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2018 Midyear Meeting

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(c) [2018] 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.

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Showing sessions 1 - 10 of (43) TOTAL sessions
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Event : ABATX38


Session : ABATX1801
Tax Bridge on the Road
Conference : 2018 Midyear Meeting
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  • A Conversation with Kathy Keneally. In this installment of “A Conversation with...” we are honored to welcome Kathy Keneally, currently a Partner at Jones Day in New York, New York, and a former Assistant Attorney General of the US Department of Justice (DOJ) Tax Division. In addition to her more than 30 years of experience representing large corporations, financial institutions, closely held businesses, and high net worth individuals in civil and criminal tax controversy matters and in non-tax criminal defense, Ms. Keneally served as a vice chair of the American Bar Association Section of Taxation and chaired the Committees on the Standards of Tax Practice and Civil and Criminal Tax Penalties.
  • Choice of Forum in Tax Litigation. This panel will address an age-old (but always current and important) topic in tax litigation: choice of forum. It will discuss the practical nuances between Federal District Courts, the Court of Federal Claims, and the US Tax Court. It will also use recent cases to highlight topics like the US Tax Court’s Golsen rule in the context of circuit splits or potential circuit splits, the increasing use of the Administrative Procedure Act in certain tax challenges, and the US Tax Court’s expanding jurisdiction over various tax issues (whistleblower actions, passport-related actions, etc.). Panelists: Michael D. Kummer, Morgan Lewis & Bockius LLP, Washington, DC; Kelley C. Miller, Reed Smith LLP, Washington, DC; Evan J. Davis, Hochman Salkin Rettig Toscher & Perez, Beverly Hills, CA
  • Nuts and Bolts of Master Limited Partnerships (MLPs) and the Up-C Structure. This panel will provide an introduction to two innovative partnership structures: the master limited partnership and the Up-C. The discussion will not only focus on the basic tax aspects of each structure, but also on the industrial application of each and the associated business and legal considerations. Panelists: Brooke Childers, KPMG, Houston, TX; Bruce DeMyer, KPMG, Houston, TX; Hasnain Valika, EY, Houston, TX; Adrienne Mikolashek, Attorney, Office of Associate Chief Counsel (Passthroughs and Special Industries), Washington, DC; Hasnain Valika, EY, Houston, TX; Adrienne Mikolashek, Attorney, Office of Associate Chief Counsel (Passthroughs and Special Industries), Washington, DC
  • Breaking State Tax News: United States Supreme Court to Hear South Dakota v. Wayfair... Is it the End of the (Nexus) World as We Know It? The United States Supreme Court recently granted cert in South Dakota v. Wayfair, et al., the lead case challenging the Court’s “physical presence” nexus rule announced in National Bellas Hess v. Illinois and reaffirmed in Quill Corp. v. North Dakota. While the question immediately before the Court is whether the motion for summary judgment was properly granted and affirmed by South Dakota state courts, what remains unknown is whether the Court will take this case as an opportunity to revisit Quill’s physical presence rule. This panel will offer a primer the issues before the Court in Wayfair as well as what implications a decision may have for states and taxpayers. Panelists: Trever Asam, Cades Schutte LLP, Honolulu, HI; Bruce Johnson, Taxometry, Salt Lake City, UT; Brian Marcus, Illinois Department of Revenue, Chicago, IL; Kelley Miller, Reed Smith LLP, Washington, DC; Lucy Wang, California Department of Justice, San Francisco, CA
  • International Tax Reform. The landscape of international tax under US law has changed drastically with meaningful consequences to taxpayers. Newly passed changes in US tax law champion unique and robust provisions to tackle effectively base erosion and tax abuse. Additionally, taxpayers will face new limitations on deductions of business interest expense, with domestic corporate members of worldwide groups facing additional limitations on deductible interest expense generally. The new law changes the landscape of international tax under domestic law, and some of these provisions potentially cause treaty override issues that run the risk of unilaterally altering current bilateral tax treaty obligations and negatively effecting relationships with treaty partners. This panel will provide an overview of the international aspects of newly passed tax reform provisions and discuss some of the unique issues the changed laws bring to international tax practice. Panelists: Kat Gregor, Ropes & Gray, Boston, MA; Dianne C. Mehany, Caplin & Drysdale, Washington, DC; Amit M. Sachdeva, EY, Houston, TX


