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2017 May Meeting

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$299.00



Showing sessions 1 - 10 of (45) TOTAL sessions
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Event : ABATX36


Session : ABATX1750
Tax Bridge to Practice
Conference : 2017 May Meeting
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$75.00


  • A Conversation with the Honorable Tamara W. Ashford. Judge Ashford sits down for an in-depth discussion of her time on the bench, her history, and the latest developments in tax law.
  • Common Cross-Border Issues in M&A and Tax Planning. This panel will provide an introduction to key concepts in international taxation, such as withholding tax issues, potential inversions under section 7874, added restrictions on tax-free status under section 367 and debt-equity concerns under the section 385 regulations. The panelists will discuss common issues and tax planning opportunities in cross-border M&A. The panel will explore hot topics and discuss how newer attorneys can add value in common cross-border transactions. Panelists: Lori A. Hellkamp, Jones Day, Washington, DC; Philip R. Hirschfeld, Ruchelman PLLC, New York, NY; Amit Sachdeva, EY, Houston, TX Co-Sponsored by: Foreign Activities of US Taxpayers; US Activities of Foreigners & Tax Treaties
  • Breakout Track: International, Corporate & Litigation
  • Notice 2016-73 and the Repatriation of Offshore Earnings. On December 2, 2016, the Department of Treasury and the IRS issued Notice 2016-73, targeting the tax-free repatriation of previously untaxed earnings. The Notice describes the government's intention to issue future regulations that would modify the existing rules regarding cross-border triangular reorganizations and certain inbound nonrecognition transactions. This panel will discuss the relevant history leading up to the issuance of the Notice, as well as the Notice's intended impact on cross-border triangular reorganizations and certain inbound nonrecognition transactions. Moderator: Clay Collins, PwC, Washington, DC Panelists: Kate Deal, Covington, Washington, DC; Micah Gibson, PwC, Washington, DC; Michael P. Liu, Baker McKenzie, Palo Alto, CA; Brenda Zent, Special Advisor on International Taxation, Department of Treasury, Washington,
  • Tax Tales 3! – Even More Seminal Cases of Subchapter C. American corporate tax law can be reduced to a dozen code sections and a few dozen Treasury Regulations that read like the Dewey Decimal System. However, beneath the crusty label of a section number, past the stilted prose, there is poetry that rivals the great mythologies of Homer and Milton. This panel will discuss a sampling of the most essential cases and rulings in Subchapter C - Plantation Patterns, Lessinger, Perrachi, Sansome, Phipps, Cromwell, and American Bantam. Framed in the medium of tax law, these are great fables of dashing heroes, poisonous villains, heart-breaking romance, and awe-inspiring (dividend-equivalent) redemptions. Moderator: Alfred Bae, EY, Houston, TX Panelists: Michelle Lo, Linklaters, New York, NY; Maury Passman, KPMG, Washington, DC; Shannon Perez, AOL Inc., Dulles, VA; Gary Scanlon, Attorney- Advisor, Department of Treasury, Washington, DC Co-Sponsored by: Corporate Tax
  • Tax Court 101: The Battle of the Experts. Experienced tax controversy attorneys will discuss key concepts relating to expert witnesses in the forum where tax issues are most likely to be litigated, the United States Tax Court. In this regard, the panelists will discuss key provisions of the Tax Court’s Rules of Practice and Procedure that relate to expert witnesses and detail the issues with which any tax litigator should be aware. Specifically, the panelists will discuss issues and share insights relating to expert qualification, direct examination, cross examination, rehabilitation, cutting-edge expert witness techniques, and privilege issues when dealing with experts. Moderator: Kelley C. Miller, Reed Smith, Washington, DC Panelist: Giovanni Alberotanza, Rosenberg Martin Greenberg LLP, Baltimore, MD; Michael J. Scarduzio, DLA Piper, New York, NY; Adriana Lofaro Wirtz, Cooley LLP, New York, NY
  • Breakout Track: Nuts & Bolts of State and Local Taxation
  • Practicing Constitutional Law Every Day. Did you know that state tax lawyers are really constitutional lawyers? Because the actions of the states are restrained by certain provisions of the US (and often their own state) Constitution, many state tax cases involve one or more constitutional claims. This panel will discuss the key constitutional provisions – including the Commerce, Due Process, and Equal Protection Clauses – that impact state and local tax issues. Moderator: David A. Hughes, Horwood Marcus & Berk, Chicago, IL Panelists: Maddie Schueler, Stoll Keenon Ogden, Lexington, KY; Matt Landwehr, Thompson Coburn, St. Louis, MO
  • Everybody Pays It, But It’s More Than Federal Conformity – A State Income Tax Primer. This panel will provide a substantive overview of state corporate income tax issues, including conformity to and deviations from the federal income tax base. The panel will also discuss state-specific issues such as nexus, allocation and apportionment, and combined/consolidated state returns. Moderator: Nicole Ford, Baker McKenzie, Dallas, TX Panelists: Lindsay LaCava, Baker McKenzie, New York, NY; Kyle Wingfield, Williams Mullen, Richmond, VA
  • What Tax Is More Than the State Income Tax? – The Sales Tax: Everything You Need to Know But Were Afraid to Ask. Is it a hidden tax? As consumers, we probably pay far more in sales tax than we can imagine. Businesses have multiple reasons for “getting the tax right,” including limiting their audit exposure, avoiding class action lawsuits and maintaining competitive pricing. This panel will discuss multistate sales and use tax issues such as: What transactions are taxable? Are there exemptions to be taken and, if so, how are they preserved? What is a mixed transaction and how is it taxed? and What are the multistate trends in response to enhanced technologies and an expanding global marketplace? Moderator: Christi Mondrik, Mondrik & Associates, Austin, TX Panelists: Maria Eberle, Baker McKenzi


