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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.

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Showing sessions 31 - 40 of (42) TOTAL sessions
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Event : ABATX42


Session : ABATX1978
Financial Transactions
Conference : 2019 May Meeting
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  • Chair: Craig Gibian, Deloitte Tax LLP, Washington, DC
  • Newfound Relevance for Age Old Issues: How the 2017 Tax Act Has Reignited Long-Standing Financial Product Debates. In light of the numerous changes to the Code, practitioners have had to consider the appropriate treatment of a variety of financial transactions where such treatment is currently unclear. The panelists will explore issues such as the treatment of securities lending transactions and repos with a right to rehypothecate and when to treat tax items on a gross or net basis. Moderator: Michael Shulman, Shearman & Sterling LLP, New York, NY. Panelists: Jeffrey Maddrey, PwC, Washington, DC; Elena Romanova, Latham & Watkins LLP, New York, NY
  • Topics of “Interest” Under Section 163(j). This panel will discuss the definition of interest in the proposed regulations under section 163(j), including the treatment of substitute interest payments, debt issuance costs and commitment fees, as well as hedging transactions and foreign currency considerations. Moderator: Craig Gibian, Deloitte Tax LLP, Washington, DC. Panelists: Mark Erwin, Deputy Associate Chief Counsel (Financial Institutions and Products), IRS, Washington, DC (Invited); Michael Mou, Deloitte Tax LLP, Washington, DC; Brett York, Department of Treasury, Washington, DC
  • Shop Talk: Current Financial Products Tax Issues for Hedge Funds. This panel will focus on issues that the participants are seeing in their asset management-focused financial products tax practices, including the application of section 163(d) and section 163(j), the impact of the unavailability of deductions under section 212 and various issues under section 475. Moderator: Matthew A. Stevens, EY, Washington, DC. Panelists: Lucy Farr, Davis Polk & Wardell, New York, NY; William Pomierski, McDermott Will & Emery LLP, Chicago, IL


Session : ABATX1979
Tax Collection, Bankruptcy and Workouts
Conference : 2019 May Meeting
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  • Chair: Christin Bucci, Bucci Law Offices, Fort Lauderdale, FL
  • Current Enforcement Priorities in Collection. The panelists will provide an update on IRS enforcement efforts within the collection division, including recent hiring, additional training, and plans to pursue nonpayment of employment taxes. The panelists will also discuss fraud referred by revenue officers, how collection is locating information about virtual currencies, 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
  • Collection-Based Tax Crimes. Fraud referrals for collection-based tax crimes are on the rise as the IRS seeks to close the tax gap. This panel will provide current statistics concerning prosecutions and an overview of the tax crimes most likely to be encountered in collection, including willful failure to collect tax, fraud and false statements, and attempts to interfere with the administration of the internal revenue laws. The panelists will also discuss practical approaches to handling civil collection cases with criminal implications and how to navigate a criminal collection case. Moderator: Jonathan Kalinski, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA. Panelists: Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC; Steven Toscher, Hochman Salkin Toscher & Perez PC, Beverly Hills, CA; David Zisserson, Counsel to the Assistant Attorney General for Civil-Criminal Coordination, Trial Attorney, Criminal Enforcement Section (Southern), Department of Justice, Tax Division, Washington, DC; Special Agent in Charge, Internal Revenue Service, Criminal Investigation Division (Invited); Michael T. Batdorf, CI Deputy Director of Operations, IRS, Washington, DCCo-sponsored by: Civil & Criminal Tax Penalties
  • Litigating International Penalties in Collection. Many penalties resulting from the failure to report foreign income and assets are assessable (i.e., the deficiency procedures do not apply). This panel will discuss the procedures that apply after the IRS Examination Division assesses or proposes to assess a penalty for failing to report foreign income or assets. The panelists will explain the options available to contest and/or compromise the international penalties under Title 26, including accelerated appeals, collection due process hearings, collection alternatives, and Tax Court litigation. Among the penalties to be covered are international information return penalties, accuracy-related penalties due to undisclosed foreign financial asset understatements, and the fraud penalty. Moderator: Frank Agostino, Agostino & Associates PC, Hackensack, NJ. Panelists: Robert Horwitz, Hochman Salkin Toscher & Perez PC, Beverly Hills, CA; Charles Pillitteri, Deputy Division Counsel, SB/SE, IRS Office of Chief Counsel, Washington, DC; Michelle F. Schwerin, Capes Sokol, St. Louis, MO. Co-sponsored by: Civil & Criminal Tax Penalties and Court Procedure & Practice


