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2019 May 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.

$299.00



Showing sessions 11 - 20 of (42) TOTAL sessions
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Event : ABATX42


Session : ABATX1956
Individual & Family Taxation
Conference : 2019 May Meeting
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  • Chair: James Creech, Law Offices of James Creech, San Francisco, CA
  • Update from the Gig Economy Trenches – What’s New for Independent Contractors and Individuals with Business Income. The number of independent contractors, especially gig economy workers, continues to grow along with the tax compliance issues this work triggers. In fact, Treasury’s Inspector General found in a report earlier this year that “along with the gig economy, self-employment tax underreporting will continue to grow if not addressed.” The 2017 Tax Act did not address the under- and non-reporting of income of these workers and may have instead added to their tax compliance and financial challenges with section 199A and the repeal of the ACA’s individual mandate. This panel will provide updates on how gig workers are affected by section 199A as well as state actions to institute new income reporting requirements. Recent developments on misclassification litigation, research on the impact of the tax compliance rules on federal in-come and self-employment taxes, particularly Social Security, as well as efforts to address these issues in the 116th Congress, will be covered. Panelists: Professor Caroline Bruckner, American University Kogod Tax Policy Center, Washington, DC; Professor Annette Nellen, San Jose State University, San Jose, CA; Sarah Schaefer, Senior Tax Policy Advisor, Senate Finance Committee, Washington, DCCo-Sponsored by: Pro Bono & Tax Clinics
  • CDP – Beyond the Weeping and Gnashing of Teeth; What Can be Done to Fulfill CDP’s Beneficial Intent? Collection due process (CDP) rights launched twenty years ago to provide additional procedural protections to taxpayers facing tax liabilities. CDP is an essential part of the practitioner’s toolkit: It offers independent review of IRS collection actions, including the chance for alternatives to enforced collection and, in certain instances, review of the liability itself. CDP may be used to achieve meaningful and lasting collection resolutions for both pro se and represented taxpayers. However, CDP also may be an expensive and emotionally wrenching experience for taxpayers who enter the process in good faith, only to be greeted by inflexible, unrealistic deadlines, overworked IRS professionals applying cookie cutter tactics to move a file off their desk, and a Court swamped with equally cookie cutter motions for summary judgment by the IRS against which pro se taxpayers are ill-equipped to defend. Even seasoned tax practitioners are frustrated by inadequate case records, inelastic government responses, and seemingly limited judicial remedies. This program will move beyond “let me tell you how it all went wrong” to brainstorm what realistically might be done to fulfill the promise of CDP. Moderator: Carolyn Lee, Morgan Lewis and Brockius, San Francisco, CA. Panelists: The Honorable David Gustafson, US Tax Court, Washington, DC; Professor Keith Fogg, Harvard Law School, Boston MA; Mitchel Hyman, IRS Office of Chief Counsel, IRS, Washington, DC; William Schmidt, Kansas Legal Services Low Income Tax Clinic, Kansas City, KS; Professor Erin Stearns, University of Denver Low Income Tax Clinic, Denver, CO. Co-Sponsored by: Pro Bono & Tax Clinics
  • IRS Refund Fraud Filters: How They Combat Fraud, How They Impact Taxpayers, and What Can Be Done to Make Them Better? The IRS applies fraud detection filters to all tax returns claiming a refund before making payment. These internal filters are designed to reduce improper payments by matching taxpayer information to statistical data as well as third party information returns. While these filters are effective and credited with saving billions in taxpayer dollars, they are not perfect and do generate false positive determinations of improperly claimed refunds. If a taxpayer is subject to a false positive the burden is on them to verify their identity and that the information was correct on the return. This panel will look at the mechanics of fraud detection, the impact on taxpayers, if certain groups of taxpayers are more likely receive false positive determinations, and what can be done to improve the fraud detection system. Moderator: Josh Beck, Senior Advisor Systemic Advocacy Taxpayer Advocate Service, Des Moines, IA. Panelists: Nina Olson, National Taxpayer Advocate, Washington, DC; Denise D. Davis, Wage & Investment Director, IRS Return Integrity Operations (RIO), Atlanta GA; James Creech, Law Offices of James Creech, San Francisco, CA; Co-Sponsored by: Pro Bono & Tax Clinics


