Conference Agenda

Wednesday, March 31, 2027

8:30 – 9:15 am | Breakfast

9:20 am | Opening Remarks

9:30 – 11:30 am | Recent Developments in Federal Income Taxation
Speaker:

Prof. Bruce A. McGovern, South Texas College of Law Houston

This session highlights important changes affecting taxpayers over the past twelve months, addressing significant court decisions, rulings, and statutory and regulatory developments.

11:30 am – 1:00 pm | Lunch and Mingle with Sponsors

1:05 – 1:55 pm | A Washington Update
Speaker:

Beth Shapiro Kaufman, Lowenstein Sandler

2:00 – 2:50 pm | Beyond the Fee: What Lender Management Means for Family Office Design
Speaker:

Christopher A. Steele, Bernstein

2:50 – 3:30 pm | Mingle with Sponsors

3:30 – 5:00 pm | Loan Rangers: Navigating Promissory Notes, Trust Debt, and Tax Risk in Planning
Speakers:

Carsten Hoffman, Stout

          Stephanie Loomis-Price, Perkins Coie LLP

          Benetta Y. Park, Bessemer Trust

Promissory notes can be powerful tools in sophisticated trust and estate planning—but they also can create tax risk. This program will saddle up and explore the income, transfer, and estate tax consequences of notes between (or among) grantors, trusts, and beneficiaries, including swaps, installment sales, unsecured loans, beneficiary loans, refinancing, and forgiveness.

Using key authorities such as the Elcan, Bolles, and Galli cases and more, the program will survey the planning frontier, highlighting opportunities, common traps, and practical questions along the trail. Topics will include whether the Applicable Federal Rate really is a safe harbor, when debt obligations may be deductible for estate tax purposes, suggestions on how to value promissory notes, and fiduciary considerations that arise when notes are held in trusts.

This program will help practitioners sharpen their planning skills, avoid costly missteps, and wrangle better use of promissory notes in planning. Giddy up!

5:00 – 6:00 pm | Welcome Reception:  Visit with fellow attendees and sponsors

Thursday, April 1, 2027

8:15 – 9:00 am | Samuel C. Ullman Memorial Breakfast sponsored by Tax Section of The Florida Bar and Mingle with Sponsors

9:05 am | Opening Remarks

9:10 – 10:40 am | Partnership Playbook – Strategies in Transactions
Speakers:

Ryan Dobens, KBF Advisory

          Adam J. Smith, BizTx Law

This session will overview common partnership transactions that every tax practitioner needs to have in their playbook. Attendees will leave understanding the difference between Rev. Rul. 99-5, Rev. Rul. 99-6, Rev. Rul. 84-111, and other common partnership transactions involving sales, distributions, and contributions. This session will attempt to cover pitfalls and opportunities in these common transactions. Attendees will be exposed to the flexibility of partnership taxation (and at times its ambiguity) but will also be confronted with certain limits to this flexibility.

10:50 – 11:40 am | TBD
Speaker:

TBD

11:45 am – 1:00 pm | Student Networking Luncheon sponsored by A. Brian Phillips, P.A. and Mingle with Sponsors

1:00 – 1:50 pm | No Controlling Interest Required: Negotiating Tax Protections for Minority Owners
Speaker:

Adi Rappoport, Gunster

Minority owners may lack control, but this need not result in unfavorable tax outcomes. This presentation examines practical tax protections that minority owners can reasonably seek in business transactions, even when negotiating leverage is limited. Topics will include tax distribution provisions; rights in connection with Section 754 elections; participation and information rights in tax audits, including proceedings under the BBA partnership audit regime; and allocation provisions addressing book-tax disparities. The presentation will address how careful drafting, targeted consent rights, and well-chosen procedural protections can help minority owners manage tax exposure, preserve economic expectations, and secure a meaningful voice in tax decisions.

1:55 – 2:45 pm | AI and Ethics in Estate and Tax Planning
Speakers:

Edward F. Smith III, Beller Smith

          Yoshimi O. Smith III, Beller Smith

2:45 – 3:25 pm | Mingle with Sponsors

3:30 – 5:00 pm | Biggest Tax Questions Answered Panel
Speakers:

Cristin Keane, Trenam Law

          Paul S. Lee, Consiglio Advisors LLC

5:00 – 6:30 pm | March Madness Mingle Reception:  Visit with fellow attendees and sponsors

Friday, April 2, 2027

8:15 – 9:00 am | Breakfast and Mingle with Sponsors

9:05 am | Opening Remarks

9:10 – 10:00 am | The New Normal for Charitable Tax Planning 
Speaker:

Justin Miller, Evercore

10:05 – 10:55 am | Trust Me, It’s Taxable: DNI Another Day – A Tour of Subchapter J
Speaker:

Mark R. Parthemer, Glenmede

10:55 – 11:15 am | Mingle with Sponsors

11:15 am – 12:05 pm | Federal Wealth Transfer Tax Update
Speaker:

Samuel A. Donaldson, Georgia State University College of Law

This informative and entertaining session will recap the important cases, rulings, and regulations from 2026, together with a preview of what we might expect from Congress in 2027 or 2028.

12:10 – 1:00 pm | Lunch and Mingle with Sponsors

1:00 – 1:50 pm | Cross Border Trust Planning 
Speaker:

Christopher R. Callahan, Fox Rothschild LLP

This presentation will focus on practical approaches to utilizing U.S. tax planning strategies to minimize the U.S. tax burden of certain foreign and U.S. trusts depending on the trust asset mix and settlor/grantor/beneficiary mix.  The presenter’s goal will be for each attendee to learn about the basic frameworks for analyzing these matters so they can better advise their clients as well as learn very specific, practical strategies that are currently implemented for clients from various countries.

1:55 – 2:45 pm | Ethical Considerations in Estate Planning and Estate/Trust Administration – And It Is Not Just for Attorneys
Speaker:

A. Stephen McDaniel, Harkavy McDaniel Kaplan and Salomon PLLC

The baby boomers turn 80 this year. It is estimated that the transfer of at least 36 trillion dollars in assets to younger generations and charities will unfold over the coming decades. Perhaps the biggest challenge facing estate planners is dealing with aging clients, to assure that the plan is properly structured and administered and to avoid undue influence and needless estate litigation. This presentation will deal with the ethical issues we face.

2:45 pm | Closing Remarks