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Showing sessions 1 - 10 of (44) TOTAL sessions
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Event : ABATX6


Session : ABATX801
Capital Recovery and Leasing
Conference : 2008 MidYear Meeting
Speaker(s) :
File Size : 20.8 MB

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$30.00


  • Chair: Kevin D. Anderson, BDO Seidman LLP, Bethesda, MD
  • Current Developments Report and Update on Pending Guidance Projects. This program will cover the important recent developments in the areas of capital recovery and leasing since the 2007 Joint Fall CLE Meeting in Vancouver, BC, and provide an update on guidance projects in these areas. The program will include a brief discussion of guidance on the treatment of expenditures with respect to tangible property if issued before the meeting. Moderator: Katherine Breaks, KPMG LLP, Washington, DC. Panelists: Sharon Kay, Taxation Specialist, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Brandon Carlton, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC.
  • Tenant Improvement Allowances and Recovery of Leasehold Improvements. This program will cover current developments and open issues regarding tenant improvement allowances within and outside the section 110 safe harbor. In addition, the program will discuss issues concerning the capital recovery of leasehold improvements. Moderator: Glenn Johnson, Ernst & Young LLP, Washington, DC. Panelists: Brandon Carlton, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Robert Schachat, Ernst & Young LLP, Washington, DC; Jill Darrow, Katten Muchin Rosenman LLP, New York, NY.


Session : ABATX802
Affiliated and Related Corporations
Conference : 2008 MidYear Meeting
Speaker(s) :
File Size : 28.9 MB

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$30.00


  • Chair: Derek Cain, PricewaterhouseCoopers LLP, Washington, DC
  • Recent Developments. This panel will review recent developments in the consolidated return area, including relevant private letter rulings and technical advice memoranda. Moderator: Jeffrey Vogel, KPMG LLP, Washington, DC. Panelists: Mark Schneider, Deputy Associate Chief Counsel (Corporate), IRS, Washington, DC; James Banks, PricewaterhouseCoopers LLP, Los Angeles, CA.
  • Consolidated Successors. This panel will consider the new loss disallowance rules (if finalized), including the basic rules, problems with those rules and possible amendments to the rules. Moderators: Derek Cain, PricewaterhouseCoopers LLP, Washington, DC; Mark Schneider, Deputy Associate Chief Counsel (Corporate), IRS, Washington, DC. Panelists: Devon Bodoh, Dewey & LeBoeuf LLP, Washington, DC; Mark Schneider, Deputy Associate Chief Counsel (Corporate), IRS, Washington, DC; Marc Countryman, Attorney-Advisor, Tax Legislative Counsel, Department of Treasury, Washington, DC; Jonathan Forrest; Deloitte Tax LLP, Washington, DC.
  • Basis in Consolidation. This panel will discuss the coordination of consolidated and non-consolidated basis rules. Moderators: Gordon Warnke, Dewey & LeBoeuf LLP, New York, NY. Panelists: Marc Countryman, Attorney-Advisor, Tax Legislative Counsel, Department of Treasury, Washington, DC; Theresa Abell, Counsel to the Associate Chief Counsel (Corporate), IRS, Washington, DC; Professor Don Leatherman, University of Tennessee College of Law, Knoxville, TN; Brian Peabody, Ernst & Young LLP, Washington, DC.


Session : ABATX803
Administrative Practice
Conference : 2008 MidYear Meeting
Speaker(s) :
File Size : 27.8 MB

