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2013 May Meeting

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(c) [2013] 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 1 - 10 of (44) TOTAL sessions
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Event : ABATX24

Session : ABATX1346
Low Income Taxpayers Representation Workshop
Conference : 2013 May Meeting
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Tax and Immigration. This panel will discuss tax issues facing individuals who have immigrated to the United States. Among the issues this panel will address are: worker classification, the detention process and ITIN issues (new regulations, problems in obtaining ITIN) and the impact of tax compliance on immigration status with a focus on the tax issues immigration judges look to have resolved and what constitutes a satisfactory resolution. This panel will discuss the impact of offers in compromise and installment agreements on tax compliance, look back periods on unfiled returns, audits and ITINs. Moderator: Paul Harrison, Center for Economic Progress, Chicago, IL Panelist: Ana Cecilia Lopez, University of Washington School of Law, Seattle, WA; W. David Koeninger, Advocates for Basic Legal Equality Inc, Toledo, OH; The Honorable Paul Schmidt, Immigration Judge, Arlington, VA

Tax and Family Law. This panel will focus on family law issues and the tax problem that trail along behind them. In the course of the presentation the panel will discuss the new indicator that the IRS uses for domestic violence cases, the 2012 innocent spouse revenue procedure (and perhaps an update to that proposal), new draft Form 8332 and instructions, and issues related to children that have tax debts (e.g., aunt fraudulently liquidates account for minor). Moderator: Professor Charles Jeane, Visiting Assistant Professor of Law, David A. Clarke School of Law, University of the District of Columbia, Washington, DC Panelists: Susan Morgenstern, Cleveland Legal Aid Society, Cleveland, OH; Jill MacNabb, Attorney Advisor, Taxpayer Advocate Service, Washington, DC

Tax and Disability. This panel will broadly discuss challenges facing taxpayers with a disability when filing their taxes, and national and local efforts to address these challenges. Further, the panel will focus on specific tax provisions that make allowances for taxpayers with a disability, such as IRC Sections 22, 72(t), 152 and 6511(h). Moderator: Jennifer Mueller, Washington College of Laws Janet R. Spragens Federal Tax Clinic, American University, Washington, DC Panelists: Josh Beck, Attorney Advisor, Taxpayer Advocate Service, Washington, DC; Johnette Hartnett, National Disability Institute, Washington, DC; Jacqueline Wilks, Outreach Specialist, Consumer Financial Protection Bureau, Atlanta, GA

Tax and Consumer Transactions. This panel will discuss tax issues arising in a consumer context. The discussion will include the tax issues arising from the cancellation of non-mortgage consumer debt. The panel will examine whether the canceled consumer debt is income and whether or not it is excludible for some reason (insolvency, etc.). The panelists will address litigation strategies for setting up a good argument for non-taxability of forgiven debt in debt defense cases and ways to attack a 1099-COD. Moderator: Professor Pamela Chaney, University of Maryland Francis King Carey School of Law, Baltimore, MD Panelists: Mandi Matlock, Texas RioGrande Legal Aid Inc, Austin, TX; Jamie Andree, Indiana Legal Services Inc, Bloomington, IN; Chi Chi Wu, National Consumer Law Center, Boston, MA

Session : ABATX1347
Tax Bridge to Practice
Conference : 2013 May Meeting
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Nuts & Bolts Series: The Nuts & Bolts of Deficiency Cases V From Examination to the Tax Court. A foundational understanding of Federal tax practice and procedure is necessary to skillfully represent a client in a civil tax controversy. This panel will address the various procedural and practical considerations associated with IRS examinations and administrative appeals. Thereafter, it will explore aspects of deficiency and refund litigation, with a focus on U.S. Tax Court jurisdiction and its unique rules of practice and procedure. The panel will conclude with a survey of the most recent and significant decisions of the U.S. Tax Court. Moderator: Brendan Sponheimer, Mayer Brown LLP, New York, NY Panelists: The Honorable Juan F. Vasquez, Judge, US Tax Court, Washington, DC; Zhanna A. Ziering, Caplin & Drysdale Chartered, New York, NY; Kevin G. Gillin, Attorney, Office of Associate Chief Counsel (Procedure & Administration), IRS, Washington, DC

