Saturday, January 20

8:30AM - 11:30AM

Fiduciary Income Tax

Chair:  David Pratt, Proskauer Rose LLP, Boca Raton, FL

8:30am                  Opening Remarks.  Report on committee chairs and
     vice-chairs breakfast topics and other committee
     business.  Speaker:  A. Christopher Sega, Venable
     LLP, Washington, DC.

8:40am                  Recent Developments.  Report on recent developments
     affecting the income taxation of trusts and estates. 
     Speaker:  Jeanne L. Newlon, Venable LLP,
     Washington, DC.

8:55am                  Trust Performance under Different Payout Scenarios -
     1986-2005.  This is an analysis of what would have
     happened to the income beneficiary and
     remainderman of a trust created in 1986 and
     terminating in 2005 had the trustee had the options
     that now exist under the Principal and Income Act
     and chosen, respectively, a 3% payout, a 4% payout,
     and payout of the trust''s yield.  Its purpose is to test
     the theory of the Principal and Income (and Prudent
     Investor) Acts against the backdrop of real market
     outcomes.  Speaker:  Jordan Sprechman, JP Morgan,
     New York, NY.

9:45am                  Funding Trusts in the Crossfire of Conflicting Estate
     Tax, Income Tax and ERISA Laws: What''s the Use
     of Happiness If It Can''t Buy You Money?   Funding
     trusts with retirement assets requires an estate
     planner to integrate three distinct sets of laws: income
     tax laws, estate tax laws and ERISA mandatory
     distribution laws. This program will examine how
     these laws interact to create special problems, 
     especially for bypass and QTIP trusts and will explore
     solutions. The program will examine basic planning
     strategies, especially in light of pending estate tax
     changes, as well as the most recent IRS rulings on the
     subject.  Speaker:  Professor Christopher R. Hoyt,
     University of Missouri (Kansas City) School of Law,
     Kansas City, MO.

10:35am                Insurance and the Transfer for Value Rule.  This
     presentation will examine the transfer for value 
     exception to the general rule of section 101 of the
     Code that life insurance death proceeds are received
     income-tax free.  In addition to discussing the transfer
     for value rule itself, the presentation will analyze its
     application to a series of common transactions,
     including buy-sell planning, retirement planning,
     general business planning, and personal planning. 
     Speaker:  Lawrence Brody, Bryan Cave LLP, St.
     Louis, MO.