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2018 Joint 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.
$299.00



Showing sessions 11 - 20 of (41) TOTAL sessions
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Event : ABATX40


Session : ABATX18110
Partnerships & LLCs
Conference : 2018 Fall Tax Meeting
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  • Chair: Jennifer Alexander, Deloitte Tax LLP, Washington, DC
  • Hot Topics. This panel will discuss recent developments in the area of domestic partnership taxation, including legislation, regulations, administrative guidance and noteworthy cases. Moderator: Lynn Fowler, Kilpatrick Townsend & Stockton LLP, Atlanta, GA Panelists: Audrey Ellis, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC (Invited); Bryan Rimmke, Attorney- Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, D.C. (Invited); Morgan L. Klinzing, Pepper Hamilton LLP, Philadelphia, PA
  • Code Section 163(j). This panel will discuss the implications of Code Section 163(j) to partnerships and their partners. Moderator: Erich Hahn, Deloitte Tax LLP, Washington, DC Panelists: Bryan Rimmke, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC (Invited); Ossie Borosh, KPMG LLP, Washington, DC; Julie Marion, Latham & Watkins LLP, Chicago, IL
  • Code Section 199A. This panel will discuss Code Section 199A and its application to partnerships and their partners and to limited liability companies treated as partnerships and their members. (Specific S Corporation Code Section 199A issues will be discussed separately during the S Corporations committee meeting.) Moderator: Wells Hall, Nelson Mullins Riley & Scarborough LLP, Charlotte, NC Panelists: Audrey Ellis, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC (Invited); Wendy L. Kribell, Office of Associate Chief Counsel (Passthroughs & Special Industries), IRS Office of Chief Counsel, Washington, DC (Invited); Sarah Ritchey Haradon, Holland & Hart LLP, Denver, CO
  • International Hot Topics. This panel will discuss recent developments in the area of international partnership taxation, including legislation, regulations, administrative guidance and noteworthy cases. Moderator: Elizabeth Hall, PwC, Washington, DC Panelist: Daniel McCall, Deputy Associate Chief Counsel (International Technical), IRS Office of Associate Chief Counsel, Washington, DC (Invited); Barksdale Penick, EY, Washington, DC


Session : ABATX18111
Transfer Pricing
Conference : 2018 Fall Tax Meeting
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  • Chair: Timothy S. Gunning, EY, New York, NY
  • The Great BEAT Debate. Taxpayers and tax planners are struggling with myriad interpretative issues related to the new Base Erosion and Anti-Abuse Tax, more fondly known as the BEAT. Until Treasury and/or IRS guidance resolves these issues, taxpayers will remain unable to reliably assess whether they are subject to the BEAT or to calculate their BEAT liability. The amounts at stake are not small. And in some cases, the “right” answer is far from clear. This panel will explore the most critical issues through a pointcounterpoint format, with panelists pairing off (and squaring off) to present the primary competing viewpoints on each of the following issues: (1) No Mark-Up Component – Does a “plus” taint the cost portion of a payment for SCM-eligible services? (2) For Which a Deduction is Allowed – Can (and should) an APA provide certainty as to the characterization of a payment for BEAT purposes? (3) Treaty Override – Does the unfavorable treatment of foreign tax credits for BEAT purposes apply in a treaty context? This lively format will enable audience members to more fully understand the factors that Treasury and the IRS are weighing as they draft guidance on the BEAT, and to better evaluate the risks to their clients. Moderator: Lisandra Ortiz, Miller & Chevalier, Washington, DC Panelists: Professor William H. Byrnes IV, Texas A&M University School of Law, Fort Worth, TX; Barbara J. Mantegani, Mantegani Tax PLLC, McLean, VA; Professor William Seeger, University of Texas at Arlington College of Business, Arlington, TX; Martin A. Sullivan, Tax Analysts, Washington, DC; Thomas A. Vidano, EY, Washington, DC
  • Impact of BEPS and US Tax Reform on Transfer Pricing Controversies: Preparing for the Storm. As a result of the Organization for Economic Co-operation and Development’s (OECD)’s Base Erosion and Profit Shifting (BEPS) project and US tax reform, multinational enterprises (“MNEs”) are anticipating a dramatic increase in tax controversies around the world. As mandated by BEPS, tax authorities will receive country-by-country (CbyC) reports beginning in the Summer of 2018. Such authorities will be reviewing such reports in light of the OECD’s Handbook on Effective Implementation and a Handbook on Effective Tax Risk Assessment, which identify a broad array of potential risk indicators in CbyC reports, including disparities between profits and functions, low risk activities, separate IP structures, and reporting discrepancies. This guidance essentially instructs governments on how to use CbyC data to effectively select audit targets. In addition, US tax reform has created a major paradigm shift in the taxation of MNEs. Foreign tax authorities will be concerned that MNEs will modify related party pricing arrangements to take advantage of favorable aspects of US tax reform, while minimizing unfavorable aspects of US tax reform. This will also create additional examination scrutiny on MNEs related party pricing arrangements by foreign tax authorities. This panel will discuss the sweeping substantive and procedural changes in transfer pricing law and practice, and most importantly how MNEs can prepare for the wave of controversies that are likely to arise from such changes. Moderator: Mark R. Martin, KPMG LLP, Washington, DC Panelists: Karen Kirwan, Senior Advisor to the Director, Treaty and Transfer Pricing Operations Practice Area, IRS, Washington, DC; Keith Robinson, PwC, Atlanta, GA; Larry Eyinla, EY, Atlanta, GA


