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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 21 - 30 of (39) TOTAL sessions
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Event : ABATX34


Session : ABATX16122
Standards of Tax Practice
Conference : 2016 Joint Meeting
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  • Ethical Obligations in Representing Deceased, Incompetent and Unavailable Clients. Communicating with even the most sophisticated clients can present challenges for practitioners, particularly when the representation involves complex aspects of tax law. Those challenges grow exponentially when a client passes away or otherwise becomes incapacitated or unavailable, especially when a filing deadline or a trial date is looming. This panel will consider some of the unique ethical issues that arise when dealing with deceased or unavailable clients, including application of the client communication provisions in Rule 1.4 of the ABA Model Rules of Professional Conduct and related privilege considerations. Moderator: Joshua Lowenthal, Washington University, St. Louis, MO; Panelists: The Honorable L. Paige Marvel, Chief Judge, US Tax Court, Washington, DC; Christine R.W. Quigley, Schiff Hardin, Chicago, IL; Rachel L. Partain, Caplin & Drysdale Chartered, New York, NY; Co-sponsored by: Real Property, Trust and Estate Law Section, Trust and Estate Law Division
  • Ethical Considerations in IRS Settlement Negotiations. ABA Model Rule 4.1 imposes an obligation on lawyers to be truthful in making statements to others. Section 10.51 of Circular 230 similarly provides for the imposition of sanctions against practitioners who provide false or misleading information to the IRS. These rules can have interesting and sometimes counter-intuitive application in the context of settlement negotiations, where some posturing is permitted and indeed may be required in order to competently represent a client. This panel will consider the scope of these rules and their application in tax cases. Moderator: Giovanni Alberotanza, Rosenberg Martin Greenberg LLP, Baltimore, MD; Panelists: Sheldon Kay, Crowe Horwath LLP, Atlanta, GA; Sara G. Neill, Capes Sokol, St. Louis, MO
  • Ethical Issues in Federal Tax Practice – The Government Perspective. This panel will provide an update on recent guidance from the IRS and the Department of Treasury, discuss issues of concern and areas of focus for the IRS Office of Professional Responsibility and Office of Chief Counsel, and give an update on pending cases that relate to tax practice standards. The panel will also expand the discussion to include recent standards-related developments affecting tax practitioners more generally, including an update on state bar and board of accountancy developments and an update on state efforts to regulate paid return preparers and other non-credentialed tax professionals. Moderator: Matthew S. Cooper, EY, Washington, DC; Panelists: Stephen Whitlock, Director, IRS Office of Professional Responsibility, Washington, DC; Drita Tonuzi, Associate Chief Counsel (Procedure & Administration), IRS Office of Chief Counsel, Washington, DC


Session : ABATX16124
Employee Benefits (TX) and Welfare Plans Committee (TE)
Conference : 2016 Joint Meeting
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  • The Proposed 457(f) and 409A Regulations - What You Need to Know. This panel will discuss the recently proposed regulations under section 457(f) and 409A and the potential impact of this guidance on deferred compensation plans and arrangements. Moderator: Martha N. Steinman, Hogan Lovells US LLP, New York, NY; Panelists: Robert Neis, Benefits Tax Counsel, Department of Treasury, Washington, DC (Invited); Susan Daley, Perkins Coie, Chicago, IL; Elizabeth Drigotas, Deloitte Tax LLP; Kurt Lawson, Hogan Lovells US LLP, Washington, DC
  • Plan Governance. This panel will consider the impact of the current litigation and regulator landscape on considerations in plan governance. The discussion will emphasize three areas of governance: plan operation and governance generally, service provider oversight, and plan investments. Moderator: David Cohen, Evercore Trust Company, Washington, DC; Panelists: James O. Fleckner, Goodwin Procter LLP, Boston, MA; Sam Henson, Locton Retirement Services, Kansas City, MO; Allison Wilkerson, McDermott Will & Emery, Dallas, TX
  • Hot Topics: Department of Treasury / Internal Revenue Service. Representatives from the Department of Treasury and IRS will review recent guidance from, and current developments at, their agencies that impact employee benefits. Moderator: Susan Wetzel, Haynes Boone, Dallas, TX; Panelists: J. Mark Iwry, Senior Advisor to the Secretary and Deputy Assistant Secretary for Retirement and Health Policy, Department of Treasury, Washington, DC (Invited); Robert Neis, Benefits Tax Counsel, Department of Treasury, Washington, DC (Invited); Seth Tievsky, Senior Technical Advisor, TE/GE, IRS, Washington, DC (Invited); Victoria Judson, Associate Chief Counsel, Office of Associate Chief Counsel (TEGE), IRS, Washington, DC (Invited); Stephen Tackney, Deputy Associate Chief Counsel (Employee Benefits), Office of Associate Chief Counsel (TEGE), IRS, Washington, DC (Invited)


