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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 31 - 40 of (45) TOTAL sessions
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Event : ABATX35


Session : ABATX1734
Partnerships & LLCs
Conference : 2017 Midyear Meeting
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  • Chair: Martin D. Pollack, Weil Gotshal & Manges LLP, New York, NY
  • Cross Border Partnership Transactions. The panel will cover the partnership aspects of recent guidance under sections 956 and 385, focusing on the regulations’ approach to partnerships as aggregates and contrasting aggregate vs. entity theory in light of the tax policy underpinning those rules. Moderator: Kimberly S. Blanchard, Weil Gotshal & Manges LLP, New York, NY Panelists: Dina A. Weisen, Deloitte Tax LLP, New York, NY; Ari Berk, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Jason Smyczek, Senior Technician Reviewer, Branch 4, IRS Office of Chief Counsel, Washington, DC
  • New Partnership Regulations under Sections 707 and 752 (Part 2). New regulations substantially change the computations for disguised sales of property to partnerships and the allocation of partnership liabilities. This panel will discuss the technical rules and how they apply to partnership transactions. Part 1 of this panel will occur at the Real Estate Committee meeting. Moderator: Eric B. Sloan, Gibson, Dunn, & Crutcher LLP, New York, NY Panelists: Trevor R. Allen, Skadden Arps Slate Meagher & Flom LLP, New York, NY; Ossie Borosh, Senior Counsel, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Clifford M. Warren, Special Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), IRS Office of Chief Counsel, Washington, DC
  • Troubled Partnerships. This panel will discuss various workout and restructuring options. Moderator: James B. Sowell, KPMG LLP, Washington, DC Panelists: Mark E. Dundon, Weil Gotshal & Manges LLP, Dallas, TX; Glenn E. Dance, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries), Office of Chief Counsel, IRS, Washington, DC
  • Section 708 Technical Terminations. In an effort to ease the burden of federal tax compliance on small businesses, the Senate's Committee on Small Business and Entrepreneurship has proposed repealing the technical partnership termination provision in section 708(b)(1)(B). This panel will discuss the issues confronting partnerships with and without section 708(b)(1)(B). Moderator: Timothy J. Leska, Pepper Hamilton LLP, Philadelphia, PA Panelists: Daniel Carmody, PwC, Philadelphia, PA; Sarah K. Ritchey, Holland & Hart LLP, Denver, CO


Session : ABATX1735
Tax Exempt Financing
Conference : 2017 Midyear Meeting
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  • Chair: Stefano Taverna, McCall Parkhurst, Dallas, TX
  • Legislative, Treasury and Internal Revenue Service Update. This panel will discuss new legislative initiatives that may affect tax exempt financing, and any new Treasury and IRS regulations and other guidance in the tax exempt bond area, including anticipated new guidance relating to the issue price of tax-exempt bonds. Moderator: Ed Oswald, Orrick Herrington, Washington, DC Panelists: John Cross III, Attorney-Advisor, Tax Legislative Counsel, Washington, DC (Invited); George Friedlander, Municipal Strategist, New York, NY (Invited); Vicky Tsilas, Chief, Branch 5, Financial Institutions and Products, Office of Chief Counsel, IRS, Washington, DC (Invited); Michael Larsen, Parker Poe, Charleston, SC; Carol Lew, Stradling Yocca, Newport Beach, CA
  • Management Contracts – What is a Safe-harbor, that is the Question. This panel will discuss the application of the Notice 2016-44 relating to safe-harbor guidelines for management and service contracts, including anticipated additional guidance. Moderator: Todd L. Cooper, Locke Lord, Cincinnati, OH Panelists: Johanna Som de Cerff, Senior Technical Reviewer, Branch 5, Financial Institutions and Products, Office of Chief Counsel, IRS, Washington, DC (Invited); Michela Daliana, Hawkins Delafield, New York, NY; Matthias Edrich, Kutak Rock, Denver, CO; Patrick O'Daniel, Norton Rose, Austin, TX
  • Selected Tax Issues in Refundings - is it Lost? This panel will examine federal tax challenges associated with multi-purpose allocations, advance refunding limitations, refunding of build America bonds, including cross-over refunding issues, and qualified tax-exempt obligation status. Moderator: Chas Cardall, Orrick Herrington, San Francisco, CA Panelists: Mark Norell, Norton Rose, New York, NY; Darren McHugh, Stradling Yocca, Denver, CO; Stefano Taverna, McCall Parkhurst, Dallas, TX


