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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 11 - 20 of (45) TOTAL sessions
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Event : ABATX35


Session : ABATX1711
Estate & Gift Taxes
Conference : 2017 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 September 2016. Panelists: Brian P. Tsu, Henderson Caverly Pum & Charney LLP, San Diego, CA; Helen E. Rogers, Holland & Hart, Denver, CO; Megan M. Curran, Jones Walker LLP, New Orleans, LA; Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC
  • Pay Early, Pay Less: Maximizing TPT Credit Availability for Married Couples. This presentation explores the estate tax credit for tax on prior transfers and explains how, with careful drafting, the credit may be optimally utilized to produce estate tax savings in the estates of married couples who die within 10 years of each other. Panelists: Michael Rosenblum, Proskauer Rose LLP, Boca Raton, FL; David Pratt, Proskauer Rose LLP, Boca Raton, FL
  • Should I Stay or Should I Go? Considerations When Switching Domicile to Florida. Domicile is seldom the on/off switch people think of - it is often messy and leads to confusion, and that there are a lot of considerations to cover before making the decision to switch the domicile to Florida. Panelists: Patrick J. Lannon, Bilzin Sumberg, Miami, FL
  • The Separate Share Rule in Operation. The separate share rule of section 663(c) of the Internal Revenue Code requires that the separate and independent shares of different beneficiaries in the same estate or trust be treated as separate shares or trusts in determining the distributable net income (DNI) allocable to the respective beneficiaries. This presentation discusses how to apply the separate share rule in practice and navigate common issues. Panelist: Birch Douglass, McGuire Woods, Richmond, VA


Session : ABATX1712
Investment Management
Conference : 2017 Midyear Meeting
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  • Chair: Amy B. Snyder, The Vanguard Group Inc., Malvern, PA
  • Current Regulatory Initiatives Impacting Regulated Investment Companies (RICs). This panel will discuss recent IRS guidance and other topics of current interest to RICs, including the IRS’s proposed regulations on RIC’s investments in controlled foreign corporations and PFICs, the IRS notice regarding commodity index-linked structured notes, foreign tax credit offset guidance, and outlook for 2017 tax legislation. Moderator: Joseph Riley, Willkie Farr & Gallagher LLP, New York, NY Panelists: Karen Lau Gibian, Investment Company Institute, Washington, DC; Helen Hubbard, IRS Office of Associate Chief Counsel (Financial Institutions & Products), Washington, DC; Kenneth Kess, Deloitte Tax LLP, Boston, MA
  • The New Section 707 and 752 Regulations and Private Equity Funds. New regulations substantially change the disguised sales rules and the allocation of partnership liabilities. This panel will discuss the technical rules and how they apply to private equity transactions. Moderator: Eric Sloan, Gibson Dunn & Crutcher LLP, New York, NY Panelists: Trevor Allen, Skadden Arps Slate Meagher & Flom LLP, New York, NY; Daniel Carmody, PwC, Philadelphia, PA; Clifford Warren, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries), IRS Office of Chief Counsel, Washington, DC
  • The New Section 385 Regulations and Private Funds. This panel will explore the impact of the new Section 385 regulations on investments by private funds. Moderator: Raj Tanden, Foley & Lardner LLP, Los Angeles, CA Panelists: Kevin M. Jacobs, Senior Technician Reviewer, Branch 4, IRS Office of Chief Counsel (Corporations), Washington, DC; Gregory Kidder, Steptoe & Johnson LLP, Washington, DC


Session : ABATX1713
Exempt Organizations
Conference : 2017 Midyear Meeting
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$75.00