Session : ABATX1980
Young Lawyers Forum
Conference : 2019 May Meeting
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  • Chair: Micah Gibson, PwC, Washington, DC
  • Motions Practice in Tax Court: From Pleadings to Post-Trial Proceedings. This panel will explore the various motions used in practice before the Tax Court. The panel will discuss strategies for effectively drafting and arguing motions as well as when to utilize particular motions with a focus on motions related to pleadings, discovery, expert witnesses, and post-trial proceedings. Moderator: Josh Savey, Shearman & Sterling, Washington, DC. Panelists: Chief Special Trial Judge Lewis R. Carluzzo, US Tax Court, Washington, DC; Han Huang, IRS, Washington, DC; Rebecca Stork, Eversheds Sutherland, Atlanta, GA


Session : ABATX1981
Tax Practice Management
Conference : 2019 May Meeting
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  • Chair: Roger Royse, Royse Law Firm, Menlo Park, CA
  • The Ethical Challenges of Social Media for Tax Practitioners. The use of social media both personally and professionally has dramatically increased in popularity over the last decade. Modernly, lawyers and tax practitioners use social media to advertise, network, and stay informed on the latest developments in their respective practice areas. While the utility of this transformative technology is evident, practitioners often face a number of ethical and practical challenges related to the use of social media which give rise to professional responsibility concerns. This panel will discuss the ethical and practical challenges related to social media that tax practitioners should be aware of when they represent clients in the future. Moderator: Travis Thompson, Sideman & Bancroft LLP, San Francisco, CA. Panelists: Starling Marshall, Covington & Burling, New York, NY; Robert Kovacev, Norton Rose Fulbright US LLP, Washington, DC


Session : ABATX1982
Corporate Tax
Conference : 2019 May Meeting
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  • Chair: Steve Fattman, EY, Washington, DC
  • Current Developments in Corporate Tax. The panel will cover new developments in corporate tax, including proposed regulations under Treas. Reg. §§ 1.337(d)-3, 1.337(d)-7, and 1.301-1, guidance under the 2017 Tax Act, recent private letter rulings, and recent guidance under section 355. Moderator: Maury Passman, KPMG, Washington, DC. Panelists: Julie Hogan Rodgers, WilmerHale, Boston, MA; Robert Stevenson, Skadden Arps Slate Meagher & Flom, Washington, DC; Colin Campbell, Department of Treasury, Washington, DC (Invited); Brian R. Loss, IRS Office of Associate Chief Counsel (Corporate), Washington, DC (Invited)
  • A Study of Attributes Post-Tax Reform. This panel will review the choices made by the government regarding the attributes consequences of the GILTI regime and section 965, explore the impact of those choices and proposals to address the issues identified, and discuss the impact of the changed role that attributes play in the tax law. Moderator: Karen Gilbreath Sowell, EY, Washington, DC. Panelists: Brian Reed, EY, Washington, DC; Gordon Warnke, KPMG, New York, NY; Christina Tacoronti, Davis Polk & Wardwell, New York, NY; Gary Scanlon, Office of International Tax Counsel, Department of Treasury, Washington, DC; Kevin Jacobs, IRS Office of Associate Chief Counsel (Corporate), Washington, DC


