_SUPPORTING AICPA MEMBERS THROUGH TAX ADVOCACY AND IN THEIR TAX PRACTICES_ Blake Vickers, Chair of the AICPA's Tax Executive Committee, and the AICPA Tax Policy & Advocacy and the Tax Practice & Ethics Teams will discuss the AICPA's advocacy efforts regarding implementation of the Inflation Reduction Act of 2022 (IRA ’22) and the IRS Strategic Operating Plan and how the AICPA supported members with the new rules and provisions. The panel will also discuss other tax legislative initiatives, including extenders, the Form 1099K threshold, and section 174 research and experimentation costs treatment, as well as the AICPA proposed extension filing safe harbor, disaster tax relief efforts, ERC issues, and IRS service updates. Finally, the updated AICPA’s tax standards, the Statements on Standards for Tax Services (SSTSs), will be covered.

Learning Objectives:

• Determine the prospects for tax legislation for the remainder of the year, including extenders.
• Distinguish the IRS’ efforts to clear its processing backlogs before the upcoming filing season.
• Analyze the AICPA’s updated tax ethical standards – the Statements on Standards for Tax Services.
• Identify insights into possible 2025 tax legislative proposals and IRS continuing implementation of Inflation Reduction Act of 2022.
• Calculate the AICPA’s efforts to help members improve the efficiency of their tax practices.

Many of the tax changes put in place as part of the TCJA will be expiring next year. A full extension would cost trillions of dollars, letting them expire in full is likely a political non-starter. Furthermore, lawmakers will have to grapple with the return of the debt-ceiling, the expiration of the current spending caps, and the challenges in Social Security and Medicare’s trust funds. With an unsustainable fiscal picture, high levels of political partisanship, and a presidential campaign that has not included a plan to address any of these issues, none of these issues will be simple to resolve.

This presentation covers highlights of any 2024 federal tax legislative changes and tax form changes relevant to individuals, and the most important federal tax rulings of 2024 involving income, deductions, losses, digital assets and other property, credits, and procedural matters and their relevance to tax planning and compliance due diligence. Planning considerations for 2025 in light of upcoming TCJA changes will also be covered.

Learning Objectives:

• Analyze 2024 rulings that represent new legal interpretations for individual income taxation.
• Identify tax planning and compliance points from any 2024 federal tax legislation and key 2024 court cases, regulations and IRS rulings.
• Identify due diligence actions highlighted by 2024 individual tax law developments and upcoming TCJA changes.

In this session we will discuss the most common international information returns that apply to taxpayers with outbound and inbound activity. We will discuss the very steep penalties for failure to file and how to avoid the penalties if a taxpayer discovers they have some delinquencies. We'll also discuss abatement techniques where the IRS has already assessed penalties.

Learning Objectives:

• Identify the common international information returns and their filing requirements.
• Identify delinquent penalties for late international information returns and assessment procedures.
• Apply abatement techniques for penalties related to Forms 5471 and 5472.
• Distinguish the delinquent international information return submission procedures and other disclosure procedures.
• Apply abatement techniques for penalties related to Forms 3520 and 3520-A.

In this session, we'll discuss how the sunsetting of many TCJA provisions on December 31, 2025 will influence a taxpayer's choice of entity, and may well usher in a golden era of C corporations. 

Learning Objectives:

• Identify the changes to the tax law slated to take effect on December 31, 2025 and how they will influence a taxpayer's choice of entity.
• Recognize the key considerations a passthrough entity should take into account before converting to a C corporation.

An exploration of the many issues clients face in estate planning when estate taxes don’t really come into play because of the high estate tax exemption amounts. The tax and financial planning topics to be covered include the importance of lifetime documents such as health care proxies and powers of attorney, properly drafted wills, protecting inheritances with trusts, probate avoidance and beneficiary designation planning, long term care planning, and basis step up planning.

Learning Objectives:

• Identify the non-estate tax planning aspects of an estate planning engagement, including necessary lifetime and testamentary documents, and the importance of proper beneficiary designations.
• Analyze the various income tax and financial matters relevant to a client's estate plan including asset protection planning, probate avoidance techniques, income tax basis step-up strategies, and long-term care planning opportunities.

