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2019 May 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 21 - 30 of (42) TOTAL sessions
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Event : ABATX42


Session : ABATX1968
State & Local Taxes
Conference : 2019 May Meeting
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  • Chair: Edward J. Bernert, BakerHostetler, Columbus, OH
  • Just Passing Through – An Update on the State Tax Treatment of Pass-Through Entities and Their Owners. The panel will provide an update on the state tax treatment of LLCs, partnerships and their owners, summarizing recent and pending state and federal tax legislation and the latest court cases and administrative rulings. The panel will provide insights on the Department of Treasury and IRS approaches to state laws intended as workarounds of the $10k limitation on the SALT deduction enacted as part of the 2017 federal tax reform. Finally, the panel will provide an update on efforts by the Multistate Tax Commission and states to conform to the controversial Federal partnership audit rules. Moderator: Bruce P. Ely, Bradley Arant Boult Cummings LLP, Birmingham, AL. Panelists: Alysse McLoughlin, McDermott Will & Emery, New York, NY; Steven N.J. Wlodychak, EY, Washington, DC
  • The State of State Tax Planning. The Supreme Court’s adoption of the economic presence nexus standard in South Dakota v. Wayfair, Inc. and other recent developments like state enactments of unitary combined reporting and intercompany expense addback statutes are raising questions about the ongoing vitality of longstanding state tax planning tools, particularly the use of holding companies to isolate business segments within a corporate group. The panel will explore these state tax developments and offer their thoughts on the direction of tax planning in the contemporary state tax world. Moderator: John A. Biek, Neal Gerber & Eisenberg LLP, Chicago, IL. Panelists: Professor Hayes R. Holderness, University of Richmond School of Law, Richmond, VA; Shirley K. Sicilian, KPMG, Washington, DC
  • The Taxation of the Digital Economy. Taxing authorities throughout the world are looking at the way in which the digital economy should be taxed. This panel will look at what role factor presence standards used by the states in the US might play in this discussion. Moderator: Steven P. Young, Holland & Hart LLP, Salt Lake City, UT. Panelists: Lila Disque, Multistate Tax Commission, Washington, DC; Professor Monica Gianni, California State University, Northridge, CA


Session : ABATX1969
Tax Exempt Financing
Conference : 2019 May Meeting
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  • Chair: Todd Cooper, Locke Lord LLP, Cincinnati, OH
  • Legislative, Treasury and Internal Revenue Service Update. This panel will discuss: (i) new legislative initiatives that might affect tax-exempt financing; (ii) updates on enforcement; (iii) the Proposed Reissuance Regulations; (iv) the Committee’s comments addressing measurement of private business use, allocation and accounting rules, and remedial action rules; (v) a very recent PLR dealing with useful life calculations, particularly in an exempt facility leasing context; (vi) Treasury Decision 9854 clarifying that investment-type property excludes the financed project; (vii) Revenue Procedure 2019-17 which reconciles sections 42 and 142 of the Code regarding the public use requirement for low income housing projects financed with low income housing tax credits and/or tax exempt bonds; and (viii) 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; Johanna Som de Cerff, Acting Branch Chief, Branch 5, Financial Institutions & Products, IRS, Washington, DC; Spence Hanemann, Special Technical Reviewer, Branch 5, Financial Institutions & Products, IRS, Washington, DC; Mark O. Norell, Ballard Spahr LLP, New York, NY; Stefano Taverna, McCall Parkhurst & Horton LLP, Dallas, TX; Chas Cardall, Orrick Herrington & Sutcliffe LLP, San Francisco, CA
  • Controversy and Cooperation with the IRS. This panel will discuss certain fact patterns that involve (i) two cases that went to appeals and why that decision was made and how the process unfolded procedurally, and (ii) seeking a PLR after the bonds are issued and related disclosure and opinion questions. Moderator: Mark O. Norell, Ballard Spahr LLP, New York, NY. Panelists: Charles Henck, Ballard Spahr LLP, Washington, DC; Aviva Roth, Orrick Herrington & Sutcliffe LLP, Washington, DC
  • Four Topics You Did Not Know Were Hot. This panel will consist of brief presentations on: (i) Unusual fact patterns in determining what are “facilities for the furnishing of water” under 142(a)(4); (ii) State Revolving Fund programs and the acquisition of loans prior to the financing – do the reimbursement rules apply and, if so, how are they applied?; (iii) Private Security - does this include pledged revenues under an indenture; and (iv) Yield compliance for student loan bonds - loan forgiveness versus yield reduction payments. Moderator: Chas Cardall, Orrick Herrington & Sutcliffe LLP, San Francisco, CA. Panelists: Bruce Serchuk, Nixon Peabody LLP, Washington, DC; Todd Cooper, Locke Lord LLP, Cincinnati, OH


