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2017 Midyear Meeting

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(c) [2017] American Bar Association.
All rights reserved. No part of this recorded content may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopy, recording, or otherwise, without the prior written permission of the American Bar Association.
$299.00



Showing sessions 1 - 10 of (45) TOTAL sessions
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Event : ABATX35


Session : ABATX1701
Transfer Pricing
Conference : 2017 Midyear Meeting
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$15.00


  • Chair: A. Tracy Gomes, McDermott Will & Emery, Dallas, TX
  • Transfer Pricing Litigation Through the Lens of Medtronic. This is a joint panel co-sponsored by the Transfer Pricing and Court Procedures Committees of the ABA Section on Taxation. The program will examine transfer pricing controversy in a fresh and dynamic format. Experienced transfer pricing practitioners and litigators will stage a mock appellate argument in the Medtronic case based on the Tax Court’s 2016 opinion. Drawing upon the issues raised in the arguments, a subsequent panel and audience discussion will explore whether and to what extent Medtronic reflects broader themes and issues in current transfer pricing litigation, and what it means for future cases.


Session : ABATX1702
Tax Bridge on the Road
Conference : 2017 Midyear Meeting
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$45.00


  • Sponsored by: Young Lawyers Forum and Diversity Program Co-Chairs: Kelley C. Miller, Reed Smith LLP, Washington, DC; Cathy Fung, Office of Chief Counsel (Large Business & International), IRS, Washington, DC
  • A Conversation with Kathy Keneally. (NO CLE) Kathy Keneally, former Assistant Attorney General for the Tax Division of the US Department of Justice, sits down for an in-depth discussion of her practice, her history, and the latest developments in tax law.
  • Tax Basics Through Crowd Funding Transactions. Kickstarter.com and Indiegogo.com are popular websites that let entrepreneurs and start-ups raise capital through online, capital-raising campaigns. The advent of these new fundraising platforms raises issues on how funds raised should be treated for income tax purposes. The panelists will discuss the tax concepts that apply to these transactions and provide insight on how crowd funding transactions should be treated for income tax purposes. Panelists: Jairo G. Cano, Agostino & Associates, Hackensack, NJ; Renay C. France, Attorney, Office of Associate Chief Counsel (Income Tax & Accounting), IRS, Washington, DC (Invited); Professor Charlene Luke, University of Florida Levin College of Law, Gainesville, FL
  • Tax Court 101: Expert Witnesses – Discussion and Demonstration. Experienced tax controversy attorneys will discuss and demonstrate key concepts relating to expert witnesses in the forum where tax issues are most likely to be litigated, the United States Tax Court. In this regard, the panelists will discuss key provisions of the Tax Court’s Rules of Practice and Procedure that relate to expert witnesses and detail the issues with which any tax litigator should be aware. Specifically, the panelists will discuss issues and share insights relating to expert qualification, direct examination, cross examination, rehabilitation, and cutting-edge expert witness techniques. After the panel discussion, there will be a live demonstration of how, in practice, many of the concepts operate. If you ever anticipate representing a taxpayer in Tax Court litigation, you will not want to miss this unique presentation! Moderator: Kelley C. Miller, Reed Smith LLP, Washington, DC Panelists: The Honorable Maurice B. Foley, US Tax Court, Washington, DC (Invited); Giovanni Alberotanza, Rosenberg Martin Greenberg LLP, Baltimore, MD; Jeffrey M. Glassman, McDermott Will & Emery LLP, Dallas, TX; Lawrence A. Sannicandro, Agostino & Associates PC, Hackensack, NJ; Adriana Lofaro Wirtz, Cooley LLP, New York, NY Co-Sponsored by: Court Procedure & Practice
  • Subpart F Income Tax: Its Scope and Application to US Shareholders. This panel will provide an overview of the anti-deferral rules taxing certain types of foreign income under Subpart F of the Internal Revenue Code. The panelists will examine what constitutes a controlled foreign corporation (CFC) for purposes of the application of subpart F to US shareholders. The discussion will include a review of the complex attribution rules applying to individuals and entities. The panelists will focus on the types of income captured by Subpart F, as well as highlight some of the exceptions to the subpart F regime, such as the same country and high tax exceptions. The panelists also will review the information reporting obligations imposed on US shareholders of CFCs. Panelists: Dianne C. Mehany, Caplin & Drysdale, Washington, DC; Danielle Rolfes, International Tax Counsel, Department of Treasury, Washington, DC (Invited) Co-Sponsored by: Foreign Activities of US Taxpayers
  • The Nuts and Bolts of Section 385 – Making Sense of the Debt-Equity Regulations. Prior to April 2016, section 385 could have been described as an unnecessary or ineffective codification of case law. The controversial and revolutionary Proposed Regulations under section 385 came on the scene producing highly unexpected and far reaching results that extend far beyond the bounds of subchapter C. This panel will discuss the Final Regulations under section 385 and the criticisms and praise in the overall scheme of the regulations as well as the revisions made from the Proposed Regulations to Final Regulations. Moderator: Alfred Bae, EY, Houston, TX Panelists: Ian Bristol, KPMG, San Francisco, CA; Lee A. Sheppard, Tax Analysts, Falls Church, VA; Gary Scanlon, Attorney-Advisor, Department of Treasury, Washington, DC (Invited)


