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2012 Joint Fall CLE Meeting

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(c) [2012] American Bar Association.
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Showing sessions 1 - 10 of (40) TOTAL sessions
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Event : ABATX22

Session : ABATX12111
Capital Recovery & Leasing
Conference : 2012 Joint Fall CLE Meeting
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Chair: Glenn Johnson, Ernst & Young LLP, Washington, DC

Current Developments Report and Update on Pending Guidance. This program will cover the important recent developments in the areas of capital recovery and leasing. Moderator: Sam Weiler, Ernst & Young LLP, Washington, DC; Panelists: Scott Mackay, Taxation Specialist, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Kathleen Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Natalie Tucker, McGladrey LLP, Washington, DC

Issues and Considerations Involving Tenant Improvement Allowances. This panel will discuss tenant improvement allowances and associated issues and considerations, including, but not limited to, ownership of the associated improvements, the Section 110 safe harbor, and related income/ expense/basis recovery issues. Moderator: Glenn Johnson, Ernst & Young LLP, Washington, DC; Panelists: Kathleen Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Natalie Tucker, McGladrey LLP, Washington, DC

Tangible Property Regulations Ongoing Implementation Issues. This panel will discuss ongoing issues associated with the implementation of the new tangible property regulations. Moderator: Alison Jones, Ernst & Young LLP, Washington, DC; Panelists: Kathleen Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Scott Dinwiddie, Special Counsel, Associate Chief Counsel, Income Tax & Accounting, IRS, Washington, DC; Scott Mackey, Taxation Specialist, Office of Tax Policy, Department of Treasury, Washington, DC

Session : ABATX12112
Administrative Practice
Conference : 2012 Joint Fall CLE Meeting
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Chair: Sheri A. Dillon, Bingham McCutchen LLP, Washington, DC

Important Developments. This panel will discuss important developments in administrative practice that have occurred since the last meeting. Moderator: Bryon Christensen, Skadden Arps Slate Meagher & Flom LLP, Washington, DC; Panelist: Alexandra Minkovich, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC

The IRS in 2012: The State of the Union. Over the last year and a half the IRS has undertaken significant changes intended to assist the various functions in becoming more effective, efficient and consistent in their ongoing operations. To accomplish this goal, the IRS rolled out a multi-year plan to better focus resources and expand taxpayer coverage, announcing last year the rebranding of LMSB and realignment of its international functions. As a second part to this plan, LB&I Commissioner Heather Maloy announced a realignment of domestic operations to take effect on October 1, 2012. The IRS has not limited it plan to LB&I, and announced changes in other functions of the IRS, including updating the existing rules on permissible communications with the Office of Appeals and the movement of certain specialists from LB&I into SB/SE. How have these changes impacted the way the IRS functions? What can taxpayers expect out of these changes? What additional future changes will be coming? This panel will explore both the recent and anticipated changes occurring within the IRS from an LB&I, SB/SE and Appeals perspective. The panel will discuss what the tax community should expect from these changes, how these changes will impact the way taxpayers interact with the IRS, as well as how the various functions of the IRS interact with each other. Moderator: Michael Desmond, Law Offices of Michael J. Desmond, Washington, DC; Panelists: Kevin Brown, PricewaterhouseCoopers LLP, Washington, DC; Paul DeNard, Deputy Commissioner, Operations, LB&I, IRS, Washington, DC; Sheldon Kay, Deputy Chief, Appeals, IRS, Washington, DC; Laura Prendergast, Industry Director, Heavy Manufacturing and Transportation, LB&I, IRS, Iselin, NJ; Christopher Wagner, Chief, Appeals, IRS, Washington, DC; Ruth Perez, Deputy Commissioner, SB/SE, IRS, Washington, DC

