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2019 Midyear Meeting

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(c) [2019] American Bar Association.
All rights reserved. No part of this recorded content may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopy, recording, or otherwise, without the prior written permission of the American Bar Association.

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Showing sessions 1 - 10 of (43) TOTAL sessions
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Event : ABATX41


Session : ABATX1901
Tax Bridge on the Road
Conference : 2019 Midyear Meeting
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$60.00


  • Sponsored by: Young Lawyers Forum and Diversity Program Co-Chairs: Kelley C. Miller, Reed Smith LLP, Washington, DC; Cathy Fung, Office of Chief Counsel (Large Business & International), IRS, Washington, DC
  • Tax Law: A Great Career Choice. A panel of attorneys with years of experience in private practice, government, clinics, and academia discuss their insights into the practice of tax law. Moderator: Abbey B. Garber, Thompson & Knight, Dallas, TX Panelists: Tyler Murray, Exxon Mobil Corporation, Houston, TX; Lany L. Villalobos, Dechert LLP, Philadelphia, PA; Morgan L. Klinzing, Pepper Hamilton LLP, Philadelphia, PA
  • The Essentials of Opportunity Zones Funds. The panelists will discuss this new intriguing tax vehicle that has everyone talking. The panel will focus on the background of Qualified Opportunity Zones and Qualified Opportunity Zone Funds, the tax benefits from investing in Qualified Opportunity Zone Funds and the ins and outs of Qualified Opportunity Zone Businesses. Panelists: Kelley C. Miller, Reed Smith LLP, Washington, DC; Richard C. LaFalce, Morgan Lewis & Bockius LLP, Washington, DC Co-sponsored by: Investment Management
  • Retirement Plan and Executive Compensation Considerations in Mergers and Acquisitions. The past few years have witnessed numerous changes to the retirement plan and executive compensation landscape, while at the same time, mergers and acquisitions have increased at a record pace. This panel will explore the intersection of these two changes, and discuss the tax and other considerations relating to retirement plans and executive compensation in the mergers and acquisitions context. This panel will also provide insight on how to assess the audit and litigation risk of plans in the mergers and acquisitions context and the potential to minimize such risks going forward. Moderator: Ryan R. Montgomery, Morgan Lewis & Bockius LLP, Boston, MA Panelists: Yongo Ding, Miller & Chevalier, Washington, DC; Laura Westfall, King & Spalding, New York, NY
  • Bankruptcy and Tax: Introduction to the Bankruptcy Court and Using Bankruptcy to Discharge Tax Debt. Bankruptcy is an important tool practitioners can use to resolve liabilities with federal and state tax authorities. A distinguished group of panelists will provide an introduction to the bankruptcy-court system and discuss (i) the role of the federal tax lien and the treatment of secured claims in bankruptcy, (ii) the priority and dischargeability of unsecured claims in bankruptcy, and (iii) tax-claim litigation in bankruptcy, whether through a contested matter or an adversary proceeding. Moderator: Professor T. Keith Fogg, Director of the Federal Tax Clinic, Harvard Law School, Jamaica Plain, MA Panelists: The Honorable Erithe A. Smith, Judge, US Bankruptcy Court for the Central District of California, Santa Ana, CA; The Honorable Mark S. Wallace, Judge, US Bankruptcy Court for the Central District of California, Santa Ana, CA; Kenneth C. Weil, Law Office of Kenneth C. Weil, Seattle, WA; Co-Sponsored by: Tax Collection, Bankruptcy & Workouts and Pro Bono & Tax Clinics
  • 360 Degree Perspective: US Withholding and Global Information Reporting. With the implementation of the Common Reporting Standard (CRS) and the Foreign Account Tax Compliance Act (FATCA), information reporting is a global operation. This panel will outline the various classifications of US individuals and entities with operations and accounts abroad under FATCA, as well as variations imposed by CRS on both US and multi-nationals. Attorneys from private practice, the US Government, and the OECD will discuss their respective experiences working within this field and provide real-world examples of the US withholding regime (chapters 3 and 4) as it applies in light of FATCA and CRS classifications. Moderator: Josiah Child, Caplin & Drysdale Chtd., New York, NY Panelists: Jeremiah Coder, Tax Policy Adviser, OECD/Global Forum on Transparency and Exchange of Information for Tax Purposes, Paris, France;Dianne C. Mehany, Caplin & Drysdale Chtd., Washington, DC; Heather R. Sidwell, EY, Washington, DC; Co-sponsored by: Foreign Activities of US Taxpayers


Session : ABATX1902
Capital Recovery & Leasing
Conference : 2019 Midyear Meeting
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$30.00


