Tax Section 38 th Annual Meeting

The Florida Bar Tax Section presents the Tax Section 38 th Annual Meeting May 19-21, 2016 The Fontainebleau Miami Beach 4441 Collins Avenue Miami Beach, FL 33140 1-305-535-3283 Remembrance Dinner for Robert Hudson, Jr. Recipient Outstanding Tax Attorney of the Year

Dear Friends: I hope that you can join us during the weekend of May 19th for our Annual Meeting at the Fontainebleau Hotel, Miami Beach. We have a full agenda planned for this meeting. Our CLE program, Tax Planning with substance: A Multi-Area Survey of the Economic Substance Doctrine will be at the Fontainebleau Hotel on Friday, May 20th. We believe that you will find this program to be both informative and practical in the important area of economic substance. The Economic Substance CLE will cover all aspects of economic substance from a practical perspective. The speakers will include the Managing Counsel, Miami Office, Jim Barrett, Chair Office of IRS Chief Counsel, two members of the faculty at the University of Miami Law School Tax Program and four former Tax Section chairs. You should book your room as soon as possible because our block of rooms at the Fontainebleau Hotel is selling out quickly due to the high demand. After Friday s CLE, we will hold a reception at the Fontainebleau Hotel and will be free to explore South Beach. On Saturday, we have a full morning of meetings that will include 3 hours of Federal Tax CLE and State Tax CLE. At lunch on Saturday, we will discuss our various Tax Section initiatives including our over 40 CLE s this year, our pending and completed regulations comments projects, our lunchtime New Tax Lawyer lunches, our new listserves and our recently completed trip to Havana, Cuba. On Saturday night, we will hold our dinner posthumously honoring Bob Hudson, Jr. as our Gerald T. Hart Outstanding Tax Attorney of the Year. This dinner will be held on Saturday night from 7 to 10 p.m. at the Fontainebleau Hotel. For those new tax lawyers who are interested in applying, we have included in these materials financial assistance application forms to assist with the expense of attending this meeting. I hope that you can join us for this busy, meaningful and fun weekend. Jim. Hotel Information Tax Section s 38 th Annual Meeting The Fontainebleau 4441 Collins Avenue Miami Beach, FL 33140 Group Cut Off Date: April 28, 2016 Special Group Rate: $329 Reservations: 1-800-548-8886

Tax Section 38th Annual Meeting May 19-21, 2016 Fountainebleau, Miami Beach, Florida SCHEDULE OF EVENTS Attire for business sessions is resort casual. Saturday night dinner is business attire. Thursday, May 19, 2016 5:00 p.m. 6:30 p.m. Directors Meeting 9:00 p.m. 11:00 p.m. Hospitality Suite Friday, May 20, 2016 7:30 a.m. 8:30 a.m. Continental Breakfast 8:45 a.m. 5:00 p.m. Tax Planning with Substance: A Multi-Area Survey of the Economic Substance Doctrine 5:30 p.m. 7:30 p.m. Networking Reception with UM Tax LLM Faculty and Students 9:00 p.m. 11:00 p.m. Hospitality Suite Saturday, May 21, 2016 7:45 a.m. 9:00 a.m. Continental Breakfast 8:00 a.m. 8:45 a.m. Long Range Planning Committee 8:30 a.m. 9:15 a.m. New Tax Lawyers Committee 8:30 a.m. 9:15 a.m. Sponsors Committee 9:15 a.m. 10:00 a.m. Education Division 9:15 a.m. 10:00 a.m. Section Administration Division 9:30 a.m. 10:30 a.m. State Tax Division 10:45 a.m. 12:30 p.m. Federal Tax Division 12:30 p.m. 2:00 p.m. Tax Section Meeting & Luncheon 6:30 p.m. 7:30 p.m. Cocktail Reception 7:30 p.m. 10:30 p.m. Tax Attorney of the Year Presentation & Dinner 10:30 p.m. Midnight Midnight Hospitality Suite

