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2014 May 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 (45) TOTAL sessions
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Event : ABATX27

Session : ABATX1447
Tax Bridge to Practice
Conference : 2014 May Meeting
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$60.00

Nuts & Bolts Series: The Affordable Care Act and Employer Shared Responsibility Penalty. This panel will explore the flexibility and the consequences of the various employer choices and the records necessary to develop and respond to the assessable penalty under the final shared responsibility penalty and the related reporting requirements under sections 6055 and 6056. Panelists will review the decisions that must be made under the final 4980H regulations and how those decisions may or may not impact other human resource policies and employers reporting obligations related to health reforms pay or play penalty. Moderator: Greta E. Cowart, Winstead PC, Dallas, TX Panelists: Ligeia Donis, Senior Technician Reviewer, Office of Division Counsel & Associate Chief Counsel (Tax Exempt and Government Entities), IRS, Washington, DC; Kathryn C. Johnson, Senior Attorney, Office of Division Counsel & Associate Chief Counsel (Tax Exempt and Government Entities), IRS, Washington, DC; Julie Burbank, Senior Counsel, Chevron, San Francisco, CA

Nuts & Bolts Series: International Tax Enforcement: FBARs, FATCA, and More. The Department of Treasury and the IRS have devoted significant time and resources to increasing enforcement of international tax reporting requirements for both individuals and entities. The various offshore voluntary disclosure programs have been somewhat overshadowed by FATCAs new requirement for reporting by non-US entities and by the Department of Justices Swiss Bank program. This panel will discuss information reporting required by US persons with connections outside the United States. The panelists will review the often times devastating penalties associated with non-compliance and highlight several remedies (both formal and informal) that may be available to taxpayers. Moderator: O.A. Ishmael, EY, Chicago, IL Panelists: Dianne C. Mehany, Caplin & Drysdale, Washington, DC; Diana Imholtz, Senior Technician Reviewer, Office of Associate Chief Counsel (International), IRS, Washington, DC; Kamela Nelan, Attorney-Advisor, Office of Associate Chief Counsel (International), IRS, Washington, DC

Nuts & Bolts Series: Trying Cases Before the Tax Court. Practicing before the Tax Court is different than practicing before other federal or state courts. This panel will address the various procedural and ethical aspects of practicing before the Tax Court. Practical considerations will be provided from members of the judiciary, the government, and the private bar. Moderator: Jairo G. Cano, Agostino & Associates, PC, Hackensack, NJ Panelists: The Honorable Ronald L. Buch, Judge, United States Tax Court, Washington, DC; Monica E. Koch, Associate Area Counsel, Office of Division Counsel (Small Business/Self-Employed), IRS, Westbury, NY; Sara G. Neill, Capes Sokol Goodman Sarachan PC, St. Louis, MO

2014 Tax Bridge to Practice Keynote - Lessons from Practice: A Conversation with Eric Solomon. In this year's Tax Bridge to Practice Keynote, Eric Solomon, Director of National Tax at EY, will offer reflections and lessons from his distinguished career including, his early private practice through his tenure as Assistant Secretary for Tax Policy at the Department of Treasury and his current role at EY. Mr. Solomon is an oft-sought expert on emerging topics in taxation and, continuing that tradition here, he will also offer his thoughts on some of most 'hot topics' in tax, such as inversions. Moderator: Kelley C. Miller, Reed Smith, Washington, DC Panelist: Eric Solomon, EY, Washington, DC

Top Ten Tax Trends of 2014. This panel will discuss the top 10 tax issues facing taxpayers in 2014. The issues will span multiple practice areas, including international and SALT. Moderator: Stephanie A. Fiumara, Bloomberg BNA, Arlington, VA Panelists: Nina E. Olson, National Taxpayer Advocate, Taxpayer Advocate Service, IRS, Washington, DC; Joan C. Arnold, Pepper Hamilton LLP, Philadelphia, PA; Alice G. Abreu, Temple University Beasley School of Law, Philadelphia, PA; Caroline D. Ciraolo, Rosenberg Martin Greenberg LLP, Baltimore, MD; Kelley C. Miller, Reed Smith, Washington, DC

Session : ABATX1448
Low Income Taxpayers Representation Workshop
Conference : 2014 May Meeting
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$45.00

