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2009 May Meeting


CONFERENCE RATE $299.00!
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Showing sessions 1 - 10 of (50) TOTAL sessions
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Event : ABATX12


Session : ABATX9100
Low Income Taxpayer Representation Workshop
Conference : 2009 May Meeting
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$60.00


  • The Low Income Taxpayer and Pro Bono Committees proudly present the annual Tax Workshop for new and pro bono tax practitioners.
  • Representing Low Income Taxpayers in IRS Collection Matters: Introduction & Overview. This panel will focus on current trends in IRS Collection activities as they pertain to low income taxpayers, typical collection issues faced by low income taxpayers, commonly encountered collection notices, intake practices related to LITP collection issues and the importance of financial analysis in collection issues. Moderator: Joseph Barry Schimmel, Cohen Chase Hoffman & Schimmel PA, Miami, FL. Panelists: Nina E. Olson, National Taxpayer Advocate, Taxpayer Advocate Service, IRS, Washington, DC; Professor Diana Leyden, University of Connecticut School of Law Tax Clinic, Hartford, CT; The Honorable Peter J. Panuthos, Chief Special Trial Judge, US Tax Court, Washington, DC; Paul Harrison, The Community Tax Law Project, Richmond, VA
  • Collection Alternatives. OIC, installment agreements, partial pay installment agreements, currently not collectible status and bankruptcy. Moderator : Professor Carlton M. Smith, Cardozo School of Law Tax Clinic, New York, NY. Panelists: Professor Keith Fogg, Villanova Law School Federal Tax Clinic, Villanova, PA; Kevin Gillin, Attorney, Office of Special Counsel (Procedure & Administration), IRS, Washington, DC; Professor Sandy Freund, Rutgers University School of Law, Newark, NJ; Laura Martin, Acting Collection Technical Liason, Taxpayer Advocate Service, IRS, Boston, MA.
  • ontesting Liability under IRC §6015. Innocent spouse, separation of liability & equitable relief. Moderator: Professor Dale Kensinger, University of Missouri at Kansas City Law School, Kansas City, MO. Panelists: Professor Paul M. Kohlhoff, Valparaiso University School of Law, Valparaiso, IN; The Honorable Lewis R. Carluzzo, Special Trial Judge, US Tax Court, Washington, DC; Professor Elizabeth Maresca, Fordham University School of Law, New York, NY; Jill McNabb, Attorney Advisor, National Taxpayer Advocate, IRS, Washington, DC; Kimberly Mattonen, Attorney, Office of Chief Counsel (Procedure & Administration), IRS, Washington, DC.
  • CDP Appeal of Collection Matters. Case study. Moderator: Professor Kathryn Sedo, University of Minnesota School of Law, Minneapolis, MN. Panelists: Matthew D. Lucey, Attorney, Office of Special Counsel (Procedure & Administration), IRS, Washington, DC; Professor John B. Snyder III, University of Baltimore School of Law Tax Clinic, Baltimore, MD; Professor Keith Blair, University of Baltimore School of Law, Baltimore, MD; Glenn Thomas, Attorney-Advisor, National Taxpayer Advocate, IRS, Washington, DC.


Session : ABATX9101
Estate & Gift Taxes
Conference : 2009 May Meeting
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$15.00


  • Chair: Martin Hall, Ropes & Gray LLP, Boston, MA
  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping laws, from January 1, 2009 through April 30, 2009. Panelists: Stacey Delich-Gould, Sullivan & Cromwell LLP, New York, NY; Benjamin G. Carter, Winstead PC, Dallas, TX; Catherine V. Hughes, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC.
  • Powers of Appointment and Decanting - Dealing with Tax Traps. When a beneficiary intends to exercise a limited power of appointment or when a trustee considers taking action that may affect such a power of appointment, such as decanting, two federal transfer tax hazards must be considered: 1. Restrictions imposed by GST tax regulations and 2. The so-called “Delaware Tax Trap.” This presentation will explore these perils. Panelist: Richard W. Nenno, Wilmington Trust Company, Wilmington, DE.
  • Estate Planning During Turbulent Times. This presentation will examine various estate planning techniques that are advantageous during a low interest rate environment, especially when coupled with depreciated market conditions. Panelist: David Pratt, Proskauer Rose LLP, Boca Raton, FL.
  • Alternate Valuation. This presentation will focus on proposed regulations under IRC section 2032 in response to the Kohler case, and review other problematic aspects of alternate valuation. Panelist: Joseph Barry Schimmel, Cohen Chase Hoffman & Schimmel PA, Miami, FL.


