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2013 Joint Fall CLE Meeting

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(c) [2013] American Bar Association.
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Showing sessions 1 - 10 of (48) TOTAL sessions
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Event : ABATX25


Session : ABATX13100
Transfer Pricing (THURSDAY)
Conference : 2013 Joint Fall CLE Meeting
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  • Chair: Matthew Frank, GE Company, Fairfield, CT
  • Transfer Pricing from the West Coast: Bay Area Tax Directors’ Perspective. The West Coast, and particularly the San Francisco Bay Area, is home to a diverse and dynamic set of companies that address the leading edge of tax issues. In this session, distinguished tax directors offer their perspectives on the current transfer pricing issues they are facing, including thoughts on intangibles, BEPS and challenges facing the international tax regime. Moderator: Fred Chilton, McDermott Will & Emery LLP, Silicon Valley, CA Panelists: Alan Sankin, Dolby Laboratories Inc, San Francisco, CA; Barry Slivinsky, Adobe Systems, Silicon Valley, CA; Peter Waterstreet, Synopsys Inc, Silicon Valley, CA; Mitchell McPeek, Coherent Inc, Silicon Valley, CA; Steven Shee, SanDisk Inc, Silicon Valley, CA


Session : ABATX13101
Capital Recovery & Leasing
Conference : 2013 Joint Fall CLE Meeting
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  • Chair: Glenn Johnson, EY, Washington, DC
  • Current Developments Report and Update on Pending Guidance. This panel will cover the important recent developments in the areas of capital recovery and leasing. Moderator: Sam Weiler, EY, Washington, DC Panelists: Scott Mackay, Taxation Specialist, Office of Tax Policy, Department of Treasury, Washington, DC; Kathleen Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; David Strong, Crowe Horwath LLP, Grand Rapids, MI
  • Research and Development: A Discussion of Recent Developments and Overlying Issues. The year 2012 has brought about some unexpected changes related to the research credit under section 41. The American Taxpayer Relief Act of 2012 made some changes to the research credit that could have unexpected consequences for taxpayers in controlled groups, or that have experienced recent business acquisitions. The IRS Large Business & International Division has made some significant changes to its approach in examining the research credit, which are largely helpful to resolving examinations, e.g., issuing two directives eliminating the Tier I initiative and providing a certification process for taxpayers in the pharmaceutical industry. This panel will discuss these developments. Moderator: David Hudson, EY, Washington, DC Panelists: Brandon Carlton, EY, Washington, DC; Roger L. Kave, Senior Counsel, LB&I, Office of Chief Counsel, IRS, Los Angeles, CA
  • Tax Credit Hot Topics. This panel will discuss recent cases and IRS guidance in the tax credits arena, including recent rulings regarding the historic tax credit (e.g., the Historic Boardwalk case) and production tax credit (e.g., the impact of and issues with Notice 2013-29). Moderator: Tom Windram, McGladrey LLP, Washington, DC Panelist: Courtney Sandifer, PricewaterhouseCoopers LLP, Washington, DC


Session : ABATX13102
Transfer Pricing (FRIDAY)
Conference : 2013 Joint Fall CLE Meeting
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  • Chair: Matthew Frank, GE Company, Fairfield, CT
  • Leading Transfer Pricing Cases in Current Litigation. There is an unusual number of prominent transfer pricing cases currently in litigation in the US, including Eaton, Amazon, Caterpillar, and several so-called 936 flip cases. This session will highlight some of the key issues in those cases, the prospect of more transfer pricing litigation, and the importance of these developments for taxpayers. The session will also address the impact the new IRS Transfer Pricing Organization (TPO) is having on the development and litigation of transfer pricing cases. Moderator: John Peterson, Baker & McKenzie LLP, Palo Alto, CA Panelist: Mark A. Oates, Baker & McKenzie LLP, Chicago, IL
  • The 3M Case and Blocked Income. For the first time in almost 20 years, a recently filed US Tax Court case, 3M Co. v. Comm’r, challenges the validity of the 1.482-1(h)(2) regulations on Foreign Legal Restrictions. This session will examine the blocked income issue in detail, including the regulatory framework and its history, the issues raised by the 3M litigation, and second-level issues with a blocked income filing position, such as the events that can terminate blocked income treatment. Moderator: John Magee, Bingham McCutchen, Washington, DC Panelists: Rob Culbertson, Covington & Burling LLP, Washington, DC; Lowell Yoder, McDermott Will & Emery LLP, Chicago, IL


