T H E L AT E S T TA X D E V E LO P M E N TS A N D P L A N N I N G F R O M TO P P R AC T I T I O N E R S

GRAND HYATT ATLANTA | IN BUCKHEAD, ATLANTA, GEORGIA

T W O DAY E XC LU S I V E Estate Planning Presentations On October 23 & 24

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The Southern Federal Tax Institute continues its proud tradition of excellence in continuing education by offering its annual Institute. This program continues to provide the most in -depth coverage of recent developments in tax and estate planning.

The 2014 Institute will be held in Atlanta’s thriving and exciting Buckhead district at the elegant and luxurious Grand Hyatt Atlanta. Take advantage of this excellent opportunity to learn and network with your colleagues and associates.

B O A R D O F T R U S T E E S B O A R D David D. AughtryChamberlain, Hrdlicka, White,Williams & AughtryAtlanta, Georgia

George S. BaileyNelson Mullins Riley & Scarborough LLP Columbia, South Carolina

Dennis I. BelcherMcGuireWoods LLP Richmond, Virginia

Turney P. BerryWyatt, Tarrant & Combs LLPLouisville, Kentucky

William M. Blume, Jr.Director, South Carolina Department of RevenueColumbia, South Carolina

Reginald J. ClarkSutherland Asbill & Brennan LLPAtlanta, Georgia

Cameron N. CosbyHogan Lovells US LLPRichmond, Virginia

Jeffery S. DrummondsLattimore Black Morgan & Cain, P.C.Brentwood, Tennessee

Michael A. LaingTaft Stettinius & Hollister LLPCincinnati, Ohio

Stephen R. LooneyDean, Mead, Egerton, Bloodworth, Capouano & Bozarth, P. A.Orlando, Florida

Alan F. Rothschild, Jr.Hatcher, Stubbs, Land, Hollis & RothschildColumbus, Georgia

James B. SowellKPMG LLPWashington, DC

Kimberly H. StognerWomble Carlyle Sandridge & Rice, LLPWinston-Salem, North Carolina

R. David WheatThompson & Knight LLPDallas, Texas

A D V I S O R Y Harold E. AbramsAtlanta, Georgia

Jean T. AdamsDurham, North Carolina

R. Keith AltizerMaitland, Florida

Scott Y. BarnesCharleston, South Carolina

Herschel M. BloomAtlanta, Georgia

Thomas A. CaldwellChattanooga, Tennessee

Thomas N. Carruthers, Jr.Birmingham, Alabama

Mark S. DrayRichmond, Virginia

H. Mitchell Dunn, Jr.Savannah, Georgia

Charles H. EgertonOrlando, Florida

J. Carlton FlemingCharlotte, North Carolina

Richard E. FoggFree Union, Virginia

William C. FowlerAtlanta, Georgia

Stephen F. GertzmanWashington, DC

Lawrence B. GibbsWashington, DC

James C. GoochNashville, Tennessee

Harry V. Lamon, Jr.Atlanta, Georgia

Lauch M. Magruder, Jr.Highlands, North Carolina

Neill G. McBrydeCharlotte, North Carolina

Robert W. MehergHendersonville, North Carolina

Mark J. SilvermanWashington, DC

J. Kenneth TomlinsonColumbia, South Carolina

Robert C. WalthallBirmingham, Alabama

EXECUTIVE DIRECTORMyra B. WhortonDecatur, Georgia

O F F I C E R S CHAIRMAN OF THE BOARDPamela F. Olson PricewaterhouseCoopers Washington, DC

PRESIDENTPeter J. GenzKing & Spalding LLPAtlanta, Georgia

VICE PRESIDENTJoyce A. WaterburyDixon Hughes Goodman LLPHigh Point, North Carolina

SECRETARYChristopher J.C. JonesMoore & Van Allen PLLCCharlotte, North Carolina

TREASURERKenneth L. ThrasherBennett Thrasher PCAtlanta, Georgia

SPECIAL ADVISOR TO THE BOARDProfessor Brant J. HellwigWashington and Lee UniversitySchool of LawLexington, Virginia

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P R E S I D E N T ’ S L E T T E R

Dear Fellow Tax Practitioner,

On behalf of the Trustees of Southern Federal Tax Institute, I invite you to join us at the Grand Hyatt Atlanta (Buckhead) for the 49th Annual Southern Federal Tax Institute. As in our 48 prior sessions, the Trustees have assembled an outstanding program presented by the country’s most respected tax CPE speakers who will cover in depth a wide range of topics.

From Monday through Wednesday our speakers will present timely insights on significant 2014 income tax developments; tax legislation, including prospects for tax reform; U.S. reporting requirements for inbound non-U.S. taxpayers; tax aspects of partnership agreements; the net investment income tax; partnership and real estate tax developments; section 1031 traps; the new proposed partnership liability allocation rules; the basics of timber taxation; incorporations; M&A transactions involving S corporations; real estate trapped in C corporations; payroll taxes and fringe benefits; ESOPs; tax accounting methods; IRS audit procedures; new ways to move a case through IRS Appeals; and professionalism, ethics and tax opinions.

The Institute continues its tradition of devoting the Thursday and Friday sessions to estate planning topics, with a number of topics focusing on highly sophisticated estate and gift tax planning strategies. However, in light of the prevailing estate planning landscape following the American Taxpayer Relief Act of 2012, the program contains several topics aimed at planning for clients under the $10 million threshold, as well as topics focusing on income tax strategies that have assumed heightened prominence in this setting.

All of our programs have been chosen to keep you up to date and on the cutting edge. We continue to offer the flexibility of a two-day, three-day or five-day program to suit your schedule.

On Monday, Wednesday and Thursday evenings, all registrants, speakers, exhibitors, and sponsors are cordially invited to join the Institute Trustees for cocktails and hors d’oeuvres at the Grand Hyatt Atlanta. These social events provide a great opportunity for networking, building relationships and renewing old ties.

We are pleased to offer registrants both paper and paperless options for your reading materials for the 2014 Institute. We recognize that some of you have a strong preference for hard copies of the materials, while others are glad not to lug the binders. This will be our third Institute with the paperless option. If you decide to try it, we think you will find it to be user-friendly.

Our sponsors’ support greatly assists us in maintaining an exceptional and reasonably priced program. Please join me in thanking them for their generous support. On a cost per CPE/CLE hour basis, we believe that the 2014 Institute is one of the best values on the market.

Please join us in October for the 49th Annual Southern Federal Tax Institute. I’m sure you’ll be glad you did.

Yours sincerely,

Peter GenzPresidentSouthern Federal Tax Institute

SUNDAY EVENING, OCTOBER 19, 20145:30-8:00 Registration

MONDAY MORNING, OCTOBER 20, 2014Pamela F. Olson, Presiding

7:15 Registration Desk Opens

8:00-9:00 Breakfast

9:00-10:30 RECENT FEDERAL INCOME TAX DEVELOPMENTS – This session will delve into significant court decisions, rulings, and statutory and regulatory developments over the past twelve months. These three experts will provide insights into the implications of recent events.

