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2015 May 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 (48) TOTAL sessions
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Event : ABATX30

Session : ABATX1546
Low Income Taxpayers Representation Workshop
Conference : 2015 May Meeting
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$45.00


  • The Pro Bono & Tax Clinics Committee proudly presents the annual workshop for new and pro bono practitioners.
  • Client Intake to Filing a Tax Court Petition. This panel will cover issues from the initial client intake process through the filing of a petition in the Tax Court. Areas addressed will include proper vetting of potential clients, the information gathering process and resolving disputes administratively, and tips on drafting and filing the petition and related attachments. Panelists:Professor Robert G. Nassau, Syracuse University College of Law, Syracuse, NY; Jane Zhao, McDermott Will & Emery LLP, Chicago, IL; Jamie Andree, Indiana Legal Services, Inc., Bloomington, IN
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  • Tax Court Pre-Trial Practice. This panel will illustrate how to navigate a Tax Court case after the petition is filed but before trial. Areas addressed will include strategies for settlement (with IRS counsel and Appeals), discovery, stipulations of fact, motions, and submitting cases fully stipulated under Rule 122. Moderator:Kevin Spencer, McDermott Will & Emery LLP, Washington, DC Panelists:The Honorable Lewis R. Carluzzo, Special Trial Judge, US Tax Court, Washington, DC; Professor Keith Fogg, Villanova Law School, Villanova, PA; Debra K. Moe, Deputy Division Counsel (Small Business / Self-Employed Division), IRS, Washington, DC
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  • Tax Court Trial and Appeals. This panel will discuss trying a case in the Tax Court. Topics covered will include filing the pre-trial memorandum, preparing and using witnesses at trial, submitting documents into evidence, brief writing, Rule 155 computations, and whether and how to appeal a Tax Court decision. The panel will also discuss trying a case picked up at the Calendar Call. Moderator:Susanna Ratner, SeniorLAW Center, Philadelphia, PA Panelists:The Honorable Peter J. Panuthos, Chief Special Trial Judge, US Tax Court, Washington, DC; Timothy Jacobs, Hunton & Williams, Washington, DC; Richard G. Goldman, Acting Deputy Associate Chief Counsel (Procedure & Administration), IRS, Washington, DC
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  • Handling a Section 6015 Case. This panel will discuss issues relating to litigating a case under section 6015. Topics covered will include intervenors, privacy concerns, and demonstrating that relief should be granted. Moderator:Susan Morgenstern, Local Taxpayer Advocate, Cleveland, OH Panelists:The Honorable Joseph R. Goeke, Judge, US Tax Court, Washington, DC; Andrew R. Roberson, McDermott Will & Emery LLP, Chicago, IL; Charles A. Hall, Special Counsel (Procedure and Administration), IRS, Washington, DC
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Session : ABATX1547
Tax Bridge to Practice
Conference : 2015 May Meeting
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$45.00