Registration Form The Florida Bar Tax Section 38 th Annual Meeting The Fontainebleau Miami Beach, FL 33140 1-305-535-3283 Return this form no later than May 2, 2016, if paying by check. Please mail your payment to: The Florida Bar - Tax Section, 651 East Jefferson Street, Tallahassee, FL 32399-2300. Or if paying by credit card, return by fax to: (850) 561-9413 or email to: registrations@flabar.org. Please call 850-561-5831 with any questions. Name (on name badge): Florida Bar # City, State: Phone: Email: Guests (for name badges): Thursday, May 19, 2016 Time Event Attendance / Fee (if applicable) 5:00 p.m. 6:30 p.m. Directors Meeting (Item #8190426) 9:00 p.m. 11:00 p.m. Hospitality Suite Friday, May 20, 2016 7:30 a.m. 8:30 a.m. Continental Breakfast 8:45 a.m. 5:00 p.m. CLE: Tax Planning with Substance: A Multi-Area Survey of the Economic Substance Doctrine (2056R) See pages 8-9 5:30 p.m. 7:30 p.m. Networking Reception - Fontainebleau Hotel (Item#8190427) 9:00 p.m. 11:00 p.m. Hospitality Suite Saturday, May 21, 2016 7:45 a.m. 9:00 a.m. Breakfast (Item #8190428) 8:00 a.m. 8:45 a.m. Long Range Planning Committee (Item #8190429 ) 8:30 a.m. 9:15 a.m. Sponsors Committee (Item #8190430) 8:30 a.m. 9:15 a.m. New Tax Lawyers Committee (Item # 8190431) 9:15 a.m. 10:00 a.m. Section Administration Division (Item #8190432 ) 9:15 a.m. 10:00 a.m. Education Division (Item # 8190433) 9:30 a.m. 10:30 a.m. State Tax Division (Item # 8190434) 10:45 a.m. 12:30 p.m. Federal Tax Division (Item #8190435) 12:30 p.m. 2:00 p.m. Executive Council Mtg. Luncheon (Item #8190436 ) 6:30 p.m. 7:30 p.m. Cocktail Reception (Item #8190439 ) 7:30 p.m. 10:30 p.m. 2016 Tax Attorney of the Year Dinner $100 per person (Item #8190440 ) ($93.46 + 6.54 tax) Please note: $135.00 After 4/30/16 10:30 p.m. Midnight. Hospitality Suite (includes hospitality suite, Tax Section Member & Sponsor Fee $100 (Item#8190441) breakfast and lunch) Guest Fee $50 (Item#8190442) TOTAL AMOUNT ENCLOSED FOR TAX SECTION ANNUAL MEETING ($) Total Enclosed METHOD OF PAYMENT Check enclosed (made payable to The Florida Bar) (CHECK ONE) Credit Card: q MasterCard q Visa q Discover q AMEX Signature: Billing Zip Code: Card Number: Expiration Date: / (MO/YR) Name on Card: WRITTEN CANCELLATION MUST BE RECEIVED NO LATER THAN MAY 5th, 2016, TO RECEIVE A REFUND. A $25 SERVICE FEE APPLIES TO ALL REFUND REQUESTS.

