Montana Tax Institute

68th Annual Montana Tax Institute October 15-17, 2020

presented by the University of Montana Blewett School of Law

Sponsors

First Interstate Bank Wealth Management
Montana Community Foundation
Wells Fargo
US Bank

About

The 68th Annual Montana Tax Institute will be fully online this year, with a program featuring a distinguished faculty of national tax practitioners and scholars addressing a broad range of current tax topics.

What's the same:

  • Qualifies for live CLE instruction
  • Same national experts bringing you the hottest tax topics
  • Professor Sam Donaldson will still wear a sweater vest 

What's different:

  • Presentations divided into three sessions over Thursday, Friday and Saturday, October 15-17
  • Interactive discussion and Q&A opportunities   
  • Lower registration fee to reflect online delivery savings
  • No coffee, but no lines at the restroom!

There will not be a room block at the DoubleTree this year. If you've booked a room at the DoubleTree and will not be coming to Missoula for other reasons, please remember to cancel your reservation.

Registration

Registration is open and available online. Please register in advance. The fee for this year's Montana Tax Institute is $295.

To pay by check for the 68th Annual Montana Tax Institute, please complete the registration form and return it with payment.

For registration assistance or questions, contact Ginger Claussen at 406-243-4623.

Refund Policy

A full refund is available if the cancellation is received on, or before, October 8, 2020. Thereafter, cancellations will not be accepted as individual access codes will be provided on October 9.

Sessions

Who C.A.R.E.S. about S.E.C.U.R.E.?:  IRAs Made Simple
Lester B. Law, Franklin, Karibjanian & Law PLLC, Naples, Florida, and Ramsay H. Slugg, Bank of America, Fort Worth, Texas

Business Losses:  Overview of Income Tax Limitations
Steve Gorin, Thompson Coburn, LLP, St. Louis, Missouri

Post-Election Planning: The Coming Storm for Estate Planners and Their Clients - What Practitioners Should Do Now
Jonathan Blattmachr, Pioneer Wealth Partners, New York

Annual Income Tax Update
Professor Samuel A. Donaldson, Georgia State University College of Law, Atlanta, Georgia

Current Developments in Corporate and Partnership Taxation
Professor Bruce A. McGovern, South Texas College of Law, Houston, Texas, and Professor James M. Delaney, University of Wyoming College of Law, Laramie, Wyoming

Wealth Transfer Tax Annual Update
Professors J. Martin Burke and Elaine H. Gagliardi, University of Montana Blewett School of Law

Foreign Trusts:  What You Don’t Know Can Hurt You
Elizabeth A. Bawden, WithersWorldwide, Los Angeles, California

S Corporations and Section 199A – Did the Government Double Down on the Importance of Shareholder Compensation?
James R. Walker, Lewis Roca Rothgerber Christie, Denver, Colorado

Planning for Transfer of the Family Business from both the Non-Tax and Tax Perspectives
Charles D. Fox IV, McGuireWoods, Charlottesville, Virginia

2020: COVID and Beyond - Grab Bag, Odds and Ends, and Miscellany
Professor Pippa Browde, University of Montana Blewett School of Law

Review of the Past Year’s Significant, Curious, or Downright Fascinating Fiduciary Cases
Dana G. Fitzsimons, Jr., Bessemer Trust, Atlanta, Georgia

Life Insurance Income Tax Traps
Steve Gorin, Thompson Coburn, LLP, St. Louis, Missouri

How to Resecure the Stretch for IRAs and Plans Despite the Secure Act
Jonathan Blattmachr, Pioneer Wealth Partners, New York

Resolving Tensions:  Lawyer Duties to Maintain Confidences, Report Elder Abuse, Avoid Conflicts and Preserve Wills
Moderated by Montana Attorneys:  Ashley Burleson, Bruce O. Bekkedahl, David J. Dietrich, Julie R. Sirrs and Cynthia R. Woods

Schedule

All times are Mountain Standard Time.

Introduction to Online Platform Q & A

8:15 - 9:00 a.m. – Join for Introduction to Online Features

5:00 - 5:45 p.m. – Join for Introduction to Online Features

We have chosen an online platform that is simple to navigate—just click and use. But it’s technology right? We are here to answer your questions about the online platform. Join us for one of the following two sessions if you have questions or simply want to confirm you are set to go for Thursday morning.

