APRIL 26 & 27 THE UNC CENTER FOR SCHOOL LEADERSHIP DEVELOPMENT

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1 School of Law The University of North Carolina at Chapel Hill THE 2018 J.NELSON Y O U N G T A X INSTITUTE APRIL 26 & 27 THE UNC CENTER FOR SCHOOL LEADERSHIP DEVELOPMENT CHAPEL HILL, NC Program Highlights Include: The State of the IRS Presented by National Taxpayer Advocate Nina Olson The 2017 Tax Reform Bill Effects on Choice of Entity, Income Taxation, Non-Profits, and More 13.0 hours of CLE credit 15.5 hours of CPE credit A Program in Continuing Legal / Professional Education

2 About the 2018 J. Nelson Young Tax Institute The Tax Institute is an annual professional institute covering current federal tax problems and issues at the post-graduate level of knowledge. The program is designed for the practitioner who must frequently handle federal tax matters. Emphasis is placed on subjects that are new and current, including in-depth coverage of recent developments and problems that often prove difficult in planning clients affairs and transactions. The teaching method employed is lecture. No prerequisites or advanced planning is required. The speakers at the Tax Institute are tax practitioners and scholars from throughout the country who have been selected for their technical expertise and speaking ability. They will address any recently enacted or pending legislation relevant to their topics. Please join us April in Chapel Hill for the 2018 Tax Institute. Program Director Kathleen DeLaney Thomas Assistant Professor of Law UNC School of Law Planning Committee The following have given valuable assistance in the planning of the program and selection of speakers for the Tax Institute. Deborah B. Andrews Hall Benefits Law Kevin J. Bassett Bassett & Byers Stacey A. Brady Schell Bray Natalie C. Folmar Tuggle Duggins W. B. Rodman Davis Davis Mangum C. Wells Hall, III Nelson Mullins Steve C. Horowitz Milazzo Schaffer Webb Law Trenton Kool Jones Day Sherri L. McGirt McNair Law Firm William W. Nelson Smith Anderson Sue A. Sprunger Sprunger Law Charles L. Steel IV Manning Fulton & Skinner Kimberly Q. Swintosky Smith Anderson Adam P.M. Tarleton Brooks Pierce Group Discount: Send 3 or more and receive $50 off EACH registration UNC Tax Institute 1 April 26-27, 2018

3 Agenda Thursday, April 26 8:30 a.m. 8:45 a.m. 9:00-10:00 a.m. 10:10-11:10 a.m. 11:20 a.m. - 12:20 p.m. 12:20-1:10 p.m. Registration Desk Opens Welcome Martin H. Brinkley, Dean, UNC School of Law and Kathleen DeLaney Thomas, Assistant Professor of Law and Director of UNC Tax Institute The Hot Topics in Tax Controversy David D. Aughtry, Chamberlain, Hrdlicka, White, Williams & Aughtry From forced accounting method changes, through targeted captives and conservation partnerships, to offshore activities, we will focus on the best way for accountants and lawyers to protect their anchor clients against tax liabilities and, failing that, penalties. Drafting and Revising Partnership and Acquisition Agreements in Response to the New Partnership Audit Rules Stephen A. Kuntz, Norton Rose Fulbright and Robert W. Phillpott, Baker Botts This presentation addresses the various areas of the new partnership audit rules, including what the significant changes are from the TEFRA rules; how these new rules will impact partnership agreements, such as the appointment and removal of the partnership representative and contractual limitations and obligations to be placed on the partnership representative; and how these new rules will impact acquisition agreements involving partnerships. The session also discusses drafting with respect to the imputed underpayment rules and the push-out election provision. Choice of Entity and Business Tax Planning under the 2017 Tax Act C. Wells Hall III, Nelson Mullins Riley & Scarborough Under the 2017 Tax Act, signed by the President on December 23, 2017, tax practitioners are required to deal with a new business tax landscape which could rival the changes brought about by the changes to the Internal Revenue Code in 1986, which repealed the General Utilities Doctrine, reduced tax rates across the board, and eliminated many deductions. Among other considerations, choice of entity decisions will require consideration of the need to accumulate capital at the corporate level compared with the desire to distribute income to owners, as well as the effective tax rate for owners of passthru entities in light of the 20% deduction for qualified business income (QBI). New expensing and accelerated cost recovery rules will encourage capital expenditures, and also make asset purchases more attractive to buyers than stock purchases. The limitation on business interest deductions will decrease the attractiveness of highly leveraged acquisitions, particularly private equity transactions. Earnings stripping strategies, involving payments to non-u.s. affiliates in multinational groups, will be impacted by the base erosion anti-abuse tax (BEAT) provisions, requiring a careful review of intra-group financing structures. In this session, Hall will explore the impact of the new tax legislation as of the date of the Institute, the effect of such changes on conventional business tax planning, and those areas requiring further guidance from the IRS and possible technical correction legislation from Congress. Networking Buffet Lunch 2018 UNC Tax Institute 2 April 26-27, 2018

