American Bar Association - Section of Taxation

Session : ABATX1001
Capital Recovery & Leasing
Conference : 2010 Midyear Meeting
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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, including a discussion of various capitalization tax accounting topics and the recent Consolidated Edison Court of Federal Claims case involving leveraged lease transactions.

MODERATOR: Alison Jones, Ernst & Young LLP, Washington, DC. PANELISTS: Brandon Carlton, Taxation Specialist, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Catherine Brandt, Ernst & Young LLP, Washington, DC; Glenn Johnson, Ernst & Young LLP, Washington, DC.

Capital Recovery Issues in Qualified Disaster Areas. As part of the Emergency Economic Stabilization Act of 2008, Congress enacted a package of tax relief provisions for qualified disaster areas. These provisions include a 50% write-off for eligible property that is restored after being damaged by an eligible disaster. For this purpose, eligible property includes real property. The package of tax relief provisions also includes a provision clarifying that eligible repairs are deductible, regardless of whether a casualty loss deduction has been claimed.

MODERATOR: Katherine Breaks, KPMG LLP, Washington, DC. PANELIST: Brandon Carlton, Taxation Specialist, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC.

Session : ABATX1002
Administrative Practice
Conference : 2010 Midyear Meeting
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$30.00

Chair: Fred F. Murray, Grant Thornton LLP, Washington, DC

How To Succeed In The Fast Track Settlement Program By Really Trying. This panel will explore practical approaches to the IRS Fast Track settlement program that can facilitate or impede a successful settlement. These include, for example, appropriate ground rules for the process, the role of the Appeals officer as a neutral facilitator, the dynamics of the Fast Track settlement process and documenting the basis of settlement. The panelists will include practitioners who have been involved in Fast Track settlements either as facilitators or as advisors to the IRS or taxpayers.

MODERATORS: Steve Salch, Law Offices of Steven C. Salch, Galveston, TX; Rita A. Cavanagh, Latham & Watkins LLP, Washington, DC. PANELISTS: Daniel Wiles, PricewaterhouseCoopers LLP, Washington, DC; Kurt Meier, Deputy Chief, Office of Appeals, IRS, Washington, DC; Anthony C. Quintero, Team Case Leader, Office of Appeals, IRS, Houston, TX; Glenn M. Pederson, Team Case Leader, Office of Appeals, IRS, San Antonio, TX; Susan T. Mosley, Senior Technical Reviewer, Branch 7, Office of the Associate Chief Counsel (Procedure & Administration), IRS, Washington, DC.

Audits in the Age of Electronic Filing? Most LMSB taxpayers are now required to e-file their tax returns, which is expected to provide significant efficiencies for the IRS. One area that has been impacted is the examination process. This panel will discuss how e-file has changed the examination process, and what taxpayers should expect in the age of electronic filing.

MODERATOR: Rochelle L. Hodes, PricewaterhouseCoopers LLP, Washington, DC. PANELISTS: Darlene G. Forgy, Acting Program Manager, LMSB e-File Project Office, IRS, Washington, DC; Phillip A. Pillar, Greenberg Traurig LLP, Philadelphia, PA.

Employment Tax Audits�A Primer for How to Prepare for These Audits, What to Expect during the Audits and How to Deal with Non-Employment Tax Issues that May Arise. The panel will consider the purpose and scope of the National Research Program, the interplay between the Form 1120/1040 income tax returns and employment tax audits, the effect on taxpayers already undergoing an examination of their income tax return and what you need to be doing now to help position your client for audit should they get selected. A subsequent panel in the Employment Tax Committee later in the day will consider �normal� employment tax audits and how to manage them.

MODERATOR: Jennifer E. Breen, PricewaterhouseCoopers LLP, Washington, DC. PANELISTS: Mary Gorman, Assistant Division Counsel (SB/SE) � Prefiling, Office of Chief Counsel, IRS, Washington, DC; Michael J. Desmond, Bingham McCutcheon LLP, Washington, DC; Edward J. Leyden, Hollrah Leyden LLC, Washington, DC.

Important Developments. This panel will discuss important developments in administrative practice that have occurred since the 2009 Joint Fall CLE Meeting in Chicago, IL.

MODERATOR: Jennifer E. Breen, PricewaterhouseCoopers LLP, Washington, DC. PANELISTS: Deborah A. Butler, Associate Chief Counsel, Office of Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC; Thomas R. Thomas, Division Counsel, SB/SE Division, IRS, Washington, DC.; Kevin M. Brown, PricewaterhouseCoopers LLP, Washington, DC.

