74th Annual VIRGINIA Conference on Federal Taxation 2023

MCLE Credits: 14.0
Ethics Credits Included: 2.5

Thursday, June 1, 8:30 a.m.–5:15 p.m. ET and Friday, June 2, 8:30 a.m.–5:15 p.m. ET Live on Site at the University of Virginia Darden School of Business 100 Darden Boulevard Charlottesville, VA 22903 Live Webcast Live Telephone
MCLE Credit: CPE Credit for Accountants:	14.0 (Ethics: 2.5) 16.0
Live-Interactive Credit:	14.0 (all dates, all formats)
Registration Fees: (all formats)	$525 regular registration $425 my firm has registered 3 full-price attendees prior to my registration $325 first-time attendee registration

Information
Schedule
Faculty
Locations, Dates and Fees

Information

Objectives

Learn the law and how to apply it so you can:

Update your practice to account for new cases, legislation, and regulations
Take advantage of new planning techniques and tax trends
Create strategies to assist with challenges faced by clients, for both individuals and businesses
Employ successful new solutions to manage common problems

Virginia’s Premier Tax Conference for Attorneys and Accountants
Sponsored by The Virginia Tax Foundation

Valuable tax-planning and tax-saving strategies developed for individuals, corporations, pass-through entities, estates, gifts, and trusts are provided by some of the nation’s leading authorities in the area of taxation law and practice.

2023 CONFERENCE HIGHLIGHTS

Federal Tax Updates—Individuals and Business
Update on Tax Policy from Washington
Tax Issues of Being Self-Employed
Tax Planning for Retirement Accounts
Opp. Zones: Common Traps and How to Avoid Them
Real-Life Ethics Issues for Tax Practitioners
Hot Topics in Partnership and Real Estate Taxation
Pass-Through Entity Tax: Where Are We Now? What’s in Store?
Recent Developments in Virginia Taxation
Transaction Structuring Changes with a Partnership Versus an S Corporation
Hot Topics in the Coming Year

Prerequisites: Minimum 5 years active practice or advanced degree
Program Level: Advanced
Advance Preparation: None
Delivery Method: Live on site, live-interactive webcast/telephone
Field of Study: Taxes

PLEASE NOTE: This seminar is not eligible for Virginia CLE^® discounts, and Virginia CLE^® Online+ Bundle credits and Unlimited Passes may NOT be used to register for this program.

COVID-19 POLICY FOR LIVE-ON-SITE ATTENDANCE

By attending a live-on-site Virginia CLE^® seminar, you acknowledge the health risks associated with COVID-19 and that you MUST follow all Virginia CLE^® COVID-19 policies. You may NOT attend a live-on-site program if you have tested positive for COVID-19, if you are experiencing COVID-19 symptoms, or if you are under any self-quarantine orders per CDC guidelines.

Registration Deadlines:
Webcast:	10 minutes prior to seminar. If you register for a webcast the day of the seminar, your e-mail receipt will include a link to launch the seminar and download the materials.
Telephone:	Online registration ends at 11:59 p.m. the day preceding the seminar Call (800) 979-8253 to register up to one hour prior to the seminar
Live on Site:	Online registration ends at 11:59 p.m. the day preceding the seminar Walk-in registration is permitted on a space-available basis

Cancellation and Administrative Policies: For registrations made for live-on-site attendance, a processing fee of $100 will be charged for cancellations made after 5:00 p.m. on Thursday, May 25. Transfers may be made to the webcast or telephone formats without penalty.

For registrations made for webcast or telephone attendance, cancellation/transfer requests will be honored until 5:00 p.m. on Wednesday, May 31; you will, however, be charged $90 if you cancel or transfer your registration to a different seminar after the link to the materials has been e-mailed by Virginia CLE. Full refunds or transfers are available up to two days after a webcast in the unlikely event that you experience technical difficulties.

Inclement Weather Policy and Updates.

MCLE Credit Caveat: The MCLE Board measures credits by the time you spend in attendance. If you enter a seminar late or leave it early, or both, you must reflect those adjustments accurately in the credits you report on your credit reporting form. A code will be given at the end of the seminar, which must be written on your MCLE form.

Can't Attend?
E-mail distance_ed@vacle.org to be notified when/if this program is made available as an On Demand or USB seminar.
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Schedule

COURSE SCHEDULE (June 1 and June 2) (Eastern Time)