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$30.00


  • Chair: Phillip A. Pillar, Reed Smith LLP, Philadelphia, PA
  • Navigating the Reportable Transactions and Penalty Regulations – Practitioner’s “Shelter Round-Up.” This panel will discuss technical details and practitioners’ experience with the reportable transaction regulations and other guidance under sections 6011, 6111 and 6112. The panel will also discuss the potentially applicable penalties under sections 6707A, 6707 and 6708. Moderator: Robert T. Carney, O’Melveny & Myers LLP, Washington, DC. Panelists: Anita Soucy, Attorney-Advisor, Tax Legislative Counsel, Department of Treasury, Washington, DC; John E. Budde, Senior Attorney, Office of Chief Counsel, IRS, Cincinnati, OH.
  • Important Developments. This panel will summarize recent developments affecting the IRS administrative practice. Panelists: Kevin Johnson, Chamberlain Hrdlicka White Williams & Martin PC, Philadelphia, PA; Kevin M. Jacobs, Latham & Watkins LLP, Washington, DC.
  • The Rise and Fall of Interest Suspension Under § 6404(g). This panel will provide a primer on the interest suspension provisions of IRC § 6404(g), including the many exceptions that limit the applicability of interest suspension. Panelists: Brian Lynn, Caplin & Drysdale Chartered, Washington, DC; Jeanne Ross, Attorney-Advisor, Tax Legislative Counsel, Department of Treasury, Washington, DC; Henry Schneiderman, Special Counsel to the Associate Chief Counsel, IRS, Washington, DC.
  • Return Preparers: As the Stakes Increase, So Does the Importance of Calculating the Odds. This panel will discuss recent amendments to the preparer penalty provisions of IRC § 6694. Moderator: Christopher S. Rizek, Caplin & Drysdale Chartered, Washington, DC. Panelists: Anita Soucy, Attorney-Advisor, Tax Legislative Counsel, Department of Treasury, Washington, DC; Thomas J. Kane, Special Counsel, Office of Chief Counsel, IRS, Washington, DC; Fred Murray, Grant Thornton LLP, Washington, DC; Eli Dicker, Tax Executives Institute, Washington, DC.
  • Simultaneous Civil/Criminal Proceedings. With the increasing intersection of criminal and civil tax proceedings, this panel will discuss issues that arise when both civil and criminal tax cases are being pursued simultaneously. Moderator: Ronald L. Buch, McKee Nelson LLP, Washington, DC. Panelists: Christopher B. Sterner, Division Counsel, Large & Mid-Size Business, IRS, Washington, DC; Dana J. Boente, First Assistant US Attorney, US Attorney’s Office for the Eastern District of Virginia, Alexandria, VA; Miriam L. Fisher, Morgan Lewis & Bockius LLP, Washington, DC.


Session : ABATX804
Banking and Savings Institutions
Conference : 2008 MidYear Meeting
Speaker(s) :
File Size : 26.9 MB

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MP3
$30.00


  • Chair: Michelle M. Henkel, Alston & Bird LLP, Atlanta, GA
  • Subprime Markets, Predatory Lending Practices and Over-Rated Debt. Since the collapse of the subprime market, attention has been focused on mortgage fees and adjustable rate mortgages, rating agencies, debt modifications and securitized debt and proposals to change the debt cancellation rules. This panel will look at tax and non-tax implications of this problem. Moderator: John Ensminger, Law Offices of John Ensminger, Stone Ridge, NY. Panelists: Yoram Keinan, Greenberg Traurig LLP, New York, NY; Fran Mordi, American Bankers Association, Washington, DC; Michael Novey, Associate Tax Legislative Counsel, Tax Legislative Counsel, Department of Treasury, Washington, DC.
  • Litigation and Behind-the-Scenes Developments in the Financial Services Industry. This panel will discuss (i) the latest developments with LILOs and SILOs, including changes in settlement ranges and changes in IRS personnel; (ii) the “designation for litigation” process, including how it works, how cases are selected, what does it mean and what internal analyses can the IRS disclose; (iii) the issue tiering process, including how issues are selected, what factors impact the selection, whether the tiered issues are public and what internal analyses can the IRS disclose and (iv) where the IRS is headed after Textron and what the IRS is planning to do next vis-à-vis FIN-48. Moderator: Michelle M. Henkel, Alston & Bird LLP, Atlanta, GA. Panelist: Roland Barral, Area Counsel-Financial Services, Division Counsel (Large & Mid-Size Business), IRS, New York, NY.
  • Recent Transactional Developments. This panel will scrutinize the recent output from the Department of Treasury and Capitol Hill on including exchange traded notes, the People’s Savings case and its impact on interpretation of section 265, reaction to section 475 safeharbor rules and section 1221(a)(4). Moderator: Viva Hammer, Crowell & Moring LLP, New York, NY. Panelists: John Rogers III, Senior Attorney, Office of Chief Counsel (Financial Institutions & Products), IRS, Washington, DC; Vincent Guiliano, Banking Industry Director, LMSB Area Counsel, IRS, New York, NY; Robert Dilworth, McDermott Will & Emery LLP, Washington, DC; Catherine C. Barre, Legg Mason & Co LLC, Baltimore, MD.