Session : ABATX1751
Low Income Taxpayers Representation Workshop
Conference : 2017 May Meeting
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$60.00


  • Inception of a Small Business. Small business and self-employed tax filings have been increasing, and are continuing to trend upwards. This panel begins with a discussion of those trends and statistics. The panel will also discuss self-employment and small business concerns in the “sharing economy” as well as traps taxpayers should be aware of in starting their business. Moderator: Lany Villalobos, Law Clerk, US Tax Court, Washington, DC Panelists: Lisa Sperow, Cal Poly Low Income Taxpayer Clinic, San Luis Obispo, CA; Professor Shu-Yi Oei, Tulane Law School, New Orleans, LA; Shanthi Ramnath, Department of Treasury, Washington, DC
  • Operation of a Small Business. The small business is up and running... what could possibly go wrong? This panel will discuss business ID Theft issues, payroll fraud problems, and the many required filings that small businesses must take care to comply with... as well as the consequences for failing to comply. Moderator: Patrick Thomas, Notre Dame Tax Clinic, South Bend, IN Panelists: Susan Morgenstern, IRS Local Taxpayer Advocate, Cleveland, OH; Professor Jacqueline Lainez, UDC – David A. Clarke School of Law, Washington, DC; Gina DeConcini, Fox Rothschild LLP, Minneapolis, MN
  • Death of a Small Business. After a valiant attempt, the taxpayer is cutting their losses and washing their hands of the business. But without proper counseling (and to the surprise of many taxpayers), some business related tax issues may persist well-after the storefront is shuttered. This panel will discuss Trust Fund Recovery Penalty issues, lingering state tax issues, and bankruptcy (and other alternatives) for small businesses. Moderator: Professor Jonathan Grossberg, American University Washington College of Law, Washington, DC Panelists: Professor T. Keith Fogg, Harvard Federal Tax Clinic, Boston, MA; Nancy Ryan, Legal Services of Northern Virginia, Fairfax, VA; Alan Marcus, Illinois Department of Revenue, Chicago, IL
  • Recent Developments. Professor Bruce McGovern will review recent developments in the law likely to affect low-income taxpayers and Caleb Smith will discuss tax “notes from the field.” Moderator: Kelley Miller, Reed Smith, Washington, DC Panelists: Professor Bruce McGovern, South Texas College of Law, Houston, TX; Caleb Smith, Harvard Federal Tax Clinic, Boston, MA


