Many entities treated as partnerships are now under attack.  The IRS claims that they are incorrectly treating their owners as “limited partners,” thereby escaping self-employment taxes on their distributive shares.  This presentation analyzes the root of the issue in 1977, relevant administrative and court rulings over the following decades, current IRS Compliance Campaign, recent Tax Court decisions, pending cases with various Courts of Appeals, and what it all means for partner characterization in the future.

This session will identify and examine key real estate tax issues likely to arise in the next Congress and beyond. The discussion will focus on the major tax policy challenges and opportunities for U.S. real estate and the real estate industry. How will the recent election influence tax legislation going forward? Topics we will discuss include capital gains, unrealized gains, wealth tax proposals, like-kind exchanges, step-up in basis at death, carried interest, taxation of foreign investment in U.S. real estate, partnership and pass-through tax reform, the net investment income tax, cost recovery/bonus depreciation, affordable housing, Opportunity Zones, tax credits/incentives, tax legislation aimed at institutional owners of housing, and more.

With a focus on real world transactional experiences, the presenter focuses on the tax aspects of certain complex real estate and partnership transactions and the opportunities and often missed issues, pitfalls, and challenges under these types of business transactions.

Mergers of partnerships are frequent occurrences.  We will discuss the implications of “assets up” or assets over” transactions, how a merger/acquisition affects the partnerships and the partners, and the effects of the continuing business.

This panel will provide a practical introduction to Sections 704(c) and 752 and their application to real estate transactions. The panel will start with the basics of Section 704(c) and contributed property before turning to the impact of Section 704(c) on Section 752 partnership liability allocations and their significance for real estate partnerships.

More than 3 million fiduciary income tax returns are filed annually. For the newer practitioner, concepts such as Distributable Net Income (DNI) and the 65-day rule may baffle. But for even the experienced attorney or CPA, the state income income tax return is a bigger quandary. In what states must a return be filed? Besides a source state, do you look to where the trust settlor or decedent was domiciled? Or do you look to the location of the fiduciary? What about the residence of the fiduciary? What if two or more states claim the right of taxation? This session will examine the interesting issues of multistate filing of Forms 1041.

The panelists will discuss the year’s important developments in the federal estate and gift tax areas.  The presentation will cover new case law, regulations, and legislation, along with any other developments of note.

This program is a practical guide for preparing gift tax returns. The intended audience includes those who are familiar with gift tax basic concepts but are either new to gift tax return reporting or want a deeper understanding and refresher. Topics include filing requirements, annual exclusion gifts, gift splitting, 529 plan elections, QTIP elections, valuation discounts, adequate disclosure, defined value clauses, and GST reporting. The presentation will review the return, schedule by schedule, to point out what reporting is required and what is best practice. We will also review recent changes to the return form and common issues practitioners encounter when preparing gift tax returns.

Comptroller Brooke Lierman and her leadership team

The Comptroller’s Office has recently undergone a major modernization effort that’s reshaping the way we serve Marylanders. This includes launching the MyCOMConnect portal, releasing a modernized tax processing system for personal, fiduciary, and pass-through entity tax types, and realigning our Customer Relationship Management (CRM) platform to give staff enhanced tools and efficient data. These upgrades are supported by improvements to internal operations, including planned updates to our Tax Pro line and more streamlined case management processes, all aimed at strengthening service consistency across the agency. These changes are intended to create a unified operational model that improves data accuracy, strengthens system integrity, and boosts overall performance across Maryland’s tax ecosystem. Because this structure applies uniformly to both prior and future tax years, taxpayers can expect greater transparency and consistency across all filing periods and platforms.

As the pace of technological change increases and reshapes everything, state tax rules are being tested. This session will examine how states are approaching taxation at a time of rapid change: nexus for income tax and sales tax, digital products and services, teleworking, old taxes on new things, and entirely new taxes. Attendees will gain perspective on this changing landscape, and an understanding of the issues that are arising in this evolving landscape.

This presentation will cover tax decisions by the Maryland Tax Court, the state circuit and appellate courts, and federal district courts, as well as updates on pending cases, staff updates, and other tax news of note.

This session is only for IN PERSON attendees. Peter will be speaking from 12:45 p.m. - 1:15 p.m.