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2010 May Meeting


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Showing sessions 1 - 10 of (48) TOTAL sessions
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Event : ABATX15


Session : ABATX10050
Low Income Taxpayers Workshop
Conference : 2010 May Meeting
Speaker(s) :
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$45.00


  • Opening Remarks by Paul Harrison, Workshop Coordinator
  • Making a Claim for Attorney’s Fees. The panel will discuss the circumstances in which clinics could or should seek attorney’s fees. Included in the discussion will be an analysis of when, how and in what amount to make qualified offers; record keeping requirements when you have a case in which you anticipate seeking attorney’s fees; exhausting administrative remedies and other practical and legal considerations surrounding a claim for attorney’s fees. MODERATOR: Professor Sandy Freund, Rutgers University School of Law, Newark, NJ. PANELISTS: Robin Wright Westbrook, Practitioner in Residence, Janet R. Spragens Tax Clinic, American University Washington College of Law, Washington, DC; Shannon Brophy, Attorney, Office of Chief Counsel, Procedure and Administration, IRS, Washington, DC; Christopher M. Duling, Attorney-Advisor, LITC Program Office, IRS, Washington, DC.
  • Filing a Refund Claim and a Refund Suit. The panel will discuss those situations in which a clinic could or should pursue a refund claim as well as the refund issues presented in audit reconsideration, innocent spouse and frozen refund situations. MODERATOR: Dale Kensinger, Attorney, Chestnut Hill, MA. PANELISTS: Professor Keith Blair, University of Baltimore School of Law, Baltimore, MD; The Honorable Peter J. Panuthos, Chief Special Trial Judge, US Tax Court, Washington, DC; Elizabeth Segovis, Rhode Island Legal Services Inc, Providence, RI.
  • Whistleblower Claims. Low income clinics will rarely qualify for the formal whistleblower claims that guarantee payment for certain high dollar tips but situations exist in which using the whistleblower process may facilitate IRS movement on a case as well as the prospect for a monetary reward to the client or the clinic. MODERATOR: Paul Harrison, Community Tax Law Project, Richmond, VA. PANELISTS: Erica Brady, The Ferraro Law Firm, Washington, DC.


Session : ABATX10051
Administrative Practice
Conference : 2010 May Meeting
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$30.00


  • Chair: Fred F. Murray, Grant Thornton LLP, Washington, DC
  • Important Developments. This panel will discuss important developments in administrative practice that have occurred since the last meeting. Moderator: Jennifer E. Breen, PricewaterhouseCoopers LLP, Washington, DC. Panelists: Deborah A. Butler, Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC.
  • Back-to-Basics: Refunds, Credits and Tentative Carryback Adjustments -- When the Government Owes You Money. This panel will provide an overview of the different ways to claim refunds and credits from the government from both the taxpayer and IRS perspectives. The panel will examine issues concerning: how, when and what type of claim to make; preparation of the claim forms; the process within the IRS once a claim is made; the effect of the new five-year NOL carryback and other strategic considerations. Moderator: Kevin R. Stults, Bingham McCutchen LLP, Washington, DC. Panelists: Matthew S. Cooper, Attorney-Advisor, Branch 1, Office of Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC; Kevin Johnson, Chamberlain Hrdlicka White Williams & Martin, Philadelphia, PA; Patricia L. Burquest, KPMG LLP, Washington, DC.
  • The New IRS Corporate Governance Tax Compliance Initiative. Last October IRS Commissioner Shulman told an audience of corporate directors that "you, the leaders of your organizations, should have a mechanism to oversee tax risk as part of your governance process," and he announced that his goal was "to start a discussion about the board of directors' role in overseeing tax risk." As the Commissioner noted, the IRS interest in the role of corporate governance in managing tax risk did not start in the US. Tax administrators around the world are ahead of the IRS in using this new approach to tax compliance. Why? What is this new initiative? How does it relate to the new IRS initiative to require disclosure of uncertain tax positions? How will it affect your clients, and what can you and your clients expect from the IRS as this new initiative unfolds? The panel will cover these and other issues related to LMSB enforcement. Moderator: Lawrence B. Gibbs, Miller & Chevalier Chartered, Washington, DC. Panelists: Heather C. Maloy, Commissioner, Large and Mid-Size Business Division, IRS, Washington, DC; Mark A. Weinberger, Ernst & Young LLP, Washington, DC; David P. Lewis, Eli Lilly & Company, Indianapolis, IN; Fred F. Murray, Grant Thornton LLP, Washington, DC.
  • Announcement 2010-9: A New Age of Transparency? The panel will discuss the proposed tax return reporting of uncertain tax positions set forth in Announcement 2010-9. Topics will include the reasons for the proposed changes, the anticipated interaction with work product and attorney-client privilege protections and the potential effects on the relationships between taxpayers, financial auditors and the IRS. Moderator: Julia M. Kazaks, Skadden Arps Slate Meagher & Flom LLP, Washington, DC. Panelists: Heather C. Maloy, Commissioner, Large and Mid-Size Business Division, IRS, Washington, DC; Pamela F. Olson, Skadden Arps Slate Meagher & Flom LLP, Washington, DC; Eli J. Dicker, Tax Executives Institute Inc, Washington, DC.


