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2016 Joint Meeting

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(c) [2016] 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 11 - 20 of (39) TOTAL sessions
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Event : ABATX34


Session : ABATX16111
Partnerships & LLCs
Conference : 2016 Joint 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: Craig Gerson, PwC, Washington, DC; Ossie Borosh, Senior Counsel, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Clifford M. Warren, Special Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), IRS Office of Chief Counsel, Washington, DC
  • Recent Sea Changes Affecting Subchapter K: Sections 385 and Section 721(c). This panel will discuss the impact of recent guidance promulgated pursuant to sections 385 and 721(c) on partnership transactions. Moderator: Jon Finkelstein, KPMG LLP, Washington, DC; Panelists: Didi W. Borden, Deloitte Tax LLP, Washington, DC; Ari Berk, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Jason T. Smyczek, Senior Technical Reviewer, Branch 4, IRS Office of Associate Chief Counsel (International), Washington, DC
  • Qualifying Income of PTP’s: What’s In (And What’s Out). This panel will discuss the impact of anticipated guidance to be promulgated on the definition of “qualifying income” for purposes of the publicly traded partnership rules. Moderator: Barbara Spudis de Marigny, Orrick Herrington & Sutcliffe LLP, Houston, TX; Panelists: Robert A. Jacobson, Bracewell LLP, Houston, TX; Glenn E. Dance, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries), Office of Chief Counsel, IRS, Washington, DC
  • Section 743 Basis Adjustments. Acquirers of partnership interests typically either seek to obtain the tax benefit of a section 743(b) basis adjustment (when there is appreciated property) or are required to suffer the costs of a downward adjustment (when partnership property has depreciated). Often an acquirer is not equipped to accurately calculate the amount of its section 743(b) adjustment, particularly for partnerships with multiple properties or where there are tiered partnerships. This panel will discuss the mechanics of the section 743(b) adjustment, the allocation rules under section 755, and strategies for ensuring that a purchaser of a partnership interest obtains the desired section 743(b) result. Moderator: Stuart L. Rosow, Proskauer Rose LLP, New York, NY; Panelists: Brian J. Knudson, EY, Minneapolis, MN; Sarah I. Staudenraus, KPMG LLP, Washington, DC; Jose Carrasco, Grant Thornton LLP, Washington, DC


Session : ABATX16112
Exempt Organization
Conference : 2016 Joint Meeting
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$75.00


  • Committee Business.
  • News from the IRS and Treasury. Representatives from the IRS and Department of Treasury will discuss topics of current interest to exempt organizations practitioners. Moderator: Suzanne Ross McDowell, Steptoe & Johnson LLP, Washington, DC; Panelists: Janine Cook, Deputy Associate Chief Counsel, IRS Office of Associate Chief Counsel (TEGE), Washington, DC (Invited); Victoria A. Judson, Associate Chief Counsel, IRS Office of Associate Chief Counsel (TEGE), Washington, DC (Invited); Elinor C. Ramey, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited)
  • Corporate Integration and Exempt Organizations. This panel will discuss tax reform proposals affecting exempt organizations, focusing in particular on corporate integration and the shareholder credit proposal under consideration at the Senate Finance Committee, and, more generally, on the tax treatment of passive income earned by exempt organizations. Moderator: Alexander L. Reid, Morgan Lewis & Bockius LLP, Washington, DC; Panelists: Professor Daniel I. Halperin, Harvard Law School, Cambridge, MA; Edward Saad, Harvard Management Company, Cambridge, MA; Michael Udell, District Economics Group, Washington, DC
  • The PATH to Partnership. The Bipartisan Budget Act of 2015 and the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) made sweeping changes to the rules governing partnership audits, effectively replacing the TEFRA rules that have been in place since 1982 with a new centralized partnership audit regime that generally assesses and collects tax at the partnership level. The new rules apply to partnership tax years beginning after December 31, 2017, but partnerships can elect to have some of the new rules apply for tax years beginning after November 2, 2015. What do these rules mean for tax-exempt entities investing in partnerships, and how do tax-exempt entities protect themselves? The panel will show you the path through this new thicket. Moderator: James P. Joseph, Arnold & Porter LLP, Washington, DC; Panelists: Robert W. Friz, PwC, Philadelphia, PA; Kat Saunders Gregor, Ropes & Gray LLP, Boston, MA; Ofer Lion, Seyfarth Shaw LLP, Los Angeles, CA
  • Giving Business Interests to Charity. This panel will discuss various techniques for giving business interests to charity, including selecting the right kind of charitable donee and matching the appropriate technique to the nature of the business interest being given. Moderator: Turney P. Berry, Wyatt Tarrant & Combs LLP, Louisville, KY; Panelists: Martin Hall, Ropes & Gray LLP, Boston, MA; Neil T. Kawashima, McDermott Will & Emery, Chicago, IL Co-sponsored by: Charitable Planning and Organizations Group
  • Using Non-501(c)(3) Vehicles to Accomplish Philanthropic Objectives. The private foundation is the traditional vehicle used by philanthropists to make a significant financial commitment to charity and conduct charitable activities. Other 501(c)(3) options, such as supporting organizations and DAFs, have been explored to avoid some of the strict private foundation prohibitions. More recently, philanthropists and social entrepreneurs are experimenting with non-501(c)(3) vehicles for some of their philanthropic endeavors, including investment activity for social good. One idea gaining interest is to use a (for profit) limited liability company as the “parent” to conduct and support substantial philanthropic endeavors. In this panel, we look at some possible non-501(c)(3) vehicles to serve in this role, such as limited liability companies, hybrid corporations, and 501(c)(4)s. We analyze tax and other implications for donors and the vehicle itself of using these alternative vehicles, as opposed to a private foundation. Moderator: Ingrid Mittermaier, Adler & Colvin, San Francisco, CA; Panelists: Sharon Lincoln, Foley Hoag LLP, Boston, MA; Professor Dana Brakman Reiser, Brooklyn Law School, Brooklyn, NY; Co-sponsored by: Charitable Planning and Organizations Group


