @ 03:10 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Ossie Borosh — Principal, Passthroughs Group, KPMG LLP | Kate Kraus — Partner, Covington & Burling LLP
- Description:
- The BBA Centralized Partnership Audit Regime fundamentally changed how partnerships are audited and how prior-year returns are corrected. From a transactional perspective, the BBA matters because it has changed the amount of tax that might be owed and the persons who might be liable, with the partnership itself being liable as a default. These changes require careful attention from all parties involved in partnership transactions so that they are prepared in a wide range of “what if” scenarios that might arise under the BBA. Panelists will discuss drafting issues and techniques relating to push-out elections, modification procedures, allocations of imputed underpayments and the filing of administrative adjustment requests that may arise in various transactions. The panel will also address various decision-making principles and provisions that may help mitigate ambiguity and unexpected results in their transactions.
QSBS and Founders: Strategies for High-Net-Worth Individuals & Families (Concurrent Session, High-Net-Worth Individuals & Families)
- Availability:
- Jan 26, 2027 @ 03:10 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Jennifer Kowal — Senior Managing Director, Senior Income Tax Strategist, IEQ Capital | Matthew S. Schonholz — Partner, Baker McKenzie
- Description:
- Join our distinguished tax experts as they identify strategies and opportunities relating to the formation of companies in order to qualify for QSBS, use of trusts and partnerships to maximize the benefits and audit risks.
Hot Topics Confronting the IRS and FTB Examination Division and Tax Practitioners (Concurrent Session, Ethics Compliance & Enforcement)
- Availability:
- Jan 26, 2027 @ 03:10 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Timothy Bilotta — Adjunct Professor, Loyola Marymount University | Chad Nardiello — Partner, Nardiello Turanchik Tompkins LLP
- Description:
- The IRS and FTB continue their enforcement efforts in a new environment. Our expert panel will discuss the top examination topics your clients face and how to best handle the difficult issues to achieve the best results.
Afternoon Networking Break
- Availability:
- Jan 26, 2027 @ 04:15 PM (PST)
- Duration:
- 15 Minutes
- Speaker:
Opportunity Zones 2.0: Navigating the Transition Period and Maximizing New Program Benefits (Concurrent Session, Partnerships & Real Estate Tax Planning)
- Availability:
- Jan 26, 2027 @ 04:30 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Blake E. Christian — Partner, Holthouse Carlin & Van Trigt LLP | Catherine Lyons — Senior Director of Policy and Coalitions, Economic Innovations Group
- Description:
- This session will discuss the scale, reach and impact of Opportunity Zones to date, discuss the changes to the now-permanent OZ 2.0 incentive, and explore strategies to both manage the transition from 1.0 to 2.0 and maximize benefits once 2.0 comes into effect on January 1, 2027. The panel will review the new OZ 2.0 map, case studies for urban and rural real estate and operating business investments, and discuss federal and state policy trends, including expanded reporting requirements.
Leaving California for a New State of Taxation: What You Need to Know! (Concurrent Session, High-Net-Worth Individuals & Families)
- Availability:
- Jan 26, 2027 @ 04:30 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Michel R. Stein — Principal, Hochman Salkin Toscher Perez P.C. | Tom van Loben Sels — Managing Partner, Apercen Partners LLC
- Description:
- Has the Sunshine Tax gotten too high? Proposed wealth tax, constant increases in the income tax rate, local mansion taxes, city taxes, etc. Is it time to break ties with California? Leaving the State of California is more than a state of mind. Join us in a conversation on what taxpayers and their advisors need to know to effectively relocate residency and domicile out of California, minimize the risk of a successful residency challenge, and prepare for and defend against an FTB residency examination. We will discuss the factors California considers in determining residency and domicile, common mistakes taxpayers make when leaving the state, planning before and after a move, documentation and record keeping, and strategies for handling an FTB residency audit.
Avoiding the Ethical Pitfalls When Using AI in Your Tax Practice (Concurrent Session, Ethics Compliance & Enforcement)
- Availability:
- Jan 26, 2027 @ 04:30 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Sharyn M. Fisk — Associate Professor, Department of Accounting, College of Business Administration, Cal Poly Pomona | Phillip Behrendt — Principal, Hochman Salkin Toscher Perez P.C. | Philip J. Wilson — Managing Director, CBIZ
- Description:
- AI presents a force multiplier that can and should enhance any tax practice-but many ethical issues are presented. Learn from experts the best practices in using AI and how to avoid the ethical pitfalls that are presented by this new technology.