Session : ABATX1957
Transfer Pricing
Conference : 2019 May Meeting
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  • Chair: Timothy S. Gunning, EY, New York, NY
  • Developments at the IRS Advance Pricing and Mutual Agreement (APMA) Program and the OECD Pertaining to Advance Pricing Agreements (APAs) and Mutual Agreement Procedure (MAP) Cases. John Hughes, Director of APMA and Sami Laaksonen, Director, Delegated Competent Authority of the Finnish Tax Administration, as well as the other panelists, will be will be discussing some new ideas being explored for reducing the length (and some of the administrative burden) of the bilateral APA process, including a “cross-border dialogue” (CBD) initiative and prospects for “light” APA procedures. Additionally, the panel will cover other timely and pertinent topics, such as the following: Recently published APMA statistics for APAs and MAP cases and what they mean for current and future case inventory and processing; The current state of competent authority relationships with key treaty partners and efforts to improve competent authority dispute resolution processes; Profit-Split and its use in competent authority cases; BEAT, and how APAs may or may not be able to address BEAT or other 2017 Tax Act-related issues; APMA’s use of “reference” sets. Moderator: Samuel M. Maruca, Covington & Burling, Washington, DC. Panelists: John C. C. Hughes, Director, Advance Pricing and Mutual Agreement Program, IRS, Washington, DC; Sami Laaksonen, Director, Delegated Competent Authority, Finnish Tax Administration, Helsinki, Finland; Bao Ho, MUFG Americas, New York, NY; Nihan Mert-Beydilli, NERA Economic Consulting, Los Angeles, CA; David Ernick, PwC, Washington, DC


Session : ABATX1958
Exempt Organizations
Conference : 2019 May Meeting
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$75.00


  • Chair: Lisa L. Johnsen, Bill & Melinda Gates Foundation, Seattle, WA
  • News from the IRS, Treasury and the Hill. Representatives from the IRS, Treasury Department and Joint Committee on Taxation will discuss topics of current interest to exempt organizations practitioners. Moderator: Celia Roady, Morgan Lewis & Bockius LLP, Washington, DC. Panelists: Victoria A. Judson, Associate Chief Counsel, IRS Office of Chief Counsel (EEE), Washington, DC (Invited); Janine Cook, Deputy Associate Chief Counsel, IRS Office of Associate Chief Counsel (EEE: EOET), Washington, DC (Invited); Elinor C. Ramey, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited); Gordon M. Clay, Senior Legislation Counsel, Joint Committee on Taxation, Washington, DC (Invited)
  • Update on Developments Under the 2017 Tax Act. This panel will discuss guidance issued with respect to provisions of the 2017 Tax Act impacting tax exempt organizations. Moderator: Carolyn O. (Morey) Ward, Ropes & Gray LLP, Washington, DC. Panelists: Elinor C. Ramey, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited); A. L. (Lorry) Spitzer, Office of the General Counsel, MIT, Cambridge, MA; Bridget M. Weiss, Arnold & Porter Kaye Scholer LLP, Washington, DC
  • Understanding and Addressing Impermissible Private Benefit in the Era of Modern Philanthropy. This panel will discuss ways in which private benefit in an era of increased engagement with non-traditional approaches and collaborators to achieve charitable purposes. Among these are opportunity zones, micro-lending to businesses, pay-for-success, so called “impact investing,” blended or hybrid structures and operating models, and ventures with government agencies and other than charitably oriented businesses and sources of capital. These and other approaches require greater intentionality around understanding the value of brand and reputation, data collection and analysis, and risk allocation. There are often charitable opportunities to pursue and philanthropic successes to be realized once the issues are identified and managed appropriately. Panelists: Hillary Bounds, Chan Zuckerberg Initiative LLC, Redwood City, CA; Edward Diener, King Philanthropies, Menlo Park, CA; John Tyler, Ewing Marion Kauffman Foundation, Kansas City, MO
  • News in the News: Current Issues in Nonprofit Journalism. This panel will discuss tax issues impacting nonprofit news organizations, philanthropic funders of journalism in the public interest, and community news outlets seeking alternative structures. Moderator: Nancy McGlamery, Adler & Colvin, San Francisco, CA. Panelists: Monika Bauerlein, Foundation for National Progress/Mother Jones, San Francisco, CA; Kimberly Eney, Latham & Watkins LLP, Washington, DC; Richard L. Fox, Buchanan Ingersoll & Rooney PC, Philadelphia, PA
  • International Philanthropy: Non-Tax Issues that Every EO Lawyer Needs to Know. This panel will discuss current issues relevant to cross-border giving, including trends in the regulation of charitable activity and charitable giving overseas, as well as recent developments in the US that affect both inbound and outbound philanthropy. Moderator: Tamara L. Watts, Bill & Melinda Gates Foundation, Seattle, WA. Panelists: Les P. Carnegie, Latham & Watkins LLP, Washington, DC; Douglas Rutzen, International Center for Not-for-Profit Law, Washington, DC; M. Ruth Madrigal, KPMG, Washington, DC


