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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 31 - 40 of (45) TOTAL sessions
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Event : ABATX41


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
  • Inventory - Hot Topics. 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 other inventory guidance issued. 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: Scott Rabinowitz, Skadden Arp Slate Meagher & Flom LLP, Washington, DC Panelists: Les Schneider, Ivins Phillips & Barker, Washington, DC; Kari Peterson, PwC, Atlanta, GA; Natasha Mulleneaux, Attorney, Branch 6, 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, Madison, WI Panelists: Connie Cheng, BDO LLP, Los Angeles, CA; Scott Mackay, EY, Washington, DC; Scott Dinwiddie, IRS Associate Chief Counsel (IT&A), Washington, DC; Anna Gleysteen, Attorney, Branch 6, IRS Office of Chief Counsel (IT&A), Washington, DC; Christopher Call, Attorney-Advisor, Office of Tax Policy, Department of Treasury, 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; Scott Dinwiddie, Associate Chief Counsel (IT&A), Washington, DC; Charles Gorham, Senior Attorney, Branch 1, IRS Office of Associate Chief Counsel (IT&A), Washington, DC; Christopher Call, Attorney-Advisor, Office of Tax Policy, Department of Treasury, 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; Kenneth C. Weil, Law Office of Kenneth C. Weil, Seattle, WA
  • 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: Darren John Guillot, Director, IRS Field Collection Operations, Washington, DC; 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


Session : ABATX1933
Tax Exempt Financing
Conference : 2019 Midyear Meeting
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  • Chair: Todd Cooper, Locke Lord LLP, Cincinnati, OH
  • Legislative, Treasury and Internal Revenue Service Update. This panel will discuss new legislative initiatives that might affect tax exempt financing, the TEFRA regs, the reissuance regs, the Committee’s remedial action comments, the Chief Counsel Memorandum on a tax exempt advance refunding of a taxable bond, PLR 201847001 and “floating equity” for exempt facility bonds, the IRS Snapshot on Federal Use of Tax-Exempt Financed Prison Facilities, the IRS Snapshot on Private Business use and Management Contracts, the overlap of Opportunity Zones and tax exempt finance, Savidge v. U.S. , and other guidance and new developments in the tax exempt bond area. Moderator: Todd L. Cooper, Locke Lord LLP, Cincinnati, OH Panelists: John Cross III, Office of Tax Policy, Department of Treasury, Washington, DC; Spence Hanemann, Special Technical Reviewer, Branch 5, Financial Institutions & Products, IRS, Washington, DC; Telly Meier, Field Operations Manager, IRS Office of Indian Tribal Governments/Tax-Exempt Bonds, Washington, DC; Mark O. Norell, Ballard Spahr LLP, New York, NY
  • A Deep Dive into Tax Increment Financing. This panel will extensively explore the private use, private payment, and private loan analysis of a tax exempt tax increment financing (TIF) across a spectrum of TIF fact patterns, including: a review of the basic rules, the special rules for PILOTs, the impermissible agreement rules, the overlap between a TIF and a special assessment, expenditure rules, unrelated and disproportionate use rules, and the anti-abuse rules. Fact patterns to be discussed include: a TIF with a grant to the developer, variations on Development Agreements, developer ownership of the bonds, residual rights of the developer in the tax payment stream, multiple projects, and multiple grants. Moderator: Chas Cardall, Orrick Herrington & Sutcliffe, San Francisco, CA Panelists: Kimberly C. Betterton, Ballard Spahr LLP, Baltimore, MD; Matthias Edrich, Kutak Rock LLP, Denver, CO


Session : ABATX1934
Foreign Lawyers Forum
Conference : 2019 Midyear Meeting
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  • Chair: Laura Gould, Reed Smith LLP, London, United Kingdom
  • Holding Companies – What to do After BEPS and US Tax Reform? Hold on to your hats - 2019 is set to be yet another eventful year in the world of international tax! With various EU anti-avoidance measures under ATAD already in force, revised bilateral tax treaties modified by the MLI coming into force in certain jurisdictions and not forgetting the UK’s imminent departure from the EU, there is much for US multinational enterprises to be mindful of. Set against this ever-changing political and tax landscape, this panel will guide you through the impact BEPS and US tax reform is having on international holding company structures in practice. Using case studies, the panel will discuss the impact that CFC rules, anti-hybrid rules, interest deductibility limitations and the introduction of a principal purpose test in many bilateral tax treaties will have on holding company structures. The panel will address how these measures overlap with BEAT, GILTI, FDII, the US interest limitation rules and other proposals introduced by the 2017 Tax Act. The panelists will also consider the benefits of, and what the future may hold for, international holding companies for US multinationals. Moderator: Danielle Rolfes, KPMG, Washington, DC Panelists: Gareth Amdor, Reed Smith LLP, London, UK; Nina Kielman, NautaDutilh, Amsterdam, The Netherlands; Vincent van der Lans, Loyens & Loeff, New York, NY; Himanshu Sinha, Trilegal, New Delhi, India; James Somerville, A&L Goodbody, Dublin, Ireland