Session : ABATX1802
Capital Recovery & Leasing
Conference : 2018 Midyear Meeting
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  • Current Developments Report and Update on Pending Guidance. This panel will cover the important recent developments in the areas of capital recovery and leasing. Moderator: Tracy Watkins, Grant Thornton, Washington, DC Panelists: Scott Dinwiddie, Associate Chief Counsel, IRS – Income Tax & Accounting, Washington, DC; John Moriarty, Deputy Associate Chief Counsel, IRS – Income Tax & Accounting, Washington, DC; Kathleen Reed, Branch Chief, IRS – Income Tax & Accounting, Branch 7 Washington, DC; Christopher Call, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC
  • Tax Reform and Its Implications. This panel will discuss the various tax issues related to tax reform and how it will impact taxpayer requirements for capital recovery. Moderator: Grant Anderson, Deloitte, Washington, DC (Invited) Panelists: Scott MacKay, EY, Washington, DC; Tracy Watkins, Grant Thornton, Washington DC; Scott Dinwiddie, Associate Chief Counsel, IRS – Income Tax & Accounting, Washington, DC; John Moriarty, Deputy Associate Chief Counsel, IRS – Income Tax & Accounting, Washington, DC; Kathleen Reed, Branch Chief, IRS – Income Tax & Accounting, Branch 7 Washington, DC; Christopher Call, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC
  • ASC 730 – R&D LB&I Directive. This panel will discuss the recent LB&I Directive regarding qualified research expenditures and ASC 730 – Research and Development. We will discuss the background of the directive and highlight the similarities and differences between IRC section 41 and AC 730, while also addressing the directive’s applicability to all LB&I taxpayers. Moderator: Ryan Corcoran, RSM, Madison, WI Panelists: Javier Heurtas, Grant Thornton, Seattle, WA; Christopher Call, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC


Session : ABATX1803
Transfer Pricing
Conference : 2018 Midyear Meeting
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  • Chair: John M. Breen, Skadden Arps Slate Meagher & Flom LLP, Washington, DC
  • Transfer Pricing in the Digital Age: Economic Considerations and Implications. This panel will discuss transfer pricing considerations that arise with respect to the rapidly growing digital economy. Specifically, the panelists will address challenges that practitioners face in connection with valuing infrastructure hardware given the rapid rate at which technology is replaced; the impact of "big data" and considerations regarding the underlying value of such data; the role of analytical software and artificial intelligence; key considerations regarding the US cost-sharing regulations; and how tax authorities may approach controversy in this environment. The panel will also consider the potential impact of digitalization on transfer pricing compliance, including the emerging use by tax administrations of artificial intelligence as an audit screening tool. Moderator: Professor Lorraine Eden, Texas A&M University, College Station, TX Panelists: Joseph P. Dewald, Senior Technical Reviewer, Branch 6, IRS Office of Associate Chief Counsel (International), Washington, DC; Matt Jennings, EY, Dallas, TX; Bernhard van Thaden, KPMG LLP, Los Angeles, CA; Niraja Srinivasan, Dell, Austin, TX; Eileen Wang, Expedia, Seattle, WA
  • The Future State of Transfer Pricing Compliance and Controversy: The Interaction Between US Tax Reform and the Adoption of BEPS-related Measures in Other Jurisdictions. In 2018, OECD member countries and a host of non-OECD member countries will begin exchanging country-by-country (CBC) reports, and in many cases they will implement revised transfer pricing documentation requirements, requiring Master File reporting. In addition, countries will start implementing DEMPE requirements to analyze profits attributable to IP holding companies. Moreover, current tax proposals, if enacted, may impose current US tax on the accumulated E&P of many US-based multinationals and make additional changes that may foster additional tax controversies. This panel will explore whether the implementation of the BEPS transfer pricing related Action Items and re-structuring as a result of US tax changes will lead to more U.S. and non-US transfer pricing controversies for US based multinationals. The discussion will focus on US-based multinationals that have IP migration structures in place. Further, the panel will consider whether the expected increased risk of double taxation can be moderated by means of: US foreign tax credits; Increased use of multi-country mutual agreement procedures (MAP), including multi-country arbitration; Multi-country APAs and joint audits; Increased litigation within or outside the United States; Other remedies. Moderator: Michael Patton, DLA Piper LLP, Los Angeles, CA Panelists: Joseph P. Dewald, Senior Technical Reviewer, Branch 6, IRS Office of Associate Chief Counsel (International), Washington, DC; Jennifer L. Best, Senior Advisor, IRS, Deputy Commissioner, Large Business & International Division, Washington, DC; Brian Jenn, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC; Kathryn Keneally, Jones Day, New York, NY; Steven Wrappe, KPMG LLP, Washington, DC


