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Return to American Bar Association - Section of Taxation Events Library Menu
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2016 Joint Meeting
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Showing sessions 1 - 10 of (39) TOTAL sessions
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Event : ABATX34 |
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Session : ABATX16100
Tax Bridge on the Road
Conference : 2016 Joint Meeting
Speaker(s) :
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- A Conversation with Nina Olson. Nina Olson, the National Taxpayer
Advocate, sits down for an in-depth discussion of her practice, her history,and the latest developments in tax law.
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- The Intersection of Sports and Tax Law. United States federal and state
tax laws impact sports franchises and players in many ways. The panelists
will provide an overview these areas, including state domicile and residency
issues, the so-called Jock Tax, business expenses, international tax issues,
and estate and gift tax issues. The panelists also will provide tax law insights
for attorneys representing professional athletes.
Moderator: Clay Collins, PwC, Washington, DC; Panelists: Travis Greaves, Caplin & Drysdale, Washington, DC; Jason
Feingertz, Reed Smith, New York, NY; Joseph P. Malca, Proskauer Rose LLP,New York, NY; Dustin Rever-Ginsburg, Venable LLP, Los Angeles, CA
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- Tax Court 101: Pre-Trial Tips & Best Practices.
Moderator: Kelley C. Miller, Reed Smith LLP, Washington, DC;
Panelists: Jeffrey M. Glassman, McDermott Will & Emery, Dallas, TX;
Lawrence A. Sannicandro, Agostino & Associates PC, Hackensack, NJ;
Adriana Lofaro Wirtz, Cooley LLP, New York, NY
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- Basics & Hot Topics: RICs and REITs. Regulated investment companies
(RICs) (more commonly known as mutual funds) and real estate investment
trusts (REITs) have long enjoyed significant tax advantages. The panelists
will overview RICs and REITs under subchapter M, addressing the purpose
of RICs and REITs, the qualification requirements for REITs and RICs, and
the taxation of RICs and REITs and their investors. The panel will also
discuss hot topics in the RIC and REIT arenas, such as REIT spinoffs.
Moderator: Richard C. LaFalce, Morgan Lewis, Washington, DC;
Panelists: Monisha Santamaria, EY, Los Angeles, CA; M. Kathryn Seevers,
Ropes & Gray LLP, Boston, MA;
Co-sponsored by: Investment Management and Real Estate
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- Nuts & Bolts: Certain Tax and State Law Repercussions from the
Obergefell Decision. This panel will examine the various theoretical,
procedural, and practice considerations associated with the effect of certain
tax and state law changes as a result of the Obergefell v. Hodges and
Windsor v. United States decisions, with an emphasis on estate planning
and employee benefits. The panelists will explore the changes in the law
as a result of these cases and discuss areas where guidance may still be needed. The discussion will also focus on the retroactive aspects of Obergefell and Windsor as to certain federal and state law aspects of estate
planning.
Moderator: Anne Gordon, Attorney-Advisor, US Tax Court, Washington, DC;
Panelists: George D. Karibjanian, Proskauer Rose LLP, Boca Raton, FL;
Laura R. Westfall, King & Spalding, New York, NY;
Co-sponsored by: Estate & Gift Taxes
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- Hot Topics: Tax Implications of the Sharing Economy.
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Session : ABATX16101
Transfer Pricing
Conference : 2016 Joint Meeting
Speaker(s) :
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MP3 | 
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- Current Transfer Pricing Issues in the Biotechnology and Technology Industries. This session will discuss recent transfer pricing developments as they relate to the biotechnology and technology fields. The panel will be comprised of tax and transfer pricing industry directors who will share their experiences from an intellectual property planning perspective in light of recent BEPS and US legislative developments. In particular, the panel will seek to address key concerns relating to US cost-sharing regulations and recent BEPS guidance with respect to economic substance and profit splits; and the use of multilateral Advance Pricing Agreements in a post-BEPS world.
