70^th Annual

Taxation Conference: Day 1 - Controversy

Wednesday: Focus on Controversy

Austin Nov 30, 2022 DoubleTree by Hilton Hotel Austin
Conference Concluded

Live Webcast Nov 30, 2022
Conference Concluded

Buy

Related products: eConference Materials

EVENT SPONSORS
ABIP, P.C.
Frost Wealth Advisors

CONFERENCE SPONSORS
Baker Botts
Clark Hill, PLC
Holland & Knight LLP
Martens, Todd, & Leonard
McCarter & English, LLP
McDonald & Adkins, LLP
Porter Hedges LLP

Download Brochure (PDF)

Overview

UT Law CLE’s 70th Annual Taxation Conference presents the expertise and in-depth analysis essential to understanding where tax law is, where it came from, and where it is going. With a renowned slate of regional and national speakers, the conference is a must attend event for those looking to keep current amidst a dramatically changing tax landscape.

NEW agenda format this year! The topics have been grouped according to subject matter and each day has a cohesive theme. Join us on Wednesday: Focus on Controversy and/or Thursday: Focus on Business Transactions.

Attendees who register for both days of the Taxation Conference will obtain their full 15.00 hours of MCLE, including 4.25 hours of ethics. No need for additional self-study or seeking extra credit!

Continue Friday with Professor Stanley M. Johanson’s popular Estate Planning Workshop offering lively discussion, practical advice, and updates.

Event Schedule

Program is subject to change.
All times are Central Time Zone.

Time

Credit

Subject

Speaker
Wednesday Morning, Nov. 30, 2022
Presiding Officer:
T. Charles Parr III, ABIP, P.C. - San Antonio, TX
7:30 am
Austin Only

Registration Opens

Includes continental breakfast.
8:20 am

Welcoming Remarks
8:30 am

2.00 hrs

Recent Developments

Review significant court decisions, rulings, and statutory and regulatory developments of the past year.

Bruce A. McGovern, South Texas College of Law Houston - Houston, TX
10:30 am

15-Minute Break
10:45 am

0.50 hr

Texas Taxes: Recent Developments

An experienced trial attorney specializing in Texas taxes covers the new laws for challenging tax assessments in state court, research incentive issues, oilfield services audit policy changes, franchise tax apportionment issues, local sales tax sourcing for internet sales, and more.

Lacy Leonard, Martens, Todd, & Leonard - Austin, TX
11:15 am

1.00 hr
0.25 hr ethics

Multistate SALT Issues and Business Migration

Navigating multistate tax compliance post-Wayfair including business migrations to Texas, remote worker issues, and transactional considerations.

Christina A. Mondrik, Mondrik & Associates - Austin, TX
Steven D. Moore, Jackson Walker LLP - Austin, TX
12:15 pm
Austin Only

Pick Up Lunch (in Austin)

Included in registration.
Wednesday Afternoon, Nov. 30, 2022
Presiding Officer:
Jimmy Martens, Martens, Todd, & Leonard - Austin, TX
LUNCHEON PRESENTATION
Introduction

Maxine Aaronson, Attorney at Law - Dallas, TX
12:45 pm

1.00 hr ethics

Identifying Emerging Issues at the IRS

A view from inside the agency about how the IRS keeps up with emerging tax noncompliance and tax fraud issues and an introduction to the new IRS Joint Strategic Emerging Issues Team.

Tom Cullinan, Office of the Commissioner, Internal Revenue Service - Washington, DC
Holly Porter, Passthroughs & Special Industries, Office of Chief Counsel, Internal Revenue Service - Washington, DC
1:45 pm

15-Minute Break
2:00 pm

1.00 hr
0.25 hr ethics

How Firm are Court Filing Deadlines in Tax Cases?

Earlier this year, the Supreme Court rejected the IRS’s position that the 30-day deadline for filing a Tax Court petition in a Collection Due Process case is “jurisdictional” and therefore not subject to equitable tolling. The decision follows a recent trend in Supreme Court jurisprudence and its potentially far-reaching consequences in Tax Court cases is already being litigated. Former IRS Chief Counsel Mike Desmond explains and evaluates the breadth of the decision, potential government responses, and the ramifications of this important development in other areas of the tax law.

