American Bar Association - Section of Taxation

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2016 May Meeting

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(c) [2016] American Bar Association.
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Showing sessions 1 - 10 of (44) TOTAL sessions
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Event : ABATX33

Session : ABATX1651
Low Income Taxpayers Representation Workshop
Conference : 2016 May Meeting
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Outside the Box of IRS Controversies: What Tax Practitioners Should Know. The Pro Bono & Tax Clinics Committee proudly presents the annual workshop for new and pro bono practitioners.

State Tax Issues. LITCs often face great obstacles to resolving clients' state income tax debts even after the clients' federal income tax controversies have been resolved. This panel will explore state tax issues affecting LITC clinicians. Moderator: Susan Morgenstern, Taxpayer Advocate Service, Cleveland, OH Panelists: Diana Leyden, NYC Taxpayer Advocate, New York, NY; Alan Marcus, Illinois Department of Revenue, Chicago, IL; Jack Trachtenberg, Reed Smith, New York, NY

Property Tax Issues. Low-income individuals face devastating consequences if they fall behind on property tax payments for their homes. In several areas of the country property tax foreclosures have become an epidemic. Property tax problems can also default a mortgage and start the homeowner on an escalating downward spiral. This presentation will highlight how low-income homeowners get swept up in the property tax dilemma and efforts that have been made to address this problem in Philadelphia, the District of Columbia, and Milwaukee. Moderator: Frank DiPietro, University of Minnesota LITC, Minneapolis, MN Panelists: Susanna W. Ratner, SeniorLAW Center, Philadelphia, PA; Joanne Savage, AARP Legal Counsel for the Elderly, Washington, DC; Phil Rosenkranz, Legal Aid Society of Milwaukee, Milwaukee, WI

Criminal Tax Issues. Many low-income tax cases have potential criminal aspects, including failure to file and omission of amounts or sources of income. This panel will discuss the criminal tax regime and the legal, strategy, and ethical issues that can arise in representing clients who have crossed the often blurry line between civil and criminal tax exposure. Moderator: The Honorable L. Paige Marvel, Judge, US Tax Court, Washington, DC Panelists: Matthew C. Hicks, Caplin & Drysdale, Washington, DC; Brian McManus, Latham & Watkins LLP, Washington, DC

Addressing ACA Problems in Non-IRS Fora. Low-income tax practice intersects with a wide variety of non-tax proceedings. This panel will cover tax-related appeals before the health benefits marketplace (Healthcare.gov), and also discuss when tax practitioners could help clients address ACA-related problems through family or probate court. Moderator: Daniel Knudsen, Oklahoma Indian Legal Services, Oklahoma City, OK Panelists: Tara Straw, Center on Budget and Policy Priorities, Washington, DC; Christine Speidel, Vermont Legal Aid, Springfield, VT

Session : ABATX1652
Tax Bridge on the Road
Conference : 2016 May Meeting
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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

A Conversation with... One of the Sections most esteemed members sits down for an in-depth discussion of her practice, her history with the Section, and the latest developments in tax law.

The Administrative Tax Collection Case. The panelists will discuss best practices for effectively managing the administrative tax collection process from the issuance of the notice and demand for payment through the filing of a request for a Collection Due Process Hearing. The panelists will also address practical tips for requesting collection alternatives and tax lien withdrawals and levy releases. Moderator: Giovanni Alberotanza, Rosenberg Martin Greenberg LLP, Baltimore, MD Panelists: Karen Lapekas, Lapekas Law, Miami, FL; Shamik Trivedi, Grant Thornton LLP, Washington, DC; Laurence K. Williams, Senior Counsel, Office of Associate Chief Counsel (Procedure & Administration), IRS, Washington, DC Co-Sponsored by: Administrative Practice

Tax Tales 2: More Seminal Cases of Subchapter C. The long-awaited second installment of Tax Tales has finally arrived! Strap on your thinking caps and join us for an old-fashioned story hour. There will be epic adventure, heart-breaking romance, inspirational drama, unexplainable mysteryand tax! Come and learn the stories behind the cases and rulings that serve as the foundation of modern tax law. Moderator: Alfred Bae, KPMG, Houston, TX Panelists: Michelle Lo, Linklaters, Washington, DC; Shannon Perez, AOL Inc., Dulles, VA; Gary Scanlon, EY, Chicago, IL

Tax Controversy Panel. Moderator: Kelley C. Miller, Reed Smith LLP, Washington, DC Co-Sponsored by: Court Procedure & Practice

