Tax.

• Author: Minton, Michael D.
• Position: Annual Reports of Sections and Divisions of the Florida Bar: 2018-2019

This has been an eventful year for the Tax Section on the heels of major tax reform legislation. We celebrated the beginning of summer with our longstanding tradition of gathering at Amelia Island to organize our year and spend time with our families. Mark A. Prater, former chief tax counsel to the U.S. Senate Finance Committee, served as keynote speaker during the annual Ullman Year in Review CLE program, and we honored him as the 2018-2019 Marvin C. Gutter Outstanding Public Service Award recipient. His unique perspective and comprehensive knowledge on the passage of the 2017 Tax Cuts and Jobs Act (TCJA) was invaluable to us as we continue to feel the reverberations of this legislation and its proposed regulations.

In keeping with our goal this year to emphasize the section's involvement in federal tax policy and to have a seat at the proverbial table regarding the implementation of the TCJA, we traveled for the first time in over a decade to Washington, D.C., for our fall meeting. We met with various key federal officials and agencies (such as the senior tax staff of the House Ways and Means Committee and Senate Finance Committee, IRS, and Department of Treasury) involved with the drafting and interpretation of the TCJA pursuant to the regulations to be promulgated thereunder. Following these in-person meetings, our International Tax Committee of the Federal Tax Division submitted regulatory comments under the guidance of Steven Hadjilogiou, Shawn Wolf, Michael Bruno, Keith Hagan, and James Barrett. Their comments were adopted on March 4 by the Treasury Department and the IRS in the form of proposed regulations to [section]250 regarding Global Intangible Low-Taxed Income (GILTI) deduction eligibility. This was a significant achievement for the Tax Section and a testament to the engagement of the Tax Section's international tax attorneys and the value of establishing and maintaining contacts at the federal level as a means of having a positive impact on tax policy and administration. Active involvement in the Tax Section provides one a platform to have that "seat at the table" to effectuate such change!

The wealth of substantive information we gleaned from our D.C. meetings fueled a subsequent five-part audio webcast CLE series for those who were unable to attend in person. Members of our Federal Tax Division have also authored comments on the proposed regulations for the [section]199A deduction, Opportunity Zones under [section]1400Z...