4 Agenda Thursday, April 26 1:10-2:10 p.m. 2:20-3:20 p.m. 3:30-4:30 p.m. North Carolina Sales and Use Tax Updates Eric K. Wayne, Director, Sales & Use Tax Division, North Carolina Department of Revenue This presentation focuses on key sales and use tax laws enacted during the 2017 legislative session with specific emphasis real property transactions and repair, maintenance and installation services to property. The presentation also provides a brief overview of a number of technical sales and use tax changes that became law. The Morality of International Tax Planning Peter A. Barnes, Senior Lecturing Fellow, Duke Law, Senior Fellow, Duke Center for International Development and Of counsel, Caplin & Drysdale Legally, taxpayers can arrange their business operations to minimize income taxes. But, in recent years, multinational corporations have been sharply criticized for doing just that. Why? And why are individuals generally not criticized (or criticized to the same degree) when they take the same tax minimization steps that companies take? We will discuss the moral compass that guides international tax planning. The State of the IRS Nina E. Olson, United States Taxpayer Advocate, and head of the Office of the Taxpayer Advocate (NTA), Internal Revenue Service Nina Olson is the National Taxpayer Advocate, the voice of the taxpayer at the IRS and before Congress. Under her leadership, the Taxpayer Advocate Service helps thousands of taxpayers every year resolve problems with the IRS and addresses systemic issues affecting groups of taxpayers. Her Annual Report to Congress identifies serious problems facing taxpayers and recommends solutions. One of her most significant achievements has been the codification of the Taxpayer Bill of Rights by Congress in She has also established a series of International Conferences on Taxpayer Rights, bringing together government officials, scholars, and practitioners from dozens of countries to explore how taxpayer rights serve as the foundation for effective tax administration. In 2017, Olson received the ABA Tax Section s Distinguished Service Award and the Jules Ritholz Memorial Merit Award for outstanding dedication, achievement, and integrity in the field of civil and criminal tax controversies. Drawing from her 2017 Annual Report to Congress, Olson will talk about problems facing the Internal Revenue Service (IRS) and the implications of those problems for tax compliance and enforcement, including: IRS funding and personnel cuts; declining audit rates; and flawed implementation of congressional mandates requiring the use of private debt collectors and the denial of passports to certain U.S. citizens with large tax debts. She will also address possible solutions to these problems 2018 UNC Tax Institute 3 April 26-27, 2018

