85th Institute on Federal Taxation 2026 (presented by NYU School of Professional Studies)

Charles P. Rettig, Esq., Shareholder | Chamberlain Hrdlicka

Charles “Chuck” Rettig is a Shareholder at Chamberlain Hrdlicka in the firm’s Tax Controversy & Litigation and other Tax and Trust & Estate practices, and served as the 49th Commissioner of the Internal Revenue Service from 2018 through 2022.

• Education & Credentials

He earned his B.A. from the University of California at Los Angeles, his J.D. with honors from Pepperdine University’s Rick J. Caruso School of Law, and his LL.M. in Taxation from New York University School of Law.

• Recognition & Leadership

In recognition of his leadership of the IRS, he received the Treasury Department’s Alexander Hamilton Award, the highest honor conferred by the Secretary. Before joining the IRS, he was listed by Chambers USA as an Eminent Practitioner, was repeatedly selected as a Best Lawyers “Lawyer of the Year” in Litigation and Controversy – Tax (Los Angeles), and received the California CPA Education Foundation’s Conference Speaker of the Year Award.

• Professional Involvement

He is a past president of the American College of Tax Counsel, a former Vice Chair (Administration) of the ABA Section of Taxation, a past Chair of the Taxation Section of the State Bar of California, and served three years on the IRS Advisory Council, chairing IRSAC in 2010–2011. He also served on the advisory boards of the California Franchise Tax Board and the California Board of Equalization, and founded the UCLA Extension VETS COUNT Scholarship Fund.

• Experience

As Commissioner, he presided over the nation’s tax system — collecting approximately $3.4 trillion in annual revenue with a workforce of roughly 80,000 — and guided the IRS through its pandemic-era modernization. Before heading the IRS, he spent 36 years as a principal with Hochman, Salkin, Rettig, Toscher & Perez in Beverly Hills, representing thousands of individuals and companies in civil and criminal tax matters before the IRS, the Department of Justice Tax Division, and federal and state courts.

David M. Rievman, Esq., Partner | Skadden, Arps, Slate, Meagher & Flom

David M. Rievman is a Tax Partner at Skadden, Arps, Slate, Meagher & Flom LLP in New York and Global Head of the firm’s Regulatory Practices.

• Education & Credentials

He earned his J.D., magna cum laude and Order of the Coif, from Boston College Law School (1987) and his B.A., magna cum laude, from Case Western Reserve University (1984). He is admitted in New York and Connecticut.

• Recognition & Leadership

He has been repeatedly selected for inclusion in Chambers Global and Chambers USA (Band 1), The Best Lawyers in America, The Legal 500, Expert Guides’ World’s Leading Tax Advisers, and Lawdragon 500, and his work was recognized with the Americas M&A Deal of the Year at the 2016 International Tax Review Americas Awards.

• Professional Involvement

He serves on the Executive Committee of the New York State Bar Association Tax Section, chairs the NYU Institute on Federal Taxation’s Corporate Tax program, serves on the USC Tax Institute Executive Committee, and lectures widely, including at the University of Chicago Law School’s Federal Tax Conference and the Practising Law Institute; he has been a guest lecturer at the University of Michigan Law School.

• Experience

He advises U.S. and international clients on the tax aspects of complex transactions — mergers and acquisitions, financings, divestitures and spin-offs, financial restructurings and recapitalizations, and joint ventures — representing public corporations, privately held businesses, investment banks, and private equity and other sponsor entities.

Jennifer Acuña, Esq., Principal, Federal Tax Legislative and Regulatory Services | KPMG

Jennifer Acuña is Co-Principal in Charge of the Federal Legislative and Regulatory Services group in KPMG’s Washington National Tax practice, specializing in tax legislation, tax policy, and regulatory authority.

• Education & Credentials

She earned her J.D. from the UCLA School of Law and her LL.M. in Taxation from New York University School of Law.

• Recognition & Leadership

She played a critical role in developing the federal tax reform proposals that became the Tax Cuts and Jobs Act of 2017, serving at every stage of reform in both the House and the Senate.

• Professional Involvement

She is a frequent speaker at tax and industry conferences on taxation and tax policy, and chairs the Current Developments program of the NYU Institute on Federal Taxation.

• Experience

Before joining KPMG, she served as Chief Tax Counsel for the U.S. Senate Committee on Finance, as Senior Tax Counsel and Policy Advisor to that committee, and as Tax Counsel — and earlier Oversight Counsel — for the House Committee on Ways and Means; she began her government service as a Competent Authority Analyst at the Internal Revenue Service.

Mary B. Hevener, Esq., Partner | The Wagner Law Group

Mary B. “Handy” Hevener is a Partner in The Wagner Law Group’s New York office, which she joined in 2025 after many years as a partner at Morgan, Lewis & Bockius.

• Education & Credentials

She earned her B.A. from Wellesley College (1974) and her J.D. from the University of Virginia School of Law (1978).

• Recognition & Leadership

She has been ranked by Chambers USA for Employee Benefits & Executive Compensation (New York) and recognized as part of Law360’s Benefits Practice Group of the Year.

• Professional Involvement

A frequent speaker on payroll tax and fringe benefit issues, she chairs the Executive Compensation & Employee Benefits program of the NYU Institute on Federal Taxation.

• Experience

She helps US and multinational enterprises minimize federal and state payroll taxes and maximize benefits-related tax deductions, focusing on the tax and information-reporting treatment of employee and independent-contractor benefits outside qualified retirement plans — from stock-based compensation and golden parachutes to fringe benefits ranging from insurance to employee loans, cars, planes, and prizes. She has served as a lead attorney in tax litigations of first impression involving employee meals, corporate aircraft deductions, stock option taxation, and FICA, and earlier served as an attorney-adviser in the Treasury Department’s Office of the Tax Legislative Counsel.

William B. Sherman, Esq., Partner | Holland & Knight

William B. Sherman is a Partner in Holland & Knight’s Miami and Fort Lauderdale offices and chair of the firm’s Tax Team.

• Education & Credentials

He earned his B.A. from Brooklyn College of the City University of New York (1975), his J.D. from Brooklyn Law School (1979), and his LL.M. in Taxation from New York University School of Law (1980). He is admitted in New York and Florida.

• Recognition & Leadership

He is a Fellow of the American College of Tax Counsel and has been recognized by Chambers USA (ranked for 18 years), The Legal 500 USA, Lawdragon 500 Leading Global Tax Lawyers, and Who’s Who Legal: Corporate Tax.

• Professional Involvement

He chairs the NYU Institute on Federal Taxation’s International Tax program and NYU’s Summer Institute in Taxation Introductory and Advanced International Tax Seminars, teaches International Taxation: Outbound as an adjunct professor in the University of Miami’s Graduate LL.M. Program in Taxation, and is a past chair of the ABA Tax Section’s Committee on U.S. Activities of Foreigners and Tax Treaties.

• Experience

He concentrates in domestic and international taxation, providing sophisticated tax planning for mergers and acquisitions, restructurings, joint ventures, and investments for clients across industries — hospitality, petrochemicals, real estate, transportation, telecommunications, investment management, and pharmaceuticals among them — with broad experience in U.S. investment overseas and foreign investment in the United States.

Andrea M. Whiteway, Esq., Principal | EY, Washington

Andrea Macintosh Whiteway is a Principal in the Partnership Transactions and Real Estate Group of Ernst & Young LLP’s National Tax Department, based in Washington, DC.

• Education & Credentials

She earned her B.A. from Cornell University, her J.D. with honors from the University of Maryland School of Law, and her LL.M. in Taxation, with distinction, from Georgetown University Law Center.

• Recognition & Leadership

She was the first woman to serve as Chair of the Real Estate Committee of the ABA Section of Taxation and is an elected Fellow of the American College of Tax Counsel.

• Professional Involvement

She serves on the Advisory Board of the NYU Institute on Federal Taxation and chairs its Partnerships, LLCs, and Real Estate sessions; co-chairs the NYU Federal Real Estate and Partnerships Tax Conference and the PLI Real Estate Tax Forum; chairs the Federal Taxation of Real Estate Committee of the ABA Section of Real Property, Trusts and Estates; and serves on the Real Estate Roundtable’s Tax Policy Advisory Committee and in the National Association of Real Estate Investment Trusts.

• Experience

With more than 30 years of experience in sophisticated partnership tax planning — dispositions and acquisitions of real estate and operating businesses, complex partnership, SPAC, and UP-C transactions, REIT tax status, and REIT-structured dispositions — she previously practiced at McDermott Will & Emery, Arnold & Porter, Steptoe & Johnson, Miles & Stockbridge, and Arthur Andersen.

Jerald David August, Esq., Partner | August Tax Law

Jerald David August is the founder and President of August Tax Law, P.C. in Blue Bell (Philadelphia), Pennsylvania, and a nationally recognized tax lawyer advising on U.S. and international income taxation, tax controversy and litigation, and wealth planning.

• Education & Credentials

He earned his B.S. in Finance and B.A. in Political Science from the Wharton School of the University of Pennsylvania (1974), his J.D. from the University of Pittsburgh School of Law (1977), and his LL.M. in Taxation from New York University School of Law (1980). He is admitted in Pennsylvania, New York, and Florida.

• Recognition & Leadership

He is a Fellow and former Regent of the American College of Tax Counsel, a Fellow of the American College of Trust and Estate Counsel, a Life Sustaining Member of the American Law Institute, and was named Best Lawyers “Lawyer of the Year” (2026) for Litigation & Controversy – Tax in Philadelphia.

• Professional Involvement

A former Vice Chair of the ABA Section of Taxation and former Editor-in-Chief of The Tax Lawyer, he serves as Editor-in-Chief of Corporate Taxation (WG&L), chairs the Editorial Board of ALI’s The Practical Tax Lawyer, serves on the NYU Institute on Federal Taxation’s Board of Advisors and chairs its Closely-Held Businesses program, and has taught corporate income taxation in the Graduate Tax Program of the University of Florida’s Levin College of Law. He is co-author of the two-volume treatise Tax Planning for S Corporations.

• Experience

He has served as chair or co-chair of the tax departments of two Am Law 200 firms — including Co-Chair of Fox Rothschild’s International Tax and Wealth Planning Group — and as a partner at Chamberlain Hrdlicka and Kostelanetz & Fink, after founding  August, Kulunas, Dawson & Siegel, P.A. in West Palm Beach and co-chairing the tax department of Steel Hector & Davis.

Bryan C. Skarlatos, Esq., Partner | Kostelanetz

Bryan C. Skarlatos is a Partner at Kostelanetz LLP in New York, where for more than thirty-five years he has represented individuals and corporations in civil and criminal tax controversies, white-collar criminal investigations, and sensitive tax planning matters.

• Education & Credentials

He earned his LL.M. in Taxation from New York University School of Law (1991).

• Recognition & Leadership

Chambers USA ranks him Band 1 nationwide for Tax Fraud — respondents call him “one of the legends in the field” — and he has three times been named Best Lawyers “Lawyer of the Year” for Litigation and Controversy – Tax in New York (2014, 2017, 2025). In 2026 he received the ABA Tax Section’s Jules Ritholz Memorial Merit Award.

• Professional Involvement

He is an adjunct professor at New York University School of Law, where he teaches a course on tax penalties and prosecutions; created and co-chairs the annual NYU Tax Controversy Forum; serves on the NYU Institute on Federal Taxation’s advisory board and chairs its Ethics program; is a Fellow of the American College of Tax Counsel; and has chaired tax committees of the American Bar Association, the New York State Bar Association, and the New York City Bar.

• Experience

He has represented hundreds of taxpayers in civil audits, at IRS Appeals, and in Tax Court; is frequently retained by individual and corporate clients, as well as foreign and state governments, to provide expert testimony on tax standards, penalties, and procedures; and maintains an active tax and estate planning advisory practice.

Sanford J. Schlesinger, Esq., Founding Partner | Schlesinger Lazetera & Auchincloss

Sanford J. “Sandy” Schlesinger is a Founding Partner of Schlesinger Lazetera & Auchincloss LLP in New York — a nationally recognized expert in estate and tax planning, estate administration, family-owned business planning, and charitable planning who also handles contested and litigated estate and trust matters.

• Education & Credentials

He received his B.S., with honors, from Columbia University (1963) and his J.D. from Fordham University School of Law (1966).

• Recognition & Leadership

He has been elected to the National Association of Estate Planners & Councils’ Estate Planning Hall of Fame, designated a Distinguished Accredited Estate Planner, and is ranked by Chambers High Net Worth as a Senior Statesperson in Private Wealth Law.

• Professional Involvement

A Fellow and former Downstate New York Chair of the American College of Trust and Estate Counsel, he is a former Chair of the New York State Bar Association’s Trusts and Estates Law Section and of the Advisory Board of the NYU Institute on Federal Taxation, where he chairs the Trusts & Estates program; he has chaired the Practising Law Institute’s Annual Estate Planning Institute for more than 20 years and is an Academician of the International Academy of Estate and Trust Law.

• Experience

He has authored three books and numerous publications on trusts, estates, taxation, closely held business and family succession planning, and charitable giving, and is a frequent lecturer nationwide.

Daniel J. Winnick, Esq., Principal, International Tax | KPMG

Daniel J. Winnick is a Principal in the International group of KPMG’s Washington National Tax practice.