Session : ABATX9102
Foreign Activities of US Taxpayers
Conference : 2009 May Meeting
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$30.00


  • Chair: Bernard T. Bress, PricewaterhouseCoopers, Washington, DC
  • Cross-Border Case Studies. FAUST will present four case studies that will examine the various aspects of US multinational cross-border issues and planning. Topics will include cross-border mergers and acquisitions, subpart F implications, foreign tax credit issues, foreign currency issues and asset ownership.
  • Co-Moderators : Giovanna T. Sparagna, Sutherland, Washington, DC; Peter H. Blessing, Shearman & Sterling LLP, New York, NY.
  • Panelists: Mike DiFronzo, Deputy Associate Chief Counsel (International), IRS, Washington, DC; John Merrick, Special Counsel to the Associate Chief Counsel (International), IRS, Washington, DC; Barbara Felker, Chief, Branch 3, Office of Associate Chief Counsel, IRS, Washington, DC; Manal Corwin, KPMG LLP, Washington, DC; Alan Fischl, Pricewaterhouse Cooper LLP, Washington, DC; Joseph Caliano, Grant Thorton, Washington, DC; Jeffrey M. Trinklein, Gibson Dunn & Crutcher, New York, NY.


Session : ABATX9103
Standards of Tax Practice
Conference : 2009 May Meeting
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$30.00


  • Chair: Professor Mona L. Hymel, University of Arizona, James E. Rogers College of Law, Tucson, AZ
  • Opening Remarks from the Chair.
  • Important Development Update. Panelist: Laura Gavioli, Sonnenschein Nath & Rosenthal LLP, Dallas, TX.
  • Report from the IRS on Ethics. Standards of practice are a continuing area of attention by the IRS. This program will provide a report on the current activities including the status of Circular 230 amendments. Panelists: Deborah A. Butler, Associate Chief Counsel, Office of Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC; Carolyn Gray, Deputy Director, Office of Professional Responsibility, IRS, Washington, DC; Bryon Christensen, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Matthew S. Cooper, Attorney, Office of Chief Counsel (Procedure and Administration), IRS, Washington, DC; Richard S. Goldstein, Special Counsel to the Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC.
  • Ethics and FBAR. Tax return preparers are subject to the Internal Revenue Code, Circular 230 and professional standards with regard to preparation of tax returns. But, what duty does the tax return preparer have with respect to client reporting obligations under the Bank Secrecy Act and what are the governing standards? This issue arises in the context of FBAR reporting. Regulations issued under the Bank Secrecy Act require that certain foreign bank account holders file a Treasury Form TD F 90-22.1 with the IRS annually by June 30. This panel will explore the impact of FBAR reporting on the professional standards of tax return preparers. Moderator : Rochelle Hodes, PricewaterhouseCoopers LLP, Washington, DC. Panelists: Carolyn Gray, Deputy Director, Office of Professional Responsibility, IRS, Washington, DC; Scott D. Michel, Caplin & Drysdale Chartered, Washington DC; Professor Linda Galler, Hofstra University School of Law, Hempstead, NY.
  • Privileges and Client Confidentiality in Tax Practice. (Co-sponsored by Young Lawyers Forum) This panel will discuss and compare the lawyer’s ethical obligation to protect confidential client information, the attorney-client privilege, the federally authorized tax practitioner privilege and the work product privilege. Particular attention will be paid to recent developments affecting both the tax practitioner privilege and the work product privilege, including the Textron case. Moderator : Professor Michael B. Lang, Chapman University School of Law, Orange, CA. Panelists: Professor Linda Galler, Hofstra University School of Law, Hempstead, NY; Veronica Rouse, Miller & Chevalier Chartered, Washington, DC; Jerald David August, Fox Rothschild LLP, West Palm Beach, FL.


Session : ABATX9104
Affiliated & Related Corporations
Conference : 2009 May Meeting
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$30.00


  • Chair: Devon M. Bodoh, Dewey & LeBoeuf LLP, Washington, DC
  • Current Developments. This panel will review recent developments in the consolidated return area, including relevant private letter rulings and technical advice memoranda. Moderator : Jeffrey Vogel, KPMG LLP, Washington, DC. Panelists: AJ Picchione, Wilmer Hale Cutler Pickering & Dorr LLP, Boston, MA; Philip Levine, McDermott Will & Emery LLP, Washington, DC; Michelle Estrada, PricewaterhouseCoopers LLP, Boston, MA; Lawrence Axelrod, Special Counsel to the Associate Chief Counsel (Corporate), Office of Chief Counsel, IRS, Washington, DC.
  • Consolidated Return Aspects of Troubled Companies. This panel will discuss the consolidated return aspects of troubled companies including the loss disallowance rules, intercompany debt and cancellation of indebtedness. Moderator : Jonathan Forrest, Deloitte Tax LLP, Washington, DC. Panelists: Mark Silverman, Steptoe & Johnson LLP, Washington, DC; Martin Huck, Ernst & Young LLP, Washington, DC; Bryan Collins, Deloitte Tax LLP, Washington, DC; Marie Milnes-Vasquez, Senior Technical Reviewer, Branch 4, IRS, Washington, DC; William Alexander, Associate Chief Counsel, Office of Associate Chief Counsel (Corporate), IRS, Washington, DC.


