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Showing sessions 1 - 10 of (51) TOTAL sessions
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Event : ABATX9


Session : ABATX8170
Low Income Taxpayer Clinic Workshop
Conference : 2008 Joint Fall CLE Meeting
Speaker(s) :
Download Format(s) :
MP3
$75.00


  • Low Income Taxpayer Chair: Joseph Schimmel, Cohen Chase Hoffman & Schimmel PA, Miami, FL; Pro Bono Chair: Robert E. McKenzie, Arnstein & Lehr LLP, Chicago, IL
  • Current Issues in IRS Examination. This panel will review the function of IRS Examinations. Included will be discussions of field examinations, campus examinations and the AUR Program, as well as issues in audits of disabled taxpayers. Moderator: Professor Alan Weinberg, Duke University School of Law, Durham, NC; Panelists: Claudia Hill, Tax Mam Inc, Cupertino, CA; Eric D. Slack, Taxpayer Advocate Service, Washington, DC.
  • Breakout Session A: Representing Taxpayers in EITC Examinations. A review of current EITC compliance efforts, and best practices for establishing entitlement to the EITC. Moderator: Professor Dale Kensinger, University of Missouri–Kansas City Law School, Kansas City, MO; Panelists: Lisa McCaughey, Tax Analyst, SB/SE, IRS, Philadelphia, PA; Eric D. Slack, Taxpayer Advocate Service, Washington, DC.
  • Breakout Session B: Identity Theft. Several aspects of identity theft will be discussed, with emphasis on misuse of taxpayer identification numbers. Moderator: Professor George Willis, Chapman University School of Law, Orange, CA. Panelists: Chris Lee, Taxpayer Advocate Service, Washington, DC; Robb A. Longman, Joseph Greenwald & Laake PA, Greenbelt, MD.
  • Cancellation of Debt. Audit issues involving the section 108 insolvency exception and the Mortgage Forgiveness Debt Relief Act. Moderator: Professor Ljubomir Nacev, Northern Kentucky University, Chase College of Law, Highland Heights, KY. Panelists: Andy Keyso, Attorney Advisor, Office of Chief Counsel, IRS, Washington, DC; Paul Petrella, Program Analyst, SB/SE Compliance Services, IRS, Holtsville, NY; Eric D. Slack, Taxpayer Advocate Service, Washington, DC.
  • Audit Reconsideration. Where, when and what to file, to obtain prompt and effective review of requests for audit reconsideration. Moderator: Professor Jerome Borison, University of Denver Sturm College of Law, Denver, CO. Panelists: John Lindsley, Acting Chief, Planning and Analysis, IRS, Austin, TX; Eric D. Slack, Taxpayer Advocate Service, Washington, DC.


Session : ABATX8171
Transfer Pricing
Conference : 2008 Joint Fall CLE Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • Chair: John P. Warner, Buchanan Ingersoll & Rooney PC, Washington, DC
  • Stock-Based Compensation: Transfer Pricing Issues. This panel will discuss the treatment, for transfer pricing purposes, of stock-based compensation under the temporary §482 services regulations, the current §482 cost sharing regulations and the Comparable Profits Method (CPM) regulations; handling the issue in tax audits for years predating the amendments to the services and cost sharing regulations and the implications of the Xilinx case. Moderator: Patricia G. Lewis, Caplin & Drysdale Chartered, Washington, DC. Panelists: David G. Chamberlain, Branch 4, Office of Associate Chief Counsel (International), IRS, San Francisco, CA; D. Clarke Norton, Duff & Phelps LLC, San Francisco, CA; Eric D. Ryan, DLA Piper, East Palo Alto, CA.
  • Practical Problems in Transfer Pricing. This panel will discuss transfer pricing issues currently facing private practitioners and in-house counsel. Among the issues that will be discussed are the treatment of secondments, implementation of the temporary §482 services regulations, coordinating business valuation with transfer pricing and coordinating transfer pricing and customs valuation. Moderator: E. Miller Williams, Ernst & Young LLP, Atlanta, GA. Panelists: Jon Tamaki, LMSB International Technical Advisor, Large and Midsize Business, IRS, San Jose, CA; Thomas Zollo, KPMG LLP, Chicago, IL.


