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2015 Midyear Meeting

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(c) [2015] 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 (45) TOTAL sessions
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Event : ABATX29

Session : ABATX1501
Capital Recovery and Leasing
Conference : 2015 Midyear Meeting
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  • Chair: Alison Jones, 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: 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; Tracy Watkins, Grant Thornton LLP, Washington, DC
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  • Hot Topics in the Oil and Gas Industry. This panel will focus on topics of interest in the oil and gas industry including capitalization of delay rentals, intangible drilling cost treatment for platform construction costs, and other issues via a discussion with tax practitioners, government officials, and industry personnel. Moderator: Scott Garrison, EY, Houston, TX Panelists: Jaime Park, Branch Chief, Branch 6, Passthroughs and Special Industries, IRS, Washington, DC; Eileen Johnson, Territory Manager, Territory 2, Large Business & International Division (Natural Resources and Construction), IRS, Houston, TX; Ross Schoppe, Exxon Mobil Corporation, Houston, TX; Susan Thibodeaux, EY, Houston, TX
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  • Tangible Property Regulations Update - Continuation from the September Meeting Disposition Regulations, FAQs, and Related Discussions. This panel will continue our discussion around the tangible property regulations specifically with respect to the regulations around dispositions as well as common tangible property regulationrelated questions seen in the marketplace. Moderator: Sharon Kay, Grant Thornton 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; Brandon Carlton, EY, Washington, DC
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Session : ABATX1502
Administrative Practice
Conference : 2015 Midyear Meeting
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$45.00


  • Chair: Kevin Johnson, Pepper Hamilton LLP, Philadelphia, PA
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  • Important Developments. This panel will discuss important developments in IRS administrative practice since the last meeting. Moderator: Mary Slonina, PwC, Washington, DC Panelists: Rochelle Hodes, Attorney Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Kathryn A. Zuba, Deputy Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC
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  • Navigating the TEFRA Swamp: Managing the Complexities of a Partnership Audit. The recent attention given to partnership audits likely will lead to more such audits, and in particular, to audits of large partnerships. The TEFRA procedures for partnership audits add layers of procedural complexity to already difficult partnership issues, and not surprisingly, several of these procedural questions have been resolved through litigation. This panel will discuss some of the basics of a TEFRA audit and focus on particular complexities that can often baffle even a veteran tax controversy attorney. In addition, the panel will discuss recent reports regarding the current state of TEFRA audits as well as some proposals for reform of the TEFRA system. Moderator: Sheri Dillon, Vinson & Elkins, Washington, DC Panelists: The Honorable Ronald L. Buch, Judge, US Tax Court, Washington, DC; Janet R. Balboni, Senior Attorney, Office of Chief Counsel, IRS, Large Business and International Division, Houston, TX; Thomas L. Fenner, Attorney, Office of Chief Counsel, IRS, Small Business and Self-Employed Division, Houston, TX; Mary McNulty, Thompson & Knight, Dallas, TX
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  • You've Been Served: Handling IRS Summonses in Audits and Tax Litigation. This panel will discuss the IRSs new LB&I IDR and summons policies including complying with the new rules. In addition, the panel will discuss defending summonses, filing a motion to quash, and other aspects of summons enforcement in tax controversies. Moderator: Chuck E. Hodges, III, Kilpatrick Townsend & Stockton LLP, Atlanta, GA Panelists: Deborah Meland, Chief, Civil Trial Sections - Eastern US, Tax Division, Department of Justice, Washington, DC; Andrew Strelka, Miller & Chevalier Chartered, Washington, DC
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Session : ABATX1503
Foreign Activities of US Taxpayers
Conference : 2015 Midyear Meeting
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  • Chair: Joseph Calianno, Grant Thornton LLP, Washington, DC
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  • Moving Overseas: Notice 2014-52 and Future Guidance and the Implications for Inversions. Press reports of US companies seeking foreign merger partners continue to be prevalent, even after the issuance of Notice 2014-52. This panel will discuss the implications of Notice 2014-52 on these potential inversions and other guidance the IRS and Department of Treasury are considering to stem the inversion tide. Moderator: Peter H. Blessing, KPMG LLP, New York, NY Panelists: J. Brian Davis, Ivins Phillips & Barker, Washington, DC; Edward Tanenbaum, Alston & Bird LLP, New York, NY; Doug Poms, Senior Counsel to the International Tax Counsel, Department of Treasury, Washington, DC (invited); David Levine, Attorney, Branch 4, Office of Associate Chief Counsel (International), IRS, Washington, DC (invited)