Session : ABATX9105
Banking & Savings Institutions
Conference : 2009 May Meeting
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$30.00


  • Chair: Michelle M. Henkel, Alston & Bird LLP, Atlanta, GA
  • MSB Initiatives and Developments in the Banking Industry. This panel will discuss current priorities and developments in federal tax administration particular to the banking community. Topics will include Tiered Issues and the industry issue focus process as well as an update and perspective from counsel. Panelists: Walter L. Harris, Industry Director, Financial Services, Large and Mid-Size Business Division, IRS, New York, NY; Roland Barral, Area Counsel, Office of Chief Counsel, Large and Mid-Size Business Division, IRS, New York, NY.
  • Vainisi v. Commissioner: What Does It Mean for Banks? This panel will discuss the implications of the section 1361 Department of Treasury Regulations and the Tax Court’s decision in Vainisi v. Commissioner, 123 T.C. No. 1 (Jan. 15, 2009), regarding the application of special financial institution rules that reduce interest expense deductions relating to qualified tax-exempt obligations of qualified subchapter S bank subsidiaries. Moderator : Francisca N. Mordi, American Bankers Association, Washington, DC. Panelists: Vincent J. Guiliano, Banking Industry Director, LMSB Area Counsel, IRS, New York, NY; John Ensminger, Law Offices of John Ensminger, Stone Ridge, NY.
  • US v. Textron: What is the Practical Effect of the First Circuit’s Decision on the Banking Industry? After a brief overview of US v. Textron Inc and Subsidiaries, 553 F.3d 87 (1st Cir. Jan. 21, 2009), this panel will focus on (i) the accounting rules and practices relating to the content of FIN-48 workpapers, (ii) the accounting rules and practices relating to the outside auditors’ workpapers, including documentation requirements, inclusion of taxpayer’s privileged information, confidentiality requirements and ownership of the workpapers and (iii) the states’ policy for seeking FIN-48 workpapers and sharing tax-sensitive documents with the IRS and other states. This panel will then discuss practical solutions for working together to maximize transparency and privilege protection. Moderator : Michelle M. Henkel, Alston & Bird LLP, Atlanta, GA. Panelists: Roburt J. Waldow, McDermott Will & Emery LLP, Palo Alto, CA; Elizabeth Askey, Ernst & Young LLP, New York, NY; Chester Abell, Ernst & Young LLP, Washington, DC.


Session : ABATX9106
Formation of Tax Policy
Conference : 2009 May Meeting
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$30.00


  • Chair: Joseph Mikrut, Capitol Tax Partners LLP, Washington, DC
  • Recent Legislative Proposals Targeting Offshore Tax Noncompliance and Deferral. The panel will examine recent legislative proposals by members of Congress to address offshore tax evasion by US individuals, including the “Stop Tax Haven Abuse Act” and Senate Finance Committee staff proposals. The panel will also discuss proposals by the Obama Administration regarding international tax enforcement and reforming deferral. Moderator : Chris Javens, Capitol Tax Partners LLP, Washington, DC. Panelists: Joshua Odintz, Democratic Tax Counsel, Senate Committee on Finance, US Congress, Washington, DC; Tony Coughlan, Republican Tax Counsel, Senate Committee on Finance, US Congress, Washington, DC; Elise Bean, Staff Director/Chief Counsel, Senate Homeland Security and Governmental Affairs Committee, Permanent Subcommittee on Investigations, US Senate, Washington, DC; John Harrington, International Tax Counsel, Office of Tax Policy, Department of Treasury, Washington, DC; David Noren, McDermott Will & Emery LLP, Washington, DC; Payson Peabody, Dykema Gossett PLLC, Washington, DC.
  • Climate Change: What Every Tax Lawyer Needs to Know. The panel will describe and discuss different legislative proposals to address climate change, the potential effects on the economy, the Federal budgetary aspects and Federal income tax issues associated with climate change proposals. Moderator : Joseph Mikrut, Capitol Tax Partners LLP, Washington, DC. Panelists: Thomas Barthold, Deputy Chief of Staff, Joint Committee on Taxation, US Congress, Washington, DC; Carolyn Fischer, Resources for the Future, Washington, DC; Mark Price, KPMG National Tax Group, Washington, DC.