Session I is generously sponsored by US Bank, The Private Client Group.
US Bank

7:30-7:55 a.m. "Meet Our Sponsors" Breakfast Social

Bring your morning cup of coffee and visit online with our many sponsors. Pop in and out of the Online Sponsor Rooms. It is only because of the generosity of our sponsors that we can bring to you a distinguished faculty of national tax practitioners and scholars. 

8:00-8:05 a.m. Introduction and Welcome

Dean Paul Kirgis, University of Montana Alexander Blewett III School of Law

8:05-9:05 Review of the Past Year's Significant, Curious, or Downright Fascinating Fiduciary Cases

Dana G. Fitzsimons, Jr.

The session reviews recent cases from across the country to assist fiduciaries and their advisors in identifying and managing contemporary challenges. The presentation discusses a range of subjects including powers of attorney, trust distributions, trust investment duties, accountings, and remedies and damages.

9:05-10:05 Planning for Transfer of the Family Business from Both the Non-Tax and Tax Perspectives

Charles D. "Skip" Fox IV

The most important decision often facing a family business is the transfer of both the ownership and the control of a family business from the older generation to a younger generation or to outsiders. This presentation will first examine the non-tax considerations and challenges involved in creating and maintaining in place a successful plan for the transfer of a family business. The presentation will then examine various tax techniques that may be appropriate in implementing the succession plan once the succession plan is in place.

10:05-10:30 a.m. Break Time with Sponsors

Need some one-on-one conversation?  Drop in to visit the Online Sponsor Rooms.

First Interstate Wealth Management, Montana Community Foundation, Wells Fargo, US Bank

Session II is generously sponsored by Crowley Fleck PLLP.
Crowley Fleck Attorneys PLLP

10:30-11:30 a.m. Post-Election Planning:  The Coming Storm for Estate Planners and Their Client – What Practitioners Should Do Now

Jonathan Blattmachr

No matter which party wins in November, it seems certain there will be pressure to raise taxes.  One area that has and will get a lot of pressure to use to raise Federal revenue relates to estate planning: Estate, gift and GST tax (with vast reduction in exemptions and elimination of GRATs, QPRTs and valuation discounts) or possibly, as recently suggested in an op-ed piece in The New York Times, having inheritances included in gross income; elimination of the step-up in basis either by adopting a  gains tax at death or adoption of a carryover basis system and the retention of estate tax. In any case, it seems certain that planner will be inundated with demands from clients as election day approaches.

11:30 a.m.-12:30 p.m. Federal Wealth Tranfser Tax Update

Professors J. Martin Burke and Elaine Gagliardi

The presentation discusses the most significant developments in wealth transfer taxation during the past 12 months and analyzes the impact of developments on estate planning technique, including limited partnerships, grantor retained annuity trusts, and marital and charitable planning techniques.

 

12:30-1:15 p.m. Lunch Social

Order in and join friends and colleagues that you haven’t seen since the last Tax Institute.

First Interstate Wealth Management, Montana Community Foundation, Wells Fargo, US Bank

Session III is generously sponsored by Accruit.
Accruit

7:30-8:00 a.m. "Meet Our Sponsors" Breakfast Social

Drop into the online sponsor room to visit with our sponsors before the presentations begin.

8:00-9:00 a.m. Life Insurance Income Tax Traps

Steve Gorin

The 2017 tax reform changed income tax rules on when a policy transfer will cause the death benefit to be subject to income tax. Learn how regulations completely overhauled these rules, going far beyond merely implementing the statutory changes (but some of those extra changes were very taxpayer-friendly). Separately, learn how to avoid income tax traps for life insurance used in buy-sell agreements. Sample forms will be provided.

9:00-10:00 a.m. S Corporations and Section 199A – Did the Government Double Down on the Importance of Shareholder Compensation?

James R. Walker

Since its enactment in the 2017 Tax Act, Section 199A has brought new complexity and challenge to S Corporation taxation.  Section 199A also raised the stakes on shareholder compensation determinations.  During this session, James Walker will explain how S corporations can effectively navigate Section 199A and defend compensation decisions making.

10:00-10:20 a.m. Break Time with Sponsors

Need some one-on-one conversation?  Drop in to visit the online sponsor rooms.

