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2019 Midyear Meeting

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(c) [2019] 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 11 - 20 of (43) TOTAL sessions
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Event : ABATX41


Session : ABATX1911
S Corporations
Conference : 2019 Midyear Meeting
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  • Chair: Thomas J. Phillips, von Briesen & Roper sc, Milwaukee, WI
  • Section 163(j) Proposed Regulations. A dialogue with representatives from the Treasury Department and the Internal Revenue Service Chief Counsel’s Office on the section 163(j) proposed regulations as applied to S corporations. Moderator: Kevin D. Anderson, BDO USA LLP, Washington, DC Panelist: H. Grace Kim, Grant Thornton LLP, Washington, DC
  • Section 1202 Entity Selection Considerations. This panel will review section 1202 as a factor in C corporation versus S corporation selection. Moderator: Thomas J. Nichols, Meissner Tierney Fisher & Nichols SC, Milwaukee, WI Panelists: Laura Howell-Smith, Deloitte Tax, Washington, DC; Steven I. Klein, Sher Garner Cahill Richter Klein & Hilbert, New Orleans, LA
  • Important Developments in the Federal Income Taxation of S Corporations. This panel will discuss recent legislative administrative and judicial developments relating to S corporations and their shareholders. Moderator: Laura Krebs Al-Shathir, Capes Sokol, St. Louis, MO Panelists: Mary Beth Dolan, Bryan Cave Leighton Paisner LLP, St. Louis, MO; Edward A. Waters, Dean Mead, Orlando, FL


Session : ABATX1912
Foreign Activities of US Taxpayers
Conference : 2019 Midyear Meeting
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  • Chair: Kimberly J. Majure, KPMG, Washington, DC
  • Foreign Tax Credits 2.0. The issuance of recent foreign tax credit guidance has made life... interesting. Taxpayers and advisors alike are struggling to grasp the implications of the new proposed regulations and identify open issues. Join several members of the FAUST comments group, for a discussion of the latest developments. Moderator: Caren Shein, Deloitte, Washington, DC Panelists: Dirk Suringa, Covington & Burling, Washington, DC; Micah Gibson, PwC, Washington, DC
  • Tax Reform: Outbound Case Study. This panel will present a case study involving a "simple" US based multinational and a few fairly common transactions. We will then walk through a comparison of the pre-Tax Reform and post-Tax Reform implications of the transactions. Moderator: Sam Kaywood, Alston & Bird, Atlanta, GA Panelists: Barbara Rasch, KPMG, Los Angeles, CA; Natan Leyva, Vinson & Elkins, Washington, DC; Rafi Mottahedeh, Cargill, Wayzata, MN


Session : ABATX1913
Transfer Pricing
Conference : 2019 Midyear Meeting
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  • Chair: Timothy S. Gunning, EY, New York, NY
  • The Great BEAT Debate – A Rematch. Taxpayers and tax planners have struggled with myriad interpretative issues related to the new Base Erosion and Anti-Abuse Tax, more fondly known as the BEAT. The proposed regulations expected in late 2018 will doubtless provide enhanced clarity, but important questions surely remain. Moreover, the proposed regulations will raise new issues—in particular, with respect to Treasury’s interpretation of the BEAT’s significant statutory ambiguities and mixed policy implications. The amounts at stake are not small. And in some cases, the “right” answer is far from clear. Reprising a pre-regulations debate among the same debaters, this panel will explore the most critical issues under the newly proposed guidance through a point-counterpoint format, with panelists pairing off (and squaring off) to present the primary competing viewpoints. This lively format will enable audience members to more fully understand and evaluate the critical risks related to the proposed BEAT regulations and the factors that Treasury and the IRS may consider in finalizing guidance on the BEAT. Moderator: Anne Gordon, PwC, Washington, DC Panelists: Loren Ponds, Miller & Chevalier, Washington, DC; Professor William J. Seeger, University of Texas at Arlington, Economics and College of Business, Arlington, TX; Martin A. Sullivan, Tax Analysts, Washington, DC; Thomas A. Vidano, EY, Washington, DC; Maruti R. Narayan, DLA Piper, New York, NY
  • Current Trends in Transfer Pricing Cases. There are billions at stake as the IRS and taxpayers continue to fight over the proper application of section 482 with no end in sight. Altera, Amazon.com, Coca-Cola, Eaton, Facebook, Medtronic, and Perrigo , among others, continue to work their way through the courts, and none of them has reached final resolution. This panel will discuss current trends and recurrent themes in the pending transfer pricing cases and what the future may hold. Panelists: Angela Chang, Baker McKenzie, Palo Alto, CA; Ryan Kelly, Alston & Bird, Washington, DC; Lillian Sullivan, KPMG, Washington, DC