Nuts & Bolts Series: So, What Do You Need to Know About Employee Benefits? A PrimerXand UpdateXon Employee Benefits and ERISA. The law governing employee benefits, mainly found in ERISA and the Internal Revenue Code, has been a hotbed of developments recently, from the debate over national health care coverage, to discussions about reforming executive compensation and the future of current retirement programs. This panel will offer an overview of employee benefits law, by introducing core concepts and identifying several key topics that often arise. During this program, the panelists will also offer perspectives on their practices and prospects in their areas, and provide a lead-in to the following Nuts & Bolts panel on the ACA. Moderator: Laura Westfall, King & Spaulding, New York, NY Panelists: Melissa Moore, Office of the Solicitor, Department of Labor, Washington, DC; Emily C. Meyer, King & Spalding LLP, New York, NY; Laura A. Szarmach, Slevin & Hart, P.C., Washington, DC; Allison M. Hoots, Keightley & Ashner LLP, Washington, DC; Kathryn Bjornstad, Groom Law Group, Washington, DC

Session : ABATX1349
Capital Recovery & Leasing
Conference : 2013 May Meeting
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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: Tracy Watkins, Grant Thornton LLP, Washington, DC Panelists: Scott Mackay, Tax Specialist, Office of Tax Policy, Department of Treasury, Washington, DC; Kathleen Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Sam Weiler, Ernst & Young LLP, Washington, DC; Glenn Johnson, Ernst & Young LLP, Washington, DC

Capitalization Issues Affecting Banks. This panel will discuss recent IRS guidance on capitalization issues for the banking industry, including whether section 263A applies to costs incurred in holding other real estate owned (OREO property), as well as the proper tax treatment of prepaid FDIC assessments under section 263(a). Moderator: Natalie Tucker, McGladrey LLP, Washington, DC Panelists: Carol Conjura, KPMG LLP, Washington, DC; Andrew Keyso, Associate Chief Counsel (Income Tax & Accounting), IRS, Washington, DC; Duke Osborne, Attorney, Branch 2 (Income Tax & Accounting), IRS, Washington, DC

Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263A. A number of the method changes to the early adoption provisions of the tangible property regulations require compliance with section 263A, for both inventory and self-constructed assets. However, many section 263A method changes are currently not eligible for automatic consent. This panel will discuss issues taxpayers should be aware of in planning to implement the tangible property regulations and determining whether the taxpayer is currently in compliance with UNICAP for the costs that are being changed or if any related UNICAP method changes will be required. Moderator: Brandon Carlton, Ernst & Young LLP, Washington, DC Panelists: Scott Dinwiddie, Special Counsel, Office of Associate Chief Counsel (Income Tax & Accounting), IRS, Washington, DC; Scott Mackay, Tax Specialist, Office of Tax Policy, Department of Treasury, Washington, DC; Heather Harman, Deloitte LLP, Washington, DC; Eric Lucas, KPMG LLP, Washington, DC; Kristine Mora, Ernst & Young LLP, Washington, DC

Session : ABATX1350
Administrative Practice
Conference : 2013 May Meeting
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Important Developments. This panel will discuss important developments in administrative practice that have occurred since the last meeting. Moderator: Bryon Christensen, Amazon, Seattle, WA Panelists: Thomas Kane, Office of Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC; Michael Kummer, Bingham McCutchen LLP, Washington, DC; Alexandra Minkovich, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC

Managing International Tax Audits and Tax Risks in a Changing Global Landscape. With the increase in foreign tax audits around the globe, the panelists will discuss how tax authorities identify and determine tax compliance risk, how companies are revamping their approaches to managing tax audits and best practices to mitigate tax controversy. Moderator: Frank Ng, Ernst & Young, LLP, Washington, DC Panelists: Peter Barnes, General Electric Company, Fairfield, CT; Lucie Bergevin, Director General (International and Large Business Directorate), Canada Revenue Agency, Ottawa, Canada; Nancy Chassman, AIG, London, UK; Mike Danilack, Deputy Commissioner (International), IRS, Washington, DC

Hey, Somebody Stole My Tax ID! Cleaning up tax identity fraud is a growing area of administrative practice at both the state and federal levels. Victims include not only individuals but also employers, who can be left footing the tax bill for fraudulent W-2s. This practical session will address the problems faced by individuals and companies who are victims of these scams and provide tools for resolution. The panelists will also address strategies currently available to individuals and employers to reduce risk and discuss regulatory and legislative proposals designed to combat this problem. Moderator: Maxine Aaronson, Dallas, TX Panelists: Nina Olson, National Taxpayer Advocate, IRS, Washington, DC; Claudia Hill, TaxMam Inc, Cupertino, CA; Debera Salam, Ernst & Young LLP, Houston, TX