Michael J. Desmond, Gibson, Dunn & Crutcher LLP - Los Angeles, CA
3:00 pm

1.00 hr
0.25 hr ethics

Dealing with Sticky Situations: Overbroad IDRs, Requests for Client Interviews, and Other Tricky Audit Situations

With the IRS laser-focused on enforcement, many taxpayers may find themselves subject to an intrusive audit. These audits can involve tricky situations like client interviews, broad IDRs, site tours, and acknowledgment of facts IDRs. These speakers discuss best practices and considerations in handling these tricky situations, as well as the importance of civility in interactions with the IRS.

Mary A. McNulty, Holland & Knight LLP - Dallas, TX
Lee Meyercord, Holland & Knight - Dallas, TX
4:00 pm

10-Minute Break
4:10 pm

1.00 hr ethics

Keeping Your Clients Out of Hot Water: Drafting Effective Tax Return Disclosures

A well-drafted disclosure statement can provide more penalty protection than a tax opinion letter. This skill-building session teaches you how to improve the disclosures you write to manage audit risk and limit penalties.

Lawrence Sannicandro, McCarter & English, LLP - Newark, NJ
5:10 pm

Adjourn
5:15 pm
Austin Only

Networking Reception (in Austin from 5:10 p.m. – 6:10 p.m.)

Join us for drinks and hors d'oeuvres with program faculty and attendees.

Thank You to Our Sponsor

Download Schedule

Conference Faculty

Maxine Aaronson

Attorney at Law
Dallas, TX

Tom Cullinan

Office of the Commissioner, Internal Revenue Service
Washington, DC

Michael J. Desmond

Gibson, Dunn & Crutcher LLP
Los Angeles, CA

Lacy Leonard

Martens, Todd, & Leonard
Austin, TX

Bruce A. McGovern

South Texas College of Law Houston
Houston, TX

Mary A. McNulty

Holland & Knight LLP
Dallas, TX

Lee Meyercord

Holland & Knight
Dallas, TX

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Steven D. Moore

Jackson Walker LLP
Austin, TX

Holly Porter

Passthroughs & Special Industries, Office of Chief Counsel, Internal Revenue Service
Washington, DC

Lawrence Sannicandro

McCarter & English, LLP
Newark, NJ

Planning Committee

Jimmy Martens—Chair

Martens, Todd, & Leonard
Austin, TX

T. Charles Parr III—Vice-Chair

ABIP, P.C.
San Antonio, TX

Maxine Aaronson

Attorney at Law
Dallas, TX

R. Gordon Appleman

Holland & Knight LLP
Fort Worth, TX

Stanley L. Blend

Clark Hill, PLC
San Antonio, TX

Michael L. Cook

Cook Brooks Johnson PLLC
Austin, TX

Joel N. Crouch

Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
Dallas, TX

Barbara Spudis de Marigny

Baker Botts
Houston, TX

Dennis B. Drapkin

Southern Methodist University Dedman School of Law
Dallas, TX

Lawrence B. Gibbs

Miller & Chevalier
Washington, DC

Donald O. Jansen

The University of Texas System
Austin, TX

Calvin H. Johnson

The University of Texas School of Law
Austin, TX

Kenton E. McDonald

McDonald & Adkins, LLP
Corpus Christi, TX

Christina A. Mondrik

Mondrik & Associates
Austin, TX

Patrick L. O'Daniel

Norton Rose Fulbright
Austin, TX

Catherine C. Scheid

Attorney at Law
Houston, TX

MCLE Credit

Texas – 7.50 hrs | 2.75 hrs Ethics
Legal Specialization(s): Estate Planning and Probate Law, Tax Law

You may claim your credit online in Your Briefcase, and UT Law CLE will report credit on your behalf to the State Bar of Texas. A Certificate of Attendance will be provided in Your Briefcase for your records. The system reports Texas CLE credit every Monday. If you are claiming credit in the last week of your birth month, self-report your CLE credit directly to the State Bar of Texas at texasbar.com

California – 7.50 hrs | 2.75 hrs Ethics

At the conference, you will need to sign in on the Record of Attendance form at the registration desk. Self-report your CLE credit directly to the State Bar of California at calbar.ca.gov. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. UT Law CLE will maintain Attendance Records for four years.