Session : ABATX1914
Exempt Organizations
Conference : 2019 Midyear Meeting
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  • Chair: Lisa L. Johnsen, Bill & Melinda Gates Foundation, Seattle, WA
  • News of the IRS and Treasury and Update on Developments Under the 2017 Tax Act. EO committee members will discuss topics of current interest to exempt organizations practitioners and developments since our last meeting with respect to provisions of the 2017 Tax Act impacting tax exempt organizations. Moderator: Cynthia M. Lewin, Venable LLP, Washington, DC; Panelists: Meghan R. Biss, Caplin & Drysdale, Washington, DC; Emily M. Lam, Skadden Arps Slate Meagher & Flom LLP, Palo Alto, CA; Preston Quesenberry, KPMG LLP, Washington, DC; Ralph DeJong, McDermott Will & Emery, Chicago, IL; Alexander L. Reid, Morgan Lewis & Bockius LLP, Washington, DC
  • Beyond Electioneering 101. The midterms may have just wrapped up, but 2020 will be upon us before you know it. This panel will focus on election-related questions for which existing guidance does not provide simple answers, covering topics such as targeting decisions and use of issues in voter engagement activities (registration, education, and get-out-the vote), fundraising, ballot measure advocacy, interactions with candidates and political parties, and use of social media. Moderator: Rosemary E. Fei, Adler & Colvin, San Francisco, CA Panelists: Andrew Schulz, Arabella Advisors, Washington, DC; Charles M. Watkins, Webster Chamberlain & Bean LLP, Washington, DC
  • Accounting for Lawyers (NOT!): The Practical Ramifications of NEW Accounting Standards Update 2018-08 on Exempt Organizations. Implementation of ASU 2016-14 (with expanded guidance via ASU 2018-08) is required for fiscal years (including interim periods within such years) beginning after 12/15/2018. The two ASUs alter financial statement presentation and footnote disclosures (NOT per se accounting). This panel will discuss how ASU 2018-08’s clarifications affect financial statements’ reporting of grants and contracts received, intersect with the Regulations’ standards for the two “public support tests,” and the challenges grantmakers have faced in light of these new edicts. Panelists: Eve Borenstein, BAM Law Office LLC, Minneapolis, MN; Deby MacLeod, Clark Nuber PS, Seattle, WA
  • Current Complex Investment Issues. This panel will discuss current complex exempt organization investment issues, including potential private benefit and inurement concerns raised by the partnership audit rules effective in 2018, the section 965 transition tax, GILTI and special private foundation issues such as excess business holdings and co-investments with disqualified persons. Moderator: David A. Shevlin, Simpson Thacher & Bartlett LLP, New York, NY Panelists: Michael E. Durham, Kirton McConkie PC, Salt Lake City, UT; Joshua E. Gewolb, Harter Secrest & Emery LLP, Rochester, NY; Chelsey Ziegler, John D. and Catherine T. MacArthur Foundation, Chicago, IL


