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2016 Midyear Meeting

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(c) [2016] 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 (44) TOTAL sessions
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Event : ABATX32

Session : ABATX1601
Tax Bridge on the Road
Conference : 2016 Midyear Meeting
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$45.00


  • Sponsored by: Young Lawyers Forum and Diversity. Program Co-Chairs: Kelley C. Miller, Reed Smith LLP, Washington DC; Cathy Fung, Office of Chief Counsel (Large Business & International), IRS, Washington, DC
  • Nuts & Bolts: The Administrative Tax Controversy Case From Examination to Appeals. This panel will provide a practical discussion on how to effectively represent clients during examination and Appeals conferences. The panelists will discuss various issues that arise during an administrative tax controversy case including effective negotiation strategies for examinations, alternative dispute resolution mechanisms and the Appeals process. Moderator: Jairo G. Cano, Agostino & Associates PC, Hackensack, NJ Panelists: James R. Gadwood, Sullivan & Cromwell, New York, NY; Ted B. Meyer, (former) Examination Territory Manager (SB/SE), IRS, Los Angeles, CA; Cory Stigile, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA; Adriana Lofaro Wirtz, Cooley LLP, New York, NY Co-Sponsored by: Administrative Practice
  • Tax Court 101: Everything You Wanted To Know About Litigating Tax Cases. This panel will provide an overview of litigation before the US Tax Court. Topics to be covered include the structure of the Court, the Courts role in adjudicating tax disputes, a comparison of the Court to other judicial forums, understanding the notice of deficiency, how to prepare and review Tax Court pleadings, how to make and respond to motions directed to the pleadings, discovery, and negotiation of the stipulation of facts. Moderator: Kelley C. Miller, Reed Smith LLP, Washington, DC Panelists: Kathleen Gregor, Ropes & Gray, Boston, MA; Lawrence Sannicandro, Agostino & Associates PC, Hackensack, NJ Co-Sponsored by: Court Procedure and Practice
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  • Tax Careers in the Government. A panel of current and former government attorneys will discuss the many different tax careers and career paths available in the government. The panelists will focus on the benefits of a tax career in the government and offer suggestions for thriving in government positions. Moderator: Cathy Fung, Office of Chief Counsel (Large Business & International), IRS, Washington, DC Panelists: The Honorable Cary Douglas Pugh, Judge, US Tax Court, Washington, DC; Diana L. Erbsen, Deputy Assistant Attorney General for Appellate and Review, Tax Division, Department of Justice, Washington, DC; Matthew S. Cooper, EY, Washington, DC; Heather D. Horton, Assistant Division Counsel, Office of Chief Counsel (Small Business/Self-Employed), IRS, Washington, DC
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  • Partnerships: The Fundamentals. This program will explore a number of entity classification concerns, including concerns related to publicly traded partnerships. The panelists will focus on allocations of taxable income and loss among the partners, including substantial economic effect requirements under section 704(b). The panelists will also discuss the use of targeted tax allocations to simplify tax allocation provisions in the partnership agreement, contributions to the partnership including ways to address the disparity between the fair market value of contributed property and its basis under section 704, and distributions from the partnership to its partners. Moderator: Michael Hirschfeld, Dechert LLP, New York, NY Panelists: Alfred Bae, KPMG, Houston, TX; Philip Hirschfeld, Ruchelman PLLC, New York, NY; Bahar Schippel, Snell & Wilmer LLP, Phoenix, AZ; Jeanne Sullivan, KPMG, Washington, DC Co-Sponsored by: Partnerships & LLCs and Real Estate
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Session : ABATX1602
Capital Recovery and Leasing
Conference : 2016 Midyear Meeting
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  • Chair: Alison Jones, 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: 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; Richard Shevak, Cohn Reznick, Roseland, NJ
  • The Treatment of Lease Termination Costs post-ABC Beverage Corp. This panel will discuss the Sixth Circuits decision in ABC Beverage Corp. v. United States and its potential impact on the treatment of lease termination costs in a variety of scenarios. Moderator: Glenn Johnson, EY, Washington, DC Panelists: Neville Jiang, Attorney, Office of Chief Counsel, Income Tax & Accounting, IRS, Washington, DC; Kate Abdoo, GE Corporate Tax, Stamford, CT
  • Tangible Property Regulations Focus on Rev. Proc. 2015-56. This panel will focus on the tangible property regulations specifically with respect to Rev. Proc. 2015-56, the recently released guidance pertaining to remodel and refresh activities performed by taxpayers in the retail and restaurant industries. Moderator: Brandon Carlton, EY, Washington, DC Panelist: 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; Rayth Myers, EY, Washington, DC

