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Showing sessions 1 - 10 of (53) TOTAL sessions
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Event : ABATX8


Session : ABATX8162
Standards of Tax Practice
Conference : 2008 May Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • Chair: Professor Mona L. Hymel, University of Arizona James E. Rogers College of Law, Tucson, AZ
  • Report from the IRS on Ethics. Standards of practice are a continuing area of attention by the IRS. This program will provide a report on the current activities including the status of Circular 230 amendments. Panelists: Deborah A. Butler, Associate Chief Counsel, IRS, Washington, DC; Richard Goldstein, Associate Chief Counsel, IRS, Washington, DC; Michael Chesman, Director, Office of Professional Responsibility, IRS, Washington, DC; Stephen Whitlock, Director, Whistleblower Office, IRS, Washington, DC; Don Svendsen, Deputy Director, Office of Professional Responsibility, IRS, Washington, DC.
  • Ethical Responsibilities of Government Attorneys in Tax Controversy (Part 2). This panel will follow up on a well-received program a year ago in which a group of experienced practitioners address the standards and rules of conduct applicable to IRS personnel (both attorneys and non-attorneys) and explore their operation in particular tax controversy scenarios. Moderator: Jasper G. Taylor III, Fulbright & Jaworski LLP, Houston, TX.
  • Preparer Standards and Ethical Issues Concerning Prior Year Returns. Due to §6694 and FIN 48, tax professionals have increased their scrutiny of uncertain tax positions. This can lead to the discovery of errors or omissions in prior year returns. Circular 230 imposes specific obligations on practitioners (not limited to return preparers) that may, in light of the pertinent changes, warrant the reexamination of positions taken on earlier year returns. The program will analyze this issue. Moderator: Pete Wilson, RSM McGladrey Inc, Raleigh, NC.


Session : ABATX8161
SECTION PROGRAM: Proposed Regulations on Capitalizing Costs of Acquiring and Improving Tangible Assets
Conference : 2008 May Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • In 2006, proposed regulations under section 263(a) were issued relating to amounts paid to acquire, produce, or improve tangible property. On March 7, 2008, the Department of Treasury released re-proposed regulations under section 263(a) relating to the treatment of expenditures with respect to tangible property. With these re-proposed rules, the IRS and Department of Treasury have offered a number of simplifying measures and safe harbors. The regulations attempt more objective measures and standards for companies evaluating whether particular repair expenses may be deducted or should be capitalized. Additionally, these new proposed regulations provide significant changes to the rules relating to unit of property and restorations, and allow for industry-specific repair allowance methods in the future. The program will review the new regulations, including consideration of how the regulatory tests and operating rules are different from the earlier proposed regulations. Government panelists involved with the regulations project, both from Department of Treasury, Office of Legislative Counsel and IRS Office of Chief Counsel will offer insight regarding policy and administrative concerns shaping the regulations. Several practitioners will discuss issues raised by the new regulations.
  • Moderator: Ellen McElroy, Pepper Hamilton LLP, Washington, DC
  • Panelists: Merrill Feldstein, Senior Counsel (Income Tax & Accounting), IRS, Washington, DC; Susan Grais, Ernst & Young LLP, Washington, DC; Heather Johnson, Discovery Communications, Silver Spring, MD; Sharon Kay, Ernst & Young LLP, Washington, DC; Kimberly Koch, Special Counsel (Income Tax & Accounting), IRS, Washington, DC; Todd Reinstein, Pepper Hamilton LLP, Washington, DC; Dennis Tingey, Taxation Specialist, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC
  • Sponsored by: Capital Recovery & Leasing, Sales, Exchanges & Basis and Tax Accounting


Session : ABATX8160
SECTION PROGRAM: Your Multinational Client is Reorganizing its Global Business Operations: A Checklist for the Tax Professional
Conference : 2008 May Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • The session will focus on the transfer pricing and international tax implications for a US-based multinational expanding its operations in the North American, European and Asia Pacific Regions while seeking to achieve tax savings to help finance that expansion by reorganizing its business operations in a tax efficient manner. The panelists will discuss opportunities in light of new tax developments both in the US and elsewhere, which will impact planning by the multinational to relocate its R&D and intellectual property to a lower tax jurisdiction (including cost sharing), to convert current manufacturing and sales operations and to centralize procurement and other group services as well as reallocate business risk and management oversight functions.
  • Moderators: David Canale, Ernst & Young LLP, Washington, DC; Elinore Richardson, Borden Ladner Gervais LLP, Toronto, ON
  • Panelists: Peter Barnes, General Electric Co., Fairfield, CT; Michael Miller, Roberts & Holland, New York, NY; Mark O’Sullivan, Matheson Ormsby Prentice, Palo Alto, CA; Klaus Sieker, Flick Gocke Schaumburg, Frankfurt, Germany; Carol Tello, Sutherland Asbill & Brennan, Washington, DC
  • Sponsored by: Transfer Pricing; supported by Foreign Activities of US Taxpayers and US Activities of Foreigners & Tax Treaties Committees and Foreign Lawyers Forum


