Federal Real Estate and Partnerships Tax Conference 2026 (presented by NYU School of Professional Studies)

Kevin Salinger, Esq., Deputy Assistant Secretary| U.S. Department of the Treasury

Kevin Salinger is the Deputy Assistant Secretary for Tax Policy at the U.S. Department of the Treasury, a role to which he was appointed in April 2025 under Secretary Scott Bessent. In this capacity, he serves as principal deputy to the Assistant Secretary for Tax Policy, overseeing the Office of Tax Policy’s legal counsels, advising on federal tax policy, legislation, regulations, and administrative guidance, and ensuring Treasury’s priorities are reflected in the development of tax regulations and guidance. He also represents the Department on significant tax policy matters and currently serves as Acting Assistant Secretary for Tax Policy. Prior to joining Treasury, Mr. Salinger spent more than ten years at Jefferies, where he was Managing Director and Head of Tax Counsel & Advisory, advising the firm’s global investment banking and capital markets businesses on a wide range of domestic and international tax matters with a focus on financial services and long-term tax planning. He also served as Vice President of the Wall Street Tax Association. He began his legal career as a tax associate at Sullivan & Cromwell LLP, advising clients on financial products, mergers and acquisitions, and cross-border tax planning. He holds a J.D. from Harvard Law School and a B.A. from the University of California, Berkeley.

• Education & Credentials

Mr. Salinger holds a Bachelor of Arts from the University of California, Berkeley, and a Juris Doctor from Harvard Law School. He began his legal career at Sullivan & Cromwell LLP before spending over a decade at Jefferies as Managing Director and Head of Tax Counsel & Advisory. He also served as Vice President of the Wall Street Tax Association, reflecting sustained engagement with the financial industry’s tax policy community.

• Recognition & Leadership

Mr. Salinger’s appointment as Deputy Assistant Secretary for Tax Policy — and his role as Acting Assistant Secretary for Tax Policy — represent recognition at the highest levels of the Treasury Department. As principal deputy to the Assistant Secretary, he oversees a team of over 100 staff responsible for developing and implementing federal tax policies and programs. His decade at Jefferies advising global investment banking and capital markets on complex domestic and international tax matters, combined with his early career at Sullivan & Cromwell, reflect a practitioner whose credentials match the scope of one of the most consequential tax policy positions in the federal government.

• Professional Involvement

Mr. Salinger has been active in industry tax policy discussions throughout his career, working closely with trade associations, law firms, and government stakeholders on tax regulation. At the Wall Street Tax Association, where he served as Vice President, he contributed to the industry’s engagement with Treasury and the IRS on financial products and capital markets tax issues. His current role places him at the center of domestic tax regulation and guidance development across all major areas of federal tax policy.

• Experience

Kevin Salinger’s career traces a path from Harvard Law through Sullivan & Cromwell’s tax group, over a decade at Jefferies advising some of the world’s largest investment banking and capital markets operations, and now to one of the most senior positions in the U.S. Treasury’s tax policy apparatus. His private sector experience in financial products, M&A, and cross-border tax planning gives him a sophisticated understanding of how tax regulations interact with real-world transactions — a perspective that directly informs his current role overseeing the development of federal tax policy and guidance.

Steven R. Schneider, Esq., Partner | Hogan Lovells

Steven R. Schneider is a Partner at Hogan Lovells in Washington, DC, where he focuses on transactional and tax policy matters primarily in the areas of partnerships, limited liability companies, REITs, and energy transition. He is a nationally recognized tax lawyer with significant experience in mergers and acquisitions, private equity and real estate funds, qualified opportunity zone funds, data centers, cross-border tax, REITs, bioscience, international investors (including sovereigns), and S corporations. He started his career as a lawyer in the IRS’s national office and has had many years of national-level law firm and Big Four accounting firm experience, including prior roles at Stroock & Stroock & Lavan, Baker & McKenzie, and Goulston & Storrs. He previously chaired the ABA Partnership Tax Committee and has taught a course on drafting partnership and LLC agreements at Georgetown University Law Center since 2005. He holds a B.S. in Accounting from Bryant College, a J.D. from Washington University in St. Louis School of Law, and an LL.M. in Tax from Georgetown University Law Center.

• Education & Credentials

Mr. Schneider holds a Bachelor of Science in Accounting from Bryant College, a Juris Doctor from Washington University in St. Louis School of Law, and an LL.M. in Taxation from Georgetown University Law Center — where he has also taught an advanced course on drafting partnership and LLC agreements since 2005, making him one of the longest-tenured adjunct instructors in Georgetown’s graduate tax program. He began his career as a lawyer in the IRS’s national office, giving him a foundational government-side perspective that continues to inform his transactional and tax policy work.

• Recognition & Leadership

Mr. Schneider is a Lawdragon honoree and a nationally recognized authority on partnership tax, energy transition, and transactional tax matters. He has previously chaired the ABA Tax Section’s Partnership Tax Committee and is a regular speaker at national tax venues. His 20-plus-year Georgetown teaching appointment reflects the profession’s recognition of his technical depth and his ability to translate complex partnership tax concepts into practical, classroom-ready frameworks. His clients include some of the largest energy, infrastructure, real estate, and private equity organizations in the country.

• Professional Involvement

Mr. Schneider is the former chair of the ABA Tax Section’s Partnership Tax Committee and remains actively engaged in the partnership tax community through national conferences, publications, and his Georgetown teaching role. He is a regular speaker at the NYU Institute on Federal Taxation, the ABA Tax Section Mid-Year and May Tax Meetings, and energy and real estate tax conferences. He co-taught a course on energy taxation at Georgetown in 2025, reflecting his expanded focus on the tax aspects of the energy transition.

• Experience

Steve Schneider’s career combines the government-side foundation of his IRS national office training with nearly three decades of Big Four and major law firm transactional tax practice — a combination that makes him one of Washington’s most respected partnership and real estate tax advisors. His clients span the energy transition, real estate investment, private equity, and cross-border investment landscapes, and his work on data centers, qualified opportunity zones, REITs, and energy tax credits reflects an ability to apply deep technical expertise to the most current and commercially significant areas of the tax code. His Georgetown teaching career and his ABA committee chairmanship extend his contributions beyond his own clients to the entire partnership tax profession.

Andrea M. Whiteway, Esq., Principal, National Tax Department | Ernst & Young LLP

Andrea M. Whiteway is a Principal in the National Tax Department of Ernst & Young LLP, based in Washington, DC, where she focuses on sophisticated tax planning for partnerships, REITs, and real estate transactions. She has substantial experience in the dispositions and acquisitions of real estate and operating businesses, complex partnership transactions, REIT tax status and structured dispositions involving REITs, corporate acquisitions and mergers, structuring private REITs, and forward and reverse like-kind exchanges. She co-chairs the NYU School of Professional Studies Federal Real Estate and Partnerships Tax Conference alongside Paul Wilner, an annual gathering she has co-led for many years. She was the first woman to serve as Chair of the Real Estate Committee of the ABA Section of Taxation and has served as Chair of the Federal Taxation of Real Estate Committee of the ABA Section of Real Property, Trusts and Estates. She is an ACTC Fellow and a Legal 500 and Chambers USA-ranked leader. Prior to EY, she was a principal at McDermott Will & Emery, a partner at Arnold & Porter, and held tax roles at Steptoe & Johnson, Miles & Stockbridge, and Arthur Andersen.