• Professional Involvement

He writes and speaks frequently on international tax policy and guidance, including on KPMG’s Inside International Tax podcast and Capitol Hill webcasts, and has spoken at the International Fiscal Association’s USA Branch conferences.

• Experience

Before joining KPMG, he served as an Attorney-Advisor in the Office of Tax Policy at the U.S. Department of the Treasury. At KPMG he advises on international tax legislation and regulatory developments, including the international provisions of the One Big Beautiful Bill Act and the corporate alternative minimum tax.

Megan L. Brackney, Esq., Partner | Kostelanetz

Megan L. Brackney is a Partner at Kostelanetz LLP, where she concentrates her practice on civil and criminal tax controversies at the federal, state, and local levels, representing clients in audits, investigations, and litigation in the Tax Court and state and federal courts.

• Education & Credentials

She earned her B.A. in Philosophy, with honors, from the University of Kansas, her J.D. from the University of Kansas School of Law, and her LL.M. in Taxation from New York University School of Law.

• Recognition & Leadership

She is the immediate past Chair of the American Bar Association Section of Taxation — having previously served as its Vice Chair of Committee Operations and a Council Director — received the ABA Tax Section’s John S. Nolan Fellowship, and has been recognized by New York Super Lawyers since 2012 and ranked by Chambers USA.

• Professional Involvement

She is an adjunct professor at New York University School of Law, where she teaches tax procedure in the Graduate Tax Program; a Fellow of the American College of Tax Counsel; a member of the New York State Bar Association Tax Section’s Executive Committee; an annual contributor to the ABA’s Effectively Representing Your Client Before the IRS; and serves on the editorial boards of the Journal of Taxation and The Tax Lawyer.

• Experience

Before joining Kostelanetz in 2004, she was an Assistant United States Attorney for the Southern District of New York and an Assistant Attorney General for the State of Missouri.

Frank Agostino, Esq. | Kostelanetz

Frank Agostino has, during four decades of practicing tax law, been the driving force behind many successful lawsuits establishing fair tax enforcement principles for taxpayers, litigating more than 100 tax matters — several of which created important precedents, including Commissioner v. Zuch before the U.S. Supreme Court (2025) and Chai v. Commissioner in the Second Circuit (2017).

• Education & Credentials

He earned his B.A., cum laude, from the City College of New York, his J.D., cum laude, from New York Law School, and his LL.M. in Taxation from New York University School of Law.

• Recognition & Leadership

He is ranked by Chambers in Band 1 for Tax: Fraud (Nationwide), and his precedent-setting challenges to government enforcement processes have changed the way the IRS and the Tax Court do business.

• Professional Involvement

He serves on the Advisory Board of the Journal of Tax Practice and Procedure, is President of Taxpayers Assistance Corp., which provides tax and legal advice to low-income taxpayers in the New York/New Jersey area, has taught tax controversy as an adjunct professor at Seton Hall University’s Stillman School of Business and Rutgers Law School, and served as co-director of the Rutgers Federal Tax Law Clinic.

• Experience

Before joining Kostelanetz in 2025, he was the founder and president of Agostino & Associates, a well-known New Jersey tax controversy firm; earlier, he was an attorney with the IRS District Counsel in Springfield, Illinois, and Newark, New Jersey, and served as a Special Assistant United States Attorney prosecuting criminal tax cases.

Steven P. Johnson, Esq., Partner | Morgan, Lewis & Bockius

Steven P. Johnson is a Partner in Morgan Lewis’s Employee Benefits Practice, focusing on tax controversy and litigation with a special focus on payroll tax, fringe benefits, executive compensation, and information reporting.

• Education & Credentials

He earned his LL.M. in Taxation from Georgetown University Law Center (2010), his J.D., cum laude, from Tulane University Law School (2005), and his B.S. in Accounting, summa cum laude, from the University of Louisiana at Lafayette (2002). He is admitted in the District of Columbia and Louisiana and before the U.S. Tax Court, the Court of Federal Claims, and the Fifth Circuit, among other federal courts.

• Recognition & Leadership

He was recognized as part of Law360’s Practice Group of the Year in both Benefits (2022) and Tax (2017), and was listed as a Washington, D.C. Super Lawyers “Rising Star.”

• Professional Involvement

He has served as an adjunct professor teaching IRS Administrative Procedures in Georgetown Law’s LL.M. program since 2015, and is a member of the D.C. Bar Tax Section and the J. Edgar Murdock Inn of Court.

• Experience

Before joining Morgan Lewis, he served as a trial attorney in the U.S. Department of Justice Tax Division and as a law clerk to Judge Tucker L. Melancon of the U.S. District Court for the Western District of Louisiana.

Joshua Odintz, Esq., Partner | Holland & Knight

Joshua D. Odintz is a tax attorney in Holland & Knight’s Washington, D.C. office, focusing on tax policy, tax controversy, and tax planning, and representing clients before Treasury, the IRS, Congress, and the OECD.

• Education & Credentials

He earned his B.A. from the University of California, San Diego, his J.D. from California Western School of Law, and his LL.M. in Taxation from Georgetown University Law Center.

• Recognition & Leadership

He is a Fellow of the American College of Tax Counsel and has been recognized by Bloomberg Tax for U.S. Taxes: Contentious and International Tax.

• Professional Involvement

He is a frequent speaker at the International Fiscal Association, Tax Executives Institute, the ABA, and the University of Chicago Tax Conference, co-chairs Holland & Knight’s Washington, D.C. pro bono program, and writes regularly on tax policy.

• Experience

He has held high-level government positions with the Treasury Department and the Senate Finance Committee — including serving as Acting Tax Legislative Counsel at Treasury, Senior Advisor for Tax Reform to the Assistant Secretary, and Chief Tax Counsel to President Obama’s National Commission on Fiscal Responsibility and Reform. Before joining Holland & Knight, he was a partner at Baker McKenzie, where he served on the management committee of the North American Tax Practice Group.

Michael J. Miller, Esq., Partner | Roberts & Holland

Michael J. Miller, a Partner at Roberts & Holland LLP, has provided U.S. tax advice to domestic and international clients for more than 20 years, structuring inbound investments and operations and developing structures that take advantage of U.S. income tax treaties and other special rules.

• Education & Credentials

He earned his B.A., cum laude, from Columbia College and his J.D. from New York University School of Law.

• Recognition & Leadership

He is designated a leading tax professional by Chambers USA, Super Lawyers, and Legal Media Group’s Expert Guides: Tax Advisers.

• Professional Involvement

He has chaired the ABA Tax Section’s U.S. Activities of Foreign Taxpayers Committee and the New York City Bar’s Business Entities Committee; edits the International column of the Journal of Taxation; serves on the advisory boards of the International Tax Journal and the Bloomberg Tax Management International Journal; co-authored two Bloomberg Tax Portfolios on tax treaties and international shipping; and co-chairs NYU’s Summer Institute international taxation conferences.

• Experience

After law school, he clerked at the U.S. Tax Court for the Honorable James S. Halpern (1991–1993), and he has been a partner at Roberts & Holland since 2000.

Barbara T. Kaplan, Esq., Shareholder | Greenberg Traurig

Barbara T. Kaplan is a Shareholder and Co-Chair of the Global Tax Practice at Greenberg Traurig, focusing her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies, and litigation, including administrative and grand jury criminal tax investigations.

• Education & Credentials

She earned her B.A. from the University of Wisconsin–Madison (1970), her M.A. from Northwestern University (1972), her J.D., cum laude, from Brooklyn Law School (1975), and her LL.M. in Taxation from New York University School of Law (1979).

• Recognition & Leadership

She was named Best Lawyers “Lawyer of the Year” for Litigation and Controversy – Tax in New York City (2020), has been named among the Top 50 Women Lawyers in New York City by Super Lawyers, and is rated AV Preeminent.

• Professional Involvement

A Fellow of the American College of Tax Counsel, she is an Adjunct Professor of Law at NYU School of Law, where she teaches Civil Tax Controversies & Litigation; served on the Executive Committee of the New York State Bar Association Tax Section; and previously served on the Advisory Board of the NYU Institute on Federal Taxation.

• Experience

Her practice spans tax compliance counseling, offshore account reporting, sensitive audits, promoter audits, voluntary disclosures, complex civil tax litigation, and criminal tax investigations.

Scott D. Michel, Esq., Member | Caplin and Drysdale

Scott D. Michel is a Member of Caplin & Drysdale, where he has practiced since 1981 and previously served as the firm’s President, and is internationally recognized for his experience in matters arising from U.S. enforcement involving undeclared foreign accounts — criminal tax investigations, sensitive civil audits, and voluntary disclosures.

• Education & Credentials

He earned his J.D. from the University of Virginia School of Law.

• Recognition & Leadership

He is a Legal 500 “Hall of Fame” lawyer for U.S. contentious tax and leads the firm’s tax controversy practice; he has testified as an expert on offshore account enforcement before the Standing Committee on Finance of the Canadian House of Commons.

• Professional Involvement

He is a Fellow of the American College of Tax Counsel, has served as a Council Director for the ABA Section of Taxation — previously chairing its Civil and Criminal Tax Penalties and Standards of Tax Practice Committees — is a member of the International Fiscal Association, and is an Adjunct Professor of Law in the University of Miami School of Law’s Graduate Program in Taxation.

• Experience

He has assisted many thousands of individual and corporate taxpayers in returning to compliance through the voluntary disclosure process, and is routinely consulted by other practitioners on sensitive ethical questions arising in tax practice.

Karen Gilbreath Sowell, Esq., Principal | EY

Karen Gilbreath Sowell is a Principal in Ernst & Young LLP’s National Tax Department in Washington, DC, where she serves as EY Global Transaction Advisory Leader and Co-Director of the National Tax Mergers and Acquisitions Group, advising on corporate tax legislative and regulatory matters and complex M&A transactions.

• Recognition & Leadership

She served as Chair of the New York State Bar Association Tax Section in 2018 and is a former Chair of the ABA Tax Section’s Corporate Tax Committee.

• Professional Involvement

She is a longtime leader of the Institute’s corporate tax programming and a frequent speaker at national tax conferences.

• Experience

She served as the U.S. Treasury Department’s Deputy Assistant Secretary for Tax Policy from 2007 to 2009, through the global financial crisis, and earlier as Associate Tax Legislative Counsel and Attorney-Advisor in the Office of Tax Policy from 1997 to 2001.

Jodi J. Schwartz, Esq., Partner | Wachtell, Lipton, Rosen, and Katz

Jodi J. Schwartz is a Tax Partner at Wachtell, Lipton, Rosen & Katz — elected partner in 1990 — focusing on the tax aspects of corporate transactions, including mergers and acquisitions, joint ventures, spin-offs, and financial instruments, and serving as principal tax lawyer on numerous domestic and cross-border transactions across industries.

• Education & Credentials

She earned her B.S. in Economics, magna cum laude, from the University of Pennsylvania (1981), her M.B.A. from the Wharton School and her J.D., magna cum laude, from the University of Pennsylvania Law School (both 1984), where she was an editor of the Law Review, and her LL.M. in Taxation from New York University School of Law (1987).

• Recognition & Leadership

She is recognized among the world’s leading tax lawyers — ranked Band 1 by Chambers USA (New York Tax, 23 years ranked) and selected by Chambers Global, the International Who’s Who of Business Lawyers, and Euromoney’s Expert Guides.

• Professional Involvement

She is a past Chair and Executive Committee member of the New York State Bar Association Tax Section, a member of the American College of Tax Counsel, and serves on the Board of Trustees of the University of Pennsylvania and the Board of Advisors of Penn Carey Law School.

• Experience

She has been the principal tax lawyer on many of the market’s most significant domestic and cross-border mergers, acquisitions, and spin-offs across a wide range of industries.

Eric Solomon, Esq., Partner | Ivins, Phillips & Barker

Eric Solomon is a Partner at Ivins, Phillips & Barker, Chartered in Washington, DC, with more than 40 years of tax experience in private practice and government service, advising clients on a wide range of transactional, policy, and controversy issues.

• Education & Credentials

He earned his A.B. from Princeton University, his J.D. from the University of Virginia, and his LL.M. in Taxation from New York University.

• Recognition & Leadership

For his government service he received the Alexander Hamilton Award — Treasury’s highest honor — and the Distinguished Presidential Rank Award; he is a former Chair of the ABA Section of Taxation and received its Distinguished Service Award in 2025, and is a past President of the American Tax Policy Institute.

• Professional Involvement

He is an adjunct professor of law at Georgetown University Law Center, where he teaches corporate taxation.

• Experience

He served as Assistant Secretary for Tax Policy at the U.S. Treasury Department from 2006 to 2009 — the Department’s highest tax policy position, which he held through the 2008 financial crisis — after joining the Office of Tax Policy in 1999 and serving as Senior Advisor and Deputy Assistant Secretary in both the Clinton and George W. Bush administrations. Earlier he headed the IRS corporate tax division as Assistant Chief Counsel (Corporate) from 1990 to 1995, co-directed Ernst & Young’s National Tax Department, and was a partner and senior counsel at Steptoe & Johnson and a partner at Drinker Biddle & Reath.

Alexander Lee, Esq., Partner | Cooley

Alexander Lee is a Partner at Cooley LLP, where he heads the tax practice in the firm’s Los Angeles office, concentrating on mergers and acquisitions, capital markets, and lending and finance with an emphasis on complex international corporate transactions — he has advised on more than 150 successful IPOs and over one thousand domestic and cross-border M&A transactions.