Session : ABATX1935
Diversity II
Conference : 2019 Midyear Meeting
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  • Chair: Lany L. Villalobos, Dechert LLP, Philadelphia, PA
  • Investing in Positive Social Impact. Can investments generate both business and social returns? This panel will provide an overview of impact investments, which direct capital to enterprises that generate social and environmental benefits, and their implications on charitable giving. The panelists will also discuss the use in New Orleans of the Low Income Housing Tax Credit program, created by the Tax Reform Act of 1986 to provide tax incentives for developers for the acquisition, rehabilitation, or new construction of rental housing targeted to low-income households. Moderator: Valerie Vlasenko, Agostino & Associates, Hackensack, NJ Panelists: Professor Khrista McCarden, Tulane University Law School, New Orleans, LA; Dr. Marla Nelson, University of New Orleans, New Orleans, LA; Hannah Adams, Southeast Louisiana Legal Services, New Orleans, LA
  • Avoiding Tax Litigation Through Financial Analysis: Tips for Advocating for Your Client’s Ability To Pay. After an assessment, taxpayers may provide the Internal Revenue Service with financial information about their ability to pay in order to avoid a levy or Notice of Federal Tax Lien. The panelists will provide an overview of when a Collection Information Statement is required, address the challenges that arise in preparing a Collection Information Statement, and discuss practical tips in gathering the necessary documentation to substantiate income and expenses to provide an accurate representation of a taxpayer’s ability to pay. Moderator: Catherine Sullivan, Law Clerk, US Tax Court, Washington, DC Panelists: Rion Daley, Revenue Officer, Small Business/Self-Employed Division, IRS, Miami, FL; Professor Patrick Thomas, University of Notre Dame Law School, South Bend, IN; Michael Wallace, Agostino & Associates, Hackensack, NJ


Session : ABATX1936
Teaching Taxation
Conference : 2019 Midyear Meeting
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  • Chair: Professor Kerry Ryan, Saint Louis University, Saint Louis, MO
  • Tax Advice in the Age of the 24-Hour News Cycle. Recent instances of exposure by the press of aggressive tax planning and tax avoidance by prominent businesses, individuals or families raise unique substantive, ethical, and other legal issues for the tax community. Practitioners advising famous clients may need to assess not only the likelihood of future examinations, but also public disclosure due to whistleblowers, cooperators, and data leaks. Reporters investigating past tax compliance may recruit tax professionals for technical assistance and expertise to uncover suspect transactions, unreported income, or improper deductions or credits. The release of such information, and related commentary from various media outlets, may pressure Federal and state tax authorities, law enforcement officials, or regulators to open audits or investigations that could result in substantial tax adjustments and/or various civil and criminal penalties. This panel will explore these issues from a variety of perspectives. Moderator: Professor Lee-Ford Tritt, University of Florida, Gainesville, FL Panelists: David Cay Johnston, DCReport.org, Rochester, NY; Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC; Michael H. Plowgian, KPMG LLP, Washington, DC; Professor Michael Lang, Chapman University, Orange, CA


Session : ABATX1937
Young Lawyers Forum
Conference : 2019 Midyear Meeting
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  • Chair: Micah Gibson, PwC, Washington, DC
  • IDRs vs. FDRs – IRS Tools to Discover Taxpayer Documents at Home and Abroad. (Young Lawyers) This panel will explore the rules and procedures the IRS uses to collect relevant taxpayer materials, as well as potential strategies for taxpayers in exam and future litigation to respond to such efforts by the IRS. This panel will specifically address the use of Information Document Requests and Formal Document Requests and their respective implications in civil proceedings. Moderator: Annie M. Wurtzebach, DLA Piper LLP, New York, NY Panelists: Sabrina Strand, Law Office of Joseph H. Thibodeau PC, Denver, CO; Jeffrey Dirmann, Agostino & Associates PC, Hackensack, NJ; Scott E. Fink, Greenberg Traurig LLP, New York, NY; Mark Eblen, Senior Counsel, Office of Chief Counsel (SB/SE), Louisville, KY (Invited)