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- Moderator: Candice King, EY, Boston, MA
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- Panelists: Sarah A. Rana, Hologic Inc., Boston, MA; Richard Olivier, Akamai Technologies, Boston, MA; Rob Filadoro, Alnylam Pharmaceuticals, Boston, MA
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Session : ABATX16102
Capital Recovery & Leasing
Conference : 2016 Joint Meeting
Speaker(s) :
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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: Ryan Corcoran, RSM, Madison, WI;
Panelists: Trevor Salzmann, Grant Thornton, Washington, DC; Kathleen
Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington,
DC; Scott Dinwiddie, Associate Chief Counsel, Income Tax & Accounting,
IRS, Washington, DC
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- Basis Recovery for Assets Subject to the Foreign Sales Corporation
Regime or Extraterritorial Income Exclusions. This panel will discuss
basis recovery for assets subject to the FSC regime or ETI exclusion in
light of the CBS Corp. v. United States decision and the recently released
ILM 201625011, with a focus on taxpayer activity in this space such as
accounting method changes and the use of general asset accounting.
Moderator: George Manousos, PwC, Washington, DC;
Panelists: Kathleen Reed, Branch Chief, Branch 7, Income Tax &
Accounting, IRS, Washington, DC; Carol Conjura, KPMG, Washington, DC
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- Research Credit Current Developments and Issues. This panel will focus
on current developments and issues involving the research credit, with a
focus on the final software regulations applicable to the research credit as
well as certain employment tax ramifications of the research credit such as
how to apply the research credit to startup companies and monetization of
the research credit for employment tax purposes.
Moderator: Mark Andrus, Grant Thornton LLP, Washington, DC;
Panelists: Jaime Park, KPMG, Washington, DC; Ligeria Donis, PwC,
Washington, DC; Bruce Benesh, Grant Thornton LLP, Columbia, SC
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Session : ABATX16103
US Activities of Foreigners & Tax Treaties
Conference : 2016 Joint Meeting
Speaker(s) :
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- Current Developments Relating to Inbound Private Equity and Real
Estate Transactions. This panel will discuss recent tax developments
relating to inbound private equity and real estate (including infrastructure)
transactions. Topics to be discussed include FIRPTA-related developments,
the proposed section 385 regulations, the new partnership audit rules, the
US as a tax haven for foreign investors (common reporting standards), the
IRS restructuring and issue-based audits.
Moderator: Ameek Ashok Ponda, Sullivan & Worcester LLP, Boston, MA;
Panelists: Adam Feuerstein, PwC, Washington, DC; Nicola Lemay, Foley
Hoag LLP, Boston, MA; Joseph E. Ladocsi, Manulife and John Hancock,
Boston, MA; Daniel McCall, Deputy Associate Chief Counsel International
(Technical), IRS Office of Associate Chief Counsel (International),
Washington, DC; Douglas Poms, Deputy International Tax Counsel,
Department of Treasury, Washington, DC
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- Brave New World Implications of the Proposed 385 Regulations on
Inbound Transactions. The breadth of the proposed 385 regulations is still
being absorbed as practitioners consider the significant challenges they
present for US companies and foreign investment in the US. This panel
will address the impact the proposed regulations may have on inbound
transactions including cash management strategies, financing structures and
treaty issues.
Moderator: Scott Harty, Alston & Bird LLP, Atlanta, GA;
Panelists: Ilene Fine, PwC, Washington, DC; Brian Davis, Ivins Philips &
Barker Chartered, Washington, DC; Raymond Stahl, Special Counsel, IRS
Office of Associate Chief Counsel (International), Washington, DC; Brian
Jenn, Attorney Advisor, Office of International Tax Counsel, Department of
Treasury, Washington, DC; Douglas Poms, Deputy International Tax Counsel,
Department of Treasury, Washington, DC
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Session : ABATX16104
Administrative Practice
Conference : 2016 Joint Meeting
Speaker(s) :
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- Important Developments. This panel will discuss current developments and
topics of immediate interest in tax administrative practice. Panel will focus
on recent Treasury and IRS guidance, court decisions, on-going litigation, or
any other items germane to tax administration.