• Education & Credentials

He earned his B.A. in Psychology from the University of California, Santa Barbara (1992), his J.D. from the UCLA School of Law (1996), and his LL.M. from New York University School of Law (1998).

• Recognition & Leadership

He received the Los Angeles County Bar Association Taxation Section’s 2021 Dana Latham Memorial Award — its youngest-ever recipient — and was the youngest practitioner recognized by Chambers Global and The Legal 500 among the nation’s top experts in international tax; he has been ranked by Chambers USA and Chambers Global, Best Lawyers, Legal 500, and Super Lawyers.

• Professional Involvement

He has taught International Taxation, Corporate Taxation, and Mergers & Acquisitions as an adjunct professor in Loyola Law School’s Tax LL.M. program for more than 20 years, and created the “Taxplaining” video series translating complex tax issues into plain English.

• Experience

Before joining Cooley in 2018, he was a tax partner at McDermott Will & Emery and, earlier, at Paul Hastings.

Sam K. Kaywood, Esq., Senior Counsel | Alston & Bird

Sam K. Kaywood, Jr. is Senior Counsel in Alston & Bird’s Federal & International Tax Group and a co-chair of the firm’s International Team, concentrating on federal income tax and international tax — cross-border M&A, joint ventures, and inbound investment into the United States — with substantial experience in Canada, Europe, China, and Latin America.

• Education & Credentials

He earned his B.S. from Babson College (1979) and his J.D. from Emory University (1986).

• Recognition & Leadership

He has been ranked by Chambers USA in Tax (Georgia) for more than 20 years, named Best Lawyers “Lawyer of the Year” for Tax Law in Atlanta (2021), and listed in The Best Lawyers in America.

• Professional Involvement

A former chair of the ABA Tax Section’s Committee on U.S. Activities of Foreigners and Tax Treaties, he serves on the Executive Committee of the International Bar Association’s Tax Section, is active in the International Fiscal Association, and is an adjunct professor at Emory University School of Law, where he teaches International Tax.

• Experience

Over a more than 30-year career he has worked on virtually all forms of cross-border investment, and is particularly active structuring investments and acquisitions in Latin America, including Brazil, Mexico, Argentina, and Chile.

Alyssa Maloof Whatley, Esq., Director | Frost Law

Alyssa Maloof Whatley is the Director of Tax Controversy (Domestic) at Frost Law, representing individuals and businesses nationwide in IRS audits, penalty abatement, collections, and complex domestic tax controversy matters.

• Education & Credentials

She earned her undergraduate degree from the University of Georgia and her J.D. from Georgia State University College of Law — which she attended at night while working full time — where she received the CALI Excellence for the Future Award and a J.B. Moore Tax Clinic Fellowship.

• Recognition & Leadership

She has been recognized by Best Lawyers for Litigation and Controversy – Tax and Tax Law, and selected to Super Lawyers Rising Stars every year since 2019.

• Professional Involvement

She serves as Vice Chair of the ABA Tax Section’s Collection, Bankruptcy & Workouts Committee and is a past President of the Metro Atlanta Consumer Bankruptcy Attorneys Group.

• Experience

Before Frost Law acquired her practice in 2025, she founded and led her own successful Georgia tax controversy firm; earlier she interned for a U.S. Bankruptcy Judge, served as a Chapter 13 courtroom attorney covering three federal courtrooms in the Atlanta Division, and represented taxpayers in tax litigation at Bomar Law Firm.

Phillip Colasanto, Esq., Partner | Charles Russell Speechlys

Phillip Colasanto is a Private Client Partner in Charles Russell Speechlys’ New York office — part of the team that launched the firm’s first North American offices in 2026 — focusing on domestic and international tax controversy and compliance matters.

• Recognition & Leadership

He received the New York County Lawyers’ Association Pro Bono Award in 2022.

• Professional Involvement

He chairs the ABA Tax Section’s Tax Collection, Bankruptcy and Workouts Committee, has spoken at the ABA, the New York County Lawyers’ Association, the IRS Nationwide Tax Forum, and the NYU Tax Controversy Forum, and has published in Tax Notes, Bloomberg BNA, the Journal of Tax Practice and Procedure, and The Practical Lawyer.

• Experience

He has represented clients before the U.S. Tax Court, U.S. district courts, the U.S. Courts of Appeals, and various state courts — from examination and collection matters through Appeals hearings, innocent spouse relief, whistleblower claims, and oral argument at the appellate level. Before joining Charles Russell Speechlys, he practiced in the tax controversy group at Withers.

Joseph M. Calianno, JD, LLM, MBA, CPA, Managing Director, National Tax Practice | Andersen Tax

Joe Calianno is a Managing Director in Andersen’s US National Tax practice in Washington, DC, where he serves as the practice’s leader for international tax, advising clients across the full range of international tax matters, including the provisions enacted under the Tax Cuts and Jobs Act and cross-border restructurings.

• Education & Credentials

He earned his B.S. in Accounting from the University of Scranton, his J.D. from Villanova University School of Law, where he served on the Villanova Law Review, his LL.M. in Taxation from New York University School of Law, and his M.B.A. from NYU’s Leonard N. Stern School of Business. He is both a CPA and an attorney.

• Recognition & Leadership

He is a member of Tax Notes’ Council of Eminent Persons and is regularly quoted in the tax press on international tax developments.

• Professional Involvement

He is a past Chair of the ABA Tax Section’s Foreign Activities of U.S. Taxpayers Committee, past Chair and Vice Chair of the AICPA’s International Tax Technical Resource Panel, a member of the IFA USA Branch Council, and an Advisory Board member and past Co-Chair of the International Tax Section of the Federal Bar Association’s Annual Tax Law Conference; he publishes widely in national tax journals.

• Experience

He previously served as Special Counsel to the Deputy Associate Chief Counsel (International) in the IRS Office of Chief Counsel, and spent more than 15 years as a partner at BDO and Grant Thornton, serving as International Technical Tax Practice Leader in both firms’ national tax offices.

Sean Dokko, JD, LLM, Managing Director, National Tax Practice | Andersen Tax

Hyung “Sean” Dokko is a Managing Director at Andersen in New York, advising clients on international tax issues concerning cross-border operations and transactions, with extensive experience developing, implementing, and reporting tax planning strategies and cross-border restructurings.

• Education & Credentials

He earned his B.A. in Economics from New York University, his J.D. from Emory University, and his LL.M. in Taxation from New York University School of Law.

• Professional Involvement

He presents regularly on international tax topics, including at NYU’s Summer Institute in Taxation alongside the Institute’s international tax faculty.

• Experience

Before joining Andersen, he was an International Tax Partner at Citrin Cooperman, Principal and Head of Tax at a New York tax consulting firm, and a Managing Director in BDO’s National Tax Office (International), where he practiced for nearly a decade.

William S. Dixon, Esq., Managing Director, Mergers and Acquisitions | Citigroup Global Markets

William S. Dixon is an investment banker and Managing Director at Citigroup Global Markets Inc., focusing on tax-advantaged domestic and cross-border M&A transactions, capital structure solutions, and financings for public and private companies — mergers, acquisitions, spin-offs and other divestitures, buy-outs, and SPAC transactions — and serves on the firm’s Fairness Opinion Committee.

• Recognition & Leadership

He was named a John S. Nolan Fellow of the ABA Section of Taxation and served on the ABA’s Task Force on International Tax Reform.

• Professional Involvement

He serves on the Board of Directors of the International Tax Institute, is a member of the New York Steering Committee of the International Fiscal Association, is a former Chair of the ABA Tax Section’s U.S. Activities of Foreigners and Tax Treaties Committee, and has taught the taxation of securities and derivatives and partnership taxation as an adjunct at Brooklyn Law School, St. John’s Tobin School of Business, and NYU’s Stern School of Business.

• Experience

Before joining Citigroup, he was a Senior Attorney at Cravath, Swaine & Moore LLP in New York, where he began his legal career as a tax associate.

Trevor R. Allen, Esq., Partner | Skadden, Arps, Slate, Meagher & Flom

Trevor R. Allen is a Tax Partner at Skadden, Arps, Slate, Meagher & Flom LLP and head of the firm’s New York Tax Group, advising on the tax aspects of mergers and acquisitions, spin-offs, joint ventures, investment fund formations, foreign investment in the U.S., REIT transactions, and IPOs, including “UP-C” IPOs.

• Education & Credentials

He earned his B.A. from Loyola University New Orleans (2006), his J.D. from Georgetown University Law Center (2010), and his LL.M. from New York University School of Law (2011). He is admitted in New York.

• Recognition & Leadership

He was elected to the Skadden partnership in 2022 and now leads the firm’s New York Tax Group.

• Professional Involvement

He has been a guest speaker on tax planning topics at the Tax Executives Institute and the ABA Section of Taxation annual meetings.

• Experience

His practice also includes tax controversies and obtaining private letter rulings from the IRS.

Joe Soltis, Esq., Partner | Freshfields

Joe Soltis is a Tax Partner in Freshfields’ New York office, representing clients across industries on the U.S. tax aspects of transactional deals — domestic and cross-border taxable and tax-free mergers and acquisitions, spin-offs, recapitalizations, financing arrangements, partnerships and joint ventures, bankruptcy reorganizations, and securities issuances.

• Recognition & Leadership

He was selected to the Lawdragon 500 Leading Global Tax Lawyers guide for 2026 and is recognized by The Legal 500 as a key lawyer for U.S. non-contentious and international tax.

• Experience

Before joining Freshfields in 2022, he practiced at Cadwalader, Wickersham & Taft in New York; his representations have included sovereign wealth funds, private equity investors, and public companies in joint ventures, IPOs, and acquisitions.

Jameson S. Lloyd, Esq., Partner | Sullivan & Cromwell

Jameson S. Lloyd is a Partner in Sullivan & Cromwell’s Tax Group, focusing on the tax aspects of public and private mergers, acquisitions, spin-offs and other restructurings, fund formations, real estate acquisitions, securities offerings, and corporate financings, with particular activity advising foreign-parented multinationals on U.S. debt-equity issues.

• Education & Credentials

He earned his B.A. from the University of Washington (2008) and his J.D. from New York University School of Law (2013).

• Professional Involvement

His pro bono work has focused on tax-related projects with LGBT nonprofit organizations.

• Experience

He has represented clients in tax controversy matters before the IRS audit and Appeals functions, and is regularly quoted in the tax press, including on the proposed stock buyback tax rules.

Isaac J. Wheeler, Esq., Partner | Sullivan & Cromwell

Isaac J. Wheeler is a Partner at Sullivan & Cromwell and Co-Head of the firm’s Tax Group and Tax Policy Practice, representing financial institutions, multinational corporations, asset managers, real estate developers, and private individuals on M&A, real estate, joint venture, hedge fund, private equity, and partnership transactions.

• Education & Credentials

He earned his B.A. from the University of Michigan (2003) and his J.D. from New York University School of Law (2009).

• Recognition & Leadership

He was named a Law360 MVP in Tax in both 2022 and 2025, The American Lawyer’s “Dealmaker of the Year” in 2022, and is ranked by Chambers USA for Tax – New York.

• Professional Involvement

He is a frequent faculty member at PLI’s partnership and joint venture tax planning programs.

• Experience

His recent matters include RedBird Capital Partners’ formation of “New Paramount,” the $113 billion xAI/X merger, Tishman Speyer’s $3.5 billion Rockefeller Center refinancing, and Boeing’s $8.3 billion acquisition of Spirit AeroSystems; he also regularly advises families on estate planning transactions and worldwide investments alongside S&C’s Estates and Personal Group.

Lorenz Haselberger, Esq., Partner | A&O Shearman

Lorenz Haselberger is a Partner in A&O Shearman’s tax practice in New York — a transactional tax generalist focusing on the taxation of financial institutions and instruments, private credit and direct lending, debt restructurings, domestic and cross-border M&A, securitizations, synthetic risk transfers, complex derivatives, and capital markets transactions, with particular depth in digital assets.

• Education & Credentials

He earned his undergraduate degree from the University of Pennsylvania (2009) and his J.D. from Harvard Law School (2012), where he authored a note in the Harvard Law Review.

• Recognition & Leadership

Chambers USA ranks him as an Up-and-Coming partner for Tax (New York) — “a rising star” noted for financial products, cryptocurrency, and derivatives — and The Legal 500 has named him a Next Generation Partner for Tax: Financial Products.

• Professional Involvement

He chairs the ABA Tax Section’s Financial Institutions and Products Committee, serves on the Executive Committee of the New York State Bar Association Tax Section, is a member of the Tax Forum, and has authored NYSBA Tax Section reports on digital assets, NFTs, and basket contract transactions as well as articles in Tax Notes Federal.

• Experience

Before his current role he practiced at Cleary Gottlieb Steen & Hamilton and served as Vice President, Corporate Tax Planning and Analytics at JPMorgan Chase, returning to the firm and being elected partner in 2022.

Vadim Novak, Esq., Partner | Fried, Frank, Harris, Shriver & Jacobson

Vadim Novik is a Tax Partner at Fried, Frank, Harris, Shriver & Jacobson LLP in New York, advising businesses, financial services firms, and investment funds on capital markets, securitization, and financial products — including structured notes — with particular expertise advising investment funds and institutional investors on derivative transactions, including synthetic risk transfers.

• Education & Credentials

He earned his B.A. in Marketing, summa cum laude, from Rutgers University and his J.D. from New York University School of Law. He is admitted in New York and New Jersey.

