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2010 Joint Fall CLE Meeting


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Showing sessions 1 - 10 of (46) TOTAL sessions
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Event : ABATX16


Session : ABATX10100
Joint Section Breakfast/Plenary Session
Conference : 2010 Joint Fall CLE Meeting
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$15.00


  • KEYNOTE SPEAKER: Douglas H. Shulman, Commissioner, Internal Revenue Service, Washington, DC


Session : ABATX10101
Capital Recovery & Leasing (TX)
Conference : 2010 Joint Fall CLE Meeting
Speaker(s) :
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$30.00


  • Chair: Katherine Breaks, KPMG LLP, Washington, DC
  • Current Developments Report and Update on Pending Guidance. This program will cover important recent developments in the areas of capital recovery and leasing, including an update on the status of the repair regulations and a discussion of the current IRS business plan. MODERATOR: Alison Jones, Ernst & Young LLP, Washington, DC. PANELISTS: Brandon Carlton, Taxation Specialist, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Glenn Johnson, Ernst & Young LLP, Washington, DC.
  • Nonshareholder Contributions to Capital. Due to recent federal stimulus legislation, taxpayers in all types of industries have applied for, and will be receiving, federal and state government grants. The key industries that will receive funds include telecommunications, power and utilities, transportation and education businesses. In many cases, these businesses may have never received government payments before. These taxpayers are now grappling with whether the payments can be excluded from gross income as a nonshareholder contribution to capital, and, if they can, how to make associated basis adjustments. This panel will discuss recent guidance in this area, pending ruling requests and choice-of-entity issues such as whether it is more advantageous to finance eligible activities in corporate or partnership form. MODERATOR: Katherine Breaks, KPMG LLP, Washington, DC. PANELISTS: Alison Jones, Ernst & Young LLP, Washington, DC; Sam Weiler, Ernst & Young LLP, Columbus, OH.


Session : ABATX10102
Transfer Pricing (TX)
Conference : 2010 Joint Fall CLE Meeting
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$15.00


  • Chair: Darrin Litsky, Deloitte Tax, New York, NY
  • Binding Arbitration. This panel will provide an update of how the mandatory arbitration mechanism found at paragraphs 6 and 7 of Article XXVI of the USCanada Tax Convention will function and the related challenges to be met between now and December 15, 2010. In addition, the panel will also provide some practical experience on dealing with arbitration provisions, namely the EU Arbitration Convention and other treaties. MODERATOR: François Vincent, Moskowitz & Meredith LLP, Montreal, QC. PANELISTS: Lucie Bergevin, Director General, International and Large Business Directorate, Canada Revenue Agency, Ottawa, ON; IRS Representative (Invited); Brian Trauman, KPMG LLP, New York, NY.
  • US - Canada Hot Transfer Pricing Issues. This panel will address current transfer pricing issues and how the IRS and CRA are addressing them, including the treatment of intangibles, business restructurings, headquarters services, permanent establishments and voluntary disclosures. MODERATOR: David Canale, Ernst & Young LLP, Washington, DC. PANELISTS: IRS Representative (Invited); Thomas Akin, McCarthy Tétrault LLP, Toronto, ON; Shiraj Keshvani, Deloitte, Ottawa, ON.


Session : ABATX10103
Administrative Practice (TX)
Conference : 2010 Joint Fall CLE Meeting
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$30.00


  • Chair: Fred F. Murray, Grant Thornton LLP, Washington, DC
  • Important Developments. This panel will explore the significant developments in administrative practice that have occurred since the last meeting, including the recent privilege opinion issued by the DC Circuit in US v. Deloitte LLP et al. 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.
  • Back-to-Basics: IRS Appeals. This panel will provide an overview of taking a client’s matter to the IRS Appeals Office for an administrative appeal. The panel will include discussion of how to understand the IRS 30-day letter, options for preparing the protest, and the mechanics for submitting a protest. The panel will also discuss fast track appeals and early issue referrals as well as settlement of issues and proper paperwork to document resolution. MODERATOR: Kevin Johnson, Chamberlain Hrdlicka White Williams & Martin, Philadelphia, PA. PANELISTS: Ruth Perez, Deputy Chief, Office of Appeals, IRS, Washington, DC; Sheri A. Dillon, Bingham McCutchen LLP, Washington, DC.
  • Future of International Enforcement in the Burgeoning Global Economy. Globalization of private business and investment activities has been followed with interest by major tax administrations around the world on international enforcement issues. LB&I Division of the IRS and the Office of Chief Counsel have both refocused internal activities and coordination around international issues. In addition, the IRS has led or participated in multinational efforts to coordinate enforcement activities. The panel will provide an update on current IRS international enforcement and competent authority programs and consider, among other issues, this new emphasis and its effects on examinations and dispute resolution. MODERATOR: Fred F. Murray, Grant Thornton LLP, Washington, DC. PANELISTS: Michael Danilack, Deputy Commissioner, LB&I (International), IRS, Washington, DC; Steven A. Musher, Associate Chief Counsel (International), Office of Chief Counsel, IRS, Washington DC; Barry B. Shott, PricewaterhouseCoopers LLP, Washington, DC.
  • IRS’ Global High Wealth Industry—What to Expect and When. This panel will explore the mission, structure, and current operations of the recently created Global High Wealth Industry within the Large and Mid-Size Business Division, the composition and audit strategies of its exam teams, their access to industry and issue specialists throughout the IRS and its role in the overall IRS compliance strategy focused on high wealth individuals. MODERATOR: Donald T. Rocen, Miller & Chevalier Chartered, Washington, DC. PANELISTS: Donna C. Hansberry, Industry Director, Global High Wealth, LB&I, IRS, Washington, DC; Guy Bigonesse, Director, Projects and Policies Division, International & Large Business Directorate, Compliance Branch, Canadian Revenue Agency, Ottawa, ON; Miriam Fisher, Morgan Lewis & Bockius, Washington, DC. TX