Session : ABATX1938
Tax Practice Management
Conference : 2019 Midyear Meeting
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  • Tax Practice Management Chair: Roger Royse, Royse Law Firm, Menlo Park, CA
  • Advice for the 21st Century Tax Lawyer. This joint panel of the Young Tax Lawyers and Tax Practice Management Committees brings together leading tax practicioners to discuss lessons they have learned along the way as well as what it takes to succeed in the current tax and legal environment. Our panel will share their personal stories and relate their experiences to the future of tax law practice. Moderator: Carina Federico, Crowell & Moring LLP, Washington, DC Panelists: Catherine Engell, Bracewell LLP, New York, NY; Frank Jackson, Jones Day, New York, NY


Session : ABATX1939
Pro Bono & Tax Clinics
Conference : 2019 Midyear Meeting
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  • Chair: Susan Morgenstern, IRS Taxpayer Advocate Service, Cleveland, OH
  • Disability Severance Pay Refund Claims by Veterans. More than 130,000 US military veterans who were separated from service because of a medical disability are due federal income tax refunds for taxes they paid on Disability Severance Pay (DSP) that should not have been taxed. For those veterans who had taxes withheld from their DSP between 1991 and 2016, the Combat-Injured Veterans Tax Fairness Act of 2016 extends the period for affected veterans to file a claim for credit or refund of overpayments attributable to their DSP. A key aspect to these DSP refund claims is the required timeframes veterans have for filing claims: most veterans will need to file their claims within one year of July 2018 when letters were mailed. This panel will explain the claims process, issues associated with the claims, and other issues specific to veterans. Moderator: David Sams, Community Tax Law Project, Richmond, VA Panelist: Susan E. Mitchell, Senior Technical Advisor, Attorney Advisor Group, Taxpayer Advocate Service, IRS, Washington, DC Co-sponsored by: Individual & Family Tax
  • National Taxpayer Advocate’s Annual Report to Congress. Nina Olson will address the committee by videotape regarding the National Taxpayer Advocate’s annual report to Congress and highlight the most important features of the report. Ms. Olson’s Senior Advisor will be present to elaborate on key issues identified in the report. Panelist: Kenneth J. Drexler, Senior Advisor to the National Taxpayer Advocate, IRS, Washington, DC
  • Administrative Burden and Taxpayer Compliance: How to Improve the Taxpayer Experience. Administrative burden is a key variable in how citizens experience interactions with the state. Research from other disciplines has defined administrative burden and explored differing aspects of how those burdens affect people, including learning, psychological and compliance costs. In this panel we will explore the research around administrative burden more generally, consider its application in interactions with the IRS and taxpayers, including in the audit process, and offer suggestions on how IRS could reduce the incidence of these burdens on taxpayers, especially lower income taxpayers who are often least equipped to overcome those burdens. This is the second part of a two-part panel co-sponsored with the Individual & Family Tax Committee exploring burdens in the filing and compliance process. Moderator: Susan Morgenstern, Local Taxpayer Advocate, Taxpayer Advocate Service, IRS, Cleveland, OH Panelists: Professor Donald Moynihan, McCourt School of Public Policy, Georgetown University, Washington, DC and Visiting Professor, Oxford University, Oxford England; Professor Leslie Book, Charles Widger School of Law, Villanova University, Villanova, PA; Laura Baek, Acting Director, TAS Research and Analysis, Taxpayer Advocate Service, IRS, Washington, DC Co-sponsored by: Individual & Family Tax
  • Winner! Winner! Chicken Dinner! Living the Gaming Life . This panel will explore two different perspectives on the gambling industry: tax issues faced by those who gamble in casinos, and tax issues faced by those who make their living in the casino service industry. We will explore the tax treatment of winnings and losses for both amateur and professional gamblers including how to handle winnings and losses in an audit. We will also delve into tip income in the context of casino tip rate determination agreements and how to handle deemed tip income. Moderator: Anastasia Kolosova, Accounting Aid Society, Detroit, MI Panelists: Professor Sonya Watson, William S. Boyd School of Law, University of Nevada, Las Vegas, Las Vegas, NV; The Hon. Peter J. Panuthos, Special Trial Judge, US Tax Court, Washington, DC; Professor Kathryn Sedo, University of Minnesota Law School, Minneapolis, MN; Frank Agostino, Agostino & Associates PC Hackensack, NJ; Phillip Colasanto, Agostino & Associates PC, Hackensack, NJ