• Professional Involvement

He serves as Vice Chair of the ABA Tax Section’s Financial Institutions and Products Committee, is a member of the Tax Club, speaks frequently at PLI, the ABA, and the Wall Street Tax Association, and has published in Tax Notes, PLI’s Taxation of Financial Products and Transactions, and Bloomberg BNA.

• Experience

He joined Fried Frank in 2025 after more than a decade of senior in-house tax roles on Wall Street — most recently as Head of U.S. Tax Advisory for the Commercial & Investment Bank at JPMorgan, with earlier senior tax counsel experience at Morgan Stanley — having begun his career as a tax associate at an international law firm.

Myra A. Sutanto Shen, Esq., Partner | Wilson Sonsini

Myra A. Sutanto Shen is a Tax Partner in the Palo Alto office of Wilson Sonsini and head of the firm’s tax practice group, representing technology and life science companies in all aspects of U.S. federal income tax planning — domestic and cross-border M&A, equity and debt financings, IPOs and convertible note offerings, and restructurings — and advising founders, investors, and companies on the qualified small business stock exemption under Section 1202.

• Education & Credentials

She earned her B.A. in Integrated Science and Biology from Northwestern University (2002), cum laude, and her J.D., cum laude with honors, from Northwestern Pritzker School of Law (2007), where she was a Production Editor of the Journal of Criminal Law and Criminology.

• Recognition & Leadership

In 2025 she was appointed Vice Chair of the ABA Tax Section’s Corporate Tax Committee, and she heads the tax practice of one of the country’s premier technology law firms.

• Professional Involvement

She is a member of the Taxation Section of the State Bar of California and of the International Fiscal Association (USA Branch), co-chairs Wilson Sonsini’s Diversity, Equity, and Inclusion Committee, and publishes regularly on Section 1202 and QSBS planning.

• Experience

During law school she represented low-income investors in broker-dealer disputes through the Bluhm Legal Clinic’s Investor Protection Center, and she has spent her practice at Wilson Sonsini advising emerging-growth and public companies at every stage of the corporate life cycle.

Timothy Shapiro, Esq., Partner | Cooley

Tim Shapiro is a Tax Partner in Cooley’s Palo Alto office, advising public and private companies on the tax aspects of domestic and cross-border transactions — mergers and acquisitions, reorganizations, debt and equity financings, and the formation and operation of limited liability companies and other passthrough entities.

• Education & Credentials

He earned his B.A. in Economics and Music, summa cum laude and Phi Beta Kappa, from Amherst College (2007) and his J.D. from Stanford Law School (2011), where he was an Articles Editor of the Stanford Law Review.

• Recognition & Leadership

He received the Tannenwald Foundation Prize for Excellence in Tax Scholarship (2010), has been named a Northern California Super Lawyers Rising Star since 2016, and is recognized by The Legal 500 US for Taxes: Non-Contentious.

• Professional Involvement

He speaks and writes on transactional tax topics, including Section 1202 planning for emerging companies.

• Experience

From 2011 to 2013 he clerked for the Honorable Richard A. Posner of the U.S. Court of Appeals for the Seventh Circuit; he then practiced at Wilson Sonsini for more than six years before joining Cooley, where he was elected partner effective 2023.

Lewis R. Steinberg, Esq. | New York University

Lewis R. Steinberg recently retired as Managing Director and Head of Structured Solutions in the Global Corporate and Investment Bank of BofA Securities, capping more than 30 years of strategic advisory experience in the tax, legal, and accounting structuring of M&A and capital markets transactions.

• Education & Credentials

He earned his A.B. in History and Music from Amherst College and his J.D. and LL.M. in Taxation from New York University School of Law.

• Recognition & Leadership

He is a past Chair of the New York State Bar Association Tax Section.

• Professional Involvement

He has served as an adjunct professor at NYU School of Law for three decades and is a mainstay of national corporate tax programs, including PLI’s Tax Strategies series.

• Experience

He began his career at Cravath, Swaine & Moore in 1984, was elected partner in 1991, and co-headed the firm’s tax department; he then moved to investment banking as Managing Director and Global Head of the Strategic Solutions Group at UBS (2005–2010), Managing Director and Head of Strategic Advisory at Credit Suisse (2010–2015), and Head of Structured Solutions, Americas M&A, at Bank of America Merrill Lynch / BofA Securities (2015–2023).

Kevin Salinger, Esq., Acting Assistant Secretary (Tax Policy), US Department of the Treasury and Acting Chief Counsel | Internal Revenue Service

Kevin Salinger is the Deputy Assistant Secretary for Tax Policy at the U.S. Department of the Treasury — appointed in April 2025 — and currently serves as Acting Assistant Secretary for Tax Policy and Acting Chief Counsel of the IRS, leading a team of more than 100 staff responsible for developing and implementing federal tax policies, regulations, and administrative guidance.

• Education & Credentials

He holds a J.D. from Harvard Law School and a B.A. from the University of California, Berkeley.

• Recognition & Leadership

As principal deputy to the Assistant Secretary, he oversees the Office of Tax Policy’s legal counsels and has advised on legislation and regulations implementing the One Big Beautiful Bill Act; he previously served as Vice President of the Wall Street Tax Association.

• Professional Involvement

He represents the Department on significant tax policy matters and speaks regularly at national tax conferences and industry forums.

• Experience

Before joining Treasury, he spent more than ten years at Jefferies as Managing Director and Head of Tax Counsel & Advisory, advising the firm’s global investment banking and capital markets businesses, and began his legal career as a tax associate at Sullivan & Cromwell, advising on financial products, M&A, and cross-border tax planning.

Adam S. Feuerstein, Esq., Principal | PwC US Tax

Adam S. Feuerstein is a Principal at PwC and the firm’s National Real Estate Tax Technical Leader, helping clients navigate real estate and REIT taxation — from PropCo/OpCo structures, M&A, and IPOs to the day-to-day tax matters of public and private REITs through their life cycle.

• Education & Credentials

He earned his B.S. with honors from Cornell University, a Master’s in Public Policy from Harvard’s John F. Kennedy School of Government, and his J.D., cum laude, from Harvard Law School.

• Recognition & Leadership

He is co-author of the treatise on Real Estate Investment Trusts for RIA’s Catalyst series and a contributor to the Guide to Global Real Estate Investment Trusts.

• Professional Involvement

He has served as an adjunct professor at Georgetown University Law Center since 2010, is an active member of the Real Estate Roundtable’s Tax Policy Advisory Committee and NAREIT, and serves on the faculty of PLI’s Real Estate Tax Forum and Real Estate M&A and REIT Transactions programs.

• Experience

Before joining PwC in 2011, he was a partner at Hogan & Hartson (now Hogan Lovells) for more than a decade and earlier practiced at Winston & Strawn.

Jonathan Talansky, Esq., Partner | King & Spalding

Jonathan Talansky is a Tax Partner in King & Spalding’s New York office, specializing in federal income taxation with an emphasis on real estate private equity funds, public and private REITs, mergers and acquisitions, infrastructure projects, capital markets, and real estate acquisitions and divestitures — and he is one of the nation’s leading authorities on the qualified opportunity zone rules.

• Education & Credentials

He earned his B.A., summa cum laude, from Columbia University and his J.D., cum laude, from Harvard Law School (2006).

• Recognition & Leadership

He co-authored the Bloomberg Tax Management Portfolio Investments in Qualified Opportunity Zones, received Bloomberg’s Federal Tax Portfolio Author of the Year recognition, and was named a New York Super Lawyers Rising Star in Tax (2012–2017); his private-REIT work appears in PLI’s Corporate Tax Practice Series.

• Professional Involvement

He is an active member of the Executive Committee of the New York State Bar Association Tax Section and co-chairs its Real Estate Committee.

• Experience

Before joining King & Spalding as a partner in 2016, he was a partner at Mintz Levin and spent seven years as an associate at Simpson Thacher & Bartlett; his practice has included leveraged buyouts, leveraged spin-offs, tax receivable agreements, and cutting-edge Section 1031 exchanges.

Marc Countryman, Esq., Partner | EY

Marc Countryman is a Partner in EY’s National Tax Department, based in San Francisco, where his practice concentrates on corporate taxation and consolidated returns.

• Education & Credentials

He earned his law degree from Loyola University Chicago School of Law. [MISSING — undergraduate degree and honors not found in public sources]

• Professional Involvement

He is a frequent speaker on corporate and consolidated-return topics at national tax programs, including the NYU Institute on Federal Taxation.

• Experience

His career spans both government and major-firm practice: he served as Associate Tax Legislative Counsel in the U.S. Treasury Department’s Office of Tax Policy and as a Senior Technician Reviewer in the IRS Office of the Associate Chief Counsel, with earlier tax roles at Arthur Andersen and Deloitte before joining EY.

Ryan Dobens, Esq., Director | KBF Advisory

Ryan J. Dobens is a Director at KBF Advisory in Washington, DC, specializing in partnership taxation and complex federal tax planning for multinational businesses, venture capital funds, and private equity firms — and he is nationally known as a leading authority on the qualified small business stock (QSBS) exclusion under Section 1202.

• Education & Credentials

He earned his B.S. in Accounting, summa cum laude, from Plymouth State University and both an M.S. in Taxation and a J.D. from Northeastern University. He is a CPA and a non-practicing attorney.

• Recognition & Leadership

He is the primary author of Bloomberg Tax’s BNA Portfolio 716 on partnership distributions and the forthcoming lead author of BNA Portfolio 760 on small business tax incentives, which extensively covers QSBS planning.

• Professional Involvement

He speaks frequently on federal tax matters nationally, including for the American Bar Association and the California Lawyers Association, and his analysis has appeared in The Tax Adviser, Tax Notes, and Forbes.

• Experience

Before joining KBF, he spent more than a decade in the national tax offices of two of the world’s largest accounting firms — Ernst & Young’s Passthrough Transactions Group and PricewaterhouseCoopers — advising on partnership taxation and high-net-worth planning strategies.

Amanda H. Nussbaum, Esq., Partner | Proskauer Rose

Amanda H. Nussbaum is the Chair of Proskauer’s Tax Department and a member of the firm’s Private Funds Group, concentrating on the planning and structuring of domestic and international private investment funds — venture capital, buyout, real estate, and hedge funds — and representing tax-exempt and non-U.S. investors in fund investments, alongside significant M&A, real estate, and capital markets work and counsel to sports teams and leagues.

• Education & Credentials

She earned her B.A., summa cum laude, from Yeshiva University’s Stern College for Women, her J.D. from Harvard Law School, and her LL.M. from New York University School of Law.

• Recognition & Leadership

Chambers USA ranks her Band 1 for Tax (New York), Law360 named her a Tax MVP (2023), Crain’s New York recognized her among its 2023 Notable Women in Law, and The Legal 500 has listed her for investment fund formation for nearly a decade.

• Professional Involvement

She is a Fellow of the American College of Tax Counsel and the American Bar Foundation, serves as vice president of the nonprofit Bottomless Closet, and has championed the advancement of women and diverse attorneys through Proskauer’s mentorship programs.

• Experience

She has spent her career at Proskauer, where she was elected partner in 2006 and rose to chair the Tax Department, counseling not-for-profits on exemption, UBTI, and joint ventures while anchoring the tax side of the firm’s market-leading funds practice.

Arash Lotfi, Esq., Associate | Latham & Watkins

Arash Lotfi is a tax associate in Latham & Watkins’ Washington, D.C. office and a member of the firm’s Transactional Tax Practice, advising on domestic and cross-border M&A and divestitures, the formation and structuring of private investment funds across a wide range of strategies, sponsor reorganizations and sales, and sponsor-led secondaries.

• Education & Credentials

He earned his B.S. in Mathematics and Philosophy from the University of Toronto, Trinity College (2014) and his J.D. from Harvard Law School (2018). He is admitted in the District of Columbia.

• Professional Involvement

He speaks on partnership and transactional tax topics, including the Section 751(b) program at this Institute.

• Experience

His recent matters at Latham include tax advice on Macquarie Asset Management’s record global data center transaction, Teledyne’s $1.1 billion acquisition of Varex Imaging, and fund formations and continuation vehicles for sponsors including Saw Mill Capital and Melange Capital Partners.

Sheri A. Dillon, Esq., Member | Miller & Chevalier, Chartered

Sheri A. Dillon focuses her practice on federal tax controversy, guiding clients through IRS examinations and appeals, administrative claims, and litigation, and counsels on business and tax planning with particular focus on high-net-worth individuals, partnership transactions, and closely held businesses; she has appeared before the U.S. Tax Court, district and appellate courts, and the Court of Federal Claims, including in matters involving economic substance, partnership audit regimes, and valuation.

• Education & Credentials

She earned her J.D., cum laude, from Georgetown University Law Center (1999), her M.P.P., with honors, from the University of Missouri-Columbia (1986), and her B.A. from the University of Missouri-Columbia (1984).

• Recognition & Leadership

She is a Fellow of the American College of Tax Counsel, ranked by Chambers USA for Tax (DC) and Tax: Controversy (Nationwide), and listed in The Best Lawyers in America for Litigation and Controversy — Tax and Tax Law.

