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Attorneys, CPAs, accountants, financial planners, estate planners, trust officers, and enrolled agents of all levels will benefit from the experiences of our nationally known faculty.


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Seminar Summary:

Our sponsors are proud to bring you a national level tax seminar in a great location and at a price that makes it affordable for all practitioners to attend. (see full course description)


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print the agenda print agenda for the Great Lakes Federal Tax Institute seminar


Training Course Syllabus:

Our sponsors are proud to bring you a national level tax seminar in a great location and at a price that makes it affordable for all practitioners to attend. Centrally located in Cleveland, Ohio, you and your staff will have access to a high level two-day tax planning seminar with some of the country´s most prestigious practitioners and speakers. The first day covers general tax and the second day focuses mostly on estate planning. All of the speakers will present timely and creative tax planning ideas mostly for closely held businesses and their owner operators, and high net worth individuals. In addition, you´ll learn about important matters that affect your professional practice including limited liability company tax issues, recent valuation trends and ways to unwind an irrevocable estate plan.

Attorneys, CPAs, accountants, financial planners, estate planners, trust officers, and enrolled agents of all levels will benefit from the experiences of our nationally known faculty.

Learning Objectives:

  • The attendee will be able to learn cutting edge creative planning techniques for closely held family businesses and their owner operators.

  • The attendee will be able to identify current income and estate planning ideas and techniques.

  • The attendee will be able to discuss current up-to-date developments.


May 11, 2006

7:30 a.m.-8:15 a.m.

Registration (Continental Breakfast Included)

8:15 a.m.-8:30 a.m.

I. Overview

- Gary A. Zwick, Esq., CPA, Walter & Haverfield LLP

8:30 a.m.-9:40 a.m.

II. 100 Best (And Worst) Planning Ideas For Your Client´s Retirement Benefits

- Natalie Choate, Esq., Bingham McCutchen LLP

Ms. Choate, one the country´s most sought after speakers, will highlight and discuss tax planning ideas that work and some that probably don´t work, relative to the accumulation and distribution of retirement benefits from qualified plans. It is highly likely that every attendee will learn new information that will allow their clients to retain more of their retirement accumulations and to avoid those ideas which could cause tax problems.

9:40 a.m.-10:45 a.m.

III. Fun With Single Member LLCs

- James Dalle Pazze, Esq., Herdeg, duPont & Dalle Pazze, LLP

Mr. Dalle Pazze, a prominent Delaware attorney, will highlight the quirky rules related to single member entities, tax options available to owners of such entities, federal tax planning
opportunities, non-tax benefits to be obtained, payroll tax and collection issues and state tax law issues including a discussion of the Delaware Series LLC.

10:45 a.m.-10:55 a.m.


10:55 a.m.-12:00 p.m.

IV. Partnership And LLC Formation Issues Including Tax and Non-Tax Considerations

- Patrick J. Mitchell, Esq., Taft, Stettinius & Hollister LLP

Mr. Mitchell is a noted tax practitioner who advises clients in the formation and use of partnerships and limited liability companies taxed as partnerships, in various industries and to facilitate the sale or acquisition of interests in businesses. He will discuss the tax and non-tax aspects of planning for the formation of these entities including the new rules related to granting income interests in exchange for services.

12:00 p.m.-1:00 p.m.

Lunch (On Your Own)

1:00 p.m.-2:05 p.m.

V. Planning for Distributions From LLCs And Partnerships Including Distributions In Liquidation And Redemption Of An Interest And Disguised Sales

- Amy Sutton, CPA, Deloitte Tax LLP

Ms. Sutton is a partner in the Washington National Tax Office of Deloitte Tax LLP, specializing in partnership taxation, and mergers and acquisitions through partnerships. Her discussion will highlight the planning opportunities and pitfalls contained in the complex rules related to distributions from partnerships and LLCs taxed as partnerships and planning around and with the disguised sale rules.

2:05 p.m.-3:10 p.m.

