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2018 Joint 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.
$299.00



Showing sessions 1 - 10 of (41) TOTAL sessions
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Event : ABATX40


Session : ABATX18100
Tax Bridge on the Road
Conference : 2018 Fall Tax Meeting
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$60.00


  • Cross-Species Mergers: Key US Federal Income Tax Considerations. Over the last half a century or so, state corporate laws have evolved and become more sophisticated to facilitate business. States have added the permissible entity forms through which business can be conducted. State laws also permit mergers of legal entities within the same legal form, and across different legal forms. The Internal Revenue Code and the Treasury Regulations classify all legal entities into those that, for US federal income tax purposes, are (i) taxed as corporations, (ii) treated as partnerships and (iii) disregarded as separate from their respective sole owners. The Code and the Treasury Regulations expressly deal with mergers of (i) an entity taxed as a corporation with another entity taxed as a corporation, and (ii) an entity treated as a partnership with another entity treated as a partnership. Guidance on other forms of merger transactions is, in some cases, spread across other authorities, while in other cases, there is a lack of direct authority altogether. This panel endeavors to piece together the relevant authorities and guidance and highlight some interesting, unresolved questions in this space. Panelists: Hasnain Valika, KPMG, Houston, TX; Amit M. Sachdeva, EY, Houston, TX; Additional Panelists Invited
  • Is There is Another Side to the Story? - C Corporation Versus Pass-through Form. Rules enacted in the Tax Cuts and Jobs Act such as the reduction in the corporate tax rate and the enactment of the pass-through deduction under section 199A have changed the basic historical assumptions regarding choice of business entity. This panel will explore the new fundamental considerations when choosing between the corporate and pass- through forms and identify necessary assumptions and issues ripe for guidance. Moderator: TBA Panelists: Alfred Bae, EY, Houston, TX; Janelle Darnell, KPMG, Washington, DC; Additional Panelists Invited
  • State and Local Tax: Wayfair and the Way Forward. Since 1967, a business has not been required to collect sales tax if it lacks a physical presence in a state. Recently, the Supreme Court reversed that precedent in South Dakota v. Wayfair. This panel will provide the basics to sales tax jurisprudence while also discussing the implications of the Wayfair decision on multinationals and other areas of tax practice. Moderator: Joshua Savey, PwC, Washington, DC Panelists: Giselle Alexander, Dickinson Wright, Phoenix, AZ; Lila Disque, Deputy General Counsel, Multistate Tax Commission, Washington, DC; DeAndré Morrow, Reed Smith, Washington, DC; Jennifer Weidler Karpchuk, Chamberlain Hrdlicka White Williams & Aughtry, Philadelphia, PA
  • Planning for Litigation in the Captive Insurance Area. Moderator: Kelley C. Miller, Reed Smith LLP, Washington, DC Panelists: Rachel L. Partain, Caplin & Drysdale, New York, NY; Justin Scheid, Special Trial Attorney, Office of Chief Counsel (Large Business and International), IRS, Downers Grove, IL (Invited)


Session : ABATX18101
Collection Workshop: How to Represent Taxpayers in Collection Matters from the Final Notice Through Trial and Resolving Collection Issues Facing Estates, Donors, and Donees
Conference : 2018 Fall Tax Meeting
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$45.00


