Learning Objective

The Institute provides high-level information and practical advice for advanced tax practitioners with a strong federal tax background. Leading national experts from the U.S. Treasury, the Internal Revenue Service, and the private practice present unique perspectives on the latest trends and developments related to regulations, rulings, and cases impacting tax practice areas with emphasis on the areas of corporate, partnership, real estate, international, and controversy. After completing the course, you will understand:

• How the IRS Independent Office of Appeals has worked to remain independent from exams, the impact of COVID, expectations for post-COVID Appeals conferences, and issues unique to LB&I cases, such as the pilot program, RAP, and the use of specialists.
• Recent developments relating to Treasury Department Circular 230, including trends from recent disciplinary actions, prospects for regulatory and legislative change, and how remote work conditions occasioned by COVID affect the obligations of tax professionals and their firms.
• How to file and pursue tax refund claims, including issues that can arise regarding the statute of limitations, the variance doctrine, and the recent uptick in refunds based on carryback claims (using Form 1139 or 1045).
• How LB&I is addressing the wholesale revamp of U.S. international tax rules under the Tax Cuts and Jobs Act.
• How the Biden-Harris administration proposes to change the U.S. international tax system.
• U.S. tax planning and structuring ideas and opportunities for non-U.S. real estate investments.
• What it takes to succeed in developing and managing a successful tax practice, including the practitioner’s ethical obligations.
• Recent developments relating to Subchapter C, M&A, and other corporate tax developments and the practical and professional affect of those developments.
• Tax issues affecting distressed companies and the current tax consequences impacting workouts and bankruptcies.
• Current tax issues affecting SPAC M&A transactions.
• The latest developments relating to work with representation and warranty insurance in M&A transactions.
• Recent IRS guidance and Treasury regulations impacting partnership taxation, including regulations under sections 163(j), 168(k), and 1061 and hot transactional trends, such as SPAC UP-Cs.
• Recent partnership tax developments relating to debt workouts, cancellation of indebtedness (COD) and special allocations arising from COD income, foreclosures, partnership equity‑for‑debt exchanges, and debt modifications.
• Recent partnership tax developments relating to leasing transactions, including timing of rental income and deductions, bad debt deductions, and COD income issues raised by lease modifications, including rent abatement and deferral, and lease terminations.

Who is the Audience for the TexFed Institute?

The Institute is designed for tax practitioners and executives (lawyers, accountants, and tax directors) who have an advanced understanding of Federal income tax principles and who seek to enhance their knowledge and understanding of strategies related to corporate, partnership, and real estate tax transactions, as well as international tax and tax controversy.