Handling Communication Breakdowns. This panel will discuss practical and ethical issues in dealing with non-responsive clients. Whether lack of response is due to circumstances beyond your clients control (domestic violence, overseas military, lack of permanent residence, deportation, etc.) or avoidance due to lack of an understanding of the role of the practitioner or even willful unresponsiveness what are your legal and ethical obligations as a practitioner? How do you get the non-responsive to respond? Moderator: Andrew VanSingel, Prairie State Legal Services, Inc., Bloomington, IN Panelists: Jamie Andree, Indiana Legal Services, Inc., Bloomington, IN; Robert Malone, Acting Chief, Legal Analysis Branch, Office of Professional Responsibility, IRS, Washington, DC; LTC Susan E. Mitchell, Deputy Chief, Legal Assistance Policy Division, Office of the Army Judge Advocate General, Washington, DC

Communicating with Immigrant Communities. Effectively communicating with immigrant communities means more than just speaking another language. Tax practitioners have to deal with cultural differences and, often, distrust. This panel will explore how to effectively communicate with these communities and how to bridge cultural gaps including differences in socio-economic and political backgrounds. Panelists: Ana C. Lopez, The Cecilia Lopez Law Firm, PLLC, Pasco, WA; Avideh Moussavian, National Immigration Law Center, Washington, DC; Professor Kathryn Sedo, University of Minnesota Law School, Minneapolis, MN

Communicating with Third Parties. This panel will explore ways to deal with the challenges in communicating with and obtaining information from third parties including: financial institutions, credit reporting agencies, medical offices (HIPAA/CMIA), schools and universities (FERPA), non-tax judiciary & administration, intervenors and other third parties commonly encountered when representing clients. Panelists: Professor Jack Snyder, University of Baltimore School of Law, Baltimore, MD; Professor George Willis, Chapman University Fowler School of Law, Orange, CA

Session : ABATX1449
Administrative Practice and U.S. Activities of Foreigners and Tax Treaties
Conference : 2014 May Meeting
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$15.00

Administrative Practice - Chair: Kevin Johnson, Pepper Hamilton LLP, Philadelphia, PA

Meeting the Ethical Challenges of Inbound Controversies.  This program will focus on ethical issues relating to inbound tax controversies including, among other things, document access, client expectations, and dealing with countries with different legal systems and cultures than the U.S. The program will focus on tax issues, but also will address non-tax ethical issues that tax lawyers must consider (e.g., apparent bribery, money laundering, securities, export control, and anti-trust violations). The program will also consider ethical issues in the transition from transaction to controversy, where the litigating attorney previously helped structure the inbound transaction. Moderator: Bruce Zagaris, Berliner Corcoran & Rowe L.L.P., Washington, DC Panelists: Dianne Mehany, Caplin & Drysdale, Washington, DC; Fred Murray, Grant Thornton LLP, Washington, DC; Karen Hawkins, Director, Office of Professional Responsibility, IRS, Washington, DC; Diana Wollman, Director, International Strategy, Large Business and International Division, IRS, Washington, DC (invited). Co-Sponsored by: U.S. Activities of Foreigners and Tax Treaties

U.S. Activities of Foreigners and Tax Treaties - Chair: David G. Shapiro, Shapiro Tax Law LLC, Philadelphia, PA

Meeting the Ethical Challenges of Inbound Controversies.  This program will focus on ethical issues relating to inbound tax controversies including, among other things, document access, client expectations, and dealing with countries with different legal systems and cultures than the U.S. The program will focus on tax issues, but also will address non-tax ethical issues that tax lawyers must consider (e.g., apparent bribery, money laundering, securities, export control, and anti-trust violations). The program will also consider ethical issues in the transition from transaction to controversy, where the litigating attorney previously helped structure the inbound transaction. Moderator: Bruce Zagaris, Berliner Corcoran & Rowe LLP, Washington, DC Panelists: Dianne Mehany, Caplin & Drysdale, Washington, DC; Fred Murray, Grant Thornton LLP, Washington, DC; Karen Hawkins, Director, Office of Professional Responsibility, IRS, Washington, DC; Diana Wollman, Director, International Strategy, Large Business and International Division, IRS, Washington, DC (invited) Co-Sponsored by: Administrative Practice

Session : ABATX1450
Capital Recovery & Leasing
Conference : 2014 May Meeting
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$30.00