  • Chair: David A. Shevlin, Simpson Thacher & Bartlett LLP, New York, NY
  • Committee Business
  • News from the IRS and Treasury. Representatives from the IRS and Treasury Department will discuss topics of current interest to exempt organizations practitioners. Moderator: Rosemary E. Fei, Adler & Colvin, San Francisco, CA Panelists: Janine Cook, Deputy Associate Chief Counsel, IRS Office of Associate Chief Counsel (TEGE), Washington, DC (Invited); Victoria A. Judson, Associate Chief Counsel, IRS Office of Associate Chief Counsel (TEGE), Washington, DC (Invited); Elinor C. Ramey, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited)
  • State of Play: Supporting Organizations. The Pension Protection Act of 2006 swept in significant changes for supporting organizations. With the Treasury Regulations promulgated as a result of those changes now largely adopted, this panel will examine the role supporting organizations now and are expected to play in the exempt organizations sector, and what issues the Regulations leave open. Moderator: Richard L. Sevcik, Perkins Coie LLP, Chicago, IL Panelists: Preston Quesenberry, Loeb & Loeb LLP, Washington, DC; Carolyn O. Ward, Ropes & Gray LLP, Washington, DC
  • US Filing Obligations of Foreign Charities and the Implications for US Funders. This panel will address the US filing obligations of foreign organizations and the implications for US funders making equivalency determinations and for US counsel opinion for purposes of reduced withholding taxes. Moderator: David A. Shevlin, Simpson Thacher & Bartlett LLP, New York, NY Panelists: Kimberly S. Blanchard, Weil Gotshal & Manges LLP, New York, NY; Dahlia B. Doumar, Patterson Belknap Webb & Tyler LLP, New York, NY
  • State of Play: Compensation and Intermediate Sanctions. Practitioners will discuss their approach to current and unusual compensation issues, including application and interpretation of the intermediate sanctions provision of section 4958 and compliance with the "rebuttable presumption of reasonableness." Moderator: Suzanne Ross McDowell, Steptoe & Johnson LLP, Washington, DC Panelist: A.L. (Lorry) Spitzer, Ropes & Gray, Boston, MA; Brian H. Vogel, Quatt Associates, Washington, DC; Robert A. Wexler, Adler & Colvin, San Francisco, CA
  • Thorny Issues for Private Foundations. This panel will cover a range of common complex issues faced by private foundations. In particular, the panel will discuss expenditure responsibility for capital expenditures, equivalency determinations for foreign schools, foreign withholding tax matters, the self-dealing exception for personal services and considerations in the disposal of excess business holdings. Moderator: Michael E. Durham, Kirton McConkie PC, Salt Lake City, UT Panelists: Natasha Cavanaugh, Bill & Melinda Gates Foundation, Seattle, WA; Jennifer I. Reynoso, Simpson Thacher & Bartlett LLP, New York, NY


Session : ABATX1714
Teaching Taxation and State & Local Taxes
Conference : 2017 Midyear Meeting
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  • Teaching Taxation Chair: Professor Anthony Infanti, University of Pittsburgh, Pittsburgh, PA State & Local Taxes: Jaye A. Calhoun, McGlinchey Stafford, New Orleans, LA
  • Taxation of the Sharing Economy: Major Issues and Trends. The sharing economy, fueled by start-ups such as Uber and Airbnb, has grown dramatically in the past few years. As a result, the tax issues presented by this new model of production and consumption of goods and services have become significant at the federal, state and local tax level. This panel will examine the fundamental challenges that the sharing economy poses to existing legal regimes for determining worker classification, application of traditional business expense reporting, sales tax, and occupancy and related tourism taxes. Additionally, the panel will consider how litigation, settlements, and tax agreements involving sharing economy businesses will impact the tax analysis. Moderator: Professor Darryll K. Jones, Florida A & M University College of Law, Orlando, FL Panelists: Professor Shu-Yi Oei, Tulane Law School, New Orleans, LA; Kelley Miller, ReedSmith, Washington, DC; David Cowart, Dentons, Dallas, TX; Mark Holcombe, Madsen Goldman & Holcomb LLP, Tallahassee, FL;