Session : ABATX1915
Tax Policy and Simplification
Conference : 2019 Midyear Meeting
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  • Chair: Roger Royse, Royse Law Firm, Menlo Park, CA
  • Tax Law Needs Couples Therapy: Alimony, Voss and Policy Considerations in Taxing Divorced and Unmarried Couples. Before their repeal by the 2017 Tax Act, former Sections 71, 215 and 682 of the Internal Revenue Code allowed payors to deduct alimony payments and required payees to treat the payments as taxable income. Alimony payments made under agreements or decrees governed by the 2017 Tax Act are not deductible by the payor and are not includible in the recipient’s income. This change is expected to raise revenue because the divorced couple’s taxable income will no longer be split between two taxpayers. Instead, the principal earner will be taxed, possibly at a high average rate, on all of his or her earnings. Since this tax will often be determined by the single taxpayer rate schedule, the overall annual tax burden on the divorced couple may be substantially greater than it was before the divorce. It may also be substantially greater than it would have been after the divorce under prior law. The 2017 Tax Act also made other changes in the law that affect divorce planning. The changes in the divorce context overall are expected to raise revenue from divorced couples. Critics of the new law argue that the alimony tax deduction has been an important incentive for settling family law cases, in part because it eased the financial impact of divorce. Proponents have characterized prior law as a “divorce subsidy” and cite non-compliance data (non-reporting of alimony income by some recipients). On the other hand, the new law basically puts divorced couples on the same playing field as couples in civil unions or domestic partnerships who may or may not have had the option of getting married. Strangely enough, a more noticeable divorce or non-marriage subsidy results under the 2015 9th Circuit Voss decision for some couples with higher incomes as a result of the limitations on deductions for mortgage interest and state taxes. Maybe it is time to rethink marriage as a special status involving shared income and expenses that differs from how other couples, those not married, handle their budgets. Our panel will present the competing arguments and discuss the practical and policy implications of the repeal. Moderator: Professor Michael B. Lang, Chapman University Fowler School of Law, Irvine, CA Panelists: Phyllis Horn Epstein, Epstein, Shapiro & Epstein PC, Philadelphia, PA; Professor Anthony C. Infanti, University of Pittsburgh School of Law, Pittsburgh, PA


Session : ABATX1917
US Activities of Foreigners & Tax Treaties
Conference : 2019 Midyear Meeting
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  • Chair: Summer LePree, Bilzin Sumberg Baena Price & Axelrod LLP, Miami, FL
  • Section 267A – A Hybrid Approach to Dealing with Hybrids. This panel will review new section 267A and how it fits (or doesn’t fit) together with other provisions of the Code and Regulations that address hybrids and hybrid related provisions in the 2016 Model Treaty. The panel will review scenarios where section 267A can deny a deduction while the hybrid regulations or a Treaty would deny treaty benefits at the same time. The panel will also address whether section 267A may apply to the use of hybrids in outbound scenarios. The panel will review proposed regulations under section 267A if they are available. Moderator: Sam K. Kaywood Jr., Alston & Bird, Atlanta, GA Panelists: Jeffrey L. Rubinger, Bilzin Sumberg Baena Price & Axelrod LLP, Miami, FL; Pamela Endreny, Skadden, New York, NY
  • Shedding Light on the BEAT. This panel will discuss the operation of the new base erosion and anti-abuse tax (BEAT) and issues that taxpayers must consider relating to the BEAT. Included in this panel discussion will be the scope of base erosion payments, how the aggregation rules work, exceptions to base erosion payments (including the service cost method and COGs exception), and the interaction of the BEAT with other tax regimes. Any guidance from the IRS and Treasury relating to the BEAT will be covered in this panel. Moderator: Joe Calianno, BDO, Washington, DC Panelists: Lucas Giardelli, Mayer Brown LLP, New York, NY; Amie Colwell Breslow, PwC, Washington, DC


