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Jerald David August, Esquire
Esperanté Building
222 Lakeview Avenue
West Palm Beach, FL 33401

Tel: 561.835.9600
Fax: 561.835.9602

info@fedtaxlaw.com









 
 


Click here to access online learning programs/podcasts delivered by Jerald David August in association with ALI-ABA.

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“Selected Income Tax Considerations Concerning Choice of Entity for Conducting Business Operations Outside the United States”, American Bar Association Section of Taxation May 2010 Meeting, S Corporations Committee, S Corporations Engaged in International Business Operations: A Good Choice?, Washington, DC, May 7, 2010.

“Estate Tax Repeal: The Impact on Estate & Small Business Planning”, ALI-ABA Live Video Webcast for Estate Planner & Tax Lawyers, City Bar Center for CLE, New York, NY, April 19, 2010.

“Codification of the Economic Substance Doctrine in the Health Care Act as Amended by the 2010 Health Care Reconciliation Act”, Fox Rothschild LLP Tax & Estates Meeting, Philadelphia, PA, April 13, 2010.

“The Estate Planning Quagmire of 2010, Caused by the One Year Repeal of the Federal Estate Tax”, Pennsylvania Bar Institute, Philadelphia, PA, March 22, 2010.

“2010 and Beyond: The State of the Estate Tax”, Philadelphia Bar Association/Pennsylvania Bar Institute Probate & Trust Law Section, Quarterly Meeting, The CLE Conference Center, Philadelphia, PA, March 2, 2010.

“The One Year ( More or Less) Repeal of the Federal Estate and Generation Skipping Transfer Taxes: What Hath Congress Wrought on Us Poor Estate Planners and Our Clients”, The Philadelphia Bar Association/Philadelphia Bar Institute, Probate & Trust Law Section, Quarterly Meeting, Philadelphia, PA, March 2, 2010.

“The One Year ( More or Less) Repeal of the Federal Estate and Generations Skipping Transfer Taxes: What Hath Congress Wrought on Us Poor Estate Planners and Our Clients: In Depth Analysis of Impact on Estate & Small Business Planning, ALI-ABA Live Video Webcast, Philadelphia, PA, February 16, 2010.

“The Modified Carryover Basis Regime”, In Depth Analysis of Impact on Estate & Small Business Planning, ALI-ABA Live Video Webcast, Philadelphia, PA, February 16, 2010.

“Estate Tax Repeal – Congress’ New Year’s Surprise and Planning with Family Limited Partnerships in Light of Tax Uncertainty”,
Fox Tax Law Review, Philadelphia, PA, February 2, 2010.


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“Update on FLP Strategies”, 16th Annual Estate Law Institute, Pennsylvania Bar Institute, Philadelphia, PA, December 10, 2009.

“S Corporations Engaged in International Business Operations: A Good Choice?”, 68th New York University Institute on Federal Taxation, Closely-Held Businesses Session, San Francisco, CA, November 19, 2009 and New York, NY, October 22, 2009.

“Offshore and International Tax Evasion: What is Going on in Washington and How it Impacts Business and Legal Professionals”, Pitt Law School & Katz School of Business, Philadelphia, PA, October 26, 2009.

“Bank Secrecy Act and Recent IRS Offshore Disclosure Initiatives”, ALI-ABA Live Video Webcast, Offshore & International Tax Evasion: Lawyers as Gatekeepers, Philadelphia, PA, October 13, 2009.

“Offshore and International Tax Evasion: The U.S. and International Community’s Response”, ALI-ABA Live Video Webcast, Offshore & International Tax Evasion: Lawyers as Gatekeepers, Philadelphia, PA, October 13, 2009.

“The Past, Present, and Future of The Federal Transfer Tax System”, New York University Summer Institute on Federal Wealth Taxation, New York, NY, July 2009.

“Planning for Creating, Operating and Unwinding Family Limited Partnerships”, New York University Summer Institute on Federal Wealth Taxation, New York, NY, July 2009.

“The Attorney-Client, Accountant Client Privileges and Work Product Doctrine in Federal Tax Controversies and Trials”, Fox Tax Law Review, Philadelphia, PA, June 17, 2009.

“Winding & Unwinding Family Limited Partnerships: Planning in A Troubled Economy”, ALI-ABA Live Video Webcast, Wealth Planning in Volatile Economic Times, Philadelphia, PA, June 3, 2009.