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  • Unresolved Issues in US International Tax. While global complexity continues to increase, US international tax guidance has slowed. Many technical issues in various areas remain unresolved. This panel will discuss unresolved international tax issues in a number of areas, including issues arising under subpart F, the foreign tax credit and international restructuring. Moderator: Rocco Femia, Miller & Chevalier, Washington, DC Panelists: Seth Goldstein, Deloitte Tax LLP, Washington, DC; Lisa Felix, Grant Thornton LLP, Houston, TX; Doug Poms, Senior Counsel to the International Tax Counsel, Department of Treasury, Washington, DC (invited); Brian Jenn, Attorney Advisor, Office of International Tax Cousel, Department of Treasury, Washington, DC (invited); Anne Devereaux, Special Counsel to the Associate Chief Counsel, Office of Associate Chief Counsel (International), IRS, Washington, DC (invited)
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Session : ABATX1504
Affiliated & Related Corporations
Conference : 2015 Midyear Meeting
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  • Chair: David Friedel, PwC, Washington, DC
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  • The Doctor Is In Corporate Tax Issues Facing Professional Service Providers. When the topic of healthcare reform comes up, most of the attention is focused on what this all means for patients. Costly emergency room visits are expected to decline as more patients with insurance coverage (hopefully) seek more preventive care from primary care physicians, but what are the other implications of this change in consumer behavior? Those patients will get more tests and more screening, they'll be referred to more specialists for earlier treatment, more drugs will be prescribed to treat and manage more chronic illnesses, etc. How will this change the practice of medicine, and what sort of tax issues should we anticipate? Will more doctors form professional service corporations? Will those corporations be able to form affiliated groups and file consolidated returns? How will those growing practice groups manage their diverse billing and medicare reimbursements? What other federal tax issues arise when doctors of various specialties combine their practices together? And what larger lessons do these answers teach us? Moderator: Patrick Spoletini, KPMG LLP, Nashville, TN Panelists: Professor Don Leatherman, University of Tennessee College of Law, Knoxville, TN; Olivia Ley, PwC, Washington, DC; Kevin Ault, PwC, Nashville, TN; Lawrence Axelrod, Special Counsel, Office of Chief Counsel, Corporate, IRS, Washington, DC
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  • Do's and Don'ts with Member Stock and Member Debt. This panel will take a transactional approach to a variety of consolidated return rules to better understand how to separate planning opportunities from pitfalls. We'll consider several transactions and consider why the good ones work and why the bad ones don't. For example, "What happens when a member redeems some of its appreciated common stock for a note? Are the results any different if the member recapitalizes and replaces appreciated common stock with newly-issued non-qualified preferred stock?" "What would happen if a group implemented a purely domestic Killer B Transaction inside a consolidated group?" "Are there planning ideas involving transfers of member stock or intercompany receivables to mitigate (or at least re-direct) the impact of attribute reduction when third-party debt is discharged?" Moderator: Greg Fairbanks, Grant Thornton, Washington, DC Panelists: E.J. Forlini, Deloitte, Washington, DC; Greg Featherman, KPMG LLP, Washington, DC; Lawrence Axelrod, Special Counsel, Office of Chief Counsel, Corporate, IRS, Washington, DC
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Session : ABATX1505
Banking & Savings Institutions
Conference : 2015 Midyear Meeting
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  • Chair: Daniel Mayo, KPMG LLP, New York, NY
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  • Recent Developments. This panel will discuss recent developments affecting the banking community. Moderator: Daniel Mayo, KPMG LLP, New York, NY Panelists: Anthony Tuths, WithumSmith+Brown, New York, NY; Additional Panelists TBD
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  • Reaching Consensus on Capital. While the need for capital in financial institutions is certain, the taxation of the return to capital for a multinational financial institution is far from certain. The OECDs Base Erosion and Profit Shifting (BEPS) action items are bringing fresh attention to this problem. This panel will discuss, from a transfer pricing perspective, the IRS views on the calculation of and compensation due to capital, how these might differ from views held in other jurisdictions and how those differences may be resolved in a competent authority setting. Moderator: Maggie Fritz, KPMG LLP, New York, NY Panelists: John Hughes, Senior Manager, Group 7, APMA Program, IRS, Washington, DC; Lucy Dasisutton, Citigroup Inc., New York, NY; Robert T. Clair, KPMG LLP, New York, NY
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  • Oil and Gas Financing. This panel will explore recent developments, typical structures, and the tax issues with oil and gas financing transactions. Moderator: Mark Price, KPMG LLP, Washington, DC Panelists: John Bradford, Liskow & Lewis, Houston, TX; Scott Joyce, BNP Paribas, Houston, TX; James Reardon, Porter Hedges LLP, Houston, TX
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Session : ABATX1506
Closely Held Businesses