Session : ABATX1918
Court Procedure & Practice Roundtable Discussion
Conference : 2019 Midyear Meeting
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  • Chair: Joshua D. Odintz, Baker & McKenzie LLP, Washington, DC
  • The Role of Form 4340 in Tax Litigation. This discussion will focus on the role of Form 4340 in tax controversies and litigation. The panel will explore the basics of Form 4340, deference to be given to the form by Settlement Officers, Tax Court, and District Court, what items on the form are entitled to a presumption of correctness, admissibility and challenges to the form under the Federal Rules of Evidence, and the impact of lost administrative files. Moderator: Valerie Vlasenko, Agostino & Associates PC, Hackensack, NJ Panelists: Lawrence Sannicandro, McCarter & English, Newark, NJ; Jonathan T. Amitrano, Law Offices of A. Lavar Taylor, Santa Ana, CA; Professor Bryan Camp, Texas Tech University School of Law, Lubbock, TX


Session : ABATX1919
Diversity I
Conference : 2019 Midyear Meeting
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  • Chair: Lany L. Villalobos, Dechert LLP, Philadelphia, PA
  • Power & Privilege: The Social and Cultural Implications Arising From Our Federal Tax System. Our federal tax system is a revenue raising mechanism, but what do the policies underlying the mechanics of our federal system reflect about our society and what we value? Is our federal tax system a reflection of the lines of difference and discrimination in American society based on race, ethnicity, socioeconomic class, gender, sexual orientation, gender identity, immigration status, and disability? This panel will discuss the theories raised in the recent book, “Our Selfish Tax Laws: Toward Tax Reform That Mirrors Our Better Selves”. Moderator: M. Blair James, Law Clerk, US Tax Court, Washington, DC Panelists: Professor Anthony Infanti, University of Pittsburgh School of Law, Pittsburgh, PA; Professor Linda Beale, Wayne State University Law School, Detroit, MI; Armita Sobhi, EY, Washington, DC


Session : ABATX1920
State & Local Taxes
Conference : 2019 Midyear Meeting
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  • Chair: Edward J. Bernert, BakerHostetler, Columbus, OH
  • The (Funny) Business of Putting on a Mardi Gras Parade. Members of the Krewe of Muses explain the process of forming an all-female carnival organization and putting on the parade that New Orleanians voted, hands down, best Mardi Gras parade each year! Moderator: Jaye Calhoun, Kean Miller LLP, New Orleans, LA Panelists: Virginia Saussy, Force of Nature, New Orleans, LA; Kathy Conklin, McGlinchey Stafford PLLC, New Orleans, LA


Session : ABATX1922
Employment Taxes
Conference : 2019 Midyear Meeting
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  • Chair: Edward J. Leyden, Leyden Law LLC, Washington, DC
  • IRS Employment Tax Update. Senior IRS officials provide an overview of important developments since the October 2018 Meeting, including pertinent Supreme Court decisions, guidance projects in connection with the 2017 Tax Act, and proposed legislation, such as the proposed EMPOWHER ACT. Speaker: Edward J. Leyden, Leyden Law LLC, Washington, DC
  • Current Developments in Federal Employment and Payroll Tax Enforcement. The IRS has been increasingly diligent in enforcing employment and payroll tax compliance. This panel will discuss challenges both to practitioners and to enforcement agents, alike. Speaker: Chaya Kundra, Kundra Tax Law LLC, Rockville, MD
  • Federal Update. Speaker: Robert Schmidt, Kean Miller LLC, Baton Rouge, LA
  • Update on the Tax Consequences of Employment Settlements and Judgements. Resolving employment disputes has always been a prominent feature of the legal landscape. Recent events, however, have brought into even sharper focus for employers and their executives, alike, the potential pitfalls that can arise from alleged workplace harassment and misconduct. Partly in response to these events – and for separate fiscal reasons, as well – the 2017 Tax Act has made very significant changes to the federal tax consequences that may arise from the disposition of an employment dispute, including for the deductibility of settlement amounts and attorneys’ fees. This panel will provide an overview of the overarching tax principles governing employment disputes, examine the tax treatment of settlements and judgments under revised federal tax law (including new IRC § 162(q)), and discuss potential next legislative and administrative steps for addressing these issues, including the proposed EMPOWHER Act. Speaker: Edward Leyden, Leyden Law LLC, Washington, DC



     


Showing sessions 11 - 20 of (43) TOTAL sessions
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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.