“Privileges and Client Confidentiality in Tax Practice”, Standards of Tax Practice, American Bar Association Section of Taxation May Meeting, Washington, D.C., May 8, 2009.

“Inside the Beltway: The State of the Federal Estate, Gift and Generation-Skipping Taxes”, Bucks County Estate Planning Council Meeting, Doylestown, PA, April 28, 2009.

“New Tax Return Preparer Standards: December 2008 Final Regulations, Including Impact on Circular 230 Standards”, Presented by ALI-ABA, Audio webcast and Telephone Seminar, Jerald David August, Planning Chair and moderator; Guy B. Maxfield, Professor Emeritus, New York University School of Law and Senior Counsel, Fox Rothschild LLP, Mary Ann Mancini, partner, Bryan Cave, and Trevor Ackerman, KPMG, February 18, 2009, Philadelphia, PA.

“Ethics in Federal Tax Practice: Tax Planning Scenarios”, University of Pennsylvania Law School, Ethics and Advocacy: From the Boardroom to the Courtroom, February 18, 2009, Philadelphia, PA.

“Tax Consequences to Transfers of Closely-Held Business Interests Incident to a Divorce”, ABA Section of Taxation 2009 Midyear Meeting, Jerald David August and Thomas R. White III, January 9, 2009, New Orleans, LA.

“Planning for Creating, Operating and Unwinding Family Limited Partnerships,”
New York University Summer Institute on Federal Taxation, New York, NY, July 2009

 “New Tax Return Preparer Standards: December 2008 Final Regulations, Including Impact on Circular 230 Standards”,

Presented by ALI-ABA, Audio webcast and Telephone Seminar, Jerald David August, Planning Chair and moderator; Guy B. Maxfield, Professor Emeritus, New York University School of Law and Senior Counsel, Fox Rothschild LLP, Mary Ann Mancini, partner, Bryan Cave, and Trevor Ackerman, KPMG, February 18, 2009, Philadelphia, PA.

“Ethics in Federal Tax Practice: Tax Planning Scenarios”,
University of Pennsylvania Law School, Ethics and Advocacy: From the Boardroom to the Courtroom, February 18, 2009, Philadelphia, PA.

“Tax Consequences to Transfers of Closely-Held Business Interests Incident to a Divorce”,
ABA Section of Taxation 2009 Midyear Meeting, Jerald David August and Thomas R. White III, January 9, 2009, New Orleans, LA.


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“Latest Developments in FLPs and Valuation Discount Planning”,
Pennsylvania Bar Institute, 15th Annual Estate Law Institute, December 10, 2008, Philadelphia, PA.

“Circular 230 and the Tax Return Preparer’s Regulations”, Fox Rothschild LLP, CPEs for CPAs,
Jerald David August and Guy B. Maxfield, December 3 & 4, 2008, Greenacres Country Club, Lawrenceville, NJ and Green Valley Country Club, Philadelphia, PA.

“Standards of Tax Practice, Including Ethical Consideration in Advising Closely-Held Business Entities and Their Owners”,
New York University 67th Institute on Federal Taxation, Closely-Held Businesses Session, Jerald David August, Chair, October 22, 2008, New York, NY/November 12, 2008, San Diego, CA.

“The Attorney-Client, Section 7525 and Work Product Privileges in Federal Tax Controversies and Litigation”, NYU 67th Institute on Federal Taxation, Closely-Held Businesses Session, Jerald David August, Chair, October 22, 2008, New York, NY.

“The New Tax Return Preparer Penalties: Impacts on Lawyers, CPAs and Professional Service Organizations”, Hot Topics in Federal Taxation, Fox Rothschild LLP Tax Seminar, October 2, 2008, Cohen Pavilion-Kravis Center, West Palm Beach, FL.

“Heightened Standards of Practice Before the Internal Revenue Service and Increased Tax Return Preparer Penalties”, Fox Rothschild Tax Law Review, September 17, 2008, Philadelphia, PA.

“Panel Discussion: Ethical Standards of Tax Practice for Estate Planners and Tax Advisors; Circular 230, Revisions to the Tax Return Preparer Rules and Conflicts of Interests”, NYU Institute on Federal Wealth Taxation, Program Chair, Jerald David August, July 17-18, 2008, New York, NY.

