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2016 Joint Meeting

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Showing sessions 1 - 10 of (39) TOTAL sessions
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Event : ABATX34


Session : ABATX16100
Tax Bridge on the Road
Conference : 2016 Joint Meeting
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$45.00


  • A Conversation with Nina Olson. Nina Olson, the National Taxpayer Advocate, sits down for an in-depth discussion of her practice, her history,and the latest developments in tax law.
  • The Intersection of Sports and Tax Law. United States federal and state tax laws impact sports franchises and players in many ways. The panelists will provide an overview these areas, including state domicile and residency issues, the so-called Jock Tax, business expenses, international tax issues, and estate and gift tax issues. The panelists also will provide tax law insights for attorneys representing professional athletes. Moderator: Clay Collins, PwC, Washington, DC; Panelists: Travis Greaves, Caplin & Drysdale, Washington, DC; Jason Feingertz, Reed Smith, New York, NY; Joseph P. Malca, Proskauer Rose LLP,New York, NY; Dustin Rever-Ginsburg, Venable LLP, Los Angeles, CA
  • Tax Court 101: Pre-Trial Tips & Best Practices. Moderator: Kelley C. Miller, Reed Smith LLP, Washington, DC; Panelists: Jeffrey M. Glassman, McDermott Will & Emery, Dallas, TX; Lawrence A. Sannicandro, Agostino & Associates PC, Hackensack, NJ; Adriana Lofaro Wirtz, Cooley LLP, New York, NY
  • Basics & Hot Topics: RICs and REITs. Regulated investment companies (RICs) (more commonly known as mutual funds) and real estate investment trusts (REITs) have long enjoyed significant tax advantages. The panelists will overview RICs and REITs under subchapter M, addressing the purpose of RICs and REITs, the qualification requirements for REITs and RICs, and the taxation of RICs and REITs and their investors. The panel will also discuss hot topics in the RIC and REIT arenas, such as REIT spinoffs. Moderator: Richard C. LaFalce, Morgan Lewis, Washington, DC; Panelists: Monisha Santamaria, EY, Los Angeles, CA; M. Kathryn Seevers, Ropes & Gray LLP, Boston, MA; Co-sponsored by: Investment Management and Real Estate
  • Nuts & Bolts: Certain Tax and State Law Repercussions from the Obergefell Decision. This panel will examine the various theoretical, procedural, and practice considerations associated with the effect of certain tax and state law changes as a result of the Obergefell v. Hodges and Windsor v. United States decisions, with an emphasis on estate planning and employee benefits. The panelists will explore the changes in the law as a result of these cases and discuss areas where guidance may still be needed. The discussion will also focus on the retroactive aspects of Obergefell and Windsor as to certain federal and state law aspects of estate planning. Moderator: Anne Gordon, Attorney-Advisor, US Tax Court, Washington, DC; Panelists: George D. Karibjanian, Proskauer Rose LLP, Boca Raton, FL; Laura R. Westfall, King & Spalding, New York, NY; Co-sponsored by: Estate & Gift Taxes
  • Hot Topics: Tax Implications of the Sharing Economy.


Session : ABATX16101
Transfer Pricing
Conference : 2016 Joint Meeting
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$15.00


  • Current Transfer Pricing Issues in the Biotechnology and Technology Industries. This session will discuss recent transfer pricing developments as they relate to the biotechnology and technology fields. The panel will be comprised of tax and transfer pricing industry directors who will share their experiences from an intellectual property planning perspective in light of recent BEPS and US legislative developments. In particular, the panel will seek to address key concerns relating to US cost-sharing regulations and recent BEPS guidance with respect to economic substance and profit splits; and the use of multilateral Advance Pricing Agreements in a post-BEPS world.
  • Moderator: Candice King, EY, Boston, MA
  • Panelists: Sarah A. Rana, Hologic Inc., Boston, MA; Richard Olivier, Akamai Technologies, Boston, MA; Rob Filadoro, Alnylam Pharmaceuticals, Boston, MA


Session : ABATX16102
Capital Recovery & Leasing
Conference : 2016 Joint Meeting
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$30.00