Session : ABATX8172
Administrative Practice
Conference : 2008 Joint Fall CLE Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • Chair: Ronald L. Buch, Jr., McKee Nelson LLP, Washington, DC
  • Important Developments. This panel will discuss important developments in administrative practice that have occurred since the 2008 May Meeting in Washington, DC. Moderator: Kevin Johnson, Chamberlain Hrdlicka White Williams & Martin, Philadelphia, PA. Panelists: Deborah A. Butler, Associate Chief Counsel, Procedure and Administration, IRS, Washington, DC; Gary D. Gray, Deputy Associate Chief Counsel, Procedure and Administration, IRS, Washington, DC; Jennifer Breen, PricewaterhouseCoopers LLP, Washington, DC.
  • LMSB Update. The panel will provide an update of the Tiered Issue initiative and discuss strategies for resolving Tiered Issues at both the Exam and Appeals levels. Moderator: Sheri Dillon, McKee Nelson LLP, Washington, DC. Panelists: Michael Desmond, McKee Nelson LLP, New York, NY; Marc Korab, Citigroup Inc, New York, NY; Frank Y. Ng, Commissioner, Large and Mid-Sized Business Division, IRS, Washington, DC.
  • Regulation Validity/Judicial Deference. What degree of deference should be accorded IRS regulations and other pronouncements? After Chevron and its progeny, does it make any difference whether the regulations are legislative or interpretive? Are IRS Rulings and proposed regulations entitled to Skidmore deference? The government has prevailed in two recent cases in the Courts of Appeals, Swallows Holding Ltd v. Commissioner, and Texaco v. US, where the degree of deference was a central issue. This panel will provide an update on recent tax and non-tax jurisprudence regarding deference. Moderator: Robert J. Chicoine, Chicoine & Hallett PS, Seattle, WA. Panelists: Fred F. Murray, Grant Thornton LLP, Washington, DC; Gilbert S. Rothenberg, Acting Deputy Assistant Attorney General, Tax Division, Department of Justice, Washington, DC; Honorable Richard Tallman, Judge, US Court of Appeals for the Ninth Circuit, San Francisco, CA.
  • TEFRA Penalty Issues. TEFRA penalties, where can they be challenged? A discussion over the ability of/requirement that taxpayers challenge accuracy-related penalties imposed on a TEFRA partnership during the partnership level proceeding. Moderator: James Hartford, Thompson Hine LLP, Washington, DC. Panelists: Henry Schneiderman, Special Counsel, Office of the Associate Chief Counsel (Procedure & Administration), IRS, Washington, DC; Todd Simmens, BDO Seidman, Metropark, NJ; Todd Welty, Sonnenschein Nath & Rosenthal LLP, Dallas, TX.
  • Ask a Commissioner. A wide-ranging conversation with former Commissioner Lawrence B. Gibbs. Moderator: James E. Merritt, Morrison & Foerster LLP, Washington, DC. Speaker: Lawrence B. Gibbs, Miller & Chevalier Chartered, Washington, DC.


Session : ABATX8173
Affiliated and Related Corporations
Conference : 2008 Joint Fall CLE Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • Chair: Devon M. Bodoh, Dewey & LeBoeuf 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: Jeff Vogel, KPMG LLP, Washington, DC. Panelists: Derek Cain, PricewaterhouseCoopers LLP, Washington, DC; Albert Gonzalez, Dewey & LeBoeuf LLP, New York, NY; Marie Milnes- Vasquez, Senior Technician Reviewer, Office of Chief Counsel (Corporate), IRS, Washington, DC; Mark Schneider, Deloitte Tax LLP, Washington, DC.
  • Loss Disallowance Rules. This panel will review developments relating to the consolidated return loss disallowance rules. Moderator: Andrew Dubroff, Ernst & Young LLP, Washington, DC. Panelists: Theresa Abell, Counsel to the Associate Chief Counsel, Office of 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; Michael Schler, Cravath Swaine & Moore LLP, New York, NY.