First Interstate Wealth Management, Montana Community Foundation, Wells Fargo, US Bank

Session IV is generously sponsored by Wipfli LLP.
Wipfli

10:20-11:50 a.m. Who C.A.R.E.S. about S.E.C.U.R.E.? IRAs Made Simple

Lester B. Law and Ramsay H. Slugg

This presentation summarizes the “old” rules and the “new” rules, post the SECURE and CARES Acts, about IRA planning.  The presentation will then discuss various planning techniques in light of the changes made by those two Acts, with particular focus on the various trade-offs between tax and non-tax considerations.

11:50 a.m.-12:50 p.m. 2020:  COVID and Beyond – Grab Bag, Odds and Ends, and Miscellany

Professor Pippa Browde

A potpourri of hot topics, including COVID-19-related tax issues and Montana state tax update on the Espinoza v. Department of Revenue case recently decided by the United States Supreme Court, with special guest appearance by Professor Anthony Johnstone.

12:50-1:30 p.m. Lunch Social by City

Order in and join colleagues in your city for an online lunch.  Speakers and sponsors will also join the conversation.  Prizes await for the most scrumptious lunch idea.

  • Kalispell & Missoula
  • Great Falls and Helena
  • Bozeman and Billings
First Interstate Wealth Management, Montana Community Foundation, Wells Fargo, US Bank
Session V is generously sponsored by The Foundation for the Diocese of Helena.
 The Foundation for the Diocese of Helena

7:30-8:00 a.m. "Meet Our Sponsors" Breakfast Social

Drop into the Online Sponsor Room to visit with our sponsors before the presentations begin.

8:00-9:00 a.m. Current Developments in Corporate and Partnership Taxation

Professors Bruce A. McGovern and James M. Delaney

The year 2020 brings with it a number of developments in the areas of partnership and corporate taxation. This session reviews the most significant statutory enactments, judicial decisions, IRS rulings, and Treasury regulations promulgated during the last twelve months that affect the domestic income taxation of corporations and partnerships.

9:00-10:00 a.m. Foreign Trusts:  What You Don't Know Can Hurt You

Elizabeth A. Bawden

Estate planners who focus primarily on planning for people in the U.S. are often unfamiliar with international planning strategies and issues. In a global society, however, it is of growing importance to be able to issue spot potential cross-border hazards.  Foreign trust issues, in particular, are complex and require specialized attention, and foreign trust status (and the associated reporting requirements) can easily be triggered inadvertently. Using case studies from actual practice, this session covers the basics of foreign trust classification, taxation and reporting, and offers tips on how to avoid hidden traps for the unwary.

10:00-10:30 a.m. Break Time with Sponsors

This is your last chance to visit with our sponsors.  Please thank them for their support of our conference.

First Interstate Wealth Management, Montana Community Foundation, Wells Fargo, US Bank

Session VI is generously sponsored by Alexander Blewett III School of Law.
University of Montana Alexander Blewett III School of Law

10:30-11:30 a.m. Annual Income Tax Update

Samuel A. Donaldson

This is our annual recap of important federal income tax cases, rulings, regulations, and legislation from the past 12 months affecting individuals and small businesses returns, this time remotely so you can’t throw fruit at the speaker.

11:30 a.m.-1:00 p.m. Resolving Tensions:  Lawyer Duties to Maintain Confidences, Report Elder Abuse, Avoid Conflicts and Preserve Wills

Ashley Burleson, Bruce O. Bekkedahl, David J. Dietrich, Julie R. Sirrs, and Cynthia R. Woods

The roundtable discussions focus on the tensions between a lawyer’s ethical duties to maintain confidences and a lawyer’s legal duties.  The moderators will lead a discussion of the Montana lawyer’s duty to report elder abuse and the recently enacted Montana legislation revoking, by operation of law, transfers at death that occur from the financial exploitation of a vulnerable person. Discussion also addresses the lawyer’s duty to preserve wills in the lawyer’s possession and ethical issues in that regard.

First Interstate Wealth Management, Montana Community Foundation, Wells Fargo, US Bank

Don’t miss out on the following one-hour presentations from two of the nation’s experts in tax and estate planning. These on-demand seminars can be submitted for "other" CLE credits, as opposed to live credits.