Session : ABATX18112
US Activities of Foreigners & Tax Treaties
Conference : 2018 Fall Tax Meeting
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  • Chair: Summer LePree, Bilzin Sumberg Baena Price & Axelrod LLP, Miami, FL
  • Advanced FIRPTA: Traps to Keep You Up at Night. This panel will explore a variety of scenarios where the FIRPTA rules produce odd results that may come as an unwelcome surprise, even to seasoned tax planners. Among the problems to be addressed are issues relating to REIT structures, phantom income, US real property holding corporations, withholding, and the exemption for foreign sovereigns. As with every international issue, special problems posed by partnerships will be addressed as well. Moderator: Michael J. Miller, Roberts & Holland, New York, NY Panelists: Kimberly S. Blanchard, Weil Gotshal & Manges LLP, New York, NY; Mark Stone, Holland & Knight, New York, NY
  • Inbound Financing After Tax Reform – What Now? US businesses are re-evaluating their capital structures and how they fund their operations in the new era of US tax law. This panel will discuss the new dynamics of financing US businesses from outside the US in light of new federal tax rates and laws impacting deductibility of interest and limits on base eroding payments. Consideration will be given to the new laws and any guidance issued as well as tax planning in the new framework of BEAT, anti-hybrid rules, amended Code section 163(j) and other legislative changes. Moderator: Jason S. Bazar, Mayer Brown LLP, New York, NY Panelists: Ora Grinberg, Fenwick and West LLP, Mountain View, CA; Victor A. Jaramillo, Caplin and Drysdale, Washington, DC; Jiyeon Lee-Lim, Latham and Watkins, New York, NY; Brett York, Associate International Tax Counsel, Office of International Tax Counsel, Department of Treasury, Washington, DC; John J. Merrick, Senior Level Counsel, IRS Office of Associate Chief Counsel (International), Washington, DC


Session : ABATX18113
Exempt Organizations
Conference : 2018 Fall Tax Meeting
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$60.00


  • Chair: Lisa L. Johnsen, Bill & Melinda Gates Foundation, Seattle, WA
  • News from the IRS and Treasury. Representatives from the IRS and Treasury Department will discuss topics of current interest to exempt organizations practitioners. Moderator: Alexander L. Reid, Morgan Lewis & Bockius LLP, Washington, DC Panelists: Victoria A. Judson, Division Counsel/Associate Chief Counsel (TEGE), IRS Office of Chief Counsel, Washington, D.C. (Invited); Janine Cook, Deputy Associate Chief Counsel (TEGE), IRS Office of Chief Counsel, Washington, DC (Invited); Elinor C. Ramey, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited)
  • Charitable Giving Under the 2017 Tax Act: Keeping and Creating Charitable Contribution Deductions. This panel will discuss the principal provisions of the 2017 Tax Act that may impact charitable giving, as well as planning techniques and strategies to enable taxpayers to maximize the tax benefits from charitable gifts. The panel also will review the status of state charitable funds established in response to new limits on state and local tax deductions. Moderator: Morey Ward, Ropes & Gray LLP, Washington, DC Panelists: Kim V. Heyman, Gadsden Schneider & Woodward LLP, Philadelphia, PA; Adam M. Holmes, Morgan Lewis & Bockius LLP, Boston, MA; Karl F. Mill, Adler & Colvin, San Francisco, CA Co-sponsored by: RPTE Charitable Group
  • Crowdfunding Charity: Navigating the Legal Landscape. This panel will discuss charitable crowdfunding and the federal tax and state law issues that arise for nonprofits, donors, and stateregulators when nonprofits and their donors use new crowdfunding platforms, such as Crowdrise, Razoo, and Indiegogo, for charitable fundraising. Moderator: Ray Prather, Prather Ebner LLP, Chicago, IL Panelists: Emily Chan, Adler & Colvin, San Francisco, CA; William Wang, New York Attorney General’s Office, New York, NY Co-sponsored by: RPTE Charitable Group


