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Chamberlain Hrdlicka Brownsville Tax and International Business Planning Seminar - May 25, 2023

May 25, 2023

Chamberlain Hrdlicka Brownsville Tax and International Business Planning Seminar at the Rancho Viejo Resort & Country Club on May 25, 2023

Chamberlain Hrdlicka Brownsville Tax & International Business Planning Seminar

Chamberlain Hrdlicka's Brownsville Tax and International Business Planning Seminar will take place on Thursday, May 25, 2023 at Rancho Viejo Resort & Country Club. Anyone is welcome to register to attend.


8:30 - 9:00 am - Registration 

9:00 am - 5:00 pm - Seminar (Lunch is included)

5:00 - 6:00 pm - Happy Hour Reception 

Location - Rancho Viejo Resort & Country Club at 1 Rancho Viejo Dr, Rancho Viejo, TX 78575

9:00 – 9:50 AM - Tax Controversy and IRS Enforcement Update

Presenters: Leo Unzeitig & Jaime Vasquez

Discussion regarding current IRS examination practices and priorities. We will cover the tax issues currently being raised in exam, how to defend them, and how to preserve a case for trial. Also included will be a discussion regarding the IRS’ increasing use of penalties.

10:00 – 10:50 AM - Monetizing Carbon Capture Initiatives with Section 45Q Tax Credits

Presenters: Tania AlbujaStuart Clements 

Section 45Q provides tax credit incentives to encourage companies to invest in carbon capture and storage solutions that reduce carbon emissions to the atmosphere as an initiative to combat climate change. This seminar provides an overview of the Section 45Q tax credits, including details about how carbon capture works, eligibility issues, and how the tax credits could improve the profitability of a taxpayer's operations by implementing carbon capture projects and claiming Section 45Q tax credits. This seminar also addresses the implications of the Inflation Reduction Act’s energy- and climate-related tax provision over Section 45Q (including higher credit amounts, a later beginning-of-construction deadline of before Jan. 1, 2033, and lower annual capture requirements).

11:00 – 11:50 AM - Crossing the Border: Relevant Issues and Planning 

Presenters: Sebastien Chain Ryan Reneau

This course will discuss the income and estate tax planning related to MX nationals moving to the United States, as well as multi-generational families with US and MX persons in the generational chain. Topics will include residency for US tax purposes, entity classification issues, gift tax and estate tax planning prior to and after obtaining residency on different types of assets (i.e., securities, real estate, closely held business interests, life insurance, etc.), and the use of both US and foreign trusts to accomplish long term planning.

12:00 – 12:50 PM Keynote Lunch Speaker Discussion - Texas State Taxes: Procedures and Updates 

Presenters: Justice David Medina & Daizia Williams

Discussion regarding various types of Texas state tax cases, procedural process of Comptroller audits and beyond, advocating for clients during the audit, and how to preserve clients’ rights and available remedies for the administrative process that ensues once an audit is finalized. We will also briefly discuss the new ‘Wayfair’ sales tax laws in Texas.

1:00 – 1:50 PM - Navigating the Tax Consequences and Audit Risks Associated with the Employee Retention Tax
Credit (ERTC)

The Employee Retention Credit (ERC), a popular COVID-19 relief measure, is at the center of many taxpayers’ responses to the pandemic. This seminar discusses what tax practitioners need to know in 2023 about the ERC. Substantive focus includes the ERC eligibility requirements and related issues such as affiliation rules, the alternative quarter election, and potential liability. This presentation also addresses the recognition, treatment, timing issues unique to each measure, and audit and appeals issues.

Presenters: Juan F. Vasquez, Jr., Tania Albjua & Victor Viser 

2:00 – 2:50 PM - Advising the Cross-Border Family with International Businesses & Investments (More than Subtitle A & B) 

Cross-border families and businesses often neglect the Mexican legal and tax consequences of their investments and how best to plan for the succession of these assets to subsequent generations. The discussion will cover specific Mexican legal and tax law consequences including specific information reporting requirements under United States laws. How and when to advise a client of their need for a cross-border legal and international tax expert advisor. Finally, a detailed discussion of how those individuals who hold lawful permanent residency status (a “green card”) living in Mexico can cause adverse tax consequences for themselves. Avoiding the “oops did I expatriate” moment for U.S. federal tax purposes? Planning strategies to live a less costly life and operate a more profitable business. Saving Taxes!

Asesorando a Familias Transfronterizas con Inversiones y Negocios Internacionales ((Mas Allá del Subtitulo A y B)

Esta discusión va analizar las consecuencias legales y fiscales mexicanas específicas, así como declaraciones informativas que deben presentarse de conformidad con las leyes de los EUA, para familias y negocios transfronterizos. Como y cuando asesorar a su cliente de la necesidad de un asesor especializado en materia transfronteriza y fiscal internacional.

Tome nota: Este panel será presentado en español.

Presenters: Patrick W. Martin, Anuar Estefan, Luz Villegas-Banuelos, & Roberto Teuffer

3:00 – 3:50 PM - Current Tax Issues of Theft Losses, Fraud, Settlements and Judgments

The speakers will discuss the impacts that the Tax Cuts and Jobs Act (TCJA) and COVID have had on the availability of a theft loss under IRC 165. The interplay has become more relevant with the revelation of recent investor and client fraud cases. For individuals claiming a loss not associated with a trade or business or a transaction entered into for profit, the limitations can be significant. The speakers will discuss alternatives and outline the facts and circumstances where there may be some silver lining (for tax purposes at least), as well as the taxation of settlements and judgments and the related impact of the TCJA on deductions for attorney fees.

Presenters: Katherine Noll & Jaime Vasquez 

4:00 – 4:50 PM - Big Brother Is Still Watching You: An Overview of the Disciplinary Regime Bearing Upon Tax Practitioners

A presentation reviewing the ethical and disciplinary environment for busy tax professionals, including an overview of Circular 230 and the three-level disciplinary regime in which tax practitioners practice their profession.

Presenter: David N. Calvillo

Texas CPAs: 8.0 hours of CPE credit hours

Texas Attorneys: 6.75 CLE credit hours

There are no prerequisites required for this Tax Seminar