Session : ABATX8159
SECTION PROGRAM: ‘Hope in Motion': How to Effectively Use a Motions Practice in the Various Forums
Conference : 2008 May Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • This panel will discuss the basics of handling motions before and after a trial in the US Tax Court, the US Court of Federal Claims and a US District Court. This program is an informal roundtable.
  • Moderator: Charles E. Hodges II, Chamberlain Hrdlicka White Williams & Martin, Atlanta, GA
  • Panelists: Judge Francis M. Allegra, US Court of Federal Claims, Washington, DC; Richard Goldman, Branch Chief, Branch 6, IRS, Washington, DC; Judge L. Paige Marvel, US Tax Court, Washington, DC; Todd Welty, Meadows Collier Reed Cousins Blau LLP, Dallas, TX
  • Sponsored by: Court Procedure and Practice


Session : ABATX8158
SECTION PROGRAM: Cross-Border M&A: Identifying and Dealing with Compensation and Benefits Issues
Conference : 2008 May Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • This program, which is presented jointly with the International Association of Pension and Employee Benefits Lawyers (IPEBLA), will cover the benefits and executive compensation issues commonly involved in cross-border transactions (including issues relating to internationally mobile employees and the section 409A rules for foreign plans). The international group of panelists will provide a variety of perspectives on these issues.
  • Moderators: George H. Bostick, Sutherland Asbill & Brennan LLP, Washington, DC; Thomas Jorgensen, Calfee Halter & Griswold LLP, Cleveland, OH
  • Panelists: Jane L. Dale, Allen & Overy LLP, London, England; Kees-Pieter Dekker, Clifford Chance LLP, Amsterdam, Holland; Mitch Frazer, Torys LLP, Toronto, ON; Peggy Haines, Freehills, Melbourne, Australia; Lyle Teichman, Towers Perrin, Toronto, ON
  • Sponsored by: Employee Benefits


Session : ABATX8157
Privilege vs. Transparency – Will Disclosure of State Tax Accrual Workpapers Be Required?
Conference : 2008 May Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • This program will discuss whether state tax accrual workpapers and related documents are (or should be) required to be provided to state taxing authorities, and whether those documents are (or should be) protected by attorney-client privilege, accountant-client privilege or the attorney work product doctrine. The speakers will review the types of documents that are prepared by both lawyers and accountants as part of the process of establishing state tax reserves under FIN 48 and FAS 5, the current state of federal law regarding privilege and work product, and the interpretation of those doctrines by the various states. Following the discussion of the current state of play regarding tax accrual workpapers, the speakers will engage in a panel discussion of the competing interpretations of the various protective privileges and doctrines, and will consider the relevance of tax accrual workpapers to state tax audits, as well as the benefits of retaining confidentiality of tax accrual workpapers.
  • Moderator: David J. Shipley, McCarter & English LLP, Philadelphia, PA
  • Panelists: John P. Barrie, Bryan Cave LLP, New York, NY; Marc A. Simonetti, Sutherland Asbill & Brennan LLP, New York, NY; Scott D. Smith, LeclairRyan, Washington, DC
  • Sponsored by: State and Local Taxes


Session : ABATX8156
SECTION PROGRAM: Election Issues for Tax-Exempt Organizations
Conference : 2008 May Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • This session will span a range of needs for the tax practitioner who may be asked to advise on the treacherous terrain of allowable activities for exempt organizations interested in this year’s federal, state and local elections. We will introduce the special IRS rules that apply to charities and other section 501(c) organizations and to section 527 political groups in relation to campaigns to elect candidates or to pass or defeat ballot measures. Panelists will cover the intersection of tax law and election laws administered by the FEC, the latest information on how exempt vehicles are deployed by political activists, safe ways to inject social issues into candidate races and recent efforts to test the constitutional limits of these often vague and confusing regulations.
  • Moderator: Greg Colvin, Adler & Colvin, San Francisco, CA
  • Panelists: Judith Kindell, Tax Law Specialist, Office of Rulings & Agreements, IRS, Washington, DC; Holly Schadler, Lichtman Trister & Ross PLLC, Washington, DC; Liz Towne, Alliance for Justice, Washington, DC; Steve Weissman, Campaign Finance Institute, Washington, DC
  • Sponsored by: Exempt Organizations


