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2014 Midyear Meeting

 

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(c) [2014] 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 (41) TOTAL sessions
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Event : ABATX26

Session : ABATX1401
Capital Recovery & Leasing
Conference : 2014 Midyear Meeting
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  • Chair: Glenn Johnson, EY , Washington, DC
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  • Current Developments Report and Update on Pending Guidance. This panel will cover the important recent developments in the areas of capital recovery and leasing. Moderator: David Strong, Crowe Horwath LLP, Grand Rapids, MI. Panelists: Scott Mackay, Taxation Specialist, Office of Tax Policy, Department of Treasury, Washington, DC; Kathleen Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Tracy Watkins, Grant Thornton LLP, Washington, DC.
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  • Tangible Property Regulations Update Transition Guidance Discussion, FAQs, and an Update on the Proposed Regulations. With the release of transition guidance, taxpayers now have the procedures they need to adopt the tangible property regulations. This panel will discuss the transition guidance in detail, address common tangible property regulation-related questions seen in the marketplace, and will provide an update and discussion surrounding the proposed regulations related to dispositions and general asset accounting. Moderator: Susan Grais, EY , Washington, DC Panelists: Scott Mackay, Taxation Specialist, Office of Tax Policy, Department of Treasury, Washington, DC; Kathleen Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Scott Dinwiddie, Special Counsel, Associate Chief Counsel IT&A, IRS, Washington, DC; David Auclair, Grant Thornton, Washington, DC; Ellen McElroy, Pepper Hamilton LLP, Washington, DC
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  • True Lease Analysis Lease vs. Sale/Financing. This program will cover important recent developments in the area of whether the lessor or the lessee should be treated as the owner of leased property and what standards should apply in light of the recent LILO /SILO court decisions. Moderator: Glenn Johnson, EY , Washington, DC Panelists: John Aramburu, Senior Counsel, IRS, Washington, DC; Ken Kempson, General Electric Company, Stamford, CT
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  • Experimenting with the Definition of a Prototype: A look at the Proposed Section 174 Regulations. This panel will examine the Proposed Section 174 Regulations, which seek to define a pilot model or prototype for purposes of the tax accounting provisions of Section 174, and the credit for increasing research expenditures under Section 41. Moderator: Christopher J. Ohmes, EY , Washington, DC. Panelists: Alexa Claybon, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; David Paul, American Honda Motor Corporation, Torrance, CA ; Les Schneider, Ivins Phillips and Barker Chartered, Washington, DC; Scott Garrison, EY , Houston, TX
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Session : ABATX1402
Indian Tribal Tax
Conference : 2014 Midyear Meeting
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  • Chair: Wendy Pearson, Pearson Law Offices PS, Seattle, WA
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  • Federal Indian Law and Policy, The Nuts & Bolts. This presentation will address fundamental Indian Law and Policy and the three basic general boundaries for the field of Indian Law in terms of political units, individuals and territory, all of which bear on federal, state, local and tribal taxation. This presentation will constitute a survey of the history, law and policies that define tribes and their communities, that define tribal lands, Indian Country and jurisdiction over those lands, and that reflect the nature of the inherent sovereign authority of Tribal governments over the intramural affairs of their citizens and the conduct of business both inside and outside their territories. Panelists: C. Joseph Lennihan, Attorney, Santa Fe, NM
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  • State and Tribal Taxing Jurisdictions, A Complicated Relationship. State taxing authority can be preempted by federal treaties and statutes. In the Indian law context, the preemption doctrine, buttressed by longstanding principles protecting tribal self-government from state law incursions provides a barrier to state taxation and a concurrent basis for tribal taxation. This panel will discuss the seminal cases that address state and tribal taxing jurisdiction and the conceptual underpinnings of the recent BIA Leasing Regulations. This is an essential primer for the state and local tax committee panel presentation this afternoon on the BIA Leasing Regulations. Moderator: Charles J. Moll, Partner, Winston & Strawn LLP Panelists: Del Laverdure, Akin Gump, Washington, DC; Pat Irvine, of Counsel Fennemore Craig, Phoenix, AZ;
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Session : ABATX1403
Transfer Pricing
Conference : 2014 Midyear Meeting
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  • Chair: Matthew Frank, GE Company, Fairfield CT
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  • New IRS Revenue Procedures for the Competent Authority and APA processes. The IRS released on November 22, 2013 two Notices (Notice 2013-78 and Notice 2013-79) proposing new Revenue Procedures to replace Competent Authority Rev Proc 2006-54 and APA Rev Proc 2006-9. Comments on the proposed Revenue Procedures are due March 10, 2014. The panelists will discuss matters addressed in the proposed Revenue Procedures and suggestions for improvements to them. Moderator: Sean Foley, KPMG LLP, Washington, DC. Panelists: Robert Green, Skadden Arps, Washington, DC; John Hinding, Deputy Associate Chief Counsel (International), Washington, DC; Craig Sharon, EY , Washington, DC
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  • Update on Transfer Pricing Issues in Developing Countries. Multinational companies are doing business more frequently in developing countries which include not only Brazil, Russia, China and India, but many other countries around the world including those in Africa and the CIS region. Many of these countries lack fully developed tax guidance and processes and do not subscribe to the fundamental principles set forth in the OECD Guidelines. This session will focus on transfer pricing positions and issues that are arising in developing countries with particular focus on issues affecting companies in the natural resource industry, such as energy and mining. Panelists will identify the issues and discuss practical approaches and solutions, including the availability of rulings and advance agreements. Moderator: Tim Gunning, EY , New York, NY . Panelists: Mark Martin, McDermott Will Emery, Houston, TX ; Ash Baskerville, Ph-ase, Inc., New York, NY ; Hugh Donahue, Freeport-McMoRan Copper & Gold Inc., Phoenix, AZ.