Session : ABATX10052
US Activities of Foreigners & Tax Treaties
Conference : 2010 May Meeting
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$30.00


  • Chair: Edward Tanenbaum, Alston & Bird LLP, New York, NY
  • Branch Profits Taxes – Another Item to Add to Your Checklist. This panel will provide a summary of the branch profits tax rules coupled with an illustration and discussion of the rules in a variety of practical commercial settings. MODERATOR: William S. Dixon, Citigroup Global Markets Inc, New York, NY. SPEAKERS: Peter J. Connors, Orrick Herrington & Sutcliffe LLP, New York, NY; Alan W. Granwell, DLA Piper LLP (US), Washington, DC.
  • Hot Topics in US Withholding Tax and Reporting Rules. The IRS has made US withholding taxes a Tier 1 audit priority and Congress is considering implementing a new withholding tax regime to catch offshore US tax evasion. This panel will discuss key developments and what taxpayers need to do to avoid potentially substantial tax liabilities for failure to comply. MODERATOR: John Staples, Burt, Staples & Maner, LLP, Washington, DC. SPEAKERS: Edward Tanenbaum, Alston & Bird LLP, New York, NY; Karan Mosley, Barclays Capital, New York, NY; Michael Danilack, Deputy Commissioner LMSB, IRS, Washington, DC.


Session : ABATX10053
Affiliated & Related Corporations
Conference : 2010 May Meeting
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$30.00


  • 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: Mark Schneider, Deloitte Tax LLP, Washington, DC. PANELISTS: Marie Milnes-Vasquez, Office of the Associate Chief Counsel (Corporate), IRS, Washington, DC; Michael Wilder, McDermott Will & Emery LLP, Washington, DC; Alexandra Yeadon, KPMG LLP, Washington, DC.
  • Consolidated Return Issues for Troubled Companies. This panel will explore consolidated return issues that arise for troubled companies including issues surrounding the application of section 108(i) and the extended loss carryback rules. MODERATOR: Professor Don Leatherman, University of Tennessee College of Law, Knoxville, TN. PANELISTS: Michelle Albert, Ernst & Young LLP, Washington, DC; Larry Axelrod, Office of the Associate Chief Counsel (Corporate), IRS, Washington, DC; Jonathan Forrest, Deloitte Tax LLP, Washington, DC.


