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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.

$299.00



Showing sessions 41 - 43 of (43) TOTAL sessions
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Event : ABATX41


Session : ABATX1943
Fiduciary Income Tax
Conference : 2019 Midyear Meeting
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  • Chair: Stacey Delich-Gould, Capital Group Private Client Services, New York, NY
  • Current Developments. AK and Emily will review current developments in fiduciary income tax and Cathy Hughes will update the committee on developments within the Treasury and the Service. Panelists: Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC; Anna Katherine (AK) Moody, Venable LLP, Washington, DC; Emily A. Plocki, Venable LLP, Washington, DC
  • Trust Planning Opportunities under Section 1202. Section 1202 provides an incentive for taxpayers to invest in many types of small businesses by providing that some or all of the gains resulting from the sale of qualified small business stock can be realized tax-free. Jeff and Liz will discuss ways in which trusts may take advantage of section 1202 in light of the decreased corporate income tax rate enacted by the 2017 Tax Act. Panelists: Jeffrey K. Gonya, Venable LLP, Baltimore, MD; Elizabeth F. Stieff, Venable LLP, Baltimore, MD
  • Alimony, Prenuptial Agreements and Trusts under the 2017 Tax Act. As with many large tax overhauls, sometimes lesser publicized changes also have a significant impact on taxpayers. With the 2017 Tax Act, some of these lesser publicized changes involve the income tax impact of divorce, which, in 2019 and beyond, will have far-reaching effects as a result of the elimination of alimony as an income/deduction item and the post-divorce continued grantor trust status of certain spousal trusts. Panelists: George D. Karibjanian, Franklin Karibjanian & Law PLLC, Boca Raton, FL/ Washington, DC; Bri Loughlin, Winstead PC, Houston, TX
  • State Fiduciary Income Tax Developments. This panel will review the treatment of the state income taxation of trusts that has been evolving recently. The recent Supreme Court decision in Wayfair impacted state and local tax fundamentals and restrained the application in Quill, and the current request for certiorari to the Supreme Court in Kaestner has heightened practitioners’ awareness. The recent Minnesota Supreme Court case of Fielding expands the nexus shifting ability of trusts and their founders. These 2018 fiduciary income tax cases have further challenged a state’s ability to tax a trust for state residency purposes and alerted practitioners advising trusts in other states to evaluate the constitutional basis regarding state taxation of trusts. Panelists: David A. Berek, Baker & McKenzie LLP, Chicago, IL; Raj A. Malviya, Miller Johnson, Grand Rapids, MI


Session : ABATX1944
Sales, Exchanges & Basis
Conference : 2019 Midyear 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. Panelist: David Shechtman, Drinker Biddle & Reath LLP, Philadelphia, PA; John Wagner, Williams Parker Harrison Dietz & Getzen, Sarasota, FL
  • Where are the Opportunities in Qualified Opportunity Funds? Panelists will review the use of qualified opportunity funds in view of proposed regulations, and identify key questions that await future guidance. Moderator: Alan S. Lederman, Gunster, Fort Lauderdale, FL Panelists: Matthew E. Rappaport, Falcon Rappaport & Berkman PLLC, New York, NY
  • US Shareholder Basis in Foreign Corporations Post-Tax Reform. Following Tax Reform, US Shareholders of foreign corporations (as defined under section 951(b) face myriad issues regarding calculating basis of foreign corporations and its effect on their overall tax liability. The lack of clarity regarding how to calculate basis and adjustments thereto has become all the more pronounced over the past year. This panel will provide an overview of some of the most important aspects of Tax Reform’s effects on the basis of foreign corporations owned by US Shareholders, including the election to adjust bases due to the use of deficits to offset income inclusions from DFICs under 965 and 245A’s interrelationship with basis adjustments, 964, and 1248. Most important, however, this panel will take a deeper dive into 961 and 959 post-Tax Reform, including issues such as PTI in 959(c)(2) without corresponding basis, the ordering rules related to layers of PTI in the same 959(c) “bucket” for distributions, unresolved issues under the 959 and 961 regulations (including 304 transactions), and the proposed regulations promised by the IRS relating to 959 and 961 if they have been released prior to the panel. Moderator: Rafi Mottahedeh, Cargill, Minneapolis, MN Panelists: Daniel Reach, Alston & Bird, Charlotte, NC; John Bates, Deloitte Tax LLP, Washington, DC


Session : ABATX1945
Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation
Conference : 2019 Midyear Meeting
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  • Sponsored by: Teaching Taxation
  • This session will review the most significant statutory enactments, judicial decisions, IRS rulings, and Treasury regulations promulgated during the last twelve months that affect general income taxation, corporate taxation, partnership taxation, wealth transfer taxation, and tax procedure. Moderator: Professor Bruce A. McGovern, South Texas College of Law Houston, Houston, TX Panelists: Professor Elaine Hightower Gagliardi, University of Montana School of Law, Missoula, MT; Professor Philip Hackney, University of Pittsburgh School of Law, Pittsburgh, PA



     


Showing sessions 41 - 43 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.