Session : ABATX8155
Joint Session of Civil & Criminal Tax Penalties and Standards of Practice
Conflicts Check: Who's Your Client? What's the Scope? Should You Take the Work?
Conference : 2008 May Meeting
Speaker(s) :
Download Format(s) :
MP3
$15.00


  • This interactive panel will explore conflict issues that tax practitioners face in a variety of contexts. Panelists will address conflicts that arise from prior and contemporaneous work, including representing husband and wife in audit and estate planning matters, formation and representation of business entities, representing exempt organizations and insiders, and defending business organizations and their officers/employees in criminal tax matters.
  • Moderator: Larry A. Campagna, Chamberlain Hrdlicka White Williams & Martin, Houston, TX.
  • Panelists: Professor Bradley T. Borden, Washburn University School of Law, Topeka, KS; Katherine E. David, Oppenheimer Blend Harrison & Tate Inc, San Antonio, TX; Natalie Fay Green, Caplin & Drysdale Chartered, Washington, DC; Nathan J. Hochman, Assistant Attorney General, Tax Division, Department of Justice, Washington, DC.


Session : ABATX8154
Foreign Lawyers Forum
Conference : 2008 May Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • Chair: Friedhelm Jacob, Hengeler Mueller, Frankfurt, Germany
  • The Rangel “Mother of All Tax Bills”: Repatriation-Contingent Deductions, Ordinary Treatment of Carried Interest and Other Heresies. Some long-established premises of the US tax system, such as the basic operation of the deferral system and the ability to earn preferred returns at capital gains rates, are being called into question. House Ways & Means Committee Chairman Charles B. Rangel (D-NY) has proposed major changes in these areas as revenue raisers to finance the lowering of the corporate tax rate and other corporate tax benefits. Other major jurisdictions are wrestling with similar issues. This panel will discuss the policy and technical issues involved in shaping an efficient, fair and administrable tax regime in the US and other major jurisdictions, focusing on Chairman Rangel’s bill and other important recent developments. Moderator: David Noren, McDermott Will & Emery LLP, Washington, DC. Panelists: David Lenter, Legislation Counsel, Joint Committee on Taxation, US Congress, Washington, DC; Sonia Velasco, Cuatrecasas LLP, New York, NY; Joshua Odintz, Tax Counsel, Senate Finance Committee, Washington, DC, Jean-Paul van den Berge, Stribbe, New York, NY.
  • Financial Derivatives and the Outbound Withholding Tax. The governments of the US and other countries have become increasingly concerned about the ability of taxpayers to avoid outbound withholding taxes through the use of equity swaps and other derivative financial products. Current US guidance does not seem to deal adequately with some of the ownership and agency issues that arise in this context. This panel will discuss the relevant technical and policy issues with a view to determining what the rules should be going forward. Moderator: Jeff Maddrey, PricewaterhouseCoopers LLP, Washington, DC. Panelists: David Shapiro, Senior Counsel (Financial Products – Domestic & International), Department of Treasury, Washington, DC; Lodewijk Berger, Loyens & Loeff NV, New York, NY; Barbara Worndl, Aird & Berlis, Toronto, ON.


Session : ABATX8153
Pro Bono
Conference : 2008 May Meeting
Speaker(s) :
Download Format(s) :
MP3
$15.00


  • Chair: Robert McKenzie, Arnstein & Lehr LLP, Chicago, IL
  • Mortgage Forgiveness Debt Relief Act of 2007. Under the Mortgage Forgiveness Debt Relief Act of 2007, enacted December 20, taxpayers may exclude debt forgiven on their principal residence if the balance of their loan was less than $2 million. The limit is $1 million for a married person filing a separate return. The program will discuss the pro bono attorneys’ role in assuring low income taxpayer rights. Moderator: Robert E. McKenzie, Arnstein & Lehr LLP, Chicago, IL. Panelists: Frances D. Sheehy, Law Office of Frances D. Sheehy, Coconut Creek, FL; Megan L. Brackney, Kostelanetz & Fink LLP, New York, NY.
  • US Tax Court Requirements for Bar Association Pro Bono Programs.The US Tax Court has proposed new rules for bar association pro bono programs. Bar associations administer pro bono programs through which volunteer tax attorneys provide assistance to low-income and unrepresented taxpayers. The new rules are designed to assure quality assistance and more uniform procedures for volunteer attorneys and Tax Court Practitioners. Moderators: Elizabeth Atkinson, LeClair Ryan, Virginia Beach, VA; Honorable Peter J. Panuthos, Chief Special Trial Judge, US Tax Court, Washington, DC.
  • Sub-Committee Reports. Committee business will be conducted with reports from sub-committee chairs and project chairs.



     


Showing sessions 1 - 10 of (53) TOTAL sessions
(PREV 10)  1 2 3 4 5 6    (NEXT 10)



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