8:55 Welcome and Introductions
9:00 How a Civil Tax Case Becomes a Criminal Fraud Investigation
Robert Nordlander, Nordlander CPA PLLC, Greensboro
Gain insight and perspective on how seemingly routine civil audits can evolve into criminal investigations. The presenter discusses warning signs, pitfalls to avoid and best practices to prevent your civil audit from becoming a criminal scrutiny.
10:00 Break
10:10 Understanding the Conservation Easement Controversy
Hale E. Sheppard, Chamberlain Hrdlicka, Atlanta, GA
Learn the ins and outs of conservation easements and review the most recent case law. Then dive into a discussion on how this planning technique became one of the most controversial and highly scrutinized topics with state and federal tax authorities.
11:10 Break
11:20 Nationwide Developments in State and Local Tax
Jeffrey A. Friedman, Eversheds Sutherland LLP, Washington, DC
Richard D. Pomp, University of Connecticut School of Law, Hartford, CT
Panelists discuss general state and local tax, including key cases and other important updates.
12:20 Lunch Break
12:50 Hot Topics in Partnership Tax
Allie Petrova, Pretrova Law PLLC, Greensboro
The session addresses recent developments in partnership tax enforcement. Hear strategic considerations of the centralized partnership audit regime concerning the partnership representative, partnership return revisions and applicable audit procedures.
1:50 Break
2:00 North Carolina Tax Update
William W. Nelson, Smith Anderson, Raleigh
This presentation provides an update on North Carolina income taxes, including taxation under the CARES Act and other recent developments.
3:00 Break
3:10 Federal Tax Update
Cassady V. "Cass" Brewer, Georgia State University College of Law, Atlanta, GA
Receive an update on federal tax laws, then review the provisions enacted in the Coronavirus Aid Relief and Economic Security Act (CARES Act) and their impact on federal taxes.
4:10 Adjourn
Thank you for joining us for 2021 Tax Section Program.
This year's Tax Section program brings you up to speed on the latest developments in tax law, including general state and local tax, partnership tax enforcement, and state and federal taxation under the Coronavirus Aid Relief and Economic Security Act (CARES Act).
Cassady V. "Cass" Brewer is an associate professor of law at Georgia State University College of Law in Atlanta, GA who teaches Basic Federal Income Taxation, Nonprofit Organizations, Taxation of Business Organizations, Partnership Taxation, and the Law of Social Enterprise. His research primarily focuses upon the legal and tax aspects of the intersection of tax-exempt, nonprofit organizations with for-profit enterprises and commercial activity. He speaks regularly on federal income tax topics as well as the legal and tax aspects of emerging "hybrid" business forms such as the benefit corporation and the low-profit limited liability company.
Cass received his LL.M. (Taxation) from New York University, where he served as graduate editor of the Tax Law Review. He is a graduate of the University of Arkansas School of Law, where he was editor-in-chief of the Arkansas Law Review. He received his undergraduate degree from Vanderbilt University.
He co-founded the Nonprofit Law Section of the State Bar of Georgia, and he is a past co-chair of the Section. Brewer also has participated in drafting and amending the Georgia Limited Liability Company and Limited Liability Partnership Acts and continues to serve as a member of the Partnerships and LLCs Subcommittee of the Business Law Section of the State Bar of Georgia. Brewer currently serves as the Reporter for the Legislative Proposals Committee of the Nonprofit Law Section of the State Bar of Georgia.
Cass is a Fellow of the American College of Tax Counsel and previously was a partner and practice leader in the Tax Group of Morris, Manning & Martin, LLP, in Atlanta, Georgia.
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Jeffrey A. Friedman is with Eversheds Sutherland LLP in Washington, DC. Honored as "Tax Lawyer of the Year" in 2011 by State Tax Notes, Jeff provides sophisticated state and local tax planning, strategic advice and advocacy to numerous Fortune 100 and industry-leading companies. His comprehensive practice includes state and local tax planning, compliance, legislation and policy, and litigation and controversy matters involving income, franchise, sales and use and property taxes. Jeff's clients span a variety of industries, including e-commerce, energy, technology and telecommunications.