Session : ABATX1603
Transfer Pricing
Conference : 2016 Midyear Meeting
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  • Chair: John Hughes, IRS, Washington, DC
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  • Media & Entertainment Considerations in Transfer Pricing. This session will focus on topics on aspects of transfer pricing through the lens of Media & Entertainment (M&E), including dispute resolution - preferred methods, audit environment, and the Cloud, the digital space, among others. The panel will consider potential impacts of the BEPS final reports on the M&E industry, in particular. Moderator: Michael Denning, EY, Los Angeles, CA Panelists: Cathy Dare, Activision Blizzard, Los Angeles, CA; Lili Kazemi, PwC, Washington, DC
  • REITs and Transfer Pricing: The IRS Takes Up the Welcome Mat. This panel will review recent developments in the REIT industry, including the IRSs recent pronouncements under Rev Notice. 2015-59 and Rev Proc. 2015-43, with a discussion of the implications for the industry and the enforcement and application of transfer pricing for current and future REITs. Moderator: Nathaniel Carden, Skadden Arps Slate Meagher & Flom, Chicago, IL Panelists: J. Harold McClure, Thomson Reuters, New York, NY; John C. Hughes, Senior International Advisor, IRS, Washington, DC
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Session : ABATX1604
US Activities of Foreigners & Tax Treaties
Conference : 2016 Midyear Meeting
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  • Chair: Michael J. Miller, Roberts & Holland LLP, New York, NY
  • Inbound IP Planning. This program will examine the inbound taxation of foreign persons with respect to intellectual property used within the United States. The panel will address the tax consequences of sales versus licenses and how to distinguish one from the other, including characterization issues arising from using the cloud. The panel will also consider issues relating to withholding on royalties, including treaty qualification, hybrid entity issues and conduit financing arrangements. Moderator: Sam K. Kaywood Jr., Alston & Bird LLP, Atlanta, GA Panelists: David L. Forst, Fenwick & West LLP, Mountain View, CA; Jeffrey L. Rubinger, Bilzin Sumberg Baena Price & Axelrod LLP, Miami, FL; Nancy Lee, Senior Technical Reviewer, Branch 8, IRS Office of the Associate Chief Counsel International, Washington, DC; Quyen Huynh, Associate Counsel, International Tax Counsel, Department of Treasury, Washington, DC; Elena Virgadamo, Attorney Advisor, International Tax Counsel, Department of Treasury, Washington, DC
  • Advanced Withholding Taxation - A Guide for the Perplexed. This panel will explore the potential withholding tax considerations that may arise from transactions which do not initially appear to be subject to a withholding obligation. The panel will also discuss some planning suggestions to deal with unexpected withholding tax obligations. Moderator: Professor Alan I. Appel, New York Law School, New York, NY Panelists: Meyer H. Fedida, Cleary Gottlieb Steen & Hamilton LLP, New York, NY; Jessica Edwards, Bryan Cave LLP, St. Louis, MO; Ursula Gee, Program Manager, Large Business and International, IRS, Laguna Niguel, CA; Nancy Lee, Senior Technical Reviewer, Branch 8, IRS Office of the Associate Chief Counsel International, Washington, DC; Quyen Huynh, Associate Counsel, International Tax Counsel, Department of Treasury, Washington, DC