Session : ABATX1003
Affiliated & Related Corporations
Conference : 2010 Midyear Meeting
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Chair: Jonathan Forrest; Deloitte Tax 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: Victor Penico, Deloitte Tax LLP, San Francisco, CA; Steven Teplinksy, Ernst & Young LLP, Washington, DC; William Alexander, Associate Chief Counsel, Office of Associate Chief Counsel (Corporate), IRS, Washington, DC.

Common Mistakes the Average Corporate Tax Practitioner Makes When Dealing With Consolidated Returns. This panel will explore common mistakes and misconceptions the average corporate tax practitioner makes when dealing with consolidated returns.

MODERATOR: Bryan Collins, Deloitte Tax LLP, Washington, DC. PANELISTS: Joe Pari, Dewey & LeBoeuf LLP, Washington, DC; Brian Peabody, Ernst & Young LLP, Washington, DC; Donald Bakke, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC.

Session : ABATX1004
Banking & Savings Institutions
Conference : 2010 Midyear Meeting
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$30.00

Chair: Roburt J. Waldow, McDermott Will & Emery LLP, Menlo Park, CA

The Final REMIC Regulations and their Impact on Commercial Mortgages. While many aspects of the final regulations were welcomed by the industry, the requirement to retest the collateral to make sure the loans were still principally secured by real property is causing turmoil. The panel will discuss the problems created and whether changes to the regulations are needed.

MODERATOR: Charles Wheeler, Alston & Bird LLP, Washington, DC. PANELISTS: Clay Littlefield, Alston & Bird LLP, Charlotte, NC; Diana Imholtz, Attorney, Financial Institutions & Products, IRS, Washington, DC.

Hot Topics in Federal Tax Controversy. The panel will discuss recent developments in federal tax controversy that are of particular interest to those in the banking and financial services industry including the Tax Court decision in Capital One v. Commissioner and the Court of Federal Claims decision in Consolidated Edison v. US, as well as other recent decisions including Southgate, Textron and Hoosier Industries, together with other �hot topics.�

MODERATOR: Jean Pawlow, McDermott Will & Emery LLP, Washington, DC. PANELIST: Brian Kaufman, Capital One Financial Corporation, McLean, VA.

News from the Banking Front: A Conversation with the Office of Chief Counsel. This panel of attorneys from the Office of Chief Counsel will discuss current issues impacting the banking and financial services industry including recent banking legislation, mark-to-market issues, interchange and merchant discount fees, non-performing loans and other current developments.

MODERATOR: Charles Wheeler, Alston & Bird LLP, Washington, DC. PANELISTS: Stephen Larson, Associate Chief Counsel, Financial Institutions & Products, Office of Chief Counsel, IRS, Washington, DC; Nicole Cammarota, Securities & Financial Services Firm Industry Counsel, Large & Mid-Sized Business, Office of Chief Counsel, IRS, Washington, DC; John Rogers, Attorney, Financial Institutions & Products, Office of Chief Counsel, IRS, Washington, DC; Vince Guiliano, Banking Industry Counsel, Large & Mid-Sized Business, Office of Chief Counsel, IRS, Washington, DC.

Session : ABATX1005
Closely Held Businesses
Conference : 2010 Midyear Meeting
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$30.00

Chair: Gregory R. Wilson, Attorney-at-Law, San Francisco, CA

�But IRS I Only Own Part of the Property!� - The Impact of Title of Property on Tax Debt � IRS and Bankruptcy Rules.

PANELISTS: David Wooldridge, Sirote & Permutt PC, Birmingham, AL; Professor T. Keith Fogg, Villanova Law School, Villanova, PA; Marguerite Kirk, Attorney-at-Law, Arlington, TX; Buddy Sanders, Locke Lord Bissell & Liddell LLP, Houston, TX.

Ethical Issues in Representing Taxpayers before IRS Collection, Exam and other Divisions.

PANELISTS: David Wooldridge, Sirote & Permutt PC, Birmingham, AL; Professor T. Keith Fogg, Villanova Law School, Villanova, PA; Marguerite Kirk, Attorney-at-Law, Arlington, TX; Buddy Sanders, Locke Lord Bissell & Liddell LLP, Houston, TX.

A Primer on Securities Law for Non-Securities Lawyers � What Business Lawyers Should Know About Forming New Businesses and Funding Old Ones.

PANELISTS: Scott Fletcher, Vinson & Elkins LLP, Houston, TX; Carol Mattick, Carol Bavousett Mattick PC, Austin, TX.