  • Collection Workshop: Part 1 . A panel of experienced government and private bar attorneys will di scuss strategies and techniques to effectively resolve collection matters before the IRS Office of Appeals and the United States Tax Court. Moderator: Susan Morgenstern, Local Taxpayer Advocate – Cleveland, Taxpayer Advocate Service, Cleveland, OH Panelist s: Professor W. Ted Afield, Georgia State University College of Law, Atlanta, GA; Eunkyong Choi, New York City Taxpayer Advocate, Office of the Taxpayer Advocate, New York, NY; Shannon E. Craft, Senior Attorney, IRS Office of Chief Counsel, SBSE, Atlanta, GA; Jeffrey M. Dirmann, Agostino & Associates PC, Hackensack, NJ; Wm. Robert Pope Jr., White & Reasor PLC, Nashville, TN
  • Collection Workshop: Part 2. The panelists will explore special collection devices available to the I RS in the estate and gift tax context, as well as best practices when representing estates, fiduciaries, beneficiaries, and transferees in collection matters before the IRS. Moderator: Susan Morgenstern, Local Taxpayer Advocate – Cleveland, Taxpayer Advoca te Service, Cleveland, OH Panelist s: Professor W. Ted Afield, Georgia State University College of Law, Atlanta, GA; Eunkyong Choi, New York City Taxpayer Advocate, Office of the Taxpayer Advocate, New York, NY; Shannon E. Craft, Senior Attorney, IRS Office of Chief Counsel, SBSE, Atlanta, GA; Jeffrey M. Dirmann, Agostino & Associates PC, Hackensack, NJ; Wm. Robert Pope Jr., White & Reasor PLC, Nashville, TN


Session : ABATX18102
Capital Recovery & Leasing
Conference : 2018 Fall Tax Meeting
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  • Current Developments and Update on Pending Guidance . This panel will cover the important recent developments in the areas of capital recovery and leasing. Moderator: Jessica Hawn, Anderson Tax, Washington, DC Panelist s: John Moriarty, Deputy Associate Chief Counsel, Office of Chief Counsel (IT&A), IRS, Washington, DC; Scott Dinwiddie, Associate Chief Counsel, Office of Chief Counsel (IT&A), IRS, Washington, D C; Kate Abdoo, PwC, Stamford, CT ; Ellen Martin, Tax Policy Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited)
  • A Discussion on Bonus Depreciation - Unpacking the Guidance . This panel will discuss recently released guida nce under section 168(k), including specific issues addressed in such guidance. Moderator: Scott Mackay, EY, Washington, DC Panelist s: Scott Dinwiddie, Associate Chief Counsel, Office of Chief Counsel (IT&A), IRS, Washington, DC; Elizabeth Binder, Attorney , Office of Chief Counsel (IT&A), IRS, Washington, DC; Ellen Martin, Tax Policy Advisor, Department of Treasury, Washington, DC; Carol Conjura, KPMG, Washington, DC; George Manousos, PwC, Washington, DC; Jane Rohrs, Deloitte, Washington, DC


Session : ABATX18103
Administrative Practice
Conference : 2018 Fall Tax Meeting
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  • Important Developments . This panel will discuss current developments and topics of immediate interest in tax administrative practice. Panel will focus on recent legislative efforts impacting tax law and the IRS, Treasury and IRS guidance, court decisions, ongoing litigation and other items germane to tax administration. Moderator: Shamik Trivedi, Grant Thronton, Washington, DC Panelist s: Anson Asbury, Asbury Law Firm, Atlanta, GA; Government Panelists Invited
  • Should You Advise Your Client to Agree to Extend the Statute of Limi tations? In the life of an IRS examination there is almost always one issue certain to arise: whether to consent to extend the statute of limitations. This panel of experienced tax controversy litigators will discuss what factors to consider when advising clients whether or not to sign. Moderator: Kevin Kenworthy, Miller & Chevalier Chartered, Washington, DC Panelist: Andrew Strelka, Latham & Watkins LLP, Washington, DC; Guinevere Moore, Johnson Moore LLC, Chicago, IL; James H. Brunson III, Senior Attorney, IRS Office of Chief Counsel, Atlanta, G
  • The New Partnership Audit Rules, Round I – The Partnership Audit: How You and the IRS Figure It Out . In part one of this two -part program, the panel will discuss what practitione rs and partnerships may expect during an examination under the new partnership audit provisions of the BBA, including the scope of the examination, modifications to the imputed underpayment, and appeals. Part two, The New Partnership Audit Rules, Round II: After the Partnership Audit: How You and the IRS Fight It Out, will be presented by the Court Procedure & Practice committee later in the day and will cover litigation under the new provisions. Moderator: Abbey Garber, Thompson & Knight, Dallas, TX Paneli sts: Mary McNulty, Thompson & Knight, Dallas, TX; Jenni Black, Senior Counsel, Associate Chief Counsel Procedure & Administration, Washington DC; Holly Paz, Director, Pass Through Entities, LB&I, IRS, Washington, DC