Session : ABATX1805
Affiliated & Related Corporations
Conference : 2018 Midyear Meeting
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  • Chair: Donald Bakke, EY, Washington, DC
  • Current Developments. This panel will discuss current developments for consolidated groups, reviewing private letter rulings and other authorities, including IRS views on worthless securities deductions with respect to stock of members of a consolidated group. Moderator: Bryan Collins, Deloitte Tax, Washington, DC Panelists: Michelle Albert, EY, Los Angeles, CA; Russell G. Jones, IRS Office of Associate Chief Counsel (Corporate), Washington, DC; Michael J. Wilder, McDermott Will & Emery, Washington, DC
  • What Tax Reform Means for Affiliated and Related Corporations. This panel will consider the effect of tax reform legislation, with a primary focus on consolidated return groups, including groups with foreign affiliates. The panel will consider a wide range of topics, including consolidated aspects of interest deduction limitations, NOL carryovers, and new Subpart F inclusions (GILTI). Moderator: Wade Sutton, PwC, Washington, DC Panelists: Julie Divola, Pillsbury Winthrop Shaw Pittman LLP, San Francisco, CA; Professor Victor Fleischer, University of San Diego, San Diego, CA; Brett York, Office of Tax Policy, Department of Treasury, Washington, DC


Session : ABATX1806
Banking & Savings Institutions
Conference : 2018 Midyear Meeting
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  • Chair: Mark H. Price, KPMG LLP, Washington, DC
  • Equity-Based Mortgages – Debt/Equity/Derivatives or a Combination Thereof? A growing number of lenders offer mortgages that are designed to share the risk and reward of depreciation/appreciation in real estate values between the lender and borrower. For the borrower to deduct payments as mortgage interest, the instrument must be a debt instrument secured by real estate. Similarly, for the instrument to be treated as “interest in real property” (so that it can be held in a REMIC or REIT), the instrument must constitute debt. Nevertheless, the equity-based products generally comprise of: (1) traditional debt with low fixed interest, (2) contingent interest, and (3) total return swap. This panel will discuss the issues surrounding these three components; whether the products should be bifurcated or integrated, and how each of the borrower and lender should treat them. Panelists: Yoram Keinan, Smith Gambrell & Russell LLP, New York, NY; Fran Mordi, Mortgage Bankers Association, Washington, DC; Stow Lovejoy, Kostelanetz & Fink LLP, New York, NY
  • Tax Treatment of Cash Advance Transactions. There are a variety of "cash advance" transactions in which a funding party will provide cash to an operating business in exchange for a fixed dollar amount of “future receivables” at a discount. The funding party will then receive a portion of payments owed to the operating business from its customers until the funding party collects the face amount of the purchased receivables. For non-tax purposes, these advances are typically styled as non-debt transactions. This panel will analyze the potential federal income tax treatment of cash advance transactions from the perspective of both the funding party and the seller of the future receivables, including the characterization of the transaction, tax reporting by each of the parties, and cross-border considerations. Panelists: James Combs, Honigmann, Detroit, MI; Brian Harris, Ropes & Gray, New York, NY; James Clegg, Ropes & Gray, New York, NY
  • Current Developments. This panel will discuss some of the recent developments relevant to the banking industry. The panelists will consider the scope of new section 451(b) and its impact on the taxation of certain income streams to banks. Other topics of discussion may include the application of section 199A to banking and related services, select issues with the BEAT, and new issues with bad debts. Panelists: Mark Price, KPMG LLP, Washington, DC; John Taylor, EY, Phoenix, AZ; Lena Hines, EY, Los Angeles, CA