Session : ABATX16113
Teaching Taxation and State & Local Taxes
Conference : 2016 Joint Meeting
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  • When Is Something a “Tax”? To provide the basis for understanding how and why the fines and penalties imposed by municipal courts for misdemeanor violations might be reclassified as taxes, this first panel will explore the importance of classification of a payment as a “tax” (as opposed to a fee or some other payment to the government) in a variety of contexts. The panelists consider the importance of classification as a tax in the state and local context as well as the constitutional law and international tax contexts. Moderator/Panelist: Vanessa Caston Lafleur, Louisiana Department of Revenue, Baton Rouge, LA; Panelists: Professor Erin Scharff, Arizona State University Sandra Day O’Connor College of Law, Tempe, AZ; Glenn Newman, Greenberg Traurig LLP, New York, NY; Jasper L. Cummings Jr., Alston & Bird LLP, Raleigh, NC; Professor Adam H. Rosenzweig, Washington University School of Law, St. Louis, MO
  • Out of Ferguson: Misdemeanors, Municipal Courts, and Tax Distribution. This panel will report on original research into the operations of the municipal justice system in St. Louis County accomplished through a survey of defendants exiting various municipal courts as well as a study of data provided by the municipalities to the state. This research tentatively indicates that the municipal justice system is performing a revenue raising rather than a law enforcement function. Because the fines and fees imposed by the justice system correlate closely with municipal revenue needs, they resemble taxes rather than punishments. Some St. Louis County municipalities (and other municipalities nationwide) derive a substantial, regular, and predictable portion of their municipal budget from the fines, costs, and fees imposed by these municipal courts. Yet the laws “enforced” have been enacted under the police power and are arguably invalid because they were enacted under the wrong power exercise. In addition, the Hancock Amendment to the Missouri Constitution requires that new taxes and increases in taxes be approved by a vote of the people and the fines and fees have not been and are constitutionally infirm. Moderator: Professor Anthony C. Infanti, University of Pittsburgh School of Law, Pittsburgh, PA; Panelists: Professor Henry Ordower, Saint Louis University School of Law, St. Louis, MO; Kenneth Warren, Saint Louis University Department of Political Science, St. Louis, MO; Onésimo Sandoval, Saint Louis University Departments of Sociology and Anthropology, St. Louis, MO


Session : ABATX16115
Foreign Activities of US Taxpayers
Conference : 2016 Joint Meeting
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  • Managing Cash in an Ever Changing World. Recent proposals and changes in interpretation, including the proposed regulations under section 385, impact the ability to manage cash and create traps for the unwary. This panel will address the changing environment impacting cash management, including debt-equity, foreign currency and hedging issues. Moderator: Kathleen Ferrell, Davis Polk, Washington, DC; Panelists: Michael Mou, Deloitte Tax, Washington, DC; Moshe Spinowitz, Skadden Arps, Boston, MA; Raymond Stahl, Special Counsel, IRS Office of Associate Chief Counsel (International), Washington, DC; Brian Jenn, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC


Session : ABATX16114
Tax Policy & Simplification
Conference : 2016 Joint Meeting
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  • Tax Incentives for Technological Innovation. Promoting innovation as a tool for economic growth is now a major focus of US and global policymakers. Several foreign countries have adopted “innovation box” or “patent box” regimes where income from the exploitation of local technology enjoys a reduced or zero rate of tax. Domestically, the R&D tax credit has recently been made permanent and a debate continues in Congress whether to expand the R&D credit or replace it altogether. Our panel of academic and legislative experts will present existing and proposed innovation incentives including credits and expensing for research and experimentation as well as “patent box” approaches. Moderator: Roger Royse, Royse Law Firm, Palo Alto, CA; Panelists: Viva Hammer, Legislation Counsel, Joint Committee on Taxation, Washington, DC; Professor Daniel Hemel, University of Chicago Law School, Chicago, IL; Professor Lily Kahng, Seattle University School of Law, Seattle, WA; Karl Russo, Economist, Joint Committee on Taxation, Washington, DC; Stephen Shay, Harvard Law School, Cambridge, MA; Co-sponsored by: American Tax Policy Institute
  • Integration of Corporate and Shareholder Income Taxes. Possible integration of corporate and shareholder income taxes raises both simplification and more general tax policy issues. Experts will explore these issues with particular attention to current legislative proposals. Moderator: Professor Michael Lang, Chapman University Fowler School of Law, Orange, CA; Panelists: Tony Coughlan, Tax Counsel, Senate Finance Committee, Washington, DC; Pamela Olson, PwC, Washington, DC; Professor James Poterba, MIT, Cambridge, MA; Co-sponsored by: Corporate Tax


