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Showing sessions 31 - 40 of (41) TOTAL sessions
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Event : ABATX40


Session : ABATX18134
S Corporations
Conference : 2018 Fall Tax Meeting
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$45.00


  • Chair: Thomas J. Phillips, von Briesen & Roper sc, Milwaukee, WI
  • Section 199A Proposed Regulations. A dialogue with representatives from the Treasury Department and the Internal Revenue Service Chief Counsel’s Office on the proposed section 199A regulations. Specific partnership section 199A rules will be discussed separately during the Partnership Committee meeting. Moderator: Thomas J. Nichols, Meissner Tierney Fisher & Nichols SC, Milwaukee, WI Panelists: Audrey W. Ellis, Attorney Advisor, Department of Treasury, Washington, DC; Wendy L. Kribell, IRS Office of Chief Counsel, Washington, DC ; Laura Howell-Smith, Deloitte Tax, Washington, DC
  • Cooperatives. A summary of the federal income tax treatment of operating a business as a cooperative for use with an S corporation or as an alternative form of doing business. Panelist: Craig A. Houghton, Baker Manock & Jensen PC, Fresno, CA
  • Important Developments in the Federal Income Taxation of S Corporations. The panel will discuss recent legislative, administrative and judicial developments relating to S corporations and their shareholders. Moderator: Laura Krebs Al-Shathir, Capes Sokol, St. Louis, MO Panelists: Gregory L. Lohmeyer, Quarles & Brady, Milwaukee, WI; Edward A. Waters, Dean Mead, Orlando, FL
  • New Tax Connect Platform for Communicating with Members of the Tax Section. This presentation will summarize the new Tax Connect website for the Tax Section.


Session : ABATX18135
Tax Accounting
Conference : 2018 Fall Tax Meeting
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  • Chair: David Strong, Crowe LLP, Grand Rapids, MI
  • Current Developments. This panel will review recent developments in the area of tax accounting since the Section of Taxation meeting held in Washington, D.C. in May. The panel will also discuss ongoing projects and anticipated guidance, with commentary and input from our guests from the Internal Revenue Service and Department of Treasury. Moderator: Connie Cheng, BDO LLP, Los Angeles, CA Panelists: Michael Resnick, Eversheds Sutherland LLP, Washington, DC; Jessica Lean, KPMG, Washington, DC; John Moriarty, Deputy Chief Counsel, Income Tax & Accounting, Washington, DC; Scott Dinwiddie, Associate Chief Counsel, Income Tax & Accounting, Washington, DC; Ellen Martin, Tax Policy Advisor, Office of Tax Policy, Department of Treasury, Washington, DC
  • Accounting Method Changes for Controlled Foreign Corporations. This panel will review the issues related to filing accounting method changes for controlled foreign corporations (CFCs). Topics will include audit protection, the exceptions to audit protection, limitations for CFCs in filing method changes and discussions of disregarded method changes filed in the 2017 or 2018 tax year and the adjustments to E&P required as a result of these changes. Moderator: Christine Turgeon, PwC, New York, NY Panelists: Carol Conjura, KPMG, Washington, DC; Jane Rohrs, Deloitte Tax LLP, Washington, DC
  • Inventory. This panel will review issued and pending guidance in the area of inventory accounting. Topics will include discussion of the negative additional section 263A regulations as well as small business accounting method changes under section 263A. The panel will also discuss ongoing projects and anticipated guidance, with commentary and input from our guests from the Internal Revenue Service and Department of Treasury. Moderator: Kristine Mora, EY, Washington, DC Panelists: Les Schneider, Ivins Phillips & Barker, Washington DC; Christina Morrison, Senior Technician Reviewer, Branch 6, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Christopher Call, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC
  • Revenue Recognition and Section 451. This panel will continue to build upon previous revenue recognition panels in light of the financial accounting standard ASC 606 and enactment of the 2017 Tax Act. This panel will discuss recently released guidance and discuss ongoing projects and anticipated guidance, with commentary and input from our guests from the Internal Revenue Service and Department of Treasury. Moderator: Les Schneider, Ivins Phillips & Barker, Washington, DC; Panelists: Colleen O’Conner, KPMG, Washington, DC; Wendy Friese, Deloitte Tax, Washington, DC; John Moriarty, Deputy Chief Counsel, Income Tax & Accounting, Washington, DC; Scott Dinwiddie, Associate Chief Counsel, Income Tax & Accounting, Washington, DC; Charles Gorham, Senior Attorney, Branch 1, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Christopher Call, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC


