The USC Gould School of Law 2026 Tax Institute convened hundreds of tax professionals January 26–28 for three days of advanced continuing legal education focused on navigating a rapidly evolving tax landscape.
Titled “The Code and Beyond: Tax Strategies for a New Era,” the Institute examined the far-reaching implications of the One Big Beautiful Bill Act (OBBBA), shifting enforcement priorities, and emerging planning challenges across corporate, individual and estate tax practice areas.
Hosted by USC Gould School of Law, the conference welcomed tax attorneys, accountants, financial planners, fiduciaries and government professionals who joined both in person at the Sheraton Grand Los Angeles and virtually via livestream. Attendees earned continuing education credit while engaging directly with nationally recognized speakers from law firms, accounting firms, financial institutions and government agencies.
Each day of the Institute featured a luncheon keynote offering high-level perspective on tax policy, administration and practice.
The Institute opened with a strong focus on corporate tax planning, as speakers examined the most consequential OBBBA changes affecting corporate taxpayers, multinational businesses and transactional practice. Sessions addressed international tax developments six months after enactment;evolving global tax strategies; and practical considerations in mergers and acquisitions, from deal structuring through post-closing integration. Additional programming explored hot tax topics for closely held businesses and cross-border intellectual property planning for middle-market companies.
Former IRS Commissioner Danny Werfel delivered the Edward Kleinbard Memorial Lecture, reflecting on the IRS’s modernization efforts and the long-term implications of enforcement capacity, funding and administrative reform.
“When I thought about the vision that I wanted to champion at the IRS, it was all modern and technology focused,” said Werfel. “I’d say we want every taxpayer to have the option to do every interaction with the IRS digitally or virtually if they choose.”
The second day broadened the discussion to include partnerships, real estate, private clients and enforcement. Morning sessions reviewed recent partnership and real estate guidance, and current trends in investment funds. In the afternoon, attendees selected from concurrent tracks covering partnership separations and loss limitation rules, advanced planning strategies for high-net-worth individuals and family enterprises — including digital asset taxation — and ethics, compliance and enforcement issues, including discussions of valuation disputes and government investigations.
Luncheon keynote Don Snyder, Senior Advisor to the Assistant Secretary for Tax Policy in the U.S. Department of the Treasury Office of Tax Policy, who provided insight into current federal tax policy priorities and the ongoing implementation of OBBBA reforms.
“As tax professionals, there can sometimes be a tendency to conflate newsworthy with new guidance,” said Snyder. “Developments in tax law are obviously very important, but an over-focus on what tax law is risks obscuring what matters more, what tax law does.”
The final day of the Institute centered on estate planning, with expert speakers addressing recent developments, cross-border estate issues and advanced wealth transfer techniques. Sessions examined qualified small business stock (QSBS) planning in the post-OBBBA environment, grantor retained annuity trust (GRAT) design and administration, Chapter 14 transfers involving private equity and hedge fund interests, and current trends in gift and estate tax audits and litigation.
John W. Porter, Senior Partner at Baker Botts LLP, closed the luncheon keynote series with an examination of current trends in gift and estate tax audits and litigation, drawing on decades of experience representing taxpayers in high-stakes transfer tax controversies.
“Preparation for the audit begins at the planning level,” said Porter. “Anticipate your potential audience at the planning stage. When you write a letter, a memo, an email: think about how that might read if it were being read by somebody at the service, a tax court judge, a district court judge.”
Evening workshops throughout the Institute allowed for deeper exploration of specialized topics, including entertainment industry tax issues, partnership divisions, AI and ethics in tax practice, family office structuring, Employee Retention Credit enforcement and wellness considerations for legal professionals.
Established in 1948, the USC Gould Tax Institute remains a cornerstone event for tax professionals, with many returning year after year. The 2026 program continued this legacy, offering a rigorous and timely forum for education, dialogue and professional connection — equipping practitioners with the insight needed to navigate complexity and advise with confidence in an evolving tax environment.
USC Gould School of Law offers continuing legal education opportunities for professionals who want to learn and network with leading experts in their industries. A fixture of the Los Angeles legal community since 1948, USC Gould Continuing Legal Education hosts annual conferences for professionals at every level to learn from, and network with, the biggest players in entertainment, estate planning, business, tax and intellectual property. To learn more, visit or subscribe at gould.usc.edu/cle – and follow on Instagram, Facebook and LinkedIn.
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