Session : ABATX10054
Banking and Savings Institutions
Conference : 2010 May Meeting
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$30.00


  • Chair: Roburt Waldow, McDermott Will & Emery LLP, Menlo Park, CA
  • The Straddle Rules: Past, Present and Future. The straddle rules, which were enacted in 1981 but significantly revised and expanded in 1984, were meant to close certain loopholes. The pros and cons of the straddle rules have been debated for years. To commemorate the 25th anniversary of the expanded straddle rules, this panel will debate some of the issues presented by these rules. Moderator: Yoram Keinan, Greenberg Traurig LLP, New York, NY. Panelists: John Ensminger, Stone Ridge, NY; Robert Gordon, Twenty First Securities, New York, NY.
  • The Interplay Between RAAP, GAAP and Tax for Banks. This panel will discuss differences between GAAP tax accounting, Regulatory accounting and tax accounting rules, including varying treatments of the timing of the recognition of deferred tax assets, which are influencing Bank's business decisions. Moderator: Hayden Brown, Mayer Brown LLP, Charlotte, NC. Panelists: TBD.
  • Developments in Cross-Border Withholding and Reporting Rules for Financial Instruments and Other Hot Topics. This panel will discuss recent legislative and regulatory developments relating to the imposition of US withholding taxes on cross-border equity derivatives, including a discussion of the broader implications for financial product taxation. This panel will also discuss other "hot" topics relating to financial products and capital markets transactions, including a discussion of the impact of current derivatives reform proposals on the taxation of financial instruments. Moderator: William R. Pomierski, McDermott Will & Emery LLP, Chicago, IL. Panelists: TBD.


Session : ABATX10055
Capital Recovery & Leasing
Conference : 2010 May Meeting
Speaker(s) :
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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, including a discussion of various capitalization tax accounting topics. MODERATOR: Alison Jones, Ernst & Young LLP, Washington, DC. PANELISTS: Brandon Carlton, Taxation Specialist, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Sam Weiler, Ernst & Young LLP, Washington, DC.
  • Back to Basics: A Topical Discussion of Lease vs. Sale Principles. This panel will discuss prevalent lease vs. sale issues, including accounting method considerations. MODERATOR: Glenn Johnson, Ernst & Young LLP, Washington, DC. PANELIST: Catherine Brandt, Ernst & Young LLP, Washington, DC.
  • Discussion of Tier 1 Repair Directives and IRS Examination Considerations. This panel will discuss significant topics involving IRS examination of repair issues, in light of the IRS’ recent release of two Industry Director Directives that designate repairs as a Tier 1 issue and seek to provide direction regarding the examination of taxpayers that have changed their accounting method to currently expense previously capitalized repair costs. MODERATOR: Susan Grais, Ernst & Young LLP. PANELISTS: Cheryl Claybough, Director of Pre-Filing and Technical Guidance, IRS, Washington, DC; Sharon Kay, Ernst & Young, LLP, Washington, DC.


Session : ABATX10056
Real Estate
Conference : 2010 May Meeting
Speaker(s) :
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$30.00


  • Chair: Jim Sowell, KPMG LLP, Washington, DC
  • Legislative Update and other Real Estate Hot Topics. This panel will provide an update on domestic and international real estate tax legislative developments as well as recent rulings, proposed and final regulations and cases that impact the real estate industry. MODERATOR: Peter J. Genz, King & Spalding LLP, Atlanta, GA. PANELISTS: Tony M. Edwards, National Association of Real Estate Investment Trusts, Washington, DC; Stephen E. Shay, Deputy Assistant Secretary - International Tax Affairs, Office of Tax Policy, Department of Treasury, Washington, DC; David B. Silber, Chief, Branch 2, Office of Associate Chief Counsel (Financial Institutions & Products), IRS, Washington, DC; Jonathan D. Silver, Attorney-Advisor, Office of Associate Chief Counsel (Financial Institutions & Products), IRS, Washington, DC.
  • It’s Easy Bein’ Green – A Primer on Green Tax Incentives. Green tax incentives have become an increasingly important component of real estate transactions. This panel will provide an overview of the available incentives and how to use them to your client’s advantage. MODERATOR: John P. Gimigliano, KPMG LLP, Washington, DC. Panelist: Holly H. Heer, Squire Sanders, Columbus, OH.
  • Carried Interests in Real Estate Transactions – What Does the Future Hold? The carried interest legislation has been the subject of great debate from a policy perspective, but few have focused on the details of what is being proposed. The proposed legislation does much more than convert the "carry" to ordinary income and, if enacted, would significantly impact the real estate industry. This panel will focus on the technical details of the legislation, with significant input from Government panelists. MODERATOR: Jim Sowell, KPMG LLP, Washington, DC. PANELISTS: Michael J. Hauswirth, Legislation Counsel, Joint Committee on Taxation, US Congress, Washington, DC; Jeffrey Van Hove, Deputy Tax Legislative Counsel – Regulatory Affairs, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC.
  • Holding Real Estate in Series LLCs – The Smoke Begins to Clear. This panel will discuss the anticipated regulations related to the taxation of series LLCs and the utility of such a structure in real estate transactions. MODERATOR: Thomas E. Yearout, Holmes Roberts & Owen LLP, Denver, CO. PANELISTS: Robert J. Crnkovich, Senior Counsel, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Steven G. Frost, Chapman & Cutler LLP, Chicago, IL; Howard J. Levine, Roberts & Holland LLP, Washington, DC.