  • Chair: Sam Weiler, EY, Columbus, OH
  • Current Developments and Update on Pending Guidance. This panel will cover the important recent developments in the areas of capital recovery and leasing. Moderator: Rayth Myers, EY, Washington, DC Panelists: Selvan Boominathan, CohnReznick, Washington, DC
  • Section 163(j) and Its Impact on Cost Recovery. This panel will discuss recently released guidance under section 163(j), including specific issues addressed in such guidance impacting the capital recovery space. Moderator: Andrea Mouw, Eide Bailly, Minneapolis, MN Panelist: Jane Rohrs, Deloitte, Washington, DC
  • A Discussion on Environmental Preservation Credits. This panel will discuss the federal tax implications of various types of programs where the government provides certain incentives for private industry to preserve the environment. Two examples include mitigation banking and carbon sequestration. This panel will discuss issues involving when taxpayers have an income recognition event, what costs (if any) may be capitalized, are there recovery mechanisms outside of a sale or exchange, and other issues that may arise with respect to these programs. Moderator: Christian Wood, RSM, Washington, DC Panelists: Kate Abdoo, PwC, Stamford, CT


Session : ABATX1903
Administrative Practice
Conference : 2019 Midyear Meeting
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$45.00


  • Chair: Jennifer Breen, Morgan Lewis & Bockius, Washington, DC
  • Important Developments. This panel will discuss current developments and topics of immediate interest in tax administrative practice. Panel will focus on recent legislative efforts impacting tax law and the IRS, Treasury and IRS guidance, court decisions, ongoing litigation and other items germane to tax administration. Moderator: James R. Gadwood, Miller & Chevalier, Washington, DC Panelist: Kat Gregor, Ropes & Gray, Boston, MA; Shamik Trivedi, Grant Thornton, Washington, DC
  • The Impact of Data Security Laws on IRS Audits. In certain instances, personal emails, employee data, and types of certain employee-to-employee communications are responsive to IDR requests on proving business purpose or clarifying the characteristics of a transaction. Those communications, however, may contain an employee’s personal data or confidential information of vendors or competitors. Generally, tax practitioners closely scrutinize IDR responses to ensure attorney client or section 7525 privileged communications or corporate trade secrets are not disclosed. However, practitioners must appreciate that those communications may also be prohibited from disclosure based upon data security laws from around the world, including the EU’s General Data Protection Regulations (“GDPR”) effective May, 2018. Further, many states, such as California, also have enacted data security laws. The penalty for violating GDPR can reach 2% of worldwide annual revenue. This panel will discuss certain data security laws and how to avoid unlawful disclosures. Panelists: Chuck Hodges, Jones Day, Atlanta, GA; Kristin Hadgis, Morgan Lewis & Bockius, Philadelphia, PA
  • Final Partnership Audit Regulations: What’s New and Where Do We Go From Here. This panel will explore the rules in the final regulations release just before the partial government shutdown with a panel of that has been closely watching this area since before enactment of BBA in 2015. They will provide their unique perspectives and provide insights on the process and changes made by the recently released guidance. Moderator: Rochelle Hodes, Crowe LLP, Washington, DC Panelist: Sheri Dillon, Morgan Lewis & Bockius, Washington, DC, Mary McNulty, Thompson & Knight, Dallas, TX


Session : ABATX1904
Affiliated & Related Corporations
Conference : 2019 Midyear Meeting
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$45.00


  • Chair: Greg Fairbanks, Grant Thornton, Washington, DC
  • Section 163(j). The panel will discuss applicable provisions of the proposed section 163(j) regulation package [REG-106089-18] as it relates to consolidated groups and observations regarding affiliated corporations as well. Moderator: Julie Allen, PwC, Washington, DC Panelists: Lisa Zarlenga, Washington, DC; Mark Hoffenberg, KPMG, Washington, DC; Anthony Sexton, Kirkland & Ellis, Chicago, IL
  • Current Developments. This panel will consider current developments affecting affiliated and related corporations other than the section 163(j) regulation package. Moderator: Matt Gareau, Deloitte, Washington, DC Panelists: Bryan Collins, Deloitte, Washington, DC; Graham Magill, KPMG, Washington, DC


Session : ABATX1905
Banking & Savings Institutions
Conference : 2019 Midyear Meeting
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$45.00


