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Showing sessions 31 - 40 of (43) TOTAL sessions
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Event : ABATX38


Session : ABATX1832
Diversity II
Conference : 2018 Midyear Meeting
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$30.00


  • Chair: Jairo Cano, E-Trade Financial, Jersey City, NJ
  • To the Shores of Tripoli: A Military Tax Overview. This panel will examine common and uncommon tax issues facing service members domestically and abroad. The panelists will discuss tax resources and avenues for assisting military families. The panel will include ways to get involved in supporting the military as a tax attorney, including the Adopt-A-Base Program. Moderator: Anson Asbury, Asbury Law Firm, Decatur, GA Panelist: Kathleen Agbayani, Baker McKenzie, Washington, DC; C. Wells Hall III, Nelson Mullins, Charlotte, NC; Elizabeth Stevens, Caplin & Drysdale, Washington, DC
  • Estate Planning, Medical Expense Deductions, and Other Tax Considerations for LGBTQ+ Individuals and Families. This panel will discuss selected tax issues that significantly affect LGBTQ+ individuals and families, including the following: (1) estate planning strategies and techniques, including the recent IRS Notice 2017-15 and considerations for marriage v. domestic partnership; (2) medical expense deductions for in-vitro fertilization procedures, which will include a discussion of the recent 11th Circuit case Morrissey v. Commissioner and other related cases, and gender reassignment surgery in light of the Tax Court’s Opinion in O’Donnabhain v. Commissioner; and (3) effects of tax reform on these and other related issues. Moderator: Brandon King, Law Clerk for the Honorable Albert G. Lauber, US Tax Court, Washington, DC Panelists: Professor Katherine Pratt, Loyola Law School, Los Angeles, CA; Professor Patricia Cain, Santa Clara University School of Law, Santa Clara, CA; Danielle Barger, Goode Hemme & Peterson, San Diego, CA; John Moriarty, Deputy Associate Chief Counsel, Associate Chief Counsel (Income Tax & Accounting), IRS Office of Chief Counsel, Washington, DC (Invited)


Session : ABATX1833
Tax Collection, Bankruptcy, and Workouts
Conference : 2018 Midyear Meeting
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$30.00


  • Chair: Christin Bucci, Bucci Law Offices, Fort Lauderdale, FL
  • How to Read IRS Transcripts and Navigate Statutes of Limitations. The panelists will offer practical tips and strategies to review and understand the full range of available IRS transcripts; compute statutes of limitation on assessment, collection, and transferee liability; and avoid procedural pitfalls when dealing with the IRS in collection and bankruptcy matters. Moderator: Giovanni Alberotanza, Rosenberg Martin Greenberg LLP, Baltimore, MD Panelists: Russel J. Haynes, Burton J. Haynes PC, Burke, VA; Josh Wu, Strasburger & Price LLP, Washington DC
  • Recent Developments. The panelists will review recent events affecting how you interact with the IRS and courts in collection matters. Topics to be covered include: updates on the IRS’s "Future State" initiative; passport revocation; private debt collection; challenging international form penalties in CDP proceedings; how to use the recently codified Taxpayer Bill of Rights in collection matters; and significant court decisions during the past six months. Moderator: Jeffrey Dirmann, Agostino & Associates PC, Hackensack, NJ Panelists: Dawn Harris, IRS Office of Chief Counsel, San Diego, CA; Ronson J. Shamoun, RJS Law, San Diego, CA; Drita Tonuzi, Deputy Chief Counsel (Operations), IRS Office of Chief Counsel, Washington, DC; Zhanna A. Ziering, Caplin & Drysdale Chartered, New York, NY
  • Debt-Equity Considerations for Partnerships and in Bankruptcy. There is a well-developed body of case law regarding whether a financial obligation issued by a corporation is to be treated as debt or stock (or something else) for tax purposes. There are few similar precedents regarding financial obligations issued by a partnership. The panel will discuss existing cases and rulings regarding partnership obligations, as well as whether some or all of the principals that apply to corporate obligation should apply to partnerships. The panel will also discuss the extent to which the section 385 regulations apply to partnership obligations. There will also be a discussion of the treatment of the transaction if partnership debt is recharacterized as equity. Also to be discussed are debt-equity classifications issues under the Bankruptcy Code. Moderator: Lee Zimet, WTS LLC, Morristown, NJ Panelist: Steven R. Schneider, Baker & McKenzie LLP, Washington, DC