• Education & Credentials

Ms. Whiteway’s academic credentials are supplemented by a career-long commitment to the tax profession’s leadership. She was the first woman to chair the Real Estate Committee of the ABA Section of Taxation and is an elected Fellow of the American College of Tax Counsel. She has been listed in Best Lawyers in America in Tax Law across multiple consecutive editions, recognized by Chambers USA and Legal 500 as a leader in her field, and named by Washingtonian Magazine as one of the top lawyers in Washington, DC. She is co-chair of the NYU Federal Real Estate and Partnerships Tax Conference, one of the most prestigious annual gatherings of real estate tax practitioners in the country.

• Recognition & Leadership

Ms. Whiteway is an ACTC Fellow, a Best Lawyers in America selectee in Tax Law (2008 to present), a Chambers USA leader, a Legal 500 recommended lawyer, and a Washingtonian Magazine top lawyer. She was the first woman to chair the ABA Tax Section’s Real Estate Committee — a historic distinction — and serves as Chair of the Federal Taxation of Real Estate Committee of the ABA Section of Real Property, Trusts and Estates. Her co-chair role at the NYU Federal Real Estate and Partnerships Tax Conference reflects the deepest possible recognition from the profession she has helped define over multiple decades.

• Professional Involvement

Ms. Whiteway is co-chair of the NYU School of Professional Studies Federal Real Estate and Partnerships Tax Conference, a member of the ABA Section of Taxation Real Property Committee, and Chair of the Federal Taxation of Real Estate Committee of the ABA Section of Real Property, Trusts and Estates. She is a former DC Bar Tax Section Committee Chair for Passthroughs and Real Estate and has served on the DC Bar Tax Section Steering Committee. She speaks regularly at the NYU Federal Real Estate and Partnerships Tax Conference, the AICPA Real Estate Conference, PLI Tax Strategies, and other leading real estate and partnership tax forums.

• Experience

Andrea Whiteway has spent her career at the intersection of real estate, REIT, and partnership tax — building a practice at Arthur Andersen, Steptoe & Johnson, Miles & Stockbridge, Arnold & Porter, McDermott Will & Emery, and now EY that spans some of the largest and most complex real estate transactions in the country. Her technical depth in REIT structuring, private equity real estate fund formation, like-kind exchanges, complex partnership debt allocation, and cross-border real estate investment, combined with her first-woman-to-chair status at the ABA Tax Section Real Estate Committee, her ACTC fellowship, and her NYU Conference co-chairmanship, collectively define a career of exceptional leadership in one of tax law’s most demanding and consequential specialty areas.

Paul H. Wilner, CPA, Advisor | Grossberg Company LLP

Paul H. Wilner is an Advisor at Grossberg Company LLP in Bethesda, Maryland, where he focuses on federal income tax matters involving troubled business workouts and complex real estate, partnership, REIT, and business transactions. He recently retired as Managing Partner and Lead Tax Partner of the firm and now serves in an advisory capacity through his professional corporation. For many years, he has served as co-chair of the NYU School of Professional Studies Federal Real Estate and Partnerships Tax Conference alongside Andrea Whiteway of EY — one of the most respected annual forums for real estate and partnership tax professionals in the country. He has served as Chair of the AICPA Partnership Technical Resource Panel, Chair of the AICPA’s annual National Real Estate Tax Conference, Chair of the NYU annual National Real Estate and Partnership Tax Conference, Chair of the Greater Washington Society of CPAs Federal Taxation Committee, and as a member of the AICPA Tax Executive Committee. Washingtonian Magazine has named him one of the top tax accountants in Washington, DC.

• Education & Credentials

Mr. Wilner holds the CPA credential and has been a member of the AICPA and the Greater Washington Society of CPAs throughout his career. His professional credentials include extensive committee leadership at both the national and regional levels — as Chair of the AICPA’s Partnership Technical Resource Panel, Chair of the AICPA’s annual National Real Estate Tax Conference, technical reviewer for the AICPA Tax Executive Committee on partnership, S corporation, and individual tax matters, and Chair of the AICPA Task Force on Debt Reduction Basis Adjustments — making him one of the most credentialed CPA-side partnership and real estate tax authorities in the country.

• Recognition & Leadership

Mr. Wilner has been named one of the top tax accountants in Washington, DC by Washingtonian Magazine. His co-chairmanship of the NYU Federal Real Estate and Partnerships Tax Conference — a position he has held for many years alongside Andrea Whiteway — is the profession’s most visible form of recognition for sustained leadership in the real estate and partnership tax field. His AICPA committee leadership at every level — Tax Executive Committee, National Real Estate Tax Conference, Partnership Technical Resource Panel, and multiple task forces — reflects an institutional engagement with the standards and development of the profession that is virtually unmatched among CPA-side practitioners.

• Professional Involvement

Mr. Wilner co-chairs the NYU School of Professional Studies Federal Real Estate and Partnerships Tax Conference and is a longtime member and committee leader within the AICPA and Greater Washington Society of CPAs. He has served on the AICPA Tax Executive Committee, chaired its Partnership Technical Resource Panel and National Real Estate Tax Conference, and served as Chair of multiple task forces on partnership debt allocations and debt reduction basis adjustments. He is a frequent lecturer and author on federal tax matters relating to real estate, partnerships, and troubled business workouts.

• Experience

Paul Wilner has spent his career at Grossberg Company building and leading a real estate and partnership tax practice that has made the firm one of the most respected CPA shops in the Washington, DC metropolitan area for complex real estate and partnership tax matters. His nearly four decades of practice in troubled business workouts, REIT transactions, complex partnership structures, and multi-party real estate deals, combined with his AICPA national committee leadership, his Washingtonian Magazine recognition, and his NYU Conference co-chairmanship alongside Andrea Whiteway, define a career of exceptional technical depth, professional leadership, and national influence in the real estate and partnership tax space.

Evan Adams, Esq., Attorney-Advisor, Office of Tax Policy | U.S. Department of the Treasury

Evan Adams is an Attorney-Advisor in the Office of Tax Policy at the U.S. Department of the Treasury in Washington, DC, where he works on the development and implementation of domestic tax policy and administrative guidance. The Office of Tax Policy’s attorney-advisors work within the Main Treasury Building advising the Assistant Secretary for Tax Policy and senior Treasury officials on the formulation of legislative and administrative proposals affecting domestic tax policy. His role places him at the center of the Treasury’s real estate and partnership tax guidance development, and he has appeared as a government representative at national tax conferences including the NYU Federal Real Estate and Partnerships Tax Conference.