VI. Basis And At Risk Issues For Partners And LLC Members

- Bruce J. Belman, CPA, J.D., Crowe Chizek and Company LLC

Mr. Belman is an attorney and CPA who has spent his entire career in public accounting, with large international, national and smaller regional CPA firms. Every practitioner advising clients owning LLCs and partnerships needs to know about the basis and at-risk rules, which can affect the ability of an owner to deduct losses allocated to them and are subject to recent changes in IRS regulations. Mr. Belman will try to make sense of this difficult area and present planning opportunities as well.

3:10 p.m.-3:20 p.m


3:20 p.m.-4:30 p.m.

VII. Tax Planning With 1031 Exchanges

- Stephen L. Robison, Esq., Strategic Property Exchanges, LLC

Mr. Robison, a board certified tax attorney with a Masters of Law degree in taxation, works as a qualified intermediary facilitating tax favored swaps of real estate and other like kind property. He will discuss planning opportunities
with tax free swaps including transactions with related parties, three party exchanges, tenants in common interests and other methods of solving tax problems of clients dealing in real estate.

4:30 p.m.-6:00 p.m.

Reception sponsored by First Merit Bank following the final presentation.
(Please confirm your attendance for this reception when you register.)


May 12, 2006

7:30 a.m.-8:00 a.m.

Registration (Continental Breakfast Included)

8:00 a.m.-9:05 a.m.

I. The Latest On Transfer Tax And Other Valuation Issues From The IRS´ Valuation

- Mukesh Bajaj, Ph.D., LECG

Mr. Bajaj is an expert in the valuation of family partnerships and closely held business interests who testifies regularly on behalf of the Internal Revenue Service in many important cases including the McCord case. He will provide participants with inside information on the factors that helped shape these court decisions and the importance of the reasoning of the courts that may not be fully appreciated by the practitioner community. He will also provide insight into the direction we can expect the courts to go in valuation cases in the future.

9:05 a.m.-10:10 a.m.

II. Tax And Estate Planning Considerations For The Client Relocating To Florida

- Stephen M. Newman, Esq., Nixon Peabody LLP

After many years of practice in upstate New York and advising wealthy clients on their relocation to Florida, Mr. Newman now splits his time between the two states in order to better facilitate the transition of these clients to their new residence.  For those participants who do not regularly practice in
Florida but see more and more clients making this move, this presentation will be invaluable in highlighting the issues that every client should consider. These include Florida Intangibles planning, homestead exemption issues, real estate transfer tax issues, Florida estate tax and severing ties with the state from which the client is moving.

10:10 a.m.-10:20 a.m.


10:20 a.m.-11:25 a.m.

III. Current Thinking On Zeroed Out GRATs And Sales To Grantor Trust

- Ronald D. Aucutt, Esq., McGuire Woods LLP

Mr. Aucutt is one the country´s most prominent estate planners, and nationally known speaker and author. He has his ear to the ground on issues surrounding these very important estate and income tax planning techniques. Mr. Aucutt will share his insights with us and highlight recent developments that affect planning in this area.

11:25 a.m.-12:25 p.m.

Lunch (On Your Own)

12:25 p.m.-1:25 p.m.

IV. Unwinding the Supposedly Irrevocable Estate Plan

- Jerald David August, Esq., and Mark Silow, Esq., Fox Rothschild LLP

No matter how diligent you are, the needs and desires of clients will change from time to time. Sometimes, the estate plan that you put in place many years ago no longer works either because of law changes or changes in circumstances. Some of the techniques implemented are irrevocable but the client would like to change them anyway. Mr. August and Mr. Silow, both nationally known tax experts, will discuss how to unwind that which is supposed to be irrevocable and how to build flexibility into your estate plans for the future.

1:25 p.m.-2:30 p.m.

V. Irrevocable Insurance Trust Planning

- James M. Mackey, Esq., Walter & Haverfield LLP

The irrevocable insurance trust is still one of the most effective and pervasive estate planning techniques in use. Over the years, practitioners have come up with ways to make them more advantageous. Mr. Mackey, a board certified estate planning attorney will discuss innovative planning techniques and the application of the generation skipping tax rules to these important vehicles.