How to Re-Secure the Stretch for IRAs and Plans Despite the Secure Act

Jonathan Blattmachr

The SECURE Act has eliminated the lifetime stretch for payments for most beneficiaries succeeding to a qualified plan or IRA after the death of the plan participant or IRA owner.  This presentation takes a deeper dive into the opportunities that remain to use plan or IRA assets to build wealth including naming a Section 678 trust (commonly called a BDIT), an S corporation or a special type of charitable remainder trust as the beneficiary. (1 hour)

Business Losses:  Overview of Income Tax Limitations

Steve Gorin

Business losses are subject to several limitations. In response to the 2020 pandemic, businesses or their owners may carry 2018, 2019, and 2020 losses back five years and get tax refunds.  We will do a “big picture” review of how the net operating loss (NOL), basis, at-risk, and passive loss limitations interact and how they affect income and self-employment tax in light of a 2020 Chief Counsel Advice. The review includes analysis of whether taxpayers benefit from deducting losses currently or suspending them until they have higher earnings and what timing opportunities exist for deducting a loss from an S corporation. (1 hour)

First Interstate Wealth Management, Montana Community Foundation, Wells Fargo, US Bank

Speakers

Elizabeth A. Bawden is a partner in the private client and tax team of Withersworldwide. She is a fellow to the American College of Trust and Estate Counsel. Active in the charitable planning community, she received the 2019 Distinguished Service Award from the Los Angeles Council of Charitable Gift Planners, where she has served as president.  She has also served as a past president of the Partnership for Philanthropic Planning of Greater Los Angeles, and on the Professional Advisory Council of the Ronald Regan Presidential Foundation.  Elizabeth currently serves on the board of the Heifer International Foundation, supporting the work of Heifer International to end hunger and poverty around the world by providing livestock and training to struggling communities.  She is recognized as a Top 50 Women Super Lawyer.  Elizabeth is a graduate of Wheaton College (IL) and the UCLA School of Law where she served as Executive Editor of the UCLA Law Review. After law school, she clerked for Judge Wiley Y. Daniel of the Federal District Court in Colorado. Elizabeth is currently adjunct faculty at the UCLA School of Law teaching Estate and Gift Tax and Estate Planning.

Bruce O. Bekkedahl, a partner with the Billings firm, Patten, Peterman, Bekkedahl & Green P.L.L.C., practices in the areas of estates and trusts, tax, and closely held business. He is a Fellow of the American College of Trust and Estate Counsel.  Bruce actively participates as a member of the Business, Estates, Trusts, Tax and Real Estate Section of the Montana State Bar, and served on the Uniform Trust Code Committee. He is a frequent speaker and lecturer on estate, trust, and tax topics.  Bruce received his Juris Doctorate from the University of Montana School of Law and his LL.M. in Taxation from University of Denver.

Jonathan G. Blattmachr is a principle of Pioneer Wealth Partners, LLC, a boutique wealth advisor firm in Manhattan, and the director of estate planning of the Alaska Trust Company. He is a retired member of Milbank, Tweed, Hadley & McCloy and of the New York, California and Alaska bars. He has authored or co-authored seven books and over 500 articles. He has chaired several committees of the New York and American Bar Associations and the American College of Trust and Estate Counsel. Jonathan is a Fellow and a former Regent of the American College of Trust and Estate Counsel and past chair of its Estate and Gift Tax Committee. Among professional activities, which are too numerous to list, Jonathan has served as an Advisor on The American Law Institute, Restatement of the Law, Trusts 3rd, and as a Fellow and Director of The New York Bar Foundation and as a Fellow of the American Bar Foundation. Jonathan graduated from Columbia University School of Law cum laude, where he was recognized as a Harlan Fiske Stone Scholar, and received his A.B. degree from Bucknell University, majoring in mathematics. He served as an officer in the United States Army from 1970 to 1972 and was awarded the Army Commendation Medal. He is codeveloper of Wealth Transfer Planning, a computerized system for lawyers that automatically generates estate planning documents, such as wills and trusts, and provides specific client advice using a form of artificial intelligence.