Session : ABATX1653
Affiliated & Related Corporations
Conference : 2016 May Meeting
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Chair: Matthew K. White, KPMG LLP, Washington, DC

Coffee and Doughnuts Primer. Join us for a pre-panel providing an overview of the key areas and concepts that will be addressed by the committees panels, including the basis adjustment and group continuation rules. The session is aimed at younger practitioners, but all are welcome. Panelists: Rebecca Holtje, KPMG LLP, Washington, DC; Olivia Ley, PwC, Washington, DC

Stock Basis and Boot Considerations Inside Consolidation. This panel will explore some of the special consolidated return rules applicable in determining the treatment of non-stock consideration and the recovery and allocation of stock basis in reorganizations and other transactions occurring inside a consolidated group. Among the rules that will be explored are those applicable to excess loss accounts, crosschain redemptions and sales, and the receipt of boot in reorganizations (including all cash D reorganizations). The panel will also consider possible changes to these rules under the proposed regulations regarding the allocation of consideration and allocation and recovery of basis published in 2009, as well as other changes that might be considered. Moderator: Gordon Warnke, Linklaters LLP, New York, NY Panelists: Neil Barr, Davis Polk & Wardwell LLP, New York, NY; Rebecca O. Burch, EY, Washington, DC; Kevin M. Jacobs, IRS Office Of Chief Counsel, Washington, DC (Invited); Brett York, Attorney Advisor, Department of Treasury, Washington, DC (Invited)

Consolidated Group Continuation Issues. This panel will discuss the various tests for when a consolidated group remains in existence, and will explore the current state of the law in this area given the dichotomy between the literal language of the rules and the more expansive interpretation of those rules by the IRS in Revenue Rulings, GCMs, and PLRs. In addition, the implications of the termination of a consolidated group will be discussed. Moderator: Jonathan Forrest, Deloitte Tax LLP, Washington, DC Panelists: Lawrence M. Axelrod, Special Counsel, IRS Office of Associate Chief Counsel (Corporate), Washington, DC (Invited); Mark Schneider, Deloitte Tax LLP, Washington, DC; Mike Wilder, McDermott Will & Emery, Washington, DC

Current Events. This panel will discuss current events in the area of consolidated returns. Moderator: Lisa M. Zarlenga, Steptoe & Johnson LLP, Washington, DC Panelists: Marc Countryman, EY, San Francisco, CA; Greg Fairbanks, Grant Thornton LLP, Washington, DC; Graham Magill, KPMG LLP, Washington, DC; Marie Milnes-Vasquez, Special Counsel to the Associate Chief Counsel (Corporate), IRS, Washington, DC (Invited)

Session : ABATX1654
Capital Recovery & Leasing
Conference : 2016 May 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: 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; Ryan Corcoran, RSM US LLP, Washington, DC

Examination Items and Issues Pertaining to Tangible Property. This panel will focus on items and issues that IRS examination teams are highlighting pertaining to tangible property as they work through implementation of the tangible property regulations. Moderator: Mary Duffy, Andersen Tax, Washington, DC Panelists: John Eiman, Senior Counsel, Large Business & International Office of Chief Counsel, IRS, Houston, TX; Jane Rohrs, Deloitte, Washington, DC; Jason Kristall, Docket Attorney, Branch 1, Income Tax & Accounting, IRS, Washington, DC

The Lease Accounting Standard and Its Impact on Taxpayers. This panel will provide background information on the new lease accounting standard and discuss its impact on taxpayers for both book and tax purposes. Moderator: Glenn Johnson, EY, Washington, DC Panelists: John Aramburu, Senior Counsel, Branch 5, Income Tax & Accounting, IRS, Washington, DC; Edward Schwartz, Docket Attorney, Branch 5, Income Tax & Accounting, IRS, Washington, DC; Annette Smith, PwC, Washington, DC; Mark Mahar, EY, Washington, DC

Session : ABATX1655
Administrative Practice
Conference : 2016 May Meeting
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Chair: George Hani, Miller & Chevalier, Washington, DC

Important Developments. This panel will discuss current developments and topics of immediate interest in tax administrative practice. Panel will focus on recent Department of Treasury and IRS guidance, court decisions, on-going litigation, or any other items germane to tax administration. Moderator: Della Bauserman, US Tax Court, Washington, DC Panelists: Brendan O'Dell, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Kathryn Zuba, Deputy Associate Chief Counsel (Procedure & Administration), IRS Office of Chief Counsel, Washington, DC; Matthew Cooper, EY, Washington, DC