Session : ABATX1970
Teaching Taxation
Conference : 2019 May Meeting
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  • Chair: Professor Kerry Ryan, Saint Louis University, Saint Louis, MO
  • Higher Education and Taxation: Are We Getting Tax Policy Right for the Mission of Education? The country is in a battle over the role, place, and funding of higher education. Who is it for? How should it be financed? What should it provide? The tax law impacts higher education in significant ways. This panel will examine those impacts and consider whether we get that policy right, and whether any changes are needed. The 2017 Tax Act imposed new taxes on colleges and universities with large endowments and big salaries. What will be the impact of these changes? Should public universities be able to elect in and out of section 501(c)(3) status? If so, should they be subject to a special set of rules? For-profit higher education providers are increasingly converting to nonprofit status in order to take advantages of benefits provided to tax exempt entities. Should there be rules limiting the entry of for-profit organizations? Tax law also impacts student borrowing. Do we get the incentives right or could we do better in structuring those incentives to benefit those in need? Moderator: Professor Philip T. Hackney, University of Pittsburgh School of Law, Pittsburgh, PA. Panelists: Professor Ellen P. Aprill, Loyola Law School, Los Angeles, CA; Professor Brian R. Galle, Georgetown University Law Center, Washington, DC; Professor Benjamin Leff, American University, Washington College of Law, Washington, DC; Alexandra Mitchell, RSM US LLP, Washington, DC


Session : ABATX1971
Diversity II
Conference : 2019 May Meeting
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  • Chair: Lany L. Villalobos, Dechert LLP, Philadelphia, PA
  • Expanding Opportunities for State and Local Collection Alternatives For Small Business Owners. This panel will engage practitioners from different state and local jurisdictions to formulate best collection practices at the state and local level for small business owners. Moderator: Sangsoo (Eddie) Lee, Fordham University School of Law, New York, NY. Panelists: Eunkyong Choi, New York City Taxpayer Advocate, New York, NY; Glenn Newman, Greenberg Traurig LLP, New York, NY; Matt Landwehr, Thompson Coburn LLP, St. Louis, MO
  • International Students & Compliance with US Federal Tax Law. The panelists will provide an overview of the various tax issues and considerations arising for international students, including whether to file a US tax return, what income must be reported, and eligibility to claim tax treaty benefits. Panelists: Michael A. Wallace, Agostino & Associates PC, Hackensack, NJ; Professor Tracy Kaye, Seton Hall University School of Law, Newark, NJ; Jairo Cano, E-Trade Financial, Jersey City, NJ


Session : ABATX1972
US Activities of Foreigners and Tax Treaties
Conference : 2019 May Meeting
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  • Chair: Summer LePree, Bilzin Sumberg Baena Price & Axelrod LLP, Miami, FL
  • Choice of Entity and Structuring for Individual Investors and Closely-Held Businesses After Tax Reform (Part 2). This is part 2 of a two-part panel, presented jointly with FAUST. This panel will focus on both inbound and outbound planning considerations for individuals and closely-held businesses after tax reform. Topics include planning for individuals with interests in CFCs, including section 965 considerations, section 962 elections, considerations on exit, and implications of tax reform for inbound financing, investment, and estate planning structures. Moderator: Kirsten Burmester, Caplin & Drysdale, Washington, DC. Panelists: Ellen K. Harrison, McDermott Will & Emery, Washington, DC; Michael Karlin, Karlin & Peebles, Beverly Hills, CA; Natalie Punchak, IRS Office of Associate Chief Counsel (International), Washington, DC; James Wang, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC
  • Discretionary Treaty Benefits. This panel will address issues related to the grant of discretionary benefits under tax treaties, including the recent DC Circuit decision in Starr International rejecting a district court finding that the treaty interpretation issues presented were nonjusticiable political questions. The panel will also address other related issues, including the potential applicability of the act of the state doctrine (recently rejected by the Tax Court in Smith), the relevance of the APA, and the status of IRS claims for unreviewable discretion over discretionary benefits (rejected by an earlier decision in the Starr saga). Moderator: Robert Culbertson, Covington & Burling, Washington, DC. Panelists: Christopher P. Bowers, Skadden Arps Meagher & Flom, Washington, DC; Amanda P. Varma, Steptoe & Johnson LLP, Washington, DC