Session : ABATX1715
Tax Policy & Simplification
Conference : 2017 Midyear Meeting
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  • Chair: Eric San Juan, Georgetown University Law Center, Washington, DC
  • Parameters for Tax Reform in the New Year. This panel will be introduced by a special presentation of recent developments by the Young Lawyers Forum (YLF) focusing on tax reform proposals in the House of Representatives and Senate Finance Committee. Then panelists with experience in government, academia, and private practice will comment on potential tax policy approaches by the new Congress and Administration. Moderator: Professor Charlene Luke, University of Florida Levin College of Law, Gainesville, FL Panelists: Morgan Klinzing, Pepper Hamilton, Philadelphia, PA; Professor Michael Graetz, Columbia Law School, New York, NY (Invited); Gregory F. Jenner, Stoel Rives, Washington, DC; Eileen J. O’Connor, Law Office of Eileen J. O’Connor, Washington, DC (Invited) Co-Sponsored by: Young Lawyers Forum


Session : ABATX1716
Transfer Pricing
Conference : 2017 Midyear Meeting
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  • Chair: A. Tracy Gomes, McDermott Will & Emery, Dallas, TX
  • From Technology to Taxation: The Interaction Between Intellectual Property Law and Transfer Pricing Rules Applicable to Intangibles Transfers Between Controlled Parties. This joint panel is co-sponsored by the Transfer Pricing Committee of the ABA Section on Taxation and the Intellectual Property Transactions & Licensing Committee of the ABA Section of Intellectual Property Law. Experienced practitioners from both fields will review hypothetical intellectual property transactions to highlight distinctions between IRC Section 482, the OECD Transfer Pricing Guidelines and substantive intellectual property law concepts. The panel will explore recent and pending changes to Chapter VI of the OECD Transfer Pricing Guidelines, resulting from the Base Erosion and Profit Shifting (BEPS) initiative. It will also consider the potential use of intellectual property holding companies, cost sharing arrangements, Advance Pricing Agreements, and other means of reducing or managing tax uncertainty in a rapidly-evolving area. Panelists: Paul Dau, McDermott Will & Emery, Palo Alto, CA; Weston Anson, CONSOR Intellectual Property Management, La Jolla, CA; Richard Lilley, PwC, Washington, DC; Steven Rubin, Morritt Hock & Hamroff, New York, NY Co-Sponsored by: ABA Section of Intellectual Property Law
  • Transfer Pricing Issues in Latin America. This session will discuss issues relevant to companies operating in Latin America. Panelists will provide comments, suggestions and insights, based on their practical experience and professional perspectives. Examples of topics include: managing and adjusting for country risk premiums; identification of comparable data; tangible good considerations with respect to imports; managing Brazilian transfer pricing rules from a US perspective; currency valuation issues; and the impact on BEPS in both OECD and non-OECD Latin American countries. Moderator: Katherine Pinzon, EY, Brazil Panelists: M. Annette Glod, Regional Tax Counsel, Shell Oil Company, Houston, TX; Luciana Peres, Votorantim Metais, Brazil; Cecilia Torres, Belcorp Group, Peru


Session : ABATX1717
US Activities of Foreigners & Tax Treaties
Conference : 2017 Midyear Meeting
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  • Chair: Jason S. Bazar, Mayer Brown LLP, New York, NY
  • Current Developments in Information Reporting. This panel will discuss recent developments in US and non-US information reporting practices. Topics to be discussed include: CbC reporting, understanding who is subject to FATCA, IGAs and CRS reporting and what data will be exchanged, changes to foreign-owned DRE reporting, and the implications of forthcoming changes to US customer due diligence rules. Moderator: Jonathan A. Sambur, Mayer Brown LLP, Washington, DC Panelists: Rafic H. Barrage, Baker & McKenzie, Washington, DC; Thierry Boitelle, Bonnard Lawson, Geneva, Switzerland; Michael H. Plowigan, KPMG, Washington, DC; Mae Lew, Special Counsel, IRS Office of Chief Counsel, Washington, DC; Julia Tonkovich, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC
  • Planning Under the Section 385 Regulations. The final section 385 regulations have added a new dimension to planning for inbound financing. This panel will discuss the opportunities and the traps, as well as procedures to chart the course. Moderator: Peter H. Blessing, KPMG, New York, NY Panelists: Sarah Berman, Macquarie Holdings, New York, NY; Janine Burman-Gage, EY, Chicago, IL; Jeffrey Rubinger, Bilzin Sumberg, Miami, FL; Raymond Stahl, Special Counsel, IRS Office of Chief Counsel, Washington, DC; Gary Scanlon, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC


