This three-day seminar was designed to ensure that all attendees would benefit, from beginners to experts. The first two days consisted of a logical and comprehensive study of the basic framework and many important intricacies of Subchapter K, an area of the tax law that many believe can be understood only in its totality. The third day focused on the application of partnership taxation to specific industries, including oil and gas, hedge funds and private equity funds.
Throughout this intensive program, emphasis was given to legislative, regulatory, and judicial developments in Subchapter K, as well as important partnership transactions, controversies, and trends. Speakers from Treasury and the IRS joined a number of the more advanced panels in order to discuss cutting-edge issues.
Mr. Skarlaros' panel "Economic Substance, Judicial Doctrines and Legal Ethics" focused on impact on partnerships of recent judicial decisions, legislation, and administrative developments relating to economic substance, tax shelters and the codification of the economic substance doctrine, including LB&I Directives; penalty defenses, rules of professional responsibility and conduct, including Circular 230 and related ethical considerations that come into play in evaluating the difference between good tax planning and overly aggressive or even criminal tax advice.