Transferee Liability. Transferee liability is an important enforcement tool for the IRS, especially in the recent Midco transactions. However, the Tax Court has almost exclusively held for taxpayers, finding in part that the federal common law principles, such as substance over form, cannot recast the transaction in a manner favorable to the governments collection efforts. Many of those cases are in the process of being appealed. The Fourth Circuit in Starnes v. Commissioner, No. 11-1636 (4th Cir. May 31, 2012) recently issued the first opinion on these issues, upholding the Tax Court. This panel will discuss the arguments made by the government and the taxpayers with a view of what might be in store in other similar Midco cases on appeals as well as what these cases mean for the evolution of the transfer liability in general. Moderator: George Hani, Miller & Chevalier Chartered, Washington, DC Panelists: Tamara Ashford, Deputy Assistant Attorney General for Appellate; and Review, Tax Division, Department of Justice, Washington, DC; Robert Probasco, Thompson & Knight LLP, Dallas, TX

Through the Looking Glass (Part I): Opting Out of the OVDI Penalty StructureWhat Happens Now? This panel will discuss matters relating to opting out of the Offshore Voluntary Disclosure Initiative, including opt-out mechanics and procedures, and issues relating to examination, negotiation and settlement expectations arising in various opt-out scenarios. This panel is Part I of a program in conjunction with the Court Procedure Committee, which in Part Two will continue the discussion of the opt-out process with emphasis on FBAR penalty assessments and litigation. Moderator: Richard J. Sapinski, Sills Cummis & Gross PC, Newark, NJ; Panelists: Caroline D. Ciraolo, Rosenberg Martin Greenberg LLP, Baltimore, MD; David A. Breen, Senior Counsel, Office of Chief Counsel, SB/SE, IRS, Philadelphia, PA; Megan L. Brackney, Kostelanetz & Fink LLP, New York, NY

Session : ABATX12113
Affiliated & Related Corporations
Conference : 2012 Joint Fall CLE Meeting
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Chair: Brian A. Peabody, Ernst & Young LLP, Washington, DC

A Primer on Consolidated Return Basics: Membership and Group Continuance. A discussion and overview covering eligibility for consolidated group membership and the impact of transactions on the continuation of an existing consolidated group, including consideration of partnership incorporations and domestications of foreign corporations. Moderator: Matt Gareau, Deloitte LLP, Washington, DC; Panelist: Lawrence Axelrod, Office of Chief Counsel, Corporate, IRS, Washington, DC; Co-Sponsored By: Young Lawyers Forum

Current Developments in Consolidated Returns: A Discussion of Important Recent Administrative Guidance Pertaining to the Consolidated Return Regulations. Government representatives will participate to share their views on this guidance as well as to comment on the status of ongoing business plan projects. Moderator: Victor Penico, Deloitte LLP, San Fransico, CA

Session : ABATX12114
Banking & Savings Institutions
Conference : 2012 Joint Fall CLE Meeting
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Chair: Yoram Keinan, Greenberg Traurig LLP, New York, NY

Current Developments in State and Local Taxation of Financial Institutions. This panel will discuss recent developments in state and local tax updates relating to financial institutions. The panelists will also discuss recent cases and administrative guidance. Moderator: Michael Desrochers, KPMG LLP, Boston, MA; Panelists: David Nagle, Sullivan & Worcester LLP, Boston, MA; Scott Salmon, KPMG LLP, Washington, DC; Russell Levitt, KPMG LLP, New York, NY

The Financial Transaction Taxes - Will They Be Imposed in the United States? Is there a Financial Transaction Tax in your future? This panel will consider recently enacted and proposed financial transaction taxes in Europe and the potential for such a tax in the United States. Topics will include the types of transactions subject to, and exempted from, tax, extraterritorial application of the tax, rationales for a financial transactions tax, and intended and unintended consequences. Moderator: Stow Lovejoy, Kostelanetz & Fink LLP, New York, NY; Panelists: Lee Sheppard, Tax Analysts, New York, NY; Steven Rosenthal, Tax Policy Center of the Urban Institute, Washington, DC; Sarah Belin-Zebib, Ernst & Young LLP, New York, NY

