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2019 Midyear Meeting - Full package download for $249.00 ($299.00 post meeting)

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(c) [2019] 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.

$249.00



Showing sessions 21 - 30 of (45) TOTAL sessions
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Event : ABATX41


Session : ABATX1921
Estate & Gift Taxes and Fiduciary Income Tax
Conference : 2019 Midyear Meeting
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  • Estate & Gift Tax Chairs: George D. Karibjanian, Franklin Karibjanian & Law PLLC, Boca Raton, Florida/Washington, DC; Hannah W. Mensch, Ehrenkranz Partners, New York, NY Fiduciary Income Tax Chair: Stacey Delich-Gould, Capital Group Private Client Services, New York, NY
  • GRATs and the Mathematics of Failure. Grantors of underwater grantor-retained annuity trusts ( "GRATs") are often faced with two choices: let the GRAT ride out its course in the hopes that its underlying assets will appreciate rapidly enough to create a successful remainder or halt the GRAT by using a note or a swap power and effectively let it fail. This presentation will show that there is only one rational choice: if a two-year GRAT is to be successful at transferring wealth to its remainder beneficiaries, it must achieve significant positive returns in its first year; otherwise, its chances of success (or even breaking even) are staggeringly improbable. Using quantitative analysis to help guide us, we will help grantors know with more precision if and when a GRAT will fail and what to do about it. While quantitative in approach, no prior mathematics background is required. Panelist: Brad Dillon, Brown Brothers Harrisman & Co., New York, NY


Session : ABATX1922
Employment Taxes
Conference : 2019 Midyear Meeting
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  • Chair: Edward J. Leyden, Leyden Law LLC, Washington, DC
  • IRS Employment Tax Update. Senior IRS officials provide an overview of important developments since the October 2018 Meeting, including pertinent Supreme Court decisions, guidance projects in connection with the 2017 Tax Act, and proposed legislation, such as the proposed EMPOWHER ACT. Speaker: Edward J. Leyden, Leyden Law LLC, Washington, DC
  • Current Developments in Federal Employment and Payroll Tax Enforcement. The IRS has been increasingly diligent in enforcing employment and payroll tax compliance. This panel will discuss challenges both to practitioners and to enforcement agents, alike. Speaker: Chaya Kundra, Kundra Tax Law LLC, Rockville, MD
  • Update on the 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. Speaker: Edward Leyden, Leyden Law LLC, Washington, DC


Session : ABATX1923
Standards of Tax Practice
Conference : 2019 Midyear Meeting
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  • Chair: Rachel L. Partain, Caplin & Drysdale Chartered, New York, NY
  • Ethical Issues in Federal Tax Practice – The Government Perspective. This panel will discuss issues of concern and areas of focus for the IRS Office of Professional Responsibility and Office of Chief Counsel and provide an update on recent guidance from the IRS and the Department of Treasury and pending cases that relate to tax practice standards. Moderator: Matthew S. Cooper, EY, Washington, DC Panelist: Hollie M. Marx, Senior Technician Reviewer, Office of Chief Counsel (P&A), IRS, Washington, DC
  • The All New Two-Minute Drills. Come on down and watch our Champions compete on Celebrity Jeopardy! This panel will be a fun take on two-minute drills covering a potpourri of ethics-related issues, particularly client confidences. All members of our studio audience will receive ethics credits. Moderator: Scott Michel, Caplin & Drysdale Chartered, Washington, DC Panelists: Frank Agostino, Agostino & Associates, Hackensack, NJ; Professor Linda M. Beale, Wayne State University Law School, Detroit, MI; Diana L. Erbsen, DLA Piper, New York, NY
  • I'm a US Lawyer, What's the EU Got To Do With Me? – Navigating Ethics in Global Practice. This panel will look at various international initiatives implementing increased tax transparency measures that have potential ethical impact on US tax professionals, including lawyers. Presenters will focus on the recently implemented EU mandatory disclosure rules and similar measures that might impose obligations on US lawyers and raise delicate ethical issues. A practical discussion will give attendees a sense of best practices and audience engagement is encouraged! Moderator: Jeremiah Coder, Organisation for Economic Co-operation and Development (OECD), Paris, France Panelists: Dèlcia M. Capocasale, Cuatrecasas, New York, NY; Alan Winston Granwell, Holland & Knight, Washington, DC; Kat Saunders Gregor, Ropes & Gray, Boston, MA
  • Co-sponsored by: Foreign Lawyers Forum


