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Showing sessions 21 - 30 of (41) TOTAL sessions
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Event : ABATX40


Session : ABATX18123
Employment Taxes
Conference : 2018 Fall Tax Meeting
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$45.00


  • Chair: Edward J. Leyden, Leyden Law LLC, Washington, DC
  • IRS Employment Tax Update. Senior IRS officials provide an overview of important developments since the May 2018 Meeting, including pertinent holdings handed down during the just-completed Supreme Court term, guidance projects in connection with the 2017 Tax Act, and proposed legislation, such as the proposed EMPOWHER ACT. Panelist: Ligeia Donis, PwC, Washington, DC
  • The Competing Tensions Driving Independent Contractor Status for Service Providers. In April, the Supreme Court of California handed down its holding in Dyamex Operations West, Inc. v. Superior Court of Los Angeles, Case S222732, which, among other things, made controlling under California law the so-called “ABC test” for determining whether a service provider may be characterized as being an independent contractor. A few months earlier, Congress enacted Internal Revenue Code (IRC) § 199A, which, some argue, provides a disincentive against employment status and wage income. This program will examine these competing policy tensions while also exploring other important evolving issues in connection with classifying workers. Panelist: William Weismann, Littler Mendelson, San Francisco, CA
  • Tax Consequences of Employment Settlements and Judgements. Resolving employment disputes has always been a prominent feature of the legal landscape. Recent events, however, have brought into even sharper focus for employers and their executives, alike, the potential pitfalls that can arise from alleged workplace harassment and misconduct. Partly in response to these events – and for separate fiscal reasons, as well – the 2017 Tax Act has made very significant changes to the federal tax consequences that may arise from the disposition of an employment dispute, including for the deductibility of settlement amounts and attorneys’ fees. This panel will provide an overview of the overarching tax principles governing employment disputes, examine the tax treatment of settlements and judgments under revised federal tax law (including new IRC § 162(q)), and discuss potential next legislative and administrative steps for addressing these issues, including the proposed EMPOWHER Act. Moderator: Megan Marlin, PwC, Washington, DC Panelist: Edward J. Leyden, Leyden Law LLC, Washington, DC
  • Correcting Payroll Tax Reporting Errors and Grossing Up Payments for Tax Consequences. In 2009, the IRS introduced Form 941-X as the vehicle for correcting payroll tax information reporting errors whenb discovered and for claiming refunds of overpayments. As the Tenth Anniversary of this initiative approaches, this program will examine its effects and explore needs for fine-tuning. Along these same lines, the program will also discuss the tax policy and real-work complications behind grossing-up taxable payments in relation to employment compensation to provide recipients with a tax-neutral economic outcome in dispute resolutions. Panelist: Edward J. Leyden, Leyden Law LLC, Washington, DC


Session : ABATX18125
Standards of Tax Practice
Conference : 2018 Fall Tax Meeting
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$30.00


  • Chair: Rachel L. Partain, Caplin & Drysdale Chartered, New York, NY
  • Ethical Pitfalls in Representing Spouses.  Innocent spouse claims and the potential for such claims present a myriad of ethical issues that practitioners must be aware of and carefully avoid. This panel will discuss how to effectively represent clients and avoid ethical breaches. Moderator: Professor Christine Speidel, Villanova University Widger School of Law, Villanova, PA Panelists: Professor Ted Afield, Georgia State University College of Law, Atlanta, GA; Karen L. Hawkins, Hawkins Law, Yachats, OR; Bryan C. Skarlatos, Kostelanetz & Fink LLP, New York, NY
  • Ethical Issues in Federal Tax Practice – The Government Perspective.  This panel will provide an update on recent guidance from the IRS and the Department of Treasury, discuss issues of concern and areas of focus for the IRS Office of Professional Responsibility and Office of Chief Counsel, and give an update on pending cases that relate to tax practice standards. Moderator: Matthew Cooper, EY, Washington, DC Panelists: Stephen Whitlock, Director, IRS Office of Professional Responsibility, Washington, DC; Emily Lesniak, Special Counsel (Procedure & Administration), IRS Office of Chief Counsel, Washington, DC
  • Ethical Issues Regarding the Partnership Representative.  Who is the Partnership Representative (“PR”)? What are the PR’s rights and responsibilities to the partnership? To partners? To the IRS? This panel will explore the differences between the new role of the PR and the old role of the Tax Matters Partner, the ethical issues in executing this new PR role, and ways to avoid ethical breaches. Moderator: Aaron Esman, Caplin & Drysdale Chartered, New York, NY Panelists: Gregory Armstrong, Senior Technical Reviewer, IRS Office of Chief Counsel, Procedure and Administration, Washington, DC; Bahar Schippel, Snell & Wilmer, Phoeniz, AZ; Barksdale Penick, EY, Washington, DC; Guinevere Moore, Johnson Moore LLC, Chicago, IL Co-sponsored by: Administrative Practice


