36-Hour Taxation Law Specialization Package

Not everything is enforcement—some of the hardest calls are technical gray zones. In this presentation, Tax Section Chair Philipp Behrendt of Hochman Salkin Toscher Perez P.C. will walk attendees through expected areas of guidance under the new administration. Whether it is staking, the tax result of “wrapping” and “unwrapping,” whether crypto lending can track § 1058 nonrecognition, and a possible de minimis approach for tiny receipts (airdrops, small staking rewards, forks). Furthermore, we invite attendees to address their questions in the field of digital asset taxation.

Philipp Behrendt, Hochman Salkin Toscher Perez, P.C.
Beverly Hills Bar Association, Hills Bar Association Household

This program covers recent decisions by the California Court of Appeal and the California Supreme Court impacting property tax law. It also addresses planning techniques to manage property tax liability and reduce exposure to related taxes, such as the “Mansion Tax” (Measure ULA). Attorneys will gain practical insights applicable to real estate transactions and tax planning for clients.

Gregory Broege, Ajalat, Polley, Ayoob, Matarese & Broege

The Beverly Hills Bar Association's Taxation Law Section invites you to a timely and in-depth presentation on the recently enacted One Big Beautiful Bill (OBBB)—a sweeping tax reform package that makes the 2017 Tax Cuts and Jobs Act (TCJA) provisions permanent and introduces major structural changes across individual, business, and energy tax policy. This program will provide attorneys with a comprehensive understanding of the OBBB’s tax provisions, legislative structure, and long-term implications.

Marc Gerson, Miller & Chevalier Chartered

The session will provide an in-depth look at how the Bipartisan Budget Act (BBA) has transformed partnership audits, including the centralized partnership audit procedures under IRC §§ 6221–6241. Jennifer Black (Citrin Cooperman) and Robert Horwitz (Hochman Salkin Toscher Perez, P.C.) will guide attendees through the key components of a BBA audit—from the designation and powers of the Partnership Representative, to the calculation and modification of imputed underpayments, to the decision-making process between paying at the partnership level versus electing a push-out.

The program will also cover the mechanics and strategy behind Administrative Adjustment Requests (AARs), the strict timing rules and procedural traps, and how tiered partnership structures complicate compliance and reporting. Whether you advise on partnership formation, prepare partnership returns, or represent clients before the IRS, this presentation will deliver essential tools for navigating the BBA regime in practice.

Robert Horwitz, Hochman Salkin Toscher Perez, P.C.
Jennifer Black, Citrin Cooperman

This program focuses on key procedural and strategic differences between refund litigation in U.S. District Court and proceedings in U.S. Tax Court. Panelists will discuss practical considerations for choosing the appropriate forum. Using District Court case pleadings as examples, the panelists will discuss the full payment rule and its exceptions, administrative claims for refund, and each of the stages of District Court refund litigation. The presentation will provide real-world practice considerations based on the Federal Rules of Civil Procedure and district court practice throughout the lifecycle of a refund case, including settlement. The panelists will also highlight hot topics in refund litigation.

Melissa Briggs, Hochman Salkin Toscher Perez P.C.
Gary Slavett, Slavett Household

Join us for an informative BHBA Tax Section webinar covering key updates on state and international information reporting requirements for the 2024 filing season. The discussion will include an overview of state reporting requirements for 1099s, highlighting key forms that practitioners frequently encounter and important changes to be aware of this season. Speakers will also explain how the IRS Combined Federal/State Filing Program works.

The webinar will also cover international information reporting, including Forms 3520, 5471, and 8938. Panelists will discuss common compliance challenges, best practices, recent developments affecting international filers, and the substantial penalties

Stephen Mihaly, Attorney, KFB Rice, LLP
Wendy Walker, VP - Regulatory Affairs (Regtech), Sovos

The Economic Substance Doctrine plays a pivotal role in tax law, aiming to curb tax avoidance through transactions that lack genuine economic purpose beyond reducing tax liabilities.

Join Sebastian Voth for a comprehensive session examining the doctrine’s origins, its codification under IRC §7701(o), and how courts assess economic substance in real-world cases. This program will also provide practical insights into the doctrine’s evolution and highlight recent Tax Court decisions shaping its application today.