Conference : 2015 Midyear Meeting
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  • Chair: J. Robert Turnipseed, Armbrecht Jackson LLP, Mobile, AL
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  • Closely Held Businesses & Tax Debts: An Update on IRS Collection Procedures and Opportunities for Resolving Outstanding Tax Debts. This panel will review current IRS Collection Procedures from the point of assessment through collection action. The panel will discuss collection tools and techniques, and review collection appeal opportunities. The panel will also review opportunities for closely held businesses to resolve outstanding tax debts, including installment agreements, offersin- compromise and bankruptcy. Panelists: Gregory Wilson, Attorney at Law, San Francisco, CA; Eric L. Green, Green & Sklarz LLC, New Haven, CT; Frank Agostino, Agostino & Associates, Hackensack, NJ Co-Sponsored by: Employment Taxes and Civil and Criminal Penalties
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  • Payroll Tax Debts: The Good, the Bad and the Criminal. This panel will review the issues surrounding payroll tax debts of closely held businesses, focusing on the issue of the continuing increasing of back payroll taxes by closely held businesses, referred to as pyramiding. The panel will also cover when civil payroll tax cases are viewed as criminal cases, and issues surrounding criminal payroll tax prosecutions. Panelists: Eric L. Green, Green & Sklarz LLC, New Haven, CT; Frank Agostino, Agostino & Associates, Hackensack, NJ; Mary Gorman, EY, Washington, DC Co-Sponsored by: Employment Taxes and Civil and Criminal Penalties
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Session : ABATX1507
Estate & Gift Taxes
Conference : 2015 Midyear Meeting
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  • Chair: Laura S. Hundley, Holland & Hart LLP, Boulder, CO
    •
  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since September 2014. Panelists: Jeffrey D. Chadwick, Winstead PC, The Woodlands, TX; Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC; Hannah W. Mensch, Ehrenkranz & Ehrenkranz LLP, New York, NY; Dustin Rever-Ginsburg, Venable LLP, Los Angeles, CA
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  • Estate Planning in the Twilight Zone: US Taxation of Non-Resident Aliens. As if the US tax laws arent complicated enough under normal circumstances, complexity rises to a whole new level when planning for a client who is a non-resident alien. Indeed, you might feel like youve stepped into another dimension. This presentation will describe the unique US income and transfer-tax rules that apply to individuals who are not citizens or residents of the United States, and it will provide suggested planning structures. Panelist: Amy P. Jetel, Beckett Tackett & Jetel PLLC, Austin, TX
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  • Going Through the Drill: An Overview of Oil and Gas In Estates and Trusts. This presentation will cover the basics of oil and gas law and will distinguish among the various kinds of interests royalties, working interests, bonuses, etc. Basic tax issues, both income tax and transfer tax, will be discussed. Panelists: Michael V. Bourland, Bourland Wall & Wenzel PC, Ft. Worth, TX; Alvin J. Golden, Ikard Golden Jones PC, Austin, TX
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  • Business Interests in Trusts. Closely-held businesses have long been the signature element of the American economy. Individuals routinely utilize trusts, motivated by tax and non-tax reasons, to achieve their estate planning goals and objectives. The panelists will focus on various issues that practitioners should consider when structuring and administering trusts to own business interests. Panelists: Benjamin G. Carter, Texas Capital Bank, Dallas, TX; Stephanie Loomis- Price, Winstead PC, Houston, TX
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Session : ABATX1508
Individual and Family Taxation
Conference : 2015 Midyear Meeting
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  • Chair: Laura Baek, Senior Attorney Advisor, Taxpayer Advocate Service, IRS, Washington, DC
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  • The National Taxpayer Advocate Discusses the Taxpayer Bill of Rights and How It Impacts Taxpayers. The IRS adopted the "Taxpayer Bill of Rights" (TBOR) in June 2014. The TBOR document is posted on irs.gov and the ten enumerated rights have been incorporated into a redesigned version of IRS Publication 1, Your Rights as a Taxpayer. By adopting TBOR, the IRS has committed to providing the nation's taxpayers with a better understanding of their rights. The National Taxpayer Advocate will explain these rights and provide further detail about how these rights impact both taxpayers and practitioners as they seek assistance from and work their tax cases before the IRS. Speaker: Nina Olson, National Taxpayer Advocate, IRS, Washington, DC
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  • Breaking Up Is Hard to Do: Protecting Divorcing Spouses From the IRS and Each Other. The presentation will cover tax controversy issues relating to divorce, including: strategies to consider before or during marriage; joint return liability; innocent spouse relief under IRC 6015; use of IRC 66 to avoid community property income; collection of joint and separate liabilities in community property states; strategies before or during a divorce; and ethical issues regarding representation of Husband and Wife. Moderator: Phyllis Horn Epstein, Epstein Shapiro & Epstein PC, Philadelphia, PA Speaker: Larry A. Campagna, Chamberlain Hrdlicka White Williams & Aughtry, Houston, TX; Fred F. Murray, Grant Thornton LLP, Washington, DC