Session : ABATX10104
Affiliated & Related Corporations (TX)
Conference : 2010 Joint Fall CLE Meeting
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$30.00


  • Chair: Jeffrey Vogel, KPMG LLP, Washington, DC
  • Consolidated Tax Attributes - A Discussion about OFLs and DC.
  • Current Developments in Consolidated Returns.


Session : ABATX10105
Banking and Savings Institutions (TX)
Conference : 2010 Joint Fall CLE Meeting
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$30.00


  • Chair: Roburt Waldow, McDermott Will & Emery LLP, Menlo Park, CA
  • Past, Present and Future of Equity Swaps. This panel will discuss the evolution of the tax law pertaining to total return swaps and other equity derivatives, with an emphasis on recent legislation and IRS guidance relating to these instruments. MODERATOR: Yoram Keinan, Greenberg Traurig, New York, NY. PANELISTS: TBD.
  • REMIC Update and Other Emerging Issues. This panel will focus on recent REMIC developments and other current and anticipated issues facing the banking and financial services industries. MODERATOR: Clay Littlefield, Alston & Bird LLP, Charlotte, NC. PANELIST: John Baron, Alston & Bird LLP, Charlotte, NC.
  • US Borrowing Activities of Foreign Investors and the Shadow Banking System of Increased Reporting. This panel will examine the FATCA provisions contained in the recent HIRE legislation, focusing on the manner in which the legislation affects foreign investors in the US. MODERATOR: Babak E. Nikravesh, Jones Day, San Francisco, CA. PANELISTS: Edward T. Kennedy, Jones Day, New York, NY; TBD.


Session : ABATX10106
Business Planning Group (TE), Closely Held Businesses (TX) and S Corporations (TX)
Conference : 2010 Joint Fall CLE Meeting
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$30.00


  • Business Planning Group (TE) Chair: William S. Forsberg, Leonard Street & Deinard, Minneapolis, MN Closely Held Businesses (TX) Chair: Gregory R. Wilson, Attorney-at-Law, San Francisco, CA S Corporations (TX) Chair: John B. Truskowski, Locke Lord Bissell & Liddell LLP, Chicago, IL
  • Important Developments. Discussion of recent legislative, administrative and judicial developments relating to S corporations and other closely held businesses and their owners. MODERATOR: Dana Lasley, Deloitte Tax LLP, St. Louis, MO. PANELISTS: Steven B. Gorin, Thompson Coburn LLP, St. Louis, MO; William P. Prescott, Wickens Herzer Panza Cook & Batista Co, Avon, OH.
  • Choice of Entity in Light of New and Proposed Legislation. Discussion of structuring a new business and the impact of new and proposed legislation on selecting the form for a new business. MODERATOR: William Klein, Gray Plant Mooty, Minneapolis, MN. PANELISTS: Thomas J. Nichols, Meissner Tierney Fisher & Nichols SC, Milwaukee, WI; Allen Sparkman, Sparkman Shaffer Perlick LLP, Denver, CO.
  • International Tax Aspects of Cross Border Business of Closely Held Businesses in Canada. This panel will review the Canadian and US tax implications of closely held businesses that carry on cross border business with Canada. MODERATOR: David Nielsen, Deloitte Tax LLP, Toronto, ON. PANELISTS: Jim Hutchinson, Miller Thomson, Toronto, ON; Laura Howell- Smith, Deloitte Tax LLP, Washington, DC.