Session : ABATX1736
Tax Collection, Bankruptcy and Workouts
Conference : 2017 Midyear Meeting
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  • Chair: Wm. Robert Pope, Jr., White & Reasor PLC, Nashville, TN
  • CDP Update: No Face-To-Face Conference. How do you make your record in the Administrative Hearing with Appeals? Lawyer as a witness? Really bad idea! Substitutes? Affidavits and recording of conferences? How do you get that record before the Tax Court? With AJAC and the new no “face-to-face” policy, what are the taxpayer’s options? Moderator: Christin Bucci, Bucci Law Offices, Ft. Lauderdale, FL
  • Defending the Absolutes: Litigation in the United States District Courts. The United States can bring two particularly draconian actions in District Court: Foreclosure of a tax lien; Reducing a Tax Liability to Judgment. How do you defend? Should you defend? What exposure remains and how does that process work? What are the consequences of either? Finally, on the other side, how does the taxpayer or a person on whom a levy has been served get before the court in a wrongful levy action? How does that process work? Are there any benefits that a taxpayer might want to explore? Should a taxpayer consider intervening? Moderator: Larry Sannicandro, Agostino & Associates, Hackensack, NJ Panelists: Moha P. Yepuri, Department of Justice, Tax Division, Dallas, TX; Eric Green, Green & Sklarz, New Haven, CT; Mitch Horowitz, Buchanan Ingersoll and Rooney, Tampa, FL
  • Quiet Title Actions: The Sword - Not a Shield! Quiet title actions represent the taxpayer's opportunity to initiate litigation in the United States District Court to dispute a liability or a lien. Our Panel reviews how to go about preparing your complaint and what to expect in the nature of counterclaims. Finally, the Panel will also consider how to file a quiet title action for someone who has been named an alter ego or nominee in a notice of federal tax lien filed by the Service. Currently, the quiet title action represents the only means, other than a bankruptcy, by which a person can get relief from the alter ego or nominee classification. Moderator: Bob Pope, White & Reasor, Nashville, TN Panelists: Bob McKenzie, Arnstein & Lehr LLP, Chicago, IL; Frank Agostino, Agostino & Associates, Hackensack, NJ;


Session : ABATX1737
Diversity 2
Conference : 2017 Midyear Meeting
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  • Chair: Jairo Cano, Agostino & Associates PC, Hackensack, NJ
  • Cultural Issues Affecting Family Business Succession Planning. This panel will focus on how cultural differences can affect estate planning decisions with particular emphasis on transfers of closely-held business interests. Smooth transfer of a family enterprise from one generation, often the generation that created the business, to a younger generation is a notoriously difficult estate-planning task. It is challenging enough when the lawyer, the family members, and other stakeholders all share similar social and economic values and goals. When the different players see the issues through different cultural or religious lenses, the process can be daunting. Do you know which clients find questions about their property distributions after death to be offensive? Which clients withhold relevant information about their family members based upon cultural norms? Are you familiar with religious laws that may conflict with state probate statutes? Do you know how different cultures perceive and handle the physical and mental decline that can accompany increasing age? The panelists will discuss these questions and the ways in which diverse clients may view important aspects of estate planning. Moderator: Professor Amy Morris Hess, University of Tennessee College of Law, Knoxville, TN Panelists: Chasity Sharp Grice, Poppel Gomes & McIntosh, Memphis, TN; Nikki J. Hasselbarth, Venable LLP, Baltimore, MD; Professor Michelle Kwon, University of Tennessee College of Law, Knoxville, TN
  • The New Markets Tax Credit: Providing Economic Stimulus to Low-Income Communities. Section 45D of the Internal Revenue Code authorizes the issuance of the New Markets Tax Credit. The law provides a credit of 39% of the capital invested in certain “qualified community development entities” whose primary missions include serving, or providing investment capital to low-income communities or low-income individuals. This panel will discuss the structure of investments in qualified community development entities, the requirements to qualify for the new markets tax credit, the economics associated with this program, and the tax issues encountered when the credit is claimed. Moderator: Alfred Bae, EY, Houston, TX Panelists: Kristin DeKuiper, Holland & Knight LLP, Boston, MA; James Holmes, IRS Office of Chief Counsel, Washington, DC; Christin Petroski, Holland & Knight LLP, Orlando, FL; Julie Treppa, Coblentz Patch Duffy & Bass, San Francisco, CA


