BUSINESS AVIATION TAXES SEMINAR - May 4-5, 2017 | Marina del Rey, CA REGISTER TODAY - NBAA

D E D I C AT E D T O H E L P I N G B U S I N E S S
         ACHIEVE ITS HIGHEST GOALS.

                              BUSINESS AVIATION
                                 TAXES SEMINAR
                      May 4-5, 2017 | Marina del Rey, CA

                                    REGISTER TODAY
                       www.nbaa.org/tax-seminar/2017

                                    Presenting Sponsor

PROVEN TAX PLANNING
STRATEGIES FOR AIRCRAFT
OWNERS AND OPERATORS
The NBAA Business Aviation Taxes Seminar on May 4 to 5 in
Marina del Rey, CA features an all new one-and-a-half-day format
providing in-depth presentations on the most important tax planning
topics. Beginning on the afternoon of May 4, the complex and evolving
IRS rules on cost disallowances for entertainment use flights will be
analyzed in three dedicated sessions.

On May 5, expert presenters will lead interactive sessions on federal
and state tax considerations that offer planning opportunities and flag
potential pitfalls. All of the presentations will focus on the latest regulatory
developments and recent audit activity.

Held at the Ritz Carlton Marina del Rey, the seminar includes an evening
reception and value added networking opportunities throughout the event.

            Entertainment Use Regulations: Learn best practices
7 8 9 0
4 5 6
            from the experts, develop strategies for calculations
1 2 3
            and create a process for classifying flights.

            IRC Section 280F: Understand why these rules and
            associated business use tests impact depreciation
            and ownership structures.

            Family Offices and Closely Held Businesses:
            Review unique tax planning strategies for the
            increasing number of aircraft not held in a traditional
            corporate structure.

WHO SHOULD ATTEND
Anyone involved with the management of tax, accounting and legal topics
associated with business aircraft, including: attorneys, accountants, tax
advisors, aviation professionals, flight department personnel, aircraft
owners/operators, and others. Both members and non-members of
NBAA are welcome and encouraged to bring their general legal counsel
or accountants who may not specialize in aviation.

REGISTRATION IS AVAILABLE ONLINE:

SEMINAR LOCATION AND
HOTEL INFORMATION
All seminar events will be held at The Ritz-Carlton, Marina del Rey
where NBAA has secured a limited number of discounted rooms
for attendees.

The Ritz-Carlton
4375 Admiralty Way
Marina del Rey, CA 90292
Telephone: (310) 823-1700

Room Rate: $279/night plus taxes
Cut-Off Date: April 11, 2017, or when room block sells out –
whichever comes first.
Online Reservations: www.nbaa.org/tax-seminar/housing

Register by April 13, 2017 for the early
bird discounted price of $950
Early-Bird Registration Saves $250!

www.nbaa.org/tax-seminar/2017

AGENDA

THURSDAY, MAY 4
1:30 – 1:40 p.m.      Welcome and Introduction

1:40 – 2:40 p.m.      Lessons Learned: Five Years of Working with the
                      Entertainment Use Final Regulations

Speakers: Rick Farley, PwC; John Hoover, Cooley LLP
Take a deep dive into the practical challenges that arise when applying the
entertainment use disallowance rules under IRC § 274 to business aviation.
Common questions including the ability to utilize straight-line depreciation
for disallowance calculations will be discussed in detail. Challenging elements
of the rules dealing with interest allocation and deadhead legs will also be
reviewed. Finally, learn how leasing and charter can be used as a planning
tool and discuss best practices for audit preparation.

2:40 – 3:40 p.m.      Entertainment Use Disallowance Calculations

Speakers: George Rice, Rice & Associates; Tom Wagner, RSM US LLP
The final entertainment use disallowance rules require complex calculations,
detailed recordkeeping, and close coordination between a flight department and
its internal or external tax advisors. Through a review of sample spreadsheets,
understand differences between the disallowance calculation methods. Details
on an organized process for tracking entertainment use, classifying passengers
and retaining key documents will also be discussed. Finally, the impact of
income imputation, timeshare reimbursements and charter flights on
entertainment use calculations will be covered in detail.

3:40 – 4:00 p.m.      Afternoon Break

4:00 – 5:00 p.m.      Defining Entertainment Use: Case Law and Scenarios

Speakers: Doug Stewart, AircraftLogs (moderator); Phil Crowther, Law Offices of
Phil Crowther; Ruth Wimer, McDermott Will & Emery
Through a review of IRS guidance and case law, develop a working definition
of what constitutes an entertainment use flight that is subject to the cost
disallowance. Learn to apply this definition to common practical scenarios,
including travel between homes and spouse or family member travel to
business events. Also discuss cases and guidance in IRC § 162 dealing with
air travel costs. Finally learn about best practices to comply with travel expense
deductibility rules and meet substantiation requirements.

5:30 – 7:00 p.m.      Evening Reception for Attendees and Speakers

FRIDAY, MAY 5
9:00 – 9:10 a.m.      Welcome and Day 1 Recap

9:10 – 10:00 a.m.     Cost Reimbursement Options for Business
                      Aviation Flights

Speakers: Aaron Goerlich, Garofalo Goerlich Hainbach; David Hernandez, Vedder Price
Creating an aircraft ownership and operating structure that accomplishes tax
planning goals while also complying with often conflicting FAA regulations is
a challenge. Understand how FAA Part 91 regulations can allow cost sharing
though arrangements such as timeshares and the potential tax consequences.
Also, review operating structures available for business aircraft and the latest
FAA legal interpretations on cost sharing. Finally, review the complex citizenship
rules for aircraft registration and the use of owner trusts as planning tools.