Session : ABATX1351
Estate & Gift Taxes
Conference : 2013 May Meeting
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Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since January 2013. Panelists: Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC; Hannah W. Mensch, Ehrenkranz & Ehrenkranz LLP, New York, NY; George D. Karibjanian, Proskauer Rose LLP, Boca Raton, FL

Tax Apportionment: One Clause Does Not Fit All. Tax apportionment clauses may be one of the most complex and challenging aspects of developing a clients estate plan. Even if the issue of tax apportionment has been carefully considered and discussed with the client, many drafting pitfalls can impact the manner in which taxes are apportioned in surprising and unwelcome ways. This presentation will discuss the apportionment of taxes and how to draft apportionment clauses to avoid traps for the unwary. Panelist: Barbara A. Sloan, McLaughlin & Stern, LLP, New York, NY

Preferred Equity Freezes: How They Work. This presentation will review the tax treatment of preferred equity freezes, including I.R.C. Section 2701, and how they can be used to reduce transfer taxes and accomplish nontax objectives. Panelist: Louis A. Mezzullo, McKenna Long & Aldridge LLP, Rancho Santa Fe, CA

Session : ABATX1352
Investment Management
Conference : 2013 May Meeting
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Taxing Private Equity Funds as Corporate Developers. Private equity funds attract a lot of attention. But what do they do? And how should they be taxed? Are they merely passive investors? Or are they corporate developers, which might suggest their profits are ordinary? Are they in a trade or business? If so, what are the consequences? This panel will discuss a provocative article penned by Steve Rosenthal in which he observes that private equity funds buy stock in companies that they intend to develop and resell. He recommends that the IRS draft regulations to treat the gains and losses on the sale of those companies (or their stock) as ordinary income. His co-panelists will offer different perspectives on the law and the implications of this proposal. For example, if the regulations were to take such a position, would it subject pension funds, charities, sovereign wealth funds and foreign investors (i.e., the majority of the capital providers to most funds) to full U.S. tax on their gains? Moderator: Amy Snyder, Ropes & Gray LLP, Boston, MA Panelists: Steven M. Rosenthal, Urban-Brookings Tax Policy Center, Washington, DC; Andrew W. Needham, Cravath Swaine & Moore LLP, New York, NY

Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and Mauritius. This first part of the panel will discuss current issues being considered by the IRS Office of Chief Counsel regarding RICs and provide an update regarding issues that continue to arise for RICs and a discussion on any recent IRS published guidance. The second part of the panel will focus on issues affecting RICs with respect to their investments in and through India and Mauritius. Moderator: Richard LaFalce, Morgan Lewis & Bockius LLP, Washington, DC Panelists: Susan T. Baker, Senior Technician Reviewer, Branch 2 of Financial Institutions and Products, IRS, Washington, DC; Cathy Fung, Attorney, Branch 2 of Financial Institutions and Products, IRS, Washington, DC; Nishith Desai, Nishith Desai Associates, Mumbai, India

Current Issues Being Addressed by the Investment Company Institute. This panel will examine the operational issues in connection with the latest proposal for tax reform, including the Camp proposal, and how those proposals might affect the taxation of RICs and their investors. In addition, the panel will discuss the implementation of the final FATCA regulations, other international tax issues, and any other current developments all with an eye to how they will affect RICs and their investors. Moderator: Karen Gibian, Investment Company Institute, Washington, DC Panelists: Ryan Lovin, Investment Company Institute, Washington, DC; Gregory Hinkle, T. Rowe Price, Baltimore, MD

Session : ABATX1353
Partnerships & LLCs
Conference : 2013 May Meeting
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Hot Topics. This panel will discuss recent developments, including legislation, regulations, administrative guidance and noteworthy cases. Moderator: Rita D. Abro, Thompson Coburn LLP, Chicago, IL Panelists: Beverly M. Katz, Special Counsel to the Associate Chief Counsel, Office of Chief Counsel, Passthroughs & Special Industries, IRS, Washington, DC; Jennifer H. Alexander, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC

Aggregate Versus Entity: The Original Sin of Subchapter K. This panel will discuss the origins of and issues arising from treating a partnership as an entity in some instances, but as an aggregate of its partners in other instances. Moderator: John J. Rooney, KPMG LLP, Washington, DC Panelists: Dawn M. Duncan, Ernst & Young LLP, New York, NY; Paul M. Carman, Chapman & Cutler LLP, Chicago, IL