Session : ABATX1940
Civil & Criminal Tax Penalties
Conference : 2019 Midyear Meeting
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  • Chair: Niles A. Elber, Caplin & Drysdale, Washington, DC
  • Reports of Subcommittees on Important Developments. Important Developments (Civil) – Sara G. Neill and Michelle F. Schwerin, Capes Sokol PC, St. Louis, MO; Important Developments (Criminal) – Evan J. Davis, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA; International Tax Enforcement – Bruce Zagaris, Berliner Corcoran & Rowe LLP, Washington, DC and Joseph M. Erwin, Dallas, TX; IRS Investigations and Practices – Michael A. Villa Jr., Meadows Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TX and Eric L. Green, Green & Sklarz LLC, New Haven, CT; Legislative and Administrative Developments – Brian C. McManus, Latham & Watkins LLP, Boston, MA and Robert J. Kovacev, Steptoe & Johnson, Washington, DC; Monetary Violations and Forfeitures – Joseph A. Rillotta, Drinker Biddle & Reath LLP, Washington, DC; Offshore Compliance and Enforcement – Zhanna A. Ziering, Caplin & Drysdale Chtd, New York, NY and Michael Sardar, Kostelanetz & Fink LLP, New York, NY; Sentencing Guidelines – Matthew C. Hicks, Caplin & Drysdale Chtd, Washington, DC and Jeffrey A. Neiman, Marcus Neiman & Rashbaum, Fort Lauderdale, FL
  • Fixing Employment Tax Errors: Best Practices for Amending Employment Tax Returns, Avoiding Penalties and Communicating With Affected Employees. When an employer makes an error on its employment tax returns that error may have tax and penalty consequences for both the employer and its employees. There are a wide range of issues an employer must consider when amending its employment tax filings. This panel will discuss the range of civil penalties applicable to employment tax filings, tips for avoiding penalties and interest when filing amended employment tax returns, ethical issues that arise when employment tax errors are identified, and best practices for communicating with affected employees. Moderator: Brian C. McManus, Latham & Watkins LLP, Boston, MA Panelists: Hollie Marx, Senior Technician Reviewer, IRS Office of Chief Counsel, Washington, DC; Megan Marlin, PwC, Washington, DC; Steven P. Johnson, Morgan Lewis, Washington, DC
  • Obtaining a Declination of a Criminal Tax Case. Every indicted criminal tax case has survived multiple rounds of review within the IRS, the Department of Justice Tax Division and, often, the local US Attorney’s office. A key aspect of defending a criminal tax case is figuring out how to put the brakes on a prosecution before it formally begins by taking advantage of the opportunities to obtain a declination. This panel will cover strategies for making the most of each conference opportunity, including the motivations of each government stakeholder, and the considerations involved in deciding how much of the potential trial defense to reveal at each stage. Moderator: Nathan Hochman, Morgan Lewis & Bockius LLP, Los Angeles, CA Panelists: Jordan Ginsberg, Assistant U.S. Attorney, Eastern District of Louisiana, New Orleans, LA; Demetrius Hardeman, Assistant Special Agent in Charge, IRS Criminal Investigation, New Orleans, LA; Andrew Kameros, Assistant Chief in Western Criminal Enforcement, DOJ Tax Division, Washington, DC
  • Cryptocurrency - IRS Enforcement Efforts to Ensure Compliance. The IRS has been monitoring the acquisition, use, and exchange of digital currencies. Nearly five years after the issuance of IRS Notice 2014-21, the IRS and its colleagues in the Department of Justice are working to identify those taxpayers failing to properly report income arising from and pay tax due on digital currency transactions. This panel will provide the IRS perspective on digital currency enforcement efforts from examination and collection to criminal investigation. The discussion will include a review of issues arising in audits involving digital currencies, use of the information obtained from the Coinbase summons enforcement proceedings, impact of digital currencies on Collection Information Statements (Forms 433), seizures of digital keys, and investigations into those seeking to evade the assessment or payment of tax through the use of digital currencies. Moderator: Michael A. Villa Jr., Meadows Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TX Panelists: Lisa Beard, Deputy Commissioner, IRS SB/SE, Lanham, MD; Darren Guillot, Director, Field Collection Operations, IRS, Washington, DC; Demetrius Hardeman, Assistant Special Agent in Charge, IRS Criminal Investigation, New Orleans, LA



     


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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.