Session : ABATX1834
Young Lawyers Forum
Conference : 2018 Midyear Meeting
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$15.00


  • Chair: Clayton Collins, PwC, Washington, DC
  • Treasury’s Regulatory Authority After Nullification of the Temporary Anti-Inversion Regulations.  In 2016, Treasury issued temporary “anti-inversion” regulations, which halted the proposed Pfizer and Allergan merger. Business associations sued, arguing the regulations violated the notice-and-comment procedures under the Administrative Procedures Act. This panel will discuss the APA, the court’s ruling in Chamber of Commerce of U.S. v. IRS, (W.D. Tex. Sept. 29, 2017), and the impact on regulatory guidance going forward. Moderator: Morgan L. Klinzing, Pepper Hamilton LLP, Philadelphia, PA Panelists: Andreas Andrews, Hunton & Williams LLP, Washington, DC; David de Ruig, Fenwick & West LLP, San Francisco, CA; Andrew M. Eisenberg, Jones Day, Washington, DC (Invited); Josh Savey, PwC, Washington, DC


Session : ABATX1835
Tax Practice Management
Conference : 2018 Midyear Meeting
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$15.00


  • Chair: Jeffrey K. Gonya, Venable LLP, Baltimore, MD
  • Ethics for Tax Lawyers.  The panel will discuss the ethical rules that all tax lawyers and tax preparers face in their day-to-day practice. The panel also will discuss the ethical rules associated with lawyers serving as fiduciaries. One panelist is a law school professor focusing in part on business and tax law ethics. Moderator: Jeffrey Gonya; Venable LLP; Baltimore, MD Panelists: Professor John I. Forry, University of San Diego, San Diego, CA; Anna Katherine Moody, Venable LLP, Washington, DC


Session : ABATX1836
Tax Implications for California Wildfire Survivors
Conference : 2018 Midyear Meeting
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$15.00


  • Sponsored by: Pro Bono & Tax Clinics, Individual & Family Taxation, Young Lawyers Division
  • Tax Implications for California Wildfire Survivors. 2017 was the costliest year on record for disasters at $306 billion, shattering the previous inflation adjusted record in 2005 of $215 billion. This panel will discuss common tax law issues fire survivors will face, and how the 2017 Tax Act will impact disaster survivors in the future. Attendees will also learn about the ABA Young Lawyers Division’s role in providing free legal assistance to disaster survivors. Moderator: Christine Speidel, Vermont Legal Aid, Springfield, VT Panelists: Professor Bruce A. McGovern, South Texas College of Law Houston, Houston, TX; Andrew VanSingel, Disaster Legal Services, ABA Young Lawyers Division, Chicago, IL; Additional Panelists TBD


Session : ABATX1837
Civil & Criminal Tax Penalties
Conference : 2018 Midyear Meeting
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$45.00