Join us for a webinar that examines the critical rules governing income apportionment for nonresident individuals and California residents. This session will provide a substantive analysis of California’s tax system, including the taxation of residents on worldwide income and nonresidents on California-source income. The discussion will focus on the legal frameworks underpinning these rules and the practical steps for addressing cross-border income allocation challenges, including when pursuing the Other State Tax Credit (OSTC) for taxes paid to other jurisdictions.

Key areas of focus will include wage allocation methodologies, the treatment of stock options and restricted stock units (RSUs), the taxation of performers and athletes, and the allocation of trust income. Our experts will review pertinent regulations and landmark case law to clarify the application of these rules and their implications for tax planning and compliance.

This program introduces attorneys to the key aspects of Qualified Small Business Stock (QSBS) under Section 1202. It covers eligibility criteria, tax benefits, holding periods, and limitations on capital gains exclusions. While Section 1202 is an income tax code section, effective tax planning often involves creative estate planning techniques, making this essential for estate planners. Additionally, attorneys involved in startup business planning will find valuable insights on business formation.

The incoming Government will consider potential shifts in tax policy that could significantly impact individuals, businesses, and the broader economy. Join us for an insightful presentation on the anticipated tax changes and priorities expected in the upcoming term. The experts will explore possible adjustments to the law and discuss policy directions that may arise in response to economic, environmental, and social goals.

Professor Edward McCaffery, Professor, USC Gould School of Law
Andrew Grossman, Chief Tax Counsel, House Committee on Ways & Means

To incentivize investment in clean or renewable energy, the Inflation Reduction Act of 2022 (IRA) created federal income tax credits available to investors in eligible clean or renewable energy projects. These credits are attractive to investors as they are transferrable, meaning that they can be sold by the entity generating the credits. But buyer beware, there are pitfalls abound! This program will explored the IRA credit and uncover the traps associated with transfer of these credits, including credit recapture, and state tax implications.

In connection with the additional appropriations from the Inflation Reduction Act, the IRS has committed to shift more attention to high-income earners – a group it defines as taxpayers earning at least $400,000 per year. This panel will inform attorneys about the IRS’s announced enforcement priorities for high-income earners and large partnerships, the expected timeline for additional enforcement, and strategies for representing clients in IRS examinations of high-income taxpayers.

Michel R. Stein, Principal, Hochman Salkin Toscher Perez
Aaron Vaughan, Managing Director, KPMG LLP
Eric Cirelli, Director of Field Operations, Global High Wealth and High Income Compliance Strategy, Internal Revenue Service
Justin D. Scheid, Deputy Area Counsel, Large Business and International Division (Area 3), Internal Revenue Service.

This presentation will cover appellate court decisions from the past 12 months, highlighting key rulings and their implications. It will also examine statutory developments, providing an overview of new laws and amendments affecting property taxation in California. Additionally, the presentation will discuss recent California initiatives, including the notable Newsom v. Weber lawsuit, and their potential impacts on property taxation policies and practices within the state.

This panel will examine the broader implications of the final regulations, particularly in relation to the computation of gross proceeds and basis, guiding attorneys on these critical issues. This session will discuss how the new reporting requirements influence the calculation of these financial metrics, which are essential for accurate tax reporting and compliance. Experts will explore the methodologies for determining gross proceeds and basis in digital asset transactions, highlighting the challenges and opportunities presented by the regulatory changes. Attorneys will gain valuable insights into advising their clients on these complex regulatory changes.

Ask the speaker a question. Email and be sure to include the program name in the subject line.

This presentation focuses on intermediary installment sales (IISs). These are marketed transactions involving a seller who is prepared to sell an asset to a buyer for a stated price. The promoter introduces the seller to an intermediary, who offers to (i) buy the asset for a note in the same amount, and (ii) sell the asset to the buyer for that price in cash (which can then be invested into some other income-producing investment).