• Professional Involvement

She serves as director and president of the Washington, DC Center for Public Interest Tax Law, is a retired Vice Chair for Pro Bono and Outreach of the ABA Tax Section, sits on the Texas Federal Tax Institute Advisory Board and the Court of Federal Claims Advisory Council’s Tax Committee, previously taught partnership taxation at Catholic University’s Columbus School of Law, and helped launch UDC’s Low-Income Taxpayer Clinic.

• Experience

She joined Miller & Chevalier in June 2026 after many years as a partner at Morgan, Lewis & Bockius (and earlier Bingham McCutchen), representing corporate taxpayers, TEFRA and BBA partnerships, tax-exempt organizations, and global high-wealth taxpayers across financial services, private equity, real estate, and energy.

George A. Hani, Esq., Member | Miller & Chevalier, Chartered

George A. Hani is a Member of Miller & Chevalier and Practice Co-Lead of its Tax Controversy & Litigation group, concentrating on the resolution of tax controversies at the administrative level with a particular focus on tax accounting issues, including tax refund litigation for major energy organizations.

• Education & Credentials

He earned his B.A. from Duke University (1987), his Ed.M. from Harvard University (1991), and his J.D., magna cum laude, from The Catholic University of America’s Columbus School of Law (1994), where he was a member of the Catholic University Law Review.

• Recognition & Leadership

He chaired Miller & Chevalier’s Tax Department from 2015 to 2019, is ranked by Chambers USA for Tax: Controversy, is routinely recognized by Legal 500 and International Tax Review, and co-authors the supplements to the leading treatise Federal Tax Accounting (Warren, Gorham & Lamont).

• Professional Involvement

He serves as Vice Chair for Committee Operations of the ABA Tax Section (former Council Director and former Chair of its Administrative Practice Committee), is a former Chair of the DC Bar Taxation Section, a Trustee of the Southern Federal Tax Institute (2025 Program Chair), a member of the Texas Federal Tax Institute Advisory Board, and writes a semi-annual Examination Issues column for the Journal of Tax Practice and Procedure.

• Experience

Before joining the firm, he was an Honors Attorney with the General Counsel’s office at the U.S. Department of the Treasury (1995-1996) and in the IRS Office of the Associate Chief Counsel (International) (1994-1995).

James O. Lang, Esq., Shareholder | Greenberg Traurig

James O. “Jim” Lang focuses his tax and corporate project finance practice on tax credit incentive programs, Qualified Opportunity Zone and Qualified Opportunity Fund financing, and related state and federal incentive programs — he is closing over $24 billion of Qualified Opportunity Funds and ancillary QOZ deployments and has closed or is structuring several billion dollars in tax credit incentivized transactions, including new markets, affordable housing, historic rehabilitation, renewable energy, and film credits.

• Education & Credentials

He earned his B.A. from the University of Florida, his J.D. from Florida State University College of Law, and his LL.M. in Taxation from the University of Florida’s Levin College of Law. He is admitted in Florida and New York.

• Recognition & Leadership

His honors include recognition as a team member of a Law360 Florida Powerhouse firm, the ABA’s “On the Rise — Top 40 Young Lawyers,” and co-authorship of Greenberg Traurig’s leading QOZ alerts tracking federal reform, including the OBBBA amendments and IRS Notice 2026-40.

• Professional Involvement

He is a member of the ABA’s Forum on Affordable Housing and Community Development Law and its Tax Credits and Tax Equity Financing Committee, served as lead advisor to the Florida New Markets Tax Credits Alliance, and chaired the Tampa Bay Economic Development Council’s International Committee.

• Experience

He joined Greenberg Traurig as a Shareholder in 2016 after building a leading Florida tax credit practice, and he works with funds, investors, lenders, community development entities, and project sponsors on incentive-financed capital stacks nationwide.

Sanford C. Presant, Esq., Shareholder | Greenberg Traurig

Sanford C. “Sandy” Presant, Senior Chair of Greenberg Traurig’s Private Funds Group and Co-Chair of its Global Real Estate Fund Practice, provides fund and joint venture best-practice business and tax structuring advice to sponsors of leading real estate private equity funds, QOZ funds, REITs, and their partners and investors — having structured and negotiated the business and tax aspects of over 500 major real estate joint ventures and fund sponsorships.

• Education & Credentials

He earned his B.A. from Cornell University (1973), his J.D. from the University at Buffalo School of Law (SUNY), and his LL.M. from Georgetown University Law Center. He is a member of the California and New York bars.

• Recognition & Leadership

He was Best Lawyers’ “Lawyer of the Year” for Tax Law in Los Angeles (2014), has been listed in The Best Lawyers in America for Tax Law since 2008, in Chambers USA (2011-2023), Lawdragon’s 500 Leading Global Real Estate Lawyers, and Legal 500 for REITs, and is co-author of the two-volume treatise Tax Aspects of Real Estate Investments.

• Professional Involvement

He is a prior Chair of the ABA Partnership Tax Committee, a member of NAREIT’s Government Relations Committee and the Real Estate Roundtable’s Tax Policy Advisory Committee (including its Opportunity Zone Working Group), and Co-Chair and co-founder of PLI’s annual Real Estate Tax Forum (1998-present); he was formerly an adjunct professor at NYU’s Real Estate Institute.

• Experience

Before Greenberg Traurig, he was National Co-Chair of Real Estate Fund Services at Ernst & Young (2000-2005) and Chair of DLA Piper’s Real Estate Fund Practice.

Robert D. Schachat, Esq., Managing Director | BDO USA

Robert D. Schachat is a Managing Director in BDO USA’s National Tax practice, focusing on all federal income tax aspects of real estate — REIT, partnership, LLC, and S corporation formations, acquisitions, like-kind exchanges, development, leases, financings, workouts, dispositions, and liquidations — with more than 40 years of real estate tax experience, and he regularly monitors federal legislative and regulatory activity in the real estate area.

• Education & Credentials

He earned his S.B. from the Massachusetts Institute of Technology, Phi Beta Kappa, his J.D. from Columbia Law School, and his LL.M. in Taxation from New York University School of Law.

• Recognition & Leadership

He is co-author, with Jim Lowy, of the CCH treatise Federal Taxation of REITs and UPREITs, chaired the NYU Like-Kind Exchange Tax Conference, and is recognized as one of the country’s leading real estate tax authorities.

• Professional Involvement

He has served as Chair of the Real Estate Committee of the ABA Tax Section, Vice Chair of the Real Estate Roundtable’s Tax Policy Advisory Committee, co-chair of its Cost Recovery Committee, and a member of the NYSBA Tax Section’s Executive Committee, and he continues to serve on the ABA Tax Section’s Partnerships and Real Estate Committees; he publishes and lectures widely, including as a regular panelist at the NYU Federal Real Estate and Partnerships Tax Conference.

• Experience

He joined BDO in 2021 after 23 years in the National Tax Real Estate Group of a Big Four accounting firm (EY) and 12 years as a partner in a Manhattan law firm practicing real estate taxation.

Glenn M. Johnson, Esq., Principal | EY

Glenn M. Johnson is a Principal in EY’s National Tax Department in Washington, DC, where he has spent his entire career since joining Ernst & Young in 1998, becoming one of the firm’s leading authorities on leasing and infrastructure taxation, including cost recovery and energy credit issues.

• Recognition & Leadership

He leads EY’s Infrastructure Tax Committee and serves on the firm’s Federal Income Tax Committee.

• Professional Involvement

He is the former Chair of the ABA Tax Section’s Capital Recovery and Leasing subcommittee and has been a member of the Equipment Leasing and Finance Association’s Federal Tax Committee for more than 13 years.

• Experience

He is a regular panelist at the NYU Federal Real Estate and Partnerships Tax Conference and this Institute, presenting annually on depreciation, amortization, and related cost recovery developments.

Larry J. Brant, Esq., Shareholder | Foster Garvey PC

Larry J. Brant is a Principal (Shareholder) at Foster Garvey and Chair of its Tax & Benefits practice group, assisting public and private companies, partnerships, and high-net-worth individuals with tax planning and advice, tax controversy, and business transactions, with deep experience in S corporations, Section 1031 exchanges, choice of entity, and entity tax classification.

• Education & Credentials

He earned his B.S. in Business Administration, cum laude, from Portland State University (1981), his J.D., cum laude, from Willamette University College of Law (1984), and his LL.M. in Taxation from the University of Florida College of Law (1987). He is admitted in Oregon and Washington and before the U.S. Tax Court.

• Recognition & Leadership

He received the Oregon State Bar Tax Section Award of Merit (2015) and the Portland Business Journal’s “Best of the Bar” Award in Taxation (2005), and has been a multiple-time JD Supra Readers’ Choice Top Author for Tax since 2019 as editor and author of the nationally recognized blog Larry’s Tax Law.

• Professional Involvement

He is a Fellow of the American College of Tax Counsel, a past Chair of the Oregon State Bar Taxation Section, longtime Chair of the Oregon Tax Institute, a member of the Portland Tax Forum Board of Directors since 2010, an Expert Contributor to Thomson Reuters Checkpoint Catalyst, and a former adjunct professor of corporate taxation at Lewis & Clark’s Northwestern School of Law.

• Experience

He speaks regularly at national, regional, and local tax institutes — including this Institute, the Florida Tax Institute, the NYU Tax Conferences in July, and the Northwest Federal Tax Conference — and serves on Foster Garvey’s board of directors.

Ronald A. Levitt, Esq., Shareholder | Dentons Sirote

Ronald A. Levitt is a Shareholder in Dentons Sirote’s Birmingham office, a member of its Tax practice group, and leader of the firm’s Conservation Easement team, advising closely held and family businesses on tax and business planning, succession planning, and federal and state tax controversy matters.

• Education & Credentials

He earned his B.S., cum laude (1979), M.B.A. (1983), and J.D. (1983) from the University of Alabama and his LL.M. in Taxation from the University of Florida (1984).

• Recognition & Leadership

Chambers USA ranks him Band 1 for Tax (Alabama); he was Best Lawyers’ Tax Law “Lawyer of the Year” in Birmingham (2012) and is co-author of the two-volume LexisNexis treatise Tax Planning for S Corporations with fellow Institute faculty member Stephen R. Looney.

• Professional Involvement

He is a Fellow and former Regent of the American College of Tax Counsel, has served as Council Director of the ABA Tax Section and Chair of its S Corporations Committee, is a former Chair of the Alabama State Bar’s Tax Section, a former President of the Birmingham Tax Forum and the Federal Tax Clinic, and taught Partnership Taxation at Cumberland School of Law and in Alabama’s LL.M. program.

• Experience

He has practiced with the firm (formerly Sirote & Permutt) since 2005, and his transactional and controversy practice spans S corporation planning, conservation easements, and closely held business representation — the subject matter of his annual Institute sessions with Mr. Looney.

Stephen R. Looney, Esq., Shareholder | Dean Mead

Stephen R. Looney is a Shareholder at Dean Mead in Orlando, where he counsels closely held businesses and their owners on S corporation and pass-through entity taxation, corporate transactions, and choice-of-entity planning, and he is one of the country’s most prolific authors and lecturers on S corporation issues.

• Recognition & Leadership

He was recognized as Best Lawyers’ “Lawyer of the Year” in Tax Law in Orlando and is co-author, with fellow Institute faculty member Ronald A. Levitt, of the two-volume LexisNexis treatise Tax Planning for S Corporations.

• Professional Involvement

He is a Fellow and Regent of the American College of Tax Counsel, a prior member of the Board of Trustees of the Southern Federal Tax Institute, and a frequent speaker for the ABA Tax Section’s S Corporations Committee, the Portland Tax Forum, and national tax conferences.

• Experience

His publications include extensively cited work on S corporation compensation reclassification risks, shareholder agreements, and due diligence in S corporation acquisitions, including co-authored articles in the Journal of Taxation.

Terence Floyd Cuff, Esq., Of Counsel | Loeb & Loeb

Terence F. “Terry” Cuff, Of Counsel at Loeb & Loeb in Los Angeles, has more than 44 years of experience in partnership taxation, real estate taxation, and the taxation of REITs; his clients include REITs, real estate investors, large energy companies, corporations with transactional tax problems, and financial institutions, and he is also known for the advanced use of Excel in tax and finance modeling.

• Education & Credentials

He earned his A.B. from the University of California at Santa Cruz (1974) and his J.D. from the University of Southern California’s Gould School of Law (1977), where he was Order of the Coif and a member of the Southern California Law Review, followed by his LL.M. in Taxation from New York University (1979). He previously served as a U.S. Marine Corps engineering and guided-missile officer.

• Recognition & Leadership

He is the author of the treatise Drafting and Understanding Partnership and LLC Allocation and Distribution Provisions (Thomson Reuters), has written several hundred articles on partnership and real estate taxation, and has been listed in The Best Lawyers in America since 1991, including as a Tax Law “Lawyer of the Year” (2026) honoree.

• Professional Involvement

He serves on the Board of Advisors of this Institute and the editorial boards of the Journal of Real Estate Taxation and Business Entities, is a former Chairman of the Los Angeles County Bar Association’s Taxation Section, and speaks frequently at national tax seminars.

• Experience

His practice centers on solving partnership and real estate tax problems, particularly the drafting of partnership and LLC agreements — the focus of his annual Institute presentations on partnership issues and agreements.

C. Wells Hall, III, Esq., Shareholder | Maynard Nexsen PC

C. Wells Hall, III practices in Maynard Nexsen’s Charlotte office, regularly handling transactions and tax planning involving pass-through entities — including M&A transactions where an S corporation or LLC is the target — along with federal, state, and multistate tax aspects of acquisitions, reorganizations, restructurings, private equity transactions, and related estate and gift planning, with particular depth in the finance, healthcare, and real estate sectors.