Moderator: James R. Gadwood, Sullivan & Cromwell, New York, NY;
Panelists: Brendan ODell, Attorney-Advisor, Office of Tax Policy, Department
of Treasury, Washington, DC; Drita Tonuzi, Associate Chief Counsel
(Procedure & Administration), Office of Chief Counsel, IRS, Washington, DC
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- Good News, Your Audit Is Over. Or Is It? The Process and Impact of a
Joint Committee Review. The IRS has completed its examination of your
claim for refund and has informed you that it agrees in principle but cant
grant your refund yet. So, whats the hold up? Before the IRS can grant a
refund of over $2 million for an individual and $5 million for a corporation,
the claim must go through review by the Joint Committee on Taxation.
What are the criteria for review and what does this process entail? What
are the responsibilities of the Joint Committee and of the IRS when a
refund is reviewed? What can a taxpayer and their representative do to best
position their case and successfully close out review at the Joint Committee
level? This panel will explore the Joint Committee refund review process,
discuss best practices for successful review, and highlight other procedural
considerations of review, including impact on cases in Appeals.
Moderator: Alex Sadler, Morgan Lewis & Bockius LLP, Washington, DC;
Panelists: Diana Erbsen, Deputy Assistant Attorney General for Appellate
and Review, Department of Justice, Tax Division, Washington, DC; Susan
Mosley, Branch Chief (Procedure & Administration), IRS Office of Chief
Counsel, Washington, DC; John Keenan, Deloitte, Washington, DC
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- International Information Return Penalties from Assessment to
Abatement and All That Is Inbetween. This panel will discuss penalties
associated with international information returns, such as Forms 5471,
Forms 926, and FinCEN Form 114 (FBAR). The panel will review the
Services procedures for penalty assessment, to opportunities for penalty
abatement. Discussion will also include what actions taxpayers can take
when they discover missing or inaccurate international information reporting
forms and how, and if, taxpayers can mitigate penalty exposure through one
of the Services foreign voluntary disclosure programs.
Moderator: Mary I. Slonina, PwC, Washington, DC;
Panelist: Thomas Greenway, KPMG, Boston, MA; Joanne MacDonald, PwC,
Boston, MA
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Session : ABATX16105
Affiliated & Related Corporations
Conference : 2016 Joint Meeting
Speaker(s) :
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- Application of the Proposed Section 385 Regulations to Consolidated
Groups. This panel will explore the application of the proposed regulations
under section 385 in the context of affiliated groups, including potential
deconsolidations, the treatment of partnerships owned by members of a
consolidated group, state tax issues, and consequences resulting from a
debt instrument, debtor or creditor entering or leaving a consolidated group.
Moderator: Wade Sutton, PwC, Washington, DC;
Panelists: Britt Haxton, McDermott Will & Emery LLP, Washington, DC;
Brian Peabody, EY, Washington, DC; Filiz Serbes, IRS Office of Associate
Chief Counsel (Corporate), Washington, DC; Jeffrey Vogel, KPMG,
Washington, DC
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- Do We Really Understand the Consolidated E&P Rules? This panel will
focus on the special consolidated rules applicable to the determination of
earnings and profits when corporations join, leave or liquidate within the
consolidated group. Topics will include the effect of the anti-duplication rules
upon liquidation, whether the anti-duplication rules can revive purged SRLY
E&P, and the allocation of E&P upon a spin-off from the consolidated group.
Moderator: Mark Hoffenberg, KPMG, Washington, DC;
Panelists: Marie Milnes-Vasquez, IRS Office of Associate Chief Counsel
(Corporate), Washington, DC; Stuart Finklestein, Skadden Arps Slate
Meagher & Flom LLP, New York, NY; Olivia Ley Orobona, PwC, Washington,
DC
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Session : ABATX16106
Banking & Savings Institutions
Conference : 2016 Joint Meeting
Speaker(s) :
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- Section 871(m) Compliance Concerns and New Proposed Regulations to
Implement the Qualified Derivative Dealer Regime under Section 871(m).