Pippa Browde, an Associate Professor of Law at the Alexander Blewett III School of  Law at the University of Montana, teaches courses in Federal Income Taxation, Tax Procedure, Taxation of Business Entities, and Taxation of Property Transactions. She currently serves as Co-Director of the law school’s Montana Tax Institute.  Professor Browde regularly writes a column, Under the Big Sky, for Tax Notes and has published numerous law review articles in the area of tax procedure.  Prior to teaching, Professor Browde worked as a tax attorney for the Internal Revenue Service Office of Chief Counsel in Sacramento, California and New York City. She clerked for the Honorable Cynthia A. Fry on the New Mexico Court of Appeals. Professor Browde earned her J.D. from the University of New Mexico School of Law and her LL.M. in Taxation from New York University School of Law.

Martin Burke is Emeritus Professor of Law and formerly served as Regents Professor of Law and Dean of the University of Montana School of Law. He served as the Director of the UM Tax Institute for more than 25 years. Burke has taught in the tax programs at New York University, the University of Florida, and the University of Washington. He earned his J.D. at the University of Montana School of Law and his LL.M. in Taxation at New York University. He is co-author with Michael K. Friel of Taxation of Individual Income (12th Ed.) (Carolina Academic Press 2018), Taxation of Partnerships and Limited Liability Companies Taxed as Partnerships (Carolina Academic Press 2016), Introduction to the Taxation of Business Organizations and Choice of Entity (Carolina Academic Press 2018) and Understanding Federal Income Tax (5th ed.) (Carolina Academic Press 2016). He is co-author with Friel and Elaine Hightower Gagliardi of Modern Estate Planning (2d ed.)(LexisNexis 2002).

Ashley Burleson is a partner with Crowley Fleck, currently practicing in the firm’s Bozeman office.  She practices in the areas of estate planning, estate and trust administration, formation and governance of family businesses, planning for people with special needs, and charitable and elder planning. She is a board member and past president of the Montana Justice Foundation, a member of the ABA Commission on IOLTA, and a board member of the Bozeman Health Foundation.   Ashley was selected as one of the Billings Gazette’s “40 under Forty” and has been named to the Best Lawyers in America in Trusts and Estates.  Ashley attended the University of Texas, graduating with honors with a degree in accounting, and the University of Montana School of Law, graduating with high honors and serving on the editorial board of the Montana Law Review.

James M. Delaney is the Winston S. Howard Distinguished Professor of Law at the University of Wyoming College of Law. He began his teaching career at the College of Law in 2003, where he teaches Federal Income Taxation, Business Entities Taxation, Estate & Gift Taxation, and Estate Planning. From 2012 through 2013, Professor Delaney served as Counsel to the Chief Judge of United States Tax Court. From 2014 through 2017 he served as the Academic Associate Dean and Professor at the University of Wyoming College of Law. He is an Academic Fellow of the American College of Tax Counsel and of the American College of Trusts and Estates Counsel. Professor Delaney currently authors Federal Income Tax Questions & Answers (2d Ed. Carolina Academic Press 2019), serves as update author for Planning for Large Estates (LexisNexis), and co-author with Prof. Elaine Gagliardi, Estate & Gift Tax Questions and Answers (3d Ed., Carolina Academic Press (2020)). Prior to accepting his position as a professor at the University of Wyoming College of Law, he practiced tax law at Perkins Coie in Seattle, Washington, served as tax counsel to General Electric Capital Assurance Corporation and served as a law clerk the Honorable Robert P. Ruwe, Judge, United States Tax Court. He earned his LL.M. in taxation from the University of Florida and his J.D. from Gonzaga University. As an undergraduate, he earned his B.A. in Economics from the University of Washington. Professor Delaney is a member of the Washington State Bar Association.

David J. Dietrich graduated from Whitman College with a B.A. degree with honors in 1979. He served in the Peace Corps in Abidjan, Ivory Coast. He attended the Alexander Blewett School of Law in 1984. David is a fourth-generation Montanan with a ranching, real estate and estate planning background. His firm, Dietrich & Associates, P.C., has provided real estate, tax, and estate planning services to high-net-worth clients. David is the Past Chair of the Real Property, Probate and Trusts Law Section (2016 to 2017) of the American Bar Association and a fellow of the American College of Trusts and Estates counsel. He is a past Co-Chair of the ABA’s Property Preservation Task Force. David is currently on the University of Montana Tax Institute Advisory Board and serves on the Board of Trustees of Rocky Mountain College in Billings and also served on the Board of Directors of the Montana Land Reliance. David’s publications include: a 2018 presentation at the ACTEC Regional Meeting on Quid Pro Quos in Conservation Easements; “Strategies and Considerations in the Use of Business Entities,” New York Law School/ABA-RPTE “Skills Training for Estate planners” (2012 to 2018), a 2011 ABA Book entitled Conservation Easements: Tax and Real Estate Planning for Landowners and Advisors; “Selected Post-Mortem Estate Tax Elections for the Small Business Owner” RPTE 2003, “Pleasing Mother Earth and the IRS: Using Conservation Easements to Save Open Space, Income and Estate Taxes” for the Heckerling Institute for Estate Planning for the University of Miami in January 2003. David and his family enjoy living in the Big Sky Country; he engages outdoor activities in any season.