This presentation covers the most significant court decisions, federal tax regulations and IRS rulings of 2024 relevant to all types of businesses and entities. These developments involve deductions, accounting methods, property transactions, credits, and more. Highlights of any federal legislation enacted this year as relevant to businesses and federal tax form changes are also covered. Due diligence and planning ideas are emphasized throughout.

Learning Objectives:

• Identify tax planning and compliance points from any 2024 federal tax legislative changes, significant court cases, regulations, and IRS rulings.
• Analyze 2024 rulings that represent new legal interpretations for taxation of businesses.
• Identify due diligence actions to take based on 2024 tax law developments and upcoming Tax Cuts and Jobs Act (TCJA) changes.

The IRS is using increased funding it received under the Inflation Reduction Act of 2022 to increase enforcement, including increasing audits of partnerships.  Changes in the IRS' organization along with increased hiring of agents and improved training on partnership tax contribute to an increased likelihood of a partnership audit.  The centralized partnership audit regime enacted under the Bipartisan Budget Act of 2015 (BBA) is complex.  This panel will discuss the changes at the IRS and provide tips to prepare for and navigate a BBA partnership audit.

Learning Objectives:

• Recognize the changes at the IRS that increase the likelihood of a partnership audit.
• Identify the steps in the BBA partnership audit process.

Generative AI tools such a ChatGPT and Microsoft 365 Copilot are being used to boost the efficiency and quality of tax services. This session will provide practical examples of how you can put the power of this technology to use in your tax and accounting services today. Every CPA, whether in public accounting or working in private industry, should have a fundamental understanding of ChatGPT and generative AI applications more broadly. This session will provide you with a foundation of knowledge that will prepare you to leverage this technology to increase your personal productivity.

Learning Objectives:

• Recognize the key concepts and nomenclature related to generative AI technology
• Identify opportunities to leverage the power of ChatGPT and Microsoft 365 Copilot in your tax and accounting services

As we navigate the post-SECURE 2.0 landscape, CPAs play a crucial role in advising clients, ensuring compliance, and maximizing retirement benefits. Join us to explore these developments and chart the path forward for retirement planning.

This session will provide an overview of new mandatory features (including automatic enrollment provisions and required minimum distribution changes) as well as optional provisions (including student loan payment matching and new distribution options), as well as future changes to the SAVER’s credit.

Learning Objectives:

• Analyze important provisions in SECURE 2.0 impacting plan design and operations
• Identify mandatory and optional changes and how best to consider for your clients.

The Corporate Transparency Act (CTA) went into effect January 1, 2024. Since that time, millions of entities have made their initial filings, though millions more filings were expected given the January 1, 2025, initial filing deadline. This session will briefly review what is required under the CTA, will explore the impact of Financial Crimes Enforcement Network’s (FinCEN) newly issued FAQ and recent case law, and will walk through some of the more complicated ownership structures that FinCEN has yet to address.

Learning Objectives:

• Identify the filing requirements of the Corporate Transparency Act and their deadlines
• Analyze the impact of recent court filings and FinCEN's FAQ
• Apply the Corporate Transparency Act to fact patterns involving trusts and other ownership structures

In this interactive session, participants will engage in a series of quizzes designed to challenge and enhance their understanding of tax ethics. Using real-world dilemmas, the session will explore key principles from the AICPA Statement on Standards for Tax Services (SSTSs) and other essential tax ethics resources. Attendees will gain insights into ethical decision-making processes and access valuable resources to navigate complex tax situations with integrity and professionalism.

Learning Objectives:

• Identify and analyze common ethical dilemmas in tax practice, referencing the AICPA SSTSs and other authoritative tax ethics guidelines.
• Apply critical thinking skills to help make informed and ethical decisions in various tax scenarios.
• Identify best practices to support ethical conduct in their tax practices.