Session : ABATX8174
Banking and Savings Institutions
Conference : 2008 Joint Fall CLE Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • Chair: Michelle M. Henkel, Alston & Bird LLP, Atlanta, GA
  • Tax Issues Resulting from the Sub-Prime Lending Crisis. This panel will discuss the tax issues that have resulted from the sub-prime lending crisis, including (i) bad debts and non-accrual, are we back to charging off performing loans because their value has decreased? (ii) book-tax conformity, should banks adopt to protect against future second guessing? (iii) forgiveness of indebtedness, the effect of proposed legislation and administration proposals on 1099 reporting and (iv) section 475 valuations, how best to preserve records to substantiate write downs for future audits and support market value when there is no market. Moderator: Charles C. Wheeler, Alston & Bird LLP, Washington, DC. Panelists: Michael Costa, Deutsche Bank, New York, NY; Fran Mordi, American Bankers Association, Washington, DC; Michael Swiader, Deutsche Bank, New York, NY.
  • Update on LILO/SILO Litigation. The Committee will discuss the status of the leveraged leasing litigation and the impact on the financial institutions industry. Moderator: Philip C. Cook, Alston & Bird LLP, Atlanta, GA.
  • FIN-48 Workpapers: The Pursuit of Transparency Versus a Claim of Privilege. This panel will provide an overview of the attorney-client, federal tax practitioner and work product privileges and will discuss the Textron and Regions decisions, the IRS’ roundtable discussions regarding transparency and the pending investigation by the Permanent Subcommittee on Investigations. The panel will then focus on corporate practices with respect to FIN-48, the impact of these developments on privilege claims regarding FIN-48 workpapers and other tax-sensitive documents and the release of tax reserves. Moderator: Michelle M. Henkel, Alston & Bird LLP, Atlanta, GA. Panelists: Robert D. Adams, Senior Industry Advisor to the Commissioner, Large & Mid-Size Business, IRS, Washington, DC; Kenneth W. Busey, PricewaterhouseCoopers LLP, Washington, DC; Robin L. Greenhouse, McDermott Will & Emery LLP, Washington, DC.


Session : ABATX8175
Closely Held Businesses (TX), Business Planning Group (RPTE) & S Corporations (TX)
Conference : 2008 Joint Fall CLE Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • Closely Held Busineses Chair: William Prescott, Wickens Herzer Panza Cook & Batista Co, Avon, OH; S Corporations Chair: Thomas J. Nichols, Meissner Tierney Fisher & Nichols SC, Milwaukee, WI; Business Planning Group Chair: David M. Naples, Leonard Street & Deinard, Mankato, MN
  • Important Developments. Discussion of recent legislative, administrative and judicial developments relating to S corporations and their shareholders. Moderator: David H. Kirk, Arnold & Porter LLP, Washington, DC.
  • Using Trusts to Hold S Corporation Stock. This panel will discuss the types of trusts that may hold S corporation stock, the qualification of such trusts, the tax treatment of such trusts and the uses of such trusts in estate planning. Moderator: Laura Howell-Smith, Deloitte Tax LLP, Washington, DC. Panelist: Sydney Traum, Sydney Traum PA, Miami, FL.
  • Uses of ESOPs as S Corporation Shareholders. This panel will consist of a dialogue with a representative from the Department of Treasury and a private practitioner who specializes in ESOPs about the advantages and disadvantages of having an ESOP shareholder and using an ESOP to buy out individual shareholders looking for an exit strategy. The panel will also discuss using ESOPs in mergers and acquisitions and rules unique to ESOPs that own S corporation stock, including code section 409(p) and listed transactions. Moderator: William Klein, Gray Plant Mooty, Minneapolis, MN. Panelists: Susan Lenczewski, Gray Plant Mooty, Minneapolis, MN; Helen Morrison, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC.
  • S Corporations with Airplanes. This panel will discuss income tax and other considerations involved in owning planes through S corporations now that Sutherland Lumber-Southwest Inc v. Commissioner, 255 F. 3d 495 (2001), has been statutorily reversed. Moderator: John Truskowski, Locke Lord Bissell & Liddell LLP, Chicago, IL. Panelists: Marc Harper, Deloitte Tax LLP, Costa Mesa, CA; Mark Jacob, Locke Lord Bissell & Liddell LLP, Houston, TX.