Session : ABATX18136
Teaching Taxation
Conference : 2018 Fall Tax Meeting
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  • Chair: Professor Kerry Ryan, St. Louis University, St. Louis, MO
  • Global Trends in Transparency and Disclosure. Over the past ten years, taxpayers and countries have faced increasing demands and obligations for tax transparency and disclosure. Global examples include BEPS Country-by-Country Reporting, the Common Reporting Standard, Beneficial Ownership Registries, and EU mandatory disclosure directives. These new requirements for taxpayer disclosure to government have prompted calls for public disclosure of the reported taxpayer information. International tax organizations and NGOS have played an active role in the debate over public access to taxpayer information. This panel will explore these trends in tax transparency and disclosure, along with the emerging problems and debates over the benefits, risks, design, and scope of these new practices. Moderator: Professor Patricia Brown, University of Miami, Coral Gables, FL Panelists: Dèlcia M. Capocasale, Cuatrecasas, New York, NY; Victor A. Jaramillo, Caplin & Drysdale, Washington, DC; Pere M. Pons, Chevez Ruiz Zamarripa, Madrid, Spain; Vincent van der Lans, Loyens & Loeff, New York, NY Co-sponsored by: Foreign Lawyers Forum


Session : ABATX18137
Tax Practice Management
Conference : 2018 Fall Tax Meeting
Speaker(s) :
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$15.00


  • Chair: Roger Royse, Royse Law Firm, Menlo Park, CA
  • The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement. As federal enforcement agencies are increasingly asked to do more with less, the US government has implemented advanced technology applications to enforce financial crimes which have increased in sophistication. In 2011, the IRS created the Office of Compliance Analytics as its answer to investigate and combat modern tax crimes. Using advanced artificial intelligence, the Office of Compliance Analytics relies on the use of big data and predictive algorithms to be more strategic in its approach in bringing cases. After decades of storage, the IRS has significant amounts of data to be analyzed with predictive algorithms. In addition, the IRS has started to combine its own data with taxpayer data mined from social media platforms like Twitter, Facebook, and Instagram to help identify potential noncompliant taxpayers and combat tax fraud. This panel will discuss the fundamentals of the IRS’s big data analytics program, potential taxpayer privacy concerns, and what tax practitioners should be aware of when they represent clients in the future. Moderator: Travis Thompson, Sideman & Bancroft LLP, San Francisco, CA Panelists: Eric Hylton, Deputy Chief, Criminal Investigation, IRS, Washington, DC; Carina Federico, Crowell & Moring LLP, Washington, DC; Michelle Schwerin, Capes Sokol, St. Louis, MO; Professor Kimberly Houser, Oklahoma State University, Stillwater, OK


Session : ABATX18138
Young Lawyers Forum
Conference : 2018 Fall Tax Meeting
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  • Chair: Micah Gibson, PwC, Washington, DC
  • New Law, New Regulations, New Practitioners: Legal and Ethical Obligations When Advising Taxpayers in an Uncertain Legal Environment.  This panel will discuss practical and technical issues that arise after a major change in law such as the 2017 Tax Act. We will explore the impact of proposed, temporary, and final regulations on the interpretation of a newly enacted statute as well as the opportunities and ethical risks the resulting uncertainty creates for lawyers of all ages and experience levels. Moderator: Robert Russell, alliantgroup, Washington, DC Panelists: William Wilkins, PwC, Washington, DC; Brian Harvel, Alston & Bird, Atlanta, GA; Heather Fincher, BakerHostetler, Washington, DC; Katie O’Grady, Equifax, Atlanta, GA


