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2018 Midyear 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.

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Showing sessions 21 - 30 of (43) TOTAL sessions
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Event : ABATX38


Session : ABATX1822
Employee Benefits I
Conference : 2018 Midyear Meeting
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  • Chair: Professor Kathryn J. Kennedy, The John Marshall Law School, Chicago, IL
  • Who’s Controlling our Plan Data? Cybersecurity is a key topic of growing concern for benefit plans, as evidenced by increased attention from the ERISA Advisory Council. This panel will discuss what benefit plan fiduciaries need to know about cybersecurity in order to protect the plan, protect plan participants, and satisfy their fiduciary duties. Topics will include prioritizing and protecting sensitive data, necessary safeguards for hiring vendors with access to participant data, legal developments to watch, litigation risks and lessons learned. Moderator: Erin M. Sweeney, Miller & Chevalier Chartered, Washington, DC Panelists: John C. Eustice, Miller & Chevalier Chartered, Washington, DC; Karen Prange, Lockton Retirement, Kansas City, MO; Pamela C. Williams, Anthem, Inc., Indianapolis, IN
  • Proposed Statement on Auditing Standards for Employee Benefit Plan Audits. In April 2017 the AICPA Auditing Standards Board released an Exposure Draft Proposed Statement on Auditing Standards entitled Forming an Opinion and Reporting on Financial Statements of Plans Subject to ERISA. This panel will review and discuss Exposure Draft Proposed Statement on Auditing Standards and its impact on employee benefit plan audits. Moderator: Bret Hamlin, Hill Ward Henderson, Tampa, FL Panelists: Anita Baker, CliftonLarsonAllen, Phoenix, AZ; Will Hansen, ERIC, Washington, DC; Howard B. Levy, Piercy Bowler Taylor & Kern, Las Vegas, NV
  • Department of the Treasury/Internal Revenue Service Hot Topics. Representatives from the Department of Treasury and IRS will provide updates on the latest guidance and developments affecting employee plans. Moderator: W. Waldan Lloyd, Durham Jones & Pinegar, Salt Lake City, UT Panelists: Kyle Brown, Division Counsel, Office of Associate Chief Counsel (TEGE), IRS, Washington, DC (Invited); Robert Neis, Benefits Tax Counsel, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC (Invited); Victoria Judson, Associate Chief Counsel, (Employee Benefits), Office of Associate Chief Counsel (TEGE), IRS, Washington, DC (Invited); Stephen Tackney, Deputy Associate Chief Counsel, (Employee Benefits), Office of Associate Chief Counsel (TEGE), IRS, Washington, DC (Invited)


Session : ABATX1823
Foreign Lawyers Forum
Conference : 2018 Midyear Meeting
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  • Chair: Saskia Bijl de Vroe, NautaDutilh, Amsterdam, Netherlands
  • BEPS Matters – Selected Country Updates. International corporate tax issues are central to the public debate all over the world, not least because of the G20-OECD Base Erosion and Profit Shifting project. Nearly 100 countries have implemented rules and regulations in response to the BEPS Action Plans, impacting the tax policies of an estimated 10,000 multinational enterprises. The Foreign Lawyers Forum is therefore proud to present an update on how the BEPS project is changing the tax landscape in selected jurisdictions. With a special focus on anti-base erosion rules and limitations on interest deductibility, our international panelists will discuss how BEPS-related tax policy is evolving in various regions, what new challenges and opportunities can be identified, how their US and international clients are responding and what lies ahead for multinational enterprises in the ever-changing world of international taxation. Moderator: Danielle Rolfes, KPMG LLP, Washington, DC Panelists: Willem Bongaerts, Bird & Bird LLP, The Hague, The Netherlands; Gerardo Nieto, Basham Ringe y Correa S.C., Mexico City, Mexico; Clint Harding, Arnold Bloch Leibler, Sydney, Australia; Mark O'Sullivan, Matheson, Palo Alto, CA; Eric Fort, Arendt & Medernach, New York, NY


Session : ABATX1824
S Corporations
Conference : 2018 Midyear Meeting
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  • Chair: Dana Lasley, Emerson Electric Company, St. Louis, MO
  • Important Developments in the Federal Income Taxation of S Corporations. The panelists will discuss tax reform and other recent legislative, administrative and judicial developments relating to S Corporations and their shareholders. Moderator: Bryan Keith, Grant Thornton LLP, Washington, DC Panelists: Laura E. Krebs Al-Shathir, Capes Sokol Goodman & Sarachan PC, St. Louis, MO; Gregory L. Lohmeyer, Quarles & Brady, Milwaukee, WI; David Kahen, Roberts & Holland LLP, New York, NY
  • Accumulated Adjustment Account, Distributions and Beyond. This panel discussion will describe the accumulated adjustment account and distribution rules and discuss a number of unusual accumulated adjustment account and distribution situations. Panelists: Laura Howell-Smith, Deloitte Tax, Washington, DC; Katie Bowles, Deloitte Tax, Costa Mesa, CA


