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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 31 - 40 of (43) TOTAL sessions
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Event : ABATX41


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 Panelist: 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: 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; Paul Butler, Kostelanetz & Fink LLP, Washington, DC


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
  • Current Developments. This session will review current developments and topics of immediate interest to individual and pro bono representation including IRS regulations, Tax Court rulings, and upcoming items of focus for the IRS related to low-income taxpayer representation.
  • 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: Sarah Lora, Legal Aid Services of Oregon, Portland, OR Panelists: David Sams, Community Tax Law Project, Richmond, VA; Wells Hall III, Nelson Mullins Riley & Scarborough LLP, Charlotte, NC Co-sponsored by: Individual & Family Tax
  • 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: Professor Christine Speidel, Charles Widger School of Law, Villanova University, Villanova, PA 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; Anna Tavis, Brooklyn Legal Services NYC, Brooklyn, NY 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: The Honorable 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
  • 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
  • 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: Megan Marlin, PwC, Washington, DC; Steven P. Johnson, Morgan Lewis, Washington, DC


Session : ABATX1941
Corporate Tax
Conference : 2019 Midyear Meeting
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  • Chair: Steve Fattman, EY, Washington, DC
  • The Ghost of Kimbell-Diamond : Application of the Step Transaction Doctrine to Multi-step Corporate Transactions. This panel will explore acquisition and restructuring techniques involving multi-step transactions, including Kimbell- Diamond transactions, reverse Kimbell-Diamond transactions, outbound transactions, and mergers with partnerships. Moderator: Jerred Blanchard, Baker & McKenzie, Houston, TX Panelists: Marc Countryman, EY, San Francisco, CA; Sara Zablotney, Kirkland & Ellis, Chicago, IL; Lisa Fuller, Deputy Associate Chief Counsel (Corporate), IRS, Washington, DC
  • Current Developments in Corporate Tax. This panel will review current developments in corporate tax, including anticipated guidance related to provisions from the 2017 Tax Act. In particular, the panel expects to discuss anticipated proposed regulations under section 163(j) and the interaction of the BEAT and the subchapter C nonrecognition provisions. In addition, the panel will discuss recent PLRs in the corporate tax area. Moderator: Jonathan Forrest, Deloitte Tax LLP, Washington, DC Panelists: Scott Levine, Jones Day, Washington, DC; Tijana Dvornic, Wachtell Lipton Rosen & Katz, New York, NY


Session : ABATX1942
Employee Benefits II
Conference : 2019 Midyear Meeting
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  • Chair: Bret Hamlin, Hill Ward Henderson, Tampa, FL
  • Lessons for 401(k) Plans from the University 403(b) Cases. This panel will discuss recent developments in university 403(b) plan litigation and the potential impact on the operation of 401(k) and other self-directed defined contribution plans. Moderator: Don Wellington, Reed Smith LLP, Los Angeles, CA Panelists: Blake C. MacKay, Alston & Bird LLP, Atlanta, GA; Sara Pikofsky, Steptoe & Johnson LLP, Washington, DC; Robert Rachal, Holifield Janich Rachal & Ferrera PLLC, New Orleans, LA
  • Round the World in 60 Minutes: Current Issues and Updates for Global Equity Programs. In today’s world it is typical for US companies to make equity grants to employees worldwide. However, global equity programs can be risky enterprises if the issuing company does not consider the myriad issues associated with global programs – tax, securities law, labor, data privacy and currency control rules all can come into play, and the rules vary from jurisdiction to jurisdiction and may change in any jurisdiction with little or no notice. This session will cover topics of current interest in this complex area. Moderator: Martha N. Steinman, Hogan Lovells US LLP, New York, NY Panelists: Mark Jones, Pillsbury Winthrop Shaw Pittman, San Francisco, CA; Margaret (Meg) McIntyre, Hogan Lovells US LLP, Washington, DC
  • Ethics Panel. This panel will discuss lawyer wellness issues, lawyers use of social media and list serves, lawyers hiring service providers to do compliance work on behalf of clients, employee benefit plan committee meeting minutes and client communications. Moderator: Bret Hamlin, Hill Ward Henderson, Tampa, FL Panelists: Tracy L. Kepler, Director, Center for Professional Responsibility, American Bar Association, Chicago, IL; Charles B. Plattsmier, Chief Disciplinary Counsel, Office of the Disciplinary Counsel, Baton Rouge, LA; John L. Utz, Utz & Lattan LLC, Overland Park, KS



     


Showing sessions 31 - 40 of (43) TOTAL sessions
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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.