“Update on Family Limited Partnerships and Litigation Strategies by the Internal Revenue Service”, NYU Institute on Federal Wealth Taxation, Program Chair, Jerald David August, July 17-18, 2008, New York, NY.

"New Tax Preparer Penalties & Enhanced Circular 230 Enforcement: An Advanced Seminar", Presented by ALI|ABA, Jerald David August, Co-Chair, Tax and Estates Department, Fox Rothschild LLP, West Palm Beach & Philadelphia, planning chair and moderator; Carolyn H. Gray, Acting Deputy Director, Office of Professional Responsibility, IRS; Richard S. Goldstein, Special Counsel to the Associate Chief Counsel, (Procedure & Administration) IRS; Trevor Ackerman, KPMG; Darryll K. Jones, Professor of Law, Stetson University School of Law; Guy B. Maxfield, Professor Emeritus, New York University School of Law and Senior Counsel, Fox Rothschild LLP;. July 11, 2008.

“New Tax Preparer Penalties & Enhanced Circular 230 Enforcement: An Advanced Seminar”, ALI-ABA video webcast, July 11, 2008, Philadelphia, PA.

"The Assault on Tax Practitioners: The New Tax Return Preparer Penalties", Pennsylvania Institute of Certified Public Accountants, Greater Philadelphia Chapter Practitioner Conference: Challenges Facing Practitioners in 2008, June 3, 2008, Springfield Country Club, Philadelphia, PA

"Tax Free Reorganizations Involving S Corporations", ABA Section of Taxation May Meeting, S Corporation Committee Program, May 9, 2008, Washington, DC.

"Outbound International Tax Planning", Palm Beach Tax Institute, Governor's Club, April 23, 2008, West Palm Beach, FL

"Tax Issues in Mergers and Acquisitions Transactions Involving S Corporations", Mergers and Acquisitions Committee of the Business Law Section, April 16, 2008, Philadelphia, PA

"Recent Revisions to the Tax Return Preparer Rules, Circular 230 and Survey of the Attorney-Client Privilege and Work Product Doctrine in Tax Controversies and Litigation", Fox Rothschild LLP, Corporate Department Meeting, (webcast) Februrary 5, 2008, Philadelphia, PA

“Mergers and Acquisitions Involving S Corporations and Their Shareholders”,
Fox Rothschild Tax Law Review, March 12, 2008, Philadelphia, PA.

“Recent Revisions to the Tax Return Preparer Rules, Circular 230 and Survey of the Attorney-Client Privilege and Work Product Doctrine in Tax Controversies and Litigation”,
B’nai B’rith International, February 28, 2008, Boca Raton, FL.

“Recent Revisions to the Tax Return Preparer Rules, Circular 230 and Survey of the Attorney-Client Privilege and Work Product Doctrine in Tax Controversies and Lititgation”, Jerald David August and Eric J. Michaels, CPEs for CPAs, February 11, 2008, Roseland, New Jersey

“Ethics in Federal Tax Practice: Tax Planning Scenarios, Ethics and Advocacy: From the Boardroom to the Courtroom", University of Pennsylvania Law School, February 4, 2008

“Recent Revisions to the Tax Return Preparer Rules, Circular 230 and Survey of the Attorney-Client Privilege and Work Product Doctrine in Tax Controversies and Litigation”, Fox Rothschild LLP Corporate Department Meeting (webcast), February 5, 2008, Philadelphia, PA.

“Recent Revisions to the Tax Return Preparer Rules, Circular 230 and Survey of the Attorney-Client Privilege and Work Product Doctrine in Tax Controversies and Lititgation”, ALI-ABA Presents Lee Sheppard on Current Tax Topics, Live Video Webcast Interview, January 23, 2008, Philadelphia, PA.

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"Mergers and Acquisitions Involving S Corporations" Caler Donten, Druker and Levine P.A., West Palm Beach, FL, January 19, 2007.