Session : ABATX18114
Tax Policy & Simplification
Conference : 2018 Fall Tax Meeting
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  • Chair: Roger Royse, Royse Law Firm, Menlo Park, CA
  • Transparency Tide or Transparency Tsunami? The New Wave of Global Reporting Rules and IRS Tools to Unearth Foreign Financial Accounts: FATCA, FBAR, & CRS developments in the wake of OVDP and Swiss Bank Program. Mandatory reporting of offshore financial assets by financial institutions has been expanding globally ever since the U.S., in the wake of the UBS scandal, passed the Foreign Account Tax Compliance Act (FATCA) as a complementary program to the Foreign Bank Account Report (FBAR). The Justice Department and IRS maintain that, despite these reporting regimes, a high percentage of U.S. taxpayers, including millions residing abroad, are still failing to comply. The IRS’ Criminal Investigation division recently unveiled two new investigative units: the International Tax Enforcement Group (ITEG) and the Nationally Coordinated Investigations Unit (NCIU)—both aimed at increasing taxpayer compliance using advanced data analytic techniques. Meanwhile, the Justice Department’s Swiss Bank Program – an amnesty program designed for Swiss financial institutions – is in its legacy phase and the IRS is closing (as of Sept. 28, 2018) its popular Offshore Voluntary Disclosure Program (OVDP) under which cooperating taxpayers could pay reduced penalties and avoid criminal sanctions. Both the Justice Department and IRS have broadened their efforts and are now investigating funds that flowed out of the scrutinized Swiss banks to banks in other countries. At the same time, an OECD transparency initiative, inspired by the FATCA and known as the Common Reporting Standard (CRS), is being adopted by an increasing number of jurisdictions on a bilateral and multilateral basis. Tax advisors with international components to their practices should be aware of the impacts and exigencies of both the FATCA and the CRS. The panel will discuss critical updates to the FATCA and FBAR reporting regimes, outline recent enforcement efforts by the Justice Dept. and IRS, and compare the OECD’s CRS to FATCA, including their respective impacts on funds. Tax planning strategies and policy implications will also be discussed, including how the automatic exchange-of-information programs are likely to affect taxpayer behaviors and compliance rates, professional tax advice, and the so-called tax gap in the U.S. and other jurisdictions. Moderator: Pamela A. Fuller, Royse Law Firm, New York, NY Panelists: Nicole Cammarota, Senior Counsel, IRS Office of Chief Counsel (Large Business & International), New York, NY; George Guttman, Senior Analyst, GAO, Washington, DC; Matthew D. Lee, Fox Rothschild, Philadelphia, PA; Gabriel Quihuis, Morgan Lewis, Boston, MA


Session : ABATX18115
Foreign Activities of US Taxpayers
Conference : 2018 Fall Tax Meeting
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  • Chair: Kimberly Tan Majure, KPMG LLP, Washington, DC
  • Repatriation of Foreign Earnings (Real or Imagined, Voluntary or Otherwise). This panel will explore the mechanisms for taxpayers to repatriate foreign earnings. Participation exemption, mandatory repat, subpart F, GILTI, 956, 1248 – with so many “choices,” what could possibly go wrong? Join us and find out. Moderator: Devon Bodoh, KPMG LLP, Washington, DC Panelists: Amie Colwell Breslow, PwC, Washington, DC; Scott Levine, Jones Day, Washington, DC; Brenda Zent, Special Advisor on International Taxation, Office of International Tax Counsel, Department of Treasury, Washington, DC; Gary Scanlon, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC; John J. Merrick,Senior Level Counsel, IRS Office of Associate Chief Counsel (International), Washington, DC
  • BEAT – Not for the Faint of Heart. One of the most angst-inspiring features of Tax Reform, BEAT brings a wide range of issues – international tax, income tax accounting, transfer pricing – to the table, and seems to raise as many questions as answers. This panel will discuss gaps, traps, and latest and greatest thinking on the new rules, including practical issues related to payment netting, COGS and cost sharing. Moderator: Amanda Varma, Steptoe & Johnson LLP, Washington, DC Panelists: Scott Harty, Alston & Bird, Atlanta, GA; Anne Gordon, PwC, Washington, DC


