Joseph R. Rekrut, Chair
Reinhart Boerner Van Deuren, S.C. · Milwaukee
Schedule
8:30 am
Federal Tax Update/Reform
Patricia A. Hintz, Courtney A. Hollander
9:20 am
What’s New in Pass-Through Taxation: Self-Employment Tax and Other Selected Topics
Joseph R. Rekrut, Colin J. Walsh
- Overview and summary of recent judicial interpretations of "limited partner" for purposes of SE Tax, including Sirius Solutions
- Economic substance issue, including Otay
- Discussion and practical takeaways from the continued implementation and evolution of the BBA Audit Regime, aka, Centralized Partnership Audit Regime
10:10 am
Break
10:25 am
Hot Tax Practice Procedure and Ethics Issues
Michael G. Goller
- Identify current federal and state tax practice and procedure developments
- Recognize significant procedural traps involving examinations, information document requests, administrative appeals, refund claims, limitations periods, and preservation of the administrative record
- Evaluate recurring ethical and professional-responsibility issues under Circular 230 and related standards, including diligence, competence, conflicts, written advice, reliance on experts, and communications with clients and taxing authorities
- Identify practical concerns involving valuation, qualified appraisals, penalty exposure, reasonable-cause defenses, and the selection and use of experts
- Apply practical risk-management techniques to avoid common practitioner errors and improve the handling of tax audits, appeals, and related controversies
11:15 am
Overview of Federal Tax Litigation
Christopher K. Dowse, Todd N. George
- Gain a general understanding of the examination process, working with exam, and working effectively with the IRS Independent Office of Appeals
- Explore how to communicate and negotiate with IRS Chief Counsel and other government representatives, including strategies for resolving disputes
- Gain an overview of the U.S. Tax Court procedural steps and practice
- Compare the differences between prosecuting a tax case in Tax Court, Court of Federal Claims, and District Court
12:00 pm
Lunch (courtesy of the Taxation Law Section)
1:10 pm
Wisconsin Department of Revenue Compliance Proceeding
Adam Y. Ben-Zikri, Nicole I. Pellerin
- Receive an overview of administrative collection options including levy, wage attachment, tax warrants, "secret" liens, execution, setoff, revocation (seller's permit & occupational license), office examination, supplemental examination, etc.
- Review administrative resolution options including petitions for compromise, installment agreement, interest rate reduction, closed year adjustment form, fair and equitable compromise, etc.
- Discuss special circumstances such as marital property, bankruptcy and receiverships, disregarded entities, and personal liability and successor liability
2:00 pm
State and Local Property Tax Update
Kristina E. Somers
2:50 pm