Session : ABATX805
Closely Held Businesses AM
Conference : 2008 MidYear Meeting
Speaker(s) :
File Size : 26.5 MB

Download Format(s) :
MP3
$30.00


  • Chair: William P. Prescott, Wickens Herzer Panza Cook & Batista Co, Avon, OH
  • Entity Selection for the Closely Held Business. Panelists: Alson R. Martin, Lathrop & Gage LC, Overland Park, KS; Leslie E. Grodd, Halloran & Sage LLC, Westport, CT; Eric L. Green, Convicer & Percy LLP, Glastonbury, CT.
  • S Corporations… What’s New? Speakers: Ronald A. Levitt, Sirote & Permutt PC, Birmingham, AL; Stephen R. Looney, Dean Mead Egerton Bloodworth Capouano & Bozarth PA, Orlando, FL.
  • Entity Formalities, Governance and Dissolution. Panelists: David L. Herzer, Wickens Herzer Panza Cook & Batista Co, Avon, OH; James Robert Turnipseed, Bowron Latta & Wasden PC, Mobile, AL.


Session : ABATX806
Estate and Gift Taxes
Conference : 2008 MidYear Meeting
Speaker(s) :
File Size : 29.5 MB

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MP3
$30.00


  • Chair: John Bergner, Winstead PC, Dallas, TX
  • Recent Developments. This panel will discuss recent developments in estate and gift tax planning and administration. Panelists: Catherine V. Hughes, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Benjamin Carter, Winstead PC, Dallas, TX.
  • 529 Plans: Extra Credit for the Estate Planning Attorney. Speakers: Christopher E. Houston, Ropes & Gray LLP, Boston, MA; Sarah M. Johnson, Venable LLP, Washington, DC.
  • Estate Planning for Lottery and Other Winners. Speakers: Judith Tobey, Hughes & Luce LLP, Dallas, TX; Russell W. Hall, Russell W. Hall & Associates PC, Bellaire, TX.
  • Gift and Estate Tax Consequences of DING Trusts. Speaker: Stephen F. Lappert, Carter Ledyard & Milburn LLP, New York, NY.


Session : ABATX807
Exempt Organizations
Conference : 2008 MidYear Meeting
Speaker(s) :
File Size : 46.2 MB

Download Format(s) :
MP3
$75.00


  • Chair: Michael A. Clark, Sidley Austin LLP, Chicago, IL
  • News from the IRS and Department of Treasury. Representatives from the Tax Exempt/Government Entities Division of IRS and from the Department of Treasury will speak on recent developments and pending guidance. Moderator: Frederick J. Gerhart, Dechert LLP, Philadelphia, PA. Panelists: Lois G. Lerner, Director, Exempt Organizations, IRS, Washington, DC; Catherine E. Livingston, Assistant Chief Counsel, Tax Exempt/Government Entities, IRS, Washington, DC; Eric A. San Juan, Deputy Tax Legislative Counsel (Tax Legislation), Office of Tax Policy, Department of Treasury, Washington, DC.
  • Form 990 Update. A panel discussion of the new IRS draft form 990, highlighting changes from the June 14, 2007 draft and analyzing implementation issues. Moderator: Ralph DeJong, McDermott Will & Emery LLP, Chicago, IL. Panelists: Ronald J. Schultz, Senior Technical Advisor to the Commissioner, Tax Exempt/Government Entities, IRS, Washington, DC; Beth Kingsley, Harmon Curran Spielberg & Eisenberg LLP, Washington, DC; Lauren Mack, Sonnenschein Nath & Rosenthal LLP, San Francisco, CA; Douglas M. Mancino, McDermott Will & Emery LLP, Los Angeles, CA.
  • Election Year Issues, as Seen by the IRS, the FEC and the Rest of Us. This panel will discuss current guidance and issues regarding lobbying and political activities. Moderator: Professor Miriam Galston, George Washington University Law School, Washington, DC. Panelists: Judith Kindell, Senior Technical Advisor to the Director, Exempt Organizations, IRS, Washington, DC; Craig Engle, Arent Fox LLP, Washington, DC; James P. Joseph, Arnold & Porter LLP, Washington, DC.
  • Endowment and Investment Issues. This panel will discuss issues regarding the management of endowment funds, including proposals with respect to the tax treatment of hedge fund investments. Moderator: Suzanne Ross McDowell, Steptoe & Johnson LLP, Washington, DC. Panelists: Bill Bowers, Senior Counsel, Office of Tax Policy, Department of Treasury, Washington, DC; David Shevlin, Simpson Thacher & Bartlett LLP, New York, NY; Carolyn M. Osteen, Ropes & Gray LLP, Boston, MA.
  • Speaker: Rev. J. Edwin Bacon Jr., All Saints Church, Pasadena, CA. Topic: A Church’s Perspective on Enforcement of the Political Campaign Proscription
  • FIN 48 Issues. This panel will discuss the application of FIN 48 to the disclosure of contingent liabilities relating to tax exempt organizations, including unrelated business income issues and exemption issues. Moderator: Elizabeth Mills, McDermott Will & Emery LLP, Chicago, IL. Panelists: Rob Friz, PricewaterhouseCoopers LLP, Philadelphia, PA; Laura Kalick, BDO Siedman LLP, Washington, DC; Fred F. Murray, Grant Thornton LLP, Washington, DC.
  • Circular 230, Tax Shelter Transactions and Preparer Penalties—What EO Practitioners Need to Know. This panel will discuss the updated Circular 230 regulations and the preparer penalty standards under section 6694, as amended by the Small Business and Work Opportunity Tax Act of 2007. Moderator: Michael A. Clark, Sidley Austin LLP, Chicago, IL. Speakers: Michael R. Chesman, Director, Office of Professional Responsibility, IRS, Washington, DC; Anita Soucy, Attorney-Advisor, Tax Legislative Counsel, Department of Treasury, Washington, DC; Brian C. Bernhardt, McGuireWoods LLP, Richmond, VA; Celia Roady, Morgan Lewis & Bockius LLP, Washington, DC.