A number of significant provisions are set to expire after 2025. Although Congress may act to extend some or all of them, what should you know to prepare taxpayers and maximize on tax planning opportunities?

Learning Objectives:

• Recall tax provisions that are set to expire after 2025.
• Identify the implications of expiring tax provisions and resulting tax planning opportunities.

To be top .1% in 2023, a household needed a net worth of $61,827,166. How does planning for those with $62M and above differ from clients with lesser wealth? The reciprocal trust doctrine, DAPTs, hybrid-DAPTs, or SPAT should not be necessary. Or should they be? What types of planning techniques should be considered? How can, for example, planning using a technique like a note sale transaction be enhanced to potentially provide a greater chance of success and to better deflect an audit challenge? Steps like independent counsel, escrow arrangements, and alternate techniques for each transaction (e.g., use a different spillover receptacle in each transaction). How can clients with scores of entities more practically handle documentation? How to address Powell/Moore issues that a Wandry or Christiansen defined value mechanism might introduce. Disclaimer provisions in trusts, spillover to sub-trusts for the grantor and more. Income tax planning for non-grantor complex trusts. What might CCA 202353018 mean to a client’s renunciation of a DAPT or hybrid-DAPT interest? The impact of tax proposals like the American Housing and Economic Mobility Act of 2024 could be especially devastating. And more…

Learning Objectives:

• Identify how larger wealth transactions can be handled with more sophisticated techniques that may enhance the plan’s potential for success.
• Apply variations of planning techniques into components of a complex large estate transfer.
• Use one planning approach to address state pass-through business alternative income tax (BAIT)/pass-through entity tax (PTET) programs, Powell, and estate inclusion.
• Identify techniques to consider incorporating into complex trust plans.

This session provides an exploration of tax planning strategies specifically tailored for real estate investments and partnerships. Attendees will gain insights into the latest tax laws, deductions, and credits that can optimize their financial outcomes. Key topics include the benefits of cost segregation, 1031 exchanges, and the intricacies of partnership taxation. This session will equip you with the knowledge to make informed decisions and maximize your tax efficiency.

Learning Objectives:

• Determine the benefits of cost segregation in real estate investments
• Identify opportunities for basis adjustments
• Compare different opportunities for tax deferral in real estate disposals

In today’s competitive landscape, attracting and retaining top talent is a critical challenge for CPA firms. As the accounting industry evolves, younger CPAs are essential for driving growth, innovation, and client satisfaction. This dynamic session will delve into proven strategies to attract, nurture, and retain the best accounting professionals. Attendees will gain insights from industry leaders and educators on what the next generation of CPAs seeks in an employer.

Learning Objectives:

• Identify key strategies for talent acquisition including understanding what younger CPAs are seeking in an employer.
• Analyze retention programs that nurture and retain top accounting professionals.
• Determine alternative talent pathways and hear ways to develop partnerships with educational institutions and tap into non-traditional candidate pools.

Increasingly companies are hiring employees or engaging the personal services of individuals in remote locations across the U.S. and the world.  These remote hires can cause surprising consequences to the companies hiring them.

This session will cover the challenges arising in meeting the complex and sometimes contradictory international, state, and local income, corporate and sales tax responsibilities when employees are allowed to work outside of the office.

Learning Objectives:

• Identify the state, local and international tax issues that may arise when hiring remote individuals
• Distinguish the steps that a company can take to avoid the unintended consequences of remote employees