Session : ABATX18126
Employee Benefits
Conference : 2018 Fall Tax Meeting
Speaker(s) :
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$45.00


  • Chair: Bret Hamlin, Hill Ward Henderson, Tampa, FL
  • Proxy Season: Looking Back, Looking Forward. After much preparation and angst, public companies and their advisors have now made it through the initial season of pay ratio calculation and reporting. This program will cover lessons learned from the inaugural process and offer observations on what companies will be focusing on in year two. Panelists also will cover other highlights from the past proxy season and issues to be focused on as companies begin planning for the next season including possible changes to incentive plans in light of the changes to Section 162(m). Moderator: Martha N. Steinman, Hogan Lovells US LLP, New York, NY Panelists: Mark Borges, Compensia Inc., San Francisco, CA; Susan Daley, Perkins Coie LLP, Chicago, IL; Charley King, FW Cook, Atlanta, GA
  • The Affordable Care Act: What Now? What Next? This panel will discuss where the Affordable Care Act stands eight years after being enacted, including recent regulatory changes, IRS enforcement activities, and the impact on trends in telemedicine and wellness programs. Moderator: Don Wellington, Reed Smith LLP, Los Angeles, CA Panelists: Yelena Gray, Nixon Peabody LLP, Chicago, IL; Jenni Krengel, Reed Smith LLP, San Francisco, CA; Rachel Levy, Groom Law Group, Washington, DC; Stephen Tackney, Deputy Associate Chief Counsel (Employee Benefits), Tax Exempt and Government Entities Division, Office of Chief Counsel, IRS, Washington, DC (Invited); Kevin Knopf, Senior Technician Reviewer, Health and Welfare Branch, Tax Exempt and Government Entities Division, IRS Office of Chief Counsel, Washington, DC (Invited)
  • 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: Professor Kathryn J. Kennedy, The John Marshall Law School, Chicago, IL Panelists: Kyle Brown, Division Counsel, Tax Exempt and Government Entities Division, Office of Chief Counsel, IRS, Washington, DC (Invited); Carol Weiser, Acting Benefits Tax Counsel, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC (Invited); Victoria Judson, Associate Chief Counsel, Tax Exempt and Government Entities Division, Office of Chief Counsel, IRS, Washington, DC (Invited); Stephen Tackney, Deputy Associate Chief Counsel, (Employee Benefits), Tax Exempt and Government Entities Division, Office of Chief Counsel, IRS, Washington, DC (Invited)


Session : ABATX18127
State & Local Taxes
Conference : 2018 Fall Tax Meeting
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$45.00


  • Chair: Edward Bernert, BakerHostetler, Columbus, OH
  • What Is a Remote Seller to Do in This Post-Quill World? In June 2018, in South Dakota v. Wayfair, Inc., the US Supreme Court overruled its 50-year-old physical presence nexus standard for the collection of use taxes, replacing that “bright line” nexus standard with a case-by-case analysis of whether the remote seller has “availed itself of the substantial privilege of carrying on business” in the customer’s state. The Supreme Court majority determined that the South Dakota “factor presence” use tax nexus statute satisfied the significant nexus requirement of the Commerce Clause, at least in the context of the small state of South Dakota, but the Wayfair decision raises far more questions than it answered about what economic presence nexus standard states can use. This panel will explore a range of issues, including what types of safe harbor (or maybe no safe harbor at all) states have to provide in their use tax collection statutes, whether states need to have simplified their sales/use tax laws pursuant to the Streamlined Sales and Use Tax Agreement, as South Dakota did, to have a constitutional statute, whether states could apply their new economic presence nexus standard retroactively, and what use tax collection burdens on smaller remote sellers might violate the Commerce Clause. Moderator: John A. Biek, Neal Gerber & Eisenberg LLP, Chicago, IL Panelists: Joe W. Garrett Jr., Deputy Commissioner, Alabama Department of Revenue, Montgomery, AL; Shirley K. Sicilian, KPMG LLP, Washington, DC
  • Impact of Wayfair on Services and International Taxes. Wayfair clearly changed the constitutional sales tax reach of states relating to remote sales of tangible personal property within the US. What about other transactions? This session will focus on the impacts of Wayfair relating to sales tax on remote sales of services within the US, and on transaction taxes on sales of products or services across international lines. Moderator: Steve P. Young, Holland & Hart LLP, Salt Lake City, UT; Panelists: Professor John S. Baker, Louisiana State University Law School, Baton Rouge, LA; Michelle DeLappe, Garvey Schubert Barer, Seattle, WA
  • SALT Deduction “Workaround” Responses to the 2017 Tax Act. This panel will discuss states’ recently enacted charitable contribution tax credit structures and other legislative provisions that address the 2017 Tax Act’s $10,000 state and local tax deduction cap. These state provisions are intended to permit taxpayers to obtain federal deductions by classifying payments as payroll taxes or charitable contributions while awarding a state tax credit. The panel will also discuss IRS Notice 2018-54 and the proposed regulations and their broad sweep, including the potential impact on longstanding non-profit scholarship granting organizations across the country. Moderator: Debra S. Herman, Hodgson Russ LLP, New York, NY Panelist: Bruce P. Ely, Bradley, Birmingham, AL; Peter L. Faber, McDermott Will & Emery, New York, NY