Samuel A. Donaldson is a Professor of Law at Georgia State University in Atlanta, Georgia. Prior to joining the Georgia State faculty in 2012, he was on the faculty at the University of Washington School of Law for 13 years. At UW, Professor Donaldson served for two years as Associate Dean for Academic Administration and for six years as the Director of the law school’s Graduate Program in Taxation. He teaches a number of tax and estate planning courses, as well as courses in the areas of property, commercial law, and professional responsibility. Professor Donaldson is an Academic Fellow of the American College of Trust and Estate Counsel (ACTEC) and a member of the Bar in Washington, Oregon, and Arizona. Among his scholarly works, he is a co-author of the West casebook, Federal Income Tax: A Contemporary Approach, and a co-author of the Price on Contemporary Estate Planning treatise published by Wolters Kluwer. Professor Donaldson has served as a visiting professor of law both at Northwestern University and at the University of Florida Levin College of Law. An amateur crossword constructor, his puzzles have been published in The New York Times, The Wall Street Journal, The Washington Post, and other outlets.

Dana G. Fitzsimons, Jr. is Principal and Fiduciary Counsel at Bessemer Trust. In this role, he is responsible for working with clients and their advisors to develop practical and efficient wealth transfer plans and for guiding the firm on fiduciary issues. Prior to joining Bessemer, Dana was a partner with McGuireWoods LLP, where he practiced in the areas of fiduciary litigation and estate planning. He is a fellow of the American College of Trust & Estate Counsel (ACTEC) and serves on its Long Range Planning, Business Planning, and Charitable Planning and Exempt Organizations Committees. Dana has been recognized in Chambers USA: America’s Leading Lawyers for Business, serves in the ABA RPTE leadership, and frequently lectures on fiduciary topics. Dana earned a J.D. from William & Mary Law School, where he was a member of the law review and graduated Order of the Coif, and a B.A. in music from Ithaca College School of Music. He continues to perform actively as a jazz drummer.

Charles D. “Skip” Fox practices in the McGuireWoods office in Charlottesville, Virginia and is former chair of its Tax & Employee Benefits Department and of the Private Wealth Services Group. He served as president of The American College of Trust and Estate Counsel from 2018 to 2019 and is an adjunct professor at the University of Virginia School of Law. As general counsel for the advocacy organization Policy and Taxation Group, he helped lead research for a study that was instrumental in persuading Congress to enact estate tax reforms in 2001. Skip serves on the faculty of the National Trust School and the National Graduate Trust School. He served on the editorial board of Trusts & Estates magazine and chaired the board of Trust & Investments. He has written or co-written seven books and numerous articles for many different publications. He has co-presented the American Bankers Association’s monthly teleconferences on trusts and estates topics since 2000 and co-wrote a monthly column on tax subjects for the ABA Trust Newsletter for 18 years. Skip is an emeritus member of the CCH Estate Planning Advisory Committee. Skip served as an adjunct professor at Northwestern University Law School from 1983-2005. He serves or has served on the boards of several charities, including the University of Virginia Law School Foundation and the Episcopal High School in Virginia, from which he received the Distinguished Service Award in 2001. He also is chair emeritus of the Duke University Estate Planning Council and serves on the Advisory Committee of the Heckerling Estate Planning Institute.