Session : ABATX1825
Closely Held Businesses II
Conference : 2018 Midyear Meeting
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  • Chair: Shawn McIntire, Ballard Spahr LLP, Denver, CO
  • Employee Tax Audit Considerations. The panelists will discuss what issues can cause an employee tax audit to occur, defenses of the audit and resolutions to the audits when there is a liability. Moderator: Jonathan Kalinski, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA Panelists: Sabrina Strand, Law Offices of Joseph H. Thibodeau PC, Denver, CO; Robb Longman, Longman & Van Grack LLC, Bethesda, MD
  • Nuts and Bolts of Estate Audits. This panel will provide a practical guide to estate tax audits, including audit triggers, how to reduce the risk of an exam, and issues when dealing with the Service if the return is selected for audit. Moderator: Joshua Lowenthal, Plante Moran, Ann Arbor, MI Panelists: Lacey Strachan, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA; Jeffrey Gonya; Venable LLP; Baltimore, MD
  • Collection Issues Affecting Estates, Donors, and Donees. This panel will explore the special collection devices available to the IRS 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: Claudia Hill, TaxMam Inc., Cupertino, CA Panelists: Frank Agostino, Agostino & Associates PC, Hackensack, NJ; Robert E. McKenzie, Saul Ewing Arnstein & Lehr LLP, Chicago, IL; Wm. Robert Pope Jr., White & Reasor, Nashville, TN; Lawrence A. Sannicandro, McCarter & English LLP, Newark, NJ


Session : ABATX1826
Court Procedure & Practice
Conference : 2018 Midyear Meeting
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  • Chair: Joshua Odintz, Baker McKenzie, Washington, DC
  • Current Developments. This panel will include a report from the Tax Court, discussion of significant IRS guidance and litigation, an update on Tax Division priorities, a report from Treasury, and a discussion of significant pending litigation. Moderator: Allison De Tal, Baker & McKenzie LLP, Washington, DC Panelists: The Honorable L. Paige Marvel, US Tax Court, Washington, DC; Rochelle Hodes, Associate Tax Legislative Counsel, Department of Treasury, Washington, DC; Robert Wearing, Acting Deputy Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC; Deborah S. Meland, Chief, Civil Trial Section—Eastern Region, Tax Division, Department of Justice, Washington, DC
  • Navigating IRS Challenges to Micro Captive Insurers. Since the IRS issued Notice 2016-66 classifying certain micro captive insurance company uses as transactions of interest, many taxpayers have been awaiting guidance on how the courts might apply relevant laws and standards to their own captives. This panel will discuss the Tax Court’s recent decision in the Avrahami case, including what lessons can be drawn from, and identifying topics avoided by, the Tax Court’s ruling. The panel will also address recent developments regarding the Economic Substance Doctrine, including the ruling in Wells Fargo v. United States, which could prove relevant to the resolution of future micro captive tax controversies. Moderator: Richard D. Euliss, Carlton Fields Jorden Burt PA, Washington, DC Panelists: Robert J. Kovacev, Steptoe & Johnson LLP, Washington, DC; Deborah S. Meland, Chief, Civil Trial Section—Eastern Region, Tax Division, Department of Justice, Washington, DC
  • The Roundabout: Summons Enforcement, Privilege and Tax Court Discovery. The panel will discuss the evolving intersections between the summons power, attorney- client privilege and Tax Court discovery. The panelists will also cover recent trends and developments in IRS summons enforcement, including the decisions in U.S. v. Owensboro Dermatology Assoc. and U.S. v. Micro Cap KY Ins. Co. Moderator: Anson H. Asbury, Asbury Law Firm, Atlanta, GA Panelists: Rich Sapinski, Sills Cummins & Gross, Newark, NJ; Wendy Abkin, Morgan Lewis & Bockius, San Francisco, CA; Lu-Ann Dominguez, Gunster, Fort Lauderdale, FL; Deborah S. Meland, Chief, Civil Trial Section - Eastern Region, Tax Division, Department of Justice, Washington, DC
  • Litigating Tax Issues in Bankruptcy: Possibilities and Pitfalls. This panel will address both some of the opportunities and limitations practitioners encounter in resorting to the US Bankruptcy Court as a forum to resolve tax issues and reference some recent decisions of interest. Moderator: Gabrielle G. Hirz, Ropes & Gray LLP, Boston, MA Panelists: Najah Shariff, Assistant US Attorney, US Attorney’s Office for the Central District of California, Los Angeles, CA; Todd F. Maynes, Kirkland & Ellis LLP, Chicago, IL; A. Lavar Taylor, Law Offices of A. Lavar Taylor LLP, Los Angeles, CA