5 Agenda Friday, April 27 7:30 a.m. 8:00-10:00 a.m. 10:10-11:10 a.m. 11:20 a.m. - 12:20 p.m. 12:20-1:20 p.m. 1:20-2:20 p.m. 2:30-4:30 p.m. Registration Desk Opens Recent Federal Income Tax Developments Cassady V. Brewer, Associate Professor of Law, Georgia State University College of Law and Bruce A. McGovern, Professor of Law, South Texas College of Law Houston This session highlights significant court decisions, rulings, and statutory and regulatory federal income tax developments affecting taxpayers over the past twelve months. Current Developments in Transfer Taxation Sanford J. Schlesinger, Schlesinger Lazetera & Auchincloss The Reconciliation Act of 2017 (the 2017 Act ), which was enacted on December 22, 2017, included significant changes to the federal transfer tax regime and related income tax provisions. Mr. Schlesinger will review such transfer tax and related income tax developments, and will discuss how they impact estate, trust and income tax planning, and the administration of decedents estates. Moreover, Mr. Schlesinger will review other recent developments regarding estate, trust and transfer tax and income tax planning in North Carolina and other states. The Tax Reform Effort of 2017 A Look Back and a Look Ahead Jonathan G. Traub, Deloitte Tax Traub will review the tax reform bill enacted at the end of 2017, explore key components of it and the political and policy calculations that went into them, examine how it came together in a deeply divided political system, and look ahead to the prospects for further refinements. Networking Buffet Lunch What's Next in Washington and Raleigh for Nonprofits? Dianne Chipps Bailey, Robinson Bradshaw This session is a discussion of how legislative and regulatory changes may impact the nonprofit sector including private foundations, donor-advised funds and public charities. Gain a deeper understanding of both proposed and recently enacted legislation and how to best prepare your organization for success in light of new state and federal rules. The presentation will cover federal tax reform, state real property tax exemptions, nonprofit executive compensation, board governance, the Johnson amendment, and much more. The conversation promises to be lively and, as always, your questions and comments are welcome. A General Counsel's Tales from the Confessional - and Some Tips to Keep You Out of It (PR/Ethics) Christopher S. Rizek, Caplin & Drysdale As the General Counsel of a tax boutique law firm, Mr. Rizek routinely sees and hears about issues involving legal ethics, tax penalties, privilege, and potential malpractice exposure. In this presentation he will discuss the rules and regulations that typically apply, and offer practical real-world advice on how to approach common sensitive situations UNC Tax Institute 4 April 26-27, 2018

6 2018 Tax Institute Faculty David D. Aughtry Chamberlain, Hrdlicka, White, Williams & Aughtry. B.A., 1975, The Citadel; J.D., 1978, South Carolina; LL.M., 1982, Emory. Dianne Chipps Bailey Robinson Bradshaw. B.A., 1992, U.C. Berkley; J.D., 1995, Georgetown. Peter A. Barnes Senior Lecturing Fellow, Duke Law, Senior Fellow, Duke Center for International Development and Of Counsel, Caplin & Drysdale. J.D., 1980, Yale. Cassady "Cass" V. Brewer Associate Professor of Law, Georgia State University College of Law. B.S., Vanderbilt; J.D., Arkansas; LL.M., NYU. C. Wells Hall III Nelson Mullins Riley & Scarborough. B.S., 1970, NCCU; J.D., 1973, Duke. Stephen A. Kuntz Norton Rose Fulbright. B.B.A., 1977, North Texas; M.P.A., 1978, J.D., 1984, University of Texas. Bruce A. McGovern Professor of Law, South Texas College of Law Houston. B.A., 1984, Columbia; J.D., 1989, Fordham; LL.M., 1996, University of Florida. Nina E. Olson United States Taxpayer Advocate, and head of the Office of the Taxpayer Advocate (NTA), Internal Revenue Service. A.B., Bryn Mawr; J.D., NCCU; LL.M., Georgetown. Robert "Bobby" W. Phillpott Baker Botts. B.B.A., 1991, J.D., 1997, Loyola; LL.M., 1999, NYU. Christopher S. Rizek Caplin & Drysdale. A.B., 1979, Dartmouth; J.D., 1997, LL.M., 1982, Georgetown. Sanford "Sandy" J. Schlesinger Schlesinger Lazetera & Auchincloss. B.S., 1963, Columbia; J.D., 1966, Fordham. Jonathan G. Traub Deloitte Tax LLP. B.A., 1998, Haverford College; J.D., 1994, University of Virginia. Eric K. Wayne Director, Sales & Use Tax Division, North Carolina Department of Revenue. B.S., 1989, UNC-Wilmington UNC Tax Institute 5 April 26-27, 2018