Session : ABATX1960
Foreign Activities of US Taxpayers
Conference : 2019 May Meeting
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  • Chair: Kimberly J. Majure, KPMG, Washington, DC
  • Repatriation of Foreign Earnings. So many ways to repatriate, too many sticky issues to navigate. This panel will take us through our new normal, including a discussion of dividends and current inclusions under subpart F and GILTI, as well as related implications for previously (US-taxed) or foreign-taxed earnings. Moderator: Jose Murillo, EY, Washington, DC. Panelists: Rachel Kleinberg, Davis Polk & Wardwell LLP, Menlo Park, CA; Aziza Yuldasheva, Deloitte LLP, Washington, DC; Brenda Zent, Special Advisor on International Taxation, Office of International Tax Counsel, Department of Treasury, Washington, DC; Melinda Harvey, Senior Counsel, Branch 2, IRS Office of Associate Chief Counsel (International), Washington, DC
  • Choice of Entity and Structuring for Multinational Corporations and Partnerships After Tax Reform (Part 1). This is a two-part panel, presented jointly with USAFTT. In the post-Tax Reform world, choice of entity is... complicated. This most basic of questions has a lot of new implications—sticks vs carrots, aggregate vs entity, who’s caught and who’s not. The FAUST piece of the presentation will take an outbound and inbound look at the issues from a “big company” perspective. Issues considered will include global intangible low-taxed income (GILTI) under section 951A, the 100% dividend received deduction under section 245A, new rules under the dual consolidated loss rules of section 1503(d), the deduction for foreign derived intangible income under section 250, the CFC group election under section 163(j), the application of the base erosion and anti-abuse tax under section 59A and the new hybrid rules relating to interest and royalties under section 267A. Moderator: Joe Calianno, BDO USA LLP, Washington, DC. Panelists: Layla Asali, Miller & Chevalier Chartered, Washington, DC; Ari Berk, Deloitte LLP, Washington, DC; Daniel M. McCall, Deputy Associate Chief Counsel (International), IRS Office of Associate Chief Counsel (International), Washington, DC; Douglas Poms, International Tax Counsel, Department of Treasury, Washington, DC


Session : ABATX1961
S Corporations
Conference : 2019 May Meeting
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  • Chair: Thomas J. Phillips, von Briesen & Roper sc, Milwaukee, WI
  • 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: Edward A. Waters, Dean Mead, Orlando, FL; Alison Helland, Boardman & Clark LLP, Madison, WI
  • Section 163(j) Proposed Regulations. A follow up dialogue with representatives from the Treasury Department and the IRS Office of Chief Counsel on the section 163(j) proposed regulations as applied to S corporations. Moderator: Kevin D. Anderson, BDO USA LLP, Washington, DC. Panelists: Colin Campbell, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Samuel P. Starr, Special Counsel, IRS Office of Chief Counsel, Pass-Throughs & Special Industries, Washington, DC; H. Grace Kim, Grant Thornton LLP, Washington, DC
  • Section 199A Regulations. A dialogue with representatives from the Treasury Department and the IRS Office of the Chief Counsel on the recently issued Section 199A Final Regulations, the Proposed Amendments thereto and the Proposed Revenue Procedure Safe Harbor (Notice 2019-07). Moderator: Thomas J. Nichols, Meissner Tierney Fisher & Nichols SC, Milwaukee, WI. Panelists: Colin Campbell, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Audrey W. Ellis, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Wendy L. Kribell, IRS Office of Chief Counsel, Pass-Throughs & Special Industries, Washington, DC