Prior to joining Eversheds Sutherland (US), Jeff was a partner in KPMG's Washington national tax practice; served as an attorney-adviser in the U.S. Department of the Treasury's Office of Tax Policy, where he assisted with the development of the U.S. government's position on domestic and international electronic commerce tax issues; and served as vice president and counsel of the Committee (now Council) On State Taxation (COST).
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Christopher E. "Chris" Hannum is a partner with Culp Elliott & Carpenter PLLC in Charlotte. He practices in the areas of corporate law, trusts and estates and tax and business law. He frequently advises on complex tax and business matters, including corporate and real estate transactions and financing, estate and income tax planning, asset protection, securities matters, tax controversies, and mergers and acquisitions.
Chris has a proven track record of handling sophisticated transactions and developing effective solutions to minimize taxes and legal risks, preserve wealth and achieve other client objectives.
Chris has led or participated in many of the corporate transactions the Firm has recently handled as part of the CEC Business Planning and Transactions Practice. He is a member of the Business Law, Elder & Special Needs Law and Tax Sections of the North Carolina Bar Association.
Chris earned his B.A. in Political Science from Allegheny College, his J.D., with honors, from The University of Florida and his LL.M., with honors, in Taxation from The University of Florida.
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Reed J. Hollander is with Nelson Mullins Riley & Scarborough LLP, Raleigh. Reed's practice areas are appellate practice and legal strategies, commercial litigation and business torts, false advertising and unfair trade practices, state and local tax, tax controversy and tax planning and consulting. Reed handles a wide range of litigation, including contract disputes, business torts, unfair competition, administrative law, eminent domain and condemnation, technology, trade secret law, intellectual property, and constitutional and First Amendment issues. He focuses in the area of state and local taxation, including property tax, sales and use tax, corporate and individual income tax, and excise taxes, and has spoken and published articles on state and local tax controversy issues regionally and nationally.
Reed is a member of the Appellate Practice, Litigation and Tax Sections of the North Carolina Bar Association and a member of the Litigation and Tax Sections of the American Bar Association. He is also a member of the Wake County/10th Judicial District Bar, Institute for Professionals in Taxation and the Council on State Taxation and Author of North Carolina Tax Updates.
Reed received his B.A. degree in English with honors and distinction from the University of Illinois at Urbana-Champaign in 1993 and his J.D. degree with honors from Duke University School of law in 1996.
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William W. "Bill" Nelson is a partner in the law firm of Smith Anderson Blount Dorsett Mitchell & Jernigan LLP in Raleigh. Mr. Nelson's principal practice areas are federal and state tax planning for businesses. He also assists taxpayers with federal and state tax controversies and has been active in numerous state tax legislative reform efforts.
Bill received his undergraduate (1982, Phi Beta Kappa) and law (1985, with high honors) degrees from the University of North Carolina at Chapel Hill. He was for twenty years the author of CCH's Guidebook to North Carolina Taxes. He is a past Chair of the Tax Section of the North Carolina Bar Association, an occasional lecturer at Duke University School of Law, a former adjunct Professor of Law at the University of North Carolina School of Law, a member of the UNC Tax Institute Board of Advisors, the Chair of the North Carolina Chamber Tax Committee, and a Fellow of the American College of Tax Counsel.
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Robert Nordlander is the principal member of Nordlander CPA, PLLC, a boutique forensic accounting and tax resolution firm in Greensboro. For over 20 years as a special agent with IRS-Criminal Investigation, he evaluated, investigated, and prosecuted federal criminal tax and money laundering violations. As a Certified Field Instructor for IRS-CI, he has trained prosecutors and law enforcement around the world in forensic accounting. He also trained various IRS civil divisions on the best practices to elevate a civil audit into a criminal investigation.
Robert is also the host of the Fraud Fighter Podcast, a podcast dedicated to fraud and forensic accounting.