Session : ABATX1605
Administrative Practice
Conference : 2016 Midyear Meeting
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  • Chair: George Hani, Miller & Chevalier, Washington, DC
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  • APA and the Administrative Process: How Has Altera Altered the Landscape? The Tax Courts reviewed decision in Altera Corp. v. Commissioner, 145 T.C. No. 3, regarding application of the Administrative Procedure Act (APA) to Treasury regulations, has left observers wondering how Treasury will respond to the Courts heightened review of its rulemaking authority. Whether the Courts unanimous adoption of APA standards of judicial review for regulations will affect other frequent areas of tax disputes such as individual determinations involving collection due process cases or deficiency notices is also an unknown possibility. This panel will discuss the future of the APA in the tax administrative process and bring awareness of general APA issues tax practitioners should be mindful of. Moderator: Jeremiah Coder, Greenberg Traurig, Washington, DC Panelists: Alexandra Minkovich, Baker & McKenzie, Washington, DC; Professor Steve Johnson, Florida State University College of Law, Tallahassee, FL; Michael Desmond, The Law Offices of Michael J. Desmond, Santa Barbara, CA
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  • The Dawn of A New Era for Partnership Examinations. The Bipartisan Budget Act of 2015 repealed TEFRA and the electing large partnership rules and adopted a new regime for auditing partnerships. A key piece of the new regime is that the tax, interest, and penalties resulting audit adjustments will be assessed at the partnership level (unless the partnership elects otherwise). The new rules will take effect for tax years beginning after December 31, 2017. Many details of how the new regime will operate will be left to future IRS guidance. This panel will discuss the regime as laid out in the statute and discuss areas where additional guidance will be necessary. Moderator: Kevin M. Johnson, Pepper Hamilton, Philadelphia, PA Panelists: Rochelle Hodes, Associate Tax Legislative Counsel, Office of Tax Policy, Department of Treasury, Washington, DC; Mary McNulty, Thompson & Knight, Dallas, TX
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  • Administrative Practice 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, ongoing litigation, or any other items germane to tax administration. Moderator: Shamik Trivedi, Grant Thornton, Washington, DC Panelists: Rochelle Hodes, Associate Tax Legislative Counsel, Office of Tax Policy, Department of Treasury, Washington, DC; Drita Tonuzi, Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC
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  • Joint Session with State and Local Taxes: California Administrative Agencies and Effective Administrative Practice. This panel, comprised of the Chief Counsels of the California Franchise Tax Board and the State Board of Equalization and private sector experts, will discuss notable differences between state and federal administrative procedures, as well as an overview of current developments and notable recent events. Moderator: Valerie Dickerson, Deloitte Tax LLP, Washington, DC Panelists: Randy Ferris, Chief Counsel, State Board of Equalization, Sacramento, CA; Jozel Brunett, Chief Counsel, Franchise Tax Board, Sacramento, CA; Charles J. Moll, Winston & Strawn LLP, San Francisco, CA Co-Sponsored by: State and Local Taxes
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Session : ABATX1606
Affiliated & Related Corporations
Conference : 2016 Midyear Meeting
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  • Chair: Matthew K. White, KPMG LLP, Washington, DC
  • The Use of Partnerships by Consolidated Groups (Part II). This panel, which is the continuation of the panel from the September meeting in Chicago, will explore how Subchapter K intersects with the consolidated return regulations and among other things will consider partnership incorporations, the sale and purchase of partnership interests, partnership terminations, and the use of partnerships in breaking affiliation and in Granite Trust planning. Moderator: Professor Don Leatherman, University of Tennessee College of Law, Knoxville, TN Panelists: Becky Holtje, KPMG LLP, Alexandria, VA; Philip B. Wright, Bryan Cave LLP, St. Louis, MO
  • Several Liability and Related Issues. This panel will explore several liability of members under Treas. Reg. Sec. 1.1502-6, the interplay of federal regulatory liability and state law liability in the context of M&A transactions, and related financial reporting issues. Moderator: Timothy S. Shuman, McDermott Will & Emery LLP, Washington, DC Panelists: Mark Schneider, Deloitte Tax LLP, Washington, DC; Andrew Turney, McDermott Will & Emery LLP, Los Angeles, CA; Dave Ware, Tyco International, Princeton, NJ

