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Showing sessions 41 - 43 of (43) TOTAL sessions
(PREV 10)  1 2 3 4 5


Event : ABATX38


Session : ABATX1842
Sales, Exchanges & Basis
Conference : 2018 Midyear Meeting
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MP3
$45.00


  • Chair: Alan S. Lederman, Gunster, Fort Lauderdale, FL
  • Current Developments Relating to Sales, Exchanges & Basis.  Panelists review recent case law and guidance on traditional sale, exchange, and basis issues, and section 1031. Developments on tax reform will be summarized. Panelists: Kelly E. Alton, NES Financial Corp, San Jose, CA; Steven M. Breitstone, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY
  • The Golden State of Section 1031 Exchanges. Whether due to the high level of its (1) state income tax rates (2) property values, or (3) skill set of its tax practitioners (like our panelists), about half of all US real estate section 1031 transactions involve property located in California. This panel will review how California Franchise Tax Board (FTB) positions on section 1031 exchanges compare to IRS views and current practice, including FTB positions concerning drop-and-swap transactions and swaps of California for non-California property by non-California-residents. The panelists will also discuss FTB’s views on the status of non-safe-harbor reverse exchanges in light of the IRS’s non-acquiescence in Bartell. Moderator: Lou Weller, Weller Partners LLP, Sausalito, CA Panelists: Adam Handler, PwC, Los Angeles, CA; Ciro Immordino, Attorney, California Franchise Tax Board, Rancho Cordova, CA; Joyce Welch, Deloitte Tax LLP, San Diego, CA
  • Working with Islamic Finance. Islamic financial products are projected to exceed $6 trillion by 2020. This large volume of financing available has caused US developers of major projects, including public-private partnership infrastructure projects, to consider the use of Islamic financing structured in such a way that its return can be characterized as interest for purposes of the Internal Revenue Code; such yield can then be both deductible interest expense to the US project owners and tax-exempt portfolio interest income to the unrelated Islamic investors. Panelists will review US income tax issues, and certain financial accounting and state law issues, which should be considered in designing Islamic financial products. Moderator: Glenn Johnson, EY, Washington, DC Panelists: Professor Roberta F. Mann, University of Oregon School of Law, Eugene, OR; Rafi W. Motttahedeh, Jenner & Block LLP, Chicago, IL; Heather Ripley, Alston & Bird, New York, NY
  • It’s My (Related) Party and I’ll Cry if I Want To. Section 267 related party status, referred to in hundreds of Code Sections and Treasury Regulations, can have implications far beyond deferring losses on sales. Without careful planning, section 267 will often thwart legitimate business transactions, such as business acquisitions, establishing pension plans, cross-border financing of a multinational group, replacement of like-kind real estate, buying equipment eligible for immediate expensing under the 2017 tax reform, issuing tax-exempt bonds, managing private foundations, and, as illustrated by Petersen, 148 T.C. No. 22 (2017), accruing employee compensation expense. The panelists will review some of the common situations when the issue of section 267 related party status arises, and focus on what constitutes a section 267 related party. Moderator: David Shechtman, Drinker Biddle & Reath LLP, Philadelphia, PA Panelists: Alfred H. Bae, EY, Houston, TX; Vivek A. Chandrasekhar, Roberts and Holland, New York, NY; Stephen J. Gee, Attorney, IRS Office of Associate Chief Counsel (Income Tax & Accounting), Washington, DC


Session : ABATX1843
California and Beyond -- What the Heck are the State Administrative Tax Appeals Practices?
Conference : 2018 Midyear Meeting
Speaker(s) :
Download Format(s) :
MP3
$45.00


  • Sponsored by: Administrative Practice and State & Local Taxes
  • In the space of a few days during June 2017, the California legislature enacted sweeping legislation that dramatically altered procedures and administration of the state’s tax system. Under the new law, most disputes over state taxes and fees are adjudicated by the newly-established “Office of Tax Appeals.” Many administrative functions of the Board of Equalization (BOE) have been transferred to a second new entity called the “California Department of Tax and Fee Administration.”
  • Earthquake-Quality Seismic Shift in California State Tax Appeals. Panel I will review the impact of this historic shift on California income taxes and other taxes and fees, and discuss the practical implications of appealing to the freshman class of Administrative Law Judges. Panelists: Kristen Kane, Office of Tax Appeals, the State of California, Sacramento, CA; Carolyn M. Lee, Morgan, Lewis & Bockius, San
  • The Good, the Bad, the Ugly – Comparing the Administrative Appeals Practices of the States. Panel II will discuss select state tax appellate approaches and what constitutes best practices for effective and efficient tax dispute resolution. Moderator: Erica Horn, Dean Dorton Allen Ford, Lexington, KY Panelists: Garland Allen, Law Office of Garland Allen, Santa Monica, CA; Amy Nogid, Mayer Brown, New York, NY; Troy Van Dongen, Winston Strawn, San Francisco, CA


Session : ABATX1844
Current Developments in Individual, Corporate, Partnership, and Estate & Gift Taxation
Conference : 2018 Midyear Meeting
Speaker(s) :
Download Format(s) :
MP3
$45.00


  • Sponsored by: Teaching Taxation
  • This session will review the most significant statutory enactments, judicial decisions, IRS rulings, and Treasury regulations promulgated during the last twelve months that affect general income taxation, corporate taxation, partnership taxation, wealth transfer taxation, and tax procedure.
  • Moderator: Professor Bruce A. McGovern, South Texas College of Law Houston, Houston, TX Panelists: Professor Cassady (Cass) Brewer, Georgia State University College of Law, Atlanta, GA; Professor Elaine Hightower Gagliardi, University of Montana School of Law, Missoula, MT



     


Showing sessions 41 - 43 of (43) TOTAL sessions
(PREV 10)  1 2 3 4 5


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