This panel with discuss compliance concerns with section 871(m) and the
recently issued proposed regulations pertaining to the implementing the new
Qualified Derivative Dealer (QDD) regime applicable to dividend equivalent
payments under section 871(m), which will apply to dividend equivalent
payments received by an electing Qualified Intermediary (QI) and replace
the previously proposed Qualified Securities Lender regime provided in
Notice 2010-46.
Moderator: Yoram Keinan, Carter Ledyard & Milburn, New York, NY;
Panelist: Stevie Conlon, Wolters Kluwer Financial Services, Chicago, IL;
Matthew Stevens, EY, Washington, DC
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- Section 50(d) and Tax Credit Partnerships. This panel will discuss the
recent guidance on section 50(d) and other developments relevant to tax
credit partnerships.
Moderator: Richard Blumenreich, KPMG, Washington, DC;
Panelists: TBD
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- Current Developments. This panel will discuss current developments
relevant to banking and savings institutions.
Moderator: Richard Larkins, EY, Washington, DC;
Panelist: Mark Price, KPMG, Washington, DC
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Session : ABATX16107
Closely Held Businesses (TX) and Business Planning Group (TE)
Conference : 2016 Joint Meeting
Speaker(s) :
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- The Purchase and Sale of a Professional Practice. This panel will discuss
and analyze all business and tax aspects of a complete or partial sale of a
professional practice to another/other professional(s) or to a corporate entity.
The panel will also distinguish the purchase and sale of a professional
practice from other closely-held businesses.
Panelists: Daniel H. McCarthy, Wick Phillips LLP, Fort Worth, TX; Robert J.
Turnipseed, Arbrecht Jackson LLP, Mobile, AL; William P. Prescott, Wickens
Herzer Panza Cook & Batista Co., Avon, OH
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- State Taxation of Trusts Holding Business Interests. The inconsistency
in the tax treatment of trusts among states creates challengesas well as
potential planning opportunitiesfor trusts with contacts in multiple states.
It particularly impacts trusts owning business interests, as those trusts may
need to navigate sourcing rules that also subject trusts to tax in multiple
jurisdictions. This presentation will highlight: (i) the various mechanisms
by which states tax trust income, including a discussion of sourcing
rules and certain traps for the unwary; (ii) constitutional limits to states
taxing authority, with a focus on recent case law; (iii) Delaware, Nevada
and Wyoming incomplete gift non-grantor trusts (DINGs, NINGs and
WINGs); and (iv) potential uniformity initiatives at the state level as to trust
taxation.
Moderator: Karen Sandler Steinert, Fredrikson & Bryron PA, Minneapolis, MN;
Panelists: Tom Myrick, Moore and Van Allen PLLC, Charlotte, NC; Justin T.
Miller, BNY Mellon Wealth Management, San Francisco, CA
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Session : ABATX16109
Individual & Family Taxation
Conference : 2016 Joint Meeting
Speaker(s) :
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- Higher Education Savings and Planning: Tax & Non-Tax Considerations.
This panel will discuss the various ways to plan, save, and pay for higher
education. The panel will compare various savings strategies, including
gifts, UTMA accounts, 529 plans, trusts, and other vehicles. The analysis
will consider both tax and non-tax considerations, including the effect on
financial aid, transaction costs, investor control, income taxes, gift and
estate taxes, flexibility, and even creditor protection. The panel will also
discuss the various tax credits, exclusions, and deductions related to higher
education.