Chair: Glenn Johnson, EY, Washington, DC

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: Christian Wood, Eide Bailly LLP, Minneapolis, MN 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; Sam Weiler, EY, Washington, DC; Glenn Johnson, EY, Washington, DC

Accounting for Certain Payments for the Use of Property or Services Under Section 467. This panel will discuss the general applicability of Section 467, the ramifications associated with applying Section 467, as well as common issues and questions brought about by this code section and its attendant regulations. Moderator: Kate Abdoo, McGladrey LLP, Washington, DC Panelists: Steve Toomey, Senior Counsel, Branch 4, Income Tax & Accounting, IRS, Washington, DC; Forest Boone, Attorney, Associate Chief Counsel Income Tax & Accounting, IRS, Washington, DC; Glenn Johnson, EY, Washington, DC

Tangible Property Regulations Update Continuation from the Midyear Meeting Transition Guidance Discussion, FAQs, and an Update on the Proposed Regulations. This panel will continue our discussion around the tangible property regulation transition guidance, 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: Ellen McElroy, Pepper Hamilton LLP, 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 Income Tax & Accounting, IRS, Washington, DC; David Auclair, Grant Thornton LLP, Washington, DC

Session : ABATX1451
Investment Management
Conference : 2014 May Meeting
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$30.00

Chair: William P. Zimmerman, Morgan Lewis & Bockius LLP, Philadelphia, PA

FATCA Update for Onshore and Offshore Private Investment Funds: Risks, Responsibilities and Oversight. This panel will consider the impact on U.S. and offshore private investment funds in light of the latest FATCA developments, including the revised regulations, other 2014 guidance, and the latest Model 1 and Model 2 intergovernmental agreements. Topics will include the duties of responsible officers, withholding responsibilities, delayed effective dates, role of counsel, international implementation of FATCA and outlook for additional developments, among others. Moderator: Joseph A. Riley, Willkie Farr & Gallagher LLP, New York, NY Panelists: Kathleen Celoria, Executive Director, DMS Offshore Investment Services Ltd, New York, NY; Julia Tonkavich, Office of International Tax Counsel, Office of Tax Policy, Department of Treasury, Washington, DC

IRS Office of Chief Counsel Update on Regulated Investment Company Issues. This panel will discuss current issues being considered by the IRS Office of Chief Counsel regarding RICs including the private letter ruling process, asset diversification test issues with respect to derivatives and implementation of RIC savings provisions. Moderator: Richard LaFalce, Morgan Lewis & Bockius LLP, Washington, DC Panelists: David B. Silber, Deputy Associate Chief Counsel (Financial Institutions & Products), Office of Chief Counsel, IRS, Washington, DC; Julanne Allen, Assistant Branch Chief, BR:3 (Financial Institutions & Products), Office of Chief Counsel, IRS, Washington, DC

Current Issues Being Addressed by the Investment Company Institute. This panel will discuss current legislative, regulatory and international tax issues affecting RICs and their shareholders. Moderator: Karen Gibian, Investment Company Institute, Washington, DC Panelists: Keith Lawson, Investment Company Institute, Washington, DC; Ryan Lovin, Investment Company Institute, Washington, DC; Gregory Hinkle, Chair of ICI Tax Committee, T. Rowe Price, Baltimore, MD

Session : ABATX1452
Real Estate
Conference : 2014 May Meeting
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$30.00

Chair: Jon G. Finkelstein, McDermott Will & Emery LLP, Washington, DC

Hot Topics. This panel will discuss recent developments, including legislation, regulations, administrative guidance and noteworthy cases in both the real estate and partnership areas. Moderator: Robert J. Crnkovich, EY, Washington, DC Panelists: Donna M. Young, Deputy Associate Chief Counsel (Passthroughs and Special Industries), Office of Chief Counsel, IRS, Washington, DC; Craig A. Gerson, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC

Section 1234A, Pilgrims Pride, Abandonment, and Capital vs. Ordinary Losses. This panel will discuss the Tax Courts opinion in Pilgrims Pride and its effect on abandoning equity in real estate investment structures. Moderator: Peter J. Genz, King & Spalding LLP, Atlanta, GA Panelist: Jeffrey Maddrey, PwC, Washington, DC

