The 2025 USC Tax Institute tackles tax policy shifts and planning for the future
The USC Tax Institute brought together hundreds of tax professionals at its 2025 conference January 27–29. The continuing legal education institute, titled “Timeless Tax Planning,” delved into emerging tax issues and highlighted the latest developments in legislation and policy.
Hosted by USC Gould School of Law, the three-day conference welcomed over 500 attendees, including tax lawyers, accountants, and financial planners, who joined both in person at the Sheraton Grand Hotel in downtown Los Angeles and virtually through a live broadcast.
Each year, the Tax Institute features a keynote lecture in honor of the late Edward Kleinbard, a USC Gould professor, renowned tax expert, and longstanding contributor to the Institute. Stephen Shay, Paulus Endowment Senior Tax Fellow and Adjunct Professor at Boston College Law School, delivered the 2025 Edward Kleinbard Keynote. Shay’s lecture explored the policy implications of aggressive tax avoidance and its classification as an illicit financial flow, emphasizing its impact on global economic stability and sustainable development.
“We need to take on tax relief, illicit financial flows of avoidance,” said Shay. “Why? Because it is in our best interest. We are asking other countries to support their own security. What sense does it make to not cooperate and coordinate in trying to improve the revenue in all our countries?”
The second day of the conference began with an overview of recent developments in partnership and real estate guidance, presented by Eric B. Sloan and James Jennings of Gibson, Dunn & Crutcher LLP. The day also featured a luncheon keynote by Michael J. Desmond, former IRS Chief Counsel, who discussed the evolving role of administrative rulemaking in tax law following recent Supreme Court decisions.
“Loper Bright is a sea change in that it pulls a lot of authority away from the executive branch to come up with any reasonable interpretation and puts it in the judicial branch,” said Desmond. “Going back to the founding of this country, the courts ultimately have the authority to say what the law is.”
Edward McCaffery, professor at USC Gould School of Law, delivered the closing keynote on the impact of recent Supreme Court tax rulings, including the impact of Connelly, Moore, and Loper Bright, in reshaping tax enforcement, limiting regulatory authority, and redefining how tax laws are applied—both in the courts and in administrative practice. McCaffery also examined declining tax enforcement, growing advantages for high-net-worth individuals, and the shift toward taxing wages over capital, emphasizing the need for proactive tax planning amid regulatory uncertainty.
“We’re not taxing capital,” said McCaffery. “The people who can live off their wealth are not paying any meaningful tax. What’s left? Wages. The government needs money. It’s not taxing capital to have tax wages. The income tax is becoming a wage tax.”
The final day centered on estate planning, with sessions addressing the planning challenges posed by the upcoming 2026 tax law changes. Expert speakers provided actionable insights into navigating the complexities of generation-skipping transfer (GST) tax on nonexempt trusts and cross-border estate planning. Attendees explored real-world financial outcomes of various estate planning strategies during an engaging afternoon session.
After the luncheon keynote presentations each day, attendees selected from concurrent session tracks covering corporate tax, partnerships and real estate tax planning, individual tax planning, and ethics, compliance, and enforcement. Evening workshops allowed for in-depth exploration of niche topics, including entertainment industry tax issues, partnership divisions, and wellness strategies for legal professionals.
Established in 1948, the Tax Institute remains a cornerstone event for tax professionals, with many returning year after year. The 2025 conference continued this legacy, offering a robust program of education, networking, and professional growth opportunities for both in-person and virtual participants.
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 six 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 Twitter, Instagram, Facebook and LinkedIn.
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