Session : ABATX1983
Employee Benefits
Conference : 2019 May Meeting
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  • Chair: Bret Hamlin, Hill Ward Henderson, Tampa, FL
  • One Law, Two Laws, Red State, Blue State. Join us as we delve into the “civil war” between the red and blue states (and the federal government) over the legality of the ACA. In the latest twist in this litigation drama, Judge Reed O’Connor of the Northern District of Texas held the entire ACA unconstitutional after concluding that the individual mandate was inseverable from the ACA. This panel will review the court’s decision, the subsequent stay, and the issues the decision and stay raise, including a deeper dive into “congressionally inflicted” injury, severability, the Commerce Clause, the federal taxing power, and the perennial favorite -- standing. We will then analyze the potential implications of the court’s ruling, the prospects on appeal, and the ACA’s status pending appeal. Time permitting, we will also discuss related chapters in the ACA federalism saga including litigation over the contraceptive mandate, short-term limited duration plans, and association health plans. Moderator: Erin M. Sweeney, Miller & Chevalier Chartered, Washington, DC. Panelists: Alden J. Bianchi, Mintz, Boston, MA; Maame Gyamfi, AARP Foundation, Washington, DC; Mary Ellen Signorille, Bloomberg, Washington, DC
  • 4960? Excise Taxes? What’s a Tax Exempt to Do? The 2017 Tax Act added section 4960 to the Code, which imposes an excise tax on excess remuneration and parachute payments made by tax-exempt organizations. Notice 2019-9 provided the first guidance on this new and complex provision. Panelists will discuss how 4960 works and questions answered (and new questions raised) by the guidance, as well as the implications for compensation paid by tax-exempt entities to their executives. Moderator: Martha N. Steinman, Hogan Lovells US LLP, New York, NY. Panelists: Kurt Lawson, Hogan Lovells US LLP, Washington, DC; Helen Morrison, EY, Washington, DC; Robert Neis, Eversheds Sutherland, Washington, DC; Stephen LaGarde, Attorney Advisor, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC; Stephen Tackney, Deputy Associate Chief Counsel (Employee Benefits), Employee Benefits, Exempt Organizations and Employment Taxes, Office of Chief Counsel, IRS, Washington, DC
  • Compensation Planning for Passthrough Entities After the 2017 Tax Act. Section 199A sets forth complex rules for determining when a taxpayer can exclude up to 20 percent of pass-through trade or business income. This panel will address what benefits practitioners need to know about structuring compensation arrangements while maximizing the 20% exclusion. It will also address special considerations when structuring profits interests. Moderator: Andrew C. Liazos, McDermott Will & Emery LLP, Boston, MA. Panelists: Elizabeth Drigotas, Deloitte Tax, Washington, DC; Ruth Wimer, Winston & Strawn, Washington, DC


Session : ABATX1984
Fiduciary Income Tax
Conference : 2019 May Meeting
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  • Chair: Stacey Delich-Gould, Capital Group Private Client Services, New York, NY
  • Current Developments. Ms. Moody and Mr. Garcia will review current developments in fiduciary income tax since January 2019. Panelists: Anna Katherine (AK) Moody, Venable LLP, Washington, DC; Francisco Garcia Jr., Henderson Caverly & Pum LLP, San Diego, CA
  • Qualified Opportunity Zones: What Estate Planners Need to Know. The 2017 Tax Act introduced the Qualified Opportunity Zone (“QOZ”) program, designed to provide a tax incentive for private, long-term investment in economically distressed communities. Since 2017, QOZs have become a “hot topic” among high net worth investors. Ms. Delich-Gould and Mr. Singer will explain the basics of how these vehicles work and outline some of the unanswered questions and potential risks. Panelists: Stacey Delich-Gould, Capital Group Private Client Services, New York, NY; Gregory D. Singer, Capital Group Private Client Services, New York, NY
  • Lemons to Lemonade: Making Use of the Delaware Tax Trap. Section 2041(a)(3), colloquially referred to as the Delaware tax trap, was initially a punitive provision, to be avoided at all costs. However, as exemption amounts have risen, it is increasingly recognized as a valuable estate planning tool that can generate significant tax savings under the right circumstances. Ms. Place and Mr. Diehl will explain the Delaware tax trap and share strategies for using it to your clients’ benefit. Panelists: Kasey A. Place, Ivins Phillips & Barker Chartered, Washington, DC; Rustin P. Diehl, The Burgess Group, Salt Lake City, UT
  • Impact of the 2017 Tax Act on Trust and Estate Income Taxation. Professor Williamson will review the changes made by the Tax Cuts and Jobs Act that will affect the preparation of estate and trust income tax returns, and he will offer planning suggestions for dealing with the new rules. Panelist: Professor Donald T. Williamson, American University Kogod School of Business, Washington, DC