  • Sponsored by:Young Lawyers Forum and Diversity.
  • Nuts & Bolts: Introduction to Life Insurance Company & Contracts Taxation. Ideal for new practitioners, the panel will provide an introduction to the taxation of life insurance companies and their contracts, including life insurance contracts and annuities. Panelists will discuss why life insurance companies receive unique treatment under the Internal Revenue Code and explain key concepts and terms so that new practitioners will be able to handle assignments in this area with confidence. Moderator:Graham R. Green, Sutherland Asbill & Brennan LLP, Washington, DC Panelists:Alexis MacIvor, Chief, Office of Associate Chief Counsel (Financial Institutions & Products), IRS, Washington, DC; Alison R. Peak, Davis & Harman LLP, Washington, DC; Mandana Parsazad, American Council of Life Insurers, Washington, DC Co-Sponsored by:Insurance Companies
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  • Nuts and Bolts: Federal Estate, Gift and Generation-Skipping Transfer Tax. This program will give a brief overview of the Federal estate, gift, and the generationskipping transfer tax concepts. The panelists will give practice tips on basic planning techniques, including trusts for spouses and children. The presentation will also include common issues facing same-sex couples and transfers to non-citizens. Moderator:Jane Zhao, McDermott Will & Emery, Chicago, IL Panelists:Hannah Mensch, Ehrenkranz & Ehrenkranz LLP, New York, NY; Christopher G. Murrer, Venable LLP, Washington, DC Co-Sponsored by:Estate & Gift Taxes
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  • Tax Tales: The Seminal Cases of Subchapter C. Boris Bittker and James Eustice once wrote, ...a corporation is like a lobster pot: easy to enter, difficult to live in, and painful to get out of. From poor Mrs. Kass to the mighty General Utilities Company, each taxpayer has a grand story of struggle in the corporate form. This panel will breathe life into some essential corporate tax cases with the goal of emphasizing the unique narratives of the taxpayers involved and how each earned a place in the glorious pantheon of tax law. Moderator:Michelle Lo, Linklaters, New York, NY Panelists:Gary Scanlon, EY, Chicago, IL; Rose E. Jenkins, Attorney, Branch 2, Office of Associate Chief Counsel (International), IRS, Washington, DC; Alfred Bae, KPMG, Houston, TX Co-Sponsored by:Corporate Tax
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  • On the Road Toward Diversity and Inclusion: Leading to Opportunities for All. (Elimination of Bias)Join the Financial Transactions Committee for an engaging conversation regarding the progress made and work remaining to adhere to the ABAs commitment to promote diversity in the legal profession. More and more businesses view diversity as a priority, not only in their own companies, but also in their relationships with service providers. The panelists will share views on how mentorship and opportunity fosters diversity of professionals and results in teams that deliver the highest level of client service. Drawing on their varied experiences, the panelists will offer suggestions for creating a culture of inclusivity that can lead to enhanced productivity and long-standing business relationships. Moderator:Lena Y. Hines, PwC, Washington, DC Panelists:Frank J. Jackson, DLA Piper, New York, NY; Pamela F. Olson, PwC, Washington, DC; Richard G. Larkins, EY, Washington, DC; Kristen Garry, Shearman & Sterling LLP, Washington, DC Co-Sponsored by:Financial Transactions
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Session : ABATX1590
Foreign Activities of US Taxpayers THURSDAY
Conference : 2015 May Meeting
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$15.00


  • Chair:Joseph Calianno, Grant Thornton LLP, Washington, DC
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  • Young Lawyers Panel. The panel will cover inbound and outbound international tax topics that are complementary to, and provide relevant background regarding, the other USAFTT and FAUST panels at the conference. The panel is targeted towards younger practitioners with an interest or background in international tax. Panelists:Cheryl C. Magat, Toronto, ON; Janine Burman-Gage, EY, New York, NY; Clayton H. Collins, PwC, Washington, DC; John D. Bates, BakerHostetler, Washington, DC
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Session : ABATX1548
Banking & Savings Institutions and Investment Management Joint Panel
Conference : 2015 May Meeting
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  • Banking & Savings Institutions Chair:Daniel Mayo, KPMG LLP, New York, NY
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  • Investment Management Chair:William P. Zimmerman, Morgan, Lewis & Bockius LLP, Philadelphia, PA
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  • The Tax Hedging Rules Revisited. Financial institutions routinely use hedging transactions to manage risks related to governments in commodities and securities prices, currencies, and interest rates. Nevertheless, the current US tax hedging rules are insufficient to accommodate the growing need of financial institutions to manage such risks. This panel will explore the history and current state of the tax hedging rules, present the drawbacks and limited scope of the current regime, and put forth a proposal for modernizing the hedging rules. Moderator:Yoram Keinan, Carter Ledyard & Milburn LLP, New York, NY Panelists:David Garlock, EY, Washington, DC; Karl Walli, Senior Counsel (Financial Products), Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Amy B. Snyder, The Vanguard Group Inc., Malvern, PA; Mark Perwien, Senior Advisor to the Industry Director (Financial Products), IRS, New York, NY

Session : ABATX1549
Capital Recovery and Leasing
Conference : 2015 May Meeting
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$30.00


  • 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:Tracy Watkins, 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; Kate Abdoo, McGladrey LLP, Washington, DC
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  • Tangible Property Regulations and the Real Estate Industry. This panel will feature a cross-section of practitioner, government, and industry personnel and will provide a discussion around the effects that the tangible property regulations have had on the real estate industry and on various asset types (residential and nonresidential) with a focus on leasehold and tenant issues. Moderator:Alison Jones, EY, Washington, DC Panelists:Kathleen Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS, Washington, DC; Tom Yeates, EY, Philadelphia, PA
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  • Tangible Property Regulations Update Continuation from the September Meeting Industry Issues/Guidance, FAQs, and Related Discussions. This panel will continue our discussion around the tangible property regulations specifically with respect to implementation issues faced by certain industries, as well as common tangible property regulation-related questions seen in the marketplace. Moderator:Rayth Myers, EY, 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; Rachelle Bernstein, National Retail Federation, Washington, DC
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Session : ABATX1550
Affiliated & Related Corporations
Conference : 2015 May Meeting
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$30.00


