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Day 2 | 23rd Annual North Carolina Tax Section Workshop

FRIDAY, MAY 24, 2024

8:25        Welcome and Introductions

8:30        Recent Federal Income Tax Developments

Cassady V. "Cass" Brewer, Georgia State University College of Law, Atlanta, GA

This session highlights significant changes affecting taxpayers and advisors over the past 12 months, addressing selected court decisions, rulings, and statutory and regulatory developments.

9:30        Break

9:45        The Income Tax and Estate Tax Benefits for Encumbered Real Estate With Negative Capital Accounts Using the Preferred Partnership

Jerome M. Hesch, Meltzer Lippe Goldstein & Breitstone LLP, Boca Raton, FL

The preferred partnership is used to obtain both an income tax-free step-up in basis at death for the preferred partnership interest included in the decedent's gross estate and an estate freeze by disposing of the common partnership interest that is allocated the appreciation in the value of the partnership's assets. The step-up in basis at death is especially attractive for encumbered real estate with negative capital accounts since it can eliminate the potential for having to report the phantom capital gains without a transfer tax cost. This session first describes how to structure the partnership so that the decedent owns the preferred partnership interest at death and how to transfer the common interest that is allocated the appreciation in value to a grantor trust.

10:45      Break

11:00      Code Section 409A and You: Common Pitfalls and Traps for the Unwary

Taylor Bracewell, Ogletree Deakins, Atlanta, GA

This session begins with a primer on Code Section 409A and its applicable exceptions, as well as the consequences for violating Section 409A, before focusing on common pitfalls that can result in the inadvertent application (and violation) of Section 409A.

12:00      Adjourn for the Day

SATURDAY, MAY 25, 2024

8:25        Introductions

8:30        North Carolina State Tax Case Law Update

Ronald D. Williams, NC Department of Justice - Revenue Division, Raleigh

Hear a discussion of recent decisions from the North Carolina Office of Administrative Hearings, the North Carolina Business Court and the North Carolina Supreme Court relating to North Carolina tax law. This update includes opinions involving disputes in sales and use tax, corporate tax, franchise tax, and individual income tax.

9:30        Break

9:45        Current Trends in IRS Enforcement

Clint Massengill, Cooley LLP, New York, NY

In August 2022, the Inflation Reduction Act (IRA) committed significant resources to IRS enforcement. We review the IRS's stated enforcement goals following the IRA and the IRS's progress in meeting those goals. In addition, we highlight less-obvious trends reflected in recent administrative actions and judicial proceedings.

10:45      Break

11:00      A Most Taxing Profession: Navigating Stress in Your Practice and in Your Life

Judge Lucy Inman, Milberg Coleman Bryson Phillips Grossman, PLLC, Raleigh
Edward Thomas Lewis, III, Medical University of South Carolina, Charleston, SC

This session examines the stressful challenges lawyers face in our profession and personal lives and explores strategies for not just surviving but thriving. Judge Inman uses an anonymous polling system to engage the audience in discussion about how lawyers can respond to stressful circumstances, even if they can't control them, and how to identify small problems before they become big problems.

12:00      Adjourn for the Day

Tax Section Annual Meeting

Robert J. "Bob" Gallagher, Carolina Tax, Trusts & Estates, Southern Pines, 2023-2024 Section Chair, presiding

A link will be provided to those wishing to participate virtually.

SUNDAY, MAY 26, 2024

8:25        Introductions

8:30        Multistate SALT Update

William W. "Bill" Nelson, Smith Anderson Blount Dorsett Mitchell & Jernigan LLP, Raleigh

This session focuses on significant recent state and local tax decisions from the United States Supreme Court and state courts around the country other than North Carolina.

9:30        Break

9:45        Tackling the To-Do List: Task and Project Management

Catherine Sanders Reach, North Carolina Bar Association, Cary

Are you looking for a way to effectively stay on top of tasks for you or your team? Do you need to delegate, supervise, and stay current on projects whether you are in the office or working remotely? Do forgotten or overdue tasks wake you up at night? Keeping a task list with assignments and deadlines can help you and your team stay synced, reduce risk, and help your practice with everything from productivity to business continuity. We walk through some concepts and technology options (including some you may already have!) and see what might work well for you or your firm.

10:45      Break

11:00      Name, Image and Likeness (NIL) in College Sports: Current Developments and Tax Implications

Micha Malouf, Schell Bray PLLC, Chapel Hill

During this session, we discuss the tax-exempt status of NIL collectives after recent IRS guidance which concludes that an organization that develops paid NIL opportunities for student athletes will not, in many cases, qualify for exempt status. We explore taxpayer reliance on prior favorable IRS determination letters, strategies for advising tax-exempt clients in this ever-evolving space, and considerations for NIL transactions and entities (both nonprofit and for-profit) engaging in these transactions. Attendees also hear about federal, state and university requirements to keep in mind and tax consequences for student athletes.

12:00      Adjourn

† Indicates portion providing Professional Well-Being credit
‡ Indicates portion providing Technology Training credit


Are you ready to dive into the latest tax law updates and strategies to enhance your practice? Join us for an in-depth analysis and discussion of federal, state, and local tax laws, policies, procedures and practices.

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May 25, 2024
Sat 8:25 AM EDT

Duration 3H 35M

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