Session : ABATX1985
Pro Bono & Tax Clinics
Conference : 2019 May Meeting
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  • Chair: Susan Morgenstern, IRS Taxpayer Advocate Service, Cleveland, OH
  • Family Members as Caregivers. Section 131 promotes community care for disabled adults by excluding certain state payments from caregivers’ gross income. Historically, Service challenged the excludability of payments to a parent caring for an adult disabled child in the provider’s home. In 2014 the Service reversed this position for certain Medicaid waiver payments, effecting a major economic change for affected families. This panel will discuss the impact of the 2014 guidance, areas of continued uncertainty, and other remaining barriers to the uniform treatment of caregivers’ income. Moderator: Camille Edwards Bennehoff, Attorney, IRS Office of Chief Counsel (Income Tax & Accounting), Washington, DC. Panelists: Victoria J. Driscoll, Senior Attorney, IRS Office of Chief Counsel (Income Tax & Accounting), Washington, DC; Professor Christine Speidel, Villanova University Charles Widger School of Law, Villanova, PA; Wayne Turner, Senior Attorney, National Health Law Program, Washington, DC. Cosponsored by: Individual & Family Taxation and Diversity
  • Procedural Due Process and the Tax System: A Fresh Look. Procedural due process is rooted in the Magna Carta and is embedded in our constitution. The right to notice and the opportunity for a hearing are the two key ways that the constitution helps ensure that the sovereign does not erroneously deprive people of essential rights, including the right to property. Procedural due process, a concept closely related to procedural justice, ensures that the sovereign treats its subjects as human beings entitled to a sense of dignity and is a foundational aspect of good government in general and tax administration in particular. In this panel, we will explore the historical roots of procedural due process jurisprudence, consider the ways that that current and proposed IRS procedures relate to due process protections and procedural justice norms, and explore insights from areas other than tax when there have been challenges to agency actions that violate procedural due process protections. Moderator: Sarah Lora, Legal Aid Services of Oregon, Statewide Tax Clinic. Portland, OR. Panelist: Professor Leslie Book, Charles Widger School of Law, Villanova University, Villanova, PA and Professor in Residence, Taxpayer Advocate Service, Washington, DC; Nina E. Olson, National Taxpayer Advocate, Taxpayer Advocate Service, Washington, DC; Professor Susannah Camic Tahk, University of Wisconsin School of Law, Madison, WI; Professor Jamie Andree, Maurer School of Law, Indiana University, Bloomington, IN. Cosponsored by: Individual & Family Taxation and Teaching Taxation
  • Nuts and Bolts of a Successful Pro Bono Settlement Day. A pro bono settlement day can be an effective tool to bring taxpayers, pro bono representatives, and the IRS together to resolve an ongoing controversy prior to calendar call. Partnering with local pro bono and LITC representatives, the IRS Office of Chief Counsel has participated in these settlement days across the United States. This panel will bring together practitioners and Chief Counsel representatives who have worked together to hold settlement days in their cities. The panel will share how the events were organized, their experiences during the events, best practices for how these events can be successfully duplicated in other cities, and the Tax Court’s thoughts on acknowledging limited scope representation. Moderator: Robb Longman, Longman & Van Grack LLC, Bethesda, MD. Panelists: Jennifer Breen, Morgan Lewis & Bockius, Washington, DC; Chief Special Trial Judge Lewis Carluzzo, US Tax Court, Washington, DC; Tamara Borland, Program Director, LITC Program, Taxpayer Advocate Service, Washington, DC; Bruce Meneely, Division Counsel (SB/SE), IRS, Washington, DC. Cosponsored by: Administrative Practice