  • Chair: David Friedel, PwC, Washington, DC
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  • Current Developments. This panel will address recent significant consolidated return regulations including the proposed "Next Day" rules as well as the final "Agency" rules. Moderator:Olivia Ley, PwC, Washington, DC Panelists:David Auclair, Grant Thornton LLP, Washington, DC; Neil Barr, Davis Polk & Wardwell LLP, New York, NY; Marie Milnes-Vasquez, Special Counsel, Associate Chief Counsel Corporate, IRS, Washington, DC; Russell Jones, Senior Counsel, Associate Chief Counsel Corporate, IRS, Washington, DC
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  • More Known Unknowns How do Members of Consolidated Groups Recover Previously Taxed Income? Consolidated groups are expanding internationally. Their foreign investments typically include entities that are disregarded for US tax purposes, entities that are treated as partnerships, and entities that are treated as corporations. When those regarded corporations (CFCs) generate subpart F income (or make investments in certain US property), the direct or indirect US shareholder faces current cashless income inclusions. Here are two things we know. We know the US shareholder is permitted to increase its adjusted basis in something to prevent inappropriate double-taxation in the event of a subsequent disposition. And we know that the US shareholder is supposed to treat subsequent distributions as tax-free (with commensurate stock basis reductions) since thats just a receipt of previously taxed income. There are several things we dont know. Some of those are separate company unknowns (like how should the PTI pools of E&P and the section 961 basis associated therewith be allocated in connection with otherwise tax-free spin-off transactions? and exactly where should the basis increases and decreases be applied when theres a chain of foreign corporations owned through partnerships?). In this panel well explore some of the consolidated return unknowns, with particular emphasis on the proposed section 959 regulations. Moderator:Matthew White, KPMG LLP, Washington, DC Panelists:Ronald Dabrowski, KPMG LLP, Washington, DC; Michael DiFronzo, PwC, Washington, DC; Michael Wilder, McDermott Will & Emery, Washington, DC; Marjorie Rollinson, Deputy Associate Chief Counsel (Technical), IRS Office of the Associate Chief Counsel International, Washington, DC
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Session : ABATX1551
Estate & Gift Taxes
Conference : 2015 May Meeting
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$30.00


  • Chair:Laura S. Hundley, Holland & Hart LLP, Boulder, CO
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  • Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since January 2015. Panelists:Jeffrey D. Chadwick, Winstead PC, The Woodlands, TX; Elizabeth R. Glasgow, Venable LLP, Los Angeles, CA and New York, NY; Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC
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  • Structuring Charitable Gifts: Blending Philanthropic Objectives with Tax Planning. This panel will review different structures for charitable giving both during an individuals lifetime and at death, including the use of charitable split interest trusts, private foundations and donor advised funds. The panelists will also discuss the tax treatment for gifts of different types of property under each structure, as well as the flexibility of each structure to respond to the individuals charitable goals. Panelists:Jennifer L. Franklin, Simpson Thacher & Bartlett LLP, New York, NY; Martin Hall, Ropes & Gray LLP, Boston, MA
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  • Top Ten Revenue Rulings for Estate Planners. This program will review ten key Revenue Rulings that should be part of every estate planners portfolio. The panel will begin with a summary of the provisions of each ruling. Where applicable, the panel will discuss what prompted the Department of Treasury to issue the ruling. The panel will then introduce practical planning tips for employing the rulings with illustrations of how these rulings have changed the way estate planners practice. Panelists:Taylor P. Bechel, Venable LLP, Washington, DC; A. Christopher Sega, Venable LLP, Washington, DC; Katherine E. Ward, Venable LLP, Washington, DC
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Session : ABATX1552
Partnerships & LLCs
Conference : 2015 May Meeting
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$30.00