Session : ABATX18104
Affiliated & Related Corporations
Conference : 2018 Fall Tax Meeting
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  • When Con solidated Groups and Insurance C ollide . The panel will discuss selected issues raised by the intersection of consolidated groups, captive insurance companies, life/non -life groups and the impact of the 2017 Tax Act. Moderat or: Williams Pauls, Deloitte Tax, Washington, DC Panelists: Kristen Hazel, McDermott Will & Emery, Chicago, IL; Additional Panelists Invited
  • Current Developments . This panel will consider current developments affecting af filiated and related corporations. Moderator: Professor Don A. Leatherman, University of Tennessee School of Law, Knoxville, TN Panelist s: Andy Dubroff, EY, Washington, DC; Additional Panelists Invited


Session : ABATX18105
Banking & Savings Institutions
Conference : 2018 Fall Tax Meeting
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  • US Tax Rules Pertaining to Hybrid Instruments . The 2017 Tax Act imposes penalties for hybrid debt. Similar to BEPS Action 2, section 267A disallows US tax deductions for related party interest and royalties associated with hybrid entities or hybrid transactions. This panel will present the evolution of US tax rules pertaining to hybrid instruments and will discuss the recent developments under the 2017 Tax Act. Moderator: Anthony Tuths, KPMG, New York, NY Panelist: Yoram Keinan, Smith Gambrell & Rus sell LLP, New York, NY
  • Cryptoasset Taxation: Where are we Now? A Comparative Discussion Across Jurisdictions . The advent of cryptoassets, which run on blockchain technology, promises to revolutionize the way we transact. Tax authorities are rushi ng to keep up with this new reality. This panel will provide a brief overview of the taxonomy of cryptoassets and their characterization by the tax authorities in Canada, the US and other jurisdictions. The panelists will then discuss certain of the income and value added tax implications of the characterization that the tax authorities have given to cryptoassets in specific situations including: trades in cryptoassets and ICOs. Moderator: Laura Gheorghiu, Gowling WLG (Canada) LLP, Montreal, Canada Panelist : Yoram Keinan, Smith Gambrell & Russell LLP, New York, NY
  • Banks and the International Provisions of the 2017 Tax Act . The panel will discuss the effect of amended subpart F rules, global intangible low- taxed income (“GI LTI”) inclusion, and the base erosion and anti -abuse tax (“BEAT”) on domestic and foreign banks. Subjects will include downward attribution, allocation of expenses and its effect on GILTI foreign tax credits, and financing of US banks by foreign affiliates . Current and potential future IRS and Treasury guidance will be considered. Moderator: Stow Lovejoy, Kostelanetz & Fink LLP, New York, NY Panelists: Shay Menuchin, KPMG, Toronto, ON; Peter Connors, Orrick, New York, NY