Session : ABATX1607
Banking & Savings Institutions
Conference : 2016 Midyear Meeting
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  • Chair: Anthony J. Tuths, WithumSmith+Brown, PC, New York, NY
    •
  • Recent Developments: STARS Transactions and Section 871(m) Issues and Concerns. This panel will review the various court decisions around the US involving STARS transactions and related foreign tax credit transactions. The panel will also assess the pending U.S. Supreme Court petition. Additionally, the panel will review the Section 871(m) regulations with an emphasis on bank implementation and the problems that may arise. Panelists: Anthony J. Tuths, WithumSmith+Brown PC, New York, NY; Henry Stow Lovejoy, Kostelanetz & Fink LLP, New York, NY
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  • FATCA Updates for Financial Institutions. This panel will discuss current developments relating to the application of FATCA to participating foreign financial institutions. Topics will include current state of IGAs, effective dates to complete due diligence, withholding, reporting, documentation and record-keeping. Panelists: Denise Hintzke, Deloitte Tax LLP, New York, NY; Yoram Keinan, Carter Ledyard & Milburn LLP, New York, NY
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  • Bank Regulatory Capital. This panel will address various issues arising from Basel III and the new rules regarding Total Loss Absorbency Capacity (TLAC). Topics will include bad debt deferrals, debt v. equity, and contingent capital or bail-in debt. Other topics to be addressed will include FHLB stock redemptions and bad debt realized built-in loss (RBIL) issues. Panelists: John Taylor, EY, Phoenix, AZ; Richard Larkins, EY, Washington, DC; Mark Price, KPMG, Washington, DC
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Session : ABATX1608
Closely Held Businesses PART 1
Conference : 2016 Midyear Meeting
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  • Chair: Shelby L. Wilson, Berchem Moses & Devlin PC, Westport, CT
  • The Convergence of Immigration & Tax Issues for Closely Held Businesses: Opportunities and Pitfalls for Employers. Since 2008 immigration and worker status has become a significant focus of the federal government, and employers are now under more pressure than ever to make sure their workers have the proper documentation. When combined with employer misclassification and tax issues and this area becomes a literal minefield for employers. This panel will discuss the governments focus on this area and its use of I9 examinations, and what employers can do to protect themselves and the consequences if they fail to clean up this issue. Panelists: William Velie, Velie Law Firm, Norman, OK; Megan L. Brackney, Kostelanetz & Fink LLP, New York, NY
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  • Worker Classification What's Old Is New Again. Worker classification continues to be an important topic. Hear the latest from the IRS and private practitioners on why misclassification is important, the risks involved, section 530 relief, the Voluntary Classification Settlement Program, a State example (California), an industry example (professional practices), and the new Department of Labor initiatives as they relate to IRS views. Panelists: Janine Cook, Deputy Associate Chief Counsel (Tax Exempt and Government Entities), IRS Office of Chief Counsel, Washington, DC; Betty J. Williams, Law Office of Williams & Associates PC, Sacramento, CA; William P. Prescott, Wickens Herzer Panza Cook & Batista Co., Avon, OH
    •