Session : ABATX1006
Estate & Gift Taxes
Conference : 2010 Midyear Meeting
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$30.00

Chair: Martin Hall, Ropes & Gray LLP, Boston, MA

Supplemental Estate Tax Returns - Are They Really Required? This program will discuss the issue of whether a supplemental estate tax return must be filed when new information is identified after a return is filed or the results of a probate litigation change the tax liability reported on the estate tax return.

PANELIST: David Pratt, Proskauer Rose LLP, Boca Raton, FL.

Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws, from September 1, 2009 through December 31, 2009.

PANELISTS: Benjamin G. Carter, Winstead PC, Dallas, TX; Catherine V. Hughes, Attorney-Advisor, Tax Legislative Counsel, Office of Tax Policy, Department of Treasury, Washington, DC.

The Good, the Bad and Avoiding the Ugly: Mending Wayward Wealth Transfer Strategies. GRATs and installment sales often transfer wealth in a tax-efficient manner. Sometimes, they may not yield the expected results. Unsuccessful economic performance, changes in circumstances or drafting errors - these events may require an �exit� strategy. This presentation discusses various exit strategies and planning for an exit strategy before the problems arise.

PANELIST: John F. Bergner, Winstead PC, Dallas, TX.

State Death Taxes - A �Crazy Quilt�. As reported recently in one national newspaper, keeping track of the constantly changing landscape in state death taxes can be tricky. This panel will shed light on recent state level developments, review state jurisdictional bases for imposing transfer taxes and discuss techniques to minimize or avoid state taxes on in-state real estate owned by out-of-state residents.

PANELISTS: Karen Sandler Steinert, Fredrikson & Byron PA, Minneapolis, MN; James Kronenberg, Bessemer Trust, New York, NY; Dana G. Fitzsimons, Jr., McGuireWoods LLP, Richmond, VA.

Session : ABATX1007
Individual & Family Taxation
Conference : 2010 Midyear Meeting
Speaker(s) :

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$30.00

Chair: Megan L. Brackney, Kostelanetz & Fink LLP, New York, NY

Protecting Taxpayer Privacy in the Age of Computer Access to Court Records (Co-Sponsored by Standards of Tax Practice). Court records are more accessible than ever before as more and more courts utilize computer records. Unless an attorney in a family matter successfully requests that the record be sealed, private information, often including tax information, is now readily available to outsiders, including tax information that would not otherwise be public. This panel will consider the dimensions of the problem and what tax lawyers can do to educate family lawyers.

MODERATOR: Professor Toni Robinson, Quinnipiac University School of Law, Hamden, CT. PANELISTS: Professor Michael B. Lang, Chapman University School of Law, Orange, CA; David L. Rice, David Lee Rice APLC, Torrance, CA.

Cancellation of Debt Income: Understanding the Complex Tax Consequences and Reporting Requirements of Debt Discharge. This panel will cover everything you need to know about cancellation of indebtedness income issues specific to individuals, including advising individual taxpayers on how to plan transactions to minimize COD Income, as well as foreclosures, bankruptcy, timing issues, debt workouts and much more.

MODERATOR: Laura Baek, Taxpayer Advocate Service, Washington, DC. PANELISTS: Shareen Pflanz, Chief Counsel, Income Tax and Accounting, IRS, Washington, DC; Rostyslav Shiller, Attorney-Advisor, Taxpayer Advocate Service, Washington, DC; Kenneth K. Wright, Kenneth K. Wright LLC, Chesterfield, MO.

Session : ABATX1008
Investment Management
Conference : 2010 Midyear Meeting
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$30.00

Chair: Joseph A. Riley, Willkie Farr & Gallagher LLP, New York, NY

Investment Company Update: Foreign Account Tax Compliance Act of 2009; Securities Cost Basis Regulations.

MODERATOR: Keith Lawson, Investment Company Institute, Washington, DC. PANELISTS: Stephen Larson, Associate Chief Counsel, Financial Institutions & Products, Office of Chief Counsel, IRS, Washington, DC; Deanna Flores, KPMG LLP, San Diego, CA.

Trading in Energy Derivatives and Electricity Contracts.

MODERATOR: Andrea S. Kramer, McDermott Will & Emery LLP, Chicago, IL. PANELISTS: Phoebe A. Mix, Special Counsel to the Associate Chief Counsel, Office of Associate Chief Counsel (Financial Institutions and Products), IRS, Washington, DC; William R. Pomierski, McDermott Will & Emery LLP, Chicago, IL.