Session : ABATX1827
Financial Transactions
Conference : 2018 Midyear Meeting
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  • Chair: Michael B. Shulman, Shearman & Sterling LLP, New York, NY
  • Issues Involving Equity-Linked and Other Complex Debt. Using real world examples, this panel will discuss the issues faced by both borrowers and lenders with respect to complex debt instruments, including interest deductibility and withholding tax considerations. Moderator: Craig Gibian, Deloitte, Washington, DC Panelists: Eileen Marshall, Wilson Sonsini, Washington, DC; Michael Yaghmour, EY, Washington, DC
  • “Currency” in the Digital Age: Cryptocurrency, ICOs and the Future of Commerce. The panel will explore the tax consequences of the rapidly expanding marketplace of cryptocurrencies and initial coin offerings (“ICOs”). The panel will consider the treatment of these assets themselves from a tax perspective, the consequences to both issuers and holders, their impact on cross-border transactions and the implications of such transactions for our tax concepts of "nexus" and location/ jurisdictional based taxation. Moderator: Rebecca Lee, PwC, San Francisco, CA Panelists: Jim Brown, Ropes & Gray LLP, New York, NY; Lisa Zarlenga, Steptoe & Johnson, Washington, DC
  • Tax Reform and Implications for Financial Transactions. This panel will focus on various aspects of the 2017 Tax Act, including limits on interest deductibility, issues arising under the transition tax, BEAT and other implications for financial transactions. Moderator: Brian Krause, Skadden Arps, New York, NY Panelists: Matthew Stevens, EY, Washington, DC; Erika Nijenhuis, Cleary Gottlieb, New York, NY


Session : ABATX1828
Insurance Companies
Conference : 2018 Midyear Meeting
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  • Chair: M. Kristan Rizzolo, Sutherland Asbill & Brennan LLP, Washington, DC
  • Tax Reform: Impact of Insurance Specific Provisions. This panel will discuss the insurance specific provisions in the tax reform proposals/legislation and the implications of those provisions for property and casualty, life, and health insurance companies. Moderator: Ann Cammack, EY, Washington, DC Panelists: Pat Wageman, USAA, San Antonio, TX
  • Tax Reform: Impact of International Provisions on Insurance Companies. This panel will discuss the tax reform proposals/legislation related to international taxation and how this impacts insurance company taxpayers. Moderator: Clarissa Potter, KPMG, Washington, DC Panelists: Surjya Mitra, PwC, Washington, DC; Norm Hannawa, EY, Chicago, IL
  • Captive Insurance Companies after Avrahami: What Happens Next? The panel will discuss the Tax Court decision in the Avrahami decision and the implications for both large and small captive insurance companies. It also will provide an update on other captive developments. Moderator: Chaz Lavelle, Bingham Greenebaum Doll LLP, Louisville, KY Panelists: Rachel Partain, Caplin & Drysdale, New York, NY; Kacie Dillon, Woolston & Tarter, Phoenix, AZ


Session : ABATX1829
Real Estate
Conference : 2018 Midyear Meeting
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  • Chair: Robert Honigman, PwC, Washington, DC
  • Regulatory and Legislative Update. This panel will focus on recent legislative proposals affecting real estate and the Treasury Department’s response to Executive Order 13789 as they relate to real estate industry and technical issues, including the potential revocation of the Temporary Treasury Regulations under section 707 and section 337(d). Moderator: Mark Van Deusen, Deloitte Tax LLP, Richmond, VA Panelists: Audrey Ellis, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited); Tony M. Edwards, Nareit, Washington, DC
  • Preferred Equity Real Estate Investments. This panel will discuss the potential tax consequences that may arise when use of preferred equity is used in real estate investment structures. The discussion will focus on the ways that the economics of preferred equity may impact the tax consequences, and will address some planning ideas and pitfalls. The panel will also include a discussion on the implications for special investors such as REITs and tax-exempt entities. Moderator: Bahar A. Schippel, Snell & Wilmer, Phoenix, AZ Panelists: Todd D. Golub, EY, Chicago, IL; Cameron N. Cosby, Hogan Lovells, Washington, DC
  • Owning and Investing in California Real Estate. This panel will focus on issues pertaining to owning and investing in California real estate, including but not limited to, ownership-investment structures, property tax change-of-control rules, federal income tax conformity, and enforcement (including an update on recent developments including a new procedure for appeals effective January 18, 2018). Moderator: Christopher J. Matarese, Ajalat Polley Ayoob & Matarese, Glendale, CA Panelists: Reed Schreiter, PwC, Sacramento, CA; Ciro Immordino, Attorney, General Tax Bureau, Franchise Tax Board, Rancho Cordova, CA
  • Qualified Foreign Pension Fund REIT Investment Issues. Section 897(l), enacted as part of the PATH Act of 2015, excludes from FIRPTA any USRPI held by, or to any distribution received from a REIT by, a qualified foreign pension fund (a “QFPF”). This panel will explore various REIT investment structures and outstanding definitional issues involving QFPFs investing in real estate. Moderator: Ana G. O’Brien, Latham & Watkins, Los Angeles, CA Panelists: Nickolas Gianou, Skadden, Chicago, IL; Jason Smyczek, Senior Technician Reviewer, IRS Office of Associate Chief Counsel (International), Washington, DC; Jason Yen, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC


Session : ABATX1830
Tax Accounting
Conference : 2018 Midyear Meeting
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  • Chair: David Auclair, Grant Thornton LLP, Washington, DC
  • Current Developments. This panel will review recent developments in the area of tax accounting since the Section of Taxation meeting held in Austin, TX, in September. The panel will also discuss ongoing projects and anticipated guidance, with commentary and input from our guests from the Internal Revenue Service. Moderator: Rich Shevak, CohnReznick LLP, Washington, DC Panelists: Connie Cheng, BDO LLP, Los Angeles, CA; Scott Dinwiddie, Associate Chief Counsel Income Tax & Accounting, IRS, Washington, DC
  • Comparison of Revenue Recognition Methods Between ASC 606 and Section 451. As taxpayers prepare to adopt the new accounting standards for revenue recognition in ASC 606, one of the issues to be considered is the difference between these new standards and the revenue recognition methods for tax, such as section 451. The panel is will build on the revenue recognition panel held during the Tax Accounting Committee’s last meeting in Austin, TX, by continuing to discuss a comparison of revenue recognition methods between ASC 606 and section 451, including any additional guidance released for taxpayers implementing tax accounting method changes as a result of the new standard. Moderator: Jan Skelton, Deloitte LLP, New York, NY Panelists: Ryan Corcoran, RSM LLP, Madison, WI; Scott Dinwiddie, Associate Chief Counsel Income Tax & Accounting, IRS, Washington, DC; Peter Ford, Attorney, Branch 2, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC
  • Current Inventory Issues. This panel will discuss various, current issues affecting how taxpayers account for inventory. Topics will include updates on anticipated regulations under IRC §472 regarding dollar-value last-in, first-out (LIFO) inventories and final regulations amending Treas. Reg. §1.472-8 regarding the inventory price index computation (IPIC) method. Moderator: Mary Duffy, Andersen Tax LLC, Los Angeles, CA Panelists: Karen Rodriguez, Deloitte LLP, Chicago, IL; David Strong, Crowe Horwath LLP, Grand Rapids, MI; Christina Morrison, Senior Technician Reviewer, Branch 6, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC
  • Tax Reform. This panel will discuss areas of the recently enacted 2017 Tax Act that impact tax accounting, including important considerations that taxpayers should keep in mind when determining next steps. Moderator: Jane Rohrs, Deloitte LLP, Washington, DC Panelists: Jason Black, PwC, Washington, DC; Michael Resnick, Eversheds Sutherland LLP, Washington, DC; Scott Dinwiddie, Associate Chief Counsel Income Tax & Accounting, IRS, Washington, DC; John Moriarty, Deputy Associate Chief Counsel Income Tax & Accounting, IRS, Washington, DC; Christopher Call, Attorney- Advisor, Office of Tax Policy, Department of the Treasury, Washington, DC


Session : ABATX1831
Teaching Taxation
Conference : 2018 Midyear Meeting
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  • Chair: Professor Kerry Ryan, Saint Louis University, Saint Louis, MO
  • Evolving Constraints on Tax Administration. The IRS and Treasury Department have faced increasing budget and legal constraints over the past few years. Treasury is also experiencing limits on its rulemaking, both from the current Presidential Administration and from courts applying administrative law, such as with respect to the anti-inversion regulations. IRS budget constraints and workforce decreases started around 2011, and the IRS’s image has suffered following a 2013 report from the Treasury Inspector General for Tax Administration (TIGTA) on the IRS’s review of applications for determination of tax-exempt status. A 2017 TIGTA report revisited that issue in a balanced way, but where does it leave the IRS? This panel will look at how we got here, what it means, and what the ideal environment for tax administration looks like. The panelists will discuss the recent cases of Altera and Chamber of Commerce and assess how the IRS, taxpayers, and counsel should proceed given the ever-evolving constraints on tax administration. Moderator: Professor Philip Hackney, LSU Law Center, Baton Rouge, LA Panelists: James R. Gadwood, Miller & Chevalier Chartered, Washington, DC; Professor Kristin E. Hickman, Minnesota Law School, Minneapolis, MN; Professor Leandra Lederman, Indiana University Maurer School of Law, Bloomington, IN; Caroline Ciraolo, Kostelanetz & Fink LLP, Washington, DC Co-Sponsored by: Administrative Practice



     


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