Session : ABATX1703
Capital Recovery & Leasing
Conference : 2017 Midyear Meeting
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$30.00


  • Chair: Christian Wood, RSM US LLP, Washington, DC
  • Current Developments. This panel will review recent developments in the area of capital recovery and leasing since the Section of Taxation meeting held in Boston, MA, in September. The panel will also discuss ongoing projects and anticipated guidance, with commentary and input from our guests from the IRS and Department of Treasury.
  • Capitalized Costs in Failed Acquisitive Transactions. This panel will discuss recent guidance and various scenarios to recovery (when possible) fees incurred during a failed acquisitive transaction.
  • Qualified Improvement Property. This panel will discuss definitions, differences under prior law, and situations where bonus depreciation may or may not be available.


Session : ABATX1704
Foreign Activities of US Taxpayers
Conference : 2017 Midyear Meeting
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$30.00


  • Chair: Paul J. Crispino, United Technologies Corporation, Farmington, CT
  • The Foreign Tax Credit. Numerous provisions limit the ability to access foreign tax credits, such as sections 901(m) and 909, enacted in 2010. Recent guidance, including Notice 2016-52 and expected regulations under section 901(m), provide additional guidance in respect of these provisions. This panel will discuss recent developments impacting the foreign tax credit. Moderator: Margaret O’Connor, EY, Washington, DC Panelists: Elizabeth J. Stevens, Caplin & Drysdale, Washington, DC; Laurie Marsh, KPMG, New York, NY; Brenda Zent, Special Advisor on International Taxation, Office of International Tax Counsel, Department of Treasury, Washington, DC; Jason Yen, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC
  • Outbound Stock and Asset Transfers. Section 367 restricts the tax-free transfer of property outside the United States. This panel will discuss recent developments impacting the outbound transfer of stock and assets, including section 367(d) and related provisions. Moderator: Joseph Calianno, BDO, Washington, DC Panelists: Andrew M. Eisenberg, Jones Day, Washington, DC; Anne R. Gordon, PwC, Washington, DC; Jason Smyczek, Senior Technician Reviewer, Branch 4, IRS Office of Chief Counsel, Washington, DC; Brenda Zent, Special Advisor on International Taxation, Office of International Tax Counsel, Department of Treasury, Washington, DC; Brian Jenn, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC


Session : ABATX1705
Administrative Practice
Conference : 2017 Midyear Meeting
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  • Chair: George A. Hani, Miller & Chevalier Chartered, Washington, DC
  • Important Developments. This panel will discuss current developments and topics of immediate interest in tax administrative practice. Panel will focus on recent Treasury and IRS guidance, court decisions, on-going litigation, or any other items germane to tax administration. Moderator: Kat Saunders Gregor, Ropes & Gray, Boston, MA Panelists: Brendan O’Dell, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Drita Tonuzi, Associate Chief Counsel (Procedure & Administration), IRS Office of Chief Counsel, Washington, DC
  • Implementation of the New BBA Partnership Audit Rules. January 1, 2018 will trigger the start of a new audit regime for partnerships. The IRS and Treasury have been working diligently to flesh out through regulations how these new rules will operate. This panel will discuss the development of these rules and what open questions remain. Moderator: Michael J. Desmond, The Law Offices of Michael J. Desmond, Santa Barbara, CA Panelists: Rochelle Hodes, Office of Tax Policy, Department of Treasury, Washington, DC; Drita Tonuzi, Office of Chief Counsel (Procedure & Administration), Internal Revenue Service, Washington, DC; Diana Wollman, Cleary Gottlieb, New York, NY
  • Recent Changes to IRS Appeals Procedures. The IRS Office of Appeals has announced several changes in the past year regarding how cases will be processed. These include the shift related to the availability of face-to-face conference, the settlement authority of Appeals Team Case Leaders, and conference attendees. This panel will analyze these changes from both the IRS and taxpayer perspective and discuss the potential implications for case resolution at Appeals. Moderator: Shelly Kay, Crowe Horwath, Atlanta, GA Panelists: Susan Seabrook, Buchanan Ingersoll & Rooney, Washington, DC; Jennifer Vozne, IRS Appeals, Tampa, FL


