NOTE: There is limited seating available so hurry & register early!

BONUS: MEET WITH THE IRS TAXPAYER ADVOCATE LIVE AT THE SEMINAR! Book a private appointment!! (Now that the government shutdown is over we expect the advocate will attend as promised).

This seminar will focus on many hot-button tax issues. Topics include: Current State of IRS, Real Estate & Opportunity Zones - OBBBA Emphasis, M&A - focus on Section 1202, Trusts and Estates in light of OBBBA.

Topics & Learning Objectives Include:

Morning Sessions:

• Session 1: M&A – Discussion on 1202 and how it was impacted by OBBBA, There will also be a discussion on family office issues coming from the OBBBA, Due Diligence in buying and selling and tax consequence
• Session 2: Real Estate – Updates on the Qualified Opportunity Zone of OBBBA

Afternoon Sessions: 

• Session 1: Trusts and Estates – How the new tax law impacts tax of trusts and estates
• Session 2: Tax Controversy:
  • Current State of the IRS: Briefly discuss funding, gov't shutdown, personnel reductions, brain drain departure
  • AI – How is AI impacting IRS
  • Emerging trends in tax enforcement and compliance for 2025: How audits are conducted, ERTC Audits, Audit Campaigns, Tales from the trenches, Family Office, Global high net worth, Monetized installment sales, Role of penalties
  • Key case rulings and their implications for taxpayers, OBBBA regulations and how IRS is going to deal with this, How the Loper Bright decision has been applied in tax cases, International penalties, Economic substance doctrine, Comm’r v. Zuck
  • Strategies for effectively managing tax audits and disputes: Evolving theories of representation in a resourced tap environment (Entire strategy needs to change due to audit cuts / More appeal cases and Tax Court Cases), Type of audit dictates considerations and procedure - JM Assets v. comm’r (BBA Audit), Equitable Tolling on NODs, Statute of Limitations cases, Digital tools being used – document upload tool etc. (Login.gov), Elimination of DOJ Tax, AUSAs moving on, Office of Counsel brain drain departure
  • Backlog at TAS
  • Practical tips for navigating international tax controversies: Quiet disclosures, Voluntary Disclosures

Note: Order of sessions may be reversed.