Martin J. McMahon, Jr., James J. Freeland Eminent Scholar and Professor of Law, University of Florida Levin College of Law, Gainesville, FL Ira B. Shepard, Professor Emeritus of Law, University of Houston Law Center, Houston, TX Bruce A. McGovern, Professor of Law, South Texas College of Law, Houston, TX

10:30-10:45 Break

10:45-12:00 RECENT FEDERAL INCOME TAX DEVELOPMENTS (Con’t)

12:15-1:05 Mid-day Program: DEFENDING CAPTIVES, CONSERVATION EASEMENTS, AND OTHER CONGRESSIONAL INDUCEMENTS – The tax incentives Congress enacts to further non-tax public policies seem to draw hostility from those charged with enforcement of all tax laws – both those laws that favor the citizen and those that favor the fisc. By focusing upon defense, this panel will shed light on planning precautions. Sponsored by CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & AUGHTRY and presented by Philip Karter, William O. Grimsinger and Hale E. Sheppard

MONDAY AFTERNOON, OCTOBER 20, 2014R. David Wheat, Presiding

1:15-2:15 LEGISLATIVE UPDATE AND THE PROSPECTS FOR TAX REFORM – This presentation will review recently enacted tax legislation and provide insight into the potential for comprehensive tax reform.

Marc J. Gerson, Miller & Chevalier Chartered, Washington, DC

2:15-3:15 STAYING ABREAST OF THE EVER-GROWING LABYRINTH OF US TAX REPORTING AND COMPLIANCE REQUIREMENTS FOR INBOUND FOREIGN CLIENTS – This program will cover a variety of tax reporting and compliance headaches faced by foreign-owned U.S. enterprises and foreign investors in U.S. real estate, including maintenance of proper transfer pricing documentation; FATCA compliance; filing section 6114 disclosures of treaty-based return positions; complying with section 6038A reporting for related party transactions (Form 5472); FIRPTA compliance issues, including notices of nonrecognition transfers, withholding certificates, and statements provided by a U.S. corporation as to its non-USRPHC status when foreign shareholder sells the corporation’s shares; and selected issues relating to U.S. obligations of withholding agents as to FDAP income, including securing and updating W9-BENs from foreign lenders.

James E. Croker, Jr., Alston & Bird LLP, Washington, DC

3:15-3:30 Break

3:30-4:30 ANALYZING TAX-RELATED PROVISIONS OF PARTNERSHIP AGREEMENTS FROM THE PERSPECTIVE OF THE LAWYER WHO DRAFTS THEM AND THE ACCOUNTANT WHO HAS TO LIVE WITH THEM – Issues to consider when drafting the tax-related provisions of partnership agreements, including avoiding or managing phantom income issues; choice of section 704(c) methods; covenants regarding section 752 debt allocation methodology; choice of profit and loss allocation methodology; provisions regarding preparation and review of tax returns; TEFRA provisions; making sure that the person or entity that the parties intend to be the return signer and TMP can, in fact, act in those capacities; and commonly encountered fractions rule issues for partnerships with tax-exempt investors.

Gary R. Huffman, Vinson & Elkins LLP, Washington, DC Lynn T. Kawaminami, Deloitte Tax LLP, Atlanta, GA

4:30-5:30 UPDATE ON THE 3.8% NET INVESTMENT INCOME TAX AND RELATED DEVELOPMENTS UNDER SECTION 469 – This program will focus on tax planning opportunities and traps in light of the final net investment income (NII) tax regulations and proposed regulations issued in the fall of 2013. Topics covered will include changes from the original proposed NII regulations; the interaction of the NII tax with the passive loss rules; meaning of “trade or business” concept and particularly as it relates to rental real estate; treatment of guaranteed payments and section 736 payments; dispositions of interests in partnerships and S corporations; application of the NII tax to estates and trusts; recent developments in the section 469 area; and tax strategies for minimizing/avoiding the NII tax.

Jeanne M. Sullivan, KPMG LLP, Washington, DC

5:30-7:00 Cocktail Party

WHAT’S NEW IN THE INCOME TAX WORLD?

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TUESDAY MORNING, OCTOBER 21, 2014James B. Sowell, Presiding

PARTNERSHIPS AND REAL ESTATE

7:15-8:15 Breakfast

8:15-9:05 HOT TOPICS IN PARTNERSHIP AND REAL ESTATE TAXATION – This session will provide you with the information you need to stay current in partnership and real estate taxation. Topics to be covered will include proposed regulations dealing with mandatory partnership downward basis adjustment rules enacted by the American Jobs Creation Act of 2004; current developments with respect to the tax treatment of management fee waivers; the new IRS safe harbor provided in Revenue Procedure 2014-12 relating to section 47 rehabilitation credit partnerships; the Tax Court’s Pilgrim’s Pride Corp. decision and what it means for those who have taken, or wish to take, an ordinary loss on abandonment of an interest in a distressed real estate partnership; and a review of so-called “payment in lieu of taxes” (PILOT) programs and similar “bonds for title” structures that are intended to reduce or eliminate ad valorem property taxes for newly developed real estate, including the federal income tax consequences that flow therefrom.

Pardis Zomorodi, Latham & Watkins LLP, Los Angeles, CA

9:05-10:05 YOU THOUGHT YOUR 1031 EXCHANGE WAS ON AUTOPILOT BUT THE CREW FELL ASLEEP: A COMPENDIUM OF CLASSIC 1031 BUSTS – A review of common section 1031 screw-ups, including disqualified person QI traps; paragraph (g)(6) violations; identifying the wrong entities; identifying too many properties; documentation errors and oversights; failure to spot potential boot issues; now you see it now you don’t co-tenancies; and related party disposition issues.

Adam M. Handler, PricewaterhouseCoopers LLP, Los Angeles, CA • Mary Cunningham, Chicago Deferred Exchange Company, Chicago, IL

10:05-10:20 Break

10:20-11:10 IT WASN’T BROKE BUT THEY FIXED IT: COPING WITH THE NEW SECTION 752 LIABILITY ALLOCATION REGIME AND TRANSITION RULES – Analysis of new section 752 rules and their effect on tax structuring of partnership roll-ups; impact on existing partnership debt allocation arrangements; impact on disguised sale planning.

John J. Rooney, KPMG LLP, Washington, DC

11:10-12:00 AN ABC PRIMER ON TIMBER TAXATION FOR TAX ADVISORS WHO HAVE TROUBLE SEEING THE FOREST AND THE TREES – Don’t be intimidated by arcane timber industry jargon any longer. This program will cover basic types of timber contracts and timber industry terminology; how to structure contracts to achieve capital gain under section 631; basic depletion concepts; tax treatment of timber gains under FIRPTA and UBTI rules; tax planning issues for timber REITs.