Session : ABATX18106
Closely Held Businesses and Business Planning Group
Conference : 2018 Fall Tax Meeting
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  • Partnership Audit Rules; Update and Practical Considerations . This panel will discuss the recent developments in the partnership audit rules including the impact of the recently enacted regulations. The panelists will focus on drafting techniques and practical planning considerations under the regime. Program schedule informat ion is preliminary and subject to change. For the most up -to-date information, please visit the 2018 Fall Tax Meeting website: http://ambar.org/18fall Panelists: Shawn L. McIntire, Velocity Global LLC, Denver, CO; Galina "Allie" Petrova, Petrova Law PLLC, Greensboro, NC; Ivan Golden, Hahn Loeser, Chica go, IL; Hannah Smith; Sherrard Roe Voight Harbison, Nashville, TN
  • Section 1202: Tax Planning in Light of the 2017 Tax Act . Following the 2017 Tax Act, C Corporations are slowly being introduced into the tax planning mix ag ain to allow taxpayers to benefit from lower tax rates. Hidden within the volumes of the Internal Revenue Code is a little known provision that permits shareholders of closely held businesses to defer gain on small business stock to the tune of $10 Million . This panel will discuss the mechanics of §1202, and planning techniques that business owners can leverage when looking prospectively to selling their company. Topics on the panel will include: what is a qualified small business, why the 2017 Tax Act revi ved the qualified small business stock deduction, steps taxpayers can take in business planning, and what is the future of 1202 transactions. Panelists: Elizabeth F. Stieff, Venable LLP, Baltimore, MD; Josh Lowenth al, Plante Moran, Ann Arbor, M


Session : ABATX18107
Estate & Gift Taxes and Income & Transfer Tax Planning Group
Conference : 2018 Fall Tax Meeting
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$30.00


  • Current Developments . This panel will review developments in federal estate, gift and generation -skipping transfer tax laws since May 2018. Panelists: Megan M. Curr an, Fiduciary Counselling Inc., Tacoma, WA; Beth Kerwin, Paul Weiss Rifkind Wharton & Garrison LLP, New York, NY; Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC
  • Wealth Transfer Planning with Carried Interests in Funds . Planners need to navigate various issues when structuring transfers of interests in closely -held entities, including preferred stock, interests in hedge and PE funds, and other interests. This session will discuss section 2701 and the so -called “ver tical slice,” as well as certain “non- vertical” alternatives including preferred partnerships. The section 2701 attribution rules, section 2036 considerations, incomplete gifts, and valuation uncertainty will also be discussed. Panelists: Todd Angkatavanic h, EY, New York, NY; Jennifer R. Einziger, EY, Washington, DC
  • Can the IRS Have Their Cahill and Eat Yours Too? This panel will discuss the Tax Court’s decision in Cahill v. Commissioner and its impact on planning and defe nding popular estate planning strategies. Panelist: Todd Angkatavanich, EY, New York, NY; James I. Dougherty, Withers Bergman LLP, New Haven, CT; Stephanie Loomis -Price, Winstead PC, Houston, TX
  • Installment Sales to Spousal Grantor Trusts . The fa miliar installment sale to a grantor trust, where a taxpayer sells property to his or her wholly -owned grantor trust, is an effective technique to shift assets among family members on an income or estate tax efficient basis. A variation on this traditional technique is a sale by a trust beneficiary to a grantor trust treated as wholly -owned by the beneficiary’s spouse (the “spousal grantor trust sale”). Similar to the grantor trust sale, the spousal grantor trust sale accomplishes a freeze on the value of t he consideration received on the sale for estate tax purposes. However, the spousal grantor trust sale provides several meaningful advantages over the traditional grantor trust sale, including the potential ability of the selling spouse to be a beneficiary of the trust, possess a special testamentary power of appointment over trust property, and serve as trustee of the spousal grantor trust. This presentation analyzes the tax and practical aspects of an installment sale to a spousal grantor trust, and how i t differs from a traditional grantor trust sale and other estate freeze techniques. Panelist: Briani B. Mellen, Culp Elliott & Carpenter PLLC, Charlotte, NC; Paul M. Hattenhauer, Culp Elliott & Carpenter PLLC, Charlotte, NC