Risky Risk of Loss and Disguised Sale Proposed Regulations (Part I). This panel will discuss the recently issued proposed regulations under Sections 707 and 752 that would amend certain of the rules on disguised sales of property between a partner and its partnership and on allocations of partnership liabilities. This discussion will continue in the afternoon with a subsequent panel sponsored by the Partnerships Committee. Moderator: Richard M. Lipton, Baker & McKenzie LLP, Chicago, IL Panelists: Julie M. Marion, Latham & Watkins LLP, Chicago, IL; Craig A. Gerson, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Mary Beth Carchia, Senior Technician Reviewer (Passthroughs and Special Industries), Office of Chief Counsel, IRS, Washington, DC

Session : ABATX1453
Estate and Gift Taxes
Conference : 2014 May Meeting
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$30.00

Chair: Derek L. Fletcher, U.S. Trust, Dallas, TX

Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since January 2014. 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

Venn Diagrams: Meet Me at the Intersection of Estate & Income Tax (Planning in the ATRA-Math). Post-ATRA planning for larger estates will increasingly focus on income tax planning, the management of tax basis, and maximizing the step-up in basis at death. This presentation will discuss: measuring the transfer tax costs (including state estate and inheritance taxes) against the income tax savings from the step-up on different types of assets; recapturing assets that have already been transferred; multiplying the applicable exclusion amount; using trust and partnership elections, distributions, and reorganizations to maximize the step-up and split income across taxpayers; and using debt to reduce estate tax exposure but maximize the step-up. Panelist: Paul Lee, Bernstein Global Wealth Management, New York, NY

Planning for Estates Under $10 Million. Estate planning for clients who may not be subject to the federal estate tax is often not as straightforward as it might first appear. Planners have to balance numerous objectives, such as maximizing income tax basis on death, minimizing state estate tax in a decoupled state, asset protection goals, simplicity and cost efficiency. This presentation will focus on the estate planning issues faced by these clients and the planning solutions that can be incorporated to address their varied planning needs. Panelist: Mark R. Parthemer, Bessemer Trust, Palm Beach, FL

Session : ABATX1454
Affiliated and Related Corporations
Conference : 2014 May Meeting
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Chair: Matthew Gareau, Deloitte Tax LLP, Washington, DC

Debt Shmebt: What's Really at Stake If a Related Party Note Is Recast as Equity? Everyone knows the IRS and State tax authorities think about denying the borrower's interest deduction. And everyone knows the IRS is less inclined to challenge intercompany debt as this would probably not generate a net adjustment. Rather than getting bogged down in the usual suspect debate surrounding debt versus equity characterization, this panel will explore the broad range of additional collateral consequences that could arise when a purported debt instrument is treated as equity. Moderator: David Friedel, PwC, Washington, DC Panelists: Jon Zelnik, KPMG, Washington, DC; Rob Ozmun, PwC, Boston, MA; Corina Trainer, PwC, Washington, DC

Dont Forget Your Passport: The Intersection Between the Consolidated Return Regulations and International Tax. In todays global economy, U.S. consolidated groups are increasingly encountering complex international tax rules in the course of planning and compliance. This panel will explore rules and issues encountered when applying international tax provisions to consolidated groups. Topics may include foreign tax credits, overall foreign losses, overall domestic losses, and dual consolidated losses. Time permitting, we will also consider the interplay between the intercompany transaction rules and international tax issues including the determination of section 1248 amounts, treatment of income as U.S. or foreign source for foreign tax credit purposes, and foreign currency gains and losses under sections 987 and 988. Moderator: Mark Schneider, Deloitte Tax LLP, Washington, DC Panelists: John Merrick, Office of Associate Chief Counsel, International, IRS, Washington, DC; Mike Wilder, McDermott Will & Emery, Washington, DC; Wade Sutton, PwC, Washington, DC; Chris Trump, Deloitte Tax LLP, Washington, DC

Session : ABATX1455
Tax Policy and Simplification
Conference : 2014 May Meeting
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Chair: Professor Jonathan B. Forman, University of Oklahoma, Norman, OK