Session : ABATX1986
Sales, Exchanges & Basis
Conference : 2019 May Meeting
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  • Chair: Stephen Breitstone, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY
  • Current Events. This panel will discuss current events, with a special focus on Rev. Proc. 2019-18. Rev. Proc. 2019-18 provides a safe harbor for a professional sports team to treat certain personnel contracts and rights to draft players as having a zero value. Panelists: David Shechtman, Drinker Biddle & Reath LLP, Philadelphia, PA; Michele Schlereth, Falcon Rappaport & Berkman PLLC, New York, NY; Suzanne R. Sinno, Attorney, Office of Associate Chief Counsel (Income Tax & Accounting), IRS, Washington, DC; Edward C. Schwartz, Attorney, Office of Associate Chief Counsel (Income Tax & Accounting), IRS, Washington, DC
  • Comparison of Gain Deferral Techniques – How Does a Section 1031 Exchange Measure Up to a Charitable Remainder Trust. Section 1031 exchanges still are a viable and popular technique for deferring gain on the disposition of real estate. However, it is not the only game in town. This panel will compare the two techniques. Topics to be covered will include a comparison of the economics of each technique, how to optimize the CRT, how the CRT can allow greater diversification of investments, and basis planning opportunities including planning for property with liabilities in excess of basis. Panelists: Stephen Breitstone, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY; Professor Jerome “Jerry” Hesch, Florida International University Law School, Miami, FL
  • Accommodate This: Lender Issues in Non-Safe Harbor Reverse Exchanges. The panel will address issues that arise with lenders where outside financing will be used in part to finance an accommodator’s acquisition and construction of “parked” property in a non-safe harbor reverse exchange using the Bartell format. Issues addressed will include exchangor guarantees, subordination of exchangor “equity” financing, bankruptcy concerns regarding the accommodator and its parent company, management of the accommodator entity during the parking period and lender input on the exchange documentation and process. Moderator: David Shechtman, Drinker Biddle & Reath LLP, Philadelphia, PA. Panelists: Mary Foster, 1031 Services Inc., Seattle, WA; Derrick Tharpe, Wells Fargo Company, Winston-Salem, NC
  • Is Now an Opportune Time to Establish Qualified Opportunity Funds? Panelists will review the issues that have been addressed, and those that remain unaddressed, by IRS guidance concerning qualified opportunity funds, with a specific focus on the second set of proposed regulations addressing QOFs that were released in April 2019. Funds focused on operating businesses, as well as funds focused on real property, will be discussed. Moderator: Alan S. Lederman, Gunster, Fort Lauderdale, FL. Panelists: Steve Glickman, Develop LLC, Washington, DC; Matthew E. Rappaport, Falcon Rappaport & Berkman PLLC, New York, NY; Michele Schlereth, Falcon Rappaport & Berkman PLLC, New York, NY; Leila Vaughan, Royer Cooper Cohen Braunfeld LLC, Conshohocken, PA; Julie Hanlon-Bolton, Special Counsel, IRS Associate Chief Counsel (Income Tax & Accounting), Washington, DC; Michael S. Novey, Associate Tax Legislative Counsel, Department of Treasury, Washington, DC


Session : ABATX1987
Civil & Criminal Tax Penalties
Conference : 2019 May Meeting
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  • Chair: Niles A. Elber, Caplin & Drysdale, Washington, DC
  • Reports of Subcommittees on Important Developments. Important Developments (Civil) – Michelle F. Schwerin, Capes Sokol, St. Louis, MO and Claire H. Taylor, Stokes Lawrence, Seattle, WA; Important Developments (Criminal) – Evan J. Davis, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA and Sara G. Neill, Capes Sokol, St. Louis, MO; 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 – Arielle M. Borsos, Caplin & Drysdale Chtd, Washington, DC and Jeffrey A. Neiman, Marcus Neiman & Rashbaum, Fort Lauderdale, FL
  • Internal Revenue Service, Criminal Investigation – Update. Moderator: Michael A. Villa Jr., Meadows, Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TXPanelist: Eric Hylton, Deputy Chief, IRS Criminal Investigation, Washington, DC
  • Department of Justice Tax Division – Update. Moderator: Niles A. Elber, Caplin & Drysdale Chtd., Washington, DC. Panelists: Samuel R. Lyons, Chief, Criminal Appeals and Tax Enforcement Policy Section, Department of Justice, Tax Division, 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.