Session : ABATX1706
S Corporations
Conference : 2017 Midyear Meeting
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$30.00


  • Chair: Dana Lasley, Emerson Electric Co., St. Louis, MO
  • S Corporations: Tips and Traps for the Unwary. (Young Lawyers) An introduction to the rules of establishing and maintaining S corporation status and some ways these rules can be unintentionally violated. Moderator: E. John Wagner II, Williams Parker Harrison, Sarasota, FL Panelists: Mary Beth Dolan, Bryan Cave, St. Louis, MO; Edward A. Waters, Dean Mead Egerton Bloodworth Capouano & Bozarth, Orlando, FL
  • Equity Compensation. A discussion of strategies for using equity-based compensation (e.g. Options, Stock Appreciation Rights plans and Phantom Stock plans) and the effect of the Single Class of Stock Regulations on incentive compensation plans. Panelists: Hallie Goodman, Gray Plant Mooty, Minneapolis, MN; Steve Looney, Dean Mead Egerton Bloodworth Capouano & Bozarth, Orlando, FL
  • Current Developments in the Federal Income Taxation of S Corporations. In this session, the panelists will discuss recent judicial, regulatory, and administrative guidance on the US federal income taxation of subchapter S corporations. Moderator: Bryan Keith, Grant Thornton LLP, Washington, DC Panelists: Laura E. Krebs Al-Shathir, Capes Sokol Goodman & Sarachan PC, St. Louis, MO; Gregory L. Lohmeyer, Quarles & Brady, Milwaukee, WI


Session : ABATX1707
Affiliated & Related Corporations
Conference : 2017 Midyear Meeting
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$30.00


  • Chair: Jay Singer, McDermott Will & Emery LLP, Washington, DC
  • Application of the Final Section 385 Regulations to Consolidated Groups. This panel will explore the application of the final section 385 regulations in the context of affiliated groups, including potential deconsolidations, the treatment of partnerships owned by members of a consolidated group, state tax issues, and consequences resulting from a debt instrument, debtor or creditor entering or leaving a consolidated group. Moderator: Bryan Collins, Deloitte Tax LLP, Washington, DC Panelists: Julie Wang, IRS Office of Associate Chief Counsel (Corporate), Washington, DC; Valerie Dickerson, Deloitte Tax, LLP, Washington, DC; Gregory Kidder, Steptoe & Johnson LLP, Washington, DC; Graham Magill, KPMG LLP, Washington, DC; Michael Wilder, McDermott Will & Emery LLP, Washington, DC
  • The Role of the Courts in Interpreting Consolidated Return Regulations. The panel will examine how courts determine whether a consolidated return regulation is valid, and what factors a court may consider in this determination. The panel will discuss how a regulation may satisfy the Administrative Procedure Act and other procedural requirements. It will also consider how the standards set out in Chevron and Mayo should be applied to determine whether Treasury exceeds its authority in issuing a consolidated return regulation. Moderator: Professor Don Leatherman, University of Tennessee, Knoxville, TN Panelists: Jasper Cummings, Alston & Bird LLP, Charlotte, NC; Professor Michelle Kwon, University of Tennessee, Knoxville, TN; Gary Wilcox, PwC, Washington, DC


Session : ABATX1708
Real Estate
Conference : 2017 Midyear Meeting
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$30.00


  • Chair: Julie Sassenrath Harvey, Winstead PC, Dallas, TX
  • Hot Topics. This panel will discuss recent developments, including legislation, regulations, administrative guidance, and noteworthy cases. Moderator: Amanda F. Wilson, Lowndes Drosdick Doster Kantor & Reed PA, Orlando, FL Panelists: Ossie Borosh, Senior Counsel, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Clifford M. Warren, Special Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), IRS, Washington, DC
  • Non-Safe Harbor Reverse Exchanges after Bartell. In Estate of Bartell, the Tax Court approved a non-safe harbor reverse like-kind exchange spanning 17 months. The panel will discuss practical applications of this case, including how to structure transactions to come within its holding. This topic will be addressed again by the Sales, Exchanges and Basis committee on Saturday. Moderator: Todd L. Keator, Thompson & Knight LLP, Dallas, TX Panelists: Adam M. Handler, PwC, Los Angeles, CA; Mary Cunningham, Chicago Deferred Exhange Company, Chicago, IL
  • Real Property for REIT Purposes. This panel will discuss the final regulations on the definition of real property for REIT purposes, including implications for IRS rulings, tax opinion practice, and the effect on other areas of the Code. Moderator: Diane Umberger, EY, Washington, DC Panelists: Ameek A. Ponda, Sullivan & Worchester LLP, Boston, MA; Andrea M. Hoffenson, Branch Chief, Branch 2, Financial Institutions and Products, IRS, Washington, DC; Julanne Allen, Assistant to the Branch Chief, Branch 3, Financial Institutions and Products, IRS, Washington, DC
  • New Partnership Regulations under Sections 707 and 752 (Part 1). New regulations substantially change the computations for disguised sales of property to partnerships and the allocation of partnership liabilities. This panel will discuss the technical rules and how they apply to real estate transactions. This panel will continue at the Partnerships & LLC committee meeting. Moderator: Eric Sloan, Gibson Dunn & Crutcher LLP, New York, NY Panelists: Trevor Allen, Skadden Arps Slate Meagher & Flom LLP, New York, NY; Ossie Borosh, Senior Counsel, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Clifford M. Warren, Special Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), IRS, Washington, DC


