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2019 Midyear 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.

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Showing sessions 21 - 30 of (43) TOTAL sessions
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Event : ABATX41


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: Paul Butler, Kostelanetz & Fink LLP, 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; Jeff Holdvogt, McDermott Will & Emery LLP, Chicago, IL; Will Hansen, The ERISA Industry Committee, Washington, DC; J. Mark Iwry, Brookings Institute, Washington, DC; Aliyah Wong, US Chamber of Commerce, Washington, DC (Invited)
  • 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: 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: TBD
  • 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 Panelist: Nathan Tasso, Shearman & Sterling LLP, Washington, DC
  • 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
  • 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


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: Sam Kamyans, Baker McKenzie LLP, Washington, DC; Nancy Langdon, 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


Session : ABATX1931
Tax Accounting
Conference : 2019 Midyear 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 Atlanta in October. 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: Stanley Barsky, Fox Rothschild LLP, New York, NY Panelists: David Schneider, Skadden Arp Slate Meagher & Flom LLP, Washington DC; Dana Flynn, PwC, New York, NY; Scott Dinwiddie, IRS Associate Chief Counsel (IT&A), Washington, DC; Kathleen Reed, Branch Chief Branch 7, IRS Office of Chief Counsel (IT&A), Washington, DC; Christopher Call, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC
  • Accounting Methods - Hot Topics. This panel will review the issues and opportunities related to filing accounting method changes for the upcoming 2018/2019 filing season. Topics will include discussions of accounting method changes stemming from the change in law under 2017 Tax Act including the evaluation of accounting method implications and procedural considerations. Moderator: Ryan Corcoran, RSM US LLP, Madison, WI Panelists: Connie Cheng, BDO LLP, Los Angeles, CA; Scott Mackay, EY, Washington, DC
  • Section 451 and Revenue Recognition. This panel will continue to build upon previous revenue recognition panels in light of the changes in law due to the enactment of 2017 Tax Act and the interaction with the rules under ASC 606. 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: Christine Turgeon, PwC, New York, NY Panelists: Sharon Kay, Grant Thornton LLP, Washington DC; Carol Conjura, KPMG, Washington, DC


Session : ABATX1932
Tax Collection, Bankruptcy and Workouts
Conference : 2019 Midyear Meeting
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  • Chair: Christin Bucci, Bucci Law Offices, Fort Lauderdale, FL
  • Bankruptcy Update. Decisions involving tax claims and bankruptcy over the last year as reviewed in the super blog, "Procedurally Taxing," will be discussed by Professor Fogg and the author of CCH’s digital bankruptcy book, Ken Weil. This presentation will make you the best informed controversy person in the room – you have the wild card and a courtroom – Bankruptcy Code trumps the Internal Revenue Code. Moderator: Christin Bucci, Bucci Law Offices, Fort Lauderdale, FL Panelists: Professor T. Keith Fogg, Harvard Law School, Jamaica Plain, MA
  • Recent Developments in Tax Collection Litigation. A review of how the Tax Court treated taxpayers contesting adverse CDP hearings over the past year, and updates on the burden of proof, how the Tax Court views its role in reviewing the record during the CDP hearing, and more. Moderator: Christin Bucci, Bucci Law Offices, Fort Lauderdale, FL Panelists: Eli S. Noff, Frost & Associates LLC, Columbia, MD; Wm. Robert Pope, White & Reasor, Nashville, TN
  • IRS Collection Programs and Objectives in 2019. A discussion, led by the Director of Field Collection, that will provide an update on IRS enforcement efforts within the collection division, including imminent hiring, additional training, and plans to pursue nonpayment of employment taxes. The panelists will also discuss suits and fraud referred by revenue officers and what to expect now that the IRS is certifying tax debts to the State Department to revoke taxpayers’ passports. Moderator: Christin Bucci, Bucci Law Offices, Fort Lauderdale, FL Panelists: Eli S. Noff, Frost & Associates LLC, Columbia, MD; Wm. Robert Pope, White & Reasor, Nashville, TN
  • Update on Corporate Debt Restructurings. Large corporate bankruptcies are back in the news. Sears and other large retailers have recently filed. With increases in interest rates, the phenomenon could hit other industries. The panel will discuss existing tax rules that are relevant to corporate bankruptcies and debt workouts, such as the cancellation of debt (COD) rules. Also to be discussed are the limitations on the use of net operating losses (NOLs) (section 382 and the new 80% limit introduced by the 2017 Tax Act). In addition, recent cases on the ownership of an NOL carryback (e.g., Rodriguez v. FDIC) will be discussed. Moderator: Lee G. Zimet, Alvarez and Marsal Taxand LLC, Morristown, NJ Panelist: The Honorable Mark S. Wallace, Judge, U.S. Bankruptcy Court for the Central District of California, Santa Ana, CA; Patrick Hoehne, Alvarez and Marsal Taxand LLC, San Francisco, CA



     


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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.