Session : ABATX16116
Diversity Part 1
Conference : 2016 Joint Meeting
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  • On the Road to Success: What You Don’t Learn in Law School. A panel of junior and mid-level attorneys will provide their perspective on finding their first legal position after law school, learning the ropes in that position, and excelling in their first legal job and beyond. The panelists will discuss their experiences in positions in large and mid-size law firms, government, accounting firms, clerkships, and low-income taxpayer clinics.
  • Moderator: Cathy Fung, Office of Chief Counsel (Large Business & International), IRS, Washington, DC
  • Panelists: Lacy L. Durham, Deloitte Tax LLP, Dallas, TX; Dianna M. Mullis, Steptoe & Johnson, Washington, DC; Shawn McIntire, Ballard Spahr LLP, Denver, CO; Derek Wagner, Pro Bono Staff Counsel, ABA Section of Taxation, Washington, DC


Session : ABATX16117
Court Procedure & Practice Roundtable Discussion
Conference : 2016 Joint Meeting
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  • “PATH” Through Privileges. In the Protecting Americans from Tax Hikes (PATH) Act of 2015, Congress changed the applicable rules of evidence in the Tax Court from those applicable in trials without a jury in DC district court to the Federal Rules of Evidence. While seemingly innocuous, when considered together with the Golsen rule, this change may have a great impact on privileges, protections, and the scope of waivers in the Tax Court. This panel will discuss the practical impacts of this change in the law, as well as provide a multi-circuit survey. The panel will also discuss the Tax Court’s recent use of the “quick peek” procedure under the rules of civil procedure and its potential impact on assertions of privilege.
  • Moderator: Elizabeth Blickley, Chicago, IL
  • Panelists: The Honorable James Halpern, US Tax Court, Washington, DC; Daniel Rosen, Baker & McKenzie LLP, New York, NY; John Altman, Deputy Area Counsel, IRS Office of Chief Counsel, Washington, DC; Professor Joni Larson, Indiana Tech Law School, Fort Wayne, IN


Session : ABATX16119
State & Local Taxes Part 1
Conference : 2016 Joint Meeting
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  • Confronting the Post-Quill World. State governments chafe under the Supreme Court’s 1992 Quill decision claiming that the “physical presence” nexus doctrine is ill-suited to electronic commerce and results in billions of dollars of lost sales tax revenue. Direct marketers, on the other hand, argue that Quill reflects core Commerce Clause principles assuring access to a single national marketplace and protecting small and emerging companies from the burdens of having to comply with over 10,000 sales tax jurisdictions. Several states have enacted “economic presence” nexus statutes in direct contravention of Quill in the hope of obtaining Supreme Court review, and there are competing proposals in Congress to address the remote seller tax collection issue. Our speaker, George Isaacson, has litigated Commerce Clause and Tax Injunction Act cases in state and federal courts throughout the country, including before the US Supreme Court, and he is currently counsel in several lawsuits challenging anti-Quill state laws. He has also been closely involved in drafting and commenting upon federal legislative proposals dealing with this issue.
  • Moderator: John A. Biek, Neal Gerber & Eisenberg LLP, Chicago, IL
  • Speaker: George Isaacson, Brann & Isaacson, Lewiston, ME


Session : ABATX16120
FAUST, Foreign Lawyers Forum, Transfer Pricing, and US Activities of Foreigners and Tax Treaties
Conference : 2016 Joint Meeting
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  • Joint Current International Developments Panel. This panel will discuss the latest international tax developments.
  • Panelists: Daniel McCall, Deputy Associate Chief Counsel International (Technical), IRS Office of Associate Chief Counsel (International), Washington, DC; Douglas Poms, Deputy International Tax Counsel, Department of Treasury, Washington, DC; Brian Jenn, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC; Additional Panelists TBD


Session : ABATX16121
Estate & Gift Taxes and FITYL Subcommittee (TX) and Income & Transfer Tax Planning Group (TE)
Conference : 2016 Joint Meeting
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  • New Hampshire Trusts: Why the Granite State Rocks at Trust Administration. This panel will review how New Hampshire has modernized its trust laws to add efficiency and flexibility that attracts domestic and foreign wealth. The panel will also compare the trust laws of other states, including Delaware, with regard to flexibility in trust administration, the availability of asset protection trusts and dynasty trusts, trustee protections, and state income taxation.
  • Panelists: Steve Burke, McLane Middleton, Manchester, NH; Constance Shields, Withers Bergman LLP, New York, NY; Thanda Fields Brassard, Fiduciary Trust Company of New England, Manchester, NH



     


Showing sessions 11 - 20 of (39) TOTAL sessions
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