Session : ABATX1924
Employee Benefits
Conference : 2019 Midyear Meeting
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  • Chair: Bret Hamlin, Hill Ward Henderson, Tampa, FL
  • Student Loan Repayment Benefits: Options and Issues for Retirement Plans. The IRS 401(k) student private letter ruling employer programs has heightened interest employer interest to subsidize student loan debt repayments through qualified retirement plans. This panel will address the matters that an employer should consider before proceeding with a student loan repayment benefit program involving a 401(k) plan, including nondiscrimination, prohibited transaction and the contingent benefit rules and administrative issues with respect to tracking student loan repayments and communicating with employees. The panel will also address efforts to expand the planning concepts from this ruling to other contexts, including ABLE accounts. Moderator: Andrew C. Liazos, McDermott Will & Emery LLP, Boston, MA Panelists: Jenny Baker, Abbott Laboratories, Chicago, IL; Carol Weiser, Acting Benefits Tax Counsel, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC; Victoria Judson, Associate Chief Counsel, Employee Benefits, Exempt Organizations and Employment Taxes, Office of Chief Counsel, IRS, Washington, DC; Jeff Holdvogt, McDermott Will & Emery LLP, Chicago, IL; Will Hansen, The ERISA Industry Committee, Washington, DC
  • The Wellness Program Wild, Wild West. Although wellness programs have become increasingly regulated over the years, it is the absence of regulations for the upcoming 2019 plan year that is bedeviling wellness program sponsors. The judicial rejection of the Equal Employment Opportunity Commission’s regulation purporting to define voluntariness under the Americans with Disabilities Act and the Genetic Information Nondiscrimination Act coupled with the likely absence of EEOC guidance regarding voluntariness until 2021, is causing wellness program sponsors to reconsider incentives for health risk assessments and to proceed cautiously with medical examinations for the 2019 plan year. Never fear, this panel is here! Our panelists will discuss strategies for surviving (and thriving!) during the Wellness Program Wild, Wild, West. Moderator: Erin M. Sweeney, Miller & Chevalier Chartered, Washington, DC Panelists: Audrey A. Browne, Browne Legal Consulting PLLC, Brooklyn, NY; Linda R. Mendel, Vorys Sater Seymour and Pease LLP, Columbus, OH; Alan Tawshunsky, Tawshunsky Law Firm PLLC, Washington, DC
  • 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: Carol Weiser, Acting Benefits Tax Counsel, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC; Victoria Judson, Associate Chief Counsel, Employee Benefits, Exempt Organizations and Employment Taxes, Office of Chief Counsel, IRS, Washington, DC; Stephen Tackney, Deputy Associate Chief Counsel, (Employee Benefits), Employee Benefits, Exempt Organizations and Employment Taxes, Office of Chief Counsel, IRS, Washington, DC; Jeanne Klinefelter Wilson, Deputy Assistant Secretary for Policy, Employee Benefits Security Administration, Department of Labor, Washington, DC (Invited); John Menke, Assistant General Counsel, Pension Benefit Guaranty Corporation, Washington, DC (Invited)