Elaine Gagliardi is a Professor of Law at the Alexander Blewett III School of Law at the University of Montana and teaches in the areas of business and estate planning. She currently co-directs the law school’s Montana Tax Institute, and served as director from 2012 through 2018. Gagliardi is an Academic Fellow of the American College of Trust and Estate Counsel and of the American College of Tax Counsel. She served as a past Chair of the State Bar of Montana’s Business, Estates, Trust, Tax and Real Estate Section. She co-authors, with J. Martin Burke and Michael K. Friel, Modern Estate Planning (2d ed.) (LexisNexis); currently authors How to Save Time and Taxes Handling Estates (Matthew Bender), and co-authors with James Delaney, Estate and Gift Tax Questions and Answers (2d Ed.) (Carolina Academic Press 2020). Prior to teaching, Gagliardi practiced with Perkins Coie LLP in Seattle, and Day, Berry & Howard LLP in Hartford, Connecticut, and clerked for Hon. James R. Browning, Ninth Circuit Court of Appeals, and Hon. William J. Jameson, U.S. District Court, District of Montana. She earned her B.A. from Yale University, her J.D. from University of Montana, and her LL.M. in Taxation from New York University.

Steve Gorin, a partner at Thompson Coburn LLP in St. Louis, Missouri, is a nationally recognized practitioner in the areas of estate planning and the structuring of privately held businesses. A Regent of the American College of Trust and Estate Counsel (ACTEC) and active member of the ABA Real Property Trust and Estate Law Section, he has served as chair of the Real Property Probate and Trust Section’s Business Planning Group and of ACTEC’s sub-committee on Pass-Through Entities. He shares his deep knowledge and expertise through quarterly publications of Gorin’s Business Succession Solutions newsletter, and has written several articles for nationally recognized professional journals. He speaks regularly at national conferences, including meetings of the New York State Society of CPAs’ Estate Planning Conference, ACTEC, and the ABA Real Property Trust and Estate Law Section Advanced Skills Training. He is also a licensed CPA and credentialed as a Chartered Global Management Accountant. Steve is named to the Bloomberg BNA Estates, Gifts and Trusts Advisory Board and listed in the Best Lawyers in America. In 2018, Steve was honored as Lawyer of the Year in St. Louis for Business Organizations (including LLCs and Partnerships).

Lester B. Law is a member of Franklin Karibjanian & Law PLLC and divides time between the Naples and Washington offices. Lester is a Fellow of the American College of Trusts and Estates Counsel (ACTEC), and serves on the Fiduciary Income Tax and Transfer Tax Study committees. He is also an active member of the American Bar Association’s Real Property Trusts and Estate (ABA RPTE) Section, serving as co-chair of the ABA RPTE’s Income and Transfer Tax Planning Group. An active member of and board certified in Wills Trusts and Estates law by the Florida Bar, Lester has held many leadership roles at the Florida Bar’s Real Property Probate and Trust Law Section, including chairing committees, being an editor of the Tax Notes for the Florida Bar Journal and currently co-chairing a subcommittee exploring the utility of Community Property Trusts in Florida. Lester is a nationally recognized speaker and author. Recent presentations and venues include, University of Miami Heckerling Institute on Estate Planning, the Notre Dame Tax & Estate Planning Institute, ABA-RPTE meetings, Washington School of Law – Annual Estate Planning Council, and Portland Estate Planning Council. He was an adjunct professor at the Ave Maria School of Law and will also serve as an adjunct professor at the University of Miami School of Law, Graduate Estate Planning Program. Lester’s writings have been published in many national journals and publications, including Trusts & Estates, The Florida Bar Journal, Probate and Property, Bloomberg/BNA Estates, Gifts & Trusts Journal, Estate Planning, and Steve Leimberg’s – LISI’s Newsletters. Lester is also a co-author of a book on estate planning titled Tools and Techniques of Trust Planning. Prior to joining Franklin Karibjanian & Law, Lester was a managing director at US Trust and Abbot Downing focusing on planning for the ultra-high net worth clients for a dozen years. Prior to law school, Lester was a CPA in Florida with PriceWaterhouseCoopers.