Session : ABATX1973
Closely Held Businesses
Conference : 2019 May Meeting
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  • Chair: Shawn L. McIntire, Velocity Global LLC, Denver CO
  • Section 197 and Personal Goodwill in Professional Practices. Some professional practices (particularly dental, dental specialty and veterinary practices) have substantial and saleable goodwill. The section 197 antichurning rules and the concept of personal goodwill in complete or fractional sales are discussed. This panel will review the rules and result if the rules are not understood or ignored. Panelists: Deena M. Devereux, Senior Technician Reviewer, Branch 7, IRS – Income Tax & Accounting, Washington, DC; Charles J. Magee, Senior Counsel, Branch 7, IRS – Income Tax & Accounting, Washington, DC; Galina “Allie” Petrova, Petrova Law, Greensboro, NC; William P. Prescott, Wickens Herzer Panza, Avon, OH
  • Closely Held Businesses From Start to Finish – Part II: Operations. The panel will discuss what should be considered when operating a closely held business and the difference considerations between C-Corporations, S-Corporations, Sole-Proprietorships and Partnerships. The panel will focus employment considerations, deductions available to each entity and other operational tax considerations for closely held business. Panelists: Robb Longman, Longman & Van Grack LLC, Bethesda, MD; Joseph B. Schimmel, Cohen Chase Hoffman & Schimmel PA, Miami, FL; Elizabeth Stieff, Venable LLP, Baltimore, MD
  • The Social Impact Side of the Qualified Opportunity Zone Discussion: What Can Treasury Do? In the initial set of proposed regulations for investments in qualified opportunity funds, Treasury and the IRS responded to the legislative mandate to create certification rules for qualified opportunity funds by allowing funds to self-certify as qualified opportunity funds. Concurrent with the issuance of the most recent set of proposed regulations in April, and consistent with Executive Order 13853, “Establishing the White House Opportunity and Revitalization Council,” Treasury and the IRS issued a request for information requesting detailed comments on data collection and methodologies for assessing relevant aspects of investments held by qualified opportunity funds. This panel will address the extent to which Treasury and the IRS have the authority to impose additional screening criteria as part of the certification process, as well as the Treasury and IRS’s ability to request additional information under the current statute and potential legislative amendments. The panel will also address opportunities under the new proposed regulations that may be favorable to current owners of real estate and businesses within qualified opportunity zone Census tracts seeking capital from the investment community.M oderator: Mark E. Wilensky, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY. Panelist: Matt Josephs, Local Initiatives Support Corporation (LISC), Washington, DC; Rachel Reilly, Economic Innovation Group, Washington, DC; Brett Theodos, Urban Institute, Washington, DC; Lisa M. Zarlenga, Steptoe, Washington, DC


Session : ABATX1974
Court Procedure & Practice
Conference : 2019 May 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: Chief Judge Maurice B. Foley, US Tax Court, Washington, DC; Richard G. Goldman, Deputy Associate Chief Counsel (Procedures & Administration) 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
  • Representing Taxpayers During Summons and Other IRS Interviews – Potted Plant v. Rambo. Representing Taxpayers During Summons and other IRS interviews reviews best practices for addressing IRS requests to interview clients, including when and whether either party can request to transcribe an interview, who can attend the interview of the taxpayer and/or the tax return preparer, or other witnesses, making objections, asserting privileges and dispute resolution techniques. Moderator: Frank Agostino, Agostino & Associates PC, Hackensack, NJ. Panelists: Lindsey Stellwagen, Special Counsel International, SBSE, Office of Chief Counsel, Washington, DC; Guinevere M. Moore, Johnson Moore, Chicago, IL
  • The APA in the Era of Tax Reform. A year and a half has passed since the 2017 Tax Act was first enacted, and the IRS and Treasury Department have been busy publishing guidance and regulations interpreting the statute since then. This panel will explore what practitioners should know about the Administrative Procedure Act and how it impacts Treasury and the IRS in exercising their regulatory authority. Topics include: the basics of administrative rulemaking; types of administrative guidance—e.g., notice-and-comment rulemaking, temporary regulations, and subregulatory guidance; the role of deference, including the future of Auer deference at issue in Kisor v. Wilkie; and challenges to the validity of administrative guidance and regulations. Moderator: Arielle Borsos, Caplin & Drysdale, Washington, DC. Panelists: Anson Asbury, Asbury Law Firm, Decatur, GA; Nicole (Niki) Ford, Baker McKenzie LLP, New York, NY; William Wilkins, PwC, Washington, DC; Gil Rothenberg, Chief, Appellate Section, Department of Justice, Tax Division, Washington, DC