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Session : ABATX1404
US Activities of Foreigners and Tax Treaties
Conference : 2014 Midyear Meeting
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  • Chair: David Shapiro, Shapiro Tax Law LLC , Philadelphia, PA
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  • FATCA for Those on This Side of the Ocean/Border.* Much has been written about the duties and obligations of foreign financial institutions (FFIs) and Non-Financial Foreign Entities (NFFEs) under the FATCA regime. But what about the duties and obligations of US withholding agents? What should US withholding agents be doing now to prepare for FATCA ? What due diligence needs to be undertaken? Which payments are subject to FATCA withholding and which payments are exempt? What certifications should be obtained before making payments to foreign persons? This panel will review the nuts and bolts of FATCA compliance from the perspective of the US withholding agent. The panel will also explore any late-breaking FATCA developments affecting US withholding agents. Moderator: Edward Tanenbaum, Alston & Bird LLP, New York, NY Panelists: Michelle Davila, Franklin Templeton Investments, Fort Lauderdale, FL; Philip Hirschfeld, Ruchelman P.L.L.C., New York, NY
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  • Inbound Financings: Issues and Planning Strategies. An increasingly complex array of issues arise in connection with the financing of US operations of non-US based businesses. These issues arise in the context of intercompany financings as well as third-party financing arrangements. This panel will discuss the US tax issues associated with inbound financings, including debt/equity, earnings stripping and other limitations on interest deductions, withholding taxes and hybrid issues. The panel will also explore various planning strategies frequently used by non-US businesses in financing their US operations. Moderator: Jason Bazar, Mayer Brown LLP, New York, NY Panelists: Laura M. Barzilai, Sidley Austin LLP, New York, NY ; Stuart Chessman, Vivendi SA, New York, NY ; Michael A. DiFronzo, PricewaterhouseCoopers LLP, Washington, DC

Session : ABATX1405
Administrative Practice
Conference : 2014 Midyear Meeting
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  • Chair: Kevin Johnson, Pepper Hamilton LLP, Philadelphia, PA
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  • Current Developments. The panel will discuss current developments in the practice before the IRS. Moderatior: Bryon Christensen, Amazon.com, Seattle, WA Panelist: Alexandra Minkovich, Associate Legistaltive Counsel, Department of Treasury, Washington, DC; Thomas J. Kane, Acting Associate Chief Counsel, Procedure and Administration, Chief Counsel, IRS, Washington, DC; Mary I. Slonina, PriceWaterhouse Coopers LLP, Washington, DC
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  • Appeals: New Initiatives. How will the Appeals Judicial Approach and Culture Project (AJAC ) affect resolution of cases? This panel will discuss the guidance issued with regard to implementation of the AJAC , including topics such as distinguishing between new issues and new arguments. We will also compare the panoply of resolution programs (Rapid Appeals Process, Early Referral, Fast Track Settlement, Traditional Appeals) with a view to identifying factors to consider when choosing a resolution program. Moderator: Sheri Dillon, Bingham McCutchen LLP, Washington, DC Panelists: Sheldon Kay, Sutherland Asbill & Brennan LLP, Atlanta, GA; Susan Seabrook, Bingham McCutchen LLP, Washington, DC; Kirsten Wielobob, Acting Chief, Office of Appeals, IRS, Washington, DC; Kevin Brown, PricewaterhouseCoopers LLP, Washington, DC
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  • LB&Is New IDR Enforcement Process. In a Directive issued on November 4, 2013, LB&I laid out a mandatory step-by-step process that could culminate with the issuance of a summons when a taxpayer fails to timely respond to an Information Document Requests (IDR). This panel will review the steps in the new process, discuss the goals and objectives of the new process, and assess potential impact on the audit dynamic between taxpayers and the IRS. Moderator: George Hani, Miller & Chevalier, Washington, DC Panelists: Linda Kroening, LB&I Division Counsel, IRS, Washington, DC; Larry Langdon, Mayer Brown LLP, Palo Alto, CA ; Bryon Christensen, Amazon.com, Seattle, WA
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Session : ABATX1406
Affiliated & Related Corporations
Conference : 2014 Midyear Meeting
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  • Chair: Matthew E. Gareau, Deloitte Tax LLP, Washington, DC