• Education & Credentials

Mr. Adams holds a Juris Doctor from an accredited law school and is a member in good standing of a U.S. state bar, as required for attorney-advisor positions in the Office of Tax Policy. His role in Treasury’s Office of Tax Policy reflects a rigorous selection process that prioritizes substantive tax expertise and the ability to work on complex legislative and regulatory projects affecting all aspects of domestic tax law.

• Recognition & Leadership

Mr. Adams’s recognition is grounded in his selection for one of the most competitive and consequential staff attorney roles in the federal government — an attorney-advisor position in Treasury’s Office of Tax Policy, where fewer than 20 lawyers serve as the core technical team responsible for advising on all aspects of domestic tax policy. His participation as a government representative at the NYU Federal Real Estate and Partnerships Tax Conference provides the practitioner community with direct insight into Treasury’s thinking on real estate and partnership tax developments.

• Professional Involvement

Mr. Adams represents the Treasury Department’s Office of Tax Policy in discussions and panels focused on current and pending developments in partnership and real estate taxation, including the NYU Federal Real Estate and Partnerships Tax Conference. As an attorney-advisor in the Office of Tax Legislative Counsel, he contributes to the drafting and review of legislation, regulations, and other guidance affecting domestic tax policy, and engages with industry stakeholders on the most significant pending real estate and partnership tax matters.

• Experience

Evan Adams’s role as an Attorney-Advisor in the Treasury’s Office of Tax Policy places him in one of the most technically demanding and policy-consequential staff attorney positions in the federal government. His work on the development of real estate and partnership tax guidance — from legislative proposals to regulatory projects — gives him firsthand knowledge of how the Treasury approaches the most complex and contested issues in this area of the tax code. His participation in national tax conference panels provides practitioners with the rare opportunity to hear directly from a government insider about what Treasury is focusing on and where guidance is heading.

Brian J. O’Connor, Esq., Partner & Chair, Transactional Tax Group | Venable LLP

Brian J. O’Connor is a Partner and Chair of Venable’s Transactional Tax Group, where he provides sophisticated tax and business advice to publicly traded and closely held businesses and their owners. His practice focuses on foreign and domestic tax matters for partnerships, LLCs, joint ventures, REITs, regulated investment companies, C and S corporations, and wealthy individuals and entrepreneurs. As a transactional tax attorney, he has worked on deals ranging from small sales to mergers valued in the billions of dollars, and as a tax controversy attorney he has represented clients in disputes with amounts at issue exceeding $1 billion. Before joining Venable, he was an attorney-advisor in the IRS Office of Chief Counsel, where he worked on high-profile legislative projects, regulations, and guidance related to partnerships, S corporations, trusts, and cooperatives. He is an adjunct professor at Georgetown University Law Center, where he teaches an advanced course on the technical tax aspects of partnerships and practical matters including partnership and LLC agreement preparation. He holds a B.S. from the University of Connecticut, a J.D., magna cum laude, from Washington and Lee University School of Law, and an LL.M., with distinction (Shell Oil Scholar, highest possible GPA), from Georgetown University Law Center.

• Education & Credentials

Brian holds a Bachelor of Science from the University of Connecticut, a Juris Doctor, magna cum laude, from Washington and Lee University School of Law (1991), and an LL.M. in Taxation with Distinction from Georgetown University Law Center (1996), where he received the Shell Oil Scholar designation for achieving the highest possible grade point average and the Thomas Bradbury Chetwood, S.J. Prize for the Most Distinguished Academic Performance Leading to a Master of Laws Degree in Taxation — the highest academic honor in Georgetown’s graduate tax program. He is admitted to practice in Maryland, Virginia, and the U.S. Tax Court.

• Recognition & Leadership

Brian has been recognized in Best Lawyers in America in Tax: Business, Real Estate: Business, and Mergers and Acquisitions, and was selected to Maryland Super Lawyers. His LL.M. honors at Georgetown — Shell Oil Scholar with the program’s highest GPA and the Chetwood Prize — are among the most distinguished academic recognitions available in the U.S. graduate tax curriculum. His prior IRS Chief Counsel experience and his ongoing Georgetown adjunct teaching role give him a dual government-and-academic perspective that is recognized across the real estate and partnership tax bar. He is a longtime panelist at the NYU Federal Real Estate and Partnerships Tax Conference.

• Professional Involvement

Brian teaches an advanced partnership and LLC drafting course as an adjunct professor at Georgetown University Law Center. He is a regular speaker at the NYU Federal Real Estate and Partnerships Tax Conference, the MACPA Advanced Tax Institute, and the AICPA Real Estate Conference. His former IRS Chief Counsel experience and his ongoing engagement with the government-side tax community give him unique insight into how regulations are drafted and how the IRS interprets partnership tax rules.

• Experience

Brian O’Connor’s career path — from magna cum laude Washington and Lee through a Chetwood Prize-winning Georgetown LL.M., to the IRS Office of Chief Counsel, to Venable’s Transactional Tax Group leadership — reflects a practitioner whose technical depth in partnership and transactional tax is matched by institutional knowledge of how the government approaches the same issues. His group chair role at Venable, his ongoing Georgetown teaching, his recognition in Best Lawyers, and his sustained presence at the NYU Federal Real Estate and Partnerships Tax Conference define a practitioner who is simultaneously one of Washington’s leading private-side partnership tax advisors and one of its most engaged contributors to the educational and professional development of the field.

David L. Friedline, Esq., CPA, LL.M., Partner & Co-Leader | Deloitte Tax LLP

David L. Friedline is a Partner at Deloitte Tax LLP and Co-Leader of Deloitte’s Global Real Estate Funds Group, with more than 30 years of real estate industry experience. He has advised a wide range of clients on the U.S. tax aspects of domestic and cross-border real estate matters, including REITs (equity and mortgage), partnerships and joint ventures, M&A transactions and due diligence, capital raising and fund formation, debt-workouts and purchases of distressed debt portfolios, leasing and tax-deferred exchanges, and real estate securitizations. He has significant experience with all major property types, including hospitality, healthcare, railroad, military housing, cell towers, power plants, and infrastructure. He also served as a senior tax counsel and regional tax director in the London and Stamford offices of GE Capital Real Estate, giving him an operating company perspective that supplements his extensive Big Four advisory background. He holds a B.S. from Florida State University, a J.D. from American University Washington College of Law, an LL.M. in Tax from Georgetown University Law Center, and is a CPA.

• Education & Credentials

David holds a Bachelor of Science from Florida State University (1988), a Juris Doctor from American University Washington College of Law (1997), and an LL.M. in Taxation from Georgetown University Law Center. He is a Certified Public Accountant. His triple credential — CPA, J.D., and Georgetown Tax LL.M. — reflects the breadth of technical training that informs his ability to advise clients on the accounting, legal, and tax policy dimensions of complex real estate transactions simultaneously.

• Recognition & Leadership

David is a nationally recognized real estate tax authority whose expertise spans public REITs, private equity real estate funds, sovereign wealth funds, and cross-border real estate investment structures. He is a regular speaker at the NYU Federal Real Estate and Partnerships Tax Conference, where he has presented for many years on cross-border real estate investment and related international tax planning topics. He also serves as Vice Chair of the Tax Policy Advisory Committee of The Real Estate Roundtable, reflecting industry recognition of his expertise and institutional engagement on real estate tax policy matters at the highest organizational level.

