Event Details
Overview
Fredrikson’s Tax Disputes & Litigation Group is hosting our annual Let’s Talk About Tax—An Annual Sampler Event. The afternoon will feature a variety of tax topics (including an engaging Ethics session!), a networking lunch and evening happy hour with live music. The event will include guest appearances by Marilyn Wethekam from COST, Olga Goldberg from Pierce Atwood and Bob Bamsey from GKC Solutions!
For more information on how to register, email events@fredlaw.com.
Agenda
| 11:30 a.m.-12 p.m. | Networking Lunch | |
| 12-4:10 p.m. | Tax Topics Sampler | |
| 4:10-6 p.m. | Networking Cocktail Reception |
Sessions and Objectives
12-1 p.m.
1.0 Ethics CLE & CPE Credit
Gryffindor v. Slytherin: Ethical Case Studies of Good Versus Evil
This interactive session will begin with the theoretical underpinnings of ethics for tax practitioners, with a brief overview of the philosophy of ethics in a tax practice and a comparison of tax ethics to malpractice standards. The speakers will then focus on the practical implications of a modern tax practice in a digital age, highlighting updates to the ABA Rules of Professional Conduct, ABA Formal Opinions and applicable state ethics rules and opinions relating to remote work and use of developing digital technologies. The speakers will also review relevant changes to the AICPA Statements of Standards for Tax Services going into effect in 2024. Finally, the audience will be engaged in a “speed round” of ethical dilemmas to ensure practical application of the subject matter in a changing and increasingly digital environment.
Learning Objectives:
After attending the session, the participant will be able to:
- Describe the applicable rules of professional conduct for tax attorneys and CPAs, including in particular the ABA Rules of Professional Conduct and recent ABA and state ethics opinions, as well as the 2024 changes to the AICPA Statements of Standards for Tax Services.
- Distinguish ethical rules applicable to tax practice from malpractice standards.
- Identify the emerging ethical considerations that arise in modern tax practice, including remote work and the use of developing digital technologies.
Speakers:
Olga Goldberg, Esq.
Partner
Pierce Atwood LLP
Portland, ME
Jessica Manivasager, Esq.
Shareholder
Fredrikson & Byron, P.A.
Minneapolis, MN
1-1:10 p.m.
Networking Break
1:10-1:35 p.m.
The Marauder’s Map to Tax Credits and Clean Energy: Managing the Mischief of the Inflation Reduction Act
In August 2022, Congress passed the largest single investment ever in clean energy. Among other things, the Inflation Reduction Act boosts investment in clean energy production, storage, and U.S. manufacturing by providing tax incentives for both the industry and consumers. This presentation will provide a brief overview of the IRA’s new and expanded tax credits, it’s two-tier credit system (including “base” and “bonus” amounts), and perhaps the most revolutionary item of the bill, the transferability of tax credits. We will also briefly discuss the plethora of guidance issued by the IRS and its practical impact.
Learning Objectives:
After attending this session, participants will be able to:
- Summarize the key tax credits created or expanded by the IRA.
- Describe the two-tier credit system, including increases to credits for satisfying certain “prevailing wage and apprenticeship” rules and other adders.
- Identify how transferability can benefit your business.
Speakers
Will Howieson, Esq.
Associate
Fredrikson & Byron, P.A.
Minneapolis, MN
Jenny Pusch, Esq.
Senior Associate
Fredrikson & Byron, P.A.
Minneapolis, MN
1:35-2 p.m.
Muggles Beware! It Takes More Than Owls to Set Up a Direct Mail Purchasing Company
Most practitioners working in the state or federal income tax space have had the experience working with transfer pricing concepts and professionals. However, for most sales and use tax practitioners transfer pricing concepts are largely unchartered territory. This session combines the experiences of both a sales tax professional and a transfer pricing expert to discuss a specific example, a direct mail purchasing company, when the two practices can come together to provide sales and use tax benefits for companies. In addition to discussing the advantages, the speakers will walk through the transfer pricing concepts in play as well as other considerations related to setting up a structure of this sort.