Session : ABATX1738
Young Lawyers Forum
Conference : 2017 Midyear Meeting
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  • Chair: Shawn L. McIntire, Ballard Spahr LLP, Denver, CO
  • Nuts and Bolts of Criminal Tax. (Young Lawyers) The panel will focus on general information every practitioner should know when your client is the subject of a criminal tax investigation. The panelists will discuss strategies and techniques for handling criminal investigations and defending a criminal prosecution, including Department of Justice taxpayer conferences, gathering defense evidence, discovery, motions practice, trial strategies, plea negotiations, and sentencing strategies. Moderator: Joshua Lowenthal, Washington University in St. Louis School of Law, St. Louis, MO Panelists: Jay Nanavati, Baker Hostetler, Washington, DC; Matthew Chaves, Marcus Neiman & Rashbaum LLP, Ft. Lauderdale, FL


Session : ABATX1739
Tax Practice Management
Conference : 2017 Midyear Meeting
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  • Chair: Jeffrey K. Gonya, Venable LLP, Baltimore, MD
  • Legal Lean Six Sigma for Law Firms. Lean Six Sigma is a combination of process improvement techniques and tools applied to the practice of law. Lean Processing improves the speed and lowers the cost of business processes while Six Sigma improves the quality of the output. Combined, the Lean Six Sigma approach is well suited to help attorneys reduce errors while controlling costs by designing and implementing sound processes. Join our panel of experts as they discuss real world applications of the Lean Six Sigma model to the legal services industry. Moderator: Roger Royse, Royse Law Firm, Silicon Valley, CA Panelist: Sandra J. Wunderlich, Stinson Leonard Street LLP, St. Louis, MO


Session : ABATX1740
Fiduciary Income Tax
Conference : 2017 Midyear Meeting
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  • Chair: David A. Berek, Horwood Marcus & Berk Chartered, Chicago, IL
  • Current Developments. Jeff Gonya will review current developments in fiduciary income tax, and Cathy Hughes will update the committee on developments with the Treasury and the Service. Panelists: Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC; Jeffrey K. Gonya, Venable LLP, Baltimore, MD
  • International Spotlight: The Common Reporting Standard and FATCA As Applied to Private Clients – What Every Planner Should Know. This panel will discuss the automatic exchange of information for trusts and other entities under the Common Reporting Standard (CRS), and provide an update on FATCA transparency initiatives as they are progressing worldwide. The focus of this session is on understanding the automatic exchange rules for private client planning. This session will look at steps families and financial institutions can take to prepare for automatic exchange, what it means, and how it works. Panelists: Kathleen Agbayani, Baker & McKenzie LLP, Washington, DC; Ceci Hassan, Baker & McKenzie LLP, Miami, FL
  • The ABCs of QSBS: The Benefits, Requirements and Planning Opportunities with Qualified Small Business Stock. The rules applicable to Qualified Small Business Stock ("QSBS") can offer many tax advantages to investors. However, planners and clients often are unaware of the existence and benefits of QSBS. This panel will provide an overview of the QSBS rules and explore the myriad of planning opportunities available. Panelists: Benetta Jenson, JP Morgan Private Bank, Chicago, IL; Stuart J. Kohn, Pearlstein LLC, Northbrook, IL
  • The New Paradigm of Estate Planning: Fiduciary Income Taxation and Grantor Trusts. The new paradigm of estate planning highlights income tax and basis planning. This program will address the prevalence of grantor trusts in estate planning, the outlook under the new administration, fiduciary accounting income and taxation of grantor and non-grantor trusts, as well as state income tax planning considerations. Panelist: Steven M. Breitstone, Meltzer Lippe Goldstein & Breitsone, Mineola, NY; Mark Wilensky, Meltzer Lippe Goldstein & Breitsone, Mineola, NY