• Professional Involvement

David serves as Vice Chair of the Tax Policy Advisory Committee of The Real Estate Roundtable and is a regular speaker at the NYU Federal Real Estate and Partnerships Tax Conference. He has also appeared at the AFIRE Tax & Regulatory Summit, PLI Tax Strategies for Corporate Acquisitions programs, and Deloitte’s Dbriefs real estate webcasts. His prior leadership of Deloitte’s Global Funds Tax Advisory practice reflects a sustained engagement with the institutional investment community’s most complex cross-border tax challenges.

• Experience

David Friedline’s more than 30-year career in real estate tax spans Big Four advisory, in-house corporate tax leadership at GE Capital Real Estate in London and Stamford, and Deloitte partnership leadership — a trajectory that has made him one of the most comprehensively experienced real estate tax advisors in the country. His work across fund formation, REIT structures, distressed debt, military housing, cell towers, power plants, and international inbound investment reflects a breadth of property type and transaction type expertise that is rare among Big Four real estate tax practitioners. His Vice Chair role at The Real Estate Roundtable’s Tax Policy Advisory Committee and his NYU Conference speaking record further demonstrate a practitioner whose influence extends beyond his own client base to the broader real estate tax policy community.

Ellen K. Harrison, Esq., Counsel | McDermott Will & Schulte

Ellen K. Harrison is Counsel in McDermott Will & Schulte’s Private Client Practice in Washington, DC, where she has been widely recognized as one of the United States’ preeminent private client lawyers for more than three decades. She advises clients on a broad range of tax issues including estate planning and administration, tax controversies, and U.S. and international income, gift, and estate tax planning for high-net-worth individuals, families, businesses, and charitable organizations. Her practice encompasses drafting wills, trusts, powers of attorney, prenuptial arrangements, and buy-sell agreements, as well as tax controversy and litigation involving IRS audits, IRS appeals, refund claims, and U.S. Tax Court litigation. She is a Fellow of the American College of Trust and Estate Counsel (ACTEC), a Past Regent and Past Chair of ACTEC’s International Estate Planning Committee, and currently serves as Chair of the Washington Affairs Committee. She is also a Vice President (Americas) of the International Academy of Trust and Estate Lawyers. She holds a B.A., with highest honors, from the University of Michigan and a J.D., cum laude, from Harvard Law School.

• Education & Credentials

Ellen holds a Bachelor of Arts, with highest honors, from the University of Michigan and a Juris Doctor, cum laude, from Harvard Law School. She is an elected Fellow of the American College of Trust and Estate Counsel, a Former Adjunct Professor at Georgetown University Law Center, a member of the American Law Institute, and a liaison from the ABA Section on Real Property, Trust and Estate Law to the AICPA. Her Harvard Law and University of Michigan academic distinctions reflect the intellectual foundation that has supported a career of exceptional technical depth in estate, gift, and international tax planning.

• Recognition & Leadership

Ellen has been recognized in Best Lawyers in America in Litigation — Trusts and Estates and Trusts and Estates continuously since 1995 — among the longest-running Best Lawyers recognitions in the country. She has been ranked by Chambers High Net Worth in Band 1 for District of Columbia: Private Wealth Law and USA Nationwide: Private Wealth Law, Eastern Region, from 2016 through 2025, and was named a Washingtonian Top Lawyer in Trusts and Estates for 2023 and 2024. Her ACTEC Past Regency and current Washington Affairs Committee Chairmanship reflect the highest level of peer recognition in the estate and trust bar.

• Professional Involvement

Ellen is a Fellow and Past Regent of ACTEC, Chair of ACTEC’s Washington Affairs Committee, Past Chair of the International Estate Planning Committee, and Vice President (Americas) of the International Academy of Trust and Estate Lawyers. She is a member of the American Law Institute, serves as AICPA liaison from the ABA Section on Real Property, Trust and Estate Law, serves on the Advisory Committee of the Heckerling Institute on Estate Planning at the University of Miami School of Law, and is a member of the DC Estate Planning Council. She was previously an adjunct professor at Georgetown Law Center.

• Experience

Ellen Harrison’s 30-plus-year private client practice at McDermott Will & Schulte represents one of the most distinguished and sustained careers in U.S. estate, gift, and international tax law. Her Band 1 Chambers ranking since 2016, her Best Lawyers recognition since 1995, her ACTEC Past Regency, her International Academy Vice Presidency (Americas), her Harvard Law J.D. cum laude, and her Georgetown adjunct teaching experience together constitute a record of professional achievement and institutional leadership at the very top of the private client bar. Her particular expertise in family office structures and international estate planning, combined with her decades of IRS controversy and Tax Court litigation experience, make her one of the most versatile and sought-after private client advisors in Washington and nationwide.

Caitlin M. Orr, Esq., Partner | McDermott Will & Schulte

Caitlin M. Orr is a Partner in McDermott Will & Schulte’s Private Client Practice in Washington, DC, where she focuses on private client matters for ultra-high-net-worth individuals and their families. She advises clients on all aspects of estate and wealth transfer planning and on a broad range of tax issues, including income, gift, and estate tax planning for individuals, businesses, and charitable organizations. Her practice includes analyzing estate, gift, and GST taxation issues, counseling individuals and families on wealth management needs, preparing primary estate plans, probating complex estates, advising fiduciaries in trust and estate administration, implementing sophisticated wealth transfer transactions (including sales to IDGTs and GRATs), advising on liquidity planning for estate tax, and preparing and reviewing federal gift, estate, and GST tax returns. She is an elected Fellow of the American College of Trust and Estate Counsel and an adjunct professor at Georgetown University Law Center, where she teaches an Estate and Gift Taxation course to LL.M. candidates. She holds a BBA and an MAcc from the University of Georgia, and a J.D. from Emory University School of Law.

• Education & Credentials

Caitlin holds a Bachelor of Business Administration and a Master of Accountancy from the University of Georgia (2007) and a Juris Doctor from Emory University School of Law (2010), where she served as a research assistant for Professor Jeffrey N. Pennell — one of the leading estate planning academics in the country. She is an elected Fellow of the American College of Trust and Estate Counsel and an adjunct professor at Georgetown University Law Center, where she teaches Estate and Gift Taxation to LL.M. candidates. Her dual business and legal education from Georgia and Emory, combined with her ACTEC fellowship and Georgetown teaching appointment, reflect a practitioner of exceptional academic and professional depth.

• Recognition & Leadership

Caitlin was elected as a Fellow of the American College of Trust and Estate Counsel in 2023 — a peer-nominated distinction recognizing the highest levels of integrity, commitment, competence, and experience in trust and estate practice. She was recognized in DC Super Lawyers Rising Stars from 2017 through 2020. Her adjunct teaching appointment at Georgetown University Law Center and her research assistant work for Professor Pennell — one of the nation’s leading estate planning academics — reflect recognition of her academic contributions alongside her private client practice. Her work under the broader McDermott Private Client Practice, which has been ranked the top private wealth practice in the U.S. by Chambers High Net Worth, further reflects the institutional setting in which her individual achievements are recognized.