Session : ABATX1610
Individual and Family Taxation
Conference : 2016 Midyear Meeting
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  • Chair: Phyllis Horn Epstein, Epstein Shapiro & Epstein PC, Philadelphia, PA
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  • New Approaches and Alternatives to Innocent Spouse Relief. In cases where spouses are still married but separated, the filing of a joint return by one spouse without the consent of the other creates substantial hurdles for the non-consenting spouse. This can result in delayed refunds, rejected original returns, and even tax liabilities against the non-consenting spouse. Before turning to Innocent Spouse Relief, are there alternatives that should be in your arsenal? This panel will focus on best practices in resolving these cases administratively or in US Tax Court as well as considerations in deciding whether to pursue an Innocent Spouse Relief claim instead. This panel will also discuss the recent California state law changes to Innocent Spouse Relief that offer a new model for facilitating access to relief at the state level. Moderator: Lany L. Villalobos, Philadelphia Legal Assistance, Philadelphia, PA Panelists: George Willis, Chapman University Tax Law Clinic, Orange, CA; Steven M. Roth, Senior Counsel, Chief Counsel-SBSE, IRS, Thousand Oaks, CA; Susan Morgenstern, Taxpayer Advocate Service, Cleveland, OH Co-Sponsored by: Pro Bono & Tax Clinics
  • Late Filed Returns. The late filed returns judicial doctrine barring discharge: A review of the US Circuit Court of Appeals decisions eviscerating the Bankruptcy Codes two-year rule for the discharge of tax liabilities on late filed returns. An examination of the opinions of the US Circuit Court of Appeals and Bankruptcy Court decisions going in the other direction. Defining the controversy. Moderator: Phyllis Horn Epstein, Epstein Shapiro & Epstein PC, Philadelphia, PA Panelists: Frances D. Sheehy, Law Office of Frances D. Sheehy, Coconut Creek, FL; Kenneth C. Weil, Seattle, WA; Wm. Robert Pope, Jr., White & Reasor PLC, Nashville, TN Co-Sponsored by: Bankruptcy & Workouts
  • Athletes, Entertainers and the IRS. Author and law professor Lionel S. Sobel presents on an assortment of tax issues that are unique to athletes and entertainers, and have some unexpected and even surprising consequences. Moderator: Phyllis Horn Epstein, Epstein Shapiro & Epstein PC, Philadelphia, PA Panelist: Professor Lionel S. Sobel, UCLA School of Law, Los Angeles, CA
    •

Session : ABATX1611
Investment Management
Conference : 2016 Midyear Meeting
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  • Chair: Amy B. Snyder, The Vanguard Group Inc., Malvern, PA
  • Offshore Issues for Private Equity Funds. This panel will discuss issues and recent changes to the cross-border tax landscape faced by private equity funds involved in cross-border deals and investments. Topics include use of treaties, holding companies, and leverage issues. Moderator: Greg Hartker, Morgan Lewis & Bockius LLP, San Francisco & Orange County, CA Panelists: Alexander Lee, Paul Hastings LLP, Los Angeles, CA; Michiel van Kempen, Loyens & Loeff NV, New York, NY; Adam Tejeda, K&L Gates LLP, New York, NY
  • Current Issues for Funds Investing in Index-Linked Financial Transactions. This panel will explore a variety of tax issues that arise when investment funds enter into financial transactions relating to indices, with a particular emphasis on the tax treatment of derivatives with respect to an index. The panel will address, among other issues, the application of section 1260, section 871(m), FIRPTA, the wash-sale rules, section 1256, and the regulated investment company rules to these types of transactions. Moderator: Jeffrey D. Hochberg, Sullivan & Cromwell LLP, New York, NY Panelist: Amy B. Snyder, The Vanguard Group Inc., Malvern, PA; Craig Gibian, Deloitte Tax LLP, Washington, DC
  • Current Issues for Investment Companies. This panel will explore several US and international tax topics arising currently in the investment company arena, including use of partnerships (rather than regulated investment companies) as investment vehicles underlying variable insurance products, tax ramifications associated with nonresident alien individuals serving as directors on fund boards, and an update on other investment company issues. Moderator: Ronald S. Cohn, Cohn & Barr, San Francisco, CA Panelists: Jason Bortz, Capital Research and Management Company, Los Angeles, CA; Mark S. Campisano, Pacific Life, Newport Beach, CA; Keith Lawson, Investment Company Institute and ICI Global, Washington, DC


     


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