Session : ABATX1962
Standards of Tax Practice
Conference : 2019 May Meeting
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  • Chair: Rachel L. Partain, Caplin & Drysdale Chartered, New York, NY
  • Ethical Issues in Federal Tax Practice – The Government Perspective. This panel will discuss issues of concern and areas of focus for the IRS Office of Professional Responsibility and Office of Chief Counsel and provide an update on recent guidance from the IRS and the Department of Treasury and pending cases that relate to tax practice standards. Moderator: Aaron Esman, Caplin & Drysdale, New York, NY. Panelists: Stuart Murray, Special Counsel to the Director, IRS Office of Professional Responsibility, Washington, DC; Hollie Marx, Senior Technician Reviewer, IRS Office of Associate Chief Counsel (Procedure and Administration), Washington, DC
  • A Whole New World: The 2017 Tax Act, Tax Advice, and Lawyer Ethics. 2018 was a significant year for taxpayers and tax advisors alike as the IRS and Treasury began to issue rules related to the 2017 Tax Act. While the bulk of the 2017 Tax Act's statutory provisions came into effect for tax years beginning after December 31, 2017, the government hasn’t quite finalized all the rules. This panel will explore practitioners’ ethical considerations in giving advice where the law is not entirely clear and authorities may be conflicting, and will discuss the impact of making disclosures on a tax return, the weighing of authorities, and general ethical issues in zealous advocacy in uncertain times. Moderator: Shamik Trivedi, Grant Thornton LLP, Washington, DC. Panelists: Ashton P. Trice, Deputy Associate Chief Counsel, IRS Office of Associate Chief Counsel (Procedure and Administration), Washington, DC; Matthew Cooper, Deloitte Tax LLP, Washington, DC; Kandyce Korotky, Covington & Burling LLP, Washington, DC; Lisa Zarlenga, Steptoe & Johnson LLP, Washington, DC
  • The Obligation to Report Tax-Related Misconduct. Tax practitioners should be mindful of their ethical obligation to report tax-related misconduct under the internal revenue laws, the Model Rules of Professional Conduct, and Circular 230. A group of experienced panelists will examine when, whether, and how to complain about professional misconduct by private practice and government attorneys or the Court. The panelists will also discuss when, whether, and how to report tax-related misconduct by unscrupulous tax professionals. Moderator: Lawrence A. Sannicandro, McCarter & English LLP, Newark, NJ. Panelists: The Honorable Elizabeth A. Copeland, Judge, US Tax Court, Washington, DC; Nina E. Olson, Taxpayer Advocate Service, Washington, DC; Frank Agostino, Agostino & Associates PC, Hackensack, NJ; Karen L. Hawkins, Hawkins Law, Yachats, OR; Special Agent in Charge, Treasury Inspector General for Tax Administration, Washington, DC (Invited)


Session : ABATX1963
Court Procedure and Practice Roundtable
Conference : 2019 May Meeting
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  • Chair: Joshua D. Odintz, Baker & McKenzie LLP, Washington, DC
  • Failure to Provide Information Returns and Litigation. The Section 6721/6722 roundtable discussion will focus on penalties and examinations for failure to issue: (a) Forms W-2s & 1099s and when the failure to issue an information return results in the loss of the deduction or other tax benefit, (b) Forms 8300 and whether & when you can make a voluntary disclosure of failure to file Forms 8300 (i.e., is cannabis-related income “illegal income”), and (c) Forms 1042-S and litigation of penalties for failure to file and filing substantially incomplete Forms 1042-S. The panelists will also discuss related issues related to the litigation of these assessable penalties including when and whether the Flora rule applies and when the conduct resulting in these penalties will also lead to the assessment of the Trust Fund Recovery Penalty. Moderator: Phillip J. Colasanto, Agostino & Associates PC, Hackensack, NJ. Panelists: Scott E. Fink, Greenberg Traurig LLP, New York, NY; Mary E. Wood, Meadows Collier Reed Cousin Crouch & Ungerman LLP, Dallas, TX; Jonathan R. Black, Special Counsel, IRS Office of Chief Counsel, Washington, DC