Session : ABATX1741
Employee Benefits (Saturday)
Conference : 2017 Midyear Meeting
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  • Chair: W. Waldan Lloyd, Durham Jones & Pinegar, Salt Lake City, UT
  • Updates on Guidance and Litigation Involving Health Coverage
  • Retirement Plan Correction Issues
  • Implementation Issues Involved with the DOL Fiduciary Regulations and Related Prohibited Transactions. As plan sponsors, record keepers, and brokerage houses gear up for the April effective date of the new DOL fiduciary regulations and related prohibited transactions, the panel will discuss the implementation issues facing these three players. Moderator: Professor Kathryn J. Kennedy, The John Marshall Law School, Chicago, IL Panelist: Sam Henson, Lockton Retirement services, Kansas City, MO; David Levine, Groom Law Group Chartered, Washington, DC; Erin M. Sweeney, Miller & Chevalier Chartered, Washington, DC


Session : ABATX1742
Sales, Exchanges & Basis
Conference : 2017 Midyear Meeting
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  • Chair: Alan S. Lederman, Gunster, Fort Lauderdale, FL
  • Current Developments in Sales, Exchanges & Basis. (Young Lawyers) Panelists review recent case law and guidance on traditional sale, exchange, and basis issues, and section 1031 developments. Panelist: David Shechtman, Drinker Biddle & Reath LLP, Philadelphia, PA; E. John Wagner II, Williams Parker Harrison Dietz & Getzen, Sarasota, FL
  • Can Replacement Property be Temporarily Parked Beyond the Rev. Proc. 2000-37 Safe Harbor? In Bartell, 147 T.C. No. 5 (2016), the Tax Court approved a reverse section 1031 exchange involving the purchase and improvement of replacement property by an affiliate of a section 1031 exchange company before transfer to the taxpayer 17 months after its initial acquisition. Panelists will discuss the implications of Bartell for parking arrangements in reverse section 1031 exchanges that do not satisfy the requirements under the IRS safe harbor procedure described in Revenue Procedure 2000-37. Moderator: Mark E. Wilensky, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY Panelists: John M. Colvin, Colvin + Hallett, Seattle, WA; Adam Handler, PwC, Los Angeles, CA; Howard J. Levine, Roberts & Holland, Washington, DC
  • "It’s My Income Interest Money and I Want It All Now!" The panelists will review the typical nontax and tax motivations that have led many donors, as part of their income tax and estate planning, to establish a charitable remainder unitrust with a net income make-up provision (NIMCRUT) or without such make-up provision (NICRUT). They will then consider the implications if the non-charitable income beneficiary and the charitable remainder beneficiary of a NIMCRUT or NICRUT subsequently decide to terminate the NIMCRUT or NICRUT early and each take their respective shares of the trust’s value. The income tax authorities concerning such issues as whether the amount received by the non-charitable beneficiary on an early termination is treated as a long-term capital gain, and whether that beneficiary’s interest has zero basis will be covered. The panelists will then review issues which have arisen as to whether, using the section 664(e) method enacted in 2015 to calculate the value of the non-charitable NIMCRUT beneficiary’s terminated income interest, an act of self-dealing will have occurred, and whether state law concerns may necessitate reducing the amount paid to the non-charitable income beneficiary below section 664(e)’s calculation of its value. Moderator: Stephen M. Breitstone, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY Panelists: Professor Jerome M. Hesch, Miami, FL; Seth Kaplan, Gunster, Boca Raton, FL
  • Current Section 336(e) Issues for Partnerships Buying Corporations. A partnership, such as a private equity fund, buying the business of a target that is a consolidated subsidiary of a C corporation or that is an S corporation, may wish to buy the stock of the target, rather than buying the target’s assets, in order to avoid state law consent and other problems created by asset-by-asset transfers. That partnership (partnerships being ineligible to make a section 338(h)(10) election) may then use section 336(e) to obtain a step-up in basis for the target corporation’s assets. Then, in order to avoid future corporate level income tax on future earnings of the acquired target corporation, the partnership may undertake a tax liquidation of the target corporation into a single-member LLC through a state law conversion statute. The panel will discuss some problem areas under this scenario of a section 336(e) purchase plus tax liquidation of the target. Certain structures outside of section 336(e) that might produce comparable state law and tax results will also be reviewed. Moderator: Rafi W. Motttahedeh, Jenner & Block LLP, Chicago, IL Panelists: Scott J. Bakal, Neal Gerber & Eisenberg LLP, Chicago, IL; Donald Bakke, EY, Washington, DC; Mark Weiss, Chief, Branch 2, IRS Office of Associate Chief Counsel (Corporate), Washington, DC