• Education & Credentials

He earned his B.S. from North Carolina State University (1970) and his J.D. from Duke University (1973).

• Recognition & Leadership

Chambers USA ranks him Band 1 for Tax (North Carolina), and he is recognized in The Best Lawyers in America for Tax Law and among North Carolina’s Legal Elite in Tax & Estate Planning.

• Professional Involvement

He serves as Secretary/Treasurer (2017-present) and former Regent (2013-2016) of the American College of Tax Counsel, is a Fellow of the American College of Trust and Estate Counsel (former North Carolina State Chair and Regent), chaired the National Association of State Bar Tax Sections (1990-1991) and the NC Bar Association’s Tax Section (1986-1988), chaired the joint subcommittee that drafted the 1999 Revised North Carolina LLC Act, and has served on the J. Nelson Young Tax Institute’s Board of Advisors since 1981.

• Experience

Over a five-decade career at leading Carolinas firms (including Nelson Mullins before joining Maynard Nexsen), he has been a columnist for the Journal of Passthrough Entities and an editorial board member of the Journal of Business Entities, and he is a fixture of the Institute’s closely held business program.

Aaron Esman, Esq., Member | Ziering & Esman

Aaron M. Esman is a founding Member of Ziering & Esman PLLC, a New York tax controversy boutique, representing individual and entity taxpayers before the IRS, the Department of Justice, and state and local taxing authorities in all stages of tax controversy — audits, appeals, and litigation — and advising on tax aspects of corporate transactions, M&A, compliance, and governance.

• Education & Credentials

He earned his J.D. from Emory University School of Law (2015), with a Transactional Law and Skills Certificate, and his LL.M. in Taxation from New York University School of Law (2016). He is admitted in New York, New Jersey, and the District of Columbia, and before the U.S. Supreme Court, the U.S. Tax Court, the Court of Federal Claims, and multiple federal district courts.

• Recognition & Leadership

He has been selected to the Super Lawyers New York Metro Rising Stars list every year since 2018 and to Best Lawyers’ “Ones to Watch in America” for Litigation & Controversy — Tax and Corporate Law (2024-present) and Tax Law (2026).

• Professional Involvement

He is active in the ABA Tax Section, serving as Chair of its Standards of Tax Practice Committee and Vice-Chair of the LGBTQ+ Lawyers in Tax Forum; he publishes in Bloomberg Tax, Law360, and the Tax Management Portfolio on topics including the partnership audit regime, and speaks regularly at the NYU Tax Controversy Forum and the New York Law School Tax Lawyering Workshop.

• Experience

Before co-founding Ziering & Esman in 2025 with Zhanna Ziering, he practiced tax controversy at leading New York firms, including Moore Tax Law Group and Kostelanetz-trained practices, building a docket spanning civil audits through sensitive examinations — the terrain of his Institute session on navigating tax issues in uncertain times.

Shaina Kamen, Esq., Partner | Holland & Knight

Shaina Kamen is a Partner in Holland & Knight’s Private Wealth Services Group — the largest private wealth practice in the United States — serving as general counsel to high-net-worth individuals and multigenerational families in New York and Florida, advising on all aspects of estate, gift, and generation-skipping transfer tax planning, business succession coordinated with estate planning, charitable legacy design, and digital asset planning.

• Education & Credentials

She earned her B.A. in International Affairs from The George Washington University, her J.D. from Syracuse University College of Law, and her LL.M. in Taxation from Georgetown University Law Center, where she worked on The Tax Lawyer. She is admitted in Florida and New York.

• Recognition & Leadership

She was elected a Fellow of the American College of Trust and Estate Counsel (ACTEC), named to Holland & Knight’s Rising Star Class of 2025, listed in The Best Lawyers in America for Trusts and Estates, and selected to Super Lawyers and Rising Stars lists across both Florida and New York.

• Professional Involvement

She is an adjunct professor in the University of Miami School of Law’s Graduate Program in Taxation and writes and speaks frequently on estate planning for high-net-worth families, including cryptocurrency and digital-asset planning for The Florida Bar’s ActionLine.

• Experience

She joined Holland & Knight in Miami in 2019 from Stroock & Stroock & Lavan in New York and was elevated to partner, building a bi-coastal Florida/New York private wealth practice — the perspective she brings to the Institute’s estate planning “hot topics” session.

Timothy P. Noonan, Esq., Partner | Hodgson Russ

Timothy P. Noonan is a Partner at Hodgson Russ and leader of its Tax Residency Practice, nationally regarded as one of the country’s foremost authorities on New York State and New York City personal income tax, residency, and sales tax; over 25 years he has handled more than 3,000 New York tax audits and over 100 cases in the Division of Tax Appeals, including the watershed 2014 Gaied residency victory in New York’s highest court.

• Education & Credentials

He earned his J.D. from the University at Buffalo School of Law (1999). [MISSING — undergraduate institution not confirmed in public sources]

• Recognition & Leadership

He is ranked in Chambers USA for State & Local Tax, was named Best Lawyers’ “Lawyer of the Year” for Tax Law (2024), authors “Noonan’s Notes,” the long-running monthly column in Tax Notes State, co-authored the CCH Residency and Allocation Audit Handbook and Contesting New York State Tax Assessments, and has published more than 400 pieces on state and local tax.

• Professional Involvement

He serves on the Advisory Board of Tax Notes State and the Hodgson Russ Board of Directors, and his commentary appears regularly in The Wall Street Journal, The New York Times, Bloomberg, and Forbes.

• Experience

Based in New York City and Buffalo, he leads multistate residency audits and litigation for high-net-worth individuals relocating among states — precisely the focus of his Institute session on income tax issues for individuals changing their state of residence.

Sharon L. Klein, Esq., President, Family Wealth, Eastern US Region | Wilmington Trust, N.A

Sharon L. Klein is Executive Vice President and President of Family Wealth for the Eastern U.S. Region at Wilmington Trust, N.A., overseeing the delivery of planning, trust, investment management, family governance and education, family office, and private banking services to ultra-high-net-worth clients, and she also heads Wilmington Trust’s National Matrimonial/Divorce Advisory Practice as a Certified Divorce Financial Analyst.

• Education & Credentials

She earned her B.A. and LL.B. from the University of New South Wales, Australia, and her LL.M. from the University of California, Berkeley School of Law (Boalt Hall).

• Recognition & Leadership

She has been included for multiple consecutive years in Chambers’ High Net Worth Guide for Wealth Managers (New York), was honored by the UJA-Federation of New York Lawyers Division (2018) for contributions to the Trusts & Estates community, and is a nationally recognized speaker and author quoted in The New York Times and The Wall Street Journal.

• Professional Involvement

A Fellow of the American College of Trust and Estate Counsel, she has chaired committees including ACTEC’s Estate and Gift Tax Committee and the New York City Bar’s Asset Protection Committee, and serves on nonprofit boards including the American Brain Foundation.

• Experience

She began her career as a trusts and estates attorney at Rosenman & Colin (now Katten), headed the Estate Advisement department at Fiduciary Trust Company International, and was Managing Director and Head of Wealth Advisory at Lazard Wealth Management before joining Wilmington Trust in 2013, rising from Tri-State Region President to her current Eastern Region role in 2018.

Yoshimi O. Smith, Esq., Co-Founding Partner | Beller Smith

Yoshimi O. Smith is a co-founding partner of Beller Smith, P.L., a trusts and estates boutique in Boca Raton, concentrating on estate and tax planning, estate and trust administration, business succession planning, and asset protection for high-net-worth individuals and families.

• Education & Credentials

She is a graduate of the State University of New York at Stony Brook and Hofstra University School of Law (J.D., 1998). She is admitted in New York and Florida and is AV-rated by Martindale-Hubbell.

• Recognition & Leadership

She is a Fellow of The American College of Trust and Estate Counsel and has been selected to Florida Super Lawyers for Estate Planning and Probate every year since 2013 (Rising Stars 2009-2012).

• Professional Involvement

She is deeply active in The Florida Bar’s Real Property, Probate and Trust Law Section — serving on its Executive Council and as co-vice chair of the Estate and Trust Tax Planning Committee and the Ad Hoc Fiduciary Licensing Committee, among other committees — chairs the Probate Committee of the South Palm Beach County Bar Association, and speaks and writes for PLI’s Annual Estate Planning Institute, the Florida Legal Education Association, and Estate Planning magazine.

• Experience

She began her career advising high-net-worth families at Rivkin Radler in New York, moved to Florida in 2005 to practice with Miller & O’Neill and then Duane Morris, and co-founded Beller Smith with Amy B. Beller in 2009.

James I. Dougherty, Esq., Partner | Dungey Dougherty PLLC

James I. Dougherty is a partner and co-founder of Dungey Dougherty PLLC in Greenwich, Connecticut, focusing on estate planning and administration for high-net-worth individuals, families, and family offices, and assisting executors and beneficiaries through probate, contested estates, trust litigation, tax, and post-mortem planning — continuing a family practice of law in Greenwich spanning four generations since 1930.

• Education & Credentials

He earned his B.A. in History and Policy from Carnegie Mellon University (2009) and his J.D. from William & Mary Law School (2012). He is admitted in Connecticut and New York.

• Recognition & Leadership

He is a Fellow of the American College of Trust and Estate Counsel (member of its Legal Education Committee and an ACTEC Dennis I. Belcher Young Leader), has been recognized in The Best Lawyers in America for Trusts and Estates since 2022 and as a Super Lawyers Rising Star since 2017, serves on the Trusts & Estates magazine Editorial Board, and co-authored the LexisNexis Practice Guide: Connecticut Probate and Estate Administration.

• Professional Involvement

He is Vice-Chair of the Connecticut Bar Association’s Estates & Probate Section, serves on the Connecticut Probate Court Rules Advisory Committee, was an ABA RPTE Trusts & Estates Fellow (2016-2018), and teaches as an adjunct professor of Trusts & Estates at the University of Connecticut School of Law and Estate & Gift Taxation at Quinnipiac University School of Law.

• Experience

Before co-founding the firm in 2021, he was a partner at Withers Bergman LLP, and he began his path in the Greenwich Probate Court — experience he brings to the Institute’s review of this year’s important estate planning developments.

John W. Porter, Esq., Senior Partner | Baker Botts

John W. Porter is a Senior Partner at Baker Botts in Houston and one of the nation’s leading tax controversy attorneys, maintaining a nationwide practice representing high-net-worth individuals and businesses in sophisticated federal estate, gift, and income tax controversies — audits, IRS appeals, and litigation — especially matters involving hard-to-value assets such as family limited partnership and LLC interests, along with a substantial fiduciary litigation practice.

• Education & Credentials

He earned his B.B.A. in Accounting from Texas A&M University (1982) and his J.D., cum laude, from Baylor Law School (1986), and he is Board Certified in Estate Planning and Probate Law by the Texas Board of Legal Specialization.

• Recognition & Leadership

Chambers interviewees call him “really the leading estate and gift tax litigator in the country”; he has served as lead counsel in many of the most significant published transfer tax decisions of the past twenty-five years — including Petter, Christiansen, McCord, and Hendrix (formula clauses), Bongard, Stone, and Schutt (Section 2036), Jelke, Dunn, and Kerr (built-in gains discounts), Steinberg (net-net gifts), and Anenberg — and obtained a $42 million estate tax refund after district court trial; he holds the NAEPC’s Distinguished Accredited Estate Planner award.

• Professional Involvement

He is a Fellow (and Regent) of the American College of Trust and Estate Counsel, a Fellow of the American College of Tax Counsel, former Chairman of ACTEC’s Tax Litigation and Controversy Committee, and a regular presenter at the Heckerling Institute, this Institute, and the Southern Federal Tax Institute.

• Experience

His four decades at Baker Botts have made his annual review of estate and gift tax audit and litigation developments — the Institute’s closing Sederbaum Memorial Lecture session — a national fixture.