Session : ABATX1925
State & Local Taxes
Conference : 2019 Midyear Meeting
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  • Chair: Edward J. Bernert, BakerHostetler, Columbus, OH
  • Murphy v. NCAA: Implications for State and Local Taxation. In Murphy v. NCAA, the Supreme Court held that Congress could not prohibit states from legalizing sports betting. Commentators have suggested that Murphy’s logic, if taken to its conclusion, calls into question federal limits on state taxing power, such as P.L. 86-272 or 4 U.S.C. 114’s limitation on taxation of non-domiciliary pension distributions. This panel will discuss the anti-commandeering principle that drove the decision, the distinction the Court made between impermissible commandeering and run-ofthe- mill preemption, and the implications of that distinction for Congress’s ability to prohibit certain forms of state taxation. Moderator: Mark F. Sommer, Frost Brown Todd LLC, Louisville, KY Panelists: Professor Brannon P. Denning, Samford University, Cumberland School of Law, Birmingham, AL; Joe Huddleston, EY, Washington, DC
  • The Next Generation of SALT Issues. Tax principles come and go and sometimes the newest issues in SALT arise from an existing tax application being adapted or redirected to another tax. The next generation of SALT professionals will share developing topics including: the taxation of streaming services, the economic substance doctrine in state and local taxes, and looking ahead in the application of the Texas Franchise (Margin) Tax. Moderator: Stephanie Lipinski Galland, Williams Mullen, Washington, DC Panelists: William J. Kolarik II, Kean Miller LLP, Baton Rouge, LA; Nicholas J. Souza, Mondrik & Associates, Austin, TX; Justin B. Stone, Eversheds Sutherland, New York, NY
  • Wheel of Ethics: Take A Spin And See What Ethical Dilemma Awaits You.  Using a game show style format, this session will focus on ethical issues and standards that tax practitioners need to know regarding the rules of confidentiality and privilege. Moderator: Debra Silverman Herman, Hodgson Russ LLP, New York, NY Panelist: David A. Hughes, Horwood Marcus & Berk Chartered, Chicago, IL


Session : ABATX1926
Closely Held Businesses II
Conference : 2019 Midyear Meeting
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  • Chair: Shawn L. McIntire, Velocity Global LLC, Denver, CO
  • Real Life Issues Under 199A. This panel will address various real life issues under Section 199A. Specifically, the panel will discuss actual client questions and concerns regarding the application of Section 199A to particular types of businesses and structures. For example, how do the W2 and UBIA limits apply to a real estate empire with a separate management company? Is the Section 199A deduction available for businesses engaged in the cannabis business? Do service provider clients need to review existing service agreements to maximize their Section 199A deduction? Panelists: Elizabeth Stieff, Venable LLP, Baltimore, MD; Emily Murphy, Plante Moran, Ann Arbor, MI; James Combs, Honigman Miller Schwartz and Cohn LLP, Detroit, MI; Kimberly Arndt, PwC, Washington, DC
  • Buy-Sell Agreements for Closely Held Businesses. This panel will review practical issues and tax considerations when assisting clients with succession planning, and specifically with drafting and putting into place a buy-sell agreement for closely held business owners. The panel will also review valuation issues and funding mechanisms for practitioners to consider. Panelists: Morgan L. Klinzing, Pepper Hamilton LLP, Philadelphia, PA; Adam L. Abrahams, Meyers Hurvitz Abrahams LLC, Rockville, MD; J. Robert Turnipseed, Armbrecht Jackson LLP, Mobile, AL