Session : ABATX18140
Corporate Tax
Conference : 2018 Fall Tax Meeting
Speaker(s) :
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$45.00


  • Chair: Steve Fattman, EY, Washington, DC
  • Special Issues Under the 2017 Tax Act. This panel will explore some of the unresolved issues arising under the 2017 Tax Act. Such issues may include the application of the holding period requirement of the new section 245A deduction for dividends received from certain foreign corporations (including deemed dividends under revised section 964(e)), the application of section 1059 in cases in which section 245A applies to such dividends, and double tax issues resulting from triggering pre-2017 Tax Act gain recognition agreements, and the post-2017 Tax Act role of section 367(b). Moderator: Audrey Nacamuli Charling, General Electric Company, Norwalk, CT Panelists: Erik Corwin, KPMG, Washington, DC; Martin Hunter, PwC, New York, NY; Brett York, Associate International Tax Counsel, Office of Tax Policy, Department of Treasury, Washington, DC; Lisa Zarlenga, Steptoe & Johnson, Washington, DC; Brenda Zent, Special Advisor to the International Tax Counsel, Office of Tax Policy, Department of Treasury, Washington, DC
  • Current Developments in Corporate Tax. This panel will discuss a number of interesting PLRs and notices from the IRS dealing with section 355 transactions, including PLRs presenting issues under the business purpose requirement and the device prohibition, rulings issued under the new Transactional Ruling program (Rev. Proc. 2017-52), recent Treasury and IRS pronouncements regarding the no net value regulations, and the recently issued May Company regulations, and issues involving the interplay of new section 163(j) and section 382. Moderator: Derek Cain, PwC, Washington, DC Panelists: Mark Schneider, Deloitte LLP, Washington, DC; Rachel Kleinberg, Davis Polk & Wardwell, Menlo Park, CA; Robert H. Wellen, IRS Associate Chief Counsel (Corporate), Washington, DC


Session : ABATX18141
Employee Benefits
Conference : 2018 Fall Tax Meeting
Speaker(s) :
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$45.00


  • Chair: Bret Hamlin, Hill Ward Henderson, Tampa, FL
  • Employment and Benefits Developments for Non-Traditional Employment Relationships. This panel will discuss the DOL final rule on Association Health Plans, worker classification in the Gig economy and the use of multiple employer plans to provide benefits to workers in the Gig economy. Moderator: Stefan P. Smith, Locke Lord LLP, Dallas, TX Panelists: Yelena F. Gray, Nixon Peabody LLP, Chicago, IL; J. Marc Fosse, Trucker Huss APC, San Francisco, CA; Robert J. Toth Jr., Law Office of Robert J. Toth Jr. LLC, Fort Wayne, IN
  • Impact of #MeToo on Executive Compensation – Clawbacks and More. This panel will address the #MeToo movement and its impact on executive compensation planning and related corporate governance matters. Matters to be addressed include recent leadership changes at major companies, legislative responses and changes to employment agreements and clawback policies. Moderator: Andrew Liazos, McDermott Will & Emery, Boston, MA Panelists: Renata Ferrari, Ropes & Gray LLP, Boston, MA; John Utz, Utz and Lattan LLC, Overland Park, KS
  • Moving Expenses, Meals, Commuting, Entertainment, Leave, De Minimis Fringes, 162(m) and 83(i), Oh My! Your Just-in-Time 2017 Tax Act Guidance Primer. This panel will provide hot-off-the-press, up-to-the-minute analysis of guidance issued under the 2017 Tax Act. Moderator: Erin M. Sweeney, Miller & Chevalier Chartered, Washington, DC Panelists: Rebecca S. Coccaro, Sullivan & Cromwell LLP, Washington, DC; Jason E. Russell, Deloitte Tax LLP, San Francisco, CA


Session : ABATX18142
Fiduciary Income Tax and Income & Transfer Tax Planning Group
Conference : 2018 Fall Tax Meeting
Speaker(s) :
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$45.00