Session : ABATX1807
Closely Held Businesses I
Conference : 2018 Midyear Meeting
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  • Chair: Shawn McIntire, Ballard Spahr LLP, Denver, CO
  • Worker Classification – the IRS, the DOL and the State of California. As worker classification continues to evolve, this panel will compare the IRS' and Department of Labor's classification tests and discuss both Section 530 relief and the Voluntary Classification Settlement Program. This panel will also highlight current worker classification issues in the State of California. Panelists: Betty J. Williams, Law Office of Williams & Associates PC, Sacramento, CA; Robb A. Longman, Longman & VanGrack LLC, Bethesda, MD; William P. Prescott, Wickens Herzer Panza Cook & Batista Co., Avon, OH; Additional Panelist TBD
  • 280E Current Law and Analysis. This panel will discuss the history of IRC section 280E as it pertains to the growing cannabis industry and a summary of the seminal Tax Court cases which define how companies navigate within the rules of 280E. The panel will discuss the C.H.A.M.P. and Olive cases along with trends in the industry. The panel will also highlight some practical considerations when applying these rules including approaching IRS audits of 280E, the importance of analyzing 280E when conducting tax due diligence and structuring deals, and the impact of tax reform on the cannabis industry. Panelists: Adam Abrahams, Meyers Hurvitz Abrahams LLC, Rockville, MD; Shawn McIntire, Ballard Spahr LLP, Denver, CO; Marc Claybon, Crowe Horwath, Denver, CO; Guinevere Moore, Johnson Moore, Chicago, IL
  • C Corporation or Pass Through? Analyzing the Decision in the Wake of the 2017 Tax Act. Just in time before the March 15 deadline to retroactively elect for 2018 C corporation status for S corporations and other pass-through entities, and vice versa, this panel will address, through various scenarios, the income tax considerations of conducting business as a C corporation as opposed to as an S corporation or other pass-through entity. In addition to the obvious federal income tax considerations, the panel will consider the potential application of the personal holding company and accumulated earnings taxes as well as state and local income taxes. Panelists: Jessica N. Cory, Chamberlain Hrdlicka, Houston, TX; Stuart I. Odell, Wilson Sonsini Goodrich & Rosati PC, New York, NY; Elizabeth F. Stieff, Venable LLP, Baltimore, MD; Mark E. Wilensky, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY


Session : ABATX1808
Estate & Gift Taxes
Conference : 2018 Midyear Meeting
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  • Chair: Benjamin G. Carter, Texas Capital Bank, Dallas, TX
  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since January 2017. Panelists: Brian P. Tsu, Henderson Caverly Pum & Charney LLP, San Diego, CA; Helen E. Rogers, Holland & Hart, Denver, CO; Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC
  • Issue Spotting and Drafting for Flexibility in Estate Planning – Both Domestic and International. This presentation will feature a dialogue between a domestic estate planning and an international tax and estate planner. The goal of this presentation is to enable practitioners to spot succession, property, tax and other planning issues in the context of domestic estate planning, provide the basic underpinnings behind them and, most importantly, to offer suggestions for addressing international issues without spending many (likely unbillable) hours researching the issues. Panelists: Brian P. Tsu, Henderson Caverly Pum & Charney LLP, San Diego, CA; Nancy Henderson, Caverly Pum & Charney LLP, San Diego, CA
  • Planning for Unmarried Couples. A growing number of Americans are choosing not to marry. Older adults who have been widowed or previously divorced are deciding to cohabitate instead of marrying. Even same sex couples that can legally marry may decide it’s just not for them. It is important that our cohabiting clients know what rights they are giving up when choosing not to marry. These rights include Social Security, immigration status, the right to decline to testify against a spouse, joint bankruptcy filing and protection of spousal obligations, surviving spouse benefits, benefits under victim’s compensation funds (e.g., 9/11 victims funds), hospital visitation, and, of course, inheritance benefits including the marital deduction. Without intentional planning, if one person dies, the survivor is not entitled to any benefits, notice in a probate proceeding or continuing support that is afforded to legally married spouses. This presentation will examine these issues, with a focus on federal tax, and how we can help our clients plan around them, to protect themselves, their loved ones and their estates. Panelist: Wendy S. Goffe, Stoel Rives LLP, Seattle, WA
  • Buy-Sell Agreements for Closely Held and Family Controlled Business Entities. The presentation will cover both tax and nontax considerations when drafting buy-sell agreements. It will also cover the impact of section 2703 on the ability to establish the value of an interest in a business entity for gift and estate tax purposes. Panelist: Louis A. Mezzullo, Withers Bergman LLP, Rancho Santa Fe, CA