DAY 1: SUNDAY, NOV. 15

10:55 a.m. Welcoming Remarks — Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY

CURRENT DEVELOPMENTS — Chair: Jennifer Acuña, Esq., Principal, Federal Tax Legislative and Regulatory Services, KPMG, Washington, DC

SESSION 1 – LEGISLATIVE UPDATE | Jennifer Acuña & Daniel J. Winnick | 11:00am – 12:00pm

A review of legislation enacted, considered and pending in the current congressional session. — Jennifer Acuña, Esq., Principal, Federal Tax Legislative and Regulatory Services, KPMG, Washington, DC; Daniel J. Winnick, Esq., Principal, International Tax, KPMG, Washington, DC

SESSION 2 – THE TREASURY AGENDA | US Department of the Treasury Representatives (invited) | 12:00pm – 12:30pm

A review of recently issued and pending Treasury guidance. — US Department of the Treasury Representatives will be invited to attend

12:30 p.m. – 12:45 p.m. | Refreshment Break

TAX CONTROVERSIES — Chair: Charles P. Rettig, Esq., Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Los Angeles, CA

SESSION 3 – IRS Operations – The Path Forward | Charles P. Rettig & Megan L. Brackney & Phillip Colasanto | 12:45pm – 2:15pm

The IRS is once again facing enormous challenges, from changing priorities to rescinded funding to hiring freezes. Practical advice “from the tax trenches” from a Former IRS Commissioner and highly experienced tax professionals on current and anticipated future IRS enforcement efforts impacting high-wealth individuals and their closely held entities, flow-thru entities. The panelists also discuss “hot topics” involving estate and gift tax issues, offshore activities, various IRS Compliance Campaigns targeting the use of business aircraft, issues regarding digital assets, Syndicated Conservation Easements, Microcaptive insurance arrangements, ERCs, Puerto Rico Act 60 and other current IRS priorities and initiatives. — Moderator: Charles P. Rettig, Esq., Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Los Angeles, CA; Megan L. Brackney, Esq., Partner, Kostelanetz, New York, NY; Phillip Colasanto, Esq., Partner, Charles Russell Speechlys, New York, NY

SESSION 4 – Pros, Cons and Ethical Considerations in Using Artificial Intelligence in Your Tax Practice (Ethics credit) | Frank Agostino & Joseph A. Ziegler (invited) & Sunshine Chow (invited) | 2:15pm – 3:15pm

How will AI impact your practice, what’s available now and what can we expect going forward? What to expect from IRS use of AI in its enforcement efforts? Ethical responsibilities under Circular 230 and otherwise associated with the use (abuse) of AI in your tax practice. Who’s Accountable When AI Gets It Wrong? — Moderator: Frank Agostino, Esq., Partner, Kostelanetz, Hackensack, NJ; Joseph A. Ziegler, Chief, Internal Consulting, Internal Revenue Service, Washington, DC (Invited); Sunshine Chow, CPA, CFE, Project Manager/Technical Data Agent, Office of Fraud Enforcement, Internal Revenue Service, Houston, TX (Invited)

3:15 p.m. – 3:30 p.m. | Refreshment Break

EXECUTIVE COMPENSATION & EMPLOYEE BENEFITS — Chair: Mary B. Hevener, Esq., Partner, The Wagner Law Group, New York, NY

SESSION 5 – Developments State & Local Payroll Tax Audits and Information Reporting | Mary B. Hevener | 3:30pm – 4:30pm

This presentation covers the recent expansion of state and local payroll tax audits, ranging from audits of both travelers to the states, and employees who have left the state, plus worker classification and withholding tax issues for all employees working in a state. The presentation includes detailed focus on ways to avoid some surprising problems that can arise, such as New York’s supplemental withholding rate (which is higher than the normal tax rate) or Washington State’s focus on leasing companies that hire temporary workers (even though the Federal “localization of work” rules would block the application of SUTA taxes to those workers), or the attempts by Philadelphia and New Jersey to tax nonqualified deferred compensation at the time of contribution, or the many states that did not increase their Form 1099 reporting threshold from $600 to $2,000. — Mary B. Hevener, Esq., Partner, The Wagner Law Group, New York, NY

SESSION 6 – Update on IRS Fringe Benefit Audit Initiatives & Recent OBBBA Guidance | Steven P. Johnson | 4:30pm – 5:35pm

This presentation discusses a new wave of IRS employment tax audits focused on employer-provided fixed indemnity benefit/wellness plans and implementing guidance from the IRS concerning the One Big Beautiful Bill Act’s qualified overtime deduction under IRC 225, employer contributions to Trump accounts under IRC 128, and employer tax credits for voluntary paid family and medical leave under IRC 45S. Topics covered include an overview of the underlying legal standards, new developments since enactment of the OBBBA, and remaining open questions that tax practitioners and employers are expected to confront during the 2026 Form W-2 filing season. — Steven P. Johnson, Esq., Partner, Morgan, Lewis & Bockius, Washington, DC.

DAY 2: MONDAY, NOV. 16

8:25 a.m. Introductory Remarks — Kathleen Costello, CMP

INTERNATIONAL TAX — Chair: William B. Sherman, Esq., Partner, Holland & Knight, Fort Lauderdale, FL

SESSION 7 – INBOUND PLANNING AND HOT TOPICS | Joshua Odintz & Michael J. Miller | 8:30am – 10:15am

This panel addresses current developments and other hot topics relating to the “inbound” taxation of foreign taxpayers. The topics discussed include regulatory guidance on the exemption for foreign sovereigns; whether and how to inbound a foreign-headquartered company; planning for the funding of US operations (e.g., “implicit support” issues); and treaty guidance pertaining to the US-Croatia Treaty and the availability of certain treaty benefits for income earned by hybrid and reverse hybrid entities. — Joshua Odintz, Esq., Partner, Holland & Knight, Washington, DC; Michael J. Miller, Esq., Partner, Roberts & Holland, New York, NY

10:15 a.m. – 10:30 a.m. | Refreshment Break

SESSION 8 – Fundamentals of Outbound Planning | Joseph M. Calianno & Sean Dokko | 10:30am – 12:15pm

This panel focuses on cross-border issues when US persons invest abroad through different organizational structures. As part of this presentation, the panel explores different international tax rules that apply when a US person invests in a foreign corporation, including the controlled foreign corporation rules and passive foreign investment company rules. In conjunction with these rules, the panel explores different rules that can apply relating to a US person’s outbound transfer of property to a foreign corporation. Additionally, this panel explores some of the rules and issues that must be considered when a US person decides to operate abroad through a fiscally transparent entity, such as a partnership or disregarded entity. Finally, this panel discusses some of the informational reporting rules associated with making cross-border investments. — Joseph M. Calianno, JD, LLM, MBA, CPA, Managing Director; National Tax Practice, Andersen Tax, Washington, DC; Sean Dokko, JD, LLM, Managing Director; National Tax Practice, Andersen Tax, New York, NY

12:15 p.m. – 1:30 p.m. | Lunch Recess

SESSION 9 – FIXING THE PAST: ETHICAL AND OTHER CONSIDERATIONS IN ADDRESSING ERRORS, OMISSIONS, AND FAILURES TO FILE (Ethics credit) | Barbara T. Kaplan & Scott D. Michel & Alyssa Maloof Whatley | 1:30pm – 2:45pm

For clients who have willfully failed to comply with tax or tax-related obligations relating to foreign income or foreign assets, submitting a voluntary disclosure may be a means to resolve non-compliance and limit exposure to criminal prosecution. This panel discusses the ethical responsibilities for tax professionals, including maintaining confidentiality, avoiding conflicts of interest, and the overarching rules of Circular 230, that come into play when advising clients about the pros and cons of voluntary disclosures and other corrective options to consider when addressing omissions and errors in complying with tax obligations. — Barbara T. Kaplan, Esq., Shareholder, Greenberg Traurig, New York, NY; Scott D. Michel, Esq., Member, Caplin and Drysdale, Chartered, Washington, DC; Alyssa Maloof Whatley, Esq., Director, Frost Law, Atlanta, GA

2:45 p.m. – 3:00 p.m. | Refreshment Break

SESSION 10 – INTERNATIONAL MERGERS AND ACQUISITIONS: US TAX CONSIDERATIONS AND PLANNING TECHNIQUES | William S. Dixon & Sam K. Kaywood & William B. Sherman | 3:00pm – 5:00pm

The OBBB made significant changes to the CFC rules and other rules that affect cross-border mergers and acquisitions. This session covers fundamentals of US tax considerations for taxable and tax-free stock acquisitions of foreign companies, CFC issues including recently issued pro rata share regulations, acquisitions of US companies, planning for the use of holding companies, and inversion transactions. — William S. Dixon, Esq., Managing Director, Mergers and Acquisitions, Citigroup Global Markets, New York, NY; Sam K. Kaywood, Esq., Senior Counsel, Alston & Bird, Atlanta, GA; William B. Sherman, Esq., Partner, Holland & Knight, Fort Lauderdale, FL

5:00 p.m. | Recess

SESSION 11 – EVENING SESSION: FUNDAMENTALS OF CORPORATE TAX | David M. Rievman & Alexander Lee | 5:15pm – 6:55pm

This fast paced and lively session prepares audiences for the day ahead, with an overview of corporate tax topics and transaction structuring considerations, including recent developments and an emphasis on key elements of value for buyers and sellers in negotiating an M&A deal. — David M. Rievman, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom, New York, NY; Alexander Lee, Esq., Partner, Cooley, Los Angeles, CA.

DAY 3: TUESDAY, NOV. 17

8:25 a.m. Introductory Remarks — Kathleen Costello, CMP

CORPORATE TAX — Chair: David M. Rievman, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom, New York, NY

SESSION 12 – Taxable Separations | Trevor R. Allen & Joe Soltis | 8:30am – 9:45am

This panel discusses key tax issues when breaking up a company as part of a sale. While taxable separations get a lot of attention, there are significant planning issues involved in tax free separations and carve outs of “unwanted” assets, including valuation issues, tax treatment of the shareholders and the ins and outs, pros and cons of Section 336e elections. — Trevor R. Allen, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom, New York, NY; Joe Soltis, Esq., Partner, Freshfields, New York, NY

9:45 a.m. – 10:00 a.m. | Refreshment Break

SESSION 13 – Structuring and Characterizing Corporate Transactions | Karen Gilbreath Sowell & Marc Countryman & Jodi J. Schwartz | 10:00am – 11:00am

This panel examines the Code, regulations, IRS administrative positions and common law authorities that must be considered to successfully secure the desired treatment of transactions. Topics include identifying and applying key step transaction authorities addressing circular flows, integration, transitory ownership, transitory entities and their limitations, as well as substance over form authorities that need to be considered when analyzing whether a transaction may be subject to recharacterization or resequencing. — Karen Gilbreath Sowell, Esq., Principal, EY, Washington, DC; Marc Countryman, Esq., Partner, EY, San Francisco, CA; Jodi J. Schwartz, Esq., Partner, Wachtell, Lipton, Rosen, and Katz, New York, NY

SESSION 14 – Update on Tax Controversy and Lessons for Corporate Transaction Planning | Jameson S. Lloyd & Isaac J. Wheeler | 11:00am – 12:15pm

The presenters provide an update on significant developments in tax controversies in recent years, and lessons and implications for corporate tax planning practitioners. — Jameson S. Lloyd, Esq., Partner, Sullivan & Cromwell, New York, NY; Isaac J. Wheeler, Esq., Partner, Sullivan & Cromwell, New York, NY

12:15 p.m. – 1:30 p.m. | Lunch Recess

SESSION 15 – Derivative or Reductive? The Taxation of Prediction Markets and Event Contracts: New Bets, Old Tax Boxes | Lorenz Haselberger & Vadim Novak | 1:30pm – 2:30pm

This panel examines whether familiar derivatives tax rules fit event contracts, and explores the federal income tax characterization and treatment of prediction market hedging transactions, Section 1256 contracts, non-1256 derivatives, and wagering transactions. — Lorenz Haselberger, Esq., Partner, A&O Shearman, New York, NY; Vadim Novak, Esq., Partner, Fried, Frank, Harris, Shriver & Jacobson, New York, NY

2:30 p.m. – 2:45 p.m. | Refreshment Break

SESSION 16 – Section 1202 Update | Myra A. Sutanto Shen & Timothy Shapiro | 2:45pm – 3:45pm

This presentation discusses the benefits of Qualified Small Business Stock, with an emphasis on planning opportunities, open questions, and new developments in this fast-developing area. — Myra A. Sutanto Shen, Esq., Partner, Wilson Sonsini, Palo Alto, CA; Timothy Shapiro, Esq., Partner, Cooley, Palo Alto, CA

SESSION 17 – Hot Topics in Corporate Taxation | Alexander Lee & Eric Solomon & Lewis R. Steinberg | 3:45pm – 5:00pm

Always an Institute favorite, this fast-paced panel discusses interesting developments in corporate income taxation and deal structuring over the past year. — Alexander Lee, Esq., Partner, Cooley, Los Angeles, CA; Eric Solomon, Esq., Partner, Ivins, Phillips & Barker, Washington, DC; Lewis R. Steinberg, Esq., New York, NY

5:00 p.m. | Recess

SESSION 18 – EVENING SESSION: FUNDAMENTALS OF PARTNERSHIP AND REAL ESTATE TAXATION | Andrea M. Whiteway | 5:15pm – 6:55pm

This session provides useful background that is helpful for attendees who do not have extensive experience in the taxation of partnerships and real estate. — Andrea M. Whiteway, Esq., Principal, EY, Washington, DC.