Session : ABATX1752
Transfer Pricing
Conference : 2017 May Meeting
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$15.00


  • The Latest in Transfer Pricing Litigation. Will the IRS appeal Medtronic? What’s the latest from the Tax Court on Amazon and Eaton? What is the status of Coca-Cola and Facebook? What’s going on with Microsoft? How do the recent U.S. transfer pricing cases fit into the post-BEPS international framework? Come get the answer to these questions and more in a discussion of the current state of transfer pricing litigation. Moderator: Lili Kazemi, PwC, Washington, DC Panelists: Jenny Austin, Baker McKenzie, Chicago, IL; Michael Educate, Mayer Brown, Chicago, IL


Session : ABATX1753
Administrative Practice
Conference : 2017 May Meeting
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$30.00


  • Administrative Practice Important Developments. This panel will discuss current developments and topics of immediate interest in tax administrative practice. The panel will focus on recent Department of Treasury and IRS guidance, court decisions, on-going litigation, or any other items germane to tax administration. Moderator: Jim Gadwood, Miller & Chevalier Chartered, Washington, DC Panelists: Brendan O’Dell, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Richard Goldman, Deputy Associate Chief Counsel (Procedure & Administration), IRS Office of Chief Counsel, Washington, DC; Kat Saunders Gregor, Ropes & Gray LLP, Boston, MA
  • Managing SB/SE Exams. Examinations conducted by the Small Business / Self Employed (“SB/SE”) operating division can have their own unique characteristics and can be quite different from examinations of larger taxpayers. This panel will discuss some best practices, strategic considerations, and practical considerations when confronted by an SB/SE examination, focusing in particular on the unique aspects of an SB/SE examination. Moderator: Carol M. Luttati, The Law Offices of Carol M. Luttati, New York, NY Panelists: E. Robert McKenzie, Arnstein & Lehr, Chicago, IL; Harold A. Lorman, Attorney at Law, Ramsey, NJ; Tammy Ripperda, Deputy Commissioner, Small Business/Self Employed Division, IRS, Washington, DC; Scott Irick, Director, Headquarters Examination, IRS, Washington, DC
  • LB&I Compliance Campaigns. The Large Business & International (“LB&I) operating division recently announced its first 13 "campaigns." This panel will discuss this latest effort at issue coordination – how the campaigns are expected to be similar to or different from past efforts at coordination, such as the tiered issue program. Moderator: Elizabeth Askey, Washington, DC Panelists: Holly O. Paz, Director, Pass Through Entities Practice Area, IRS Large Business and International, Washington, DC; Thomas J. Kane, Division Counsel, IRS Office of Chief Counsel, Washington, DC; Heather Maloy, EY, Washington, DC


Session : ABATX1754
Affiliated & Related Corporations
Conference : 2017 May Meeting
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$30.00


  • Section 355 in Consolidation: Is It Different? This panel will explore intercompany section 355 transactions within consolidated groups, with a focus on issues that are unique to distributions occurring in consolidation. We will discuss so-called "drop-spin-liquidate" transactions, the application of the device rules to intercompany spins, General Utilities concerns, and excess loss account and intercompany transaction issues, among other topics. Moderator: Matt Gareau, Deloitte Tax LLP, Washington, DC Panelists: Gerald Fleming, Senior Technician Reviewer, IRS Office of Associate Chief Counsel (Corporate), Washington, DC; Jay Singer, McDermott Will & Emery LLP, Washington, DC; Lisa Zarlenga, Steptoe & Johnson LLP, Washington, DC
  • SALT Issues in Transactions Among Consolidated Group Members. Experts in consolidated returns typically caveat advice they give to their clients with the statement that “state and local tax consequences may be different.” This panel will explore how those consequences may be different in a variety of common intercompany transactions. Moderator: Peter Faber, McDermott Will & Emery LLP, New York, NY Panelists: Jaye Calhoun, Kean Miller LLP, New Orleans, LA; Greg Fairbanks, Grant Thornton LLP, Washington, DC; Ross Poulsen, Jones Day LLP, Washington, DC
  • Worthless Securities Deductions in Consolidated Groups. This panel will consider various issues affecting the application of section 165(g) to consolidated group member stock, including the Unified Loss Rules and the "look-through" approach adopted in several private letter rulings. Moderator: Brian Peabody, EY, Washington, DC Panelists: Marie Milnes-Vasquez, Special Counsel to the IRS Associate Chief Counsel (Corporate), Washington, DC; John Sweet, King & Spalding, New York, NY; David Wheat, KPMG, Dallas, TX