Session : ABATX13103
Administrative Practice
Conference : 2013 Joint Fall CLE Meeting
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  • Chair: Kevin Johnson, Pepper Hamilton LLP, Philadelphia, PA
  • Current Developments. The panel will address current developments in the practice before the IRS. Moderator: Bryon Christensen, Amazon.com, Seattle, WA Panelists: Alexandra Minkovich, Associate Legislative Counsel, Department of Treasury, Washington, DC; Matthew S. Cooper, Special Counsel, Procedure and Administration, Office of Associate Chief Counsel, IRS, Washington, DC
  • Phone a Friend: When and How to Involve Others in the Government When Your Corporate Examination Languishes. This panel will explore delicate issues that may develop in examinations that fall behind schedule, include critical decisions made without the taxpayer, involve difficult personalities, and other similar problems. How do you use your “contacts” to your best advantage? When do you elevate an issue and when should you not? What do the recent developments in IRS issue management and issue coordination mean for control of your issue or your case? Our panel of experts will share their ideas and invite your questions on best practices for “phoning a friend” when your examination languishes. Moderator: Phillip Pillar, Grant Thornton LLP, Philadelphia, PA Panelists: Maria Hwang, Director, Field Operations West, CTM, LB&I, IRS, Oakland, CA; Patricia Chaback, EY, San Francisco, CA; Eli Dicker, Tax Executives Institute Inc, Washington, DC


Session : ABATX13104
Affiliated & Related Corporations
Conference : 2013 Joint Fall CLE Meeting
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  • Chair: Matthew E. Gareau, Deloitte Tax LLP, Washington, DC
  • Tax Issues Arising from Tax Sharing Agreements. Tax sharing agreements come in two basic varieties: “static” agreements (prescribing rights and responsibilities among members of a consolidated group) and “dynamic” agreements (addressing tax issues in acquisition/disposition transactions when members join or leave a group). After reviewing the “blocking and tackling” aspects of these agreements, panelists will explore some of the technical tax issues arising from amounts paid and amounts not paid, including the collateral E&P and stock basis consequences. A government representative will offer views on the rules and issues to be discussed. Moderator: David Friedel, PricewaterhouseCoopers LLP, Washington, DC Panelists: Lawrence Axelrod, Special Counsel to the Associate Chief Counsel, Corporate, Office of the Chief Counsel, IRS, Washington, DC; Julie Hogan Rodgers, WilmerHale, Boston, MA; Christopher Nelson, EY, Washington, DC
  • Intercompany Debt Issues and Traps: A Discussion and Overview of the Rules Governing the Treatment of Intercompany Obligations, with a Transactional Focus. We will examine the treatment of intercompany obligations in a number of transactional fact patterns, including those that trigger the deemed satisfaction and reissuance model of Treasury Regulation 1.1502-13(g) and those to which an exception applies. Moderator: Jonathan Forrest, Deloitte Tax LLP, Washington, DC Panelists: Marc Countryman, EY, San Francisco, CA; Michael Wilder, McDermott Will & Emery LLP, Washington, DC; Krishna Vallabhaneni, Attorney-Advisor, Tax Legislation, Office of Tax Policy, Department of Treasury, Washington, DC


Session : ABATX13105
Banking & Savings Institutions
Conference : 2013 Joint Fall CLE Meeting
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  • Chair: Daniel Mayo, KPMG LLP, New York, NW
  • Current Developments in Banking/Capital Markets Taxation. This panel will explore recent developments affecting capital markets transactions and the banking industry. Moderator: Anthony Tuths, Withum Smith & Brown, New York, NY Panelists: Yoram Keinan, Greenberg & Traurig LLP, New York, NY; Lee Sheppard, Tax Analysts, Falls Church, VA
  • Practical Considerations in Dealing with the Final Cost Basis Reporting Regulations for Debt, Options and Securities Futures Contracts. This panel will address the scope and staggered effective dates under the final regulations, as well as key operational challenges for brokers to consider as they move towards implementation. The panel also will explore how the reporting requirements of the final regulations may depart from current industry practice and customer expectations, including with respect to customer elections. Lastly, the panel will discuss the incremental requirements for securities transfers beginning in 2015 and related industry preparations. Moderator: Deanna Flores, KPMG LLP, San Diego, CA Panelist: Stevie D. Conlon, Wolters Kluwer Financial Services, Chicago, IL
  • Repurchase Agreements and Dollar Rolls. The panel will discuss the mechanics and tax characterization of repos and “dollar rolls” (sale and repurchase agreements with respect to certain mortgage pass-through securities). The panel will also discuss “purchase/repos” of Treasuries and mortgage assets (purchases of assets simultaneously funded through repo agreements). Moderator: Frank Strong, Deloitte Tax LLP, Washington, DC Panelist: Kristen M. Garry, Shearman & Sterling LLP, Washington, DC