10:00 – 10:50 a.m. Federal Excise Tax Considerations for Aircraft
                   Owners and Operators

Speakers: Joanne Barbera and Melissa Stanley, Barbera & Watkins
Flights operated under either Part 91 or 135 of the Federal Aviation Regulations
can be subject to federal excise taxes (FET) requiring careful planning.
Analyze how FET can have an impact on structures involving compensation
or reimbursement and discuss non-compliance risks and defenses. Also learn
about potential FET implications for structures involving a single member LLC
and hear about air transportation tax issues for management companies and
emerging business aircraft utilization business models.

10:50 – 11:10 a.m. Morning Break

11:10 – 12:00 p.m. State Tax Planning: Focus on Western States

Speakers: Vicky Boladian, Aerlex Tax Services; Jordan Miller, CenterPoint Aviation Law
Learn how to implement a state tax planning strategy that takes into account
federal tax issues and FAA considerations. Examine the relevance of property
taxes on aircraft ownership in key western states and challenging property tax
apportionment issues. Also, discuss the latest developing state tax issues,
including renewed focus on related party leasing structures. In California,
understand the differences between common exemptions and specific
requirements for achieving each exemption.

12:00 – 1:30 p.m      Lunch

1:30 – 2:00 p.m.      Tax Reform and Congressional Priorities:
                      The Impact on Business Aviation

Speaker: Gary Gasper, Washington Counsel Ernst & Young (invited)
Comprehensive tax reform plans currently being discussed by the Adminis-
tration and Congress will have a significant impact on aircraft owners and
operators. For example, learn how fundamental changes to the depreciation
system that are under discussion could affect aircraft transactions. The
potential repeal of the Affordable Care Act and elimination of the Net
Investment Income Tax will also be discussed in detail.

2:00 – 3:00 p.m.      Aviation Tax Planning for Closely Held Businesses
                      and Family Offices

Speakers: Alvaro Pascotto, Law Offices of Alvaro Pascotto
Analyze common ownership and operating structures used by closely held
businesses or family offices and learn to identify unique federal tax consid-
erations. Focus on the “at-risk” rules under IRC § 465 and their application to
these structures. Also, analyze the specific federal tax issues for ownership
structures involving partnerships and S corporations and learn about the
latest IRS audit issues.

3:00 – 3:20 p.m       Afternoon Break

3:20 – 4:10 p.m.      Passive Activity Loss Rules for Business Aircraft
                      Transactions

Speakers: Keith Swirsky, GKG Law
The passive activity loss limitation rules under IRC § 469 are a common audit
target, and apply to a variety of common aircraft ownership/operating structures.
Analyze how these rules apply to dry leases and charters to related or third parties.
Since the exceptions to the passive loss rules are complex, learn how they can
apply to common business aviation activities. Finally, review the grouping rules,
their potential planning benefits and recent IRS guidance on the subject.

4:10 – 5:00 p.m.      IRC Section 280F: Planning Strategies for
                      Listed Property

Speakers: Jed Wolcott, Wolcott & Associates (moderator);
Ryan DeMoor, Amway; Sue Folkringa, Wolcott & Associates
Properly applying the rules and tests under IRC § 280F is critical, as in most
cases that will determine how a business aircraft is depreciated for tax purposes.
Learn how to apply the 25%/50% tests as they relate to qualified business
use. Using specific examples, understand how common aircraft utilization
strategies are defined for § 280F purposes. Also analyze how falling below
certain business use thresholds can have significant tax depreciation impacts.
Finally, review the unique § 280F challenges for certain related party leasing
structures commonly used in business aviation.

5:00 – 5:10 p.m.      Closing Remarks

TITLES OF ATTENDEES AT 2016 SEMINAR

CONTINUING EDUCATION CREDIT
         CPE CREDIT
Attending this NBAA Business Aviation Taxes Seminar provides a
maximum of 11.0 hours of recommended continuing education (CPE)
credits. In accordance with the standards of the National Registry of CPE
Sponsors, CPE credits have been granted based on a 50-minute hour.
NBAA 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 addressed to the National Registry of CPE
Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN, 37219-2417. Website: www.nasba.org.

Delivery Method: Group-Live
Program Level: Intermediate
Prerequisites: None
Advance Preparation: None Required
Recommend CPE Credit: 11.0
Fields of Study: Taxes (8.0 hours maximum CPE recommended)
		                 Business Law (3.0 hours maximum CPE recommended)
CPE Complaint Resolution Policy: For more information regarding
administrative policies such as complaint and refund, please contact the
National Business Aviation Association at (202) 783-9000.

CLE CREDIT
NBAA has not submitted this Seminar for CLE approval to any state
provider. Upon request, NBAA will provide an attendance confirmation
letter to support CLE applications. Based on a 50-minute hour, this
Seminar may be eligible for up to 11.0 CLE credits.

National Business Aviation Association
          1200 G Street NW, Suite 1100
          Washington, DC 20005

SPONSORS
NBAA thanks the sponsors of the 2017 Business Aviation Taxes Seminar:

PLATINUM
                                          An   Company

                       VedderPrice

GOLD

SILVER

BRONZE

If you would like to sponsor the 2017 Tax Committee
Seminars/Conferences, please contact Scott O’Brien
at sobrien@nbaa.org.