  • Chair: Niles A. Elber, Caplin & Drysdale, Washington, DC
  • Reports of Subcommittees on Important Developments. Important Developments (Civil) – Sara G. Neill and Michelle F. Schwerin, Capes Sokol Goodman Sarachan PC, St. Louis, MO; Important Developments (Criminal) – Evan J. Davis, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA and Claire Taylor, Colvin & Hallett, Seattle, WA; International Tax Enforcement – Bruce Zagaris, Berliner Corcoran & Rowe LLP, Washington, DC and Joseph M. Erwin, Dallas, TX; IRS Investigations and Practices – Michael A. Villa Jr., Meadows Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TX; Legislative and Administrative Developments – Brian C. McManus, Latham & Watkins LLP, Boston, MA and Robert J. Kovacev, Steptoe & Johnson, Washington, DC; Monetary Violations and Forfeitures – Peter D. Hardy, Ballard Spahr LLP, Philadelphia, PA; Offshore Compliance and Enforcement, Zhanna A. Ziering, Caplin & Drysdale, New York, NY and Michael Sardar, Kostelanetz & Fink, New York, NY; Sentencing Guidelines – Matthew C. Hicks, Caplin & Drysdale Chtd., Washington, DC and Jeffrey A. Neiman, Marcus Neiman & Rashbaum, Fort Lauderdale, FL
  • The New Wave of Fraud Referrals – IRS Collections. Taxpayers with unpaid tax liabilities who take steps to minimize or conceal their income and assets are the subject of increased scrutiny by the Internal Revenue Service and the Department of Justice. IRS Field Collections and Criminal Investigation are working together to train revenue officers to identify fraudulent conduct and refer collection matters for criminal investigation, and the Tax Division has identified this area as a priority for criminal enforcement. As a result, we are seeing an increase in fraud referrals involving evasion of payment, false statements, obstruction, and other violations based on false Collection Information Statements (Forms 433A and B), transfers of income streams and assets to family members and other nominees, the creation of new entities to avoid liens and levies, and other steps to evade IRS collection efforts. This panel will discuss this enforcement initiative, the types of cases being referred, and best practices to avoid a fraud referral. Moderator: Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC Panelists: Darren John Guillot, Director, IRS Field Collection Operations, Washington, DC; R. Damon Rowe, Special Agent in Charge, IRS Criminal Investigation, Los Angeles, CA; Luis Tejeda, Fraud Technical Advisor Supervisor, IRS, Los Angeles, CA; Steven Toscher, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA
  • Skills Workshop: Preparing Witnesses to Testify. Witness testimony can make or break your tax case, whether given in an audit interview, a deposition, or a civil or criminal trial. This panel of experienced trial lawyers will discuss the critical thinking you need to do prior to meeting with the witness, instructions to give the witness, and tools for helping the witness practice effective testimony. The panel will also examine specific techniques to use in preparing different types of witnesses, and variations in approach depending on the context in which the testimony will be given. Note that this is the first in a planned series of skills workshops. Moderator: Guinevere M. Moore, Johnson Moore, Chicago, IL Panelists: Loren Washburn, Smith Correll, Salt Lake City, UT; Nina Marino, Kaplan Marino, Beverly Hills, CA
  • Inter-Agency Investigations with IRS-CI: Are Taxes Really the Driving Force in Your Case? IRS-CI participates in numerous inter-agency investigations, some of which focus on issues related to narcotics, money laundering, terrorism and healthcare fraud. These cases often involve collaborating with formal task forces or numerous other agencies. In the healthcare context, you may find yourself working with IRS-CI, the Department of Health and Human Services (HHS), the Drug Enforcement Administration (DEA), the Federal Bureau of Investigation (FBI), as well as state agencies. IRS-CI also works alongside other federal agencies, such as ICE, HSI, Postal Inspection Service and the Secret Service. The panelists will discuss the logistical and procedural nuances of representing your client in an IRS-CI inter- agency investigation. Moderator: Paula M. Junghans, Zuckerman Spaeder, Washington, DC Panelist: Angela Clark, Special Agent, IRS Criminal Investigation, Los Angeles, CA; Brian D. Poe, Brian D. Poe Attorney at Law PLLC, Fort Worth, TX; Joseph A. Rillotta, Dinker Biddle & Reath, Washington, DC


Session : ABATX1838
Corporate Tax
Conference : 2018 Midyear Meeting
Speaker(s) :
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$45.00