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  • 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: Mark Schneider, Deloitte Tax LLP, Washington, DC Panelists: Matt Gareau, Deloitte Tax LLP, Washington, DC, Gray Kidder, Steptoe & Johnson, Washington, DC, Krishna Vallabhaneni, Attorney-Advisor, Office of Tax Legislative Counsel, Office of Tax Policy, Department of Treasury, Washington, DC
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  • Exploring the Intersection of the Federal Consolidated Return Rules and State Tax. Using a series of simple transactions (contributions, distributions, reorganizations, etc), the panel will identify some of the many instances in which the consolidated return rules modify or entirely over-ride the separate company consequences relevant to many states, with particular attention to the opportunities and pitfalls flowing from these disconnects. Moderator: David Friedel, PricewaterhouseCoopers LLP, Washington, DC Panelist: Rob Ozmum, PricewaterhouseCoopers LLP, Boston, MA
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Session : ABATX1407
Banking & Savings Institutions
Conference : 2014 Midyear Meeting
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  • Chair: Daniel Mayo, KPMG LLP, New York, New York
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  • Advising Banks and Savings Institutions in 2014. This panel will consider recent decisions concerning economic substance, substance over form and business purpose. It will then explore recent changes in penalties for corporations and the legal and ethical obligations of practitioners under Circular 230 and section 6694. The panel will conclude by applying these concepts to several hypothetical cases. Moderator: Stow Lovejoy, Kostelanetz & Fink LLP, New York, NY Panelist: Daniel A Rosen, Special Trial Attorney, Chief Counsel, IRS, New York, NY
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  • Final and Proposed Section 871(m) Regulations & FATCA Update. The IRS issued final and proposed regulations under section 871(m) on December 4, 2013. This panel will explore the regulations and their impact on the derivatives market. This panel also will discuss recent developments with respect to FATCA and how financial and non-financial institutions should prepare for the 2014 deadlines. In particular, we will explore the guidance issued by the IRS pertaining to the registration process of foreign financial institutions, the model FFI agreement that was released by the IRS in notice 2013-69. Moderator: Daniel Mayo, KPMG LLP, New York, NY Panelists: Yoram Keinan, Greenberg Traurig LLP; Anthony Tuths, WithumSmith + Brown PC, New York, NY
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  • Basel III and Deferred Tax Assets: theres no such thing as a mere timing difference. This panel will explore the rules limiting the amount of DTA s that banks and certain non-bank SIFIs can include in measuring regulatory capital, how regulatory capital drives business decisions and the growing importance of monetizing DTA s for banking institutions. Moderator: John M. Taylor, EY , Phoenix, AZ
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Session : ABATX1408
Closely Held Businesses
Conference : 2014 Midyear Meeting
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  • Chair: James Robert Turnipseed, Armbrecht Jackson LLP, Mobile, AL
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  • Entity Selection and Corporate Governance for Closely-Held Businesses. This panel will discuss the tax and practical aspects of entity selection and maintenance, including issues in formation and dissolution for closely-held businesses. Panelists: Alson R. Martin, Lathrop & Gage LLP, Overland Park, KS; Morton A. Harris, Hatcher Stubbs Land Hollis & Rothschild, Columbus, GA; William P. Prescott, Wickens Herzer Panza Cook & Batista Co, Avon, OH
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  • The Taxation of the Purchase and Sale of Closely-Held Businesses and Professional Practices. This panel will review the tax issues for the complete and fractional purchase and sale of closely-held businesses and professional practices with an update on personal goodwill and the Section 197 anti-churning rules. There will also be a discussion on the buy-out of a shareholder, member or partner for any reason under buy-sell agreements. Panelists: Alson R. Martin, Lathrop & Gage LLP, Overland Park, KS; Morton A. Harris, Hatcher Stubbs Land Hollis & Rothschild, Columbus, GA; William P. Prescott, Wickens Herzer Panza Cook & Batista Co, Avon, OH
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Session : ABATX1409
Estate & Gift Taxes
Conference : 2014 Midyear Meeting
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  • Chair: Derek L. Fletcher, US Trust, Dallas, TX