Session : ABATX1927
Court Procedure & Practice
Conference : 2019 Midyear Meeting
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  • 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: Drita Tonuzi, Deputy Chief Counsel (Operations), IRS, Washington, DC; Gil Rothenberg, Chief, Appellate Section, Department of Justice, Tax Division, Washington, DC; Hannah Hawkins, Acting Deputy Tax Legislative Counsel, Department of Treasury, Washington, DC; The Honorable L. Paige Marvel, US Tax Court, Washington, DC
  • Employment Tax Litigation. More than one-third of the country’s workers participate in the gig economy. The gig economy also called the “sharing economy,” is the environment where workers engage in temporary jobs fueled by Smartphone apps and online platforms. The trend has led to an increase in employment tax controversies because many employers treat gig economy workers as independent contractors, as opposed to employees. The tax stakes are high because employers must pay a share of payroll taxes for workers while providing them with the fringe benefits traditionally offered to employees. The gig economy raises other tax issues, including the deductions that can be claimed by taxpayers who hold these jobs. This session will review the life-cycle of an employment tax case from to the SS-8 Program through the Tax Court trial, including settlement programs offered by the IRS to employers and employees and unexpected twists resulting from identity theft and immigration laws that affect worker classification. Moderator: Frank Agostino, Agostino & Associates, Hackensack, NJ Panelists: Monica Koch, Senior Trial Attorney, Office of Area Counsel, Westbury, NY; Anna C. Tavis, Brooklyn Legal Services Corporation, Brooklyn, NY; Gary M. Slavett, Holtz Slavett & Drabkin, Beverly Hills, CA
  • Navigating Cross-Border Discovery Issues and the GDPR. At an increasing rate, US practitioners are facing matters, both civil and criminal, where the information they need or the IRS requests is located in a foreign jurisdiction. International audit requests and discovery presents complex and challenging issues for today’s tax litigators. With the Global Data Protection Regulation (GDPR) now in full effect as of May 25, 2018, as well as the data privacy laws of other countries like Mexico, practitioners face additional complications in gathering evidence and disclosing personal data to the IRS. This panel will explore how US discovery rules function outside of the US, the data collection procedures available through the Hague Convention and letters rogatory, obstacles to discovery under various countries’ data privacy laws and statutes, and how the GDPR, which covers data protection and privacy of all individuals within the EU as well as the export of personal data outside the EU, has, and will continue to, impact it all. Moderator: Arielle Borsos, Caplin & Drysdale, Washington, DC Panelists: Charles E. Hodges II, Jones Day, Atlanta, GA; Polly Sprenger, Katten Muchin Rosenman (UK), London, UK; Joseph A. Rillotta, Drinker Biddle, Philadelphia, PA; Nathaniel Parker, Senior Counsel, IRS Associate Chief Counsel, Washington, DC; Robert Kovacev, Norton Rose Fulbright, Washington, DC


Session : ABATX1928
Financial Transactions
Conference : 2019 Midyear Meeting
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  • Chair: Craig Gibian, Deloitte Tax LLP, Washington, DC
  • Section 163(j) and other 2017 Tax Act Topics of Interest. This panel will discuss issues relating to the proposed regulations under section 163(j) from a financial transactions perspective, including the definition of “interest” for this purpose. The panelists may also address other provisions relating to financial instruments, such as the derivatives provisions of the BEAT. Moderator: Erika Nijenhuis, Cleary Gottlieb Steen & Hamilton LLP, New York, NY Panelists: Mark Erwin, Deputy Associate Chief Counsel (Financial Institutions and Products), IRS, Washington, DC; Nathan Tasso, Shearman & Sterling LLP, Washington, DC; Brett York, Department of the Treasury, Washington, DC (Invited)
  • Estate of Andrew J. McKelvey v. Commissioner and Other Derivative Transactions . This panel will explore the recent decision in Estate of Andrew J. McKelvey v. Commissioner where the Second Circuit overturned a Tax Court decision by holding that the modification of variable prepaid forward contracts (VPFCs) resulted in a termination of the original VPFCs. In addition to discussing the court’s reasoning, the panelists will explore the impact of the decision on other issues such as (i) the modification of other derivatives, such as options and swaps, and (ii) the character of any resulting income/deduction/gain/loss. Moderator: Michael Yaghmour, EY, Washington, DC Panelists: Kristen Garry, Shearman & Sterling LLP, Washington, DC; Christina Lizza, PwC, Washington, DC
  • The Role of Financial Instruments in a Cross-Border Context. This panel will consider financial instruments and transactions in a post-tax-reform world, including topics such as the scope of the hybrid provisions under sections 245A(e) and 267A, opportunities and issues under GILTI, and the placement of leverage and hedges in multi-national groups. Moderator: Pamela Endreny, Skadden Arps Slate Meagher & Flom LLP, New York, NY Panelists: John Bates, Deloitte Tax LLP, Washington, DC; Aaron Junge, PwC, Washington, DC