Moderator: Phyllis Horn Epstein, Epstein Shapiro & Epstein PC,
Philadelphia, PA;
Panelists: Professor F. Philip Manns Jr., Liberty University School of Law,
Lynchburg, VA; Professor Timothy M. Todd, Liberty University School of
Law, Lynchburg, VA
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- Tax Attributes of Consumer Debt. This panel will discuss the tax attributes
of and recent developments surrounding consumer debt. In the student
loan forgiveness area, the panelists will discuss Rev. Proc. 2015-57 dealing
with the discharge of certain Federal student loans. Regarding the mortgage
interest deduction, the panelists will examine the decision by the Court
of Appeals for the Ninth Circuit in Voss v. Commissioner, deciding the
interpretation of section 163(h) with regard to the returns of two unmarried
same-sex partners. The panel will also discuss section 108 cancelation of
debt income, the impact of recourse v. non-recourse debt on COD income,
and the limitations of COD income, including insolvency and qualified debt.
Moderator: Victoria Sherlock, KMPG, Houston, TX;
Panelists: Rachel L. Partain, Caplin & Drysdale, New York, NY; Norma C.
Rotunno; Senior Technician Reviewer, Office of Associate Chief Counsel (Income Tax & Accounting) (Branch 2), IRS, Washington, DC; Professor
Theodore S. Sims, Boston University School of Law, Boston, MA; Donna
Welsh, Senior Technician Reviewer, Office of Associate Chief Counsel
(Income Tax & Accounting) (Branch 4), IRS, Washington, DC
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- Ethical Considerations in Individual and Family Representation. This
panel will provide tax practitioners with an overview of ethical considerations
applicable in the representation of individuals and families. The panel will
discuss ethical issues involving scope of representation, conflicts of interest
in joint representation, disclosures to the IRS, and the duty of confidentiality.
Moderator: Stephanie Coleman, Legal Aid of West Virginia, Charleston, WV;
Panelists: Jamie Andree, Indiana Legal Services, Bloomington, IN; D. Sean
McMahon, McMahon & Associates, Boston, MA; Brendan Shea, Law Office
of Brendan Shea, Boston, MA;
Co-Sponsored by: Pro Bono & Tax Clinics
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Session : ABATX16110
Investment Management
Conference : 2016 Joint Meeting
Speaker(s) :
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- Partnership Audit Reform and Private Funds. This panel will discuss the
recently-enacted partnership audit reform rules in the Bipartisan Budget Act
of 2015. After a brief overview of the new rules, the panel will focus on the
current impact on new and existing fund documents and negotiations. The
panel will also discuss Treasurys priorities for forthcoming guidance and
how guidance might affect structuring and negotiations for new investment
funds.
Moderator: Kat Gregor, Ropes & Gray LLP, Boston, MA;
Panelists: Glenn E. Dance, Special Counsel to the Associate Chief Counsel
(Passthroughs and Special Industries), IRS Office of Chief Counsel,
Washington, DC; Kip Cawley, Foley Hoag LLP, Boston, MA; Raj Tanden,
Foley & Lardner LLP, Los Angeles, CA
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- Current Legislative and Regulatory Initiatives Impacting Regulated
Investment Companies. This panel will examine the current legislative and
regulatory initiatives potentially impacting regulated investment companies,
including the Modernization of Derivatives Tax Act of 2016 discussion draft.
The panel will also discuss recent IRS guidance and other topics of current
interest to regulated investment companies, including money market reform.
Moderator: Jason Paul Traue, Morgan Lewis & Bockius LLP, Boston, MA;
Panelists: Stephen Fisher, EY, Boston, MA; Roger Wise, Stradley Ronan
Stevens & Young LLP, Washington, DC
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- Managing the Special Tax Issues Presented by Sovereign Wealth Fund
Investors in US-Domiciled Funds. This panel will explore the special tax
issues presented by inbound investments into the United States by sovereign
wealth funds, with a particular focus on real estate funds and privately
managed funds.
Moderator: Amy B. Snyder, The Vanguard Group Inc., Malvern, PA;
Panelists: William L. McRae, Cleary Gottlieb Steen & Hamilton LLP, New
York, NY; Rom Watson, Ropes & Gray LLP, Boston, MA
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Showing sessions 1 - 10 of (39) TOTAL sessions
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