• Professional Involvement

Caitlin is a Fellow of ACTEC and an adjunct professor at Georgetown University Law Center teaching Estate and Gift Taxation to LL.M. candidates. She publishes on wealth management and estate planning developments for Wealth Management magazine and other outlets, covering topics including disclaimer planning, trust decanting, estate planning considerations for 2025 tax reform, and cross-border trust registration. She is an active participant in the ACTEC community and the DC estate planning bar.

• Experience

Caitlin Orr’s career at McDermott Will & Schulte combines the intellectual foundation of a University of Georgia dual business degree and an Emory Law education with the practical depth of a decade-plus of ultra-high-net-worth estate and wealth transfer planning at one of the country’s most distinguished private client practices. Her ACTC fellowship, her Georgetown adjunct teaching, her Chambers-recognized firm setting, and her sustained practice advising families on complex IDGT, GRAT, GST planning, and trust repair strategies reflect a private client practitioner of exceptional ability and institutional recognition. Her prior research collaboration with Professor Pennell at Emory Law further demonstrates a connection to the academic dimensions of estate planning that enriches her client-facing practice.

Michael Greenberg, Esq., Principal, U.S. Tax | PwC

Michael Greenberg is a Principal in PwC’s U.S. Tax practice in Los Angeles, where he focuses on the tax aspects of real estate, partnership, and investment fund transactions. He advises U.S. and non-U.S. investment fund sponsors on fund formation, coinvestments, restructurings, secondary transactions, and minority investments in fund sponsor groups, with significant experience representing REITs, offshore investors, and investors in real estate and infrastructure assets. His practice includes advising on cross-border real estate investment structures, partnership tax planning, and REIT-related M&A and joint ventures. He is a regular presenter at the NYU Federal Real Estate and Partnerships Tax Conference and other national real estate and partnership tax forums.

• Education & Credentials

Mr. Greenberg holds a Juris Doctor and is a member of the California bar. His practice at PwC builds on deep technical expertise in partnership tax, real estate fund formation, and cross-border real estate investment structures developed across an extensive career in the real estate and investment fund tax advisory space.

• Recognition & Leadership

Mr. Greenberg is recognized as a leading practitioner in real estate and partnership tax through his sustained participation as a panelist at the NYU Federal Real Estate and Partnerships Tax Conference and other national tax forums. His practice at PwC — one of the Big Four’s preeminent real estate and investment fund tax practices — reflects peer and institutional recognition of his expertise in the most complex areas of partnership and REIT taxation.

• Professional Involvement

Mr. Greenberg is a regular speaker at the NYU Federal Real Estate and Partnerships Tax Conference on topics including cross-border real estate investment structures, REIT planning, and partnership tax developments. He contributes to PwC’s client education and thought leadership in the real estate and investment fund tax space.

• Experience

Michael Greenberg has built a partnership and real estate tax practice at PwC that spans the full range of investment fund formation, REIT advisory, and cross-border real estate transaction challenges facing institutional and private equity real estate investors today. His Los Angeles base gives him particular engagement with the West Coast real estate investment and entertainment industry sectors, while his NYU Conference participation reflects national-level recognition as a real estate and partnership tax authority.

Chelsea Riedel, CPA, Director of Tax | VICI Properties Inc.

Chelsea Riedel is a CPA who recently joined VICI Properties Inc. as Director of Tax after nearly a decade as a Managing Director in KPMG’s real estate and partnership tax practice. At KPMG, she specialized in tax planning for partnership transactions and compliance for clients including real estate, private equity, hedge, operating partnerships, and alternative investment funds. She was deeply involved in developing and instructing many of KPMG’s federal tax seminars on the taxation of partnerships, and served as a frequent instructor for internal and web-based training programs. She holds an LL.M. in Tax from New York University School of Law and was previously a faculty member at the University of Maryland Robert H. Smith School of Business.

• Education & Credentials

Chelsea holds an LL.M. in Taxation from New York University School of Law (2019) and a CPA credential, and previously served as an adjunct faculty member at the University of Maryland Robert H. Smith School of Business. Her NYU Tax LL.M. and her teaching experience at Maryland Smith reflect an academic foundation that complements her extensive practitioner experience in partnership and real estate tax at KPMG. Her undergraduate work at the University of Maryland was recognized with the Philip Merrill Scholar distinction, University Honors, and multiple scholarship recognitions from Ernst & Young, PricewaterhouseCoopers, and the Dean’s office.

• Recognition & Leadership

Chelsea’s recognition at KPMG — where she rose to Managing Director and became a lead instructor for the firm’s federal tax partnership seminars and training programs — reflects sustained peer and institutional recognition of her technical expertise and teaching ability. Her NYU Tax LL.M. and her University of Maryland Smith School faculty appointment reflect academic credentials that distinguished her within the KPMG practitioner community. Her move to VICI Properties as Director of Tax reflects the value that a major public REIT placed on her combination of partnership, REIT, and real estate tax expertise.

• Professional Involvement

Chelsea has been an active participant in the real estate and partnership tax professional community through her KPMG training leadership, her University of Maryland Smith School teaching, and her participation at national tax conferences including the NYU Federal Real Estate and Partnerships Tax Conference. At VICI Properties, she brings her practitioner expertise to the in-house tax function of one of the largest experiential real estate companies in the world.

• Experience

Chelsea Riedel’s career spans nearly a decade at KPMG’s real estate and partnership tax practice, where she advised real estate funds, private equity, and alternative investment funds on their most complex federal tax planning challenges and built KPMG’s internal partnership tax training curriculum — and now the in-house Director of Tax role at VICI Properties, a S&P 500 gaming REIT. Her NYU Tax LL.M., her University of Maryland Smith School teaching, and her KPMG training leadership reflect a practitioner who has simultaneously built technical depth, teaching credibility, and institutional recognition across both the Big Four and the real estate industry.

Glenn M. Johnson, Esq., Principal | Ernst & Young LLP

Glenn M. Johnson is a Principal in Ernst & Young LLP’s U.S. National Tax Department in Washington, DC, where he leads the U.S. PPP Infrastructure Tax Practice and serves as Director of Leasing Tax Services. He focuses on leasing, asset-based structured transactions, infrastructure finance, deferred like-kind exchanges, and captive leasing company structures, advising both developers and investors on a wide range of tax issues. He joined Ernst & Young in 1998 and has spent his entire career in the EY National Tax Department, becoming one of the firm’s leading authorities on leasing and infrastructure taxation. He is the former ABA Tax Section Chair of the Capital Recovery and Leasing subcommittee, a member of EY’s Federal Income Tax Committee, and leads EY’s Infrastructure Tax Committee. He has been a longtime member of the Equipment Leasing and Finance Association Federal Tax Committee for more than 13 years. He earned his LL.M. in Taxation from Georgetown University Law School, his J.D., with honors, from Boston University School of Law, and his B.A. in Economics from Wesleyan University.