Session : ABATX13106
Closely Held Businesses (TX) and Business Planning Group (TE)
Conference : 2013 Joint Fall CLE Meeting
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  • Closely Held Businesses Chair: J. Robert Turnipseed, Armbrecht Jackson LLP, Mobile, AL Business Planning Group Chair: Lisa Rico, Shea Diamond & Rico LLP, Needham, MA
  • Hot Topics for Small and Family Businesses. Panelists: Robert M. Nemzin, Butzel Long, Bloomfield Hills, MI; Dana Foley, Arnold & Porter LLP, Washington, DC
  • Succession Planning for Closely Held Businesses and Professional Practices. The panel will address the tax, financial and personal issues involved in succession planning for closely held businesses and professional practices and the related retirement and estate planning issues for the owner. The panel will deal with answering the advisors’ frequently asked questions of: How to get the owner off the dime? and How to deal with family dynamics? It will also deal with concerns of the owner, such as: Can I afford to retire and transition my business and also be fair to my children? and What are my choices? Special focus will be given to identifying and solving issues that can prevent a successful transition of the business or practice and the successful planning for the owner and his family. Also included will be a discussion of the importance of business valuations, buy-sell agreements, recapitalizations and successful compensation techniques for keeping non-family “key employees” with the business, both during and after the transition. Panelists: Morton A. Harris, Hatcher Stubbs Land Hollis & Rothschild, Columbus, GA; Shawn L. McIntire, Donelson Ciancio & Grant PC, Broomfield, CO; William P. Prescott, Wickens Herzer Panza Cook & Batista Co, Avon, OH
  • Beyond IRC Section 6166: the Future of Graegin-Style Loans. In administering the estate with a significant interest in a closely-held business, there were once two options: pay the tax or defer the tax. With Estate of Graegin, another option emerged: reduce the tax by way of interest deductions. This panel will review the requirements of section 2053 regarding deductions for expenses, indebtedness and taxes; examine the line of cases, starting with Estate of Graegin and culminating in Koons v. Comm’r, that address the deductibility of interest expenses as a cost of administration; and discuss the impact – from both an administration and income tax perspective – of significant indebtedness on the estate (as the maker of the indebtedness) and the closely-held business (as the holder of the indebtedness). Panelists: Shelby Wilson, Berchem Moses & Devlin, Westport, CT; Lisa Rico, Shea Diamond & Rico LLP, Needham, MA; Tye Klooster, Katten Muchin Rosenman LLP, Chicago, IL


Session : ABATX13107
Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE)
Conference : 2013 Joint Fall CLE Meeting
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  • Estate & Gift Taxes Chair: Derek L. Fletcher, US Trust, Dallas, TX Income & Transfer Tax Planning Group Chair: Leigh-Alexandra Basha, Holland & Knight LLP, McLean, VA
  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since May 2013. Panelists: Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC; George D. Karibjanian, Proskauer Rose LLP, Boca Raton, FL; Hannah W. Mensch, Ehrenkranz & Ehrenkranz LLP, New York, NY
  • Estate Planning Without a Passport: Section 2801 and Other International Hot Topics. Section 2801 imposes an inheritance tax (at the highest applicable gift or estate tax rate) on US persons who receive gifts or bequests from a “covered expatriate.” As such, this tax and the associated reporting obligations can impact domestic clients who otherwise have no international planning of their own. This panel will discuss a variety of international hot topics as well as what every estate planning professional needs to understand about section 2801. Panelists: Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC; Scott A. Bowman, Proskauer Rose LLP, Boca Raton, FL
  • Much Ado About Something: Clash of the Agent, Attorney and Appraiser in Gift Tax Audits (in 4 Scenes). Far from Shakespearean comedy (and more like Odysseus’s struggles), gift tax audits present clashes among appraisers, whose valuations support gift tax returns; attorneys, who defend Program Schedule friday, SEPTEMBER 20 25  = Taped « = Young Lawyers Program  = Ethics Credits Requested = No CLE Credit the returns; and IRS agents, who challenge the returns and underlying valuations. This saga will demonstrate the importance of presentation of the gift tax return, appraisals, and materials provided in audit. Panelists: David Pratt, Proskauer Rose LLP, Boca Raton, FL; Stephanie Loomis- Price, Winstead, Houston, TX; Scott A. Bowman, Proskauer Rose LLP, Boca Raton, FL; Timothy K. Bronza, Business Valuation Analysts LLC, Maitland, FL
  • Better Late Than Never: Maximizing the Tax Effectiveness of an Estate Plan Through Post-Mortem Planning. The death of a client does not necessarily mean that the estate and tax planning process has come to an end. Instead, a wide variety of planning options and elections can be deployed by planners, representatives and beneficiaries to fine tune the tax effectiveness of the client’s estate plan. This panel will examine the tax implications associated with post-mortem planning opportunities, including the tax issues associated with the ownership of S corporation stock, section 645 elections, funding, disclaimers, portability, and many others. Panelists: Marya P. Robben, Lindquist & Vennum, Minneapolis, MN; Phillip J. Hayes, Bessemer Trust, San Francisco, CA