Thursday, June 1

8:00	Registration
8:30	Opening Remarks
8:40	Update on Tax Policy from Washington Jeffrey Kummer A look at the potential for tax legislation this year including a review of key tax proposals that would impact businesses and individuals, the possible timing of proposed tax law changes, and the budgetary processes that can be expected to be considered.
9:40	Break
9:50	Tax Issues of Being Self-Employed/Worker Classification Rules Karen M. Field A review of the federal income tax rules and employee benefit rules that apply to a self-employed individual. This will include the IRS tests for determining whether an individual is an independent contractor or a misclassified employee. We will discuss contract issues and the “employee benefits” an independent contractor can have, and how they differ from benefits for employees. We will also very briefly discuss the updated Virginia rule on independent contractors.
10:50	Break
11:00	Tax Planning for Retirement Accounts After the SECURE Act 2.0 Christine Nguyen Piersall The SECURE Act 2.0 was signed into law on December 29, 2022. This session will explore the effect on retirement accounts and potential tax planning with the new 2.0 Act, as well as the SECURE Act and the IRS proposed regulations.
12:00	Lunch (provided at live-on-site program)
12:45	Merger and Acquisition Update David L. Dallas, Jr., Scott Zickefoose This session will discuss the trends that merger and acquisition professionals are seeing in the middle market. The panelists will discuss observations about current valuations, key deal provisions, and changes to deal structure that have been observed over the past year and comment on expected trends for the rest of 2023.
2:15	Break
2:30	Opp. Zones: Common Traps and How to Avoid Them Laura Jones, Drew Hermiller This session will discuss opportunity zone investments and common compliance and structuring problems that often arise (such as tangible asset and gross income test compliance, “circular cash” issues, related party issues, and working capital safe harbor issues) as well as strategies for how to avoid or ameliorate such problems.
3:30	Break
3:40	Real-Life Ethical Issues in Everyday Tax Practice Chris Rizek Tax practitioners of all varieties are often confronted by ethical quandaries—although we might not recognize them immediately. And even when we do, the number and variety of potentially applicable rules can be bewildering. This presentation will cover a number of common situations and issues, discuss the rules applicable to them, and give some pointers for avoiding problems. Topics will include conflicts (under Rule 1.7 and related provisions of both the ABA Model Rules and the Virginia Rules of Professional Conduct; and Section 10.29 of Circular 230); competence and due diligence, especially in return preparation and the correction of errors (Model/VA Rules 1.1, 1.3; Cir. 230 secs. 10.21, 10.22, 10.34, 10.35, 10.37; Internal Revenue Code section 6694; and AICPA’s SSTS 1 and 6); fee arrangements (Rule 1.5; Cir. 230 sec. 10.27); and confidentiality and privileges (Rules 1.6; Code secs. 7216, 7525).
5:10	Closing Remarks
5:15	Adjourn
5:30	Reception

Friday, June 2

8:30	Opening Remarks
8:40	Federal Tax Update—Individuals Cassady V. Brewer, Bruce McGovern This session will review the most significant statutory enactments, judicial decisions, IRS rulings, and Treasury regulations promulgated during the last twelve months that affect general domestic income taxation and tax procedure for individuals.
9:55	Break
10:05	Federal Tax Update—Business Cassady V. Brewer, Bruce McGovern A review of statutory enactments, judicial decisions, IRS rulings, and Treasury regulations promulgated during the last twelve months that affect corporate taxation, partnership taxation, tax-exempt organizations, and tax procedure.
11:20	Break
11:30	Hot Topics in Partnership and Real Estate Taxation Kendal Sibley This session will discuss recent developments in the areas of partnership and real estate taxation, including authorities addressing treatment of limited partners under section 1402, deductibility of deferred compensation in a sale transaction, partnership and real estate proposals in the Administration’s 2023 budget, updates on partnership tax reporting, and other important guidance.
12:30	Lunch (provided at live-on-site program)
1:15	Pass-Through Entity Tax: Where Are We Now? What’s in Store? Lori Roberts This presentation will include a review of existing provisions and pending changes of Pass-Through Entity Taxation, aka PTET, in Virginia; an overview of PTET provisions in other states; and a discussion regarding planning considerations, traps, and opportunities.
2:15	Break
2:25	How Transaction Structuring Changes with a Partnership Versus an S Corporation Brian J. O'Connor, Steven R. Schneider This panel will discuss how transactions are structured differently depending on whether the equity vehicle is a partnership or an S corporation, including (1) infusing new money; (2) restructuring and disposition structuring; (3) compensation planning; (4) estate planning; and (5) capital gain and holding period planning.
3:55	Break
4:00	Ethical Issues Regarding Tax Information, Reporting, and Disclosures Stephen W. Murphy, Bradley Ridlehoover When offering tax analysis and advice, the client and professional confront a host of issues regarding the management and flow of information, particularly related to ethics and confidentiality. False steps can open the professional to ethical violations and liability and can put the client in a difficult position related to third parties and the IRS. This presentation will address ethical issues for the tax attorney, accountant, advisor, and tax professional regarding disclosures and information. The topics addressed will include the duty to disclose (or to not disclose) past errors or omissions to the IRS; ethical issues regarding reporting positions to the IRS; the “fiduciary exception” to attorney-client privilege and its application to tax-related issues; the attorney-client privilege and third parties, such as CPAs, investment advisors, valuation firms, family office professionals, and family members; and the effect of technology on these issues.
5:00	Closing Remarks
5:15	Adjourn

Q&A will be handled via chat room for Webcast attendees.
Q&A will be handled via e-mail for telephone seminar attendees.