Session : ABATX1975
Insurance Companies
Conference : 2019 May Meeting
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  • Chairs: Ann Cammack, EY, Washington, DC; Sheryl Flum, KPMG, Washington, DC
  • Impact of the 2017 Tax Act on Insurance Companies. A discussion with IRS and Treasury representatives about the status of guidance implementing 2017 Tax Act provisions that impact insurance companies. Moderator: Ann Cammack, EY, Washington, DC. Panelists: Alexis MacIvor, Chief of the Insurance Branch, IRS Chief Counsel, Washington, DC; Kathryn Sneade, Assistant to Branch Chief of the Insurance Branch, IRS Chief Counsel, Washington, DC; Angela Walitt, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Regina Rose, American Council of Life Insurers, Washington, DC
  • Tax Issues for Captive Insurance Companies. This panel will discuss the IRS’s audit campaign on micro-captives, as well as the impact recent Tax Court decisions may have on the structuring of captive insurance companies. Moderator: Charles J. Lavelle, Bingham Greenebaum Doll LLP, Louisville, KY. Panelists: Kacie Dillon, Woolston & Tarter PC, Phoenix, AZ; Sheryl Flum, KPMG, Washington, DC; Michael Halpert, Program Manager, LB&I Pass-thru Entities, IRS, Washington, DC; Pete Puzakulics, Director, Financial Institutions and Products Area, LB&I Enterprise Activities Practice Area, IRS, Washington, DC
  • Retirement Legislation and Insurance Companies. This panel will discuss retirement-related legislative proposals, including the Setting Every Community Up for Retirement Enhancement (SECURE) Act, the Retirement Enhancement and Savings Act (RESA), the Retirement Plan Simplification & Enhancement Act, and the Retirement Security and Savings Act, and how these bills may affect life insurance companies and the products they offer. Moderator: Bryan Keene, Davis & Harman LLP, Washington, DC. Panelists: Kara Getz, House Ways & Means Committee, Washington, DC; Drew Crouch, Senate Finance Committee, Washington, DC; Chris Spence, TIAA, Washington, DC


Session : ABATX1976
Real Estate
Conference : 2019 May Meeting
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  • Chair: Todd D. Keator, Thompson & Knight LLP, Dallas, TX
  • Conservation Easements – The Lay of the Land. Conservation easement donations can be an effective tax-minimization strategy if properly structured. This panel will provide an introduction to conservation easements with an overview of structuring considerations. In addition, panelists will discuss recent IRS challenges and court decisions addressing conservation easements, and pitfalls advisors should consider. Moderator: Valerie Vlasenko, Agostino & Associates PC, Hackensack, NJ. Panelists: Anson Asbury, Asbury Law Firm, Decatur, GA; Ronald Levitt, Sirote & Permutt PC, Birmingham, AL
  • Rental Real Estate. Since enactment of the 2017 Tax Act, the IRS has released a plethora of new guidance aimed at owners of rental real estate, including under section 199A, section 163(j), and other areas. This panel will discuss the recent guidance and the impact on rental real estate. Moderator: Matthew Lay, Deloitte Tax LLP, Washington, DC. Panelists: Julanne Allen, PwC, Washington, DC; Michael Hirschfeld, Anderson Tax, New York, NY; Vishal Amin, IRS Office of Associate Chief Counsel (Passthroughs & Special Industries), Washington, DC
  • REITs in the Aftermath of the 2017 Tax Act. How are REITs faring in the aftermath of the 2017 Tax Act? This panel will explore various 2017 Tax Act effects on REITs. Moderator: Cristina Arumi, Hogan Lovells, Washington, DC. Panelists: Kimberly Arndt, PwC, Washington, DC; Mark Van Deusen, Deloitte, Richmond, VA; Andrea Hoffenson, Branch Chief, IRS Office of Associate Chief Counsel (Financial Institutions & Products), Washington, DC; Grace Cho, Attorney-Advisor, IRS Office of Associate Chief Counsel (Financial Institutions & Products), Washington, DC
  • Back to the Land of QOZ! An Update on the Latest Round of QOZ Guidance.Qualified opportunity zones are hot! The IRS released the first wave of guidance in 2018, and recently released a second set of proposed regulations only weeks ago. This panel will discuss the latest guidance for qualified opportunity zones that investors and their advisors need to know. Moderator: Tom West, KPMG, Washington, DC. Panelists: Kathleen Gerber, Thompson & Knight LLP, Dallas, TX; Sam Kamyans, Baker McKenzie, Washington, DC; Bryan Rimmke, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC


Session : ABATX1977
Tax Accounting
Conference : 2019 May 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 New Orleans, LA in January. 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: Ryan Corcoran, RSM US LLP, Madison, WI. Panelists: David Schneider, Skadden Arp Slate Meagher & Flom LLP, Washington, DC; Caleb Cordonnier, Grant Thornton LLP, Washington, DC; Scott Dinwiddie, IRS Associate Chief Counsel IT&A, Washington, DC; John Moriarty, Deputy Chief Counsel, IT&A, Washington, DC; Kathleen Reed, Branch Chief Branch 7, IRS Office of Chief Counsel IT&A, Washington, DC
  • Section 199A Issues and Opportunities. This panel will discuss various issues and opportunities facing taxpayers as they determine their Sec. 199A deduction under the 2017 Tax Act. The panel will focus on the separate trade or business designations and its impact on computing the deduction in addition to other related items with input from our guests from the Internal Revenue Service and Department of Treasury. Moderator: Stanley Barsky, EisnerAmper LLP, New York, NY. Panelists: George Manousos, PwC, Washington, DC; Pamela A. Fuller, Royse Law Firm, Menlo Park, CA; Norma Rotunno, Branch Chief, Branch 1, Office of Associate Chief Counsel IT&A, Washington, DC; Douglas Kim, General Attorney, Branch 1, Office of Associate Chief Counsel IT&A, Washington, DC; Margaret Burow, General Attorney, Office of Associate Chief Counsel PSI, Washington, DC; Robert Alinsky, General Attorney, Branch 3, Office of Associate Chief Counsel PSI, Washington, DC
  • International Tax Accounting Items. This panel will discuss tax accounting implications of the various international provisions of the 2017 Tax Act related to BEAT, GILTI, FDII and other areas. The panel will also discuss impact the tax accounting rules have on the implementation and application of the international provision of the 2017 Tax Act with input from our guests from the Internal Revenue Service and Department of Treasury. Moderator: Ellen McElroy, Eversheds Sutherland LLP, Washington, DC. Panelists: Scott Rabinowitz, Skadden Arp Slate Meagher & Flom LLP, Washington, DC; Carol Conjura, KPMG, Washington, DC; Jeffrey G. Mitchell, Branch Chief, Branch 2, IRS Office of Associate Chief Counsel (International), Washington, DC; Wade Sutton, Senior Counsel, International Tax Counsel, 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 regarding the implementation 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: Jane Rohrs, Deloitte Tax LLP, Washington, DC. Panelists: Colleen O’Connor, KPMG, Washington, DC; Michael Solomon, MFSolomon Tax Consulting LLC, Rancho Santa Fe, CA; John Moriarty, Deputy Chief Counsel IT&A, Washington, DC; Charles Gorham, Special Counsel, Office of Associate Chief Counsel IT&A, Washington, DC; Peter Ford, Senior Counsel, Branch 2, Office of Associate Chief Counsel IT&A, Washington, DC; Karla Meola, Special Counsel, Office of Associate Chief Counsel IT&A, Washington, DC; Heather Harman, Legislative Tax Accountant, Joint Committee on Taxation, 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.