Allocation of Basis Adjustments Under Section 743(b) to Contingent Liabilities. This panel will discuss the treatment of basis adjustments under section 743(b) when a partnership has contingent liabilities. Moderator: Matthew W. Lay, Deloitte Tax LLP, Washington, DC Panelists: Martin D. Pollack, Weil Gotshal & Manges LLP, New York, NY; Jessica M. Jones, Ernst & Young LLP, St. Louis, MO; David R. Haglund, Branch Chief, Office of Chief Counsel, Passthroughs & Special Industries, IRS, Washington, DC

Session : ABATX1354
Affiliated & Related Corporations
Conference : 2013 May Meeting
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Member Tax Years and Related Issues. A discussion and overview covering the rules governing taxable years and allocation of items of income, deduction, gain, and loss between taxable periods of members that join or leave a consolidated group. In particular, we will discuss the application of the next-day rule and the end-of-the-day rule to certain deductions that arise on the date of a members change in status, including a generic legal advice memorandum recently issued by the IRS that addresses this topic. Moderator: Matt Gareau, Deloitte Tax LLP, Washington, DC Panelists: Russell Jones, Office of Chief Counsel, IRS, Washington, DC; Lawrence Axelrod, Office of Chief Counsel, Corporate, IRS, Washington, DC; Michelle Albert, Ernst & Young LLP, Washington, DC; Greg Featherman, KPMG LLP, Washington, DC

Current Developments in Consolidated Returns. A Survey of the Consolidated Aspects of the Section 336(e) Regulations. The panel will provide an overview of the section 336(e) regulations and will focus on issues under the regulations that relate to consolidated groups. A panel for the Corporate Committee will focus on issues under the regulations that relate more generally to corporations. Moderator: Professor Don Leatherman, University of Tennessee, Knoxville, TN Panelists: Kenneth Cohen, Senior Technician Review, Branch 3, Office of the Associate Chief Counsel (Corporate), IRS, Washington, DC; Gordon Warnke, Linklaters LLP, New York, NY; Professor Michelle Kwon, University of Tennessee, Knoxville, TN

Session : ABATX1355
Foreign Activities of US Taxpayers
Conference : 2013 May Meeting
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Outbound Property Transfers Under Section 367(a)(5). This panel will discuss expected final regulations governing outbound property transfers under section 367(a)(5). Moderator: Giovanna T. Sparagna, Sutherland Asbill & Brennan LLP, Washington, DC Panelists: Brenda Zent, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Robert Williams, Jr., Attorney, Branch 4, Office of Associate Chief Counsel (International), IRS, Washington, DC; Joseph Calianno, Grant Thornton LLP, Washington, DC

Foreign Tax Credits. This panel will discuss recent developments and guidance on foreign tax credits and the impact on tax planning. Moderator: Martin Collins, PricewaterhouseCoopers LLP, Washington, DC Panelists: Ginny Chung, Acting Deputy International Tax Counsel, Office of Tax Policy, Department of Treasury, Washington, DC; Barbara A. Felker, Chief, Branch 3, Office of Associate Chief Counsel (International), IRS, Washington, DC; Carol Tello, Sutherland Asbill & Brennan LLP, Washington, DC

Session : ABATX1356
Tax Policy & Simplification
Conference : 2013 May Meeting
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What are the Constitutional Parameters of Tax Reform and Simplification? Tax reform may raise Constitutional issues, such as whether a VAT is an indirect tax that requires apportionment. While in the past 100 years the Constitution has placed few barriers to the imposition of taxes, could Constitutional issues rise again in the search for new revenue? Moderator: Professor Roberta Mann, University of Oregon, Eugene, OR Panelists: Jack Cummings, Alston & Bird, Raleigh, NC; Professor Erik Jensen, Case Western Reserve University School of Law, Cleveland, OH; Professor Tracy Kaye, Seton Hall University School of Law, Orange, NJ; Joseph Thorndike, Tax Analysts, Washington, DC

Government Perspectives on Tax Reform. Moderator: Professor Itai Grinberg, Georgetown University Law Center, Washington, DC Panelists: Mark Mazur, Assistant Secretary for Tax Policy, Department of Treasury, Washington, DC; Mark Prater, Senate Finance Committee, Washington, DC

Showing sessions 1 - 10 of (44) TOTAL sessions
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