• Education & Credentials

Glenn holds a Bachelor of Arts in Economics from Wesleyan University, a Juris Doctor, with honors, from Boston University School of Law, and an LL.M. in Taxation from Georgetown University Law School — an academic trifecta that reflects the economics, law, and tax foundations that underpin his practice in leasing, infrastructure finance, and like-kind exchange transactions. He joined Ernst & Young in 1998 and has built his entire career in the firm’s National Tax Department in Washington, DC.

• Recognition & Leadership

Glenn is the former ABA Tax Section Chair of the Capital Recovery and Leasing subcommittee and leads EY’s Infrastructure Tax Committee. He has been a member of the Equipment Leasing and Finance Association Federal Tax Committee for more than 13 years — a sustained engagement with the leasing industry’s tax policy community that has made him a go-to authority on equipment leasing and infrastructure tax matters. His longtime participation as a panelist at the NYU Federal Real Estate and Partnerships Tax Conference reflects national-level peer recognition in the real estate and partnership tax community.

• Professional Involvement

Glenn leads EY’s Infrastructure Tax Practice and serves as Director of Leasing Tax Services. He is a former ABA Tax Section Capital Recovery and Leasing subcommittee Chair and a current member of EY’s Federal Income Tax Committee and Infrastructure Tax Committee. He has been a member of the ELFA Federal Tax Committee for more than 13 years. He is a regular speaker at the NYU Federal Real Estate and Partnerships Tax Conference, the MACPA Advanced Tax Institute, and other national real estate and infrastructure tax forums.

• Experience

Glenn Johnson has spent nearly three decades in EY’s National Tax Department building one of the firm’s leading specialized practices in leasing, infrastructure, and like-kind exchange taxation. His combination of a Boston University Law honors degree, a Georgetown Tax LL.M., and 25-plus years of practice advising developers, investors, and manufacturers on leasing structures, infrastructure finance, and tax-deferred exchanges has made him one of the most technically credentialed specialists in these fields at any Big Four firm. His ABA committee chairmanship, his ELFA committee tenure, his EY infrastructure practice leadership, and his sustained NYU Conference presence reflect a practitioner whose contributions to the profession extend well beyond his own client engagements.

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

Robert D. Schachat is a Managing Director in BDO USA’s National Tax practice, where he focuses on all federal income tax aspects of real estate, including REIT, partnership, LLC, and S corporation formations, acquisitions, like-kind exchanges, development, leases, financings, workouts, dispositions, and liquidations. He is co-author (with Jim Lowy) of the CCH treatise Federal Taxation of Real Estate Investment Trusts — the definitive reference work on REIT taxation — and is a frequent author and speaker at real estate industry and tax conferences. He joined BDO in 2021 after 23 years in the National Tax Real Estate Group of a Big Four accounting firm and 12 years as a partner in a Manhattan law firm specializing in real estate taxation, bringing more than 40 years of total real estate tax experience to his current role. He has served as Chair of the Real Estate Committee of the ABA Section of Taxation, Vice Chair of the Tax Policy Advisory Committee of The Real Estate Roundtable, and Conference Chair of the NYU Like-Kind Exchange Tax Conference. He holds an S.B. from MIT and a J.D. and LL.M. from New York University School of Law.

• Education & Credentials

Robert holds a Bachelor of Science from the Massachusetts Institute of Technology, a Juris Doctor from New York University School of Law, and an LL.M. in Taxation from New York University School of Law — a combination of MIT’s analytical rigor and NYU Law’s nationally preeminent tax program that reflects the technical foundation underlying more than four decades of real estate and REIT tax practice. He is co-author of the CCH treatise Federal Taxation of Real Estate Investment Trusts, the most comprehensive and widely cited reference work on REIT taxation in existence.

• Recognition & Leadership

Robert has been recognized as one of the country’s leading real estate tax authorities through his chairmanship of the ABA Tax Section Real Estate Committee, his Vice Chairmanship of The Real Estate Roundtable’s Tax Policy Advisory Committee, and his Conference Chair role at the NYU Like-Kind Exchange Tax Conference. His co-authorship of the CCH REIT taxation treatise is a form of scholarly recognition that has influenced the field for decades, and his 40-plus years of practice spanning a Manhattan law firm partnership and the National Tax Real Estate Groups of a Big Four firm and BDO represent a career record of exceptional technical depth and institutional engagement.

• Professional Involvement

Robert has chaired the ABA Tax Section Real Estate Committee, served as Vice Chair of The Real Estate Roundtable Tax Policy Advisory Committee, and chaired the NYU Like-Kind Exchange Tax Conference. He is a regular panelist at the NYU Federal Real Estate and Partnerships Tax Conference and the AICPA-CIMA Real Estate Conference. He has also monitored federal legislative and regulatory activity in the real estate area on behalf of clients throughout his career, giving him a policy-engagement dimension that complements his transactional and advisory practice.

• Experience

Robert Schachat’s more than 40-year real estate tax career — from a Manhattan law firm partnership to 23 years in Big Four practice to BDO — encompasses the full spectrum of real estate tax complexity: REITs, partnerships, like-kind exchanges, workouts, fund formation, and international inbound investment. His MIT analytical foundation, his NYU Law and LL.M. credentials, his CCH treatise co-authorship, his ABA committee chairmanship, his Roundtable Vice Chairmanship, and his NYU Conference leadership together define a practitioner whose contributions to the field are simultaneously transactional, scholarly, and institutional. As Conference Chair of the NYU Like-Kind Exchange Tax Conference and a longtime panelist at the broader NYU Real Estate and Partnerships Conference, he has helped shape the national discourse on real estate taxation for decades.

Andrew Weiner, Esq., Counsel | Kostelanetz LLP

Andrew (Andy) Weiner is Counsel at Kostelanetz LLP in Washington, DC, where he focuses on tax controversies — both civil and criminal — in trial and appellate courts and at the agency level. He is a Fellow of the American College of Tax Counsel, a Forbes contributing columnist on tax controversy and policy, and an adjunct professor at American University Washington College of Law. Prior to Kostelanetz, he was a DOJ Tax Division trial attorney for more than a decade, briefing and arguing approximately 50 cases before U.S. Courts of Appeals and handling complex matters in the Court of Federal Claims involving tax shelters, research credits, and other federal tax issues. He held the Director of the Graduate Tax Program and founding Director of the Low Income Taxpayer Clinic at Temple University Beasley School of Law. (See full biography in the main Tax Conference Panelists file.)

• Education & Credentials

Andy is a graduate of the University of Pennsylvania Carey Law School, a Fellow of the American College of Tax Counsel, and an adjunct professor at American University Washington College of Law. He received the DOJ Tax Division’s Outstanding Attorney Award five times and a Special Commendation during his government service.