Session : ABATX18128
Closely Held Businesses and Business Planning Group
Conference : 2018 Fall Tax Meeting
Speaker(s) :
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MP3
$45.00


  • Closely Held Businesses Chair: Shawn McIntire, Ballard Spahr LLP, Denver, CO Business Planning Group Chair: William I. Sanderson, McGuireWoods, Washington, DC
  • 199A: Update and Analysis. The panelists will focus on the effects of the proposed regulations and how they affect the planning for closely held business, especially with regards to planning techniques for pass through entities. Panelists: Mark E. Wilensky, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY; Robb A. Longman, Longman & VanGrack LLC, Bethesda, MD; Galina “Allie” Petrova, Petrova Law PLLC, Greensboro, NC; Ivan Golden, Hahn Loeser, Chicago, IL
  • Beyond Powell – Examining the Important Provisions of Operating Agreements and Shareholder Agreements. The panel will examine common – and important – provisions of operating agreements, partnership agreements, and shareholders agreements. The governing documents of an entity can provide the structure for a productive business. The panel will include the in-house general counsel of a family enterprise, and the topics covered will include: important tax provisions, transfer restrictions and responsible frameworks for transitioning ownership, and common management and operational control provisions. Panelists: David A. Berek, Baker & McKenzie LLP, Chicago, IL; Buzz Winchester, Quikrete Companies Inc., Atlanta, GA


Session : ABATX18129
Court Procedure & Practice
Conference : 2018 Fall Tax Meeting
Speaker(s) :
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$45.00


  • Chair: Joshua D. Odintz, Baker & McKenzie LLP, 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: Jeffrey M. Glassman, Meadows Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TX Panelists: Chief Judge Maurice B. Foley, US Tax Court, Washington, DC; Richard G. Goldman, Deputy Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC; Brendan T. O’Dell, Attorney- Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Gil Rothenberg, Chief, Appellate Section, Department of Justice Tax Division, Washington, DC
  • Litigating Whistleblower Cases in the Tax Court. Whistleblower cases are moving through the Tax Court and are becoming more common. This panel will cover representing whistleblowers in the Tax Court, including the Tax Court’s jurisdiction, standard of review, and discovery issues. Additionally, this panel will discuss how to represent taxpayers whose tax liability may be at issue in a whistleblower case, including quashing subpoenas and ensuring their privacy. Moderator: Elizabeth Blickley, Washington, DC Panelists: Judge James Halpern, US Tax Court, Washington, DC; Erica Brady, The Ferraro Law Firm, Washington, DC; Patricia P. Davis, Special Trial Attorney, IRS Office of Chief Counsel (Large Business & International), Chicago, IL; Diana Erbsen, DLA Piper, New York, NY
  • The New Partnership Audit Rules, Round 2 – After the Partnership Audit, How You and the IRS Fight It Out. In Round 1, the Administrative Law Committee covered what will happen during the audit. In Round 2, we discuss the Final Partnership Adjustment (“FPA”) and what options partnerships have following the end of the audit, including challenges to the adjustments in the FPA. We also discuss the assessment and collection of imputed underpayments and penalties under the new regime, including the operation of the push-out election. Moderators: Robert J. Kovacev, Norton Rose Fulbright US LLP, Washington, DC; Rebecca M. Stork, Eversheds Sutherland LLP, Atlanta, GA Panelists: Jean A. Pawlow, Latham & Watkins LLP, Washington DC; Megan L. Brackney, Kostelanetz & Fink LLP, New York, NY; Jenni Black, Senior Counsel, Associate Chief Counsel Procedure & Administration, Washington, DC; Rochelle Hodes, Crowe LLP, Washington, DC
  • Post-Mayo Jurisprudence: Challenging Regulations After Mayo. Seven years had passed since the Supreme Court eliminated the distinction between interpretive and legislative regulations and require the courts to accord Chevron deference to all tax regulations. This panel will discuss potential avenues to challenging regulations under APA and in light of Chevron deference and how the courts evaluate such challenges in the post-Mayo world. Moderator: Arielle Borsos, Caplin & Drysdale Chartered, Washington, DC Panelists: Professor Clinton G. Wallace, University of South Carolina, School of Law, Columbia, SC; Zhanna A. Ziering, Caplin & Drysdale Chartered, New York, NY; Gil Rothenberg, Chief, Appellate Section, Department of Justice Tax Division, Washington, DC