DAY 4: WEDNESDAY, NOV. 18

8:25 a.m. Introductory Remarks — Kathleen Costello, CMP

PARTNERSHIPS, LLCs, AND REAL ESTATE — Chair: Andrea M. Whiteway, Esq., Principal, EY, Washington, DC

SESSION 19 – HOT TOPICS IN PARTNERSHIP AND REAL ESTATE TAXATION: LEGISLATIVE AND REGULATORY DEVELOPMENTS | Kevin Salinger & Andrea M. Whiteway | 8:30am – 9:15am

An overview of recent and pending developments in partnership and real estate taxation from the government perspective. An opportunity to hear first-hand the views of government officials about what’s important, why it’s important, and what the government is doing about it. — Kevin Salinger, Esq., Acting Assistant Secretary (Tax Policy), US Department of the Treasury and Acting Chief Counsel, Internal Revenue Service, Washington, DC; Andrea M. Whiteway, Esq., Principal, EY, Washington, DC

SESSION 20 – STRUCTURING FOR INBOUND INVESTMENT IN US REAL ESTATE | Adam S. Feuerstein & Jonathan Talansky | 9:15am – 10:15am

This presentation discusses structures to own US real estate in a tax efficient manner, special concerns when a non-US person becomes a partner in a partnership or investment fund owning US real estate or mortgage debt and use of related party debt to reduce US tax exposure. — Adam S. Feuerstein, Esq., Principal, PwC US Tax, Washington, DC; Jonathan Talansky, Esq., Partner, King & Spalding, New York, NY

10:15 a.m. – 10:30 a.m. | Refreshment Break

SESSION 21 – Section 1202 and Partnerships: Allocating, Preserving, and Monetizing QSBS Benefits | Ryan Dobens | 10:30am – 11:30am

Explore how partnership ownership affects a partner’s ability to benefit from a § 1202(a) gain exclusion. This session covers common structuring considerations involving QSBS and partnerships, including both traps for the unwary and possible ways to maximize a § 1202(a) gain exclusion while the stock is held within the Subchapter K framework. — Ryan Dobens, Esq., Director, KBF Advisory, Washington, DC

SESSION 22 – Allocations In Lieu of Fees: Fee Waiver Planning Techniques in Private Funds & Beyond | Amanda H. Nussbaum & Arash Lotfi | 11:30am – 12:30pm

This presentation addresses the proposed disguised payment for services regulations under Section 707(a)(2)(A) of the US Internal Revenue Code, as well as general profits interest guidance. Topics discussed include: the grant of profits interests by a partnership for the provision of past and future services to the partnership or its affiliates in the context of these regulations and guidance and certain related market practices, including the ways in which these practices differ across industries (e.g., private equity, real estate development). — Amanda H. Nussbaum, Esq., Partner, Proskauer Rose, New York, NY; Arash Lotfi, Esq., Associate, Latham & Watkins, Washington, DC

12:30 p.m. – 1:30 p.m. | Lunch Recess

SESSION 23 – HOT TOPICS IN PARTNERSHIP BBA AUDITS | Sheri A. Dillon & George A. Hani | 1:30pm – 2:30pm

IRS audits under the BBA partnership audit rules are well underway. This panel discusses how the BBA rules are being implemented by the IRS, considerations associated with whether to make a Section 6226 push out election, and administrative adjustment requests. — Sheri A. Dillon, Esq., Member, Miller & Chevalier, Chartered, Washington, DC; George A. Hani, Esq., Member, Miller & Chevalier, Chartered, Washington, DC

SESSION 24 – QUALIFIED OPPORTUNITY FUNDS: NEW AND EXPANDED OPPORTUNITIES | James O. Lang & Sanford C. Presant | 2:30pm – 3:35pm

This panel discusses current tax planning for investments in qualified opportunity funds as well as explores the changes made to the program under the new qualified opportunity fund legislation and recently issued transition relief. — James O. Lang, Esq., Shareholder, Greenberg Traurig, Tampa, FL; Sanford C. Presant, Esq., Shareholder, Greenberg Traurig, Los Angeles, CA

3:35 p.m. – 3:45 p.m. | Refreshment Break

SESSION 25 – HOT LIKE-KIND EXCHANGE ISSUES | Robert D. Schachat & Glenn M. Johnson | 3:45pm – 5:00pm

Related party exchanges; build to suits, reverse exchanges and parking arrangements within and outside the safe harbor; exchanges involving partnerships and trusts; exchanges of property into and out of foreclosure; recent developments on what constitutes “like kind”; other current issues including legislative outlook. — Robert D. Schachat, Esq., Managing Director, BDO USA, Washington, DC; Glenn M. Johnson, Esq., Principal, EY, Washington, DC.

DAY 5: THURSDAY, NOV. 19

8:25 a.m. Introductory Remarks — Kathleen Costello, CMP

CLOSELY-HELD BUSINESSES — Chair: Jerald David August, Esq., Partner, August Tax Law, PC, Philadelphia, PA

SESSION 26 – Another Look at the Single Class of Stock Requirement Under Subchapter S | Larry J. Brant | 8:30am – 9:40am

The single-class-of-stock rules are far more intricate than they appear on the surface. The basic rule is that an S corporation can only have one class of stock. For this purpose, voting stock and non-voting stock are permitted. The key to having just one class of stock is generally to make sure that all shares have identical rights to distribution and liquidation proceeds. While seemingly simple in concept, it can be extremely complex in application. The mystery that often comes into play is whether shares have identical rights to distribution and liquidation proceeds. The discussion explores this issue in detail, including how to identify the problem, as well as a possible simple remedy to cure the problem if it arises. — Larry J. Brant, Esq., Shareholder, Foster Garvey PC, Portland. OR

9:40 a.m. – 9:50 a.m. | Refreshment Break

SESSION 27 – S Corporations in Court: What’s Different and What’s the Same | Ronald A. Levitt & Stephen R. Looney | 9:50am – 11:00am

S corporation litigation can raise distinct procedural and substantive challenges affecting strategy and outcomes. This panel examines the interaction between entity-level determinations and shareholder-level issues, as well as the impact of the Bipartisan Budget Act of 2015 (BBA) in tiered structures. Panelists address frequently litigated issues—such as reasonable compensation, basis (including debt basis), eligibility, and built-in gains tax—and challenges that frequently arise, such as substantiation and penalties. The discussion also highlights settlement dynamics unique to S corporations, including coordinating entity- and shareholder-level outcomes and managing inconsistencies among shareholders. — Ronald A. Levitt, Esq., Shareholder, Dentons Sirote, Birmingham. AL; Stephen R. Looney, Esq., Shareholder, Dean Mead, Orlando, FL

SESSION 28 – ATTORNEY-CLIENT AND ACCOUNTANT-CLIENT Privileges AND Work Product IMPACTS FROM USE OF ai “TOOLS” (Ethics credit) | Jerald David August & Terence Floyd Cuff | 11:00am – 12:40pm

The use of AI Tools by lawyers, accountants and clients engaged in legal and tax compliance matters, including in-house counsel, will soon be tested by informal and formal discovery requests by tax and other governmental agencies as well as private parties. In U.S. v. Heppner, 820 F.Supp. 3d 292 (2026), the Federal District Court for the Southern District of New York held, in a case of first impression, defendant’s use of AI communications in connection with pending criminal investigation were not protected by the attorney-client privilege and were further not protected by work product doctrine. The panelists introduce the AI tools that are used in tax practice and then apply the long-standing law on privileged communications and the work product doctrine to the AI phenomenon of privilege and work product. Emphasis is on public accountants and legal counsel to privately owned business. This panel is intended to qualify for ethics credit. — Jerald David August, Esq., Partner, August Tax Law, PC, Philadelphia, PA; Terence Floyd Cuff, Esq., Of Counsel, Loeb & Loeb, Los Angeles, CA

12:40 p.m. – 1:45 p.m. | Lunch Recess

SESSION 29 – TAX ASPECTS OF DIVORCE OF PARTNERS IN PARTNERSHIPS | Terence Floyd Cuff | 1:45pm – 3:00pm

This presentation highlights the important tax aspects of divorce and living together relationships. Particular emphasis focuses on complex tax involved when the marital property or relationship property is a partnership interest. — Terence Floyd Cuff, Esq., Of Counsel, Loeb & Loeb, Los Angeles, CA

3:00 p.m. – 3:10 p.m. | Refreshment Break

SESSION 30 – MERGERS AND ACQUISITIONS OF CLOSELY-HELD S AND C CORPORATIONS IN PRIVATE EQUITY, UP-C, AND DOMESTIC AND CROSS BORDER SPAC TRANSACTIONS | Jerald David August & C. Wells Hall, Ill | 3:10pm – 5:00pm

This presentation reviews the general patterns where a privately owned company is acquired by another privately owned company in either an all stock, all asset or stock sale treated as a “deemed asset sale” under Sections 338 or 336(e). This discussion focuses on the tax outcomes to the buyer and the seller and important characterization and timing issues. Use of equity rollovers and other contingent consideration methods are discussed as well as private equity acquisitions of US based target companies. Discussion also addresses the benefits for the Section 1202 gain exclusion provisions for qualified small business stock, as further enhanced by the OBBBA legislation. — Jerald David August, Esq., Partner, August Tax Law, PC, Philadelphia, PA; C. Wells Hall, Ill, Esq., Shareholder. Maynard Nexsen PC, Charlotte. NC

5:00 p.m. | Recess

SESSION 31 – EVENING SESSION: Ethical Issues for Tax Practitioners: Good Tax Planning, Aggressive Tax Advice or Criminal Tax Evasion (Ethics credit) | Bryan C. Skarlatos & Aaron Esman | 5:15pm – 6:55pm

Tax practitioners are governed by a host of rules and regulations, from Circular 230, to IRC 6694, to the Statements on Standards for Tax Services, to the criminal provisions of the Internal Revenue Code. And now practitioners have to grapple with how Artificial Intelligence affects their ethical, legal and practical obligations. The real question is how practitioners can navigate all these standards and issues in everyday practice. For example, when can you tell a client it is okay to take a deduction or report income as capital gain, and does a quick AI search suffice? Do you have to audit a client’s records, or can you just rely on what the client tells you, and can you rely on a client’s AI generated memo? What do you do when a client tells you she made a mistake on her tax return? This panel of expert practitioners addresses these and other thorny ethical and practical issues that arise in everyday tax practice using real-world hypothetical examples that incorporate AI. — Chair: Bryan C. Skarlatos, Esq., Partner, Kostelanetz, New York, NY; Aaron Esman, Esq., Member, Ziering & Esman, New York, NY.

DAY 6: FRIDAY, NOV. 20

8:25 a.m. Introductory Remarks — Kathleen Costello, CMP

TRUSTS & ESTATES — Chair: Sanford J. Schlesinger, Esq., Founding Partner, Schlesinger Lazetera & Auchincloss, New York, NY

SESSION 32 – Current Developments in Estate Planning and Taxation | Shaina Kamen | 8:30am – 9:30am
This session discusses recent tax and non-tax developments impacting trusts & estates professionals, with an emphasis on recent legislative updates, decisions of interest, and regulatory guidance. — Shaina Kamen, Esq., Partner, Holland & Knight, Miami, FL

SESSION 33 – STATE WEALTH TAX AND RELATED ISSUES | Timothy P. Noonan | 9:30am – 10:30am

This presentation covers the outcome of California’s Proposition 40, the ballot initiative that would impose a one-time 5% tax on billionaires’ accumulated wealth, and examines whether other states are likely to pursue similar wealth tax measures in light of the vote. It also provides an update on recent developments in the state residency area. — Timothy P. Noonan, Esq., Partner, Hodgson Russ, New York, NY

10:30 a.m. – 10:45 a.m. | Refreshment Break

SESSION 34 – The State of the States: Latest Key Planning Developments Across the US | Sharon L. Klein | 10:45am – 12:00pm

Learn about the most important state-level recent developments, trends and estate planning ideas, including latest legislative developments, case law updates, estate, gift and tax law changes, how AI is redefining publicity rights, planning and valuation issues and other breaking state-level developments. — Sharon L. Klein, Esq., President, Family Wealth, Eastern US Region, Wilmington Trust, NA, New York, NY

12:00 p.m. – 1:15 p.m. | Lunch Recess

SESSION 35 – The Future of Trusts and Estates: AI, Innovation & Ethical Concerns (Ethics credit) | Yoshimi O. Smith | 1:15pm – 2:15pm

This presentation explores the evolving role of generative AI in trusts and estates practice, including how professionals can leverage AI to enhance efficiency, research, drafting, and client service. The program provides a comprehensive examination of the ethical concerns that may arise from AI use and discusses practical procedures for reducing risks. Attendees learn about the importance of effective prompt development and how thoughtful prompting can improve the quality, reliability, and usefulness of AI-generated results. The program also examines the IRS’s use of AI and the IRS Alert regarding Circular 230 and AI use by tax professionals. — Yoshimi O. Smith, Esq., Co-Founding Partner, Beller Smith, PL, Boca Raton, FL

2:15 p.m. – 2:30 p.m. | Refreshment Break

SESSION 36 – PONDERING PORTABILITY: PRACTICAL CONSIDERATIONS DURING PLANNING AND ADMINISTRATION | James I. Dougherty | 2:30pm – 3:30pm

This presentation takes a deep dive into portability – a seemingly simple topic that, in fact, has its own complexities that can trip up the unwary practitioner. This talk provides an overview of the essential and more nuanced issues at play with portability, one of few techniques providing wide benefit to a large cohort of planning clients. — James I. Dougherty, Esq.., Partner, Dungey Dougherty PLLC, Greenwich, CT and New York, NY

SESSION 37 – THE ARTHUR D. SEDERBAUM MEMORIAL LECTURE — Family Limited Partnerships and other Closely-Held Entities – The Continuing Saga | John W. Porter & Sanford J. Schlesinger | 3:30pm – 4:30pm

This discussion addresses current issues and trends in the transfer tax controversy arena involving family limited partnerships and other closely-held entities at the audit level, IRS Appeals, and in litigation. It includes issues related to the valuation and transfer of interests in closely-held entities, the use of formula clauses, Section 2036, split-dollar life insurance, valuation of promissory notes, GRAT audits, adequate disclosure, recent caselaw, positions taken by the IRS and practical ways to address them at the planning level. — John W. Porter, Esq., Senior Partner, Baker Botts, Houston, TX; Sanford J. Schlesinger, Esq., Founding Partner, Schlesinger Lazetera & Auchincloss, New York, NY