New developments affecting estate and related planning have been issued at a furious pace that has made absorbing the changes into practice challenging, if not impossible. This session will review a few of the many recent developments and how they affect estate and related planning. The FTC Ban on non-compete agreements may devastate succession planning for many closely held and family businesses. The Supreme Court’s decision in Connelly requires that every insurance-funded redemption buyout arrangement be revisited, and insurance LLCs may not solve the issues. The Supreme Court’s decision in Loper has changed the dynamic of interpreting Treasury regulations, and practitioners should evaluate when filing protective claims for refunds are appropriate. Meanwhile, proposed regulations on transactions with foreign trusts and the receipt of large foreign gifts provide rules re-characterizing of certain transactions that may result in additional taxation and imposes new information reporting requirements. The Corporate Transparency Act and recent state bar opinions on UPL must be addressed. The decisions and steps required are especially complex for clients with trust-owned entities that are reporting companies. What new drafting techniques may affect income tax advice and compliance for non-grantor trusts? Estate and trust compliance and planning is more litigious than ever. Today’s malpractice environment is worrisome. What can practitioners do? Trust modification or change by any means may be under attack by the IRS based on a recent CCA. Is the day of easy decanting ending? Formalities count – the Connelly, Sorensen, Levine and Smaldino cases drive this point home. Practitioners need to guide clients to focus on proper administration of plan details. And more……

Learning Objectives:

• Analyze how several recent Supreme Court cases may affect practitioners in daily estate planning practice.
• Identify practical lessons key cases over the past several years teach about the often-ignored issues of proper administration of trusts and plans and the unique role the CPA can serve.

Generative AI, including large language models like GPT-4, is reshaping

the landscape of tax research and professional practice. This session will explore the ethical

challenges involved in adopting AI tools in tax work, covering areas such as accuracy, bias, and

data privacy. Attendees will gain practical insights into mitigating these risks while using AI tools

to improve efficiency and maintain compliance with evolving ethical standards.

Learning Objectives:

• Understand the challenges associated with the use of generative AI in tax research, including accuracy and bias concerns.
• Explore privacy and regulatory considerations in AI adoption for tax professionals.
• Learn practical strategies to integrate AI tools into tax practices while maintaining ethical standards.

This session will provide the statutory and regulatory authorities controlling employees taxable income inclusion using common real life examples of the corporate jet, automobiles, and other corporate assets. In addition, it will cover the tax deduction to the employer, often less than the employee income inclusion but more when bonus depreciation was taken.

Learning Objectives:

• Calculate the correct income inclusion to the employee for use of the corporate jet, automobile, or other corporate asset.
• Calculate the correct tax deduction for the employer for use of the corporate asset including the entertainment disallowance.

The Bipartisan Budget Act of 2015 (BBA) introduced significant changes to partnership audits and making adjustments to partnership returns. As tax professionals, understanding the intricacies of the BBA is crucial for accurate compliance and effective representation. In this session, we’ll delve into the process of preparing Administrative Adjustment Requests (AARs) under the BBA, with a focus on practical steps, challenges, and best practices.

Learning Objectives:

• Identify the purpose of an Administrative Adjustment Requests (AAR)
• Identify unique challenges in preparing an AAR
• Identify how to file an AAR

We will walk through a case study and review the process and steps to take when a client dies. We will cover the more practical aspects of the process as well as the more complex tax planning and elections that can be made at death.

Learning Objectives:

• Identify the first steps to take when a client dies.
• Identify important tax deadlines to be aware of.

The Infrastructure Investment and Jobs Act of 2021 expanded broker reporting of IRC Section 6045 to include digital assets. This reporting will start for 2025 and final regulations were issued in June 2024. This presentation covers the highlights of the final regulations, two notices and a revenue procedure released in June that address reporting for 2025 and later changes, transitional guidance, and basis adjustments to reconcile basis tracking of the virtual currency FAQs versus basis rules included with the broker reporting regulations and new Form 1099-DA. Recordkeeping and other due diligence requirements will be a focal point including the additional time your clients and you will need to take to ensure proper reporting because not all digital asset transactions will have a 1099-DA and the forms received will need to be reconciled to taxpayer records.

Learning Objectives:

• Identify the basic approach of the digital asset reporting regulations including who is a broker, what is reported and how, and determination of amount realized and basis.
• Recognize what will be reported on Form 1099-DA and what transactions involving digital assets will not be reported on a 1099-DA and the importance of clients maintaining excellent records of all digital asset transactions.
• Identify a tax preparer's due diligence actions needed to help clients with digital asset transactions prepare a proper tax return.