The Looming Financial Institution Cost Basis Compliance Challenges for Debt Instruments and Options. The new cost basis law has posed significant regulatory compliance challenges for banks and brokers of all sizes. Cost basis reporting will be expanded to include debt and options acquired on or after January 1, 2014, and the basis complexities for these asset classes are significantly more daunting. The panel will focus on the major concerns in preparing to meet these looming challenges. Moderator: Stevie D. Conlon, Wolters Kluwer Financial Services, Chicago, IL; Panelists: Dale Collinson, KPMG LLP, Washington, DC; Pamela Lew, General Attorney, Office of the Associate Chief Counsel, Financial Institutions and Products, IRS, Washington, DC

Session : ABATX12115
Closely Held Businesses (TX) and Business Planning Group (TE)
Conference : 2012 Joint Fall CLE Meeting
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Closely Held Businesses Chair: Eric L. Green, Convicer Percy & Green LLP, Glastonbury, CT

Business Planning Group Chair: Hugh Drake, Brown Hay & Stephens LLP, Springfield, IL

Hot Topics. Panelists: Robert M. Nemzin, Butzel Long PC, Bloomfield Hills, MI; Karen Sandler Steinert, Fredrikson & Byron PA, Minneapolis, MN

Structuring Buyouts for Retiring Professionals. This panel will address the many complexities involved with buyouts of retiring professionals in closely held businesses. Along with providing advice and recommendations on the practical issues that can arise in these buyouts, the panel will discuss valuation issues involved in determining the buyout price; the advantages and disadvantages of the varying forms used to structure the buyout; and the income tax and estate tax issues that must be addressed in the buyout transaction. Panelists: Daniel McCarthy, The Blum Firm PC, Fort Worth, TX; Steven Gorin, Thompson Coburn LLP, St. Louis, MO; Robert Turnipseed, Armbrecht Jackson LLP, Mobile, AL; William Prescott, Wickens Herzer Panza Cook & Batista, Avon, OH

Issues in Dividing Up and Transferring Property Out of Professional Corporations and Partnerships. In a continuation of the prior discussion, this panel will discuss the practical and tax issues involved with the breakup and division of a professional company and related businesses, including Section 355 issues; how to divide or distribute corporate and partnership property; best ways to set up and fund separate partnerships or corporations for the professionals, and other key issues involved with the division of a professional company and related businesses. Panelists: Steven Gorin, Thompson Coburn LLP, St. Louis, MO; Daniel McCarthy, The Blum Firm PC, Fort Worth, TX; Robert Turnipseed, Armbrecht Jackson LLP, Mobile, AL; William Prescott, Wickens Herzer Panza Cook & Batista, Avon, OH

Session : ABATX12116
Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE)
Conference : 2012 Joint Fall CLE Meeting
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Estate & Gift Taxes Chair: Derek L. Fletcher, US Trust, Dallas, TX

Income & Transfer Tax Planning Group Chair: Leigh-Alexandra Basha, Holland & Knight, McLean, VA

Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since May, 2012. Panelists: Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC; George D. Karibjanian, Proskauer Rose LLP, Boca Raton, FL; Hannah W. Mensch, McLaughlin & Stern LLP, New York, NY

Decanting. Decanting may offer the flexibility to modify an irrevocable trust agreement but not without potential tax pitfalls. This panel will address the income and transfer tax issues that are implicated by decanting and that are expected to be addressed in forthcoming Treasury guidance as well as a discussion of the comments submitted in response to Notice 2011-101 by RPTE and the Section of Taxation. Panelists: Amy E. Heller, McDermott, Will & Emery, New York, NY; Briani Bennett Mellen, Nexsen Pruet, Columbia, SC; Jeffrey D. Chadwick, Williams Mullen, Richmond, VA

Planning in the Face of Uncertainty Including Last Minute, 4th Quarter Strategies. This presentation will address the remaining opportunity for clients to shift significant wealth during 2012 free of federal transfer tax consequences, including a discussion of specific planning strategies. The presentation will also address the now familiar sunset provisions of the 2010 Act and the planning that clients can implement to address the corresponding uncertainty. Panelists: David Scott Sloan, Holland & Knight, Boston, MA; Mary H. Schmidt, Schmidt & Federico, Boston, MA