Session : ABATX1929
Insurance Companies
Conference : 2019 Midyear Meeting
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  • Chairs: Ann Cammack, EY, Washington, DC; Sheryl Flum, KPMG, Washington, DC
  • Update on Insurance Company Tax. This panel will discuss current issues related to determining taxable income for life and non-life insurance companies. Panelists will focus on the impact of the 2017 Tax Act. Moderator: Sheryl Flum, KPMG LLP, Washington, DC Panelists: Julie Gackenbach, Confrere Strategies, Washington, DC; Mark Smith, PwC, Washington, DC; Angela Walitt, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC
  • Investment Tax Issues for Insurance Companies. This panel will review changes to the taxation of investments made by the 2017 Tax Act and how these changes impact insurance companies. Moderator: Graham Green, Eversheds Sutherland (US) LLP, Washington, DC Panelist: Jean Baxley, Deloitte LLP, Washington, DC; Roger Wise, Willkie Farr & Gallagher LLP, Washington, DC; Michael A. Mingolelli Jr., Winged Keel Group, Boston, MA
  • BEAT and GILTI Issues for Insurance Companies. This panel will discuss the latest guidance related to the application of BEAT and GILTI to insurance companies. Moderator: Ted Clabault, EY, Washington, DC Panelists: Clarissa Potter, KPMG LLP, New York, NY; Kriss Rizzolo, Eversheds Sutherland (US) LLP, New York, NY; Angela Walitt, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC


Session : ABATX1930
Partnerships & LLCs
Conference : 2019 Midyear Meeting
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  • Chair: Jennifer Alexander, Deloitte Tax LLP, Washington, DC
  • What You Need to Know About the Recent Guidance Issued Under the 2017 Tax Act. This panel will provide an overview of recently enacted rules in the areas of domestic and international partnership taxation under the 2017 Tax Act, focusing on guidance issued under these rules. Moderator: Jose Carrasco, Grant Thornton LLP, Washington, DC Panelists: Bryan Rimmke, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC (Invited); Meghan Howard, Office of Associate Chief Counsel (Passthroughs & Special Industries), IRS Office of Chief Counsel, Washington, DC (Invited); Sam Kamyans, Baker McKenzie LLP, Washington, DC; Matt Arndt, PwC, Washington, DC
  • How the Recent Guidance Issued Under the 2017 Tax Act Has Impacted Transactions. This panel will apply the rules discussed in the first panel to domestic and international fact patterns, highlighting structural opportunities and issues. Moderator: Dana Trier, Davis Polk & Wardwell LLP, New York, NY Panelists: Bahar Schippel, Snell & Wilmer LLP, Phoenix, AZ; David H. Schnabel, Davis Polk & Wardwell LLP, New York, NY; Diana Doyle, Latham & Watkins LLP, Chicago, IL; Ari Berk, Deloitte Tax LLP, Washington, DC
  • How the Recent Guidance Issued Under the 2017 Tax Act Has Impacted Transactions (Cont’d). This panel will apply the rules discussed in the first panel to domestic and international fact patterns, highlighting structural opportunities and issues. Moderator: Dana Trier, Davis Polk & Wardwell LLP, New York, NY Panelists: Bahar Schippel, Snell & Wilmer LLP, Phoenix, AZ; David H. Schnabel, Davis Polk & Wardwell LLP, New York, NY; Diana Doyle, Latham & Watkins LLP, Chicago, IL; Ari Berk, Deloitte Tax LLP, Washington, DC



     


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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.