Session : ABATX18116
Court Procedure & Practice Roundtable Discussion
Conference : 2018 Fall Tax Meeting
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  • Chair: Joshua D. Odintz, Baker & McKenzie LLP, Washington, DC
  • A Primer on the Use of Experts in Tax Court. This Joint Program between the Tax and Real Property, Trust and Estate Sections will focus on using experts in tax controversy cases, with an emphasis on the unique rules in Tax Court litigation. The panel will use a case study approach, from determining the issues that require the hiring of an expert, identifying and engaging the right expert and the timing of such engagement; through the preparation of the expert’s report, preparing the expert for trial testimony, voir dire, cross examination, and then reliance on the expert’s report and testimony in posttrial briefs. Moderators: Abigail Rosen Earthman, Winstead PC, Dallas, TX; Mitchell I. Horowitz, Buchanan Ingersoll & Rooney PC, Tampa, FL Panelists: The Honorable Richard T. Morrison, US Tax Court, Washington, DC; Andrew M. Tiktin, Special Trial Attorney, IRS Office of Chief Counsel, Denver, CO; Lu-Ann Dominguez, Gunster, Ft. Lauderdale, FL; Timothy K. Bronza, Business Valuation Analysts LLC, Orlando, FL


Session : ABATX18121
State & Local Taxes
Conference : 2018 Fall Tax Meeting
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  • Chair: Edward Bernert, BakerHostetler, Columbus, OH
  • Improving the Sales Tax Systems: COST Report on the Best and Worst of Sales Tax Administration. Moderator: Leah S. Robinson, Mayer Brown LLP, New York, NY Panelists: Karl Frieden, Council on State Taxation, Washington, DC; Fred Nicely, Council on State Taxation, Washington, DC


Session : ABATX18122
Energy & Environmental Taxes
Conference : 2018 Fall Tax Meeting
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  • Chair: Amish M. Shah, Eversheds Sutherland, Washington, DC
  • Energy Industry Tax Updates Roundtable. This roundtable session will involve discussions among attendees of recent legislative, judicial and regulatory tax developments impacting the energy sector and companies engaged in energy transactions and investments, including a discussion of the most recent beginning of construction notice, tax reform impacts and related regulatory guidance, and other income and excise tax oil and gas, renewable energy and alternative fuels developments. Moderators: Amish Shah, Eversheds Sutherland, Washington, DC; Courtney Sandifer, Mazars USA, Washington, DC Panelists: Jennifer Bernardini, Attorney, Branch 6, Passthroughs and Special Industries, IRS, Washington, DC; Hannah Hawkins, Attorney Adviser, Department of Treasury, Office of Tax Policy, Washington, DC; Jaime Park, Attorney, Branch 7, Income Tax and Accounting; Brian Americus, Deloitte, Washington, DC; Deborah Gordon, KPMG, Washington, DC; Brad Seltzer, Eversheds Sutherland, Washington, DC


Session : ABATX18146
Estate & Gift Taxes, Fiduciary Income Tax and Income & Transfer Tax Planning Group
Conference : 2018 Fall Tax Meeting
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  • Estate & Gift Taxes Chairs: Hannah W. Mensch, Ehrenkranz Partners, New York, NY and George D. Karibjanian, Franklin Karibjanian & Law PLLC, Boca Raton, FL / Washington, DC Fiduciary Income Tax Chair: Stacey Delich-Gould, Capital Group Private Client Services, New York, NY Income & Transfer Tax Planning Group Chair: Rana Salti, Kinship Trust Company, Chicago, IL
  • 2018 Update of Privileges and Fiduciaries. This presentation will review current case law on the application of privileges in the fiduciary context. Speaker: Dana G. Fitzsimons Jr., Bessemer Trust, Atlanta, GA



     


Showing sessions 11 - 20 of (41) TOTAL sessions
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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.