The way in which seller benefits from these arrangements differs depending on the transaction. In one popular variation, the “Monetized Installment Sale” (MIS), the intermediary refers the seller to a third-party lender to obtain a loan for close to the same amount of the sale, and all three parties agree to an escrow process whereby seller’s interest income on the note is paid from intermediary to seller’s escrow account, which is ultimately forwarded to another escrow account to pay seller’s loan payment to lender.

IISs are marketed as a tax deferral strategy, and the result approximates a tax-free exchange, like a 1031 exchange but available for non-real property. The panel will discuss the recent proposed regulations on MISs, current enforcement by IRS, and possible alternative approaches to IISs generally.

Ask the speaker a question. Email and be sure to include the program name in the subject line.

The BBA audit rules provide a radically different approach for how adjustments are made in the partnership context. Although the BBA was enacted in 2015, practitioners are still grappling with its implications and how to advise clients. This panel will address issues that are critical in transactions and audits. After completing this session, participants will be able to:

Draft provisions in partnership agreements and other transactional documentation that address BBA issues
Calculate the imputed underpayment and evaluate strategies for shifting risk
Address the partnership audit rules in transactional due diligence

Navigating California’s tax code can be difficult for taxpayers living in California, but it gets even more difficult for taxpayers who either left the state or just moved here. Learn about California Residency Tax Audits and understand the rules for who is and isn’t a California resident. This program will also provide practical advice for those who plan to leave the state.

Beginning January 1, 2024, The federal Corporate Transparency Act will require certain (non-exempt) companies to file a report with the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) containing personal identifying information about the company, beneficial owners, and company applicants (filers). This presentation will cover:

Background on the Corporate Transparency Act

- Which companies are required to report
- What information must be included in the report
- Who are the beneficial owners and company applicants
- When the reports (and related amendments) are due
- What are some of the issues companies and law firms may consider

Jim Bourbeau, former EDD attorney and experienced taxpayer representative, will discuss post-AB 5 worker classification developments, both generally and specific to EDD payroll tax audits and litigation, as well as drafting post-AB 5 defensible independent contractor agreements.

The program will provide an overview of Tax Court litigation procedure with practical tips for litigating a case in Tax Court. It will be presented by practitioners whose experience includes representing taxpayers, the IRS, and clerking for a Tax Court judge to hear all sides of how to best present a case in Tax Court

After trusts were abused as income tax shelters in the early 20th Century, the government deployed a host of countermeasures. What remains of income tax planning with trusts in the current environment? We will explore the resurgence of nongrantor trusts, SLANTs, QSBS, basis management, jurisdictional planning, and charitable split interest trusts, with an eye for the income tax planning aspects of each.

This presentation covers the most significant tax rules that planners and clients should be aware of in making sure that a corporate separation will qualify as a tax-free event. Corporate separations typically occur when:
- Shareholders no longer agree on the direction of the corporation,
- Family business succession planning issues arise,
- Shareholders want to insulate different corporate divisions from the liabilities of other divisions,
- A corporation wants to give certain key employees an equity interest in a certain corporate division or
- A corporation wants to consolidate certain assets that are expected to sell in the future for a higher price.
- Failure to understand and carefully comply with the detailed tax rules to qualify as a tax-free corporate divisive reorganization will result in the entire business being treated as if it were sold.

The Pandora Papers is a leak of almost 12 million documents that reveals hidden wealth, tax avoidance and, in some cases, money laundering by some of the world's rich and powerful. Join the tax section for a discussion on the impact of the leak from the perspective of estate planning, tax, entertainment and criminal law.

IRS International Disclosure Requirements & Enforcement. Foreign Bank Account (FBAR) Reporting. Tools of Foreign Asset Protection Trusts for Lawyers and their Clients. Criminal and Civil Penalties ? FBAR Violations. Who Goes Offshore? Honest people? Dishonest people? People seeking highest form of financial privacy and protection from lawsuit creditors and predators? Crooks too, but we rarely see them and unlikely they will be accepted by trustees and offshore financial institutions. Why Go Offshore? Choice of law. Review of Voidable Transactions Act (Effective January 1, 2016). What is a ?voidable transaction?? California?s Uniform Voidable Transactions Act. The Panama Papers. 2021: The Pandora Papers. Civil and Ethical Implications for the Asset Protection Planner. Affidavit of Solvency. ?Tips to Live by When Counseling Clients on Asset Protection Strategies?. A Trustee?s Role in Defending the Trust. Bankruptcy. Foreign judgements not enforceable? A Trustee?s Role with Regards to Taxation.