Oklahoma – 9.00 hrs | 3.50 hrs Ethics

At the conference, you will need to sign in on the Record of Attendance form at the registration desk. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. UT Law CLE will report credit on your behalf to the Oklahoma Bar Association within 30 days after the conference.

Pennsylvania – 7.50 hrs | 2.50 hrs Ethics

UT Law CLE is an approved provider of Pennsylvania credit, sponsor #236. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. You may also be required to sign-in at the registration desk if you are attending in-person - please see staff onsite for more details. Attorney attendance will be reported to Pennsylvania within 2 weeks of the webcast conclusion. Attorneys are not able to report this credit on their own, and UT Law CLE pays all associated fees for the credit hours. Contact Laura Tolin, ltolin@law.utexas.edu, if you have additional questions.

Other States – 7.50 hrs | 2.75 hrs Ethics

Note on Self-Reporting Your Credits in Another State

If you wish to satisfy MCLE or other professional education requirements in another state for a program offered by the University of Texas School of Law, please check with the state bar or other licensing authority in that state to ensure it will qualify for self-reporting your credits.

At the conference, you will need to sign in on the Record of Attendance form at the registration desk. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records.

MCLE credit is presented based on a 60-minute credit hour.

Other Credit

Certified Financial Planner (CFP) – 9.00 hrs

This course has been approved for Certified Financial Planner (CFP) credit. UT Law CLE will report your credit for you, but we do require your CFP license number and other information in order to do so. Accreditation Coordinator April Rogers will follow up with you to obtain this information within 7 days of the conference.

You can learn more at: http://www.cfp.net/

National Accounting CPE – 9.00 hrs

The University of Texas School of Law 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.nasbaregistry.org.

Delivery Method: Group-Live (UT Law CLE is a provider of NASBA Group-Live credit only, which excludes online offerings. If you need Accounting credit in any state other than Texas, please review the self-reporting guidelines on the NASBA website to confirm your ability to self-report credit from the live webcast.)

To comply with NASBA Standards, attendees claiming CPE credit must sign in to verify attendance for each segment. Attendance sign-in sheets will be available at the registration desk. You will need your CPA license number to sign in. A CPE Certificate of Completion will be provided at the conclusion of the conference.

Reporting: CPAs are responsible for reporting CPE credits earned to their state's accountancy board, and must retain appropriate documentation of their participation in learning activities. Visit your state’s reporting website for more information or www.nasba.org.

TX Accounting CPE – 9.00 hrs

The University of Texas School of Law (Provider #250) live conferences are presumptively approved by The Texas State Board of Public Accountancy for Texas Accounting CPE credit based on a 50-minute credit hour. Approved for general CPE credit only.

At the conference, you are welcome to sign in on the Accounting CPE Record of Attendance form at the registration desk, but we are now reporting all credit online. You will receive a Texas Accounting Certificate of Completion in Your Briefcase. Self-report your CPE credit directly to TSBPA. UT Law CLE will maintain Attendance Records for four years.

Contact Laura Tolin, ltolin@law.utexas.edu, if you have additional questions.

MCLE Credit

Texas – 7.50 hrs | 2.75 hrs Ethics
Legal Specialization(s): Estate Planning and Probate Law, Tax Law

UT Law CLE will report credit to the State Bar of Texas on your behalf. If you are claiming credit in the last week of your birth month, self-report your credit directly to the State Bar of Texas at texasbar.com. A Certificate of Completion will be emailed to you upon claiming credit.

California – 7.50 hrs | 2.75 hrs Ethics

Self-report your CLE credit directly to the State Bar of California at calbar.ca.gov. Print and keep the Certificate of Completion for your records. A Certificate of Completion will be emailed to you upon claiming credit.