Daniel R. McKeithen, Sutherland Asbill & Brennan LLP, Atlanta, GA

12:15-1:05 Mid-day Program: POSSIBILITIES AND PITFALLS: HOW TO CAPTIVATE YOUR CLIENTS WITH THE FASTEST GROWING BUSINESS TOOL – With over half a century of history, its own Internal Revenue Code Section, and over 65 domestic and international domiciles to choose from for licensure, the $200 billion a year Captive Insurance Company Industry continues to grow in popularity and gain recognition as a valid, and oftentimes vital, business tool. This session will focus on explaining Captive Insurance Companies and their potential for clients, service providers, and local economies, as well as highlight specific issues when poorly planned or improperly “sold.” Sponsored by The STRAUSS LAW FIRM and presented by Peter J. Strauss

TUESDAY AFTERNOON, OCTOBER 21, 2014Stephen R. Looney, Presiding

CORPORATIONS

1:15-2:15 SECTION 351: TRAPS AND OPPORTUNITIES – Review of various tax issues, potential pitfalls and planning opportunities encountered in section 351 transactions, including a discussion of step-transaction issues affecting the “control” requirement; springing liabilities in check-the-box elections and other section 357(c) issues; dealing with investment company issues under section 351(e); and use of section 351 to achieve tax-free treatment in management rollover and other acquisition transactions.

Martin Huck, Ernst & Young LLP, Washington, DC

2:15-3:15 TAX CONSIDERATIONS FOR BUYERS AND SELLERS OF S CORPORATIONS – Selected tax issues faced by buyers and sellers of S corporations in taxable and tax-free transactions. Issues discussed will include elections under section 338(h)(10) and section 336(e); dealing with the built-in gains tax; installment sales; sale of qualified Subchapter S subsidiaries; and particular considerations related to acquisition of C corporations by S corporations. Eric M. Elfman, Ropes & Gray LLP, Boston, MA

3:15-3:30 Break

3:30-4:30 DEALING WITH STATE AND LOCAL TAX ISSUES IN CORPORATE ACQUISITIONS – This presentation will address significant state and local tax aspects of corporate acquisitions, including important areas of focus in due diligence, rules governing the sourcing of gain, the effect of acquisitions on state tax attributes, successor liability concerns, and the availability of sales and use tax exemptions. Bruce P. Ely, Bradley Arant Boult Cummings LLP, Birmingham, AL • Peter G. Stathopoulos, Bennett Thrasher PC, Atlanta, GA

4:30-5:30 WHAT TO DO WHEN YOUR CLIENT HAS VALUABLE REAL ESTATE TRAPPED IN A C CORPORATION – C to REIT conversions; the ABC’s of living with a REIT; built-in gains tax issues; conversion to S corporation status; tax-free spin-offs (including the Penn National ruling and the prospects for similar transactions).

Michael Mollerus, Davis Polk & Wardwell LLP, New York, NY

5:45-7:45 FLORIDA CPA REQUIREMENTS FOR ETHICS IN TAX PRACTICE – Covers the ethical standards for tax practice for CPAs, including an overview of Circular 230, discussion of key provisions with examples, state accountancy rules for ethics, and the AICPA ethical guidelines in Statements on Standards for Tax Services. For Florida CPAs only.

BUSINESS TAXATION

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ACCOUNTING, ERISA, ETHICS, ET CETERAWEDNESDAY MORNING, OCTOBER 22, 2014Michael A. Laing, Presiding

7:30-8:30 Breakfast

8:30-9:30 PAYROLL TAX AND FRINGE BENEFIT AUDIT UPDATE – This session will focus on the latest worker classification, reporting, and payroll tax issues affecting taxpayers, including the effect of Windsor and Quality Stores on payroll tax refunds, developments in the fringe benefit and business expense areas, and other issues being raised by the IRS and Congress that affect employment tax liabilities.

Mary B. (“Handy”) Hevener, Morgan, Lewis & Bockius LLP, Washington, DC

9:30-10:45 CLAIMS OF ESOP PROMOTERS: PEELING THE ONION – This presentation will examine the use of an ESOP to finance the acquisition of a company, the parties to the transactions, the need for the ESOP to have its own legal, tax, financial and valuation advisors, and special governance, valuation, and operational issues relating to an ESOP company.

Gregory K. Brown, Holland & Knight LLP, Chicago, IL • W. Dennis Summers, Taylor English Duma LLP, Atlanta, GA

10:45-11:00 Break

11:00-12:00 NEW ISSUES AND OPPORTUNITIES IN THE EVER CHANGING WORLD OF ACCOUNTING METHODS – A discussion of what every practitioner needs to know about current issues and opportunities available to taxpayers when adopting or changing their methods of accounting; about the questions being raised by the IRS at the National Office and on audit and how those questions and the issues they present are being resolved; and how to use accounting methods to avoid issues from being raised in the future.

John C. (Jack) Donovan, Ernst & Young LLP, Washington, DC

12:15-1:05 Mid-day Program: AN ADVISOR’S GUIDE TO LIFE INSURANCE – The speakers will have a Q&A discussion focusing on recent trends in the affluent life insurance marketplace. Topics that will be covered include: funding strategies for affluent families and business owners; evaluating policy performance and benchmarking to the current marketplace; and options to consider with policies when goals and objectives have changed. Sponsored by MCGUIREWOODS LLP and NEASE, LAGANA, EDEN & CULLEY, INC. and presented by Dennis I. Belcher and Lawton M. “Mac” Nease, III

WEDNESDAY AFTERNOON, OCTOBER 22, 2014David D. Aughtry, Presiding

1:15-2:15 TRICKLE DOWN AUDIT PROCEDURES – The IRS continues to revamp the LB&I audit process to increase coverage and collections. Beyond static IDR/summons procedures, how will the IRS do it? And what does it mean for small and mid-size taxpayers who have dealt with IRS audits informally in the past or avoided them altogether? This program will explore recent changes to the IRS audit process for large and mid-size taxpayers and where the changes may lead.

Elizabeth Tucker, PricewaterhouseCoopers LLP, Dallas, TX • Colin E. Blalock, Jones & Kolb, Atlanta, GA

2:15-3:15 APPEALING ALTERNATIVES FOR DEALING WITH APPEALS – Trial can be expensive, time-consuming, and uncertain, but your client can’t accept the IRS audit team’s position. When does docketed status improve settlement prospects? What are the options short of trial that your client can use to resolve disputes with the IRS without appearing in court? This program will look at the options adopted by the IRS to resolve issues—fast track, post-appeals mediation, and post-appeals arbitration—and how to use them effectively.

Sheldon M. “Shelly” Kay, Sutherland Asbill & Brennan LLP, Atlanta, GA

3:15-3:30 Break

3:30-4:30 IT STILL TAKES A VILLAGE:  BALANCING PROFESSIONALISM, PRIVILEGES, AND ADVOCACY IN TAX CONTROVERSIES – How do you balance civility and the aspirational goals of professionalism against the duty of zealous tax advocacy, a Kovel accountant’s role in a tax defense, and the client’s expectations in an era of change at the IRS? We will focus upon several reported cases and current developments to demonstrate how that balance can be maintained or collapsed.

(Submitted for 1.0 hours of Ethics and Professionalism Credit) Larry A. Campagna, Chamberlain, Hrdlicka, White, Williams & Aughtry, Houston, TX 4:30-5:30 GETTING COMFORTABLE WITH YOUR LEVELS OF COMFORT AND DETERMINING WHAT LEVEL OF COMFORT YOU NEED TO GET COMFORTABLE WITH – These days it seems that no call with a client on a tax issue can end without a pointed “what is your comfort level” type of question. This presentation will attempt to provide

a framework for understanding the morass of opinion levels and their consequences, including ethical standards, Circular 230, the preparer penalty, section 6662 substantial understatement penalty, section 6662A reportable transaction understatement penalty, reasonable cause penalty waivers, section 6694 preparer penalty, reportable transactions, material advisor disclosures, FIN 48, UTP and how to handle sensitive “deal buster” type issues and work effectively with other advisors whose risk assessment differs from your own.