Gregory Zbylut, In-House Counsel, Singer Burke Zimmer Kogan, LLP
Jeffrey M. Verdon, Managing Partner, Jeffrey M. Verdon Law Group, LLP
Gary Slavett, Principal, Holtz, Slavett & Drabkin, APLC
Craig S. Redler, Attorney, Jeffrey M. Verdon Law Group, LLP
Moderated by Michele F. L. Weiss, Principal, Holtz, Slavett & Drabkin, APLC

This program will go over the fundamentals of tax audits in order to provide business owners, entrepreneurs, and practitioners with the tools and language they need to navigate the maze of an audit situation. The IRS audit rate will rise as a result of the new funds from the Inflation Reduction Act; thus, this program will familiarize you with what to expect and prepare you for the various types of audit situations.

Cory Stigile, Hochman Salkin Toscher Perez, PC
Philipp Behrendt, Hochman Salkin Toscher Perez, PC

Jared Johnson will discuss how to help clients harmonize conflicts between their federal tax obligations and their religious practices.

Jared R. Johnson
White and Williams, LLP
Drawing on his fluency in French, Portuguese, and Spanish, Jared advises clients on matters related to cross-border transactions, helping numerous family businesses and high-net-worth individuals minimize their risks and tax liabilities through strategic business administration, estate planning and legacy planning.

Jared holds a certificate in dispute resolution from the Straus Institute for Dispute Resolution at Pepperdine University School of Law and is skilled at finding leverage in a dispute to force a settlement. However, having practiced extensively before the IRS and DOL in examinations and Tax Court litigation, he is prepared to fervently advocate for his clients in any setting. Jared is also a Certified Public Accountant enabling him to better service his clients regarding tax issues.

Jared?s clients include private Fortune 100 companies; Cayman Island and U.S. banks and their clientele; project investors in oil and gas, real estate, mining, gems and agriculture ventures; International Grammy-winning, Broadway, Hall of Fame and platinum entertainers; professional and Olympic athletes; and federal judges and politicians.

Cynthia Brittain with Karlin & Peebles, LLP works closely with multinational clients to design cross-border tax-efficient strategies, maximizing the benefits to their families? global companies while meeting the clients? personal succession needs.

Thomas Giordano-Lascari is a partner with Karlin & Peebles, LLP. Thomas?s practice focuses primarily on advising high-net-worth individuals and closely held businesses in connection with international income tax and estate planning issues. A significant portion of Thomas?s practice involves advising global families with respect to structuring and reorganizing multinational businesses to minimize worldwide taxes. Thomas also regularly advises clients regarding pre-immigration planning, foreign investment in the United States, U.S. residency planning and management, and expatriation planning.

The course covers the new rules for required minimum distributions (RMDs) from qualified retirement plans and IRAs that have been enacted in recent years. The course discusses changes that may be required to existing trusts and planning opportunities that may be available under the new rules.

Robert J. Lowe is a partner in the Los Angeles office of Mitchell Silberberg & Knupp LLP where he heads the employee benefits and executive compensation practice. His practice includes all areas of employee benefits and executive compensation including: qualified and nonqualified retirement plans; multiemployer pension and health plans; benefit plan issues in mergers and acquisitions; benefit plan investments in venture capital and real estate; equity incentive and nonqualified deferred compensation plans; group health plans including cafeteria plans and COBRA; benefit plans and executive compensation arrangements for employees of tax-exempt entities; income and estate tax planning for receipt of large distributions from retirement plans; and negotiating and drafting executive employment agreements.
Bob received his law degree from the University of California, Berkeley (Boalt Hall) and his undergraduate degree from the State University of New York at Binghamton. Bob has written many articles and speaks frequently on employee benefits issues.