If you've read any of the IRS's press releases over the past two years, you should already be familiar with the IRS's top 3 enforcement targets: high net worth individuals, complex partnerships, and large corporations.  Come hear from a panel of experienced tax controversy professionals about how the IRS is deploying the $60 billion in additional funds it received under the Inflation Reduction Act and how those resources are being used in the IRS enforcement space.  We will discuss the trends we're seeing in audit and issue selection, and the new methods the IRS is employing to identify and collect unpaid taxes.

Learning Objectives:

• Identify IRS enforcement strategic objectives.
• Recognize the preparation needed to navigate an IRS large business audit in the new environment.

Utilize an individual tax return to find extraordinary opportunities by identifying additional revenue. This series guides the practitioner through planning opportunities that are in an individual tax return. This session will provide tools, strategies, and concepts to leverage in your income tax practice to perform PFP services.

Learning Objectives:

• Identify areas of planning and implementable solutions.
• Differentiate reactive compliance work from proactive planning value and revenue.
• Recognize ways to convert your tax practice into a high value PFP advisory business.

Starting with years beginning on or after January 1, 2022, the treatment of research and experimental expenditures has changed drastically from prior years. We will review the changes under the new code section 174, review the interim guidance under Notice 23-63 in September 2023 and Notice 24-12 in December 2023, and discuss new developments and strategies resulting from the changes.

Learning Objectives:

• Identify the change in law and reporting requirements starting with years beginning on or after Jan 1, 2022
• Distinguish the IRS interim guidance issues after implementation of the law

In this session, Tony Nitti will discuss all you need to know about one of the most powerful incentives in the Code — the "qualified small business stock" exclusion of Section 1202 —but with a twist: Nitti will use Section 1202 as an example of how you can use the process of learning, writing and teaching about a topic to make your career more rewarding and enjoyable.

Learning Objectives:

• Identify the corporate and shareholder level requirements that must be satisfied for stock to meet the definition of qualified small business stock.
• Apply the process a tax professional can use to gain mastery over a subject.

Trusts are an important tool for estate planning. They can expedite the distribution of assets, maintain privacy, and provide greater control and flexibility over how your assets are managed. They can also offer asset protection, facilitate charitable giving, and help minimize estate taxes for your family members. This presentation will provide an overview of the various types of trusts, including both revocable and irrevocable trusts.

Learning Objectives:

• Identify the parties involved with a trust - settlor, trustee and beneficiary.
• Distinguish the different types of trusts and the purposes for which they are formed.

Most tax practitioners will, at some point in their careers, find themselves advocating for a client before the IRS or other taxing authority. This session will share tips and tricks on how to best communicate with the IRS to achieve your clients’ goals, as well as warning signs that it may be time to bring in a specialist. The discussion will also include a review of the ways that taxpayers and representatives can communicate with the IRS electronically/online to avoid the perils of mailing correspondence.

Learning Objectives:

• Identify best practices for communicating with the IRS in advocacy situations
• Recognize how to leverage IRS online communications options and navigate the IRS "roadmap"

This session pertains to whether a partner in a partnership must include net business income / (loss) in net earnings from self-employment (NESE).  In particular, this session will focus on the exclusion of income / (loss) from NESE under section 1402(a)(13). 

Learning Objectives:

• Distinguish the history of IRC section 1402(a)(13)
• Identify the litigation position of the IRS in recent cases

In today’s dynamic tax environment, staying ahead requires more than just seasonal tax preparation. This session is designed to provide tax practitioners with innovative strategies to enhance their practice by incorporating year-round tax advisory services. Attendees will learn how to leverage resources and tools to foster proactive client conversations, ultimately leading to improved client satisfaction and practice growth. Join us to discover actionable ideas and best practices that will transform your tax practice into one with comprehensive advisory services.

Learning Objectives:

• Identify key strategies for year-round tax advisory services including understanding the benefits of offering year-round services.
• Apply effective client communication techniques, including examples of how proactive planning has provided savings.
• Apply techniques to enhance practice efficiency and client satisfaction.
• Analyze best practices and success stories for integrating advisory services.