"Ethics in Federal Tax Practice: Tax Planning Scenarios, Ethics and Advocacy: From the Boardroom to the Courtroom",
University of Pennsylvania Law School, February 5, 2007

"Mergers and Acquisitions Involving S Corporations",
Carnegie Mellon University, Tepper School of Business, Business Valuation and Deal Structure, Posner Hall, Pittsburgh, PA, February 7, 2007

"Planning for the Termination of an Interest in a Family Limited Partnership – Withdrawals, Distributions and Other Exit Strategies"

Pennsylvania Bar Institute, Practical Estate Planning Opportunities Using FLPs, Philadelphia, PA /Mechanicsburg, PA and Pittsburgh, PA, April 11, 18 & 25, 2007

"From Byrum to Bongard….the Long Journey that Section 2036 Has Taken in Moving from Trusts to Family Limited Partnerships for Estate Tax Purposes"
Pennsylvania Bar Institute, Practical Estate Planning Opportunities Using FLPs, Jerald David August, Guy B. Maxfield & Pamela H. Schneider, Philadelphia, PA, April 11, 2007; Jerald David August & Guy B. Maxfield, Mechanicsburg, PA, April 18, 2007; Jerald David August, Guy B. Maxfield, Raymond P. Parker, Pittsburgh, PA, April 25, 2007

"Partnership Allocation Issues Under Section 704(b) for the Closely-Held Business: Issuing Interests in Profits and Capital to Service Partners",
Jerald David August and Thomas R. White, III, American Bar Association, Tax Section Meeting, May 11, 2007, Washington, DC

"Mergers and Acquisitions Involving S Corporations"
Seventh Annual Oregon Tax Institute, Portland, Oregon, May 18, 2007

"Planning for the Termination of an Interest in a Family Limited Partnership—Withdrawals, Distributions and Other Exit Strategies",

B’nai B’rith International, June 6, 2007, Philadelphia, PA.

"Update on FLP Litigation and Important Planning Issues in Forming and Maintaining FLPs for Transfer Tax Purposes",
Institute on Federal Wealth Taxation, Program Chair, Jerald David August, NYU Summer Institute in Taxation, July 26 -27, 2007, New York, NY.

"Impact of FIN 48 on Publicly & Privately Owned Businesses",
Jerald David August, Program Chair, Pennsylvania Bar Institute (Videoconference - Mechanicsburg), September 24, 2007, Philadelphia

"Choice of Entity Selection in the New Millennium",
"Mergers and Acquisitions Involving S Corporations", Jerald David August, Chair, Closely-Held Businesses program, 66th NYU Annual Institute on Federal Taxation, Wednesday, October 24, 2007, New York, NY.

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"Unwinding the Supposedly Irrevocable Estate Plan", Jerald David August and Mark L. Silow, Second Annual Great Lakes Federal Tax Institute, Cleveland, Ohio, May 12, 2006.

"Planning for the Termination of an Interest in a Family Limited Partnership—Withdrawals, Distributions and Other Exit Strategies",
Jerald David August, Second Annual Great Lakes Federal Tax Institute, Cleveland, Ohio, May 12, 2006.

"Will Congress Retain the Estate Tax? Impact on Circular 230 on Estate Planners", Jerald David August and Guy Maxfield, CPEs for CPAs, Green Valley Country Club, Lafayette Hill, PA, June 30, 2006

"Mergers and Acquisitions Involving S Corporations" 65th New York University Annual Institute on Federal Taxation, (Oct/Nov. 2006)

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“Tax Issues in Forming and Operating Joint Ventures” ABA – Tax Section Mid-Year Meeting, San Diego, California, January 21, 2005

“Tax Consequences to Transfers of Closely-Held Business Interests Incident to a Divorce” ABA – Tax Section Mid-Year Meeting, San Diego, California, January 21, 2005

“Evidentiary Privileges Applicable to Accounts and Lawyers in Tax Matters” FICPA – Broward County Chapter Meeting, Dania, Florida, January 8, 2005.

"The Impact of Circular 230 and Tax Shelter Reporting and Disclosure Rules on Privately-Held Companies and Their Tax Advisors" 64th New York University Annual Institute on Federal Taxation, (Oct/Nov. 2005)

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“Conversions From C to S Status” The 56th Annual Virginia Conference of Federal Taxation, Charlottesville, Virginia, June 3, 2004

"Avoiding Malpractice in Advising Owners of Closely-Held Businesses",

63rd New York University Annual Institute on Federal Taxation, (Oct/Nov. 2004).