Session : ABATX10057
Tax Policy & Simplification
Conference : 2010 May Meeting
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$30.00


  • Chair: Professor Reuven Avi-Yonah, University of Michigan Law, Ann Arbor, MI
  • Are State VATs Viable? This panel will discuss recent attempts by several states (Michigan, New Hampshire, and current proposals in California) to replace their corporate and/or sales tax with a state VAT. Can states have a VAT in the absence of a Federal VAT? Experience with VATs with open borders in the EU and in Brazil will be considered. MODERATOR: Professor Reuven Avi-Yonah, University of Michigan Law, Ann Arbor, MI. PANELISTS: Professor Richard Pomp, University of Connecticut School of Law, Hartford, CT; Professor Kirk Stark, University of California, Los Angeles, School of Law, Los Angeles, CA; Professor Richard Ainsworth, ADP and Boston University School of Law, Boston, MA; Linneu Mello, Rio de Janeiro, Brazil.
  • Will Healthcare Reform Hurt Tax Policy? This panel will discuss the potential impact of healthcare reform on tax policy, including the policy pros and cons for the exemption for employer-provided healthcare, the medical expense deduction and excise taxes on high value plans. MODERATOR: Professor Roberta Mann, University of Oregon School of Law, Eugene, OR. PANELISTS: Thomas Barthold, Joint Committee on Taxation, US Congress, Washington, DC; Roberton Williams, Tax Policy Center, Urban Institute, Washington, DC; Jennifer Bell, Patton Boggs LLP, Washington, DC.


Session : ABATX10058
Estate & Gift Taxes
Conference : 2010 May Meeting
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$30.00


  • Chair: Martin Hall, Ropes & Gray LLP, Boston, MA
  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws, from January 1, 2010 through April 30, 2010. PANELISTS: Benjamin G. Carter, Winstead PC, Dallas, TX; Stacey Delich-Gould, Sullivan & Cromwell LLP, New York, NY; Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC.
  • Funding Estate Tax Liabilities – Graegin Loans and Other Options. This panel will review the alternatives available to an estate for funding estate tax liabilities in cases where illiquid assets are present. Case law on the deductibility of interest expenses associated with loans used to pay estate taxes will be addressed. There will also be an economic analysis of the benefits of so called "Graegin" loans and the practical considerations for an executor who is contemplating borrowing options. PANELISTS: Farhad Aghdami, Williams Mullen, Richmond, VA; Janine A. Racanelli, JPMorgan Private Bank, New York, NY.
  • Estate Tax Legislative Update. This presentation will take an up-to-the-minute look at the estate tax legislative climate. If Congress has acted, the panel will analyze that action and its effect on our clients and our practices. If Congress has not acted, the panel will examine the political, fiscal and practical prospects for legislation and the issues confronting us in the meantime, including: the interpretation of formula clauses in 2010; carryover basis; drafting challenges and opportunities; planning opportunities and risks in 2010; the inscrutable face of the 2011 GST tax and the possibility and effectiveness of retroactive legislation. PANELISTS: Ronald D. Aucutt, McGuireWoods LLP, Washington, DC; Beth Shapiro Kaufman, Caplin & Drysdale Chartered, Washington, DC; Mary Ann Mancini, Bryan Cave LLP, Washington, DC.