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  • Penalties and Penalty Abatement: A Refresher / Overview. The presentation will focus on numerous penalties relating to individuals including, but not limited to, late filing penalties, late payment penalties, underpayment penalties, other penalties pursuant to section 6662, and how to obtain abatement of any such penalties. Moderator: Jonathan E. Strouse, Harrison & Held LLP, Chicago, IL Panelists: Alex E. Sadler, Ivins Phillips & Baker Chartered, Washington, DC; James Creech, Law Offices of James Creech, Chicago, IL; Kevin E. Packman, Holland & Knight, Miami FL; Kathryn A. Zuba, Deputy Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC
    •

Session : ABATX1509
Investment Management
Conference : 2015 Midyear Meeting
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  • Chair: William P. Zimmerman, Morgan, Lewis & Bockius LLP, Philadelphia, PA
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  • How BEPS Is Changing the International Tax Landscape. The Organization for Economic Cooperation and Development ("OECD")'s Base Erosion and Profit Shifting ("BEPS") initiative has been moving forward at an unprecedented pace. By its design and purpose, the BEPS initiative is realigning and redefining many of the principles of international taxation. This panel will discuss some of the profound changes BEPS is engendering in the tax landscape of select jurisdictions. Our panelists will discuss the legislative and administrative responses by select countries to the BEPS initiative, such as audit activity (in select jurisdictions, including the US) and the changing approaches to negotiated tax arrangements (e.g., tax rulings and APAs) in jurisdictions of focus. Moderator: Puneet Arora, PwC, New York, NY Panelists: David Mayo, Paul Weiss Rifkind Wharton & Garrison LLP, New York, NY; Allison Rosier, PwC, New York, NY; Jay Freedman, KPMG LLP, New York, NY; Carol Tan, Special Counsel to the Deputy, Office of Associate Chief Counsel (International), IRS, Washington, DC
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  • Tender Option Bond Derivatives and Life After Volcker: Tax issues for Market Participants, Including Funds and Banks. This panel will discuss tax issues associated with proposals to address the required restructuring of tender option bond derivatives under the Volcker Rule. Moderator: Deanna Flores, KPMG LLP, San Diego, CA Panelists: Christopher DiJulia, Fidelity Investments, Merrimack, NH; Elizabeth LHommedieu, KPMG LLP, Columbus, OH; John Lutz, McDermott Will & Emery LLP, New York, NY
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  • State Tax Considerations and Developments for Mutual Funds and Their Advisors. This panel will discuss the state tax nexus and apportionment considerations for advisors and the funds, including a focus on recent proposed regulations introduced by California and Massachusetts. Moderator: Jane Steinmetz, EY, Boston MA Panelist: Will Gorrod, Morgan Lewis & Bockius LLP, San Francisco, CA
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Session : ABATX1510
Real Estate
Conference : 2015 Midyear Meeting
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  • Chair: L. Wayne Pressgrove, Jr., King & Spalding LLP, Atlanta, GA
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  • Hot Topics. This panel will briefly discuss the status of the business plan. For the remainder of the panel, the government will share reactions to recent bar association reports on the proposed regulations under sections 707 and 752. Audience participation and comments on those reports and suggestions for the final regulations will be encouraged. Moderator: Jennifer H. Alexander, Deloitte Tax LLP, Washington, DC Panelists: Craig A. Gerson, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Curtis G. Wilson, Associate Chief Counsel, Passthroughs and Special Industries, IRS, Washington, DC
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  • Real Estate Fund Allocation Issues. Mounting pressure to accommodate investor tax sensitivities is causing fund structures and partnership agreements to become more and more complex. This panel will discuss issues relating to fund allocations arising in this current environment. Moderator: James B. Sowell, KPMG, Washington, DC Panelists: A. Cristina Arumi, EY, Washington, DC; Michael Hirschfeld, Dechert LLP, New York, NY
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  • Tenant Improvements and Other Leasing Issues. This panel will discuss lessor and lessee tax treatment of tenant improvement allowances, leasing commissions, and other tax issues common to leasing arrangements. Moderator: Glenn Johnson, EY, Washington, DC Panelist: Jill E. Darrow, Katten Muchin Rosenman LLP, New York, NY
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  • I Think I Have a Busted REIT. What Do I Do Now? This panel will discuss the practical aspects of dealing with a REIT disqualification issue, including attempts to maintain REIT status through savings provisions under section 856(c) and (g), dealing with the IRS in obtaining closing agreements, and other approaches. The panel also will address termination issues when REIT status cannot be maintained. Moderator: Peter J. Genz, King & Spalding, Atlanta, GA Panelists: Dianne O. Umberger, EY, Washington, DC; David B. Silber, Deputy Associate Chief Counsel, Financial Institutions & Products, IRS, Washington, DC
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