Session : ABATX1709
Closely Held Businesses
Conference : 2017 Midyear Meeting
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  • Chair: Shelby L. Wilson, Berchem Moses & Devlin PC, Westport, CT
  • Selling and Buying the Dreaded Tax Embroiled Business. This panel will discuss what buyers and sellers need to be aware of when purchasing a business that is not in compliance with its taxes. It will discuss who must be notified, what actions can be taken to remove tax liens, what tax liens attach too and other necessary information and cautions for buyers and sellers. Panelists: Robb. A. Longman, Longman & VanGrack LLC, Bethesda, MD; Joseph B. Schimmel, Cohen Chase Hoffman Schimmel, Miami, FL; Frederick W. Schindler, IRS Office of Chief Counsel, Washington, DC
  • Choice of Entity


Session : ABATX1710
Individual & Family Taxation
Conference : 2017 Midyear Meeting
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  • Chair: Phyllis Horn Epstein, Epstein Shapiro & Epstein PC, Philadelphia, PA
  • Deductible Medical Expenses Under Section 213 Take on New Meaning. The Code provides for the deduction of medical expenses that meet the definition under IRC 213. What is or is not a medical expense isn’t always obvious or apparent and taxpayers have proposed interesting and unique challenges to defining a deductible medical expense. Alternative non-medical treatments, home repairs, sex reassignment therapy, and surrogacy payments are just a few of these. Our panel explores the most recent legal challenges to the definition of medical expense, the ongoing Priority Guidance Plan project to update the Regulations under section 213 and the cross impact of religion and surrogacy on the subject of medical expense deductions. Moderator: Patrick Thomas, Director, Tax Clinic, University of Notre Dame School of Law, South Bend, IN Panelist: John Moriarty, Deputy Associate Chief Counsel, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Thomas Moffitt, Chief, Branch 2, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Professor Anthony Infanti, University of Pittsburgh, Pittsburgh, PA Co-Sponsored by: Pro Bono & Tax Clinics
  • Can You Get Your Business Client Relief Under Section 530 of the Revenue Act of 1978? Section 530 provides employers safe harbor provision relieving it from prior years' employment taxes and penalties for the misclassification of hired workers as independent contractors if it consistently treated such workers as independent contractors, issued Forms 1099-MISC when required, and had a reasonable basis for classifying the workers as independent contractors, even if such reasonable classification is judicially determined to be incorrect. Discussion will focus on the taxpayer’s burden of proof in meeting the requirements for relief under section 530, choice of forum considerations and case law under section 530. Moderator: Lany Villalobos, Law Clerk, US Tax Court, Washington, DC Panelists: Jerald David August, Kostelanetz & Fink, New York, NY; Phyllis Horn Epstein, Epstein Shapiro & Epstein, Philadelphia, PA; Megan Marlin, PwC, Washington, DC; Additional Speaker TBD Co-Sponsored by: Employment Taxes
  • Form 1099 Issues. Our panel will focus on Form 1099 reporting (including some new and/or obscure Forms 1099), account transcripts, and the IRS matching program of “matching up” Forms 1099, Forms W-2, Forms K-1 to file tax returns, and other related matters. Moderator: Jonathan E. Strouse, Harrison and Held LLP, Chicago, IL Panelists: Michael J. Desmond, Law Offices of Michael J. Desmond APC, Santa Barbara, CA; Gary Yingst, Group Manager, IRS, Maitland, FL Co-Sponsored by: Pro Bono & Tax Clinics



     


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(c) [2016] Digital Conference Providers, Inc. All rights reserved. No part of this recorded content may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopy, recording, or otherwise, without the prior written permission of Digital Conference Providers, Inc. All sales are final and are intended for individual use.