Session : ABATX1755
Banking & Savings Institutions
Conference : 2017 May Meeting
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$30.00




Session : ABATX1756
Estate & Gift Taxes
Conference : 2017 May Meeting
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$30.00


  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since January 2017. Panelists: Brian P. Tsu, Henderson Caverly Pum & Charney LLP, San Diego, CA; Helen E. Rogers, Holland & Hart, Denver, CO; Megan M. Curran, Jones Walker LLP, New Orleans, LA; Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC
  • Planning for Privacy in a Public World: The Ethics and Mechanics of Protecting Your Client’s Privacy and Personal Security. As public access to information increases, clients are seeking solutions to protect their privacy and personal security. This panel will discuss how the professional advisor can structure estate plans and financial transactions in a confidential manner and protect clients against cyberattacks. Panelists: Jeff Chadwick, Winstead PC, The Woodlands, TX; Joshua A. James, Bryan Cave LLP, Washington DC
  • Enhancing Estate Planning with Private Placement Life Insurance. This panel will review two or three common domestic and international estate planning strategies, propose that the benefits of these strategies may be substantially augmented by combining them with the use of private placement life insurance (PPLI) and, finally, illustrate the magnitude of the value of combining such strategies with PPLI in one plan. Panelists: Joseph Septimus, Bernstein Global Wealth Management, New York, NY; Shelly Meerovitch, Bernstein Global Wealth Management, New York, NY
  • The Private Family Trust Company: A Fully Empowered Platform for Family Flourishing. A private trust company constitutes a fully empowered tool that gathers, under one entity, family assets and financial services activities and then exercises full legal authority over those assets and activities. By doing so, it provides a family that desires to flourish - as a family - with a control mechanism to implement the family’s strategic plan by controlling its assets according to its chosen criteria. This session will explore the reasons why families create PTCs, will compare PTCs to alternatives, and explore, from a practical perspective, how PTCs are built and operated. Panelist: Miles C. Padgett, Kozusko Harris Duncan, Chicago, IL


Session : ABATX1757
Investment Management
Conference : 2017 May Meeting
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  • Primer on Structuring Real Estate Funds. This panel will focus on the basic structures and tax issues relating to real estate funds. The principal topics include utilizing a REIT within the fund structure and the associated Subchapter K, UBTI and FIRPTA considerations. The panel will also touch on the IRS’s partnership audit procedures. Moderator: Ameek Ponda, Sullivan & Worcester LLP, Boston, MA Panelists: Cameron N. Cosby, Hogan Lovells, Washington, DC; Peter J. Genz, King & Spaulding LLP, Atlanta, GA
  • Impact of Tax Reform on the Investment Management Industry. This panel will consider the current proposals for tax reform and their potential impact on investment funds and advisers. Moderator: Karen Lau Gibian, Investment Company Institute, Washington, DC Panelists: Benjamin Allensworth, Managed Funds Association, Washington, DC; Mary Baker, K&L Gates LLP, Washington, DC; Jeffrey Levey, EY, Washington, DC
  • Investment Funds and Treaty Entitlements. This panel will discuss various issues related to investment funds and their entitlement to treaty benefits, including the future of US treaty policy, the impact of BEPS Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances), and tax administration issues faced by investment funds and their investors in claiming treaty benefits. Moderator: Keith Lawson, Investment Company Institute, Washington, DC Panelists: Michael Plowgian, KPMG LLP, Washington, DC; Quyen Huynh, Associate International Tax Counsel, Department of Treasury, Washington, DC (Invited)