Session : ABATX10059
Exempt Organizations
Conference : 2010 May Meeting
Speaker(s) :
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$90.00


  • Chair: Frederick J. Gerhart, Dechert LLP, Philadelphia, PA
  • News from the IRS and Department of Treasury. Representatives from the IRS and from the Department of Treasury will speak on recent developments and pending guidance. MODERATOR: Joseph E. Lundy, Lundy & Flynn LLP, Bala Cynwyd, PA. PANELISTS: Emily M. Lam, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Lois G. Lerner, Director, Exempt Organizations, IRS, Washington, DC; Catherine E. Livingston, Assistant Chief Counsel, Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities), IRS, Washington, DC.
  • News from the Hill. Speakers from Congressional tax-writing committees will address issues raised by recent and pending legislation relevant to exempt organizations. MODERATOR: Betsy Buchalter Adler, Adler & Colvin, San Francisco, CA. PANELISTS: Gordon Clay, Legislative Counsel, Joint Committee on Taxation, US Congress, Washington, DC; Theresa Pattara, Tax Counsel, Minority Staff, Senate Finance Committee, US Congress, Washington, DC; Tiffany Smith, Tax Counsel, Majority Staff, Senate Finance Committee, US Congress, Washington, DC.
  • The Plight of Newspapers: Can Tax-Exempt Organizations Help? The panel will explore the issues faced not only by tax-exempt organizations that operate newspapers and other news media, but also by the charities and private foundations that support news media, including recent examples of such activities. MODERATOR: Suzanne Ross McDowell, Steptoe & Johnson LLP, Washington, DC. PANELISTS: Professor Harvey P. Dale, University Professor of Philanthropy and the Law, New York University School of Law, New York, NY; Richard Tofel, ProPublica, New York, NY; Douglas N. Varley, Caplin & Drysdale Chartered, Washington, DC.
  • Exempt Organizations Committee Luncheon X INTRODUCTION: Celia Roady, Morgan Lewis & Bockius LLP, Washington, DC. SPEAKER: Mary Elcano, American Red Cross, Washington, DC.
  • Bankruptcy and Creditors’ Rights in a Charitable Context. Panelists will discuss the many issues facing charities in financial distress, including the application of bankruptcy laws and procedures, the treatment of endowment funds, the relative priority of donor restrictions and creditors’ rights and the risk of personal liability for employee trust fund taxes. MODERATOR: Professor Evelyn Brody, Chicago-Kent College of Law, Chicago, IL. PANELISTS: Douglas M. Mancino, McDermott Will & Emery LLP, Los Angeles, CA; Linda Manley, Lawyers Alliance of New York, New York, NY.
  • Affiliated Organizations – Avoiding Traps for the Unwary. Panelists will address issues posed by affiliations between 501(c)(3) and non-(c)(3) organizations, including the reasons for creating affiliates (such as the effect of the Supreme Court’s recent decision in Citizens United), employment taxes, employee benefit plans, use of intangible assets, federal and state lobbying disclosure laws, Form 990 reporting, common paymaster procedures and accounting rules. MODERATOR: John Pomeranz, Harmon Curran Spielberg & Eisenberg LLP, Washington, DC. PANELISTS: Eve Borenstein, Borenstein & McVeigh Law Office LLC, Minneapolis, MN; Anne Spielberg, Harmon Curran Spielberg & Eisenberg LLP, Washington, DC; Douglas N. Varley, Caplin & Drysdale Chartered, Washington, DC.



     


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