Friday, January 22, 2010
8:30 a.m. – 11:45 a.m.
Tax Law Section
3.0 MCLE credit hours, 3.0 Estate Planning & Probate Specialty Credit Hours, 3.0 Taxation Specialty Credit Hours

Selected Issues Posed by Audits, State and Local Taxes, Debt Restructuring, Purchase of or Compensation with Partnership Interests, The New Estate and Gift Tax Law

I. The Eggshell Audit. Tony Rebollo, who concentrates on tax controversy matters, will discuss conducting an IRS audit in the context of a client with significant, multiple levels of exposure.

II. Is There a Better Way to Hold Title to Real Estate for Asset Protection Purposes? Shawn M. Flanagan will lead a discussion of the usefulness of Smith v. Cutler, 366 S.C. 546, 623 S.E.2d 644 (2005)"

III. Debt Restructuring. Bob August will discuss a topic which faces virtually every tax practitioner today--the tax effects of debt cancellation, workouts and foreclosures.

IV. Partnership Interests: Purchase, Compensation. With the use of limited liability companies and partnerships being ever-more prevalent, and cash being scarce, compensation of persons by means of various interests is being frequently utilized. Lynn Chandler will present a discussion of the myriad techniques used and their tax effects on the grantor and recipient.

V. The New Estate and Gift Tax Law. Changes in the tax law are inevitable, but perhaps in no area as much as the estate and gift tax. The approach of 2010 and 2011, years long fraught with planning pitfalls and uncertainty, virtually mandate new and sweeping legislation. Lad Boyle will speak about the new legislation and its opportunities and uncertainties.

Please join this exceptional group of speakers as they discuss these critical, timely tax topics.

Agenda

8:30 a.m. – 9:15 a.m. The “Eggshell” Audit
Anthony Rebollo, Columbia

9:15 a.m. – 9:45 a.m. Is There a Better Way to Hold Title to Real Estate for Asset Protection Purposes?
Shawn M. Flanagan, Charleston

9:45 a.m. – 10:00 a.m. Break

10:00 a.m. – 10:30 a.m. Selected Debt Restructuring Issues
Robert E. August, Greenville

10:30 a.m. – 11:00 a.m. Purchase of or Compensation with Partnership Interests
Lynn F. Chandler, Charlotte, NC

11:00 a.m. – 11:45 a.m. The New Estate and Gift Tax Law
Prof. F. Ladson Boyle, Columbia

Course Planner/Moderator: John H. Muench, Florence