Oklahoma – 9.00 hrs | 3.50 hrs Ethics

The University of Texas School of Law (Provider #169) live webcast presentations meet the requirements and are presumptively approved by the Oklahoma Bar Association for MCLE credit based on a 50-minute credit hour. This accreditation requires attendance verification. In compliance with the rules, UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. The response record is detailed on the Certificate of Completion.

To claim Oklahoma MCLE credit, Oklahoma credit option must be selected PRIOR to viewing the live webcast. Upon claiming credit, a Certificate of Completion will be emailed to you. UT Law CLE will report credit on your behalf to the Oklahoma Bar Association within 30 days after the webcast.

Pennsylvania – 7.50 hrs | 2.50 hrs Ethics

UT Law CLE is an approved provider of Pennsylvania credit, sponsor #236. Attorney attendance will be reported to Pennsylvania within 2 weeks of the webcast conclusion. Attorneys are not able to report this credit on their own, and UT Law CLE pays all associated fees for the credit hours. Contact Laura Tolin, ltolin@law.utexas.edu, if you have additional questions.

Other States – 7.50 hrs | 2.75 hrs Ethics

Note on Self-Reporting Your Credits in Another State

To claim Other States MCLE credit, Other States credit option must be selected PRIOR to viewing the live webcast. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records.

This accreditation requires attendance verification. UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. The response record is detailed on the Certificate of Completion.

MCLE credit is presented based on a 60-minute credit hour.

Other Credit

Certified Financial Planner (CFP) – 9.00 hrs

TX Accounting CPE – 9.00 hrs

The University of Texas School of Law (Provider #250) live webcast presentations meet the requirements and are presumptively approved by the Texas State Board of Public Accountancy for Texas Accounting CPE credit based on a 50-minute credit hour. Approved for general CPE credit only.

This accreditation requires attendance verification. In compliance with the rules, UT Law CLE monitors and records attendee responses to questions that randomly appear during the live webcast presentation. The response record is detailed on the Certificate of Completion.

To claim Texas Accounting CPE credit, the Texas Accounting CPE credit option must be selected PRIOR to viewing the live webcast. Upon claiming credit, a Certificate of Completion will be emailed to you. Self-report your CPE credit directly to the Texas State Board of Public Accountancy.

Contact Laura Tolin, ltolin@law.utexas.edu, if you have additional questions.

Key Dates

Austin – Nov 30, 2022 – DoubleTree by Hilton Hotel Austin

Conference Concluded

Live Webcast – Nov 30, 2022

Conference Concluded

Buy

Austin
Live Webcast

Individual
Last day for $350.00 Regular pricing: Nov 21, 2022

$400.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $315.00 Regular pricing: Nov 21, 2022

$365.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $280.00 Regular pricing: Nov 21, 2022

$330.00 for registrations received after this time

Last day for cancellation (full refund): Nov 21, 2022

$50 processing fee applied after this date

Last day for cancellation: Nov 28, 2022

Individual
Last day for $350.00 Regular pricing: Nov 21, 2022

$400.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $315.00 Regular pricing: Nov 21, 2022

$365.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $280.00 Regular pricing: Nov 21, 2022

$330.00 for registrations received after this time

Venue

DoubleTree by Hilton Hotel Austin

6505 N. Interstate 35
Austin, TX 78752-4346
512-454-3737
512-454-3737 (reservations)
Map

Accommodations

A limited number of rooms have been reserved at a special rate of $140 per night. Special room rate is available until November 8, 2022, or until the room block is exhausted, whichever comes first. You can reserve by calling 800-866-3126 and reference UT Taxation and Estate Planning Conference or by visiting their website here.

Parking Information

Daily or Overnight Self-parking: $10

Valet parking is available at $25 a day

Our Sponsors

Thank you to our sponsors! Click each logo below to learn more.

ABIP, P.C.

