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Chamberlain Hrdlicka 38th Annual Atlanta Tax and Business Planning Seminar on Wednesday, November 29, 2023

November 29, 2023

Chamberlain Hrdlicka Annual Tax and Business Planning Seminar will present a variety of important and timely topics

Westin Perimeter, 7 Concourse Pkwy, Atlanta, GA

Chamberlain Hrdlicka's 38th Annual Atlanta Tax and Business Planning Seminar will take place on Wednesday, November 29, 2023 at The Westin Perimeter. Anyone is welcome to register to attend. 

There are no prerequisites for these courses.

Georgia CLE: 5.0 credit hours
Georgia CPE: 5.0 credit hours


11:00 a.m. - 12:00 p.m.  Registration 

12:00 p.m. - 12:50 p.m. Luncheon Presentation

1:00 p.m. - 5:00 p.m.  Presentations 

5:00 p.m. - 6:00 p.m.  Happy Hour Reception

Location - The Westin Perimeter, 7 Concourse Pkwy, Atlanta, Georgia, 30328

Cost: $75 - Registrations, $100 - On-site Registrations, $125 Virtual attendance, register by 11/21/23 

12:00 - 12:50 PM - Judicial Highlights - Keynote and Lunch by David Aughtry 

A timely review of the past year's most significant court decisions on federal and state tax issues. 

1:00 - 1:50 PMDr. Jekyll? Mr. Hyde? What to Do When Estate Plans Go Awry

Presenters: Scott M. Ratchick, Stephen C. Heymann & Emily A. Dabney

There are numerous unquestionable benefits to sophisticated estate planning for all, but particularly for high net worth clients. Such benefits include the orderly arrangement of a family’s financial affairs and the ability  successive generations for the responsible stewardship of inherited wealth…not to mention the potential to save millions in income and estate tax liabilities. But what happens when well-meaning estate plans morph into a horror story?
This presentation will explore the good, the bad, and the ghastly sides of estate planning, or the lack of it, from a planner’s perspective and from a civil litigator’s perspective. The speakers will provide insight into common scenarios where planning can go awry and how to minimize or avoid the potential for dispute. Should a dispute arise, the speakers will provide insight into navigating negotiations for settlement and litigation based on decades of experience in the field.

2:00 - 2:50 PM Structuring Successful Succession

Presenters: J. Scot Kirkpatrick, Mark Lubin, Robert J. Waddell & Steven M. Wyatt

While tax planning often drives many clients as they engage and work with estate planning counsel, there is no success without a successor. Undoubtedly, sound tax planning remains a prerequisite for effective transfer of the family business or significant family-owned assets to the next generation. But, for clients with a family business or significant family-owned assets, successfully transferring wealth to the next generation also depends on establishing proper governance structures within the owned entities and trusts. Effective governance both facilitates the efficient and orderly transfer of wealth and control to the next generation and puts the next generation in the best position to survive and thrive as successor family business owners or inheritors of life-changing wealth.

Through case studies that highlight common challenges and opportunities faced by many business owners and other high-net-worth people, this presentation will illustrate the importance of incorporating proper governance into trusts and family business entities.

3:00 - 3:50 PM TEFRA Leaves Us Feeling BBA'ad

Presenters: John W. Hackney, Cassandra S. Bradford & Samuel H. Grier

Dad jokes aside, Congress replaced the TEFRA partnership audit procedures with the Bipartisan Budget Act of 2015(“BBA”). Although taxpayers could elect to have it apply early, the BBA partnership audit procedures apply beginning in 2018. The first BBA partnership audits have reached their conclusion. These audits raise a series of tough questions facing taxpayers: Who should serve as partnership representative or designated individual? What is a modification request? When does a partnership make a push-out election and what does it mean? How do I account for any adjustment and when? This speech will discuss these important procedural topics from tax attorneys who have been helping their clients grapple with these very questions.

4:00 - 4:50 PM - The Tax Man Cometh - What Increased IRS Enforcement Means for Taxpayers and Their Advisors

Presenters: Tom A. Cullinan, Jasen D. Hanson & John H. Kirbo

The Inflation Reduction Act earmarked $80 billion over the next 10 years for enforcement activities at the IRS. Even with the recent debt ceiling $20 billion reduction in that funding, the Service has made clear that it plans to use those funds to target high-net-worth individuals, large corporations, and pass through entities. This development, along with the establishment of the Office of Promoter Investigations at the IRS, make it clear that Taxpayers and their advisors can expect increased scrutiny from the Service over the next several years. This seminar will discuss considerations professional advisors should take into account when advising their clients on potential transactions, including their own potential liability.