Robert Hudson, Jr. Tax Section of The Florida Bar Gerald T. Hart Outstanding Tax Attorney of the Year 2015-2016 On Saturday night, we will be having a dinner to honor our recipient of the Gerald T. Hart Outstanding Tax Attorney of the Year, Bob Hudson. Bob passed away last December. As such, the dinner will be a fond remembrance rather than the more traditional roast. Bob was a passionate person who loved his work, his family and his friends. He was a larger than life character and had a great sense of humor. Bob was a significant patron of the arts and was active in community service organizations including the Performing Arts Center Foundation, the Concert Association of Florida, Camillus House, the International Wine & Food Society, the Leukemia Society and the Greater Miami Chamber of Commerce to name a few. He had an encyclopedic knowledge of wine and a superb palate. Bob was born in Miami and attended Coral Gables Senior High. He earned both his J.D. and his Bachelor degrees in economics from the University of Florida. He earned an LL.M. in Taxation from New York University. He had an outstanding 44-year career as an internationally known and respected tax attorney. In June, he would have celebrated his 30th year with Baker & McKenzie. Some of his notable accomplishments of which he was most proud included spearheading the Florida Bar Committee whose members wrote the pivotal draft legislation to amend the Foreign Investment in Real Property Tax Act (FIRPTA), which was enacted by Congress as Code Section 1445 in 1984. In 1990, he was invited to testify before the U.S. House of Representatives Ways and Means Committee on federal taxation of non-u.s. investors in U.S. real estate. He wrote extensively, publishing some 100 articles. He spoke at all 33 of the FICPA/FBTS International Tax Conferences. His BNA portfolio on Federal Tax Considerations of Foreign Investment in the U.S. Real Estate is regarded as one of the leading authorities on that subject. Bob was the Chairman of the Florida Bar Tax Section from 1989 to 1990. He learned of his being named as the recipient of the Gerald T. Hart Outstanding Tax Attorney of the Year Award shortly before his passing and was excited about the event and the roast that went with it. Bob was a member of the American College of Tax Counsel, the Advisory Board Member of BNA s Tax Management International Journal, the Executive Council of the U.S. Branch of the International Fiscal Association, FIBA, the Florida Bar International Law Section, the ABA s Committee on Inbound International Tax, the New York Bar Tax Section and STEP. Bob was the past President of the Japan Society of South Florida and an active participant in the World Trade Center, the British-American Chamber, the German-American Trade Council, and the Swiss-American Chamber. He served as the Honorary Legal Advisor to Her Majesty s Britannic Consul and Co-chair of the Host Committee on the occasion of Queen Elizabeth s visit to Miami in May 1991. Bob served as the Managing Partner of Baker & McKenzie s Miami office several times and was a wellrespected leader to attorneys and staff alike. His clients benefitted from his brilliant intellect, clever mind and dedication to problem solving. He encouraged people to do their best and to pursue their dreams. He will be remembered as a husband, father and grandfather as well as a friend and mentor to many and an inspiration to all. In addition to his wife, Edith, Bob was survived by his children, Daniel and Patrick and his grandchildren, Ava and William.

IN MEMORIAM NICK LIOCE 1951-2016 It is with deep sorrow that we announce the passing away of Nick Lioce, 65, a former Chair of The Tax Section of the Florida Bar. He was born February 13, 1951 and passed away March 10, 2016 from complications following heart surgery. Originally from New Jersey, his family moved to Riviera Beach in the 1950 s. His father, Dominick, worked at Pratt & Whitney while his mother, Evelyn raised him and his sister Laraine and brother David. He graduated from Riviera Beach High School and went on to attend Florida State University, where he earned a Bachelor s and Master s of Accountancy. He then graduated from Florida State University College of Law in 1979. He loved FSU and was an active alumni. Nick was a partner at Nason, Yeager, Gerson, White, and Lioce in Palm beach Gardens, specializing in tax law. In addition to being a former chair of the Tax Section, he was Past President of The Palm Beach Tax institute, Past President of The American Association of Attorney- CPA S and a member of the Board of Directors of The Florida Lawyers mutual insurance company. He was past chairman of The Forum Club of the Palm Beaches and was an author/speaker on numerous tax topics. Nick was an energetic, friendly free spirit. His great passion was music, and he spent much of his free time as the lead singer of the eponymous Nick-O-Rockwa and Contra Band. With a songbook featuring classic rock and R&B hits, they played many venues across Palm Beach County. Despite an ever changing lineup, Nick remained a constant during the band s 30-year run. As Chair of The Tax Section Chair, his Amelia Island reception where he performed with members of the rock bands Survivor and White Snake, was unforgettable. Nick also was tireless in his efforts to help improve Florida s partnership and LLC acts. He was a wonderful chair of the Tax Section who was always active with Tax Section projects. He took the lead with many of the Tax Section s sponsor relationships and built that aspect of the Tax Section s activities considerably during his years with the Tax Section. Nick is survived by his wife Pamela Cherry Lioce, his son Michael Lioce, Michael s wife Ash Lioce, his grandson Domenick, his granddaughter Leeta, his daughter Christina Lioce Cramer, her husband Chris Cramer, his sister Laraine Cheek and her husband John Cheek. Nick was loved by many people and will be deeply missed.