(Submitted for 1.0 hours of Ethics and Professionalism Credit) Anita C. Soucy, Deloitte Tax LLP, Washington, DC • Matthew D. Lerner, Sidley Austin LLP, Washington, DC5:30-6:30 Exhibitor’s Cocktail Hour

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TAILOR THE INSTITUTE

LET US HELP YOU... The Southern Federal Tax Institute, Inc. is a non -profit

corporation organized for the exclusive purpose of

developing and presenting annually a professional institute

covering current federal tax problems and issues at the

post-graduate level.

This program is designed for the practitioner who must

frequently anticipate and handle tax matters. Emphasis is

placed on subjects which are new and current, including

in- depth coverage of recent developments and problems

which often prove difficult in planning clients’ affairs

and transactions.

WHAT WE DO... The speakers are tax practitioners and scholars from

every section of the country. Each speaker has been

selected based on his or her competence on the subject

matter and the ability to communicate ably and clearly.

Visit SFTI.org to register for the Institute and sign up

for the SFTI mailing list to stay up to date with SFTI

happenings!

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BE SURE TO REGISTER OR VISIT US AT WWW. SFTI.ORG

TAILOR THE INSTITUTE TO YOUR SPECIFIC NEEDSTHE SOUTHERN FEDERAL TAX INSTITUTE OFFERS PRACTITIONERS THE ABILITY TO CHOOSE A REGISTRATION PACKAGE THAT BEST MEETS THEIR NEEDS.

THE FIVE -DAY INSTITUTE:

This package includes admission to all sessions and is ideal for the general tax practitioner and others who want a full week of first- rate tax instruction from the country’s leading tax practitioners. This remains the favorite choice for most of our registrants and is a great way to sharpen your expertise in a broad range of tax areas.

MONDAY THROUGH WEDNESDAY:

This choice combines the presentations on Monday through Wednesday covering Recent Income Tax Developments, Legislative Update, Reporting and Compliance Requirements of Inbound Investments, Focus on Tax Provisions in Partnership Agreements, Net Investment Income Tax, Partnership Tax Update, Classic 1031 Busts, Effect of New 752 Liability Allocation Rules, Timber Taxation, 351 Tips and Traps, Transactions Involving S Corporations, State and Local Tax Concerns in Transactions, Solutions to Corporate-owned Appreciated Real Estate, Employment Tax Update, Debugging ESOP Transactions, and Changing Accounting Methods.

Wednesday afternoon will be devoted to IRS Audits, Litigation, Ethics and Professionalism and will include presentations on the Effect of LB&I Audits on Small Businesses, Resolving Audit Issues, Balancing Professionalism, Privileges and Advocacy, and Opinion Comfort Levels.

WEDNESDAY THROUGH FRIDAY:

This package combines the Estate Planning Sessions on Thursday and Friday, which include presentations covering Special Early Morning Hot Topics, Small Estates, Malpractice in Estate Planning, Grantor Trust Flexibility, Future of Estate Planning, Balancing Income and Transfer Taxes, Audit Proofing Gift Tax Returns, Integrating Asset Protection into Estate Planning, Income Tax Tips for Trusts, Fixing Irrevocable Trusts, Gifts of Private Equity Interests to Charities, Estate Planning for Second Marriages, Fixing Broken IRAs, and Recent Estate Planning Developments, with Wednesday morning’s session covering Employment Taxes, ESOPs, and Accounting Methods, and Wednesday afternoon’s session covering IRS Audits, Litigation, Ethics and Professionalism.

THURSDAY AND FRIDAY: This two -day session, which includes the Thursday and Friday presentations

described in the package above, focuses exclusively on topics relevant to practitioners working primarily in the area of wealth transfer planning.

THURSDAY MORNING, OCTOBER 23, 2014Turney P. Berry, Presiding

6:30-7:30 Breakfast

7:30-8:15 SPECIAL EARLY MORNING PRESENTATION: RECENT CASES, REGULATIONS, RULINGS, AND PRONOUNCEMENTS – This panel of experts will survey the field of recent developments in the federal transfer tax arena, highlighting those most likely to affect your daily practice.

Panel: Charles A. “Clary” Redd and Steve R. Akers • Moderator: Turney P. Berry

8:15-9:15 PLANNING FOR ESTATES UNDER $10 MILLION: A RUBIK’S CUBE OF SIMPLICITY – Estate planning clients who may not be subject to the federal estate tax might, on first blush, appear seemingly simple; yet, the permutations of planning options are legion. And like the Rubik’s cube, a turn to align one issue, shifts another out of alignment. Planners will have to balance the often competing client objectives of: maximizing income tax basis on death, minimizing state estate tax in a decoupled state, asset protection goals, and simplicity and cost consciousness if there is no federal estate tax, and more. Default reliance on bypass/QTIP planning will no longer suffice. Existing planning will also have to be re-evaluated, often resulting in an Alice in Wonderland-like planning where taxpayers will affirmatively assert positions the IRS had historically used to challenge planning options. Welcome to the rabbit hole of FLPs with intentional 2036 strings, ILITs without typical Crummey powers, and more. Steve R. Akers, Bessemer Trust, Dallas, TX

9:15-10:00 MALPRACTICE IN ESTATE PLANNING: SOME GUIDANCE ON HOW TO AVOID IT – The intricacy of the federal gift, estate, and generation-skipping transfer tax regime and its interaction with the federal income tax presents a number of planning opportunities for estate planners. Unfortunately, the complexity of a modern estate planning practice also carries a heightened risk of making a mistake in the course of your representation. This presentation will identify malpractice hazard zones in the estate planning field while providing advice on how to best navigate them. (Submitted for 0.75 hours of Ethics and Professionalism Credit) Charles A. “Clary” Redd, Stinson Leonard Street LLP, St. Louis, MO

10:00-10:15 Break

10:15-11:00 GRANTOR TRUSTS AND THE NEW PLANNING LANDSCAPE – Grantor trusts are a long-time staple of estate planning for taxable estates. This session will address the appropriateness of grantor trusts as donees of gifts in view of the current income and transfer tax landscape, how to draft grantor trust instruments flexibly to respond to future changes in tax law and other circumstances, and how to modify the grantor trust status of inflexibly-drafted trusts. The presentation also will include a discussion of traps for the unwary, including the income tax consequences on a termination of grantor trust status. Amy E. Heller, McDermott Will & Emery LLP, New York, NY

11:00-12:00 THE FUTURE OF ESTATE PLANNING – The outlook for an estate planning practice in a post-ATRA environment—with an inflation-indexed $5 million exemption and portability of the unified credit—is far different than the landscape even five years ago. This presentation will ponder the future of the estate planning field. In particular, the presentation will consider what aspects of the estate planning practice will emerge at the forefront as estate and gift tax planning becomes increasingly less significant.