  • 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
  • Current Developments. AK and Nick will review current developments in fiduciary income tax and Cathy Hughes will update the committee on developments within the Treasury and the Service including the new proposed section 199A regulations. Panelists: Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC; Anna Katherine (AK) Moody, Venable LLP, Washington, DC; Nicholas A. Jacobus, Venable LLP, Los Angeles, CA
  • Can You Keep a Secret? Working with Silent Trusts. This panel will provide a thorough and practical guide to working with so-called “silent trusts,” including a discussion of the key obligations that fiduciaries need to grasp and meet to avoid liability and defend against beneficiary claims, the ways in which these obligations can vary between jurisdictions, and how to avoid being caught between the settlor’s directions and the duties imposed under governing law. Panelists: Nicole Mann, McDermott Will and Emery, Chicago, IL; Stacey Delich-Gould, Capital Group Private Client Services, New York, NY
  • Trusts and the Transition Tax: Everything You Didn’t Want to Know. Section 965 (the “transition tax”) added new complexity to the Internal Revenue Code for taxpayers with interests in foreign corporations. Trusts face unique challenges when approaching transition tax issues. This session will provide a brief primer on section 965 and address trustee considerations for the current year and going forward: reporting issues, paying the tax, and transferring property that is subject to 965(h) installment payments or 965(i) deferral. Panelist: Jennifer Einziger, EY, Washington, DC
  • The Tax Overhaul for Tax Exempts: What You Need to Know Now. Whether you work with tax exempt organizations or their donors, you likely have been getting questions about the new tax law. Donors want to maximize the tax benefits of giving. Nonprofits want to minimize unrelated business taxable income or “UBTI.” And colleges are concerned about the new endowment tax. Come discover the story behind the story and hear the latest on how the nonprofit sector is navigating the tax overhaul. Panelist: Diana Myers, Northern Trust, Chicago, IL


Session : ABATX18143
Pro Bono & Tax Clinics
Conference : 2018 Fall Tax Meeting
Speaker(s) :
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$45.00


  • Chair: Susan Morgenstern, IRS Taxpayer Advocate Service, Cleveland, OH
  • Canceled Debt Reporting Under IRC Section 6050P. Disputed cancellation of debt income is an issue frequently encountered in tax controversy work. Debt collectors and creditors who issue Form 1099-C Cancellation of Debt often do so absent an actual cancellation, discharge, or extinguishment of indebtedness, causing taxpayers to face liability for tax on canceled debt income while simultaneously facing continued collections actions by the debt collector. Additionally, taxpayers who receive a Form 1099-C often do not understand that mere receipt of the form does not automatically require including in gross income the amount reported in the form. This panel will discuss controversies that may arise as the result of Form 1099-C, ambiguities found in Treas. Reg. section 1.6050P-1, and areas for potential improvement in the cancellation of debt reporting regime. Moderator: Professor Christine Speidel, Villanova University Charles Widger School of Law, Villanova, PA Panelists: Christina Glendening, IRS Office of Chief Counsel, Washington, DC; Kristie Iatrou, Mondrik & Associates, Austin, TX; Fran Mordi, Mortgage Bankers Association, Washington, DC; Professor Sonya Watson, William S. Boyd School of Law, Las Vegas, NV
  • Tax Consequences of Student Loan Debt Cancellation. This panel will discuss cancelled student loan debt from cradle to grave. The panel will begin with a discussion of the expanding student loan debt crisis writ large, as well as some of the means for discharging student loan debts (for example, the “defense to repayment” process in the Higher Education Act). The panel will then discuss the tax consequences of the various student loan cancellation provisions, including how to report them and when they may or may not be taxable. Lastly, the panel will talk about potential legislative or advocacy fixes for the looming student debt issues. Moderator: Professor Caleb Smith, University of Minnesota Law School, Minneapolis, MN Panelists: Professor Ted Afield, Georgia State University Law School, Atlanta, GA; Toby Merrill, Legal Services Center of Harvard Law School, Jamaica Plain, MA; Vijay Raghavan, Illinois Attorney General’s Office, Chicago, IL
  • Jurisdictional Ramifications of a CDP Request. Upon receipt of a section 6320 or 6330 Notice from the IRS offering a Collection Due Process hearing, the taxpayer must send in the CDP request (usually using Form 12153) within 30 days of the notice. The IRS has mostly taken the position that the taxpayer must mail the notice to the “right” place within the IRS in order for the Tax Court to have jurisdiction over a CDP case should the taxpayer file a Tax Court petition following the CDP hearing with Appeals. Can the IRS administrative rules dictate to a court when it has jurisdiction? Is the IRS consistent in the application of its rules? Do its rules make sense? Recent cases cast doubt on the ability of the IRS to dictate to the Tax Court which cases meet the jurisdictional requirement and cast doubt on the way in which the IRS applies its own rules. This panel will discuss the issue and the cases challenging the position of the IRS. Moderator: Omeed Firouzi, Christine A. Brunswick Public Service Fellow, Philadelphia Legal Assistance, Philadelphia, PA Panelists: Professor T. Keith Fogg, Legal Services Center of Harvard Law School, Jamaica Plain, MA; Additional panelist TBD