ABIP is a Texas-based CPA and advisory firm with offices in San Antonio and Houston. ABIP’s client service approach is to seek and assist with value contributions as organizations grow. This approach is collaborative and technical to achieve the desired and unique goals of each client.

While each client has different needs, ABIP’s services help clients focus on their core business. The available services are robust and include access to an international network of member firms. Their clients include privately held businesses, family legacy offices, start-up companies, high-net-worth individuals, non-profits, and government entities. To learn more, please reach us at 210.341.2581.
www.abipcpa.com
Frost Wealth Advisors

Frost is the banking, investments and insurance subsidiary of Cullen/Frost Bankers, Inc. (NYSE: CFR), a financial holding company with $51 billion in assets at September 30, 2022. One of the 50 largest U.S. banks by asset size, Frost provides a full range of banking, investments and insurance services to businesses and individuals in the Austin, Corpus Christi, Dallas, Fort Worth, Houston, Permian Basin, Rio Grande Valley and San Antonio regions. Founded in 1868, Frost has helped Texans with their financial needs during three centuries. For more information, visit www.frostbank.com.
www.frostbank.com/personal/investments
Baker Botts

Since 1840, Baker Botts has been among the leading law firms. Today, with 725 lawyers based in 13 locations around the world, it ranks among the largest global law firms in scope and influence. We focus on providing full service in the energy and technology sectors. We regularly work with project companies, banks, insurance companies, investment firms, governmental agencies, non-profit organizations, individuals, estates and partnerships. Baker Botts represents most of the Fortune 100 companies, as well as many individuals and small and medium sized business entities.

Baker Botts’ market leading practices advise clients on cutting edge issues in all manner of tax matters; project development and finance; international trade; corporate finance and securities; legislative, administrative and regulatory activities; civil and white-collar criminal defense, litigation, arbitration; real estate; intellectual property; government contracts law; and environmental matters. We are chosen for experience in representing clients in novel and innovative projects, and for matters that can determine the success or failure of a company. Trust is a cornerstone of all our client relationships.
www.bakerbotts.com
Clark Hill, PLC

Clark Hill is a full service international law firm with 27 offices in the United States, Ireland, and Mexico. In Texas, Clark Hill has offices in Austin, Beaumont, Collin County, Dallas, Houston, and San Antonio. While Clark Hill is full service, it has a significant practice in tax and estate planning. To establish its presence in Texas, Clark Hill merged with the Strasburger firm in 2018, which seven years earlier had merged with Oppenheimer, Blend, Harrison and Tate, a San Antonio firm with a strong presence in tax and estate planning. Clark Hill is pleased to be a sponsor of the University of Texas Annual Tax program.
www.clarkhill.com
Holland & Knight LLP

Established in 1887, Thompson & Knight is a full-service law firm with more than 300 attorneys and nine offices worldwide. Our Firm has been at the forefront of groundbreaking litigation and transactions that have historically shaped the legal and business communities in Texas and the Southwest.

Our robust Tax Practice offers comprehensive tax planning and compliance advice to individuals and all types of business entities and organizations. Our attorneys provide creative and seasoned tax advice in corporate and business tax, international and cross-border tax, employee benefits and executive compensation, estate planning, family office tax, nonprofit tax, oil and gas tax, real estate tax, and tax controversies. We represent clients in tax audits, administrative appeals and proceedings, and in tax litigation in both federal and state courts.
www.hklaw.com
Martens, Todd, & Leonard

Martens, Todd & Leonard represents clients in tax disputes concerning the Texas sales and use tax, the Texas franchise (margin) tax, the Texas motor vehicle and Texas motor fuels taxes, Texas oil and gas production (severance) taxes, Texas oil well servicing taxes, and other Texas taxes. We assist clients with minimizing the impact of an audit and challenging any adverse assessment through the administrative hearing process, in state district court, and on appeal. Our innovative case strategies enable us to obtain favorable settlements and to confidently take our clients through the full legal process, when necessary.