Hedge Funds and Offshore Funds: Cross Border Lending and Workout Activity. This program will focus on the risk of effectively connected income to foreign investors with respect to lending and workout activity by private investment funds, including private equity, hedge, loan and workout funds in view of recent IRS guidance (IRS Chief Counsel Advice Memorandum No. AM 2009-010, September 22, 2009).

MODERATOR: Raj Tanden, Proskauer Rose LLP, Los Angeles, CA. PANELISTS: John Harrell, Senior Counsel, Office of the International Tax Counsel, Department of Treasury, Washington, DC; Stuart E. LeBlang, Akin Gump Strauss Hauer & Feld LLP, New York, NY; David S. Miller, Cadwalader Wickersham & Taft LLP, New York, NY.

Session : ABATX1009
Partnerships & LLCs
Conference : 2010 Midyear Meeting
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$30.00

Chair: Susan Mello, Prudential Real Estate Investors, Parsippany, NJ

Partner/Partnership Wars: Ethical, Professional and Tax Aspects of Inconsistent Reporting Positions involving Pass-through Entities. This panel will discuss ethical, professional and tax issues in advising a partnership on tax return positions and advising partners considering inconsistent reporting positions when conflicts arise between a partner and the partnership (or other partners). Discussion models will include the attempted abandonment of a partnership interest and subsequent allocations after the purported abandonment.

MODERATOR: Sheldon Banoff, Katten Muchin Rosenman LLP, Chicago, IL. PANELISTS: Robert Keatinge, Holland & Hart LLP, Denver, CO; Peter Wilson, RSM McGladrey Inc, Chapel Hill, NC.

Hot Topics in Partnerships. This panel will discuss recent developments affecting partnerships including legislation, regulations, administrative guidance and noteworthy cases.

MODERATOR: Steven Frost, Chapman & Cutler LLP, Chicago, IL. PANELISTS: R. Brent Clifton, Locke Lord Bissell & Liddell LLP, Dallas, TX; Christopher Kelley, Special Counsel to the Associate Chief Counsel, Passthroughs & Special Industries, IRS, Washington, DC.

Feel the Love: Allocating COD Income Among Partners. When COD income arises, partners must determine how that income should be allocated. Because the income is not accompanied by cash, and because the partners may be in disparate tax postures, one or more of the partners may want (or not want) to be allocated COD income. This panel will address the factors to be taken into account by the partners in determining how to allocate the COD income.

MODERATOR: Richard Lipton, Baker & McKenzie LLP, Chicago, IL. PANELISTS: Bahar Schippel, Snell & Wilmer LLP, Phoenix, AZ; Martin Pollack, Weil Gotshal & Manges LLP, New York, NY.

Your Built-in Gain is My Built-in Pain: �704(c) Issues and Insights. This panel will include an in-depth discussion of the issues and insights of the American Bar Association Section of Taxation comment project in response to the IRS�s request for �704(c) comments under Notice 2009-70.

MODERATOR: Monte Jackel, PricewaterhouseCoopers LLP, Washington, DC. PANELISTS: Mark Wilensky, Roberts & Holland LLP, New York, NY; Paul Kugler, KPMG LLP, Washington, DC; Audrey Ellis, PricewaterhouseCoopers LLP, Washington, DC.

Session : ABATX1010
Tax Policy & Simplification
Conference : 2010 Midyear Meeting
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$30.00

Chair: Professor Reuven S. Avi-Yonah, University of Michigan Law School, Ann Arbor, MI

President Obama�s International Tax Proposals from a Broad Policy Perspective. This panel will discuss the Administration�s tax policy proposals against the background of broad policy questions like why we need to tax corporations and whether an ideal corporate tax should be worldwide or territorial in scope.

MODERATOR: Professor Reuven Avi-Yonah, University of Michigan Law School, Ann Arbor, MI. PANELISTS: Jeff Trinklein, Gibson Dunn, New York, NY; Professor William Barker, Pennsylvania State University, Dickinson School of Law, Carlisle, PA; Philip West, Steptoe & Johnson LLP, Washington, DC; Eric Solomon, Ernst & Young LLP, Washington, DC.

Death (Taxes) be Not Proud: Estate Tax Reform, a National and Comparative Perspective. This panel will comment on estate tax changes necessitated by the sunset of the 2001 tax legislation, and suggest directions for further reform. MODERATOR: Professor Roberta Mann, University of Oregon School of Law, Eugene, OR.

PANELISTS: Professor Lily Batchelder, New York University School of Law, New York, NY; Professor David Cay Johnston, Syracuse University College of Law, Syracuse, NY; Professor Walter Schwidetzky, University of Baltimore School of Law, Baltimore, MD.