Session : ABATX1809
Individual & Family Taxation
Conference : 2018 Midyear Meeting
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  • Chair: James Creech, Law Offices of James Creech, San Francisco, CA
  • Easy Money? Crowdfunding and Its Tax Considerations. Technology can bring parties together to buy and sell goods and services, loan money, gamble online, offer advertising, and raise funds from strangers. Crowdfunding opportunities are widespread and individuals and businesses can obtain money for medical needs, education, product design, company launches and more. This program explains the crowdfunding model(s) and addresses the tax considerations and issues at the international, federal, state and local levels. Panelists: Carolyn Lee, Morgan Lewis & Bockius, San Francisco, CA; Professor Annette Nellen, San Jose State University, San Jose, CA; Dawn Rhea, Moss Adams, Los Angeles, CA
  • Tips and Best Practices on How Taxpayers May Obtain Relief from Penalties. This panel will discuss a number of penalties that the IRS has the authority to impose on taxpayers. Further, it will consider what type of relief from these penalties is available to taxpayers, such as reasonable cause abatement or first time abatement, and if penalties truly achieve the ultimate goal of promoting voluntary compliance with the nation’s tax laws. Moderator: Joshua R. Beck, Senior Advisor to the Executive Director of Systemic Advocacy, IRS Taxpayer Advocate Service, Des Moines, IA Panelists: Nina E. Olson, National Taxpayer Advocate, Washington, DC; The Honorable Peter J. Panuthos, Special Trial Judge, US Tax Court, Washington, DC; Robert Horwitz, Hochman Salkin Rettig Toscher & Perez PC, Los Angeles, CA
  • Section 104(a)(2) and the Taxation of Damages Received Pursuant to a Settlement Agreement. Damages awarded in a lawsuit are generally included in gross income under section 61(a). However, taxpayers may be able to exclude damages received on account of personal physical injuries and physical sickness from gross income under section 104(a)(2). Whether the taxpayer can avail himself or herself of the exclusion depends in large part on the underlying nature of the harm alleged in the lawsuit. This panel will provide an overview of the exclusion under section 104(a)(2) and discuss the limitations on a taxpayer’s ability to exclude damages received pursuant to settlement agreements. Moderator: Patrick Thomas, University of Notre Dame Law School Tax Clinic, South Bend, IN Panelists: The Honorable Diana L. Leyden, US Tax Court, Washington, DC; Angella L. Warren, IRS Office of Chief Counsel (Income Tax & Accounting), Washington, DC; Jonathan Strouse, Harrison & Held LLP, Chicago, IL; Michael J. Desmond, The Law Offices of Michael J. Desmond APC, Santa Barbara, CA (Invited)