Session : ABATX8176
Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (RPTE)
Conference : 2008 Joint Fall CLE Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • Estate & Gift Taxes Chair: Martin Hall, Ropes & Gray LLP, Boston, MA; Income & Transfer Tax Planning Group Chair: Edward M. Manigault, Jones Day, Atlanta, GA
  • Current Developments. This panel will review recent developments in federal gift, estate and generation-skipping transfer tax laws, with a special presentation on the new “exit tax” provisions in the HEART Act of 2008. Panelists: Leigh-Alexandra Basha, Holland & Knight LLP, McLean, VA; Stacey Delich-Gould, Sullivan & Cromwell LLP, New York, NY; Catherine V. Hughes, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC.
  • What Every Estate Planner Needs to Know About Hedge Funds. Individuals, corporations and non-profits are increasingly investing in hedge funds and need to understand the tax and other risks such investments may carry. This presentation discusses how hedge funds are structured, the myriad of income, partnership, international, estate & gift tax considerations, the interplay of the constructive sale & straddle rules and the taxation of financial derivatives, along with the specific investment risks that are inherent in hedge funds. Panelist: Paul S. Lee, Bernstein Global Wealth Management, New York, NY.
  • Community Property: Dabblers Beware! – Pitfalls from the Trenches. This panel will address pitfalls that can befall both community property and non-community property practitioners, such as the downside to transmuting community property to fund separate GRATs, how life insurance trusts should be handled, as well as suggestions to those lawyers in non-community property states who might “dabble” in community property matters (including, by accident, when clients buy a vacation home in a community property state), or have clients who move back and forth between community property and non-community property states. Panelists: Max Gutierrez, Jr., Morgan Lewis, San Francisco, CA; Philp Hayes, Bessemer Trust, San Francisco, CA.
  • Unanticipated Consequences and Fallout from Tax Planning Structures. Tax planners create a variety of charitable and non-charitable trusts, partnerships, limited liability companies and other entities, but what happens after they are implemented? The speakers will address some of the unanticipated consequences that surround “problematic assets”, such as ILITs, overfunded UTMA accounts, QPRTs, concentrated positions, UBIT and PFIC issues, partial liquidations and unproductive property. Speakers: Philip B. Feldman, Coblentz Patch Duffy & Bass LLP, San Francisco, CA; Amy E. Heller, Weil Gotshal & Manges, New York, NY; Susan Porter, Bank of America Private Wealth Management, New York, NY.


Session : ABATX8177
Investment Management (formerly the Investment Companies Committee)
Conference : 2008 Joint Fall CLE Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • Chair: Deanna Flores, KPMG LLP, San Diego, CA
  • Current Developments for Investment Companies. This panel will discuss current regulatory and legislative developments for investment companies. Moderator : Keith Lawson, Investment Company Institute, Washington, DC. Panelists: Ronald Cohn, Ernst & Young LLP, San Francisco, CA; John Harrell, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC.
  • Auction Rate Securities: Tax Issues for Closed-End Funds. This panel will discuss tax issues associated with various proposals to remedy the 2008 failure of the auction-rate securities marketplace, including various alternatives for closed-end investment companies with auction-rate preferred stock. Moderator: Joseph A. Riley, Willkie Farr & Gallagher LLP, New York, NY. Panelists: Joel D. Almquist, K&L Gates LLP, Boston, MA; Alfred C. Bishop, Jr., Branch Chief, Branch 6, Office of Associate Chief Counsel (Corporate), IRS, Washington, DC; John J. Cross III, Associate Tax Legislative Counsel, Office of Tax Policy, Department of Treasury, Washington, DC; Pamela F. Olson, Skadden Arps Slate Meagher & Flom, Washington, DC.
  • Domestic and International Tax Issues Facing Alternative Investment Funds. Topics to be addressed by this panel will include: (1) an update on tax trading safe harbors in various jurisdictions, including the US, UK, Hong Kong, Singapore and Japan; (2) current trends in setting up a fund manager from a federal, state and local and non-US perspective; and (3) an update on FIN 48 and section 6694 (preparer penalties). Moderator: Allison Rosier, PricewaterhouseCoopers LLP, New York, NY. Panelists: Puneet Arora, PricewaterhouseCoopers LLP, New York, NY; Steven R. Franklin, Gunderson Dettmer Stough Villeneuve Franklin & Hachigian LLP, Menlo Park, CA.


Session : ABATX8178
Real Estate
Conference : 2008 Joint Fall CLE Meeting
Speaker(s) :
Download Format(s) :
MP3
$30.00