  • 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: Ryan Corcoran, RSM, Madison, WI; Panelists: Trevor Salzmann, Grant Thornton, Washington, DC; Kathleen Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Scott Dinwiddie, Associate Chief Counsel, Income Tax & Accounting, IRS, Washington, DC
  • Basis Recovery for Assets Subject to the Foreign Sales Corporation Regime or Extraterritorial Income Exclusions. This panel will discuss basis recovery for assets subject to the FSC regime or ETI exclusion in light of the CBS Corp. v. United States decision and the recently released ILM 201625011, with a focus on taxpayer activity in this space such as accounting method changes and the use of general asset accounting. Moderator: George Manousos, PwC, Washington, DC; Panelists: Kathleen Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Carol Conjura, KPMG, Washington, DC
  • Research Credit – Current Developments and Issues. This panel will focus on current developments and issues involving the research credit, with a focus on the final software regulations applicable to the research credit as well as certain employment tax ramifications of the research credit such as how to apply the research credit to startup companies and monetization of the research credit for employment tax purposes. Moderator: Mark Andrus, Grant Thornton LLP, Washington, DC; Panelists: Jaime Park, KPMG, Washington, DC; Ligeria Donis, PwC, Washington, DC; Bruce Benesh, Grant Thornton LLP, Columbia, SC


Session : ABATX16103
US Activities of Foreigners & Tax Treaties
Conference : 2016 Joint Meeting
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$30.00


  • Current Developments Relating to Inbound Private Equity and Real Estate Transactions. This panel will discuss recent tax developments relating to inbound private equity and real estate (including infrastructure) transactions. Topics to be discussed include FIRPTA-related developments, the proposed section 385 regulations, the new partnership audit rules, the US as a tax haven for foreign investors (common reporting standards), the IRS restructuring and issue-based audits. Moderator: Ameek Ashok Ponda, Sullivan & Worcester LLP, Boston, MA; Panelists: Adam Feuerstein, PwC, Washington, DC; Nicola Lemay, Foley Hoag LLP, Boston, MA; Joseph E. Ladocsi, Manulife and John Hancock, Boston, MA; Daniel McCall, Deputy Associate Chief Counsel International (Technical), IRS Office of Associate Chief Counsel (International), Washington, DC; Douglas Poms, Deputy International Tax Counsel, Department of Treasury, Washington, DC
  • Brave New World – Implications of the Proposed 385 Regulations on Inbound Transactions. The breadth of the proposed 385 regulations is still being absorbed as practitioners consider the significant challenges they present for US companies and foreign investment in the US. This panel will address the impact the proposed regulations may have on inbound transactions including cash management strategies, financing structures and treaty issues. Moderator: Scott Harty, Alston & Bird LLP, Atlanta, GA; Panelists: Ilene Fine, PwC, Washington, DC; Brian Davis, Ivins Philips & Barker Chartered, Washington, DC; Raymond Stahl, Special Counsel, IRS Office of Associate Chief Counsel (International), Washington, DC; Brian Jenn, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC; Douglas Poms, Deputy International Tax Counsel, Department of Treasury, Washington, DC


Session : ABATX16104
Administrative Practice
Conference : 2016 Joint Meeting
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  • Important Developments. This panel will discuss current developments and topics of immediate interest in tax administrative practice. Panel will focus on recent Treasury and IRS guidance, court decisions, on-going litigation, or any other items germane to tax administration. Moderator: James R. Gadwood, Sullivan & Cromwell, New York, NY; Panelists: Brendan O’Dell, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Drita Tonuzi, Associate Chief Counsel (Procedure & Administration), Office of Chief Counsel, IRS, Washington, DC
  • Good News, Your Audit Is Over. Or Is It? The Process and Impact of a Joint Committee Review. The IRS has completed its examination of your claim for refund and has informed you that it agrees in principle but can’t grant your refund yet. So, what’s the hold up? Before the IRS can grant a refund of over $2 million for an individual and $5 million for a corporation, the claim must go through review by the Joint Committee on Taxation. What are the criteria for review and what does this process entail? What are the responsibilities of the Joint Committee and of the IRS when a refund is reviewed? What can a taxpayer and their representative do to best position their case and successfully close out review at the Joint Committee level? This panel will explore the Joint Committee refund review process, discuss best practices for successful review, and highlight other procedural considerations of review, including impact on cases in Appeals. Moderator: Alex Sadler, Morgan Lewis & Bockius LLP, Washington, DC; Panelists: Diana Erbsen, Deputy Assistant Attorney General for Appellate and Review, Department of Justice, Tax Division, Washington, DC; Susan Mosley, Branch Chief (Procedure & Administration), IRS Office of Chief Counsel, Washington, DC; John Keenan, Deloitte, Washington, DC
  • International Information Return Penalties from Assessment to Abatement and All That Is Inbetween. This panel will discuss penalties associated with international information returns, such as Forms 5471, Forms 926, and FinCEN Form 114 (“FBAR”). The panel will review the Service’s procedures for penalty assessment, to opportunities for penalty abatement. Discussion will also include what actions taxpayers can take when they discover missing or inaccurate international information reporting forms and how, and if, taxpayers can mitigate penalty exposure through one of the Service’s foreign voluntary disclosure programs. Moderator: Mary I. Slonina, PwC, Washington, DC; Panelist: Thomas Greenway, KPMG, Boston, MA; Joanne MacDonald, PwC, Boston, MA