Session : ABATX1810
Investment Management
Conference : 2018 Midyear Meeting
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  • Chair: Roger S. Wise, Willkie Farr & Gallagher LLP, Washington, DC
  • Bearer Notes and Bearer Bonds. This panel will discuss the September 2017 proposed regulations providing guidance on the definitions of “registered-required obligation” and “registered form.” These regulations address changes in market practices and the repeal of the exception to the registered form requirement for foreign-targeted bearer obligations. Moderator: Joe Riley, Dechert LLP, New York, NY Panelists: Spence Hanemann, Office of Associate Chief Counsel (Financial Institutions & Products), IRS, Washington, DC
  • Disruptive Technologies Impacting Investment Management Professionals. The pace of change is incessant and the opportunities and challenges seem to be continuously shifting. The panel will provide an overview of the evolving technology landscape for investment management, including a presentation of the blockchain platform, FundsDLT, on which a first transaction was successfully completed for distribution of fund shares. We will then explore how the evolution of technology is impacting and will continue to impact the tax function in a highly dynamic product, services, and data-driven environment. Finally, we will consider the implications for legal practitioners, with a particular focus on corporate and tax aspects. Moderator: Deanna Flores, KPMG LLP, San Diego, CA Panelists: Julien Ganter, KPMG, Luxembourg; Sarah-Jane Morin, Morgan Lewis & Bockius LLP, San Francisco, CA
  • The 2017 Tax Act: Impact on the Investment Management Industry. This panel will discuss the impacts of the tax bill on funds, investors and managers. Panelists will address the new rules and issues for which technical corrections and/or regulatory guidance is needed. Moderator: Karen Gibian, Investment Company Institute, Washington, DC Panelists: Rebecca Lee, PwC, San Francisco, CA; Amy B. Snyder, The Vanguard Group Inc., Malvern, PA


Session : ABATX1811
Partnerships & LLCs
Conference : 2018 Midyear Meeting
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  • Chair: Professor Noel P. Brock, Eastern Michigan University, Ann Arbor, MI
  • Hot Topics. This panel will discuss the impact of tax reform on partnerships and recent guidance on the BBA rules. Moderator: Beverly Katz, KPMG LLP, Washington, DC Panelists: Adam M. Cohen, Holland & Hart LLP, Denver, CO; Jason Smyczek, Senior Technical Reviewer, Office of Associate Chief Counsel (International), IRS, Washington, DC; Bryan Rimmke, Attorney Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC
  • Tax Distributions. This panel will discuss various issues to address in drafting tax distributions and the pitfalls of failing to account for certain key considerations. Moderator: Steven R. Schneider, Baker & McKenzie LLP, Washington, DC Panelists: Bahar A. Schippel, Snell & Wilmer, Phoenix, AZ; Bryan Rimmke, Attorney- Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC
  • Your Allocations and Capital Accounts are Screwed Up! – What's a Partner(ship)/ Tax Advisor/Return Preparer To Do? Part 2. If (absent an IRS audit) a partnership’s allocations are discovered to have been misallocated among the partners in one or more prior years, and/or capital accounts have not been properly maintained, can the partnership not file amended returns but correct things prospectively? If so, when and how? What are the consequences if not all partners would agree with the changes? This panel will also analyze the partnership’s tax advisors and return preparers’ potential professional and ethical responsibilities, obligations under Circular 230 and risks of penalty. (Continued from Part 1 at the September, 2017 meeting in Austin.) Moderator: Jeff Erickson, EY, Washington, DC Panelists: Nancy Langdon, PwC, Washington, DC; Jose Carrasco, Grant Thornton LLP, Washington, DC
  • Transaction Costs. The BBA rules, which generally are effective for partnership taxable years beginning after December 31, 2017, are expected to be finalized shortly. When the final regulations are published, it is expected that there will be an uptick in IRS examinations involving partnerships. As a result, it is anticipated that the treatment of transaction costs incurred in partnership transactions may be one issue that will receive enhanced IRS Exam scrutiny. This panel will discuss and consider a range of issues that arise regarding the proper treatment of transaction costs associated with a partnership transaction, including which entity (target or acquirer) may take costs into account; the scope of syndication costs; and the application of the covered transaction rules in a partnership transaction. Moderator: Amy Sargent, EY, Washington, DC Panelists: Vish Amin, KPMG, Washington, DC; Ellen McElroy, Eversheds-Sutherland (US) LLP, Washington, DC; Thomas D. Moffitt, Deputy Associate Chief Counsel, Passthroughs and Special Industries, IRS, Washington, DC



     


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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.