2:30 p.m.-2:40 p.m.


2:40 p.m.-3:45 p.m.

VI. Live Generously: An Insider´s Perspective On Charitable Gift Planning - Alan D. Gross, Esq., Jewish Community Federation of Cleveland

Charitable giving involves a combination of tax and non-tax motivations. There are many techniques available to donors including charitable gift annuities, private foundations, supporting organizations, donor advised funds and charitable trusts. Mr. Gross has many years of experience advising donors and their professional advisors on these techniques and has a unique perspective that he will impart to participants in a way that can help them to better advise their clients.


National Speakers:

Ronald D. Aucutt, Esq., of McGuire Woods LLP, in McLean, Virginia, is a partner of the law firm. Mr. Aucutt is a nationally known and respected expert in the estate planning area. He previously practiced for many years with the prominent Washington D.C. law firm of Miller & Chevalier. Mr. Aucutt speaks regularly at
the most important seminars on estate planning and has published numerous articles in technical publications. He is a fellow of the American College of Trust and Estate Counsel having previously served as its president.

Jerald David August, Esq., of Fox Rothschild LLP, in West Palm Beach, Florida, is a prominent, nationally known tax lawyer, who is a graduate of the NYU Graduate Tax Program. Mr. August is managing partner of the West Palm Beach office of Fox Rothschild and co-chair of
the firm´s Tax and Estates Department. In addition to substantial tax planning and controversy experience, including trials before the U.S. Tax Court and the Eleventh Circuit Court of Appeals, he is the editor-in-chief of The Tax Lawyer, and a member of both the American College of Tax Counsel and the American
College of Trusts and Estates Counsel. Mr. August is a regular speaker at the most prestigious tax seminars in the country and is a frequently published author on tax and estate planning subjects.

Mukesh Bajaj, Ph.D., of LECG in Emeryville, California, is managing director of the finance and damages practice, and is a member of the Governing Board of LECG, a national consulting firm. Dr. Bajaj holds a bachelor´s degree in chemical engineering from the Indian Institute of Technology in Delhi, India, an MBA degree from the University of Texas at Austin and a Ph.D. degree in finance from UC Berkeley. He is often published and is an adjunct faculty member at UC Berkeley. The IRS relies heavily on Dr. Bajaj in valuation cases both in the transfer tax and income tax areas, having testified in several prominent cases.

Bruce J. Belman, CPA, J.D., of Crowe Chizek and Company LLC, in Louisville, Kentucky, is a partner in the regional CPA firm. His main area of practice is the taxation of partners and partnerships, having contributed to the Real Estate Accounting and Reporting Manual published by Warren Gorham and Lamont as well as The Tax Adviser and various other journal articles and technical publications. Mr. Belman speaks regularly around the country on tax issues and at in-house seminars. He holds a J.D. degree from Case Western Reserve University School of
Law and a B.A. degree in political science from Miami University of Ohio.

Natalie B. Choate, Esq., of Bingham McCutchen LLP, in Boston, Massachusetts, is an expert in the areas of retirement benefits and estate planning, and is affiliated with a prominent Boston law firm. She is the author of the book, Life And Death Planning For Retirement Benefits as well as The QPRT Manual, both leading resources for estate planning professionals. Ms. Choate is a regent of the American College of Trust and Estate Counsel, was named Estate Planner of the Year by the Boston Estate Planning Council and is listed in The Best Lawyers in America. She is a nationally known speaker and has authored numerous technical articles and other technical publications.

James Dalle Pazze, Esq., of Herdeg, du Pont & Dalle Pazze, LLP, in Wilmington, Delaware, practices tax law as a name partner. He is a graduate of the Georgetown University Law Center Graduate Tax Program and for many years was an adjunct professor of law at the Delaware Law School. Mr. Dalle Pazze is a fellow of the American College of Tax Counsel and is admitted to practice in New Jersey, the District of Columbia and Delaware.