• Recognition & Leadership

Andy is a Fellow of the American College of Tax Counsel, a Forbes contributing columnist, and a five-time DOJ Outstanding Attorney Award recipient. He is Vice Chair of the ABA Tax Section Diversity Committee and Vice Chair of the D.C. Bar Tax Audits and Litigation Committee.

• Professional Involvement

Andy is Vice Chair of the ABA Tax Section Diversity Committee and the D.C. Bar Tax Audits and Litigation Committee. He speaks at PLI, the ABA Tax Section, and the FBA Tax Law Conference on BBA audits, refund litigation, and international controversies, and is co-author of the forthcoming ABA Tax Section chapter on applying administrative law in tax cases.

• Experience

Andy Weiner’s career spans DOJ Tax Division trial work (approximately 50 circuit arguments), Temple Law clinical direction, and Kostelanetz counsel practice — defining one of Washington’s most accomplished tax controversy practices. His ACTC fellowship, Forbes column, adjunct professorship, and ABA and D.C. Bar committee leadership reflect sustained excellence in advocacy and professional development.

Ryan P. McCormick, Esq., Senior Vice President & Counsel | The Real Estate Roundtable

Ryan P. McCormick is Senior Vice President and Counsel at The Real Estate Roundtable in Washington, DC, where he is responsible for managing the organization’s tax policy activities. He coordinates the Roundtable’s Tax Policy Advisory Committee — a group of 150 leading real estate tax experts including in-house tax directors, general counsel, CFOs of major real estate companies, and senior partners from national law and accounting firms — and created and directs the Real Estate Research Consortium, which commissions and supports academic and economic research on real estate taxation. Ryan joined the Roundtable in May 2013 following nearly 11 years in the U.S. Senate as a tax and economic policy advisor to Senators Daniel Patrick Moynihan, John Kerry, Joe Lieberman, Bob Graham, and Bill Nelson. In the 112th Congress, he served as Staff Director of the Senate Finance Subcommittee on Fiscal Responsibility and Economic Growth. Prior to the Senate, he practiced tax law at Miller & Chevalier Chartered and was editor-in-chief of the University of Texas International Law Journal. He was a Fulbright Scholar. He holds a J.D. from the University of Texas School of Law and previously served as a tax associate at Miller & Chevalier.

• Education & Credentials

Ryan holds a Juris Doctor from the University of Texas School of Law and was editor-in-chief of the University of Texas International Law Journal. He is a former Fulbright Scholar. His Senate service — including 11 years as a tax and economic policy advisor to five U.S. Senators and his role as Staff Director of the Senate Finance Subcommittee on Fiscal Responsibility and Economic Growth — combined with his Miller & Chevalier tax law practice experience, gives him an extraordinarily deep understanding of both tax policy and tax law from the legislative, executive, and private sector perspectives.

• Recognition & Leadership

Ryan’s recognition is grounded in his dual role as the leading tax policy voice of one of the most influential real estate trade organizations in Washington and as the creator of the Real Estate Research Consortium, which has commissioned and supported major academic and economic research on real estate taxation. His 11-year Senate career — advising five Finance Committee members on tax, budget, and economic policy — reflects the deepest possible immersion in the federal tax legislative process. His Fulbright scholarship and his editorial leadership of the University of Texas International Law Journal reflect academic distinction alongside his policy credentials.

• Professional Involvement

Ryan coordinates the Real Estate Roundtable’s Tax Policy Advisory Committee of 150 leading real estate tax experts and directs the Real Estate Research Consortium. He is a regular speaker at the NYU Federal Real Estate and Partnerships Tax Conference, where he delivers the annual Legislative Outlook for Real Estate address, and participates in the AICPA Real Estate Conference, the KPMG Financial Services Tax Conference, the ABA Tax Section, and the House Financial Services Committee. He also testified before the House Financial Services Committee on proxy process reform on behalf of the Roundtable.

• Experience

Ryan McCormick has spent a decade at The Real Estate Roundtable translating nearly 11 years of Senate Finance Committee experience into the most effective real estate tax policy advocacy program in Washington. His creation of the Real Estate Research Consortium, his coordination of a 150-member Tax Policy Advisory Committee, and his annual Legislative Outlook address at the NYU Federal Real Estate Conference have made him the most authoritative voice in Washington on where real estate tax policy is heading and why. His Fulbright background, his Miller & Chevalier tax law experience, his UT Law Journal editorship, and his decade of Senate service to five Finance Committee members collectively define a practitioner whose unique combination of legal training, policy expertise, and institutional relationships has positioned him as an indispensable resource for the real estate tax community.

Sarah Brodie, Esq., Tax Planning Partner | Morgan, Lewis & Bockius LLP

Sarah Brodie is a Tax Planning Partner at Morgan, Lewis & Bockius LLP in Washington, DC, where she concentrates her practice on partnership tax, advising financial institutions, energy companies, and other multinational corporations on partnership transactions, M&A, internal restructurings, and proceedings before the IRS. She is the co-author of two of the most widely used treatises in the partnership tax field: McKee, Nelson, Whitmire & Brodie: Federal Taxation of Partnerships and Partners (Thomson Reuters/Tax & Accounting, 5th ed. 2024) — the leading multi-volume treatise on partnership taxation — and Whitmire, Nelson, McKee & Brodie: Structuring and Drafting Partnership and LLC Agreements (Thomson Reuters/WG&L, 4th ed. 2021). Previously, she was a Principal in the National Tax Department at Ernst & Young LLP. She has also interned for the IRS Office of Chief Counsel, Large and Mid-Sized Business division, assisting in tax shelter litigation and settlement negotiations with corporate taxpayers.

• Education & Credentials

Sarah is a graduate of a leading law school and holds credentials reflecting deep academic engagement with partnership tax scholarship. She is co-author of McKee, Nelson, Whitmire & Brodie: Federal Taxation of Partnerships and Partners (5th ed. 2024) — a multi-volume treatise considered the most authoritative reference in the field — and Whitmire, Nelson, McKee & Brodie: Structuring and Drafting Partnership and LLC Agreements (4th ed. 2021). Her co-authorship of both the leading partnership tax treatise and the leading partnership drafting guide reflects a scholarly engagement with the partnership tax field that is matched by very few practitioners.

• Recognition & Leadership

Sarah’s co-authorship of the 5th edition of McKee, Nelson, Whitmire & Brodie: Federal Taxation of Partnerships and Partners — the most comprehensive and authoritative treatise on partnership taxation — is a career-defining contribution to the field that is recognized by practitioners, academics, and courts as a foundational reference. The treatise’s Thomson Reuters/Tax & Accounting publication reflects the highest standard of scholarly recognition in tax law. Her co-authorship of the companion Structuring and Drafting Partnership and LLC Agreements treatise further establishes her as one of the most significant contributors to the partnership tax literature of her generation. Her prior Principal role at EY and her current partner position at Morgan Lewis reflect sustained client recognition of her transactional partnership tax expertise.

• Professional Involvement

Sarah is co-author of the two most influential treatises in the partnership tax field and an active contributor to the national partnership tax professional community. She has participated as a panelist at the NYU Federal Real Estate and Partnerships Tax Conference and other national tax conferences on partnership tax topics. Her prior EY National Tax Department experience and her current Morgan Lewis practice reflect sustained engagement with the partnership tax advisory community at both the Big Four and major law firm levels.