Session : ABATX16125
State & Local Taxes Part 2
Conference : 2016 Joint Meeting
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  • Remote Use Tax Collection in a Post-Quill World. As states continue to expand their respective laws to require remote use tax collection without physical presence in order to elicit a judicial challenge to the Quill physical presence standard, remote sellers are being forced to consider nationwide collection obligations, and the web of conflicting and unclear laws that apply to such responsibilities. Panelists will outline the various types of provisions being enacted around the country requiring remote use tax collection as well as current and expected litigation resulting from these provisions. In addition, the panelists will discuss the possibility and types of federal legislation that have been proposed, the likelihood of US Supreme Court action and options available to remote sellers under the various scenarios. Moderator: Janette Lohman, Thompson Coburn LLP, St. Louis, MO; Panelists: Eric Yauch, TaxAnalysts, Alexandria, VA; Matthew Hedstrom, Alston & Bird, Washington, DC; Joe W. Garrett Jr., Alabama Department of Revenue, Montgomery, AL
  • No Winners Here: Tax Administration in an Anti-Tax Environment. This panel will discuss ethical and policy issues for taxpayers and tax administrators in a self-assessment, and often adversarial, tax system. What are the ground rules for appropriate tax planning? Can a taxpayer engage in a transaction in which the substance does not match the form? What are appropriate governmental responses? What department of revenue strategies are perceived by taxpayers to be overly aggressive? When, if ever, should DORs seek retroactive legislation? Moderator: Michelle DeLappe, Garvey Schubert Barer LLP, Seattle, WA; Panelists: Peter L. Faber, McDermott Will & Emery LLP, New York, NY; Professor Walter Hellerstein, University of Georgia Law School, Athens, GA; Kimberly L. Robinson, Secretary of Revenue, Louisiana Department of Revenue, Baton Rouge, LA
  • Potential State Tax Implications of Proposed IRC 385 Debt/Equity Regulations. In April, the Department of Treasury proposed comprehensive regulations under section 385 of the Internal Revenue Code. Although Treasury indicated that the regulations were issued in the context of addressing corporate inversions, if adopted in their present form, the regulations would apply well beyond corporate inversions, to a broad range of related-party transactions. The proposed regulations would authorize the IRS to treat certain related-party interests that would otherwise be treated as indebtedness as stock for federal tax purposes (or as part stock and part debt) and establish extensive documentation requirements for intra-group indebtedness. This panel provides an overview of the proposed regulations and discusses potential state and local tax implications. Questions to be addressed include: What are the general implications for the states? How would the rules apply in the context of a group of taxpayers that file a federal consolidated return (and therefore may not be subject to the federal rules) but file separate state tax returns? Moderator: Debra Herman, Hodgson Russ LLP, New York, NY; Panelists: John P. Barrie, Bryan Cave LLP, New York, NY; Michael T. Fatale, Deputy General Counsel, Massachusetts Department of Revenue, Boston, MA; Richard L. Jones, Sullivan & Worcester LLP, Boston, MA


Session : ABATX16126
Transfer Pricing
Conference : 2016 Joint Meeting
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  • OECD Country-by-Country Data Submissions: A Potential for Misapplication of Big Data? The new country-by-country (CbC) reporting obligations on large multinational corporations (MNCs) seek to improve transparency to taxing authorities worldwide and to provide them with a new transfer pricing risk assessment tool. However, they also raise challenging implementation issues for MNCs, such as integration of tax reporting into financial and management reporting systems, and increased standardization of financial reporting across jurisdictions and MNCs. The CbC reporting of profits, inter-company debt, employee head counts, and assets by jurisdiction could also result in a risk assessment being based primarily on a formulaic approach to income allocation. This panel, featuring academic and economic consulting experts, will discuss the accounting, economics, and finance frameworks under which the “Big Data” generated from CbC reporting can be used reliably as a preliminary risk assessment tool, and illustrate the potential pitfalls of a mechanical or purely statistical interpretation of the data. Moderator: Bin Zhou, The Brattle Group, Cambridge, MA; Panelists: Russ O’Haver, Northeastern University, Boston, MA; Professor Shannon W. Anderson, UC Davis, Davis, CA (visiting Prof. Harvard Business School); Michael Cragg, The Brattle Group, Cambridge, MA; Professor Dirk Hackbarth, Boston University Questrom School of Business, Boston, MA
  • The Work of Competent Authority Today: Perspectives from Canada and the US. A review and discussion with representatives from the Canadian and US Competent Authorities on a broad range of issues confronting CAs and the Mutual Agreement Process in the post-BEPS world, including: rising caseloads; BEPS implementation; individual country practices vs. multilateralism; MAP Forum and more. Moderators: Tracy Gomes, McDermott Will & Emery, Dallas, TX; Thomas Akin, McCarthy Tetrault, Toronto, ON; Panelists: John C. C. Hughes, Acting Director, APMA, IRS, Washington, DC; Paul Mulvihill, EY, Ottawa, ON