Session : ABATX18130
Diversity
Conference : 2018 Fall Tax Meeting
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  • Chair: Lany L. Villalobos, Dechert LLP, Philadelphia, PA
  • The “Nanny Tax”: Taxation of Household Employees. Individuals who hire household employees may be subject to state and federal employment taxes. This panel will discuss worker classification issues in determining whether an individual is a household employee and the federal income and employment tax reporting, withholding, and payment requirements that apply to household employees. Moderator: Professor Tameka E. Lester, Georgia State University College of Law, Atlanta, GA Panelists: Mikhail A. Zhidkov, IRS Office of Chief Counsel (TEGE, Employment Tax Branch 2), Washington, DC; Michael Wallace, Agostino & Associates, Hackensack, NJ; Professor Emily Yaun, Georgia State University College of Law, Atlanta, GA
  • Preparing Fiduciary Income Tax Returns and Representing Clients on Audit. This panel will walk through the Federal fiduciary income tax return along with its accompanying schedules. Panelists will discuss how to prepare these Federal fiduciary income tax returns and how to avoid commonly mishandled issues from a practical perspective. The panel will also discuss best practices when representing a client in an audit. Panelists: Samuel Hercules, Fiduciary Tax Consultants LLC, New York, NY; Elizabeth Lindsay-Ochoa, CBIZ & MHM, Boston, MA
  • The 21st Century Family: Drafting Wills and Trusts in a Time of Changing Concepts of Family, Gender, and Race. Family issues pose challenges for attorneys trying to fulfill a client’s long-term goals, especially for families with unique circumstances. This panel will give practical perspectives and advice on how to handle difficult situations that arise from the composition of the 21st century family. Moderator: Elizabeth Lindsay-Ochoa, CBIZ & MHM, Boston, MA Panelists: Professor Lee-ford Tritt, University of Florida, Levin College of Law, Gainesville, FL; Laura Joy Lattman, McLaughlin & Stern LLP, New York, NY; Vanessa Browne, Bessemer Trust, Washington, DC


Session : ABATX18131
Financial Transactions
Conference : 2018 Fall Tax Meeting
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  • Chair: Craig Gibian, Deloitte Tax LLP, Washington, DC
  • Section 163(j) Update. This panel will discuss issues relating to section 163(j) from a financial transactions perspective, including the definition of “business interest,” hedging transactions and cancellation of debt income. To the extent proposed regulations have been released, this panel will also consider the impact of such regulations. Moderator: Craig Gibian, Deloitte Tax LLP, Washington, DC Panelists: Jeff Borghino, Grant Thornton LLP, Washington, DC; Eileen Marshall, Wilson Sonsini Goodrich & Rosati, Washington, DC; Brett York, Department of Treasury, Washington, DC (Invited)
  • Treatment of Certain Debt Related Fees. This panel will explore the treatment of certain fees relating to debt, including upfront fees and fees paid during the life of a debt instrument. Moderator: Michael Bauer, PwC, Washington, DC Panelist: Bora Bozkurt, Latham & Watkins LLP, New York, NY; Diana Imholtz, IRS Office of Associate Chief Counsel (FI&P), Washington, DC (Invited)
  • Banks and the BEAT. This panel will discuss the questions confronting financial institutions as they navigate the BEAT, including the scope of the “qualified derivative” exemption, the impact of derivatives on the base erosion percentage, the effect of the global dealing rules and the special issues facing US branches of foreign banks. Moderator: Lucy Farr, Davis Polk & Wardell, New York, NY Panelists: Rhiannon Nakano, Citigroup Inc., New York, NY; Elena Romanova, Latham & Watkins LLP, New York, NY


