ALI-ABA Topical Courses Income Tax Provisions of the New Federal Legislation January 18, 2011 Telephone Seminar/Audio Webcast

Transcription

1 ALI-ABA Topical Courses Income Tax Provisions of the New Federal Legislation January 18, 2011 Telephone Seminar/Audio Webcast PROGRAM SCHEDULE FACULTY PARTICIPANTS FACULTY BIOGRAPHIES STUDY MATERIALS TABLE OF CONTENTS Page ix Tax Legislation Congress Extends the Bush Tax Cuts 1 By Jerald David August and Bryan P. Collins 2010 Tax Legislation Congress Extends the Bush Tax Cuts 2 The Tax Relief Unemployment Insurance Reauthorization and Job Creation Act of Expensing & Bonus Depreciation 5 Partial Payroll Tax Holiday 11 Estate, Gift, & GST Taxes 13 Foreign Tax Changes 23 Individual Income Tax Relief 26 Extenders 34 A Measure of Certainty for Now 46 xi xiii vii

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3 PROGRAM SCHEDULE January 18, 2011 Program Schedule Eastern Central Mountain Pacific Alaska Hawaii Program Begins 1:00 p.m. 12:00 p.m. 11:00 a.m. 10:00 a.m. 9:00 a.m. 8:00 a.m. Adjournment 2:00 p.m. 1:00 p.m. 12:00 p.m. 11:00 a.m. 10:00 a.m. 9:00 a.m. Just signed into law on December 17, The Tax Relief Unemployment Insurance Reauthorization and Job Creation Act of 2010 is extremely complicated, with numerous income tax incentives and rate changes. But this one short seminar will give you the framework for understanding the new law and how it affects your clients. Just as important as what is in the legislation is what is not in the package. Invest just one hour from the convenience from your office or anywhere you have a phone or internet connection (choose audio webcast or phone format) to hear a concise analysis of the new law by two of the nation s leading tax lawyers. Program Schedule All Times Eastern Daylight 1:00 pm Program begins 2:00 pm Adjournment Total 60-minute hours of instruction: 1.0; Total 50-minute hours: 1.2 Suggested Prerequisite: Significant experience in taxation. Educational Objective: Acquisition of knowledge and skills to develop proficiency as a practitioner; maintenance of professional competence as a practitioner; provision of information on recent legal developments. Level of Instruction: Intermediate ix

4 Nothing in this program, the program materials, or communications stemming from the program (including questions and answers) should be considered as the rendering of legal advice. Non-lawyers should seek the advice of a licensed attorney in all legal matters. Registrants/readers should assure themselves that these presentations/materials/communications are still current and applicable at the time they are delivered or read. Neither ALI- ABA nor the speakers/authors can warrant that these presentations/ materials/communications will continue to be accurate, nor do they warrant them to be completely free of errors when delivered/published. Registrants/readers should verify statements before relying on them. These presentations/materials/communications reflect the viewpoints of their speakers/authors and do not necessarily express the opinions of ALI-ABA Continuing Professional Education or its sponsors. The members of this program's faculty are contributing their services to further the continuing legal education of their fellow members of the Bar. x

5 ALI-ABA Topical Courses Income Tax Provisions of the New Federal Legislation January 18, 2011 Telephone Seminar/Audio Webcast PLANNING CHAIR & MODERATOR Jerald David August, Esquire Fox Rothschild LLP 222 Lakeview Avenue, Suite 700 Esperante Building West Palm Beach, Florida & Philadelphia Office 2000 Market Street 20th Floor Philadelphia, Pennsylvania FACULTY Bryan P. Collins, Esquire Washington National Tax Deloitte Tax LLP th Street, N.W. Suite 500 Washington, DC xi