  • Chair: Yoram Keinan, Kostelanetz & Fink LLP, New York, NY
  • Advising Financial Institutions in Times of Uncertainty.  The passage of the 2017 Tax Act in December 2017 resulted in significant changes to the international tax landscape in the United States. To fully implement the legislation which contains many unresolved issues and unanswered questions, Treasury and IRS are working hard on drafting and issuing regulations that once finalized, are expected to supplement the provisions of the Act. In the interim, for a period of almost 18 months, financial institutions are expected to operate, plan and comply with provisions which in part are yet to be published (section 7805(b)(2) allows the Treasury to issue regulations up to 18 months from the enactment date of the legislation with an effective date as of the date of the original legislation and without it being considered retroactive). In light of this unique situation, the panel will discuss how financial institutions and their tax advisers should operate in times of uncertainty and how to manage and minimize the risks associated. Moderator: Shay Menuchin, KPMG, Toronto, ON Panelists: Professor Diane Ring, Boston College Law School, Boston, MA; Chris Ferguson, Kostelanetz & Fink, New York, NY
  • Recent Developments Including Updates on International Tax Rules Pertaining to Financial Institutions. This panel will discuss current developments in taxation of financial institutions, in anticipation of regulations by the end of the year pertaining to the international tax provisions of the 2017 Tax Act. Moderator: Anthony Tuths, KPMG, New York, NY Panelist: Yoram Keinan, Kostelanetz & Fink LLP, New York, NY


Session : ABATX1906
Closely Held Businesses I
Conference : 2019 Midyear Meeting
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$45.00


  • Chair: Shawn L. McIntire, Velocity Global LLC, Denver, CO
  • Current Developments for Closely Held Businesses. This panel will discuss the recent developments in closely held businesses. Panelists: Shawn L. McIntire, Velocity Global LLC, Denver CO; Sabrina Strand, Law Offices of Joseph H. Thibodeau PC, Denver, CO
  • 280E – Introduction and Analysis of the Taxation of Cannabis Businesses. This panel will discuss the legislative history of I.R.C. Section 280E as well as current case law governing the cannabis industry including the C.H.A.M.P., Olive, Patients and Harborside cases. The panel will also discuss the overall regulatory landscape of the industry and the application of international cross-border transactions. Panelist: Shawn L. McIntire, Velocity Global LLC, Denver CO; Adam Abrahams, Meyers Hurvitz Abrahams LLC, Rockville, MD; Brandon King, Baker & McKenzie LLP, Washington, DC; Carina Federico, Crowell & Moring LLP, Washington, DC
  • Closely Held Businesses From Start to Finish: A Three Part Series. Part I: Formation: The panel will discuss what should be considered when establishing a closely held business and the difference considerations between C-Corporations, S-Corporations, Sole-Proprietorships and Partnerships. The panel will focus on both formation issues, corporate matters and taxation issues the business can face. Panelists: Robb Longman, Longman & Van Grack LLC, Bethesda, MD; Joseph B. Schimmel, Cohen Chase Hoffman & Schimmel PA, Miami, FL; Catherine Engell, Bracewell LLP, New York, NY


Session : ABATX1907
Estate & Gift Taxes
Conference : 2019 Midyear Meeting
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$45.00


  • Chairs: George D. Karibjanian, Franklin Karibjanian & Law PLLC, Boca Raton, FL/Washington, DC; Hannah W. Mensch, Ehrenkranz Partners, New York, NY
  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since October 2018. Panelists: Megan M. Curran, Fiduciary Counselling Inc., Tacoma, WA; Beth Kerwin, Paul Weiss Rifkind Wharton & Garrison LLP, New York, NY
  • Louisiana Estate Planning and Trust Practice: Some Challenges and Opportunities Under the Civil Law. Under the civil law, Louisiana estates and trusts have many unique characteristics. This panel will compare those characteristics to their common law analogues with the goal of helping practitioners avoid unintended tax and estate planning consequences for clients who own Louisiana property. Panelists: Professor Ron Scalise, Tulane Law School, New Orleans, LA; Kara McQueen-Borden, Jones Walker, New Orleans, LA
  • It’s All ‘Bout That Basis. Unlike Meghan Trainor’s song, which is quite repetitive, and like her song, where she says she’s “gon’ take it to a whole other level,” Lester plans to not be repetitive in his presentation and introduce us to a higher level of understanding “tax basis.” Lester will focus on some tax planning strategies which allows clients to take advantage of the tax basis rules (generally achieving stepping up the basis of assets) under sections 1014 and 1015. He, will also discuss some of the more complicated issues in tax basis today. Finally, he will share his planning thoughts for those representing the client migrating from community property states to common law states and the issues involved in preserving (if possible) the double basis step up under section 1014(b)(6). Panelist: Lester B. Law, Franklin Karibjanian & Law PLLC, Naples, FL/Washington, DC
  • The 2017 Tax Act: International Updates for the Trust and Estates Practitioner. This panel will review and examine the impact of the international aspects of the 2017 US tax legislation from the perspective of trusts, estates and individuals. In particular, this panel will cover new rules applicable to interests in controlled foreign corporations, passive foreign investment companies, the GILTI tax and nonresident beneficiaries of ESBTs. Panelists: Michael Karlin, Karlin and Peebles, Los Angeles, CA; Thomas M. Giordano- Lascari, Karlin and Peebles, Los Angeles, CA


Session : ABATX1908
Individual & Family Taxation
Conference : 2019 Midyear Meeting
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$15.00