Session : ABATX13108
Individual & Family Taxation
Conference : 2013 Joint Fall CLE Meeting
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  • Chair: Laura Baek, Senior Attorney Advisor, Taxpayer Advocate Service, IRS, Washington, DC
  • Reporting Foreign Source Income. Taxpayers who live or work abroad continue to have an obligation to file with the IRS and Department of Treasury (Treasury Form TD F 90-22.1) and to pay taxes. Citizens who live overseas have unique tax reporting issues when it comes to pensions, deductions, investments and reciprocal Treaties. All taxpayers, including those residing in the United States, who own or inherit financial accounts or other assets in foreign countries should be aware of their FBAR reporting requirements. Non-citizens who work in the US on green cards must also file with IRS and their situation presents another unique set of obligations. Moderator: Phyllis Horn Epstein, Epstein Shapiro & Epstein PC, Philadelphia, PA Panelists: Carol P. Tello, Sutherland Asbill & Brennan LLP, Washington, DC; Deborah J. Jacobs, Esquire, New York, NY; Samuel Berman, Special Counsel, Office of Division Counsel, Small Business/Self-Employed, IRS, Washington, DC
  • Helpful Tips on How to Bring a Case to Taxpayer Advocate Service and Recent Changes to IRS Collection Alternatives. When having difficulties resolving a case through normal IRS Channels, Taxpayer Advocate Service may be able to help. This panel will discuss what types of cases meet TAS criteria, and how to work with your Local Taxpayer Advocate to achieve a fair resolution for your client. Additionally, the panel will briefly provide an update on recent IRS changes to collection alternatives, such as who is eligible for installment agreements and offers-in-compromise. Opening Remarks: Nina E. Olson, National Taxpayer Advocate, Taxpayer Advocate Service, IRS, Washington, DC Moderator: Joshua Beck, Attorney Advisor, to the National Taxpayer Advocate, Taxpayer Advocate Service, IRS, Washington, DC Panelists: Jonathan E. Strouse, Holland & Knight LLP, Chicago, IL; Tiffany J. Todaro, Local Taxpayer Advocate, Taxpayer Advocate Service, IRS, Oakland, CA; Dorathea T. Curran, Local Taxpayer Advocate for Los Angeles, Taxpayer Advocate Service, IRS, Los Angeles, CA; Alex E. Sadler, Ivins Phillips & Barker, Washington, DC
  • How Implementation of the Affordable Care Act (ACA) Impacts Individual Taxpayers. With the start of open season and the Health Insurance Marketplaces on October 1, it seems a fitting time to review the status of the ACA as it relates to individual taxpayers. Representatives from the Taxpayer Advocate Service and IRS will discuss implementation of the ACA, new and forthcoming guidance, and potential areas of concern. Moderator: Laura Baek, Senior Attorney Advisor, Taxpayer Advocate Service, IRS, Washington, DC Panelists: Bridget Roberts, Deputy Executive Director of Systemic Advocacy, Taxpayer Advocate Service, IRS, Washington, DC; Donna M. Crisalli, Senior Level Counsel, Income Tax and Accounting, Office of Chief Counsel, IRS, Washington, DC


Session : ABATX13109
Investment Management
Conference : 2013 Joint Fall CLE Meeting
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  • Chair: William P. Zimmerman, Morgan Lewis & Bockius LLP, Philadelphia, PA
  • Current Developments Regarding Tax Issues for Private Funds. This panel will discuss the potential effect of various proposed legislation and regulations and other recent developments on private funds, including carried interest, management fee waivers, PFICs, sovereign wealth funds, section 1256 contracts, blocker structures, the pass-through treatment of partnerships under Subchapter K, and the 3.8% Medicare contribution tax on investment income. Moderator: Lucas Rachuba, Ropes & Gray LLP, San Francisco, CA Panelist: Ted Dougherty, Deloitte Tax LLP, New York, NY
  • An Overview of Business Development Companies (BDCs) and Uses of These Vehicles in the Current Climate. This panel will focus on the differences and similarities between BDCs and open-end mutual funds. It will also focus on when BDCs are the entity of choice in today’s investment environment. Moderator: Eric Byrnes, Deloitte Tax LLP, Parsippany, NJ Panelists: Jeff Sion, KPMG LLP, New York, NY; Mike Doherty, Ropes & Gray LLP, New York, NY
  • Current Issues Confronting Regulated Investment Companies (RICs). This panel will examine recent developments and issues relating to the scope of the “other income” qualifying income basket and will then focus on issues that arise in connection with tax penalty assessments asserted against investment companies, including RICs. Moderator: Ronald S. Cohn, Cohn & Barr, San Francisco, CA Panelists: William E. Bonano, Pillsbury Winthrop Shaw Pittman LLP, San Francisco, CA; Richard LaFalce, Morgan Lewis & Bockius LLP, Washington, DC



     


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