  • Chair: Kathleen Ferrell, Davis Polk & Wardwell LLP, New York, NY
  • Current Developments in Corporate Tax. This panel will address new developments in administrative guidance and tax reform legislation. Moderator: Elliot Freier, Irell & Manella LLP, Los Angeles, CA Panelists: Amie Colwell Breslow, PwC, Washington, DC; Victor Penico, Deloitte, San Francisco, CA; Krishna Vallabhaneni, Deputy Tax Legislative Counsel, Office of Tax Policy Department of Treasury, Washington, DC; Mark Weiss, Chief, Branch 2, IRS Office of the Associate Chief Counsel (Corporate), Washington, DC; Graham Magill, KPMG, Washington, DC
  • Cross-Border Transactions Under Sections 351, 355, and 368 – A Roadmap for the Casual Tourist. This panel will provide a general overview of the key issues practitioners must successfully navigate when advising on cross-border transactions. The potential impact of international tax reform measures will also be discussed. Moderator: David B. Strong, Morrison & Foerster LLP, Denver, CO Panelists: Rachel Kleinberg, Davis Polk & Wardwell LLP, Menlo Park, CA; Kirsten Simpson, EY, Washington, DC; Scott M. Levine, Jones Day, Washington, DC; Brenda Zent, Special Advisor on International Taxation, Office of International Tax Counsel, Department of Treasury, Washington, DC


Session : ABATX1839
Employee Benefits II
Conference : 2018 Midyear Meeting
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$45.00


  • Chair: Professor Kathryn J. Kennedy, The John Marshall Law School, Chicago, IL
  • Foreign Plans and Section 402(b) – What’s an Employer to Do? As the workforce becomes increasing mobile, it has become more and more common for US employees working abroad to continue participation in their US retirement plans and for foreign employees working in the US to continue participation in their home country plans. This panel will discuss the complication and uncertainty concerning the proper tax treatment of these arrangements under section 402(b). Panelists will discuss possible solutions which potentially be effected through guidance under section 402(b) and also review the Tax Section’s comment on these issues. Moderator: Martha N. Steinman, Hogan Lovells US LLP, New York, NY Panelists: Maureen Gorman, Mayer Brown, Palo Alto, CA; Mark Jones, Pillsbury Winthrop Shaw Pittman LLP, Los Angeles, CA: Kurt Lawson, Hogan Lovells US LLP, Washington, DC; Robert Neis, Benefits Tax Counsel, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC (Invited); Stephen Tackney, Deputy Associate Chief Counsel, (Employee Benefits), Office of Associate Chief Counsel (TEGE), IRS, Washington, DC (Invited)
  • Impact of Tax Reform on Executive Compensation and Employee Benefits. This panel will address the impact of the 2017 Tax Act on executive compensation and employee benefits practices, with a focus on the repeal of the performance-based compensation exemption, the 20% tax on excess executive compensation paid by tax exempt organizations, the 5 year tax deferral opportunity for qualifying equity grants made by privately held companies, restrictions on fringe benefits and the changes to payroll tax reporting and withholding as a result of tax rate changes. Moderator: Andrew Liazos, McDermott Will & Emery LLP, Boston, MA Panelists: Gerald Audant, Fenwick & West LLP, San Francisco, CA; Jennifer Krengel, Steptoe & Johnson LLP, Los Angeles, CA; Robert Neis, Benefits Tax Counsel, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC (Invited)
  • Misclassified Employees. The proper administration of various types of employee benefits depends on the proper classification of employees. This can include properly classifying individuals as employees, and the proper classification of employees within the employer’s own employees. The mischaracterization of employees can lead to a number of different problems, including issues with the qualieied status of qualified plans, proper treatment of certain stock options, and the payment of employment tax. This session will explore those issues and potential solutions. Moderators: Thomas Pevarnik, Deloitte Tax LLP, Washington, DC Panelist: Jason Russell, Deloitte Tax LLP, San Francisco, CA; Rhonda Migdail, Mercer, Washington, DC


