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Return to American Bar Association - Section of Taxation Events Library Menu
ABA Section
of Taxation
As the national representative of the
legal profession, the mission of the ABA Section of Taxation is to serve its
members and the public through education and leadership to achieve an
equitable, efficient, and workable tax system.
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2009 May Meeting
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(c) [2009] American Bar Association.
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Showing sessions 1 - 10 of (50) TOTAL sessions
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Event : ABATX12 |
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Session : ABATX9100
Low Income Taxpayer Representation Workshop
Conference : 2009 May Meeting
Speaker(s) :
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- The Low Income Taxpayer and Pro Bono Committees proudly present the annual Tax
Workshop for new and pro bono tax practitioners.
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- 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
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- 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.
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- 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.
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- 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.
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Session : ABATX9101
Estate & Gift Taxes
Conference : 2009 May Meeting
Speaker(s) :
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- Chair: Martin Hall, Ropes & Gray LLP, Boston, MA
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- 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.
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- 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.
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- 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.
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- 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.
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Session : ABATX9102
Foreign Activities of US Taxpayers
Conference : 2009 May Meeting
Speaker(s) :
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- Chair: Bernard T. Bress, PricewaterhouseCoopers, Washington, DC
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- 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.
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- Co-Moderators : Giovanna T. Sparagna, Sutherland, Washington, DC;
Peter H. Blessing, Shearman & Sterling LLP, New York, NY.
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- 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.
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Session : ABATX9103
Standards of Tax Practice
Conference : 2009 May Meeting
Speaker(s) :
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- Chair: Professor Mona L. Hymel, University of Arizona, James E. Rogers College
of Law, Tucson, AZ
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- Opening Remarks from the Chair.
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- Important Development Update.
Panelist: Laura Gavioli, Sonnenschein Nath & Rosenthal LLP, Dallas, TX.
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- 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.
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- 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.
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- 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.
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Session : ABATX9104
Affiliated & Related Corporations
Conference : 2009 May Meeting
Speaker(s) :
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- Chair: Devon M. Bodoh, Dewey & LeBoeuf LLP, Washington, DC
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- 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.
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- 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.
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Session : ABATX9105
Banking & Savings Institutions
Conference : 2009 May Meeting
Speaker(s) :
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- Chair: Michelle M. Henkel, Alston & Bird LLP, Atlanta, GA
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- 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.
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- 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.
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- 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.
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Session : ABATX9106
Formation of Tax Policy
Conference : 2009 May Meeting
Speaker(s) :
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- Chair: Joseph Mikrut, Capitol Tax Partners LLP, Washington, DC
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- 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.
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- 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.
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Session : ABATX9107
Exempt Organizations
Conference : 2009 May Meeting
Speaker(s) :
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- Chair: Michael A. Clark, Sidley Austin LLP, Chicago, IL
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- 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.
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- Moderator : Paul J. Dostart, Dostart Clapp Gordon & Coveney LLP,
San Diego, CA.
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- 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.
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Session : ABATX9108
Capital Recovery & Leasing
Conference : 2009 May Meeting
Speaker(s) :
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- Chair: Susan Grais, Ernst & Young LLP, Washington, DC
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- 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.
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- 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
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Session : ABATX9109
Partnerships & LLCs
Conference : 2009 May Meeting
Speaker(s) :
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- Chair: R. Brent Clifton, Locke Lord Bissell & Liddell LLP, Dallas, TX
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- Opening Remarks by the Chair
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- 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.
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- 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.
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- 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.
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- 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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Showing sessions 1 - 10 of (50) TOTAL sessions
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