Session : ABATX1718
Court Procedure & Practice Roundtable Discussion
Conference : 2017 Midyear Meeting
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  • Chair: Juan F. Vasquez, Jr., Chamberlain Hrdlicka White Williams & Aughtry, Houston, TX
  • Horse of a Different Color. More than half of newly-filed Tax Court cases are collection (CDP) cases, but very few law schools teach how they are litigated. This panel will discuss what you can expect when litigating these cases--routine and unusual motions, disputes about the administrative record, and how to make your case for or against relief. The panel will also touch on the upcoming private debt collection agencies and processes. Moderator: Elizabeth K. Blickley, Washington, DC Panelists: The Honorable Juan F. Vasquez, US Tax Court, Washington, DC; Mark Tober, SB/SE Associate Area Counsel, IRS, Jacksonville, FL; Larry Sannicandro, Agostino & Associates, Hackensack, NJ


Session : ABATX1719
State & Local Taxes Luncheon
Conference : 2017 Midyear Meeting
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  • Chair: Jaye Calhoun, McGlinchey Stafford PLLC, New Orleans, LA
  • Will 2017 Usher in Sweeping Federal Tax Reform Legislation? What Are the State Tax Implications? The election of Donald Trump combined with Republican control of Congress is likely to result in transformative federal tax reform with far reaching consequences for both international and state taxation. Among the federal tax law changes under serious consideration are: reducing the corporate income tax rate by almost 50 percent; full and immediate expensing of all capital investments; disallowing any interest deduction on new loans; eliminating 199 and all business credits; border adjusting business taxes to exclude income relating to exports and deny deductions for the costs of imports. This panel will discuss the prospects for federal tax reform and its sweeping implications for state taxation. In particular, the panel will discuss which federal tax law changes will flow through automatically to the states, require proactive enactment, or have no impact at all? The panel will also discuss whether the section 385 regulations will survive the new regime or be revoked? Finally, the panel will explore the potential for a vastly different state corporate tax law environment within 12 months of the Trump Presidency. Moderator: John A. Biek, Neal Gerber & Eisenberg LLP, Chicago, IL Panelists: John P. Barrie, Bryan Cave LLP, New York, NY; Karl Frieden, COST, Washington, DC; Jordan Goodman, Horwood Marcus & Berk Chartered, Chicago, IL


Session : ABATX1720
Diversity 1
Conference : 2017 Midyear Meeting
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  • Chair: Jairo Cano, Agostino & Associates PC, Hackensack, NJ
  • Sections 139E and 139F: Putting the E and F in Tax Relief for Indian Tribal Members and Exonerees. Two recently enacted tax provisions, sections 139E and 139F, provide tax relief to Indian tribal members and wrongfully incarcerated individuals. The Tribal General Welfare Exclusion Act of 2014 created section 139E in the Code, which provides that the value of any qualified Indian general welfare benefit is excluded from gross income if certain requirements are met. The panel will discuss the requirements to qualify for the general welfare exclusion provision and the challenges of reconciling the requirements with varying tribal cultural practices. Section 139F, enacted into law by The Protecting Americans From Tax Hikes Act of 2015, exempts from gross income compensation received for wrongful imprisonment. The panel will explore the tax benefits available under section 139F to victims of wrongful incarceration, the frequently asked questions arising from the provision, and recent advocacy efforts to reach exonerees. Moderator: Laura LaPrade, Community Tax Aid Inc., Washington, DC Panelists: Daniel Knudsen, Oklahoma Indian Legal Services, Oklahoma City, OK; Kelly C. Miller, Reed Smith LLP, Washington, DC; Amy Pfalzgraf, IRS Office of Chief Counsel, 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.