S Corporations: What an Estate Planner Should Know.This panel will discuss the income tax aspects of S corporations, who qualifies as an S corporation shareholder, especially focusing on the types of trusts that qualify, and general pre and post-death planning techniques and considerations for S corporation shareholders. Panelists: Brian S. Masterson, KPMG LLP, Nashville, TN; Jeanne L. Newlon, Venable LLP, Washington, DC

Session : ABATX12117
Individual & Family Taxation
Conference : 2012 Joint Fall CLE Meeting
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Chair: Professor David L. Rice, California Polytechnic State University, Pomona, CA

Disabled Client and the Tax Code Some Gems. What Every Tax Practitioner and Controversy Attorney Should Know In Order to Properly Represent Their Clients. Taxpayers as well as elderly individuals with a disability and their families have a wide range of unique tax issues to consider. These issues include when the Statue of Limitations is tolled for filing for a claim for refund under IRC Section 6511(h); abatement of penalties; how to properly structure a personal injury settlement; the benefits of a Special Needs Trust (SNT) and Pooled Trusts; various deductions and credits a person with a disability might be eligible to claim; and how to deal with collection issues when social security and disability benefits are involved. Moderator: Joshua Beck, Attorney Advisor, Taxpayer Advocate Service, IRS, Washington, DC; Speakers: Professor Keith Fogg, Villanova Law School, Villanova, PA; Professor David L. Rice, California Polytechnic State University, Pomona, CA; Ken W. Shulman, Day Pitney LLP, Boston MA Co-Sponsored By: Elder Law, Disability Planning and Bioethics Group (TE)

IRS Audits of Electronic Accounting Systems What Can a Practitioner Legally Do? The IRS during the audit process has increasingly been demanding the actual files of various accounting programs. This program will focus on what rights the IRS has in demanding the files, what the taxpayer is required to turn over, what the IRS typically does with the information and the dangers and pitfalls of handing over clients accounting program files. Moderator: Elizabeth Nelson, David Lee Rice APLC, Torrance, CA; Speakers: Jim Mastracchio, Baker & Hostetler LLP, Washington, DC; Christin Bucci, Bucci Law Offices PA, Fort Lauderdale, FL; Duane Gillen, Director, Examination Policy, SB/SE, IRS, Washington, DC; Co-Sponsored By: Civil & Criminal Tax Penalties (TX)

Session : ABATX12118
Partnerships & LLCs
Conference : 2012 Joint Fall CLE Meeting
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Chair: Todd D. Golub, Ernst & Young LLP

Geminate: Can a Partner also be an Employee? Despite a long-standing IRS position to the contrary, practitioners frequently encounter partners being treated as employees of their own partnerships, usually due to oversight. Other practitioners set up structures to allow partners to be employees of their own partnerships without running afoul of the IRS position. This panel will discuss the state of the law, what they are seeing in practice and some common structures used to plan around the IRS position. Moderator: Bahar A. Schippel, Snell & Wilmer, Phoenix, AZ; Panelist: Elizabeth E. Drigotas, Deloitte LLP, Washington, DC

Our Little Tea Party: Tax Reform and Its Legislative Outlook. The panel will discuss the year-end legislative outlook, including expired and expiring provisions, as well as the issues and prognosis for tax reform. Moderator: Jeanne Sullivan, KPMG LLP, Washington, DC; Panelists: Eric Solomon, Ernst & Young LLP, Washington, DC; Professor Stephen E. Shay, Harvard Law School, Boston, MA; Jefferson Vander Wolk, US Senate Committee on Finance, Washington, DC

Hot Topics. This panel will discuss recent developments, including legislation, regulations, administrative guidance and noteworthy cases. Moderator: Eric B. Sloan, Deloitte LLP, New York, NY; Panelists: Beverly M. Katz, Special Counsel to the Deputy Associate Chief Counsel, Passthroughs and Special Industries, IRS, Washington, DC; Jacob B. Smith, Squire Sanders, Phoenix, AZ

What? This Old Stuff? Section 197 Planning for Partnerships. Section 197 issues exist in nearly every partnership transaction. This panel will explore relevant issues surrounding the application of section 197 to partnerships and partnership transactions, focusing on the anti-churning rules of section 197(f)(9). Moderator: Jeffrey A. Erickson, Ernst & Young LLP, Washington, DC; Panelists: John D. Currivan, Jones Day, Cleveland, OH; H. Grace Kim, Grant Thornton, Washington, DC