Session : ABATX10107
Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE)
Conference : 2010 Joint Fall CLE Meeting
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$30.00


  • Estate & Gift Taxes Chair: Paul E. Van Horn, McLaughlin & Stern LLP, New York, NY
  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since May 1, 2010. PANELISTS: Benjamin G. Carter, Winstead PC, Dallas, TX; Stacey Delich- Gould, Cahill Gordon & Reindel LLP, New York, NY; Catherine V. Hughes, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC.
  • Transfers to Non-US Spouses – QDOTs and Other Options. This program reviews the limitations on the availability of the Federal gift and estate tax marital deduction where the donee or surviving spouse is not a US citizen. The discussion explores lifetime gift planning, the qualification and use of qualified domestic trusts (QDOTs), planning where retirement benefits arepost-mortem planning to minimize the impact of these limitations. SPEAKER: Douglas L. Siegler, Sutherland Asbill & Brennan LLP, Washington, DC.
  • Expatriation Under Section 877A's Mark-To-Market System, and What Notice 2009-85 Did and Did Not Tell Us. Effective for expatriations on or after June 17, 2008, the US Congress introduced a mark-to-market expatriation tax system and a companion succession tax provision in place of the prior alternative tax regime on expatriates. On November 9, 2009, the IRS released Notice 2009-85 providing guidance on certain issues under Section 877A, but leaving other issues unanswered. This presentation will discuss the new regime and what the Notice tells us about its operation, and will also highlight some of the remaining issues the IRS and Department of Treasury need to address before taxpayers and advisors can comfortably navigate the new law. SPEAKER: Summer Ayers LePree, Holland & Knight, Miami, FL.
  • Tax Issues in International Philanthropy. Cross-border philanthropy is on the rise as international borders no longer limit the charitable goals of donors and charitable institutions alike. This presentation will address tax and administrative considerations for international philanthropic giving by individual and corporate donors, as well as charitable entities participating in international grantmaking and/or operations. Included will be a discussion of various alternatives for facilitating international philanthropic activities, including the use of so-called "friends of" organizations, international charitable institutions (with or without domestic affiliates), anti-terrorism financing rules, and special rules applicable to international grantmaking by US private foundations. SPEAKER: Ellen E. Halfon, Jones Day, Cleveland, OH.


Session : ABATX10108
Individual & Family Taxation (TX)
Conference : 2010 Joint Fall CLE Meeting
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$30.00


  • Chair: Megan L. Brackney, Kostelanetz & Fink, LLP New York, NY
  • Collection: Current Issues and Comparative Perspectives. This panel will discuss strategies for representing individual clients in collection proceedings, as well as current issues in collection, such as the declining viability of Offers in Compromise. In addition, we will explore Canada’s tax collection procedures and what we can learn from each other’s experiences. MODERATOR: Megan L. Brackney, Kostelanetz & Fink LLP, New York, NY. PANELISTS: Nina E. Olson, National Taxpayer Advocate, Washington, DC; Professor Leslie Book, Villanova University School of Law, Villanova, PA; David Malach, Aird & Berlis LLP, Toronto, Canada; Darrell J. Wickstrom, Fasken Martineau, Toronto, Canada.
  • Tax Consequences of Disasters. Disasters such as the Deepwater Horizon Oil Spill in the Gulf of Mexico, flooding in Arkansas and Tennessee, Tropical Storm Alex and an earthquake in Haiti cause havoc in the lives of many individuals and result in significant disruption to businesses. The panel will focus on the tax aspects of disasters including payments received for lost business income, lost wages, lost profits, property damage or destruction, physical injuries, sickness, emotional distress and charitable contributions and how they should be treated for tax purposes. The panel will compare the tax treatment of payments for disasters in the US with how payments are treated in Canada.MODERATOR: Dianne Mehany, Caplin & Drysdale Chartered, Washington, DC. PANELISTS: Professor Francine J. Lipman, Chapman University School of Law, Orange, CA; Louise R. Summerhill, Aird & Berlis, Toronto, Canada; TBD.


Session : ABATX10109
Investment Management (TX)
Conference : 2010 Joint Fall CLE Meeting
Speaker(s) :
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$30.00


  • Chair: Joseph A. Riley, Willkie Farr & Gallagher LLP, New York, NY
  • RIC Modernization Legislation. MODERATOR: Kristin M. McKenna, Stradley Ronon Stevens & Young LLP, Philadelphia, PA. PANELISTS: TBD.
  • Carried Interest. MODERATOR: Arnold P. May, Proskauer Rose LLP, Boston, MA. PANELISTS: TBD.
  • Partnership Allocations. MODERATOR: TBD. PANELISTS: TBD.



     


Showing sessions 1 - 10 of (46) TOTAL sessions
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