Jonathan Blattmachr, Pioneer Wealth Partners, LLC, New York, NY

12:15-1:05 Mid-day Program: PATHWAYS TO LIQUIDITY:  ADVISING YOUR CLIENTS IN MONETIZING THEIR LIQUID WEALTH – With the current uptick in the economy and the demographic realities of baby boomer business owner transitions, estate planners have a client base that may be seeking to monetize their investment in their closely held businesses. Many business owners immediately assume that means an outright sale. However, there are other liquidity options to consider. This session will cover these various liquidity options including dividend policy, partial sales to insiders, employee stock ownership plans, private equity investors, as well as third party sales. Sponsored by MERCER CAPITAL and presented by Matthew R. Crow, CFA, ASA and Nicholas J. Heinz, ASA

THURSDAY AFTERNOON, OCTOBER 23, 2014George S. Bailey, Presiding

1:15-2:15 THE INVIGORATING INTERSECTION OF THE ESTATE TAX AND INCOME TAX – Post-ATRA planning for larger estates will increasingly focus on income tax planning, the management of tax basis, and maximizing the “step-up” in basis at death. This presentation will discuss measuring the transfer tax costs (including state estate and inheritance taxes) against the income tax savings from the “step-up” on different types of assets; recapturing assets that have already been transferred; multiplying the applicable exclusion amount; using trust and partnership elections, distributions, and reorganizations to maximize the “step-up” and “split” income across taxpayers.

Paul S. Lee, Bernstein Global Wealth Management, New York, NY

2:15-3:15 FILING THE GIFT TAX RETURN WITH AN EYE TOWARD AUDIT – Did you file a record number of gift tax returns on behalf of your clients in recent years? Do you use formula clauses for gifts and sales? How do you report them? This presentation will explore audit-proofing (to the extent possible) the return, addressing in particular how to report formula transfers that may be highly scrutinized. Stephanie Loomis-Price, Winstead, PC, Houston, TX

3:15-3:30 Break

3:30-4:30 ESTATE PLANNING THROUGH AN ASSET PROTECTION LENS – With “permanent” portability and a $5,000,000 exemption, clients have begun to question the necessity of “estate planning.” Fortunately, all signs indicate that the litigation explosion continues unabated, and that clients are demanding “asset protection planning” solutions from their estate planning advisors. This program will discuss ways in which an advisor can help clients integrate their estate and asset protection planning.

Gideon Rothschild, Moses & Singer, LLP, New York, NY

4:30-5:30 CONTEMPORARY ISSUES IN THE FEDERAL INCOME TAXATION OF TRUSTS – This presentation will explore practical strategies for dealing with thorny trust income tax issues, such as the 3.8% net investment income tax, distributable net income, and deemed ownership of the trust for income tax purposes by grantors and beneficiaries.

Samuel A. Donaldson, Georgia State University College of Law, Atlanta, GA

5:30-7:00 Cocktail Party

ESTATE PLANNING - DAY I

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FRIDAY MORNING, OCTOBER 24, 2014Christopher J.C. Jones, Presiding

7:00-8:00 Breakfast

8:00-9:00 FIXING A BROKEN TRUST – Trusts are fantastically flexible estate planning vehicles, but irrevocable trusts established during life and trusts established by testamentary devise suffer from one inconvenient drawback – they cannot be changed. Or can they? This presentation will examine the options to amend a trust to better serve the objectives of grantors and beneficiaries, including the prospect of decanting the trust property into a trust with more suitable terms. The various income, gift, estate, and generation-skipping transfer tax issues implicated by trust decanting also will be explored.

Elizabeth K. Arias, Womble Carlyle Sandridge and Rice, LLP, Raleigh, NC

9:00-10:00 CHARITABLE DISPOSITIONS OF PRIVATE EQUITY INTERESTS, INCLUDING FAMILY PARTNERSHIPS – This session will deal with the particular issues surrounding the gift to charity of venture capital and other private equity investments, including carried interests. How to minimize unrelated business income tax, obtain effective appraisals, select the right kind of charitable recipient, and create a favorable monetization plan will be discussed, as will how to motivate the capitalist whose interest in charity is only beginning.

Karla D’Alleva Valas, Fidelity Charitable, Raleigh NC

10:00-10:15 Break

10:15-11:00 ESTATE PLANNING FOR SECOND MARRIAGES AND BLENDED FAMILIES – Prenuptial and postnuptial agreements have become common especially in second marriage situations. Incorporating these agreements into estate and trust plans for spouses presents challenges and the tax implications of these agreements can be significant. This presentation will discuss best practices for designing and implementing estate plans for second and blended families, and incorporating prenuptial and postnuptial agreements into estate and trust plans. The presentation also will highlight the most common tax implications to be considered in this context.

Eric Manterfield, Krieg Devault LLP, Indianapolis, IN

11:00-12:00 HOW TO FIX A BROKEN IRA – IRAs can get derailed in 100 ways, but with a little specialized knowledge you can fix (almost) any problem. Learn how to help your clients recover from missed minimum distributions, botched rollovers, and missing beneficiary designations.

Natalie B. Choate, Nutter, McClennen & Fish LLP, Boston, MA

12:15-1:05 Mid-day Program: IMPACTFUL TRENDS AND OPPORTUNITIES IN STRATEGIC PHILANTHROPY – Learn about the most innovative giving strategies currently used by advisors to build and deepen their practice. Sponsored by FIDELITY CHARITABLE and presented by Josh Daly

FRIDAY AFTERNOON, OCTOBER 24, 2014Kimberly H. Stogner, Presiding

1:15-3:15 RECENT ESTATE PLANNING DEVELOPMENTS – Significant court decisions, rulings and statutory and regulatory developments relating to federal trust and wealth transfer taxes.

Stanley M. Johanson, James A. Elkins Centennial Chair in Law and University Distinguished Teaching Professor, University of Texas School of Law, Austin, TX

3:15 Adjourn

ESTATE PLANNING - DAY II

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GRAND HYATT ATLANTASFTI’S ST YLISH HOST HOTEL Located in the fashionable Buckhead district, the Grand Hyatt Atlanta is convenient to Atlanta’s finest dining, shopping and nightlife for you and your colleagues. Only minutes from downtown, the plush Grand Hyatt melds seamless service with elegant décor and haute cuisine to provide an ideal setting for networking with your associates. All this plus Atlanta’s tradition of warm Southern hospitality makes a stay at the Grand Hyatt Atlanta an unforgettable experience.

ACCOMMODATIONS The Grand Hyatt Atlanta’s elegantly appointed rooms soothe the eye and spirit of every weary traveler. Peace and contentment await Institute attendees in rooms designed with comfort as the top priority.

DINING While Buckhead is home to many fine restaurants, you can also find delectable dining options in the hotel. For breakfast, lunch and dinner, the Grand Hyatt Atlanta’s Cassis Restaurant combines award winning cuisine with the charming ambience of the garden level. The Lobby Lounge offers cocktails, light dining and entertainment for dinner. Convenient, 24- hour room service is also available.

FACILITIES The Grand Hyatt Atlanta offers world class amenities for you and your colleagues. The health spa features a sauna, strength and cardiovascular building equipment, steam room, outdoor pool and optional massage. For business -minded attendees, the hotel’s business center can attend to every need from secretarial services, photocopies, faxes, equipment rental, and more.