Session : ABATX12119
Transfer Pricing
Conference : 2012 Joint Fall CLE Meeting
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Chair: Mark R. Martin, McDermott Will & Emery LLP, Houston, TX

Evolving OECD Concepts for Pricing of Intangibles Transactions. This panel will discuss the interim discussion draft on intangibles published by the Organization for Economic Cooperation and Development on June 6, 2012, including the definition of intangibles, the identification of parties entitled to intangible returns and transactions involving intangibles, and other considerations associated with the pricing of related party intangible arrangements. Moderator: Cym H. Lowell, McDermott Will & Emery LLP, Dallas, TX; Panelists: David Ernick, Attorney Advisor, US Delegate to OECD Working Party 6, Associate International Tax Counsel, Department of Treasury, Washington, DC; Rocco V. Femia, Miller & Chevalier Chartered, Washington, DC; Jon Haug, Eli Lilly and Company, Indianapolis, IN

Practical Considerations for Dealing with the Pricing of Guarantee Arrangements. This panel will address the related party pricing of guarantee arrangements (financial and performance) taking into account recent case law developments and commentary, including a focus on the impact of group affiliation, the relevance of existing guidance on related party service transactions, and practical considerations pending more complete guidance from the IRS and other tax authorities. Moderator: Lucia Fedina, Deutsche Bank, New York, NY; Panelists: John Hinding, Deputy Associate Chief Counsel, Office of Associate Chief Counsel, International, IRS, Washington, DC; Alexey V. Manasuev, Ernst & Young LLP, Toronto, Canada; David Ernick, Attorney Advisor, US Delegate to OECD Working Party 6, Associate International Tax Counsel, Department of Treasury, Washington, DC

Session : ABATX12120
Exempt Organizations
Conference : 2012 Joint Fall CLE Meeting
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$45.00

Chair: Suzanne Ross McDowell, Steptoe & Johnson LLP, Washington, DC

Committee Business.

News from the IRS and Treasury. Representatives from the IRS and the Department of Treasury will speak on recent developments, pending guidance, and pending and proposed legislation. Moderator: Carolyn M. Osteen, Ropes & Gray LLP, Boston, MA; Panelists: Lois G. Lerner, Director, EO Division, TE/GE, IRS, Washington, DC; Victoria A. Judson, Division Counsel/Associate Chief Counsel, TE/GE, IRS, Washington, DC; Janine Cook, Deputy Division Counsel/Deputy Associate Chief Counsel, TE/GE, IRS, Washington, DC; M. Ruth M. Madrigal, Attorney- Advisor, Office of Tax Policy, Department of Treasury, Washington, DC

Election Year Issues for Exempt Organizations. Panelists will address a variety of issues relating to political activities of charities and other exempt organizations, including election laws affecting charities non-political activities, the increasing use of private benefit analysis on charities in the political context, and how the FEC major purpose test compares to the federal tax primary purpose test for exempt organizations. Moderator: Rosemary Fei, Adler & Colvin, San Francisco, CA; Panelists: Professor Ellen P. Aprill, Loyola Law School, Los Angeles, CA; Ezra W. Reese, Perkins Coie LLP, Washington, DC; Paul J. Murphy, Harmon Curran Spielberg + Eisenberg LLP, Washington, DC

Counseling and Representing Churches and Other Religious Organizations. This panel will explore tax, real estate and other issues unique to churches and religious organizations. Moderator: Boyd J. Black, Church of Jesus Christ of Latter-day Saints, Salt Lake City, UT; Panelists: April Davenport, Associate General Counsel, Presbyterian Church, Louisville, KY; Deirdre Dessingue, Associate General Counsel, United States Conference of Catholic Bishops, Washington, DC; Paul J. Bankes, Jr., Whiteman Bankes & Chebot LLC, Philadelphia, PA; Stuart J. Lark, Bryan Cave LLP, Colorado Springs, CO TX

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