Session : ABATX808
Individual and Family Taxation
Conference : 2008 MidYear Meeting
Speaker(s) :
File Size : 29.4 MB

Download Format(s) :
MP3
$30.00


  • Chair: Professor Bryan T. Camp, Texas Tech University School of Law, Lubbock, TX
  • When Having Fun is Making Money: Taxation of Hobbies. This panel will explore the rules associated with section 183, which allows taxpayers to deduct expenses associated with income from hobbies, but does not permit taxpayers to shelter non-hobby income when hobby expenses exceed hobby income. Moderator: Professor Roberta Mann, Widener University School of Law, Wilmington, DE. Panelists: Professor Christopher M. Pietruszkiewicz, Louisiana State University, Paul M. Hebert Law Center, Baton Rouge, LA; Andrew J. Keyso, Special Counsel to the Associate Chief Counsel (Income Tax & Accounting), IRS, Washington, DC.
  • When Making Money is Having Fun: Taxation of Gaming. This panel will explore the rules associated with gaming activities with a focus on potential realization issues. Panelists: Professor Bryan T. Camp, Texas Tech University School of Law, Lubbock, TX; Professor Theodore Seto, Loyola Law School, Los Angeles, CA.


Session : ABATX809
Real Estate
Conference : 2008 MidYear Meeting
Speaker(s) :
File Size : 31 MB

