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Chamberlain Hrdlicka 46th Annual Houston Tax and Business Planning Seminar on Wednesday, November 1, 2023 at The Houstonian

November 1, 2023

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

The Houstonian, 111 North Post Oak Lane

Chamberlain Hrdlicka 46th Annual Houston Tax and Business Planning Seminar

Chamberlain Hrdlicka's 46th Annual Houston Tax and Business Planning Seminar will take place on Wednesday, November 1, 2023 at The Houstonian Hotel.

Anyone is welcome to register to attend. Self-parking is free.

If you would like to register to attend, please email Margaret Surette at Margaret.Surette@chamberlainlaw.com. 

There are no prerequisites for these courses.

Texas CLE: 5.0 credit hours
Texas CPE: 6.0 credit hours

Cost: $150 per person

*$175 per person for Walk-In Registration (if space allows)


11:00 a.m. - Registration begins

11:45 a.m. - 1:00 p.m. - Luncheon Presentation by Tom Cullinan, Chamberlain Hrdlicka Shareholder and former Acting Chief of Staff for the IRS Commissioner

1:05 p.m. - 5:30 p.m. - Presentations 

5:30 p.m. - 6:30 p.m. - Reception

Location - The Houstonian Hotel at 111 N Post Oak Lane, Houston, Texas 77024

Detailed Schedule:

Keynote Lunch Discussion: A Peek Behind the IRS Curtain, and the Future of IRS Enforcement 

Presenter: Tom Cullinan and Moderated by Managing Shareholder Larry Campagna

Tom Cullinan joined Chamberlain Hrdlicka's Atlanta office as a Shareholder from the IRS, where he served as the Counselor to the IRS Commissioner and then as the acting IRS Chief of Staff. While at the IRS, he was a member of the Commissioner’s core leadership team, advising on the IRS strategic plan and budget, staffing, internal operations, enforcement of tax laws and service to taxpayers. Tom was particularly involved in high-level enforcement issues, conceiving and/or helping launch the Office of Fraud Enforcement, the Office of Promoter Investigations, and the Joint Strategic Emerging Issues Team.

Prior to joining the IRS, Tom spent twenty years as a tax attorney, representing hundreds of taxpayers, including low-income individuals in pro bono matters, high net-worth individuals, partnerships, trusts and estates, and corporations in IRS audits, administrative appeals, and litigation, on a wide variety of tax issues often with significant amounts at issue.

Tom graduated from the State University of New York at Geneseo with a bachelor's degree in accounting, and the State University of New York at Albany with a master's degree in taxation. He earned his law degree from the Vanderbilt University School of Law. Recognized in the legal community, he's been named to Chambers USA, Legal 500 and Georgia Super Lawyers.


You may attend any presentation on a first-come, first-served basis as seating allows.

1A | Intra-Family Loans

Presenter: Ryan Carlock

Parents are often motivated to support one or more of their children in their various pursuits, such as buying a home or starting a business venture. This support is frequently provided in the form of a loan from the parent to the child, particularly when parents cannot afford to make overly generous gifts. However, intra-family loans can also be a simple and effective estate planning tool for wealthy parents to transfer assets to their children without gift tax implications. We will discuss intra-family loan basics for income and gift tax purposes, paying particular attention to transactions common in the family and estate planning context. We will also discuss some of the disadvantages and risks associated with intra-family loans and the income and gift tax consequences of debt forgiveness when an intra-family loan is later forgiven. Finally, our discussion will conclude with some advanced planning techniques including self-cancelling installment notes and Graegin loans.

1B | The Chronicles of Business Technology: The Compliance, The Glitch and The Regulations 

Presenter: Aly Dossa

As we immerse ourselves into a newer generation of data privacy and cybersecurity, the IT shields of the world we once knew have begun to show their wear and tear. New regulations in data privacy, groundbreaking innovations in artificial intelligence, and recent advancements in data security have allowed us to open the wardrobe and enter into a new digital world. The story of the information age is still ever-changing, but through its many crevices, we can learn it better so that we may better understand its implications for the future.

2A | Judicial Highlights 

Presenters: Alissa Gipson and Jonathan Stasney

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

2B | Unraveling the Web: Cross Border Joint Ventures

Presenters: Phyllis Guillory and Morgan Alleyn 

While LLCs and Partnerships are a preferred investment vehicle, their investment in foreign ventures can lead to surprising (and often expensive) tax and reporting consequences to their owners. This section will explore the rules that can impact U.S. owners of even small interests in entities that invest overseas. We will also focus on recent changes in the regulations that have flipped the entity versus aggregate rules in many cases, and further compounded these issues for U.S. owners.

3A | Tax Controversy ERC Update: The Latest from the Front Lines Involving IRS Challenges to Eligibility, More than Nominal Test, Applicable Governmental Orders, Supplier Delays, and Other Hot Topics Relating to the Employee Retention Credit 

Presenters: Juan F. Vasquez, Jr. and Tania Albuja 

The Employee Retention Credit (ERC), a popular COVID-19 relief measure, targets Congressional and taxpayers’ responses to the pandemic. This seminar discusses what tax practitioners need to know in 2023 and 2024 about the ERC. Our review will include commenting on front-end eligibility determinations, and how to be cognizant of the IRS audit issues as well as Appeals activity. Substantive review will include a discussion of IRS challenges to eligibility for the ERC, a review of the "more than nominal" test, a discussion of the applicability of Governmental Orders, Supplier Delays, the recent IRS Moratorium, and other relevant topics.

3B | Income Tax and Estate Planning for Person with Disabilities and Special Needs 

Presenters: Julie Edelman and Christine Borrett 

This presentation covers federal tax credits and deductions for disabled taxpayers along with property and ad valorem tax breaks for the disabled. We will also cover ABLE Trusts, and estate planning techniques for families supporting beneficiaries with special needs. We will discuss how popular estate planning techniques clash with a standard to supplement but not supplant need-based means-tested support for our family members who depend on us the most.

4A | The Corporate Transparency Act 

Presenters: Jack Najarian and Luz Villegas-Banuelos 

The Corporate Transparency Act (CTA) is a new law that is scheduled to go into effect January 1, 2024, and will require entities (LLCs, Corporations, LPs etc.), unless they qualify for an exemption, to disclose information about their beneficial owners with the Financial Crimes Enforcement Network (FinCEN). Failure to comply can result in civil penalties and criminal penalties (including jail time). Most privately held entities will not qualify for an exemption, and will need to comply with this new law. 

4B | Taxing Times in the Crypto World - What You Need to Know 

Presenters: Stuart Clements and Karl Jackson

Join us for a comprehensive exploration of cryptocurrency taxation in our presentation. In this illuminating session, we will demystify the intricate world of crypto taxation, helping you understand the essentials for responsible financial management in the digital asset realm. We will begin by addressing the fundamental classification of cryptocurrencies as property, setting the stage for a deeper dive into tax implications. Learn about the tax obligations associated with acquiring, holding, and trading digital assets, and discover how to manage your transactions efficiently to simplify reporting. Our presentation will also highlight the significance of accurate record-keeping, showcasing how it can be a valuable tool for tracking and managing your crypto-related tax obligations.