Florida Bar Tax Section Scholarship Application Scholarships to defray tuition expense for the Florida Bar Tax Section programs are available upon application on a program-by-program, case-by-case basis. Preference will be given to public interest lawyers, solo or small firm practitioners of limited means, and unemployed attorneys. To request a scholarship for a Florida Bar Tax Section program, please complete the form below and email the completed form to dapfelbaum@deanmead.com. Please submit a completed application at least three weeks before the first day of the program. Please allow two weeks for a response. Program Information Please provide the following information about the specific Florida Bar Tax Section program for which you are requesting a scholarship. Program Title: Lowest Tuition Rate Applicable to You: Applicant Information Name: Bar Number: Firm/Organization: Address: City/State/ZIP: Phone Number: Email: Are you a current Florida Bar Member? Are you a current Tax Section Member? Y / N Y / N Are you a member of any Tax Section Committees? If yes, please list them: Please list the states/jurisdictions in which you are licensed: How many years have you practiced law? What is your area of practice? If you work for a law firm, please indicate how many attorneys are at the firm: F0214624.v1

The Florida Bar Continuing Legal Education Committee and the Tax Section present Tax Planning with Substance: A Multi-Area Survey of the Economic Substance Doctrine COURSE CLASSIFICATION: INTERMEDIATE LEVEL Live Presentation: Friday May 20, 2016 The Fontainebleau 4441 Collins Avenue Miami Beach, FL 33140 (305) 585-3283 Live Live Webcast Audio CD Video DVD Course No. 2056R This presentation is meant to set the stage for the application of economic substance and related doctrines in federal tax law to various substantive tax areas. The program will briefly trace the history of the tension between structuring transactions in a tax efficient manner and building structures which only promote tax savings. The Taxman s version of Tom and Jerry. 8:45 a.m. - 9:00 a.m. If it s too good to be true...an Overview of Economic Substance and Related Doctrines Guy Whitesman, Ft. Myers 9:00 a.m. - 9:50 a.m. Questioning Your Substance: Understanding How the Economic Substance Doctrine Impacts Joint Ventures and Related Partnership Issues William R. Siegel, Miami James A. Schmidt, Tampa 9:50 a.m. - 10:40 a.m. Economic Substance and Corporate Transactions Mitch Goldberg, Boca Raton Dana L. Trier, New York, NY 10:40 a.m. - 10:55 a.m. Break 10:55 a.m. - 11:45 a.m. The Economic Substance Doctrine in Florida State and Local Taxation Mark E. Holcomb, Tallahassee Steven M. Hogan, Tallahassee 11:45 a.m. - 12:35 p.m. Limitations on the Use of Tax Advice to Avoid Civil Penalties Andrew M. Tiktin, Miami 12:35 p.m. - 1:45 p.m. (Lunch Included) Substance Abuse: The Wild Ride to Defining Economic Substance and Applying it in Tax Controversies Mitchell I. Horowitz, Tampa Adam J. Smith, Gainesville 1:45 p.m. - 2:00 p.m. Break 2:00 p.m. - 2:50 p.m. The Application of U.S. Substance-Based Rules to Non U.S. Taxpayers Patricia A. Brown, Coral Gables Christopher Callahan, Coral Gables 2:50 p.m. - 3:40 p.m. The Application of U.S. Substance-Based Rules to U.S. Taxpayers with Foreign Investments, Businesses or Other Economic Connections Shawn Wolf, Miami Michael J. Bruno, Miami 3:40 p.m. - 3:55 p.m. Break 3:55 p.m. - 4:45 p.m. Estate Planning Minefield: Economic Substance and Related Doctrine David E. Bowers, West Palm Beach Scott Snyder, Miami 4:45 p.m. - 5:00 p.m. Looking Through: Finding the Next Big Thing in Economic Substance Joseph Schimmel, Miami CLE CREDITS CLER PROGRAM (Max. Credit: 9.0 hours) General: 9.0 hours CERTIFICATION PROGRAM (Max. Credit: 9.0 hours) Tax Law: 9.0 hours Business Litigation: 9.0 hours Seminar credit may be applied to satisfy CLER / Certification requirements in the amounts specified above, not to exceed the maximum credit. See the CLE link at www.floridabar.org for more information. Prior to your CLER reporting date (located on the mailing label of your Florida Bar News or available in your CLE record on-line) you will be sent a Reporting Affidavit if you have not completed your required hours (must be returned by your CLER reporting date). TAX LAW SECTION James H. Barrett, Miami Chair William R. Lane, Jr., Tampa Chair-elect Steven Hadjilogiou, Miami CLE Chair Abrahm Smith, Miami CLE Chair CLE COMMITTEE Patrick L. Booter Imhof, Tallahassee, Chair Terry L. Hill, Director, Programs Division FACULTY & STEERING COMMITTEE Joseph Schimmel, Miami Program Chair Guy Whitesman, Ft. Myers Program Chair David E. Bowers, West Palm Beach Patricia A. Brown, Coral Gables Michael J. Bruno, Miami Christopher Callahan, Coral Gables Mitch Goldberg, Boca Raton Steven M. Hogan, Tallahassee Mark E. Holcomb, Tallahassee Mitchell I. Horowitz, Tampa James A. Schmidt, Tampa William R. Siegel, Miami Adam J. Smith, Gainesville Scott Snyder, Miami Andrew M. Tiktin, Miami Dana L. Trier, New York, NY Shawn Wolf, Miami WEBCAST: http://tinyurl.com/floridabarcle2056r