  • Chair: James Creech, Law Offices of James Creech, San Francisco, CA
  • Unintended Gender Bias in Our Tax Laws. As the effects of the 2017 Tax Act on tax expenditures begin to take effect, some stakeholders have raised questions on the distribution of the benefits. For example, an October 2018 article in the New York Times reported that the cuts are "disproportionately helping white American over African-Americans and Latinos". Congress has taken note, at least with respect to section 199A and the Senate has heard testimony on how the JCT’s distribution of the revenue loss of section 199A reflects an unintended gender bias. This panel will discuss gender bias particularly with respect to women business owners and small business tax incentives. 2017 Tax Act provisions covered include elimination of the alimony inclusion/deduction regime; section 162(q); the corporate tax rate cut, section 199A, and the changes to sections 179 and 168(k)). Moderator: Professor Anthony Infanti Sr., University of Pittsburgh School of Law, Pittsburgh, PA Panelists: Professor Anne Bauer, University of Pittsburgh School of Law, Pittsburgh, PA; Professor Caroline Bruckner, American University and the Kogod Tax Policy Center, Washington, DC; Professor Annette Nellen, San Jose State University, San Jose, CA


Session : ABATX1909
Investment Management
Conference : 2019 Midyear Meeting
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$45.00


  • Chair: Roger S. Wise, Willkie Farr & Gallagher LLP, Washington, DC
  • Insurance Company Separate Accounts. This panel will discuss the tax requirements for investments in insurance company separate accounts and recent developments in this area, including recent guidance such as Rev. Proc. 2018-54 (diversification testing for uniform MBS) and Notice 2016-32 (diversification testing in light of money market reforms), implications of Webber v. Commissioner , and recent private letter rulings on investor control and diversification. Moderator: Graham R. Green, Eversheds Sutherland (US) LLP, Washington, DC Panelists: Jean Baxley, Deloitte LLP, Washington, DC; Michael Mingolelli, Winged Keel Group, Boston, MA
  • Current Regulatory and Legislative Developments Impacting Investment Funds. This panel will examine the current legislative and regulatory developments impacting investment funds, including proposed regulations and guidance under sections 163(j), 451(b), and 965(h), and provisions in the technical corrections bill on the pass-through of section 199A deductions by regulated investment companies. Moderator: Joseph Riley, Dechert LLP, New York, NY Panelist: Jessica Reif-Caplan, Fidelity Investments, Boston, MA; Katie Sunderland, Investment Company Institute, Washington, DC
  • An Opportunity to Discuss Opportunity Zones. This panel will discuss the definitions and requirements applicable to Qualified Opportunity Funds and Qualified Opportunity Zone Businesses, with a particular focus on some of the most challenging investor and fund-related issues. Panelists: Lisa Starczewski, Buchanan Ingersoll & Rooney, Washington, DC; Robert Cassanos, Fried Frank, New York, NY; Michael Shulman, Shearman & Sterling LLP, New York, NY


Session : ABATX1910
Real Estate
Conference : 2019 Midyear Meeting
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  • Chair: Todd D. Keator, Thompson & Knight LLP, Dallas, TX
  • Hot Topics. This panel will focus on new judicial, legislative, and administrative guidance and other recent developments relating to the taxation of real estate and partnerships. Moderator: Kate Kraus, Allen Matkins Leck Gamble Mallory & Natsis LLP, Los Angeles, CA Panelist: Glenn Johnson, EY, Washington, DC
  • Qualified Opportunity Zones - Reboot. This panel will discuss the proposed regulations regarding qualified opportunity zones and questions remaining for real estate developers and investors looking to undertake an opportunity zone project. Moderator: Mark Wilensky, Melzer Lippe Goldstein & Breitstone LLP, Mineola, NY Panelists: Steven Kennedy, PwC, Boston, MA; Lisa Starczewski, Buchanan Ingersoll & Rooney PC, Washington, DC; Lou Weller, Weller Partners LLP, Sausalito, CA; Leila Vaughan, Royer Cooper Cohen Braunfeld LLC, Conshohocken, PA
  • Section 163(j) — Update. This panel will provide a detailed discussion of the aspects of the proposed regulations on the limitation on the deduction for business interest expense that are applicable to partnerships and the real estate industry. Moderator: Ossie Borosh, KPMG LLP, Washington, DC Panelist: Monisha Santamaria, EY, Los Angeles, CA; Jon Finkelstein, KPMG, Washington, DC
  • Section 1061 - O&G and Real Estate Funds. This panel will provide a detailed discussion of the application of the carried interest rules to oil and gas and real estate funds. Moderator: Craig Gerson, PwC, Washington, DC Panelists: Roger Aksamit, Thompson & Knight LLP, Houston, TX; Orla O’Connor, KPMG LLP, San Francisco, CA



     


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