Bruce A. McGovern is a Professor of Law at South Texas College of Law Houston, where he teaches in the areas of taxation and business organizations. For many years he also served as its Vice President and Associate Dean of Academic Administration. He currently serves as Director of the school’s Low Income Taxpayer Clinic. He has held visiting appointments at the University of Florida Levin College of Law and Loyola University Chicago School of Law. Bruce is a fellow of the American College of Tax Counsel. He speaks nationally and has presented at more than 25 different tax conferences. He co-authors Agency, Partnerships and Limited Liability Companies (Carolina Academic Press) and has authored numerous chapters in Consolidated Groups, CCH Tax Research Consultant (online treatise) (Chicago, Illinois, Commerce Clearing House Tax Research Network 2006). Prior to teaching, Bruce served as a judicial clerk for the Honorable Thomas Meskill, U.S. Court of Appeals, Second Circuit, and practiced law with Covington and Burling in Washington, D.C. Bruce received his LL.M. in Taxation from the University of Florida Levin College of Law, his J.D. from Fordham University School of Law, and his B.A. from Columbia University.

Julie R. Sirrs is a shareholder with the Missoula firm of Boone Karlberg and practices in the areas of elder law, estate planning and tax litigation.  She is a fellow of the American College of Trust and Estate Counsel and a member of the National Academy of Elder Law Attorneys.  An active member of the State Bar of Montana’s Business, Estates, Trust, Tax and Real Estate Section, she currently serves as its treasurer.  She is a co-founder and board member of Montanans for National Security and a board member of the Rocky Mountain Ballet Theater School.  Her recent publications include The Tax Cuts and Jobs Act and Charitable Giving: Impact and Planning Strategies, ABA Probate and Property Nov/Dec 2019.  She has taught Elder Law, Taxation of Business Entities and Federal Income Tax as adjunct faculty at the University of Montana Blewett School of Law.  Julie graduated with high honors from law school at the University of Montana and received a Master of Laws in Taxation from the University of Washington. Prior to becoming an attorney Julie was an intelligence officer with the Defense Intelligence Agency.

Ramsay H. Slugg is a Managing Director and member of the National Wealth Planning Strategies Group at Bank of America. Previously, he was the National Practice Director of Bank of America’s Philanthropic Management group. He has also served as an adjunct professor at Texas Christian University and Texas A&M College of Law. Ramsay speaks frequently on tax and financial planning topics, especially as they relate to art and collectibles, and has been quoted in the Wall Street Journal, New York Times, Forbes, Barron’s and other business publications. He authored the Handbook of Practical Planning for Artists, Art Collectors and Their Advisors, 2d Edition, published by the American Bar Association’s Section of Real Property, Trust and Estate Law. Mr. Slugg is admitted to practice law in Texas and has chaired the Tax and Estate Planning Section of the Tarrant County Bar. He currently serves as Co-chair of the American Bar Association’s Real Property Trust and Estate Law Art and Collectibles Committee, as well as holding several other leadership positions. Ramsay received his J.D. from the Ohio State University College of Law, and his undergraduate degree from Wittenberg University.

James R. Walker is a partner with the Denver firm of Lewis Roca Rothgerber Christie and chairs its Tax Practice Group and its Trust and Estate Practice Group. He is a fellow of both the American College of Trust and Estate Counsel and the American College of Tax Counsel. James has been listed in the Best Lawyers of America for more than a decade. He currently chairs the Colorado Bar Association’s Taxation Committee and in 2012 served as president of the Colorado Chapter of the American Association of Attorney Certified Public Accountants. He is an adjunct faculty member of the Graduate Tax Program at University of Denver Sturm College of Law. James received his LL.M. in Taxation from New York University School of Law and J.D. from University of Denver Sturm College of Law. 

Cynthia R. Woods, attorney-at-law, owns a solo law practice in Billings, Montana. She advises clients in estate planning, estate and trust administration, guardianship/conservatorship proceedings, and business succession planning. She received her undergraduate degree (magna cum laude) in finance from the University of Denver, her law degree (with honors) from the University of Montana, and an advanced tax law degree from the University of Miami (LLM, Taxation).  Cynthia is a fellow of the American College of Trust and Estate Counsel.

CLE Credits

The 68th Montana Tax Institute brings to you “live” presentations as has been our tradition. Registrants earn “live” CLE credit by attending the program as scheduled. This year, the online format allows us to bring to you two additional “on-demand” presentations. Application has been made for a total of 15 CLE credits, 13 "live" credits and two "other" credits. The two on-demand presentations may be viewed at your convenience beginning Saturday, October 17, through the week following the conference to earn “other credit."

Thank You

Thank you to our sponsors for their support! It is only because of the generosity of our sponsors that we can bring to you a distinguished faculty of national tax practitioners and scholars.