• Experience

Sarah Brodie’s partnership tax practice and her co-authorship of the McKee, Nelson, Whitmire & Brodie treatise — now in its fifth edition — together define one of the most distinctive careers in the partnership tax field. Her combination of transactional practice advising financial institutions, energy companies, and multinationals; prior EY National Tax experience; IRS Chief Counsel internship background; and co-authorship of both the leading partnership tax treatise and the leading partnership drafting guide represents a breadth of contribution to the field — practitioner, scholar, and instructor — that is extraordinarily rare. Her move from EY to Morgan Lewis & Bockius reflects the value that a major international law firm placed on her unique combination of treatise authorship and transactional depth.

DAY 1, Thursday, June 4, 2026

SESSION 1 – Recent Legislative and Regulatory Developments: One Big Beautiful Bill Act (OBBBA) and the Government Perspective | 8:25am – 9:30am

This panel discusses changes made that impact partnership and real estate in the One Big Beautiful Bill Act, and regulatory guidance issued and forthcoming from the Government.

Kevin Salinger, Esq., Deputy Assistant Secretary (Tax Policy), US Department of the Treasury, Washington, DC

Steven R. Schneider, Esq., Partner, Hogan Lovells, Washington, DC

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

Paul H. Wilner, CPA, Advisor, Grossberg Company, Bethesda, MD

SESSION 2 – Opportunity Zone Planning Under the TCJA and Now the OBBA | 9:30am – 10:30am

This panel discusses current tax planning for qualified opportunity funds as well as the changes made under the OBBBA. We will explore transition relief and other opportunity zone implementation issues associated with the overlap of the Tax Cuts and Jobs Act and the OBBBA opportunity zone provisions.

Evan Adams, Esq., Attorney-Advisor, Office of Tax Policy, US Department of the Treasury, Washington, DC

Steven R. Schneider, Esq., Partner, Hogan Lovells, Washington, DC

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

Paul H. Wilner, CPA, Advisor, Grossberg Company, Bethesda, MD

BREAK | 10:30am – 10:45am

SESSION 3 – Real Estate Tax Transactional Planning Issues and Opportunities | 10:45am – 12:00pm

With a focus on real world transactional experiences, the presenters focus on the tax aspects of certain complex real estate and partnership transactions and the opportunities and often missed issues, pitfalls, and challenges under these types of business transactions.

Brian J. O’Connor, Esq., Partner, Venable, Washington, DC

Paul H. Wilner, CPA, Advisor, Grossberg Company, Bethesda, MD

LUNCH | 12:00pm – 1:00pm

SESSION 4 – Post-LuncheOn Address: Ask the Experts | 1:00pm – 1:45pm

This session provides an outstanding opportunity for the audience to raise tax questions with a panel of leading experts.

David Friedline, Esq., Partner, Deloitte Tax, Jacksonville, FL

Ellen K. Harrison, Esq., Counsel, McDermott, Will & Schulte, Washington, DC

Brian J. O’Connor, Esq., Partner, Venable, Washington, DC

Steven R. Schneider, Esq., Partner, Hogan Lovells, Washington, DC

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

Paul H. Wilner, CPA, Advisor, Grossberg Company, Bethesda, MD

SESSION 5 – Estate Planning Using Partnership Freeze | 1:45pm – 3:00pm

Examine why freeze partnerships may outperform sales to defective grantor trusts for real estate entrepreneurs, including swap powers, integration strategies, and authorities on basis step-up at death such as Rev. Rul. 2023-2 and Belmont v. Commissioner.

Ellen K. Harrison, Esq., Counsel, McDermott, Will & Schulte, Washington, DC

Caitlin M. Orr, Esq., Partner, McDermott, Will & Schulte, Washington, DC

BREAK | 3:00pm – 3:15pm

SESSION 6 – Creative Planning for Cross-Border Real Estate Investment | 3:15pm – 4:30pm

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.

David Friedline, Esq., Partner, Deloitte Tax, Jacksonville, FL

Michael Greenberg, Esq., Principal, PwC US Tax, Los Angeles, CA

SESSION 7 – Troubled Business Workouts | 4:30pm – 5:30pm

This presentation covers the issues associated with troubled businesses and debt restructuring/workouts with a focus on partnerships and real estate.

David Friedline, Esq., Partner, Deloitte Tax, Jacksonville, FL

Chelsea Riedel, CPA, Managing Director, KPMG, Washington, DC

DAY 2, Friday, June 5, 2026

SESSION 1 – Leasing Property in a Troubled Real Estate Environment | 8:30am – 9:45am

The federal income tax ramifications from different Landlord/Tenant lease negotiation incentives and structures in a tenant favorable market, including: rent reductions; rent holidays; tenant inducement payments; tenant allowances; and landlord improvements.

Glenn M. Johnson, Esq., Principal, EY, Washington, DC

Robert D. Schachat, Esq., Managing Director, BDO USA, Washington, DC

SESSION 2 – Nuts and Bolts of a Partnership BBA Audit | 9:45am – 10:45am

IRS audits under the BBA partnership audit rules are well underway. This presentation 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.

Andrew Weiner, Esq., Counsel, Kostelanetz, Washington, DC

BREAK | 10:45am – 11:00am

SESSION 3 – Hot Topics in Like Kind Exchanges | 11:00am – 12:15pm

This panel covers a wide variety of recent developments and trends involving like-kind exchanges of real property, including partnership split-ups, parking arrangements within and outside the safe harbor, construction exchanges, leases, pre- and post-exchange debt refinancing, transfers in foreclosure and related party transactions.

Glenn M. Johnson, Esq., Principal, EY, Washington, DC

Robert D. Schachat, Esq., Managing Director, BDO USA, Washington, DC

LUNCH | 12:15pm – 1:15pm

SESSION 4 – Post-LuncheOn Address: Legislative Outlook for Real Estate | 1:15pm – 2:00pm

This presentation focuses on current key national public policy issues and legislative actions under consideration as they affect the real estate industry as well as the overall economy.
Ryan P. McCormick, Esq., Senior Vice President and Counsel, The Real Estate Roundtable, Washington, DC

SESSION 5 – Section 704(c) Planning | 2:00pm – 3:15pm

This presentation focuses on the Section 704(c) rules and practical application of the rules in the context of transaction planning.

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

BREAK | 3:15pm – 3:30pm

SESSION 6 – Nuts and Bolts of Basis Adjustments; Including Recent Developments (OTAY and Related Party Basis and Related Party Basis Adjustments Regulations) | 3:30pm -4:45pm

This panel covers basis adjustments under Sections 743(b) and 743(b), as well as their allocation under Section 755. The presentation gives a broad overview of the basic rules, and discuss several areas of uncertainty, including the recent Otay case and the coming demise of the so-called basis shifting regulations.

Sarah Brodie, Esq., Principal, EY, Washington, DC