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THE HEART OF ATLANTA Join your friends and colleagues in Buckhead, Atlanta’s destination for great food, abundant shopping and exciting nightlife. Home to many of the most popular restaurants in Atlanta, Buckhead provides a friendly atmosphere and boasts a wide spectrum of casual to elegant dining options, from French and Italian to Asian, New American and Eclectic.

ATTRACTIONS Buckhead has a variety of attractions including the Atlanta History Center and the Georgia Governor’s Mansion. Other Atlanta attractions, like Atlanta Braves Baseball, Atlanta Falcons Football, the Fox Theatre, Georgia Aquarium, High Museum of Art, Underground Atlanta, Martin Luther King, Jr. Center, Centennial Park and the Coca- Cola Museum, are minutes away and easily accessible by MARTA.

SHOPPING Shopping enthusiasts can join friends and colleagues at two upscale malls that are within walking distance of the hotel – Lenox Square and Phipps Plaza. Enjoy boutiques as well as grand department store shopping at Nordstrom, Saks Fifth Avenue, Neiman Marcus, Williams- Sonoma, Brooks Brothers and many other fine establishments. Both malls also feature fine restaurants.

RESTAURANTS Atlanta Fish Market (Seafood) • Aria (American Contemporary) • Bone’s (Steakhouse) • Chops & The Lobster Bar (Seafood/Steakhouse) • Kyma (Greek) • La Grotta (Italian) • King & Duke (Contemporary) • Portofino (Italian) • Restaurant Eugene (American Contemporary)

SPONSORSSFTI acknowledges the generous support of the following sponsors for their involvement in this year’s Institute.

PLATINUM

MID-DAY

SPEAKER/TRUSTEE DINNER GOLD

PARTNER

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FOR YOUR INFORMATIONREGISTRATION Four custom registration packages are available for this year’s Institute. Two -day registration is $695 (received by August 18, 2014); $745 (received by September 29, 2014); $825 (received after September 29, 2014). Three- day registration (first three days or last three days) is $795 (received by August 18, 2014); $845 (received by September 29, 2014); $925 (received after September 29, 2014). Five-day registration is $995 (received by August 18, 2014); $1,045 (received by September 29, 2014); $1,125 (received after September 29, 2014). A “paperless” discount of $50 will be provided to registrants who opt to receive no hardcopy materials, and a discount of $25 will be provided to those who opt to receive a hardcopy of only one volume of the two-volume set of materials. A discount will be provided equal to 15% of the total registration price for firms or companies registering six or more people and 30% for firms or companies registering 11 or more people. As registration will close at capacity, we suggest you register as soon as possible. Registration is by mail or website, and can be processed by American Express, VISA or MasterCard or a check for the full amount, payable to the Southern Federal Tax Institute, Inc. Registration will be accepted on-site, based on the availability of space and materials. All events are scheduled at the Grand Hyatt Atlanta in Buckhead. Hyatt reservations and discounted room rates are only available if you register on or before September 26, 2014.

PAPERLESS OPTIONS Every registrant will receive a thumb-drive containing all of the materials for this year’s program along with all prior program materials dating back to 1998. In addition, every registrant will receive an e-mail in advance of the program with a link and password that will provide access to this year’s materials via the internet. You will be able to download and print the materials for any programs that you desire to have at the conference. In addition, you will be able to access and download the materials at the conference via the SFTI website. There will be power strips at many tables so that registrants can use their computers for the duration of the conference. Printers will not be available at the conference, so it will be necessary to print any materials that you may desire to have prior to arriving at the conference.

SPECIAL ACCOMMODATIONS SFTI is committed to providing equal access to our meetings for all attendees. If you are an attendee with a disability and require programmatic accommodations, please contact the SFTI office. In an effort to provide the highest quality of service

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to all attendees, we require that details of all access requests be communicated in writing to our office at least 14 days in advance of the commencement of the meeting.

BADGES Attendees will be issued a name badge upon arrival that is required for admission to all events.

BREAKFAST A complimentary continental breakfast will be provided each morning at the time indicated on the daily schedule. Food and beverages are provided for on- site consumption only.

MID-DAY PROGRAMThose registrants who sign up for an optional mid-day program no later than 10:00 AM the day of the program will be provided a box lunch free of charge when they attend.

REFUND POLIC Y Registrants who are unable to attend the Institute will receive a full refund (less a $75 administrative fee) if a written cancellation notice, via U.S. mail or email, is received on or before October 6, 2014. The Institute will gladly accept substitutions for cancellations received after that date, but refunds will not be issued.

FUTURE INSTITUTES Fiftieth Annual Institute, October 19-23, 2015 Fifty-First Annual Institute, September 19-23, 2016

AIRLINES SFTI has arranged for discounted travel on American Airlines. Use your own travel agent or call the airline directly. American Airlines (800) 433- 1790 (file #A96H4BR) or go to www.aa.com.

CAR RENTAL SFTI has arranged for discounted car rental rates with AVIS. To receive a special discount call 1-800-525-7537 x 33297 and reference group AWD: D086179

CONTINUING EDUCATIONSFTI is an advanced seminar for tax professionals versed in the field based on education in law, accounting, or business programs, or the equivalent in practical experience. The seminar consists of a series of lectures on specific topics grouped by subject matter, for which no specific advance preparation is required. In past years, the Institute’s program has been approved for CPE/CLE accreditation by states with mandatory requirements.

Objectives: Acquisition of knowledge and skills to develop proficiency as a practitioner; maintenance of professional competence as a practitioner; and development of proficiency in performance of intricate and complex legal, accounting, estate and trust law tasks. SFTI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education of the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219 -2417. Web site: www.nasba.org.

For more information regarding administrative policies such as complaints and refunds, please contact our offices at (770) 640- 8300.

The Institute strives to present programs that will meet most state continuing education requirements for attorneys and CPAs, and will continue to submit all of its offerings for approval by the various states´ legal and accounting boards. The Institute seeks to offer programs that will allow registrants to satisfy their obligation to receive continuing education credit in the areas of ethics and professionalism. However, each state licensing organization has specific requirements for these programs, and some organizations will not allow a single program to simultaneously qualify for ethics and professionalism credit. The Institute cannot guarantee that the programs it designates as addressing ethics and professionalism will be credited by all continuing education certifying organizations.

The 2014 program will be submitted to NASBA and the State Bars in Alabama, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee and Virginia. The rules of the North Carolina State Board of CPE Examiners provide that sponsors of continuing education programs which are listed in good standing on the National Registry of CPE Sponsors maintained by the NASBA are also approved CPE sponsors. Submissions will be made to other states where necessary. The 2014 program will also be submitted for CFP approval. Various forms required by each state will be available at the registration desk.