Session : ABATX16127
Closely Held Businesses (TX) and Business Planning Group (TE)
Conference : 2016 Joint Meeting
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  • A Primer on Key Tax Elections to Plan for When Estate Planning with Closely Held Business Interests. A practical overview of key time sensitive elections that are often overlooked in the estate planning for closely held businesses. While many of tax elections are made post death, planning for them should be considered in the estate planning phase. The panel will provide a survey of the following elections, and if time permits, will include a case study to illustrate practical application of such elections: portability election; marital deduction elections (QTIP, QDOT); GST allocation, reverse QTIP election; S Corporation elections (QSST/ESBT); Partnership bases elections (754 and 732 (d)); Alternate Valuation Date election (2032); Special Use Valuation election (2032A); Estate tax payment deferral election (6166); estate tax return v. inclome tax return deduction election (642(g)); and Fiduciary income tax elections (645 and 663(b)). Moderator: Shelby L. Wilson, Berchem Moses & Devlin PC, Westport, CT; Panelists: Raj Malviya, Miller Johnson, Grand Rapids, MI; Toni Ann Kruse, McDermott Will & Emery, New York, NY; Michael H. Barker, McGuireWoods LLP, Richmond, VA; Jeremy Mertens, BDO USA LLP, Grand Rapids, MI
  • Asset Transfers and Tax Liens: The IRS Monkey-Wrench in Probate and Business Succession Planning. It can be very difficult for closely held business clients to get their succession plan in place and have it work under the best of circumstances. When back tax issues arise it can create headaches, or worse, cause the whole plan to go south. This panel will review issues that arise frequently when tax debts exist when client’s pass away and it comes time to transfer assets, including the timing of the transfers and the issue of the tax lien arising, and its impact on both probate and non-probate assets. Panelists: Eric L. Green, Green & Sklarz LLC, New Haven, CT; Frank Agostino, Agostino & Associates, Hackensack, NJ; Frederick W. Schindler, IRS Office of Chief Counsel, Washington, DC