Name Florida Bar # Address Phone: ( In-Person Attendance ) City/State/Zip E-mail* *E-mail address required to transmit electronic course materials and is only used for this order. DT: Course No. 2056R Tax Planning with Substance: A Multi-Area Survey of the Economic Substance Doctrine (023) THE FONTAINEBLEAU, MIAMI BEACH, FRIDAY, MAY 20, 2016 MIAMI BEACH, FL o Member of the Tax Section...$295 o Non-section Member...$355 o Full-time law college faculty or full-time law student...$203 o Fee waiver (documentation required)...$50 *On-site registration add $25 REGISTRATION LIVE SEMINAR Online Webcast Section Member...$345 Non-section Member...$405 *Webcast registrants receive an email two days prior to the seminar, with log-in credentials to access course materials and the webcast link. Call InReach at (877) 880 1335 with any questions. How to Register o Check (made payable to The Florida Bar) 651 E. Jefferson St., Tallahassee, FL 32399 o Enclosed is my check in the amount of $60 to join the Tax Section. Membership expires June 30, 2016. o Credit Card Online (www.flabar.org/cle) Phone (850-561-5831) Fax (850-561-9413) Email (registrations@flabar.org) o Visa o Master Card o AMEX o Discover Name on Card: Card No.: Exp. Date: Billing Zip: Signature: How to Register Go to: http://www.tinyurl.com/floridabarcle2056r Please call 877-880-1335 for assistance with webcast registration. Please check here if you have a disability that may require special attention or services. To ensure availability of appropriate accommodations, attach a general description of your needs. We will contact you for further coordination. REFUND POLICY: A $25 service fee applies to all refunds. Requests must be in writing and received by the appropriate entity no later than two business days following the live course presentation or receipt of product. Registration fees are non-transferrable across platforms. Registrants who do not notify The Florida Bar by 5:00 p.m., May 10, 2016 that they will be unable to attend the seminar, will have an additional $50 retained. Persons attending under the policy of fee waivers will be required to pay $50. COURSE BOOK AUDIO CD VIDEO DVD PUBLICATIONS Private recording of this program is not permitted. Delivery time is 4 to 6 weeks after 5/20/16. Please include sales tax unless tax-exempt or a nonresident of Florida. If tax exempt, include documentation with the order form. o COURSE BOOK ONLY (2056M) Cost $60 plus tax (Certification/CLER credit is not awarded for the purchase of the course book only.) + TAX $ = TOTAL $ o AUDIO CD (2056C) (includes electronic course material) $295 plus tax (section member) $355 plus tax (non-section member) + TAX $ = TOTAL $ o VIDEO DVD (2056D) (includes electronic course material) $345 plus tax (section member) $405 plus tax (non-section member) + TAX $ = TOTAL $ Related Florida Bar Publications can be found at http://www.lexisnexis.com/shop/flabar/default.page

Register Now! Tax Section 38 th Annual Meeting The Florida Bar 651 E. Jefferson Street Tallahassee, FL 32399-2300 PRSRT-STD U.S. POSTAGE PAID TALLAHASSEE, FL Permit No. 43 Special Thanks to the Tax Section Sponsors 2015 2016 Platinum Management Planning, Inc. Silver Bessemer Trust Business Valuation Analysts Coral Gables Trust Kaufman, Rossin & Co. Key Private Bank Morgan Stanley MRW Consulting PCE Companies Wilmington Trust Strategic Alliance American Association of Attorney - CPAs