  • Chair:Jeanne M. Sullivan, KPMG LLP, Washington, DC
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  • Partnership Compliance Issues. This panel will discuss compliance issues involving partnerships (including large partnerships and TEFRA). Moderator:Professor Noel P. Brock, West Virginia University, Morgantown, WV Panelists:William J. Wilkins, Chief Counsel, Office of Chief Counsel, IRS, Washington, DC; Kenneth W. Gideon, Skadden Arps Slate Meagher & Flom LLP, Washington, DC
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  • Hot Topics in Partnership Taxation. This panel will discuss significant recent developments related to subchapter K. Moderator:Todd D. Golub, EY, Chicago, IL Panelists:Kimberly S. Blanchard, Weil Gotshal & Manges LLP, New York, NY; Gregory M. Bopp, Bracewell & Giuliani LLP, Houston, TX; Benjamin H. Weaver, Attorney-Advisor, Office of Associate Chief Counsel (Passthroughs and Special Industries), IRS Office of Chief Counsel, Washington, DC
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  • May Company Regulations. This panel will discuss the publication project concerning regulations under section 1.337(d)-3 relating to partnership transactions involving a corporate partners stock or other equity interests. Moderator:David H. Schnabel, Debevoise & Plimpton LLP, New York, NY Panelists: Matthew E. Gareau, Deloitte Tax LLP, Washington, DC; Joseph Worst, Attorney-Advisor, Office of Associate Chief Counsel (Passthroughs and Special Industries), IRS Office of Chief Counsel, Washington, DC
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Session : ABATX1553
Administrative Practice
Conference : 2015 May Meeting
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  • 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:Jeremiah Coder, Greenburg Traurig LLP, San Francisco, CA Panelists:Rochelle Hodes, Attorney-Adviser, 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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  • Memories Fade But Emails are Forever: New Electronic Discovery Rules in US Tax Court. The US Tax Court held last fall in Dynamo Holdings, LP v. Commissioner that taxpayers could use predictive coding to help identify non-privileged electronically stored information in discovery requests. This is a first for the Tax Court. This will make electronic discovery requests less expensive for litigants and should speed up the process. This panel will discuss how predictive coding differs from manual discovery response, and cover implementation of predictive coding issues, such as selection of search terms and seed documents. Moderator:Martin Press, Gunster Law Firm, Ft. Lauderdale, FL Panelist:James Scarazzo, FTI Consulting, Washington, DC
  • What's New in IRS Exam and Appeals. This panel will discuss new procedures and processes in Large Business & International (LB&I) Division examinations and related processes in Appeals. LB&I has a year of experience with its new Information Document Requests procedures and recently described new examination procedures in a draft Publication 5125 (dated 7-2014). Appeals has also adopted new policies under its Appeals Judicial Approach and Culture (AJAC) project. The panel will examine the interaction of the new policies in both examination and Appeals. Moderator:Fred Murray, Grant Thornton, Washington, DC Panelists:Heather Maloy, Commissioner, LB&I Division, IRS, Washington, DC; Kirsten Wielobob, Chief, Appeals Office, IRS, Washington, DC
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Session : ABATX1554
Foreign Activities of US Taxpayers FRIDAY
Conference : 2015 May Meeting
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  • Chair:Joseph Calianno, Grant Thornton LLP, Washington, DC
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  • The Intersection of Partnerships & Subpart F. Complexity exists in both the taxation of partnerships and in the subpart F regime, but when they intersect, things really get interesting. This panel will analyze issues that arise when the two worlds collide, including issues arising under section 956. Moderator:Aaron A. Farmer, Farmer & Associates PLLC, Naples, FL Panelists:Jennifer H. Alexander, Deloitte Tax LLP, Washington, DC; Barbara Rasch, Senior Technical Reviewer, Branch 2, IRS Office of the Associate Chief Counsel International, Washington, DC; Brian Jenn, Attorney Advisor, Department of Treasury, Washington, DC
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  • Alternative Proposals for International Tax Reform. This panel will analyze the tax technical and implementation aspects of alternative proposals for international tax reform, including proposals for a territorial tax or minimum tax regime. Moderator:Professor Robert J. Peroni, The University of Texas School of Law, Austin, TX Panelists:Tony Coughlan, Tax Counsel, Republican Staff, Senate Finance Committee, Washington, DC; Kathleen L. Ferrell, Davis Polk & Wardwell LLP, New York, NY; Danielle E. Rolfes, International Tax Counsel, Department of Treasury, Washington, DC
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Showing sessions 1 - 10 of (48) TOTAL sessions
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