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Galina "Allie" Petrova is the founder and owner of Petrova Law PLLC in Greensboro, a boutique law firm focused exclusively on tax and transactional business matters. Allie concentrates her practice in complex business tax planning for closely held businesses, M&A transactions, and taxpayer representation before the Internal Revenue Service and the North Carolina Department of Revenue.
Allie is the current chair of the Closely Held Businesses Committee of the American Bar Association's Section of Taxation and serves as the treasurer of the North Carolina Bar Association's Tax Section. Allie presents at American Bar Association Tax Section meetings regularly and has spoken at the J. Nelson Young Tax Institute.
In 2020, Allie was awarded the Nolan Fellowship by the American Bar Association's Section of Taxation. She was recognized as Legal Elite by North Carolina Business Magazine and by Super Lawyers as a Rising Star from 2018 through 2021 and by Best Lawyers in 2021.
Allie Petrova is admitted to practice in North Carolina and New York and is a member of the United States Tax Court Bar and the United States Supreme Court Bar. Allie earned her J.D. and LL.M. in Taxation degrees from the Georgetown University Law Center, where she served as Symposium Editor of the Journal of Legal Ethics. She also holds a bilingual LL.M. degree in International Economic Law from The Sorbonne in Paris and has presented on tax law matters internationally. Allie received her B.S. degree in Business Administration and Economics with a Finance concentration and an Accounting minor, magna cum laude, from Greensboro College.
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Richard D. Pomp is the Alva P. Loiselle Professor of Law at University of Connecticut School of Law in Hartford, CT. He is a summa cum laude graduate of the University of Michigan and a magna cum laude graduate of Harvard Law School. He has taught at Harvard, New York University, Columbia, University of Texas, and Boston College. In addition, he has been a Distinguished Professor in Residence, Chulalongkorn Law School, Bangkok, Thailand, and a Visiting Scholar at the University of Tokyo Law School and at Harvard Law School.
Richard has been qualified as an expert witness in more than 30 states and the federal district courts and has appeared in more than 120 cases. He serves as counsel and a litigation consultant to law firms, corporations, accounting firms, and state tax administrations. He has participated in various capacities in U.S. Supreme Court litigation.
Richard has also served as a consultant to cities, states, the Multistate Tax Commission, the Navajo Nation, the U.S. Congress, the U.S. Treasury, the Department of Justice, the IRS, the United Nations, the IMF, the World Bank, and numerous foreign countries, including the People's Republic of China, the Republic of China, Indonesia, the Gambia, Zambia, Mexico, the Philippines, Pakistan, India, and Vietnam. He is the former Director of the New York Tax Study Commission. Under his tenure, New York restructured its personal and corporate income taxes, and created an independent tax court.
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Hale E. Sheppard is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka White Williams & Aughtry in Atlanta, GA. He defends individuals and businesses during tax audits, tax appeals and tax litigation.
Hale has participated in over 150 tax cases before the Tax Court, Court of Appeals, District Court, and State Tax Tribunals. In addition to resolving issues through tax litigation, Hale has obtained dozens of favorable Private Letter Rulings for clients from the IRS National Office on procedural, tax, and international issues.
During his studies, Hale received several awards for academic excellence, including the prestigious Harry S. Truman Foundation Scholarship, Janice Dawson Quinn Tax Scholarship, Tinker Foundation Scholarship, and Senator James B. Pearson International Fellowship. He also served as a graduate editor of the Florida Tax Review and member of the Kansas Journal of Law & Public Policy. Chambers USA, Legal 500, Super Lawyers, and Best Lawyers in America have recognized him as a leader in tax litigation, with the latter naming him tax attorney of the year for 2023. He has also been inducted into the American College of Tax Counsel.
Hale holds five college degrees. At the University of Kansas, he earned a B.S., with distinction, M.A., with honors, and J.D. He later received an LL.M. in international law, with highest distinction, from the Universidad de Chile in South America. Finally, he obtained an LL.M. in tax from the University of Florida, where he was a graduate tax scholar.
Hale ranks among the most active tax writers in the country. He has published nearly 170 major articles in top tax journals and university law reviews, both domestically and abroad.
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