Session : ABATX1964
Diversity I
Conference : 2019 May Meeting
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  • Chair: Lany L. Villalobos, Dechert LLP, Philadelphia, PA
  • Tax Crimes and Inequality. How does gender inequality arise in the context of offshore tax evasion? Does rising income inequality contribute to tax evasion? The panel will explore various manifestations of gender and income inequality that arise in the criminal enforcement of federal tax laws. The panelists will discuss the issue of gender inequality in offshore tax enforcement and how family law, criminal law, and tax law may work in tandem to resolve current issues in offshore tax enforcement when spouses become entangled in the civil and criminal tax issues of tax-evading spouses. The panelists will also discuss how income inequality undermines tax enforcement efforts. Moderator: DeAndré R. Morrow, Reed Smith LLP, Washington, DC. Panelists: Professor Khrista McCarden, Tulane University School of Law, New Orleans, LA; Elizabeth J. Atkinson, Whiteford Taylor Preston LLP, Baltimore, MD


Session : ABATX1966
Employment Taxes
Conference : 2019 May Meeting
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  • Chair: Edward J. Leyden, Leyden Law LLC, Washington, DC
  • RS Employment Tax Update. 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. Moderator: Edward J. Leyden, Leyden Law LLC, Washington, DC. Panelist: Janine Cook, Deputy Associate Chief Counsel, IRS Office of Chief Counsel (EEE), 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. Panelist: Chaya Kundra, Kundra & Associates PC, Washington, DC
  • Creative Use of Federal Tax Statutes as Enforcement Tools in Employment Controversies. An emerging strategy being utilized by counsel for workers in employment controversies is the invocation of the federal tax laws as an affirmative weapon against employers that have been targeted for Wage & Hour and similar claims. This session will discuss the plaintiffs’ bar evolving use of this and other tax enforcement strategies in non-tax cases. Moderator: Edward J. Leyden, Leyden Law LLC, Washington, DC. Panelist: Richard Neuworth, Lebeau & Neuworth, Towson, MD
  • Update on the Tax Consequences of Employment Settlements and Judgements. Resolving employment disputes has always been a prominent feature of the legal landscape. Furthermore, the IRS has recently issued guidance clarifying – for the better – the very significant changes the 2017 Tax Act has made regarding the deductibility of settlement amounts and attorneys’ fees (including new IRC § 162(q)). Panelist: Edward Leyden, Leyden Law LLC, Washington, DC


Session : ABATX1967
Employee Benefits
Conference : 2019 May Meeting
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  • Chair: Bret Hamlin, Hill Ward Henderson, Tampa, FL
  • Department of Labor, Employee Benefits Security Administration and Pension Benefit Guaranty Corporation Hot Topics. Representatives from the Department of Labor and Pension Benefit Guaranty Corporation will provide updates on the latest guidance and developments affecting employee plans. Moderator: Harold Ashner, Keightley & Ashner LLP, Washington, DC. Panelists: Preston Rutledge, Assistant Secretary of the Department of Labor, Employee Benefits Security Administration, Department of Labor, Washington, DC; Judith Starr, General Counsel, Pension Benefit Guaranty Corporation, Washington, DC
  • Department of the Treasury/Internal Revenue Service Hot Topics. Representatives from the Department of Treasury and the IRS will provide updates on the latest guidance and developments affecting employee plans. Moderator: Professor Kathryn J. Kennedy, The John Marshall Law School, Chicago, IL. Panelists: Kyle Brown, Division Counsel, Office of Chief Counsel, TEGEDC, IRS, Washington, DC; Victoria Judson, Associate Chief Counsel, Employee Benefits, Exempt Organizations, and Employment Taxes, Office of Chief Counsel, IRS, Washington, DC; Stephen Tackney, Deputy Associate Chief Counsel (Employee Benefits), Employee Benefits, Exempt Organizations, and Employment Taxes, Office of Chief Counsel, IRS, Washington, DC; Carol Weiser, Acting Benefits Tax Counsel, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC
  • Department of the Treasury/Internal Revenue Service Joint Committee on Employee Benefits Technical Sessions Overview. This panel will provide an overview of some of the issues presented to the Department of Treasury and the IRS during the Joint Committee on Employee Benefits technical session meeting on May 9, 2019. Moderator: Bret Hamlin, Hill Ward Henderson, Tampa, FL. Panelists: J. Rose Zaklad, Groom Law Group, Washington, DC; Brian Gallagher, Fraser Trebilcock, Lansing, MI; Stefan P. Smith, Locke Lord LLP, Dallas, TX; Elena Kaplan, Jones Day, Atlanta, GA; Rita Patel, DLA Piper LLP, 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.