Session : ABATX1758
Partnerships & LLCs
Conference : 2017 May Meeting
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  • Hot Topics. This panel will discuss recent developments, including legislation, regulations, administrative guidance and noteworthy cases. Moderator: Beverly Katz, KPMG LLP, Washington, DC Panelists: Ari Berk, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Glenn E. Dance, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries), Office of Chief Counsel, IRS, Washington, DC
  • Breaking Bad – Dealing with the Partnership Audit Rules and Partnership Agreement Drafting Considerations. This panel will consider techniques for drafting partnership agreements to deal with the considerations presented by the partnership audit rules, taking into account the rules' potential application for both federal and state purposes. Moderator: Terence F. Cuff, Loeb & Loeb LLP, Los Angeles, CA Panelists: Bruce P. Ely, Bradley Arant Boult Cummings LLP, Birmingham, AL; Charles P. Rettig, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA; Elizabeth A. Copeland, Strasburger & Price LLP, San Antonio, TX
  • Issues Arising Under Section 721(c) Guidance. This panel will discuss recent temporary and proposed regulations under section 721(c), concerning certain transfers of appreciated property by US persons to partnerships having one or more foreign partners related to the transferor. Moderator: Craig Gerson, PwC, Washington, DC Panelists: H. Grace Kim, Grant Thornton LLP, Washington, DC; Ari Berk, Attorney- Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Jason Smyczek, Senior Technician Reviewer, IRS Office of Chief Counsel (ACCI), Washington, DC
  • The Partnership Anti-Abuse Rule 20 Years Later – What’s the Verdict? This panel will discuss the status of the partnership anti-abuse rule under 1.701-2 over the past 20 years and whether it has served its intended purpose or should be revoked as deadwood. The panel will also address whether the anti-abuse rule could have been applied in lieu of some recent partnership regulations that have addressed specific partnership abuses. Moderator: Monte A. Jackel, Akin Gump Strauss Hauer & Feld LLP, Washington, DC Panelists: Curtis G. Wilson, KPMG LLP, Washington, DC; Sheri A. Dillon, Morgan Lewis & Bockius LLP, Washington, DC


Session : ABATX1759
Capital Recovery & Leasing
Conference : 2017 May Meeting
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  • 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: Trevor Salzmann, Grant Thornton LLP, Washington, DC Panelists: Wendy Friese, Deloitte, Washington, DC; Kathleen Reed, Chief, Branch 7, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Merrill Feldstein, Senior Counsel, Branch 3, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Christopher Call, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC
  • Tax Reform and Its Impact on Capitalization and Cost Recovery. This panel will discuss the various tax reform proposals and their specific impact on capitalization and cost recovery matters. Moderator: Jane Rohrs, Deloitte LLP, Washington, DC Panelists: Christian Wood, RSM US LLP, Washington, DC; Christopher Arneson, Tax Policy Advisor, US Senate Finance Committee, Washington, DC; Mark Warren, Senior Tax Counsel, Office of Senator John Thune, Washington, DC; Heather Harman, Tax Accountant, Joint Committee of Taxation, Washington, DC; Randell Gartin, Tax Counsel, Committee on Ways and Means, Washington, DC (Invited)
  • Leasing Issues and Current Developments. This panel will focus on the factors the IRS considers when determining if a transaction is a true lease, a financing, or a sale. The panel will also discuss GAAP standards including build-to-suit arrangements. Moderator: Ryan Corcoran, RSM US LLP, Madison, WI Panelists: Glenn Johnson, EY, Washington, DC; Jason Kristall, Assistant to the Branch Chief, Branch 5, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Suzanne Sinno, General Attorney, Branch 4, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Kenneth Beck, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited)



     


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