Session : ABATX18132
Insurance Companies
Conference : 2018 Fall Tax Meeting
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  • Chair: Ann Cammack, EY, Washington, DC; Sheryl Flum, KPMG, Washington, DC
  • Insurance Tax “Real Time” Topics. Panelists will provide an update regarding the status and content of developing/resolved 2017 Tax Act items, recent court decisions (if any), and IRS guidance on insurance tax issues. Panelists will discuss industry tax issues, including tax reform-related issues, any 2017 Tax Act guidance that is issued by meeting time, and the recent captive decision in Reserve Mechanical. Moderator: Jean Baxley, Deloitte Tax LLP, Washington, DC Panelists: Mark S. Smith, PwC, Washington, DC; Kathryn M. Sneade, Assistant Branch Chief, IRS Office of Chief Counsel, Financial Institutions and Products, Branch 4, Washington, DC; Richard Riley, Foley & Lardner LLP, Washington, DC
  • International Tax Reform and Insurance Companies. The panel will discuss how insurance companies are implementing the international tax provisions added by the 2017 Tax Act, including the following topics: Application of the BEAT to Cross-Border Insurance Transactions; GILTI Issues and Planning for Insurance Companies; Insurance Company Exception from PFIC Status under section 1297(f). Moderator: Stuart Katz, KPMG, New York, NY Panelists: Surjya Mitra, PwC, Washington, DC; Revital Gallen, EY, Irvine, CA
  • Traps for the Unwary: Life Insurance Valuation and Transfer Issues. Panelists will discuss various tax traps involving life insurance contracts. The panel will describe different methods for valuing life insurance contracts for income tax purposes, gift tax purposes, and GST valuation. The panel will also discuss issues that arise in connection with the transfer of a life insurance contract, including transfers for value that affect the tax-free death benefit, the part-gift/part-sale rules, gratuitous transfers, and how transfers affect the investment in the contract and cost basis of a contract going forward. In addition, the panel will discuss the new reportable policy sale rules that were enacted under the 2017 Tax Act, the recent guidance in Notice 2018-41 relating to these new rules, and any subsequent guidance that may be forthcoming that interprets these new rules. Moderator: Alison Peak, Davis & Harman LLP, Washington, DC Panelists: Kathryn M. Sneade, Assistant Branch Chief, IRS Office of Chief Counsel, Financial Institutions and Products, Branch 4, Washington, DC; Patrick Horning, Northwestern Mutual, Milwaukee, WI; Graham Green, Eversheds Sutherland, Washington, DC


Session : ABATX18133
Real Estate
Conference : 2018 Fall Tax Meeting
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  • Chair: Todd D. Keator, Thompson & Knight LLP, Dallas, TX
  • Overview of Qualified Opportunity Zones. This panel will provide an overview of qualified opportunity zones and qualified opportunity funds, focusing on what they are, how qualified opportunity fund investments can be structured, how investors and distressed communities can benefit, and what we know and don’t know. Moderator: Jessica Millett, Duval & Stachenfeld LLP, New York, NY Panelists: Lou Weller, Weller Partners LLP, Sausalito, CA; Steven Berman, Berman Indictor LLP, Philadelphia, PA; Michael Novogradac, Novogradac & Co. LLP, San Francisco, CA; Tom West, Tax Legislative Counsel, Department of Treasury, Office of Tax Policy, Washington, DC
  • What is a Real Estate Trade or Business? This panel will provide a detailed discussion of what it means to have a real estate trade or business, with an emphasis on the meaning in the context of new sections 163(j), 199A, and 1061 brought on by tax reform. Moderator: David Leavitt, PwC, New York, NY Panelists: Peter J. Genz, King & Spalding, Atlanta, GA; James B. Sowell, KPMG LLP, Washington, DC; Tom West, Tax Legislative Counsel, Department of the Treasury, Office of Tax Policy, Washington, DC
  • Structuring Foreign Investment in US Real Property After Tax Reform. This panel will focus on structuring foreign investment in US real property after tax reform, including new tax considerations applicable to blocker corporations. This panel also will provide an update on qualified foreign pension funds. Panelists: David Friedline, Deloitte Tax LLP, New York, NY; Marcy G. Geller, Simpson Thacher & Bartlett LLP, New York, NY
  • Special Issues Applicable to Timber. This panel will discuss tax issues applicable to timber ownership and operations, including special rules applicable to timber REITs, disposition of timber, depletion, and reforestation expenditures. Panelists: Brian E. Hammell, Sullivan & Worcester LLP, Boston, MA; James E. Wreggelsworth, Davis Wright Tremaine LLP, Seattle, WA



     


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