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7 Jerald David August, West Palm Beach, FL Fox Rothschild LLP FACULTY BIOGRAPHIES Co-chair of the firm's Tax & Estates Department, Jerry practices out of the Philadelphia and West Palm Beach offices. His nationally recognized taxation experience includes: federal tax matters, including corporate and partnership taxation federal transfer taxation tax litigation and tax controversy, including trials before the United States Tax Court and appeals before the Eleventh Circuit Court of Appeals corporate and partnership taxation estate planning for owners of closely-held businesses international taxation (inbound and outbound) For three consecutive years, Jerry has been named as one of the leading tax attorneys in Florida by Chambers USA. Beyond Fox Rothschild Jerry represented the Tax Section of the Florida Bar Association before the U.S. Supreme Court in Estate of Hubert v. Commissioner. He also has served as adjunct professor, University of Miami Law School, and as visiting professor, University of Pittsburgh School of Law and the Graduate Tax Program, University of Florida School of Law. Jerry maintains his full-time residence in Jupiter, Florida, and a part-time residence in Haverford, Pennsylvania. Client Resources Federal Taxation Developments Blog Join nationally recognized tax attorney Jerald David August as he discusses recent tax legislation, regulations, rulings and case law developments have resulted in a significant amount of new information that can substantially impact taxpayers. Professional Accomplishments Jerry has published extensively on federal taxation and lectured at leading tax institutes. For a list of such articles, presentations and other professionals accomplishments, go to Honors and Awards Named "West Palm Beach Tax Lawyer of the Year," by Best Lawyers (2011) Named as one of the leading tax attorneys in Florida, Chambers USA (2008, 2009 and 2010) Selected as a "Super Lawyer" in the field of Tax by Super Lawyers Magazine (Corporate xiii

8 Counsel Edition) (2009) Selected as a "Super Lawyer" by Law & Politics Magazine (2009 and 2010) Martindale-Hubbell "AV" rated For more than ten years, selected for inclusion in "The Best Lawyers in America" for Tax Law and Trusts & Estates Selected as a "Super Lawyer," as well as a "Top 100 Florida Lawyer," by Law & Politics Magazine (2007) Bryan P. Collins, Washington, DC Washington National Tax Deloitte Tax LLP Mr. Collins is a partner in Deloitte s Washington National Tax Office. Mr. Collins' responsibilities include providing firm-wide consultation regarding consolidated returns, mergers, acquisitions, spin-offs, bankruptcies, and corporate restructurings. Mr. Collins has extensive experience in complex mergers, acquisitions, bankruptcies, and spin offs by public companies, having been the lead tax specialist on a significant number of large transactions. Mr. Collins has been a frequent author on Federal income tax matters; his articles have appeared in a number of publications, including Tax Notes, the New York University Institute on Federal Taxation, and the Journal of Corporate Taxation. He is an Adjunct Professor in the LL.M program at Georgetown University, where he teaches Consolidated Returns -- Principles and Planning. He also has been a frequent speaker on a variety of Federal income tax subjects at conferences such as the Southern Federal Tax Institute, the Practicing Law Institute Tax Conference on Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings, and the ALI-ABA Consolidated Tax Return Conference, among others. From 1986 to 1989, Mr. Collins served as Attorney-Advisor in the Office of the Tax Legislative Counsel, U.S. Treasury Department. In this position, he advised the Assistant Secretary (Tax Policy) regarding legislative proposals and administrative guidance. His substantive areas of responsibility included consolidated returns, C and S corporations, publicly traded partnerships, and oil and gas. He worked extensively on a variety of regulations projects, including regulations on spin-offs (Section 355), the built-in gain tax (Section 1374), and numerous consolidated return subjects. Education B.B.A Accounting, University of Texas, Highest Honors J.D. University of Texas, Order of the Coif L.L.M Taxation, New York University Professional Affiliations xiv

9 American Bar Association (Tax Section), Past-Chair Affiliated and Related Corporations Committee and S Corporations Committee D.C and Texas State Bar Associations Certified Public Accountant (AICPA, DC, and Texas) xv

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