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  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since September, 2013. Panelists: Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC; George D. Karibjanian, Proskauer Rose LLP, Boca Raton, FL; Hannah Menseh, Ehrenkranz & Ehrenkranz LLP, New York, NY
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  • Captive Insurance Companies and the Closely Held Business. Captive insurance companies are becoming an increasingly popular risk management tool for closely-held business owners. Accordingly, it is important for the estate planning professional to understand the structure and operation of captives as well as the manner in which these entities can be incorporated into a clients estate plan. This panel discussion will review the organization, benefits, tax treatment and wealth transfer potential of the captive insurance company. Panelists: Sean G. King, SageView Retirement Plan Consultants Inc, Knoxville, TN; James J. Coomes, The Coomes Law Firm, Birmingham, AL
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  • Self-Settled Asset Protection Trusts. With litigation on the rise, more and more clients are focusing on methods to preserve and protect wealth from the multitude of potential claims arising from future litigation and other threats. One such planning technique is the self-settled asset protection trust. This presentation will address the design (including jurisdiction selection), benefits, tax treatment, operation and limitations associated with the use of a self-settled asset protection trust in a clients tax, financial and estate planning. Speaker: Richard W. Nenno, Wilmington Trust Company, Wilmington DE.
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  • Audit Proofing Family Limited Partnerships. The family limited partnership continues to be a popular estate planning vehicle, but one that remains subject to a variety of IRS attacks, including scrutiny under Sections 2036/2038, the step transaction doctrine, Section 2703 and Section 2503. This presentation will cover the proactive steps that can be taken at each phase of the entity planning process, including design, implementation and operation of the family entity in order to minimize the risk and exposure of an IRS attack. Speaker: Stephanie Loomis-Price, Winstead, Houston, TX
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Session : ABATX1410
Partnerships & LLCs
Conference : 2014 Midyear Meeting
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  • Chair: Adam M. Cohen, Holland & Hart LLP, Denver, CO
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  • Hot Topics in Partnership Taxation. This panel will discuss significant recent developments related to subchapter K. Moderator: Thomas E. Yearout, J & J Management Services Inc, St. Louis, MO Panelists: Benjamin H. Weaver, General Attorney, Branch 1, Office of the Associate Chief Counsel, Passthroughs & Special Industries, IRS, Washington, DC; Timothy J. Leska, Pepper Hamilton LLP, Philadelphia, PA
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  • Is Private Equity Engaged in the Conduct of a Trade or Business? In light of the recent First Circuit decision, Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund, this panel will discuss whether private equity funds are engaged in the conduct of a trade or business and the implications to partners and partnerships in the event that a private equity funds activities were considered to constitute a trade or business. Moderator: Patrick B. Fenn, Akin Gump Strauss Hauer & Feld LLP, New York, NY Panelists: David Franklin, Deloitte Tax LLP, New York, NY ; Steven M. Rosenthal, Urban- Brookings Tax Policy Center, Washington, DC; Curtis G. Wilson, Associate Chief Counsel (Passthroughs & Special Industries), Chief counsel, IRS, Washington, DC
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  • Prickliest Provisions in a Partnership Agreement: Allocations. This panel will discuss approaches to allocations in partnership agreements and their implications. Moderator: Professor Noel P. Brock, West Virginia University Law School, Morgantown, WV Panelists: Jennifer H. Alexander, Deloitte Tax LLP, Washington, DC; Jim G. Tod, KPMG LLP, San Francisco, CA
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  • Considering Retirement in Arizona? Payments to Retiring Partners under Section 736. This panel will discuss various aspects of payments to retiring partners. Moderator: John J. Rooney, KPMG LLP, Washington, DC Panelist: Ossie Borosh, KPMG LLP, Washington, DC
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Showing sessions 1 - 10 of (41) TOTAL sessions
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