We have successfully tried numerous Texas sales tax and franchise tax cases and handled the ensuing appeals: Combs v. Roark Amusement & Vending, L.P.; Hegar v. Gulf Copper and Manufacturing Corp.; Titan Transportation, L.P. v. Combs; Combs v. Newpark Resources, Inc.; Hegar v. CGG Veritas Services (U.S.), Inc.; Pointsmith Point-of-Purchase Management Services, L.P. v. Hegar; Garriott v. Combs; L.P.; Taylor & Hill, Inc. v. Combs.
texastaxlaw.com
McCarter & English, LLP

McCarter & English is a full-service firm with 375 attorneys across 11 offices and a thriving Tax & Employee Benefits practice. Businesses and individuals nationwide turn to us for precise guidance on complex and continually changing tax laws. We deliver solutions on everything from sophisticated forward and reverse like-kind exchange transactions to complex federal and state tax controversies. For more information on McCarter, please visit mccarter.com.
www.mccarter.com
McDonald & Adkins, LLP

Significant businesses throughout Texas rely on McDonald & Adkins, LLP, for experienced counsel and representation.

With over 44 years of experience, Kenton McDonald’s practice is focused on helping clients structure their businesses and transactions in a tax-advantaged manner; structure their estates to minimize estate taxes; and contest unfavorable actions proposed by the IRS.

With 30 years’ experience as a trial attorney, Alissa Adkins has a broad civil litigation practice involving contested matters in state and federal trial and appellate courts, including the U.S. Bankruptcy Court.

McDonald & Adkins, LLP, has been selected by U.S. News and World Report as a top tier law firm for Tax Law.
mcdonaldadkins.com
Porter Hedges LLP

Founded in 1981, Porter Hedges is a full-service Houston-based law firm with an office in Oklahoma City. We provide the highest quality work across a range of industries, with particular preeminence in the energy sector. As leading practitioners, we are committed to excellence across our firm and favor an efficient, value-minded approach to serving our clients. We develop practical and integrated solutions to complex challenges that we approach with a business-oriented mindset.

Porter Hedges tax lawyers help businesses, exempt organizations, and individuals plan and achieve their financial objectives while maximizing their tax advantages. We integrate tax planning, transactional assistance, and tax controversy resolution in advising clients on all aspects of federal, state, local, and international taxation. Our tax lawyers regularly assist company owners and executives, chief financial officers, tax directors, bankers, outside accountants, and other advisors in creating sophisticated solutions for complex tax challenges.
www.porterhedges.com

70th Annual

Taxation Conference: Day 1 - Controversy

Wednesday: Focus on Controversy

Austin Nov 30, 2022 DoubleTree by Hilton Hotel Austin Conference Concluded

Live Webcast Nov 30, 2022 Conference Concluded

Buy

Related products: eConference Materials

Overview

Event Schedule

Wednesday Morning, Nov. 30, 2022

Wednesday Afternoon, Nov. 30, 2022

Conference Faculty

Maxine Aaronson

Tom Cullinan

Michael J. Desmond

Lacy Leonard

Bruce A. McGovern

Mary A. McNulty

Lee Meyercord

Christina A. Mondrik

Steven D. Moore

Holly Porter

Lawrence Sannicandro

Planning Committee

Jimmy Martens—Chair

T. Charles Parr III—Vice-Chair

Maxine Aaronson

R. Gordon Appleman

Stanley L. Blend

Michael L. Cook

Joel N. Crouch

Barbara Spudis de Marigny

Dennis B. Drapkin

Lawrence B. Gibbs

Donald O. Jansen

Calvin H. Johnson

Kenton E. McDonald

Christina A. Mondrik

Patrick L. O'Daniel

Catherine C. Scheid

Credit Info

MCLE Credit

Other Credit

MCLE Credit

Other Credit

Key Dates

Venue

DoubleTree by Hilton Hotel Austin

Accommodations

Parking Information

Our Sponsors

Sign-Up for Our Hooked on CLE Monthly Newsletter

70^th Annual

Austin Nov 30, 2022 DoubleTree by Hilton Hotel Austin
Conference Concluded

Live Webcast Nov 30, 2022
Conference Concluded