Session : ABATX1743
Pro Bono & Tax Clinics
Conference : 2017 Midyear Meeting
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  • Chair: Christine Speidel, Vermont Legal Aid, Springfield, VT
  • National Taxpayer Advocate’s Annual Report to Congress. Nina Olson will address the committee by video regarding the National Taxpayer Advocate’s annual report to Congress and highlight the most important features of the report. Ms. Olson’s Senior Attorney Advisor will then discuss Private Debt Collection and other Most Serious Problems identified in the report. Panelist: Kenneth J. Drexler, Senior Attorney Advisor to the National Taxpayer Advocate, IRS, Washington, DC Co-sponsored by: Individual & Family Taxation
  • Low Income Taxpayer Representation: Past, Present and Future. This panel celebrates the leadership of Bill Nelson and the development of the Low-Income Taxpayer Clinic program under his tenure. Panelists will also examine the relatively recent introduction of tax advocacy to traditional legal services programs, and the importance of tax in the poverty lawyer’s toolkit. Moderator: Susan Morgenstern, Taxpayer Advocate Service, Cleveland, OH Panelists: William P. Nelson, New York, NY; Professor T. Keith Fogg, WilmerHale Legal Services Center of Harvard Law School, Jamaica Plain, MA Co-sponsored by: Individual & Family Taxation
  • Pro Bono at US Tax Court Calendar Call: Celebrating 25 Years. The first pro bono program to provide assistance at US Tax Court calendar calls began 25 years ago. Today, pro bono assistance is available to pro se taxpayers at every calendar call nationwide. This panel will examine how the programs developed and overcame hurdles, as well as current issues that the Court and the Service are grappling with as they accommodate pro se litigants. Moderator: The Honorable L. Paige Marvel, Chief Judge, US Tax Court, Washington, DC Panelists: Karen L. Hawkins, Yachats, OR; Bruce K. Meneely, Division Counsel (Small Business/Self-Employed Division), IRS Office of Chief Counsel, Washington, DC; The Honorable Peter J. Panuthos, Chief Special Trial Judge, US Tax Court, Washington, DC; Elizabeth Copeland, Strasburger & Price, San Antonio, TX Co-sponsored by: Individual & Family Taxation
  • Disaster Tax Issues. Millions of Americans are affected by disasters each year. This panel will present common tax law issues faced by disaster victims and resources for helping them. Moderator: Austin D. Thacker, Holland & Knight, Orlando, FL Panelists: Paul Tuttle, Southeast Louisiana Legal Services, New Orleans, LA; Mandi L. Matlock, Texas RioGrande Legal Aid, Austin, TX; Andrew VanSingel, Prairie State Legal Services Inc., Chicago, IL; Martiza Rabinovitz, Senior Stakeholder Liaison, IRS SBSE (Communications and Stakeholder Outreach), Orlando, FL Co-sponsored by: Individual & Family Taxation



     


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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.