Download Format(s) :
MP3
$30.00


  • Chair: Kevin Thomason, Thompson & Knight LLP, Dallas, TX
  • Just What is “Real Property” for Tax Purposes? This panel will describe and analyze the major distinctions among the meanings of the term “real property” for purposes of section 512 (Unrelated Trade or Business Income), section 856 (REITs), section 897 (FIRPTA) and section 1031 (Like Kind Exchanges). Moderator: David Miller, Ernst & Young LLP, Dallas, TX. Panelists: Professor Bradley T. Borden, Washburn University School of Law, Topeka, KS; Roger Aksamit, Bracewell & Giuliani LLP, Houston, TX.
  • REIT Liquidations. This panel will explore the methods of effectuating, and the tax issues implicated in, the liquidation of REITs, both public and private, including 100-shareholder compliance, personal holding company issues, FIRPTA gain recognition and withholding for non-US investors and maintaining REIT compliance during the liquidation period. Moderator: Peter J. Genz, King & Spalding LLP, Atlanta, GA. Panelists: John Merrick, Special Counsel to the Associate Chief Counsel, Chief Counsel (International), IRS, Washington, DC; Brian S. Masterson, Venable LLP, Washington, DC.
  • Hot Planning Techniques Involving Leases. The panel will describe key tax planning techniques involving leases, including (i) the treatment of rent prepayments for tax purposes and the limits on the number of years for which rent can be prepaid, (ii) the use of leases to obtain state tax advantages and (iii) the structuring of a lease so that it does not “cross the line” and become a current sale for tax purposes. Moderator: Jill Darrow, Katten Muchin Rosenman LLP, New York, NY. Panelists: Carolyn Joy Lee, Jones Day, New York, NY; Joseph Lipari, Roberts & Holland LLP, New York, NY; Kevin Anderson, BDO Seidman LLP, Bethesda, MD.
  • Troubled Like Kind Exchanges. Has your intended like kind exchange gone awry? Is your qualified intermediary disappearing? This panel will focus on cutting edge techniques for dealing with these and other issues that have recently arisen in connection with troubled section 1031 exchanges. Moderator: Robert D. Schachat, Ernst & Young LLP, Washington, DC. Panelist: Louis Weller, Deloitte Tax LLP, San Francisco, CA.
  • Doing Deals with Funds and REITs Part I. This panel, as well as a companion panel to be presented in the afternoon by the Partnerships & LLCs Committee, will focus on the business, REIT and other tax issues faced by a modest-sized regional real estate company that has been approached by a REIT and/or a fund with tax-exempt and foreign investors. Potential negotiation strategies that may be employed by the real estate company will also be discussed. This panel will focus on the business and REIT-specific issues involved in such negotiations. Moderator: Darryl Steinhause, Luce Forward Hamilton & Scripps LLP, San Diego, CA. Panelists: Jim Lowy, Ernst & Young LLP, San Francisco, CA; Leslie H. Loffman, DLA Piper LLP, New York, NY; James H. Lokey, King & Spalding LLP, Atlanta, GA.


Session : ABATX810
S Corporations
Conference : 2008 MidYear Meeting
Speaker(s) :
File Size : 39.2 MB

Download Format(s) :
MP3
$45.00


  • Chair: Carol Kulish Harvey, KPMG LLP, Washington, DC
  • Important Developments. Discussion of recent legislative, administrative and judicial developments relating to S corporations and their shareholders, including a discussion of provisions relevant to S corporations in the Tax Reduction and Reform Act of 2007, introduced by Charles Rangel (D-NY), the Chairman of the House Committee on Ways and Means. Moderator: Laura Howell-Smith, Deloitte Tax LLP, Washington, DC.
  • Recent Developments Regarding Estate Planning for Shareholders of S Corporations. Moderator: Laura Howell-Smith, Deloitte Tax LLP, Washington, DC. Panelist: Jeanne L. Newlon, Venable LLP, Washington, DC.
  • Recent Developments in State and Local Taxation of S Corporations. A discussion of recent developments in state and local taxation relevant to S corporations, including states that require withholding on nonresident shareholders, state treatment of Qualified Subchapter S Subsidiaries and single-member limited liability companies, state recognition of section 338(h)(10) elections, sales of S corporation stock by nonresidents and availability of credits for taxes paid to another state. Moderator: Stephen Nechemias, Taft Stettinius & Hollister LLP, Cincinnati, OH. Panelist: David E. Kahen, Roberts & Holland LLP, New York, NY.
  • Limited Liability Companies Classified as S Corporations – Part II. Continuation of discussion from 2007 May Meeting in Washington, DC, along with discussion of form of operating agreement for Delaware LLC that elects S corporation status. Moderator: Ronald Levitt, Sirote & Permutt PC, Birmingham, AL. Panelists: Steven Klein, Sher Garner Cahill Richter Klein McAlister & Hilbert LLC, New Orleans, LA; Stephen R. Looney, Dean Mead Egerton Bloodworth Capouano & Bozarth PA, Orlando, FL; Christopher R. D’Amico, Dean Mead Egerton Bloodworth Capouano & Bozarth PA, Orlando, FL.
  • Built-In Gains Tax – Planning Considerations. A discussion with members of the Committee regarding selected built-in gains tax issues and a paper on the subject. Moderators: Professor Lorence Bravenec, Texas A&M University, Mays Business School, College Station, TX; Professor Fred Feucht, Prairie View A&M, Prairie View, TX.



     


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