Faculty

FACULTY

Cassady V. Brewer, Georgia State University College of Law / Atlanta, GA
David L. Dallas, Jr., Williams Mullen / Charlottesville
Karen M. Field, RSM US LLP / Washington, DC
Drew Hermiller, Hunton Andrews Kurth / New York, NY
Laura E. Jones, Hunton Andrews Kurth / Richmond
Jeffrey Kummer, Deloitte Tax LLP / Washington, DC
Bruce McGovern, South Texas College of Law Houston / Houston, TX
Stephen W. Murphy, McGuireWoods LLP / Charlottesville
Brian J. O'Connor, Venable LLP / Baltimore, MD
Christine Nguyen Piersall, Williams Mullen / Norfolk
Bradley A. Ridlehoover, McGuireWoods / Richmond
Christopher S. Rizek, Caplin & Drysdale / Washington, DC
Lorilei J. Roberts, PBMares / Fairfax
Steven R. Schneider, Stroock / Washington, DC
Kendal A. Sibley, Hunton Andrews Kurth / Richmond
Scott Zickefoose, Keiter CPA / Glen Allen

PLANNING COMMITTEE

L. Michael Gracik, Jr., Co-Director
Keiter / Glen Allen

D. French Slaughter, III, Co-Director
Charlottesville

Jeff Barbour
Brown, Edwards & Company, LLP / Roanoke

Christopher C. Brubaker
Hantzmon Wiebel LLP / Charlottesville

David M. Chase, Jr.
Wall, Einhorn & Chernitzer, PC / Norfolk

David J. Damiani, J.D.
PBMares / Williamsburg

Michael Doran
University of Virginia School of Law / Charlottesville

Kristen Frances Hager
McGuireWoods / Richmond

Cecelia P. Horner
Hunton Andrews Kurth LLP / Richmond

Christopher M. Kozlowski
Gentry Locke / Roanoke

Lawrence J. Martin
Hantzmon Wiebel LLP / Charlottesville

Jon G. Neal
McGuireWoods / Richmond

Professor Susan L. Porter
University of Virginia McIntire School of Commerce / Charlottesville

Professor Jeri K. Seidman
University of Virginia McIntire School of Commerce / Charlottesville

Bruce C. Stockburger
Gentry Locke / Roanoke

Kyle Wingfield
Williams Mullen / Richmond

Professor Ethan Yale
University of Virginia School of Law / Charlottesville

TRUSTEES EMERITUS

George C. Howell, III
Hunton Andrews Kurth / Richmond

Thomas P. Rohman
McGuireWoods LLP / Richmond

Thomas R. White
University of Virginia School of Law / Charlottesville

George K. Yin
University of Virginia School of Law / Charlottesville

Locations, Dates and Fees

REGISTRATION FEES (all formats)
(All registrants will receive access to a complete set of downloadable e-book seminar materials. Printed materials will NOT be available.)

$525 regular registration
$425 my firm has registered 3 full-price attendees prior to my registration
$325 first-time attendee registration

LIVE LOCATION AND DATES

Charlottesville / Thursday and Friday, June 1-2
University of Virginia / Darden School of Business (Venue Website / Google Map)
100 Darden Boulevard
Charlottesville, VA 22903

COMPLIMENTARY REFRESHMENTS AND SOCIAL EVENTS

BREAKFAST. Breakfast breads and beverages will be provided both mornings of the Conference.
LUNCH. Lunch will be provided both days of the Conference.
COCKTAIL PARTY. “Meet and Greet” on Thursday, June 1, at 5:30 p.m.

OVERNIGHT ACCOMMODATIONS

We have room blocks available at the Boar’s Head Resort and Sonesta Suites:

Boar’s Head Resort
200 Ednam Drive
Charlottesville, VA 22903
434-972-7439

Overnight accommodations are still available at the Boar’s Head. Please call the Reservations Office at 434-972-7439 and be sure to mention the Virginia Conference on Federal Taxation to receive our group rate.

We also have room blocks available at the Sonesta Suites:

Sonesta ES Suites Charlottesville University
1111 Millmont Street
Charlottesville, VA 22903
434-923-0300

Please follow this link for web reservations.

ACCREDITATION

The Virginia Tax Foundation is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.

CANCELLATION AND ADMINISTRATIVE POLICIES: For registrations made for live-on-site attendance, a processing fee of $100 will be charged for cancellations made after 5:00 p.m. on Thursday, May 25. Transfers may be made to the webcast or telephone formats without penalty.

Inclement Weather Policy and Updates.

If you have a disability that requires special accommodation, please contact Virginia CLE^® well in advance of the program date.

If you have dietary restrictions, please contact Virginia CLE^® at least 7 days before the seminar date.

Private recording of this program is prohibited.