2008 AIFT Schedule
Wednesday, June 18th
8:30am-10:15am	Recent Developments in Estate and Gift Tax and Estate Planning – This is a review of recent cases, rulings, and other developments with respect to the estate, gift, generation-skipping and fiduciary income taxes and a discussion of their impact on estate planning and administration.Among the topics to be covered are the marital deduction; gifts; valuation issues; using family limited partnerships and limited liability companies; retirement benefits; charitable giving; asset protection; fiduciary income tax; fiduciary liability; and insurance.	Charles D. Fox IV
10:30am-12:00pm	Charitable Contribution Tax Strategies … Avoiding Bad Heir Days and Near-Death Tax Experiences – You’ll learn: how to choose wisely among the four types of charitable remainder unitrusts and when to use an annuity trust; the tax consequences of terminating an existing charitable remainder trust and giving the life interest to the charitable remainder organization or dividing the trust assets between the life beneficiary and the charity; and how to patch up defective trusts by reformation, disclaimers and when you can call the scrivener’s error doctrine to the rescue.You’ll be up-to-the minute with the latest developments.	Conrad Teitell
12:00pm-1:00pm	Lunch Break - On Your Own
1:00pm-2:45pm	Good News and Bad News: Section 529 Plans and Section 409A Planning – §529: These popular savings plans for educational expenses are flexible though subject to abuse.The speaker will discuss the tax and asset protection aspects of 529 plans as well as compare to other ways to pay educational expenses.§409A:Until and unless Congress exempts small employers from the onerous rules of §409A, nearly every agreement of every business involving an employee, partner, owner and independent contractor will need to be reviewed for the implications of this section.The speaker will discuss practical aspects of dealing with 409A proposals for correction procedures and things to watch out for.	Gary A. Zwick
3:00pm-4:30pm	To B(orrow) or not to B(orrow): Hamlet Meets Estate Tax Financing Strategies - What options are available to finance the estate tax? Structuring the Graegin loan and its tax implications. Structuring a straight loan and its advantages and disadvantages versus Graegin. Understanding 6166 as a means to finance estate tax payments. Reconsideration ofsection 6161 relief for financing tax payments. How to compare the financial results of each transaction. Risks associated with financing estate taxes versus immediate liquidation of assets.	Louis S. Harrison
4:35pm-5:50pm	Alabama's Uniform Estate Tax Apportionment Act — Don't Get Caught in the Apportion-Net – Until this year, Alabama was one of only five states that continued to charge estate taxes to residue (absent a contrary provision in the decedent’s will).Following the trend to equitable apportionment, Alabama has now enacted the Alabama Uniform Estate Tax Apportionment Act.This program explores the provisions of the Uniform Estate Tax Apportionment Act and improvements thereto which were made by Alabama.Although the default rules provided by the Act remedy many inequities encountered under prior law (as well as provide enforcement mechanisms), many practitioners may want to include tailored estate tax apportionment provisions in wills and trusts.The materials will include sample will language that might be used for this purpose.	C. Fred Daniels Cynthia G. Lamar-Hart
5:50pm-6:00pm	Question & Answer
Thursday, June 19th
8:00am-9:45am	Current Developments in Federal Income Taxation – A review of significant administrative and judicial developments over the past twelve months, and the status of legislative tax proposals.	Professor Ira B. Shepard
10:00am-11:45am	Employee or Independent Contractor?  New Perspectives On An Old Issue – Distinguishing independent contractors from employees remains a problem, not just for small businesses but also for public companies.This presentation addresses problems in determining, choosing and defending worker classification in light of new settlement initiatives by the IRS; the many differences among tax, labor and state unemployment laws; and other recent developments.	Larry A. Campagna
11:45am-1:00pm	Luncheon - Topic To Be Announced	To Be Announced
1:15pm-2:45pm	What Has Congress Done: Changes to Section 6694 – In May 2007, Congress amended the tax return preparer penalty under section 6694, raising the standard for imposing the penalty and increasing the amount of the penalty.In December 2007, the IRS issued interim guidance implementing the new standard.Tax professionals now must come to grips with the changed standard and the interim guidance.	Robert S. Walton
3:00pm-4:30pm	Partnership Workouts:Is It That Time Again? – What goes around comes around.Real estate values were up; now they are down.This presentation will discuss the issues that a practitioner must address when working out a troubled real estate project.The discussion will include issues from both the side of the debtor/partnership (COD income, etc.) and the lender/partner (bad debt write off, etc.).	James B. Sowell
4:35pm-5:45pm	Incentives and Stuff – A Pragmatic Overview of Alabama Incentives. Are you missing out on possible Alabama incentives for your client’s new or existing Alabama business?The panelists will discuss Alabama’s overall sales, use, property and income tax incentives structure, as well as some very attractive non-tax incentives.The panelists will also discuss and provide insight on the “State of the State” of economic development in Alabama and where it’s headed.	Christopher R. Grissom Neal Wade Kelly M. Graham
5:45pm-6:00 pm	Question & Answer
Friday, June 20th
8:00am-9:45am	Hot Section 1031 Topics:Trading Places and Other Current Conundra – This presentation will cover current issues in like-kind exchanges under Section 1031 including pending IRS enforcement and guidance projects, a selection of “qualified use” topics including exchanges of vacation homes, the role of intangibles in exchanges and various problems and opportunities associated with related party transactions.	Louis S. Weller
10:00am-11:45am	S Corporations – Developments and Structuring Techniques – A discussion of various new developments pertaining to S corporations, including developments pertaining to the sale of QSSS stock and the passive investment income penalty tax, and will analyze, in a transactional setting, S corporation planning techniques involving distributions from S corporations, shareholder debt and the preservation of a corporation’s S status.	Charles R. Levun
11:45am-12:00pm	Question & Answer
12:00pm	Adjourned