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“Basic Federal Tax Considerations With Respect to Involuntary Conversions of Real Property” 20th Annual ALI-ABA Course of Study – Eminent Domain and Land Valuation Litigation, Coral Gables, Florida, January 11, 2003

“Phantom Income Problems with Holding Partnership Interests Having Deficit Capital Accounts at Death”
ABA – Tax Section Meeting, San Antonio, Texas, January 24, 2003

“Significant Estate, Gift and General Skipping Tax Changes Made by the Economic Growth and Tax Relief Reconciliation Act of 2001 (“EGTRRA”)”
The Smith Companies, Ltd. & SunLife Financial – Present Estate Planning for the New Year and Beyond, Ft. Lauderdale, Florida, February 19, 2003

"Utilization of Formula Clauses to Reduce the Impact of Federal Transfer Taxes",
62nd New York University Annual Institute on Federal Taxation, (Oct./Nov.2003)

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“General Tax Principles and Concepts in Structuring an Acquisition of a Corporation” The Florida Bar – Tax Section 24th Annual Meeting, Kissimmee, Florida, April 25, 2002

“Moving In, Out and Around 2701: When You See It, When You Don’t”
Federal Tax Day, New Brunswick, New Jersey, May 8, 2002


"General Tax Principles and Concepts in Structuring an Acquisition of a Corporation" 61st New York University Annual Institute on Federal Taxation, Oct/Nov. 2002

"Where Are We Now with Family Limited Partnerships for Federal Tax Purposes" 61st New York University Annual Institute on Federal Taxation, Oct/Nov. 2002

“Selected Current Developments in Income Taxation for Pass Through Entities”
FICPA Conference, Orlando, Florida, November 7, 2002


“Converting C Corporations to S Corporations – A Review of Important Tax Planning Issues” FICPA Conference, Orlando, Florida, November 7, 2002

“Selected Current Developments In Income Taxation for Pass Through Entities”
CBIZ Century Business Services –  SRTDA Business Services, Inc., Boca Raton, Florida, November 27, 2002

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“Planning for Acquisitions or Dispositions of S Corporations”
The Palm Beach Tax Institute West Palm Beach, Florida, January 24, 2001

“Federal Estate Tax: The Present and The Future” 2001 ULPA/LPI Annual Meeting, Singer Island, Florida, January 25, 2001

“S Corporations as Acquisition Vehicles” Columbus Bar Association – 2001 Tax Institute, Columbus, Ohio, February 28, 2001

“What Estate Planners Need to Know about Planning for Sales and Acquisitions of S Corporations” Martin County Estate Planning Council, Inc., Stuart, Florida, April 26, 2001

“Current Developments in Family Limited Partnerships” AICPA Conference on Tax Strategies for The High-Income Individual Nashville, Tennessee, May 17, 2001

“Impact of Section 1041 on Redemptions and Other Dispositions of Interests in Corporations and Partnerships Incident to Divorce”
Presidential Showcase Program / ABA Tax, Family Law and Real Property Probate & Trust Law Sections, Chicago, Illinois, August 6, 2001

“Converting C Corporations to S Corporations – A Review of Important Issues”
36th Annual Southern Federal Tax Institute, October 2, 2001

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“Estate Planning for Owners of Pass-Through Entities” National CLE Conference, Vail, Colorado, January 7, 2000

“Impact of Section 1041 on Redemptions and Other Dispositions of Interests in Corporations and Partnerships Incident to Divorce” ABA Section of Taxation –Winter Meeting, January 22, 2000

“Liabilities and Ethical Obligations of Accountants and Lawyers in Practicing before the Internal Revenue Service” Daskal Bolton Manela Devlin & Co., CPAs, Boca Raton, Florida, January 14, 2000

“Use of GRATs to Own S Stock” 11th Annual Spring CLE Symposia – Real Property, Probate & Trust Law, Miami Beach, Florida, March 24, 2000

“Liabilities and Ethical Obligations of Accountants and Lawyers in Practicing Before the Internal Revenue Service”
Schmidt & Company, CPAs, West Palm Beach, Florida, October 11, 2000

© 1995-2010 Jerald David August

ATTENTION: IRS CIRCULAR 230 DISCLOSURE:
Pursuant to Treasury Regulations, any tax advice contained in this communication
(including any attachments) is not intended or written to be used, and cannot be
used or relied upon by you or any other person, for the purpose of (i) avoiding
penalties under the Internal Revenue Code, or (ii) promoting, marketing or
recommending to another party any tax advice addressed herein.