Session : ABATX18108
Individual & Family Taxation
Conference : 2018 Fall Tax Meeting
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  • SALT Deduction Limit Workarounds Panel . This panel will discuss the various strategies that States are implementing to provide a workaround to the 2017 Tax Act’s state and local tax deduction limit. In general, these programs us e contributions to various state -sponsored funds or programs that offer a credit against state tax liability. The panel will evaluate and discuss the legal merits of such workarounds. Panelists: Professor Andy Grewal, University of Iowa College of Law, Iowa City, IA; Professor Kirk J. Stark, UCLA School of Law, Los Angeles, CA; Professor Timothy M. Todd, Liberty University School of Law, Lynchburg, VA
  • What Is APA's Role i n Tax Administration? This panel will examine what practitioners should know a bout how the APA interacts with IRS decision making, as well as a discussion on APA current developments. Topics include: What The Heck Is Going On With Altera ?; How to identify what types of IRS decisions are potentially subject to APA review; How to rais e an APA objection; and What the future may hold for further IRS and APA integration. Moderator: James Creech, Law Offices of James Creech, San Francisco, CA Panelists: The Honorable Mark Holmes, US Tax Court, Washington DC; Professor Leandra Lederman, Ind iana University Maurer School of Law, Bloomington, IN; Bryan Skarlatos, Kostelanetz and Fink, New York NY; Emily Lesniak, Office Of Chief Counsel, IRS (Practice and Administration), Washington, DC
  • How Can I Live On That? This panel will discuss the challenges low to moderate income individuals face in communicating their true economic situations to the IRS and authorized private debt collection agencies who make decisions based upon allowable expense data that may not ref lect reality. The panel will discuss strategies for presenting taxpayers’ economic situations to better ensure they qualify for collection alternatives, such as Effective Tax Administration and doubt as to collectability offers in compromise, practitioners ’ due diligence requirements and ethical responsibilities when advocating for clients to pay no more than the correct amount of tax. Moderator: Pro fessor Erin Sterns, University o f Denver, Denver, CO Panelists: Professor Tameka Lester, Georgia State Univer sity, Atlanta, GA; Joshua Wu, Clark Hill Strasburger, Washington DC; Ashley Y. Smith, Senior Attorney, Office of Chief Counsel, Atlanta, GA; Daniel B Causey IV, TAS Attorney Advisor Group, Washington, DC


Session : ABATX18109
Investment Management
Conference : 2018 Fall Tax Meeting
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  • Chair: Roger S. Wise, Willkie Farr & Gallagher LLP, Washington, DC
  • Post-Tax Reform Planning for Cross-Border Investments by Private Funds. This panel will discuss the implications of tax reform for structuring certain outbound and inbound investments by private equity funds. Topics will include issues arising from changes to the rules regarding the determination of controlled foreign corporation status and the global intangible low-taxed income rules, as well as the impact of tax reform changes on planning using blocker corporations. Moderator: Erik Corwin, KPMG, Washington, DC Panelists: Cheryl Coe, Latham & Watkins LLP, Washington, DC; David R. Sicular, Paul Weiss Rifkind Wharton & Garrison LLP, New York, NY
  • State Tax Issues for Investment Funds. This panel will cover a few significant recent developments in the state tax area affecting investment managers and funds. These topics will include the Supreme Court’s recent decision in the Wayfair case and some of the ways in which it might affect managers and their clients, including in states that have adopted market-based sourcing. Moderator: Sam Megally, K&L Gates LLP, Dallas, TX Panelist: Nikki E. Dobay, Council On State Taxation, Portland, OR
  • Cryptocurrency Funds. This panel will address issues faced by funds that invest in virtual currencies. Topics will include the treatment of virtual currencies for purposes of sections 721, the application of the straddle rules and the wash sale rules, the section 475(f) election, reverse section 704(c) allocations, section 864(b) and the FATCA rules, as well as choice-of-entity considerations for virtual currency funds. Moderator: Mary Conway, Davis Polk & Wardwell LLP, New York, NY Panelists: Rebecca Lee, PwC, Washington, DC; David Wermuth, Schulte Roth & Zabel LLP, New York, NY



     


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