Recent Developments and Current Trends in Estate Planning
- Availability:
- Jan 27, 2027 @ 09:00 AM (PST)
- Duration:
- 2 Hours
- Speaker:
-
Charles A. "Clary" Redd — Partner, Stinson LLP | Turney P. Berry — Partner, Bricker Graydon Wyatt LLP
- Description:
- Two nationally-known experts will provide an overview of significant changes and developments in the law, impacting estate planners and those who administer estates and trusts. Keep on top of current trends and developments that will affect all wealth transfer advisors.
Trust Deductions after OBBBA
- Availability:
- Jan 27, 2027 @ 11:30 AM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Justin Miller — Partner and National Director of Wealth Planning, Evercore
- Description:
- This presentation examines the evolving legal landscape of trust and estate deductions following the One Big Beautiful Bill Act. Topics include distribution deductions, specific gifts and bequests, administration expenses, excess deductions, charitable deductions, and the new Section 68 disallowance. The session will highlight key legal uncertainties and provide practical guidance to help attorneys and other professionals navigate risks and advise clients effectively.
Morning Networking Break presented by McGuireWoods LLP
- Availability:
- Jan 27, 2027 @ 11:00 AM (PST)
- Duration:
- 30 Minutes
- Speaker:
Passing Period
- Availability:
- Jan 27, 2027 @ 12:30 PM (PST)
- Duration:
- 10 Minutes
- Speaker:
Keynote Presentation
- Availability:
- Jan 27, 2027 @ 01:20 PM (PST)
- Duration:
- 30 Minutes
- Speaker:
-
Kirk J. Stark — Barrall Family Professor of Tax Law and Policy, UCLA School of Law
- Description:
- Join Professor Kirk Stark of UCLA School of Law for a timely exploration of how states are rethinking the taxation of wealth. This session will examine emerging tax policy proposals—including wealth taxes and measures targeting high-value real estate, such as New York’s proposed pied-à-terre tax—and the legal, economic, and practical considerations they raise. Gain valuable insights into the evolving state tax landscape and what these developments could mean for the future of tax policy!
Passing Period
- Availability:
- Jan 27, 2027 @ 01:50 PM (PST)
- Duration:
- 10 Minutes
- Speaker:
Planning with 6166: Qualifying and Disqualifying Yourself, Interplay of 302 and 303 Redemptions
- Availability:
- Jan 27, 2027 @ 02:00 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Craig L. Janes — Partner, Ballard Spahr LLP
- Description:
- This session will discuss the qualifications required for statutory deferral of the estate tax and the elections available when those qualifications are not initially met. We will also discuss the conditions under which the deferral will be accelerated and the means of avoiding acceleration through proper coordination with IRC sections 302 and 303. Finally, we will discuss the measures the IRS may impose to safeguard its position, including the implications of the Roski case.
Passing Period
- Availability:
- Jan 27, 2027 @ 03:00 PM (PST)
- Duration:
- 10 Minutes
- Speaker:
CRUTs: Getting the Benefits and Avoiding the Pitfalls
- Availability:
- Jan 27, 2027 @ 03:10 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Reynolds Cafferata — Partner, Rodriguez, Horii, Choi & Cafferata LLP | Diana Xuan Gallagher — Principal, GHJ
- Description:
- CRUTs are a win-win for individuals looking to make a significant charitable gift, generate income and minimize the impact of capital gains tax. To obtain these benefits, the CRUT needs to be properly planned, funded and administered. This presentation will cover important planning, funding and administration rules to allow a planner to provide a client with the all of the benefits a CRUT has to offer.
Afternoon Networking Break
- Availability:
- Jan 27, 2027 @ 04:10 PM (PST)
- Duration:
- 20 Minutes
- Speaker:
Bricks, Dirt, Basis and Beyond - Advanced Planning with Real Estate
- Availability:
- Jan 27, 2027 @ 04:30 PM (PST)
- Duration:
- 1 Hour
- Speaker:
-
Jonathan C. Lurie — Senior Counsel, Private Wealth, Willkie Farr & Gallagher LLP | Megan L. Jones — Partner, Holland & Knight LLP
- Description:
- This program will discuss sophisticated income and estate tax strategies for families holding real estate portfolios. The session will tackle complex wealth transfer, structural transitions, governance and transfer issues and valuation challenges.
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