7 General Information Registration Learning Objectives of the Tax Institute The Institute provides the perfect setting to meet practitioners from around the state. It s an opportunity to share ideas, exchange views, learn what others are doing, and obtain credit for continuing education. At the Institute, you will: Learn about federal, state and local tax developments. Explore the professional challenges and ethical dilemmas you may face in the profession. Obtain up-to-date analyses of state sales and use tax developments. Examine the potential affect federal tax and state tax reform will have on the profession. Register Online & Save Time: Online registration is available at and provides you with a quick and easy way to register for the Tax Institute. Take advantage of this online option and register today! MasterCard or VISA is required to register online. Registration Attorney/CPA Paralegal Registration $400 $300 *The registration fee includes a daily morning and afternoon breaks, lunches and parking. This is a paperless conference! Registrations will be accepted at the door on a spaceavailable basis. To check space availability, please contact the CLE Office before April 26 at unclawcle@unc.edu. Cancellations Cancellations received on or prior to March 15 will be honored and registration fees refunded. Cancellations received after March 15 but before March 15 will be honored and registration fees refunded, less a $75.00 charge for processing and unrecoverable expenses. Cancellations will not be honored after April 18. Confirmed participants who do not attend the program are responsible for the entire fee unless other arrangements have been made with the School of Law s director of continuing legal education at (919) Location: The Tax Institute will be held at the UNC Center for School Leadership Development on the UNC campus with free parking. Course Credit CLE Credit for Attorneys: The Tax Institute is accredited for 13 hours (includes 2.0 hours of ethics) under North Carolina State Bar Mandatory Continuing Legal Education requirements. CPE Credit for CPAs: The Tax Institute is recommended for 15.5 hours of CPE credit (includes 2 hours of ethics). UNC School of Law is registered sponsor (112618) with the National Association of State Boards of Accountancy (NASBA) for continuing professional education (CPE). CLE and CPE Credit in Other States: Please indicate states in which you would like to receive credit on your registration form, and we will assist in that process. Payment of out-of-state fees is the responsibility of the attendee UNC Tax Institute 6 April 26-27, 2018

8 Yes, please register me for the 2018 Tax Institute: Remember, online registration is available at No printing, no mailing, no postage! Immediate confirmation. What could be easier? Registration Information Please print the following information: Mr. Ms. Mrs. Dr. Judge Name: Firm/Company: Address: City, State: Daytime Phone: address: Name as you would like it to appear on nametag: I am a graduate of the UNC School of Law. I would like to receive CLE credit in North Carolina. Zip: Fax: I am not a graduate of the UNC School of Law. I would like to receive CLE Credit in the state of: My N.C. Bar number is: My Bar Number* is: *Please include your bar number, appropriate address, and any other needed information if attendance verification is required. Out of state bar reporting fees are the responsibility of the registrant. Occupation: Attorney CPA Paralegal Other: Payment Information Program Fees Attorneys/CPAs Paralegals Group Discount* Buddy Discount** $ $ $50.00 $ * GROUP DISCOUNT! Send 3 or more and save $50 on EACH registration. ** BUDDY DISCOUNT! Refer new attendee/s and receive $100 for each off your registration after the program. See website for full details! Referral name/s Total Enclosed $ To Pay by Check: Please send your registration form and a check made payable to UNC School of Law (please, no staples) to: CLE Office. You May Register: Online By Mail UNC School of Law Office of CLE 160 Ridge Road CB#3380 Chapel Hill, NC ATTN: Tax Registration If you have questions about registration or the conference, please contact the Carolina Law Office of Continuing Legal Education at (919) or by at unclawcle@unc.edu.