Alan D. Gross, Esq. is assistant vice president of the Jewish Community Federation of Cleveland with primary responsibility for endowment development. Mr. Gross practiced law in Cleveland with a large law firm prior to joining the federation in 1984. He is a graduate of Kenyon College and Vanderbilt University Law School. Mr. Gross is a frequent speaker and author on charitable gift planning topics both locally and nationally.

James M. Mackey, Esq., of Walter & Haverfield LLP, in Cleveland, Ohio, is a
board certified estate planner and a partner in the Tax and Wealth Management Section of the Cleveland law firm. Mr. Mackey has over 25 years of experience advising wealthy individuals, their families and their closely held
businesses in estate planning, asset protection and tax matters including extensive experience in succession planning. He is also a frequent speaker at local tax and estate planning seminars. Mr. Mackey is a graduate of John Carroll University and the Cleveland-Marshall College of Law.

Patrick J. Mitchell, Esq., of Taft, Stettinius & Hollister LLP, in Cincinnati, Ohio, is a partner and head of the Tax Department of the prominent Cincinnati law firm. He is listed in The Best Lawyers in America and Ohio Super Lawyer magazine. Mr. Mitchell is a CPA, inactive and holds an M.S. degree in taxation in addition to his law degree. He formerly taught at American University in Washington D.C. and in the Masters in Taxation program at the University of Cincinnati. Mr. Mitchell is a member of the Federal Taxation Specialization Board of the Supreme Court of Ohio and is
admitted to practice in Ohio and before the U.S. Tax Court.

Stephen M. Newman, Esq., of Nixon Peabody LLP, in Palm Beach Gardens, Florida, is a partner in the Private Clients Group and is licensed to practice law in both New York and Florida. He concentrates his practice in the areas of tax and estate planning for high net worth individuals and works extensively in the implementation of tax savings strategies to accomplish family planning and asset protection goals. Mr. Newman also has extensive experience advising physicians and other professionals in structuring compensation, buy sell agreements,
pensions and fringe benefits.

Stephen L. Robison, Esq., of Strategic Property Exchanges, LLC, in Cincinnati, Ohio, holds a B.A. degree from the University of Cincinnati, a J.D. degree from the University of Cincinnati School of Law and an LL.M. degree in business and taxation from the University of Bridgeport. He is a board certified specialist in federal tax law and was named as an Ohio Super Lawyer. Mr. Robison is a specialist in tax-deferred Section 1031 Exchanges including forward, reverse, construction exchanges, parking
arrangements and personal property exchanges.

Mark L. Silow, Esq., of Fox Rothschild LLP, in Philadelphia, Pennsylvania, is a partner in the Tax and Estates Department and is the firm´s administrative partner. A graduate of the NYU
Graduate Tax Program, Mr. Silow is listed as a Pennsylvania Super Lawyer. His practice includes business and tax planning, corporate acquisitions and dispositions, estate planning and employee benefits. Mr. Silow writes and
lectures extensively including speeches at the NYU Federal Tax Institute and other national seminars.

Amy Sutton, CPA, of Deloitte Tax LLP, in Houston, Texas, is a partner in the Washington National Tax Office of the Big 4 accounting firm of Deloitte & Touche LLP. She works from the Houston, Texas, office focusing on partnership taxation with an emphasis on the use of partnerships in mergers and acquisitions, and financing transactions. Ms. Sutton received her B.A. and MBA degrees from Rice University and her M.S. degree in taxation from Golden Gate University. She is a CPA licensed to practice in California and Texas. Ms. Sutton is the co-author of Taxation Of Passive Activities, published by Warren Gorham and Lamont.




First Merit Bank of Cleveland

Walter & Haverfield LLP, Cleveland,

Lorman Education Services


Seminar Summary:

Our sponsors are proud to bring you a national level tax seminar in a great location and at a price that makes it affordable for all practitioners to attend. (see full course description)

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