TOTAL COURSE HOURS*

34.75 (60-minute hours) 41.50 (50-minute hours) 2.75 hours ethics 2.75 hours professionalism 4 hours of ethics for Florida CPAs (on Tuesday evening) COURSE HOURS FOR MONDAY - WEDNESDAY*

21.50 (60-minute hours) 25.75 (50-minute hours) 2.00 hours ethics 2.00 hours professionalism 4 hours of ethics for Florida CPAs (on Tuesday evening) COURSE HOURS FOR WEDNESDAY - FRIDAY*

20.50 (60-minute hours) 24.50 (50-minute hours) 2.75 hours ethics2.75 hours professionalism COURSE HOURS FOR THURSDAY AND FRIDAY*

13.25 (60-minute hours)15.75 (50-minute hours).75 hours ethics.75 hours professionalism * Not including Early Morning and Mid-day presentations.

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BE SURE TO REGISTER OR VISIT US AT WWW. SFTI.ORG

SCHEDULE AT A GLANCE

14

MONDAY, OCTOBER 208:00-9:00Breakfast

9:00-10:30 RECENT FEDERAL INCOME TAX DEVELOPMENTS

10:30-10:45 Break

10:45-12:00RECENT FEDERAL INCOME TAX DEVELOPMENTS (Con’t)

12:15-1:05Mid-day Program: DEFENDING CAPTIVES, CONSERVATION EASEMENTS, AND OTHER CONGRESSIONAL INDUCEMENTS. Sponsored by CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & AUGHTRY and presented by Philip Karter, William O. Grimsinger and Hale E. Sheppard

1:15-2:15LEGISLATIVE UPDATE AND THE PROSPECTS FOR TAX REFORM

2:15-3:15STAYING ABREAST OF THE EVER-GROWING LABYRINTH OF US TAX REPORTING AND COMPLIANCE REQUIREMENTS FOR INBOUND FOREIGN CLIENTS

3:15-3:30Break

3:30-4:30ANALYZING TAX-RELATED PROVISIONS OF PARTNERSHIP AGREEMENTS FROM THE PERSPECTIVE OF THE LAWYER WHO DRAFTS THEM AND THE ACCOUNTANT WHO HAS TO LIVE WITH THEM

4:30-5:30UPDATE ON THE 3.8% NET INVESTMENT INCOME TAX AND RELATED DEVELOPMENTS UNDER SECTION 469

5:30-7:00Cocktail Party

TUESDAY, OCTOBER 217:15-8:15Breakfast

8:15-9:05HOT TOPICS IN PARTNERSHIP AND REAL ESTATE TAXATION

9:05-10:05YOU THOUGHT YOUR 1031 EXCHANGE WAS ON AUTOPILOT BUT THE CREW FELL ASLEEP: A COMPENDIUM OF CLASSIC 1031 BUSTS

10:05-10:20 Break

10:20-11:10 IT WASN’T BROKE BUT THEY FIXED IT: COPING WITH THE NEW SECTION 752 LIABILITY ALLOCATION REGIME AND TRANSITION RULES

11:10-12:00AN ABC PRIMER ON TIMBER TAXATION FOR TAX ADVISORS WHO HAVE TROUBLE SEEING THE FOREST AND THE TREES

12:15-1:05Mid-day Program: POSSIBILITIES AND PITFALLS: HOW TO CAPTIVATE YOUR CLIENTS WITH THE FASTEST GROWING BUSINESS TOOL. Sponsored by The STRAUSS LAW FIRM and presented by Peter J. Strauss

1:15-2:15 SECTION 351: TRAPS AND OPPORTUNITIES

2:15-3:15 TAX CONSIDERATIONS FOR BUYERS AND SELLERS OF S CORPORATIONS

3:15-3:30 Break

3:30-4:30 DEALING WITH STATE AND LOCAL TAX ISSUES IN CORPORATE ACQUISITIONS

4:30-5:30 WHAT TO DO WHEN YOUR CLIENT HAS VALUABLE REAL ESTATE TRAPPED IN A C CORPORATION

5:45-7:45 FLORIDA CPA REQUIREMENTS FOR ETHICS IN TAX PRACTICE

WEDNESDAY, OCTOBER 227:30-8:30 Breakfast

8:30-9:30 PAYROLL TAX AND FRINGE BENEFIT AUDIT UPDATE

9:30-10:45 CLAIMS OF ESOP PROMOTERS: PEELING THE ONION

10:45-11:00 Break

11:00-12:00 NEW ISSUES AND OPPORTUNITIES IN THE EVER CHANGING WORLD OF ACCOUNTING METHODS

12:15 -1:05 Mid-day Program: AN ADVISOR’S GUIDE TO LIFE INSURANCE. Sponsored by MCGUIREWOODS LLP AND NEASE, LAGANA, EDEN & CULLEY, INC. and presented by Dennis I. Belcher and Lawton M. “Mac” Nease, III

1:15-2:15 TRICKLE DOWN AUDIT PROCEDURES

2:15-3:15 APPEALING ALTERNATIVES FOR DEALING WITH APPEALS

3:15-3:30 Break

3:30-4:30 IT STILL TAKES A VILLAGE: BALANCING PROFESSIONALISM, PRIVILEGES, AND ADVOCACY IN TAX CONTROVERSIES

4:30-5:30 GETTING COMFORTABLE WITH YOUR LEVELS OF COMFORT AND DETERMINING WHAT LEVEL OF COMFORT YOU NEED TO GET COMFORTABLE WITH

5:30-6:30 Exhibitor’s Cocktail Hour

THURSDAY, OCTOBER 23

6:30-7:30 Breakfast

7:30-8:15 Special Early Morning Presentation: RECENT CASES, REGULATIONS, RULINGS, AND PRONOUNCEMENTS

8:15-9:15 PLANNING FOR ESTATES UNDER $10 MILLION: A RUBIK’S CUBE OF SIMPLICITY

9:15-10:00 MALPRACTICE IN ESTATE PLANNING: SOME GUIDANCE ON HOW TO AVOID IT

10:00-10:15 Break

10:15-11:00 GRANTOR TRUSTS AND THE NEW PLANNING LANDSCAPE

11:00-12:00 THE FUTURE OF ESTATE PLANNING

12:15-1:05 Mid-day Program: PATHWAYS TO LIQUIDITY: ADVISING YOUR CLIENTS IN MONETIZING THEIR LIQUID WEALTH. Sponsored by MERCER CAPITAL and presented by Matthew R. Crow, CFA, ASA and Nicholas J. Heinz, ASA

1:15-2:15 THE INVIGORATING INTERSECTION OF THE ESTATE TAX AND INCOME TAX

2:15-3:15 FILING THE GIFT TAX RETURN WITH AN EYE TOWARD AUDIT

3:15-3:30 Break

3:30-4:30 ESTATE PLANNING THROUGH AN ASSET PROTECTION LENS

4:30-5:30 CONTEMPORARY ISSUES IN THE FEDERAL INCOME TAXATION OF TRUSTS

5:30-7:00 Cocktail Party

FRIDAY, OCTOBER 24

7:00-8:00 Breakfast

8:00-9:00 FIXING A BROKEN TRUST

9:00-10:00 CHARITABLE DISPOSITIONS OF PRIVATE EQUITY INTERESTS, INCLUDING FAMILY PARTNERSHIPS

10:00-10:15 Break

10:15-11:00 ESTATE PLANNING FOR SECOND MARRIAGES AND BLENDED FAMILIES

11:00-12:00 HOW TO FIX A BROKEN IRA

12:15-1:05 Mid-day Program: IMPACTFUL TRENDS AND OPPORTUNITIES IN STRATEGIC PHILANTHROPY. Sponsored by FIDELITY CHARITABLE and presented by Josh Daly