Session : ABATX16128
Court Procedure & Practice
Conference : 2016 Joint Meeting
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  • Current Developments. This panel will include a report from the Tax Court, significant IRS guidance and litigation, an update on Tax Division priorities, a report from Treasury, and significant pending litigation. Moderator: Bryan Koorstad, Baker & McKenzie LLP, Chicago, IL; Panelists: The Honorable L. Paige Marvel, US Tax Court, Washington, DC; Rochelle Hodes, Associate Tax Legislative Counsel, Office of Tax Policy, Department of Treasury, Washington, DC; Drita Tonuzi, Associate Chief Counsel (Procedure & Administration), IRS Office of Chief Counsel, Washington, DC; Diana Erbsen, Deputy Assistant Attorney General for Appellate and Review, Department of Justice, Tax Division, Washington, DC
  • Honoring Judge Howard A. Dawson, Jr., US Tax Court. The Honorable Juan F. Vasquez, US Tax Court, will provide a tribute to Judge Dawson, a long-time supporter and good friend of the committee.
  • Litigating the Characterization of a Debt Instrument Under Current Case Law and the Proposed 385 Regulations. Intra-group borrowing is very common in multinational, mid-market, and closely-held companies and in inbound investment arrangements. Debt-equity characterization is an issue easily identified during an examination and often challenged. The recharacterization of a debt instrument can have very sizeable income and withholding tax consequences and can impact non-tax areas such as bankruptcy. This panel will discuss issues that commonly arise when litigating the characterization of a debt instrument under current case law, and will discuss how the final adoption of regulations issued in proposed form under section 385 would impact these cases. Moderator: Rachel L. Partain, Caplin & Drysdale Chartered, New York, NY; Panelists: Thomas J. Kane, Division Counsel, Office of Division Counsel (LB&I), IRS, Washington, DC; Joshua D. Odintz, Baker & McKenzie LLP, Washington, DC
  • It’s a Small World After All: Evidence in Offshore Noncompliance Cases (Part I). The panel will discuss government’s ability to use stolen or improperly obtained foreign records, such as Panama Papers, in administrative or court proceedings. Moderators: Zhanna A. Ziering, Caplin & Drysdale Chartered, New York, NY; Panelists: The Honorable Marvin J. Garbis, Senior Judge, US District Court for the District of Maryland, Baltimore, MD; Edward M. Robbins Jr., Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA; Richard J. Sapinski, Sills Cummis & Gross PC, Newark, NJ
  • Large Case Litigation in the US Tax Court – Discovery and Depositions. In most federal jurisdictions, depositions are an ordinary method of discovery governed by the Federal Rules of Evidence. In the Tax Court, however, depositions traditionally have been an extraordinary method of discovery and authorized by the court only when the information sought has not been or cannot be obtained otherwise. Tax Court Rule 74(c). Nonetheless, deposition requests are becoming more commonplace, particularly in large case litigation. IRS Chief Counsel has even requested that the Tax Court amend its rules to allow depositions. This panel will review discovery and deposition issues and strategies in large case litigation before the Tax Court, including issues relevant to transfer pricing litigation and other common large cases. Moderators: Juan F. Vazquez Jr., Chamberlain Hrdlicka White Williams & Aughtry, Houston, TX; Panelists: The Honorable L. Paige Marvel, US Tax Court, Washington, DC; Jenny Austin, Baker & McKenzie LLP, Chicago, IL; Thomas J. Kane, Division Counsel, Office of Division Counsel (LB&I), IRS, Washington, DC


Session : ABATX16129
Financial Transactions
Conference : 2016 Joint Meeting
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  • Speaking Truth to Power: The Finance Committee Reports on the Modernization of Derivatives Act. This panel will summarize Senator Ron Wyden’s proposed legislation, which would generally require the mark-tomarket of derivatives for tax purposes, as well as the current state of the Finance Committee’s report on that legislation. Moderator: Matthew Stevens, EY, Washington, DC; Panelists: Viva Hammer, Legislation Counsel, Joint Committee on Taxation, Washington, DC; John Kaufmann, Greenberg Traurig, New York, NY; Christopher DiJulia, Fidelity Investments, Boston, MA
  • Section 871(m) Update and the New QI – QDD Notice. The panel will explore the current state of the regulations, the varying degrees of readiness, as well as the potential for technology solutions for section 871(m). The panel will also discuss Notice 2016-42, with a special focus on the requirements of becoming a QDD and sunsetting of the QSL regime. Moderator: Michael Gaffney, PwC, New York, NY; Panelists: Tara Ferris, EY, New York, NY; Cyrus Daftary, Markit CTI Tax Solutions, Boston MA; Robert Foley, State Street, Boston, MA
  • Section 385, the Financial Industry and the Proposed (Final?) Regulations. This panel will explore the current state of the proposed (or final) intercompany debt regulations under section 385, focusing on the issues they present for and their potential impact on the financial industry and what financial firms are doing to get ready. The panel will also discuss developments relating to the developing capital rules that apply to financial firms, including banks and bank holding companies, and the challenges they create from a tax standpoint, both under the section 385 regulations and under general debt v. equity tax law principles. Moderator: Michael Mollerus, Davis Polk & Wardwell LLP, New York, NY; Panelists: Erika W. Nijenhuis, Cleary Gottlieb Steen & Hamilton LLP, New York, NY; Doug Bailey, Bank of America, Charlotte, NC