Session : ABATX16105
Affiliated & Related Corporations
Conference : 2016 Joint Meeting
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  • Application of the Proposed Section 385 Regulations to Consolidated Groups. This panel will explore the application of the proposed regulations under section 385 in the context of affiliated groups, including potential deconsolidations, the treatment of partnerships owned by members of a consolidated group, state tax issues, and consequences resulting from a debt instrument, debtor or creditor entering or leaving a consolidated group. Moderator: Wade Sutton, PwC, Washington, DC; Panelists: Britt Haxton, McDermott Will & Emery LLP, Washington, DC; Brian Peabody, EY, Washington, DC; Filiz Serbes, IRS Office of Associate Chief Counsel (Corporate), Washington, DC; Jeffrey Vogel, KPMG, Washington, DC
  • Do We Really Understand the Consolidated E&P Rules? This panel will focus on the special consolidated rules applicable to the determination of earnings and profits when corporations join, leave or liquidate within the consolidated group. Topics will include the effect of the anti-duplication rules upon liquidation, whether the anti-duplication rules can revive purged SRLY E&P, and the allocation of E&P upon a spin-off from the consolidated group. Moderator: Mark Hoffenberg, KPMG, Washington, DC; Panelists: Marie Milnes-Vasquez, IRS Office of Associate Chief Counsel (Corporate), Washington, DC; Stuart Finklestein, Skadden Arps Slate Meagher & Flom LLP, New York, NY; Olivia Ley Orobona, PwC, Washington, DC


Session : ABATX16106
Banking & Savings Institutions
Conference : 2016 Joint Meeting
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$30.00


  • Section 871(m) Compliance Concerns and New Proposed Regulations to Implement the Qualified Derivative Dealer Regime under Section 871(m). This panel with discuss compliance concerns with section 871(m) and the recently issued proposed regulations pertaining to the implementing the new Qualified Derivative Dealer (“QDD”) regime applicable to dividend equivalent payments under section 871(m), which will apply to dividend equivalent payments received by an electing Qualified Intermediary (“QI”) and replace the previously proposed Qualified Securities Lender regime provided in Notice 2010-46. Moderator: Yoram Keinan, Carter Ledyard & Milburn, New York, NY; Panelist: Stevie Conlon, Wolters Kluwer Financial Services, Chicago, IL; Matthew Stevens, EY, Washington, DC
  • Section 50(d) and Tax Credit Partnerships. This panel will discuss the recent guidance on section 50(d) and other developments relevant to tax credit partnerships. Moderator: Richard Blumenreich, KPMG, Washington, DC; Panelists: TBD
  • Current Developments. This panel will discuss current developments relevant to banking and savings institutions. Moderator: Richard Larkins, EY, Washington, DC; Panelist: Mark Price, KPMG, Washington, DC


Session : ABATX16107
Closely Held Businesses (TX) and Business Planning Group (TE)
Conference : 2016 Joint Meeting
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  • The Purchase and Sale of a Professional Practice. This panel will discuss and analyze all business and tax aspects of a complete or partial sale of a professional practice to another/other professional(s) or to a corporate entity. The panel will also distinguish the purchase and sale of a professional practice from other closely-held businesses. Panelists: Daniel H. McCarthy, Wick Phillips LLP, Fort Worth, TX; Robert J. Turnipseed, Arbrecht Jackson LLP, Mobile, AL; William P. Prescott, Wickens Herzer Panza Cook & Batista Co., Avon, OH
  • State Taxation of Trusts Holding Business Interests. The inconsistency in the tax treatment of trusts among states creates challenges—as well as potential planning opportunities—for trusts with contacts in multiple states. It particularly impacts trusts owning business interests, as those trusts may need to navigate sourcing rules that also subject trusts to tax in multiple jurisdictions. This presentation will highlight: (i) the various mechanisms by which states tax trust income, including a discussion of sourcing rules and certain traps for the unwary; (ii) constitutional limits to states’ taxing authority, with a focus on recent case law; (iii) Delaware, Nevada and Wyoming incomplete gift non-grantor trusts (“DINGs,” “NINGs” and “WINGs”); and (iv) potential uniformity initiatives at the state level as to trust taxation. Moderator: Karen Sandler Steinert, Fredrikson & Bryron PA, Minneapolis, MN; Panelists: Tom Myrick, Moore and Van Allen PLLC, Charlotte, NC; Justin T. Miller, BNY Mellon Wealth Management, San Francisco, CA