Session : ABATX18144
Sales, Exchanges & Basis
Conference : 2018 Fall Tax Meeting
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  • Chair: Glenn M. Johnson, EY, Washington, DC
  • 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. Panelists: David Shechtman, Drinker Biddle & Reath LLP, Philadelphia, PA; E. John Wagner II, Williams Parker Harrison Dietz & Getzen, Sarasota, FL
  • The Interaction of Section 267, 1031 and 1033 with the Qualified Business Income Limitation. One planning technique to seek to maximize a qualified business deduction for rental real estate, and other non-laborintensive businesses is obtaining limitation under the section 199A(b) (2)(B)(ii) item equal to 2.5% unadjusted basis of qualified property whose depreciable period has not yet expired. The panelists will discuss this limitation, including the possible scope of regulations under section 199A(h)(1) to prevent extension of the depreciable period by purchases from section 267 – related parties, and under section 199A(h)(2) to coordinate the unadjusted basis computation with sections 1031 and 1033 non-recognition exchanges. Moderator: Rafi Mottahedeh, Cargill, Chicago, IL Panelist: Alfred Bae, EY, Houston, TX
  • Deferring and Reducing Income Taxes on Non-Opportunity Zone Property, and Eliminating Income Taxes on Opportunity Zone Property, Through Qualified Opportunity Funds. Upon the sale of appreciated property, the seller can defer tax until 2026, and reduce the amount of such deferred tax by up to 15%, by investing the amount of gain in a qualified opportunity fund. If the fund interest is itself held for 10 years, gain on the fund (though not on any original rolled-over gain) can be completely excluded. Panelists will discuss the opportunities, limitations and uncertainties in achieving these favorable tax deferrals, reduced rates, and complete exemptions. Also discussed will be the possible benefits and detriments of deferring gain arising from a real estate sale, through investing in a qualified opportunity fund that will own replacement real estate, as an alternative to directly investing in replacement real estate under section 1031. Moderator: Alan S. Lederman, Gunster, Fort Lauderdale, FL Panelists: Matthew E. Rappaport, Falcon Rappaport & Berkman PLLC, New York, NY; Julie Hanlon-Bolton, Special Counsel, IRS Associate Chief Counsel (Income Tax & Accounting), Washington, DC
  • Handling Associated Personal Property in Real Estate Contracts. Beginning in 2018, the federal tax law has created even greater divergent tax treatment between personal and real property acquired as part of the same transaction: personal property is now eligible for immediate expensing, and personal property is no longer eligible for section 1031 like-kind exchange treatment. Moreover, state laws, such as sales taxes and recording of security interests, likewise typically create greatly divergent rules for personal property and real property. The panelists will discuss the possible advisability to parties to a real estate contract of separating the real property from the associated personal property as clearly as possible, such as by separately identifying, appraising in a cost segregation engineering study, contracting for, transferring, and planning is a different ownership entity, personal property and real property acquired as part of the same transaction. Panelists: Steve Breitstone, Meltzer Lippe Goldstein & Breitstone, Mineola, NY; David Shechtman, Drinker Biddle, Philadelphia, PA



     


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