Session : ABATX16130
Insurance Companies
Conference : 2016 Joint Meeting
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  • Section 385 Regulations. The panel will discuss the proposed (or final, if issued) section 385 regulations. The panel will focus on issues specific to insurance companies arising out of those regulations. Moderator: William R. Pauls, Sutherland Asbill & Brennan LLP, Washington, DC; Panelists: Norman Hannawa, EY, Washington, DC; Eric Miller, AIG, London, England; Surjya Mitra, PwC, Washington, DC
  • The Secret Life of Captives. The panel will discuss various issues that arise in the formation or in the operation of a captive which may catch captive managers and owners unawares. The panel will address federal, state, and international tax issues. Moderator: Saren Goldner, Sutherland Asbill & Brennan LLP, New York, NY; Panelists: Paul Phillips, EY, Dallas, TX; Tom Cyr, KPMG LLP, Boston, MA
  • Emerging Issues in Insurance Dedicated Funds. The panel will discuss the tax implications of new market entrants and insurance dedicated fund offerings, including private placement products and IDFs offered by asset managers. The panel will focus on diversification and investor control but will also discuss additional issues that arise in specific situations. Moderator: Ann Cammack, EY, Washington, DC; Panelists: Susan Seabrook, Buchanan Ingersoll Rooney PC, Washington, DC; Mark Rush, MassMutual, Springfield, MA


Session : ABATX16131
Real Estate
Conference : 2016 Joint Meeting
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  • The Section 385 Regulations: Partnerships, REITs and S Corps. These proposed regulations have been among the most far reaching and controversial in memory and may be finalized before the meeting. This panel will discuss the proposed (or final) regulations focusing on real estate structures and how they change the leverage game. Moderator: Robert J. Crnkovich, EY, Washington, DC; Panelists: Ari Berk, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Craig A. Gerson, PwC, Washington, DC
  • PATH Act – Section 897. This panel will discuss the changes to FIRPTA made in the PATH Act, including recent regulations. FIRPTA has been changed in useful and interesting ways, including the exemption for qualified foreign pension trusts. Moderator: Peter J. Genz, King & Spalding LLP, Atlanta, GA; Panelist: Sarah E. Ralph, Skadden Arps Slate Meagher & Flom LLP, Chicago, IL
  • Current Events Affecting Real Estate Transactions. Important guidance items relating to partnerships and real estate have been, or hopefully will be, released by the time of the meeting. Items relating to debt allocations, disguised sales, REITs, section 1031 exchanges, and COD income/qualified real property business indebtedness are at the top of the list. Guidance on fee waivers and the fractions rule may be soon to come. Moderator: James B. Sowell, KPMG, Washington, DC; Panelists: 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, Washington, DC


Session : ABATX16133
Tax Accounting
Conference : 2016 Joint Meeting
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  • Current Developments. This panel will review recent developments in the area of tax accounting since the Section of Taxation meeting held in Washington, DC, in May. The panel will also discuss ongoing projects and anticipated guidance, with commentary and input from our guests from the Internal Revenue Service. Moderator: Jeff Malo, Andersen Tax LLC, New York, NY; Panelists: Wendy Friese, Deloitte Tax, Washington, DC; Karen Messner, KPMG LLP, Washington, DC; Scott Dinwiddie, Associate Chief Counsel, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; John Moriarty, Deputy Associate Chief Counsel, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC
  • Inventory Accounting Update. This panel will address the treatment of certain inventory issues encountered in practice. The discussion will include selected topics that may be addressed in items listed in the Priority Guidance Plan. Moderator: Les Schneider, Ivins Phillips & Barker, Washington, DC; Panelists: Kristine Mora, EY, Washington, DC; Scott Dinwiddie, Associate Chief Counsel, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Karla Meola, Special Counsel, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC
  • Handling Method Changes in Appeals. This panel will discuss issues that may arise related to method changes in settling issues at Appeals. The discussion will include the use of closing agreements and rules surrounding involuntary method changes. Moderator: Ellen McElroy, Sutherland Asbill & Brennan LLP, Washington, DC; Panelists: Carol Conjura, KPMG LLP, Washington, DC; Shelly Kay, Crowe Horwath LLP, Washington, DC; John Moriarty, Deputy Associate Chief Counsel, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Brinton Warren, Special Counsel, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Michael McLane, Domestic Operations Technical Guidance Specialist, IRS, Boston, MA
  • Issues Involving Advance Payments. This panel will discuss selected issues related to accounting for advance payments. The topics will include the treatment of advance payments highlighted in recent court cases and IRS guidance and will also cover issues that may be addressed in future guidance. Moderator: Jane Rohrs, Deloitte Tax LLP, Washington, DC; Panelists: Annette Ahlers, Pepper Hamilton LLP, Irvine, CA; John Moriarty, Deputy Associate Chief Counsel, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC; Thomas Moffitt, Chief, Branch 2, Income Tax & Accounting, Office of Associate Chief Counsel, IRS, Washington, DC



     


Showing sessions 21 - 30 of (39) TOTAL sessions
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