  • Chair: Kevin J. Thomason, Thompson & Knight LLP, Dallas, TX
  • The Infamous Fractions Rule. This panel will take a deep dive into section 514(c)(9) with a special emphasis on the fractions rule. It will not only explore the basic workings of the fractions rule, it will also address thorny issues including the impact of staged closings, reserve accounts, clawbacks, forfeiture provisions, reverse promotes, opt-out provisions, recourse deductions and tiered partnerships on compliance with the fractions rule. Moderator: James B. Sowell, KPMG LLP, Washington, DC. Panelists: Sanford C. Presant, DLA Piper US LLP, Los Angeles, CA; L. Wayne Pressgrove, Jr., King & Spalding LLP, Atlanta, GA.
  • Hot Topics. This panel will focus on recent rulings, proposed and final regulations, case law and trends in the marketplace that impact real estate. Moderator: Peter J. Genz, King & Spalding LLP, Atlanta, GA. Panelists: Jon Finkelstein, McDermott Will & Emery LLP, Washington, DC; Eric Solomon, Assistant Secretary (Tax Policy), Department of Treasury, Washington, DC.
  • Free Money – Or Is It? The Taxation of Nonpartner Capital Contributions. This panel will address whether there is a common law exclusion from gross income for nonpartner capital contributions, the collateral consequences of such a contribution on inside and outside basis, IRS activity in this area and planning techniques with respect to nonpartner contributions of commonly used governmental incentives. Moderator: Eliot L. Kaplan, Squire Sanders & Dempsey LLP, Phoenix, AZ. Panelists: Beverly Katz, Special Counsel to the Associate Chief Counsel (PSI), IRS, Washington, DC; Louis S. Weller, Deloitte & Touche LLP, San Francisco, CA.
  • Select Section 1031 Issues. This panel will focus on a variety of issues related to section 1031 exchanges including the types of closing costs that may be paid by a QI without creating boot, whether and when a taxpayer may allocate line of credit debt to property transferred as part of an exchange, whether and when a transaction constitutes a single exchange, strategies to create multiple exchanges and current state activity regarding swap and drop exchanges. Moderator: Adam M. Handler, PricewaterhouseCoopers LLP, Los Angeles, CA. Panelists: Terence F. Cuff, Loeb & Loeb LLP, Los Angeles, CA; Todd D. Keator, Thompson & Knight LLP, Dallas, TX.
  • ecourse or Nonrecourse: A Simple Question. This panel will focus primarily upon the status of indebtedness as recourse or nonrecourse for purposes of section 1001 including recourse loans to limited liability companies that are classified as partnerships or are disregarded for federal income tax purposes and the consequences of this determination in the context of a workout. It will also address the status of indebtedness as recourse or nonrecourse for purposes of sections 465, 704 and 752. The panel will also address debt/equity classification issues arising in connection with current transactions in the marketplace. Moderator: Blake D. Rubin, McDermott Will & Emery LLP, Washington, DC. Panelists: Beverly Katz, Special Counsel to the Associate Chief Counsel (PSI), IRS, Washington, DC; Brian S. Masterson, Venable LLP, Washington, DC.


Session : ABATX8179
Exempt Organizations
Conference : 2008 Joint Fall CLE Meeting
Speaker(s) :
Download Format(s) :
MP3
$45.00


  • Chair: Michael A. Clark, Sidley Austin LLP, Chicago, IL
  • News from the IRS and Department of Treasury. Representatives from the TE/GE Division of IRS and from the Department of Treasury will speak on recent developments and pending guidance. Moderator: Suzanne Ross McDowell, Steptoe & Johnson LLP, Washington, DC. Panelists: Emily M. Lam, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Lois G. Lerner, Director, Exempt Organizations, IRS, Washington, DC; Catherine E. Livingston, Associate Chief Counsel, Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities), IRS, Washington, DC.
  • Form 990 Update. A panel discussion of the IRS form 990, the draft instructions thereto (if released) and implementation issues. Moderator: Boyd Black, Church of Jesus Christ of Latter-day Saints, Salt Lake City, UT. Panelists: Michael Bailey, Foley & Lardner LLP, Chicago, IL; Laura Gabrysch, Fulbright & Jaworski LLP, San Antonio, TX; Judith Kindell, Senior Technical Advisor to the Director, Exempt Organizations, IRS, Washington, DC; Beth Kingsley, Harmon Curran Spielberg & Eisenberg LLP, Washington, DC; Nancy Ortmeyer Kuhn, Caplin & Drysdale Chartered, Washington, DC; Gwen Spencer, PricewaterhouseCoopers LLP, Boston, MA.
  • Deferred Compensation and 409A Issues for Exempt Organizations. A panel discussion of the basics of executive-level benefits, including the 409A aspects of deferred compensation and 457(f) arrangement. Moderator: Celia Roady, Morgan Lewis, Washington, DC. Panelists: Ralph DeJong, McDermott Will & Emery LLP, Chicago, IL; William C. Schmidt, Senior Counsel, Executive Compensation, IRS, Washington, DC; Stephen B. Tackney, Senior Counsel, Executive Compensation, IRS, Washington, DC; William Bortz, Associate Benefits Tax Counsel, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC.



     


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