Session : ABATX16109
Individual & Family Taxation
Conference : 2016 Joint Meeting
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  • Higher Education Savings and Planning: Tax & Non-Tax Considerations. This panel will discuss the various ways to plan, save, and pay for higher education. The panel will compare various savings strategies, including gifts, UTMA accounts, 529 plans, trusts, and other vehicles. The analysis will consider both tax and non-tax considerations, including the effect on financial aid, transaction costs, investor control, income taxes, gift and estate taxes, flexibility, and even creditor protection. The panel will also discuss the various tax credits, exclusions, and deductions related to higher education. Moderator: Phyllis Horn Epstein, Epstein Shapiro & Epstein PC, Philadelphia, PA; Panelists: Professor F. Philip Manns Jr., Liberty University School of Law, Lynchburg, VA; Professor Timothy M. Todd, Liberty University School of Law, Lynchburg, VA
  • Tax Attributes of Consumer Debt. This panel will discuss the tax attributes of and recent developments surrounding consumer debt. In the student loan forgiveness area, the panelists will discuss Rev. Proc. 2015-57 dealing with the discharge of certain Federal student loans. Regarding the mortgage interest deduction, the panelists will examine the decision by the Court of Appeals for the Ninth Circuit in Voss v. Commissioner, deciding the interpretation of section 163(h) with regard to the returns of two unmarried same-sex partners. The panel will also discuss section 108 cancelation of debt income, the impact of recourse v. non-recourse debt on COD income, and the limitations of COD income, including insolvency and qualified debt. Moderator: Victoria Sherlock, KMPG, Houston, TX; Panelists: Rachel L. Partain, Caplin & Drysdale, New York, NY; Norma C. Rotunno; Senior Technician Reviewer, Office of Associate Chief Counsel (Income Tax & Accounting) (Branch 2), IRS, Washington, DC; Professor Theodore S. Sims, Boston University School of Law, Boston, MA; Donna Welsh, Senior Technician Reviewer, Office of Associate Chief Counsel (Income Tax & Accounting) (Branch 4), IRS, Washington, DC
  • Ethical Considerations in Individual and Family Representation. This panel will provide tax practitioners with an overview of ethical considerations applicable in the representation of individuals and families. The panel will discuss ethical issues involving scope of representation, conflicts of interest in joint representation, disclosures to the IRS, and the duty of confidentiality. Moderator: Stephanie Coleman, Legal Aid of West Virginia, Charleston, WV; Panelists: Jamie Andree, Indiana Legal Services, Bloomington, IN; D. Sean McMahon, McMahon & Associates, Boston, MA; Brendan Shea, Law Office of Brendan Shea, Boston, MA; Co-Sponsored by: Pro Bono & Tax Clinics


Session : ABATX16110
Investment Management
Conference : 2016 Joint Meeting
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  • Partnership Audit Reform and Private Funds. This panel will discuss the recently-enacted partnership audit reform rules in the Bipartisan Budget Act of 2015. After a brief overview of the new rules, the panel will focus on the current impact on new and existing fund documents and negotiations. The panel will also discuss Treasury’s priorities for forthcoming guidance and how guidance might affect structuring and negotiations for new investment funds. Moderator: Kat Gregor, Ropes & Gray LLP, Boston, MA; Panelists: Glenn E. Dance, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries), IRS Office of Chief Counsel, Washington, DC; Kip Cawley, Foley Hoag LLP, Boston, MA; Raj Tanden, Foley & Lardner LLP, Los Angeles, CA
  • Current Legislative and Regulatory Initiatives Impacting Regulated Investment Companies. This panel will examine the current legislative and regulatory initiatives potentially impacting regulated investment companies, including the Modernization of Derivatives Tax Act of 2016 discussion draft. The panel will also discuss recent IRS guidance and other topics of current interest to regulated investment companies, including money market reform. Moderator: Jason Paul Traue, Morgan Lewis & Bockius LLP, Boston, MA; Panelists: Stephen Fisher, EY, Boston, MA; Roger Wise, Stradley Ronan Stevens & Young LLP, Washington, DC
  • Managing the Special Tax Issues Presented by Sovereign Wealth Fund Investors in US-Domiciled Funds. This panel will explore the special tax issues presented by inbound investments into the United States by sovereign wealth funds, with a particular focus on real estate funds and privately managed funds. Moderator: Amy B. Snyder, The Vanguard Group Inc., Malvern, PA; Panelists: William L. McRae, Cleary Gottlieb Steen & Hamilton LLP, New York, NY; Rom Watson, Ropes & Gray LLP, Boston, MA



     


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