9:00 AM - 10:15 AM
International Taxation: OBBBA Implementing Guidance, Part 1 (Sections 951(a), 904(b)(5), 898(c), 960(d)(4)): Breaking Up (Income Amounts) Is Hard to Do
Corporate Taxation: Taxation of Troubled Companies in a Shifting Rate and Trade Environment
Partnership Taxation: Subchapter K Update: What Came, What Went, What Survived
Credits & Incentives: Shrinking the Gain: QSBS and Opportunity Zones After the OBBBA and Recent Related Guidance
Individual Taxation: Equity Awards & Payroll Taxes
10:30 AM - 11:45 AM
International Taxation: OBBBA Implementing Guidance, Part 2 (Sections 250, 951B, 904(b)(6), 163(j)): Meet the New Issues, Same as the Old Issues
Corporate Taxation: Full Circle: Section 355 Ruling Practice After Rev. Proc. 2025-30
Partnership Taxation: Real Estate and Sovereign Wealth: Inbound Investment in a Shifting Landscape
Credits & Incentives: Section 174A in Practice: Immediate Expensing and Year-End Guidance Filling the Gaps
Individual Taxation: Section 7216 in Practice: Confidential Taxpayer Data and the Third-Party Prep Industry
11:45 AM - 12:30 PM
Lunch Buffet and Exhibitor Hall
12:30 PM - 1:30 PM
Legislative Update: An Early Read After the Midterms
1:30 PM - 2:15 PM
The Fiscal Outlook: Deficits, Debt, and the Choices Ahead
2:30 PM - 3:45 PM
International Taxation: Conceptualizing an FTC Rethink: How to Improve Your Credit (Rules)
Corporate Taxation: No Place Like Home? Redomiciliation and Cross-Border M&A in the Onshoring Era
Credits & Incentives: Follow the Supply Chain — FEOC and Material Assistance in Practice
Individual Taxation: Paid Family and Medical Leave Taxation
4:00 PM - 4:30 PM
Keynot Address: To be announced
4:30 PM - 5:30 PM
The Wealth Divide: Defining the Issue and Whether Tax Policy Should Be Part of the Solution
5:30 PM - 6:30 PM
Networking and Cocktail Reception
6:30 PM - 8:30 PM
Conference Dinner - additional fee
9:00 AM - 10:15 AM
International Taxation: Taxation of the Digital Economy: Where Do We Go From Here?
Tax Controversy: The Continued Evolution of the Economic Substance Doctrine
Tax-Exempt Organizations: Redefining "Charitable": Public Policy, Bob Jones, and the Future of Section 501(c)(3)
Partnership Taxation: Guaranteed - or Not? Considering Partnership Payments In ExxonMobil and Current Deal Structures
Financial Products: House Money or Smart Money? Taxing Sports Betting, Prediction Markets, and the Line Between a Wager and a Financial Product
10:30 AM - 11:45 AM
International Taxation: Building on Sand: Character, Source, and the Taxation of AI-Generated Income
Tax Controversy/Partnership Taxation: BBA at Ten - The Centralized Partnership Audit Regime Update
Tax-Exempt Organizations: Making the Grade: Section 25F and the Overhaul of Education Taxation
Financial Products: Section 852(b)(6) Under the Microscope: ETF Planning in Focus
Individual Taxation: Trump Accounts and Employer Contribution: A New Employee Benefit Opportunity
11:45 AM - 12:30 PM
Lunch Buffet and Exhibitor Hall
12:30 PM - 1:15 PM
The Singularity Will Have to Wait: Consensus, Conflict, and the Limits of Machine Analysis
1:15 PM - 2:15 PM
The End of Deference: Tax Guidance After Loper Bright, Jarkesy, and Corner Post
2:30 PM - 3:45 PM
International Taxation: Pillar Two Update
Tax-Exempt Organizations: Electoral Activity of Charities: Policy, Enforcement, and Impact on the Exempt Sector
AI Taxation: Taxing Artificial Intelligence: A Discussion on Recent Legislative Proposals
Tax Controversy: Tax Litigation Update — The Year's Most Significant Decisions
Financial Products: Will Congress Stake its Claim? The Possible Overhaul of Digital Asset Taxation
4:00 PM - 5:00 PM
Wage Against the Machine: Labor, AI, and the Tax Base
5:00 PM - 6:00 PM
Global Tax Policy Update
6:00 PM - 7:00 PM
Networking and Cocktail Reception