Do Inversions Matter? How Should Inversion Transactions Affect Our Thinking About U.S. International Tax Reform? Since Congress added section 7874 as part of American Jobs Creation Act of 2004, there have been significant limitations on the ability of U.S. corporate groups to obtain the tax benefits previously available from entering into inversion transactions, and successive IRS guidance has further limited the ability of U.S. corporate groups to successfully invert. This panel will explore how concerns regarding inversion transactions should (or should not) inform the ongoing debate about U.S. international tax reform. Moderator: Professor Itai Grinberg, Georgetown Law School, Washington, DC Panelists: Ronald Dawbrowski, Special Counsel, Office of Tax Policy, Department of Treasury, Washington, DC (invited); Professor Mihir A. Desai, Harvard Business School & Harvard Law School, Cambridge, MA; Jefferson VanderWolk, EY, Washington, DC

Corporate Tax Aggressiveness. This panel will discuss common themes of corporate tax aggressiveness, including signs of tax aggressiveness, financial accounting objectives, risks and challenges of tax-focused transactions, and industry and enforcement perspectives on aggressive transactions. Moderator: Professor Stephen E. Shay, Harvard Law School, Cambridge, MA Panelists: Professor J. Richard (Dick) Harvey, Jr., Villanova School of Law, Villanova, PA; Professor Edmund Outslay: Michigan State University, East Lansing, MI Co-Sponsored by: The American Tax Policy Institute

Session : ABATX1456
Individual and Family Taxation
Conference : 2014 May Meeting
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Chair: Laura Baek, Taxpayer Advocate Service, IRS, Washington, DC

Taxpayer Uncertainty from Damage Awards and Settlements. Business and non-business related damage awards and settlements may give rise unexpectedly to income. While a taxpayer may attempt to structure those awards to minimize the realization of income, the Tax Court, as related in Blackwood, M., (2012) TC Memo 2012-190, RIA TC Memo 2012-190, 104 CCH TCM 27 may upend those expectations with its own examination and analysis of the actual underlying dispute. With new medical advances in fertility, the Tax Court is the arena for novel damage award arguments. The Taxpayer Advocate Service has issued its own recommendations in this area in an attempt to reduce the high level of uncertainty in reporting damage awards and settlements. Moderator: Phyllis Horn Epstein, Epstein, Shapiro & Epstein, PC, Philadelphia, PA Panelists: Joshua R. Beck, Taxpayer Advocate Service, IRS, Washington, DC; Andrew Keyso, Office of Chief Counsel, IRS, Washington, DC; Shareen Pflanz, Office of Chief Counsel, IRS, Washington, DC; Mona Hymel, University of Arizona, Tucson, AZ

Eggshell Audits and Avoiding a Criminal Referral. An eggshell audit is one in which the client and the representative are aware of potential indicators of civil fraud or criminal tax violations that have not yet come to the attention of the IRS. The primary goal in these audits is to avoid a referral by the revenue agent to the IRS Criminal Investigation Division (CI). The panelists will discuss various aspects of eggshell audits, including issues raised at the beginning of an audit, applicable privileges, how to deal with the client, how to conduct a shadow investigation, how to work with the agent, common indicators of fraud, and IRS fraud development procedures. Moderator: Alex E. Sadler, Ivins, Phillips & Barker, Washington, DC Panelists: Larry A. Campagna, Chamberlain, Hrdlicka, White, Williams & Aughtry, Houston, TX; Caroline D. Ciraolo, Rosenberg Martin Greenberg LLP, Baltimore, MD

Learning the Basic Rules and Staying Updated on Recent Changes to Requesting Innocent Spouse Relief. Treas. Reg. 1.6015-5(b) requires a taxpayer seeking equitable innocent spouse relief under IRC 6015(f) to request relief within two years after the IRS commenced certain collection activity against that taxpayer. However, in 2011 the IRS announced it would consider certain requests for equitable relief under IRC 6015(f) without regard to when the first collection activity was taken, and in 2013 published a proposed revision of Treas. Reg. 1.6015-5(b). In addition, in 2013 the IRS issued Revenue Procedure 2013-34, which supersedes earlier guidance on how the IRS evaluates requests for relief under IRC 6015(f). This panel will discuss these changes and how Tax Court decisions have referenced or interpreted Revenue Procedure 2013-34. Moderator: Jill MacNabb, Taxpayer Advocate Service, IRS, Washington, DC Panelists: Kathryn Sedo, University of Minnesota Law School, Minneapolis, MN; Jamie Andree, Indiana Legal Services, Inc., Bloomington, IN; Christine Speidel, Vermont Legal Aid, Inc., Springfield, VT

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