1:15-3:15 RECENT ESTATE PLANNING DEVELOPMENTS

3:15 Adjourn

October 20-24, 2014Grand Hyatt Atlanta In Buckhead

Atlanta, Georgia

Name _________________________________________________Name on Badge __________________________________________________________ Profession: q Attorney q CPA qAtty/CPA q CFP qCLU q ChFC q Other _____________________________________________________________________Firm __________________________________________________________________________________ Mailing Address ___________________________________________________________________________ City/State/Zip Code ________________________ Phone ( ) _______________________ Fax ( ) __________________________ Email/Internet Address _____________________________________How did you learn about SFTI: q Word of Mouth q Direct Mail q Publication (Please List)__________________________________________________________________ Registration fees include: session, presentation outlines in print and electronic form, continental breakfast, Monday & Thursday evening cocktail parties and the Wednesday exhibitors’ cocktail hour. Food and beverage is provided for on site consumption only.

REGISTRATION FEES* EARLY: STANDARD: LATE: Received by 8/18/14 Received by 9/29/14 Received after 9/29/14 ◊TWO- DAY REGISTRATION – ESTATE PLANNING TOPICS 10/23-10/24 (Thurs & Fri) $695 $745 $825 ◊THREE- DAY REGISTRATION – GENERAL SESSIONS & ETHICS 10/20-10/22 (Mon, Tues, Wed) $795 $845 $925 ◊THREE-DAY REGISTRATION – ETHICS & ESTATE PLANNING 10/22-10/24 (Wed, Thurs, Fri) $795 $845 $925 ◊FIVE -DAY REGISTRATION – ALL SESSIONS 10/20-10/24 (Mon - Fri) $995 $1,045 $1,125

*PAPERLESS DISCOUNTS: $50 Discount - No Hardcopy Materials • $25 Discount – Volume 1 Only (Mon-Wed) • $25 Discount – Volume 2 Only (Thurs-Fri)*OTHER DISCOUNTS: *50% Discount for IRS/Treasury Employees. **15% Discount for firms or companies registering 6 or more people - registrations must be mailed together in the same envelope (please use printable registration form). ***30% Discount for firms or companies registering 11 or more people - registrations must be mailed together in the same envelope (please use printable registration form).

Florida CPAs: Will you attend the Tuesday evening Ethics session (no additional cost)? q Yes q No

Do you plan to attend the cocktail party Monday evening? q Yes q No Do you plan to attend the cocktail party Thursday evening? q Yes q No

Are you staying at the Grand Hyatt? q Yes q No If no, where? q Other hotel _______________ q Friend/Relative q Home

Is this your first time attending SFTI? q Yes q No How many years have you attended SFTI? _______________

METHOD OF PAYMENT (Checks or VISA, MasterCard and American Express) Enclosed is a check for $ _______________ Check#_________________ (Make checks payable to: SFTI) Please charge my (check one): q Visa q MasterCard q American Express Account # __________________________________________ Expiration Date________________ Name of Cardholder _____________________________________________________ Signature__________________________________________________

Refund Policy: Registrants who are unable to attend the Institute will receive a full refund (less a $75 administrative fee) if a written cancellation notice is received on or before October 6, 2014.The Institute will gladly accept substitutions for cancellations received after that date, but refunds will not be issued. Refunds will be made after the Institute. Tax ID#: 58 6047220

If you are registering additional persons from your firm, please submit a registration form for each registrant. This form may be photocopied. To avoid duplicate charges, DO NOT MAIL original registration form if you have already faxed it. Southern Federal Tax Institute, Inc. • 2107 North Decatur Road • PMB 521 • Decatur, GA 30033 • 770.640.8300 • FAX 800.858.9940 • www.sfti.org

Mail or fax this form directly to: Reservations Department, Grand Hyatt Atlanta in Buckhead, 3300 Peachtree Road, Atlanta, Georgia 30305 or call (404) 365-8100 or (800) 233- 1234; FAX (404) 364 -3887. For discounted rates, reservations must be received by September 26, 2014 and before the reserved block of rooms are filled.

HOTEL RESERVATIONS

Name ___________________________________________________________________ Phone ( ) _______________________________________ Address __________________________________________________________________ City/State/Zip Code ______________________________________Firm Name ________________________________________________________________ Phone ( ) _______________________________________ Address __________________________________________________________________ City/State/Zip Code _____________________________________Arrival Date_______________ Time ____________ Departure Date_______________Time ____________ CHECK IN TIME 3:00 PM. Access to accommodations prior to 3:00 PM is subject to availability. CHECK OUT TIME 12:00 NOON Guaranteed Reservations: Reservations must be accompanied by deposit or credit card guarantee.

FOR GUARANTEED RESERVATIONS: I understand that I am liable for one night’s room and tax which will be deducted from my deposit, or billed through my credit card, in the event that I do not arrive or cancel by 4 PM on day prior to my arrival. An early departure fee of $50 will be charged if you check out prior to your scheduled departure date. Departure date can be changed up to your check- in date without penalty.

Signature ___________________________________________Gold Passport No _______________________ Requests for specific accommodations will be first come, first serve at check- in. Tax rate on room is 15%, subject to change. If unable to present a credit card at check- in, cash deposit is requested.

Guest Room Information: No. of Rooms: ______ Single (1 person) @ $239 ______ Double (2 persons) @ $239 (including unlimited internet access)Bed Type: q King q 2 Doubles q Smoking, Additional persons: $25. Children under 18 free when sharing room with parents. If room is not available at rate requested, reservations will be made at next available rate. Share with ___________________________________________________________ In accordance with the Americans with Disabilities Act, please notify Grand Hyatt Atlanta if you have any special needs. 15

REGISTRATION FORM

Please hold my reservation for (check one) q Guaranteed by 1st night’s deposit plus 15% tax ($___________ enclosed)

q Credit Card guarantee Type___________________________________

Credit Card No.____________________________ Exp._____________

Signature of Cardholder ______________________________________

SFTI expects to receive commissions from the Grand Hyatt Atlanta that are derived from room fees paid by SFTI registrants. SFTI uses these commissions to pay a portion of the expenses it incurs in producing the Institute.

SOUTHERN FEDERAL TAX INSTITUTE 2107 NORTH DECATUR ROAD, PMB 521 DECATUR, GA 30033 770.640.8300 PHONE

WWW.SFTI.ORG

NOW OFFERING 2, 3 OR 5 -DAY SESSIONS

tax attorneys • accountants • financial planners • estate planners • life under writers

JOIN US!October 20-24, 2014

Grand Hyatt Atlanta In Buckhead | Atlanta, Georgia

ALL SESSIONSMONDAY - FRIDAY

GENERAL SESSIONS & ETHICS

MONDAY - WEDNESDAY

ETHICS & ESTATE PLANNINGWEDNESDAY - FRIDAY

ESTATE PLANNINGTOPICS

THURSDAY - FRIDAY

NON-PROFIT ORG.U.S. POSTAGEPAID

Permit No. 2276Atlanta, GA