Session : ABATX9107
Exempt Organizations
Conference : 2009 May Meeting
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$60.00


  • Chair: Michael A. Clark, Sidley Austin LLP, Chicago, IL
  • The Application of Penalties to Tax-Exempt Organizations. The Code provides various penalties applicable to taxpayers; some of these penalties are applicable to tax-exempt organizations. This panel will discuss the contexts in which penalties may be applicable to tax-exempt organizations and considerations in penalty enforcement. This panel will also discuss the ethical issues involved (under Circular 230 and otherwise) in representing taxpayers engaged in transactions which may be subject to penalties.
  • Moderator : Paul J. Dostart, Dostart Clapp Gordon & Coveney LLP, San Diego, CA.
  • Panelists: Douglas M. Mancino, McDermott Will & Emery LLP, Los Angeles, CA; Don R. Spellmann, Senior Counsel, Office of Division Counsel/ Associate Chief Counsel (Tax Exempt and Government Entities), IRS, Washington, DC; Richard Riley, Foley & Lardner LLP, Washington, DC; Mark Matthews, Morgan Lewis & Bockius LLP, Washington, DC.


Session : ABATX9108
Capital Recovery & Leasing
Conference : 2009 May Meeting
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$30.00


  • Chair: Susan Grais, Ernst & Young LLP, Washington, DC
  • Current Developments Report and Update on Pending Guidance. This program will cover the important recent developments in the areas of capital recovery and leasing since the 2009 Midyear Meeting and provide an update on guidance projects in these areas, including the currently proposed tangible property regulations under section 263(a). The program will include topics such as bonus depreciation, including the election out of bonus depreciation under section 168(k)(4). Moderator : Alison Jones, Ernst & Young LLP, Washington, DC. Panelists: Brandon Carlton,Taxation Specialist, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Kathy Reed, Branch Chief, Office of Chief Counsel, Branch 7, IRS, Washington, DC; Katherine Breaks, KMPG LLP, Washington, DC; Susan Grais, Ernst & Young LLP, Washington, DC.
  • Infrastructure Transactions Update. This panel will (i) provide an overview of infrastructure projects involving private sector investment; (ii) discuss the effect of the American Recovery and Reinvestment Tax Act of 2009 on infrastructure taxpayers and (iii) discuss the open federal income tax issues encountered in infrastructure transactions. Moderator : Glenn M. Johnson, Ernst & Young LLP, Washington, DC. Panelist: Jay H. Zukerman, Ernst & Young LLP, New York, NY


Session : ABATX9109
Partnerships & LLCs
Conference : 2009 May Meeting
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$30.00


  • Chair: R. Brent Clifton, Locke Lord Bissell & Liddell LLP, Dallas, TX
  • Opening Remarks by the Chair
  • My Money Went to the Caymans and All I Got Was This Lousy Tax Bill—New Section 457A Deferred Compensation Guidance: Not Just Foreign Hedge Funds. This panel will discuss the tax issues that confront domestic and foreign partnerships with tax-exempt or foreign partners as they navigate new section 457A and Notice 2009-8. Moderator : Glenn Mincey, Deloitte Tax LLP, Washington, DC. Panelists: Steve Frost, Special Assistant to the Assistant Secretary of Treasury (Tax Policy), Office of Assistant Secretary of Treasury (Tax Policy), Department of Treasury, Washington, DC; Elizabeth Drigotas, Deloitte Tax LLP, Washington, DC; Michael Plowigan, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Helen Morrison, Deputy Benefits Tax Counsel, Office of Tax Policy, Department of Treasury, Washington, DC.
  • Debt-for-Partnership-Equity: How Much Is That Partnership Interest in the Window? This panel will discuss conversions of partnership debt for partnership equity and the proposed regulations under section 108(e)(8). How should you value the partnership interest and measure the cancellation of debt income? Planning ideas for lenders to avoid losing the deduction. Moderator : Bahar Schippel, Snell & Wilmer LLP, Phoenix, AZ. Panelists: Karen Lohnes, PricewaterhouseCoopers LLP, Washington, DC; Blake D. Rubin, McDermott Will & Emery LLP, Washington, DC.
  • The Pantomime’s Box: Series LLCs and Their Tax Treatment. This panel will discuss the Committee’s comments on series LLCs and the potential analysis to be applied to their tax treatment. When should a series be a separate partnership? What to do in the absence of guidance? Moderator : Thomas Yearout, Holme Roberts & Owens LLP, Denver, CO. Panelists: Robert R. Keatinge, Holland & Hart LLP, Denver, CO; Dianna K. Miosi, Branch Chief, Passthroughs & Special Industries, IRS, Washington, DC.
  • Hot Topics in Partnerships. This panel will discuss recent developments affecting partnerships including legislation, regulations, administrative guidance and noteworthy cases. Moderator : Jeanne M. Sullivan, KPMG LLP, Washington, DC. Panelists: Curtis G. Wilson, Associate Chief Counsel, Passthroughs & Special Industries, IRS, Washington, DC; Laura Fields, Attorney, Branch 1, Passthroughs & Special Industries, IRS, Washington, DC.



     


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