Session : ABATX1840
Fiduciary Income Tax
Conference : 2018 Midyear Meeting
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  • Chair: Stacey Delich-Gould, Capital Group Private Client Services, New York, NY
  • Current Developments. Nolan Moullé 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; Nolan A. Moullé III, Northern Trust, Houston, TX
  • “ING” Trusts: Legal and Practical Issues. With tremendous opportunities for clients to establish trusts in low-tax jurisdictions come a number of challenges and potential pitfalls. This panel will explore recent developments in “ING” trust planning and the broader context of personal residency and business planning opportunities. The Panel will also examine federal tax planning opportunities which may be available to business owners who create incomplete gift trusts. Panelists: Elizabeth R. Glasgow, Venable LLP, Los Angeles, CA; Daniel C. Lorenzen, Venable LLP, Los Angeles, CA; Victor Shlionsky, Moss Adams, Los Angeles, CA
  • Foreign Trusts: What You Don’t Know Can Hurt You. Estate planners who focus primarily on domestic planning often eschew international planning strategies and issues, but in a global society, it is of growing importance to be able to issue spot potential cross-border hazards. Foreign trusts issues, in particular, are complex and require specialized attention, and foreign trust status (and the associated reporting requirements) can easily be triggered inadvertently. Using case studies from actual practice, this panel (comprised of a domestic estate planner and an international estate planner) will cover the basics of foreign trust classification, taxation and reporting, and offer tips on how to avoid hidden traps for the unwary. Panelists: Elizabeth A. Bawden, Withers Bergman, Los Angeles, CA; Michelle B. Graham, Withers Bergman, Rancho Santa Fe, CA
  • Back to Basics: The Anatomy of a Life Insurance Trust. The drafting of a life insurance trust often seems a routine part of the estate planning practice, but if care is not taken to structure the trust to avoid the imposition of the adverse tax consequences of income, estate, gift and generation skipping transfer taxes, the result can be an estate planning disaster. This panel will review how to properly draft and structure a life insurance trust. Panelist: Danielle E. Miller, Loeb & Loeb LLP, Los Angeles, CA


Session : ABATX1841
Pro Bono & Tax Clinics
Conference : 2018 Midyear Meeting
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  • Chair: Christine Speidel, Vermont Legal Aid, Springfield, VT
  • National Taxpayer Advocate’s Annual Report to Congress. This annual presentation brings Nina Olson to the committee to talk about the National Taxpayer Advocate’s annual report to Congress and to highlight the most important features of the report. Panelist: Nina Olson, National Taxpayer Advocate, IRS, Washington, DC
  • Legal Issues for Military Families and Survivors. This panel will discuss issues that military taxpayers and their practitioners may encounter, to include filing taxes after death in a combat zone, timing, and filing requirements, as well as Servicemembers Civil Relief Act (SCRA) and Military Spouse Residency Relief (MSRRA) implications. Additionally, we will discuss the Survivor Benefit Plan (the insurance policy on military pension for a spouse or children), the timing for election on whether to take the Spouse or Child Option and the tax consequences of each, and the Hero Heart Act, which allows a Survivor to place death gratuity and certain life insurance funds in a Roth IRA. Moderator: Catherine Strouse, Legal Aid of San Diego, San Diego, CA Panelists: Matthew R. Cooper, Servicemembers Civil Relief Act Foundation, Paw Paw, MI; Susan E. Mitchell, Senior Technical Advisor, IRS Taxpayer Advocate Service, Washington, DC; Traci J. Voelke, Legal Assistance Attorney, Office of the Staff Judge Advocate, Department of the Army, Fort Belvoir, VA
  • ITIN Renewal: Due Process and Language Issues. Panelists will discuss current IRS practice as it relates to ITIN renewal. The panel's focus will be on practical considerations related to ITIN renewal, IRS's language access policies as they relate to renewal and math error notices, use of math error notices for returns with deactivated ITINs, and other due process issues. Moderator: Sarah Lora, Legal Aid Services of Oregon, Portland, OR Panelists: Professor Jennifer J. Lee, Temple University, Philadelphia, PA; Robert W. Wunderle, La Posada Tax Clinic, Twin Falls, ID



     


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