Learning Objectives:
After attending the session, the participant will be able to:
- Describe the overall structure of a direct mail purchasing company and determine the potential tax benefits of setting up this type of structure.
- Identify the specific transfer pricing considerations that must be evaluated, modeled, and documented when setting up intercompany transactions in a structure such as a direct mail purchasing company.
- Evaluate other considerations such as increased and/or shifting state income tax burdens that are created when putting in place purchasing company structures.
Speakers:
Bob Bamsey, MBA
Partner
GKC Solutions, LLC
West St. Paul, MN
Kyle Brehm, Esq., MBA
Officer
Fredrikson & Byron, P.A.
Minneapolis, MN
2-2:10 p.m.
Networking Break
2:10 – 2:35 pm
Tricks, Trapdoors, and the Minnesota Ministry of Revenue’s Three-Headed Dog
Over the past two decades, and spanning a half dozen different Commissioners of Revenue, the Minnesota Department of Revenue has a disappointing history of less than transparent behavior. During this session, the presenter will discuss multiple instances where the Department of Revenue chose not to follow Minnesota Tax Court decisions. In several of these situations, the Department did not issue any type of notification to taxpayers and then later forced them into either relitigating the same cases or accepting settlements of assessments based only on the taxpayer following established tax court precedent. But, there may be hope—this presentation will close with a discussion of proposed legislation within the 2024 legislative session.
Learning Objectives:
After attending the session, the participant will be able to:
- Discuss the lengthy history of the Minnesota Department of Revenue ignoring Minnesota Tax Court decisions to the detriment of taxpayers and providing little to no transparency while doing so.
- Understand the proposed legislation impacting this issue during the 2024 legislative session.
Speaker:
Masha Yevzelman, Esq.
Shareholder
Fredrikson & Byron, P.A.
Minneapolis, MN
2:35-3p.m.
Magic in the Market: Unlocking Hogwarts' Real Estate Value
This session will cover current trends in valuing corporate headquarters and other owner-occupied properties for purposes of property tax appeals.
Learning Objectives:
After attending the session, the participant will be able to:
- Identify current issues in valuing corporate campuses and owner-occupied office properties.
- Discuss recent cases involving corporate campuses and other owner-occupied properties.
- Determine next steps, tricks, and traps for initiating a property tax appeal of corporate campus.
Speaker:
Lynn Linné, Esq.
Shareholder
Fredrikson & Byron, P.A.
Minneapolis, MN
3-3:10 p.m.
Networking Break
3:10-4:10 p.m.
From Hogsmeade to Diagon Alley, Where You Set Up Shop Matters: A Multistate Income Tax Update
From the invasive spread of worldwide combined reporting to states’ ongoing shapeshifting between cost-of-performance and market-based sourcing, there has been no shortage of recent developments within the state income tax space. During this session, presenters will discuss a number of recent litigation updates and the impact these case results have on other taxpayers. In addition, the speakers will dive into the challenges related to worldwide combined reporting specifically as well as discuss the overall state and local tax costs of doing business in states across the country.
Learning Objectives:
After attending the session, the participant will be able to:
- Describe the impact that recent case litigation around the country has on taxpayers doing business within the corresponding states.
- Determine the state and local tax costs associated with doing business on a multistate basis.
- Discuss the costs and challenges that result when states enact worldwide combined reporting.
Speakers:
Marilyn Wethekam, Esq.
Of Counsel
Council On State Taxation
Chicago, IL
Masha Yevzelman, Esq.
Shareholder
Fredrikson & Byron, P.A.
Minneapolis, MN
4:10-6 p.m.
Networking Reception
Continuing Education
We have applied for Continuing Legal Education (CLE) credit for this program (including 1.0 Ethics credit) in Minnesota.
We have also applied for Continuing Professional Education (CPE) credit for this program (including 1.0 Ethics credit).
Advance Preparation: None | Program Level: Basic | Prerequisites: None | Delivery Method: Group Live | Field of Study: Regulatory Ethics – 1.0 and Taxes – 3.0 | CPE: 4.0 credits.
Fredrikson & Byron, P.A. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on 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 submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.