Managing Transfer Pricing, Double Taxation, and Other Complex Multi-Country Tax Matters in a Post-BEPS World. Taxpayers and governments alike are facing a world never seen before. Multiple intergovernmental actions since 2001 have significantly increased the transparency of taxpayer business activities and related tax filings. In particular, filings and Exchange of Information related to Country-byCountry Reporting created by the BEPS Project in the OECD and now adopted or under adoption by a number of countries will create enormous new challenges. As another example, changes in tax treaties, particularly changes affecting the definition of permanent establishments and their associated profits, will certainly increase scrutiny of tax filings. Many expect that disputes with and between tax authorities will increase in response. LB&I at IRS has reorganized, in part, to adapt to these changes. What should taxpayers and their counsel expect, and what should be done now in anticipation, is the subject of our panel. Moderator: Fred Murray, Grant Thornton LLP, Washington, DC Panelists: Sharon Porter, Director, Treaty and Transfer Pricing Operations, IRS - LB&I, Washington, DC; Theodore D. Setzer, Assistant Deputy Commissioner, International, IRS - LB&I, Washington, DC; John Magee, Morgan Lewis & Bockius LLP, Washington, DC; Pam Olson, PwC, Washington, DC; Tim McDonald, The Procter & Gamble Company, Cincinnati, OH

LB&I Reorganization and Audit Redesign. This panel will discuss the current implementation status of the LB&I reorganization (announced in September 2015) and changes to LB&I examination procedures in light of the reorganization. Panel will discuss the impact of the reorganization on the LB&I mission including the role of counsel and interplay with LB&I litigation strategies. Panel will also discuss what taxpayers should be aware of and anticipate in examinations under the new LB&I structure. Invited panelists will include LB&I executive(s) and private practitioners. Moderator: Elizabeth Askey, PwC, Washington, DC Panelists: Sharon Porter, Director, Treaty and Transfer Pricing Operations, IRS - LB&I, Washington, DC; Theodore D. Setzer, Assistant Deputy Commissioner, International, IRS - LB&I, Washington, DC; Jennifer Breen, Morgan, Lewis & Bockius LLP, Washington, DC

Session : ABATX1656
Banking & Savings Institutions
Conference : 2016 May Meeting
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Chair: Anthony J. Tuths, WithumSmith+Brown PC, New York, NY

New Proposed Section 305(c) Regulations. Deemed dividends on convertibles analysis and compliance Implications, plus corporate action and combination rule issues under section 871(m). Panelists: Stevie Conlon, Wolters Kluwer, Arlington Heights, IL; Stefan Gottschalk, RSM US LLP, Washington, DC; Pamela Lew, Tax Attorney, Office of Chief Counsel (Financial Institutions and Products), IRS, Washington, DC; Maurice LaBrie, Tax Attorney, Office of Chief Counsel (Corporate Division), IRS, Washington, DC; Karl Walli, Senior Counsel (Financial Products), Tax Legislative Counsel, Department of Treasury, Washington, DC

New Proposed Section 385 Regulations. Related party debt treated as equity analysis of the implications to bank intercompany financing, treasury center operations, TLAC issues, as well as possible banking opportunities with respect to intermediary transactions. Panelists: Yoram Keinan, Carter Ledyard & Milburn LLP, New York, NY; Anthony J. Tuths, WithumSmith+Brown PC, New York, NY; Additional Panelists TBD

Session : ABATX1657
Estate & Gift Taxes
Conference : 2016 May Meeting
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Chair: Laura S. Hundley, Holland & Hart LLP, Boulder, CO

Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since January 2016. Panelists: Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC; Jeffrey D. Chadwick, Winstead PC, The Woodlands, TX; Helen E. Rogers, Holland & Hart LLP, Denver, CO; Dustin Rever-Ginsburg, Venable LLP, Los Angeles, CA

Oh, What a Relief It Is: Curing Estate Plans That No Longer Make Sense in Light of the American Taxpayer Relief Act of 2012. As a result of the American Taxpayer Relief Act of 2012, typical estate planning strategies may no longer be appropriate. Explore how clients can escape from no-longer useful, or even harmful, planning transactions or more efficiently administer those from which they cannot escape. Panelists: Jordan M. Ware, Winstead PC, Austin, TX; Caitlin M. Orr, McDermott Will & Emery, Washington, DC

Session : ABATX1658
Investment Management
Conference : 2016 May Meeting
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Chair: Amy B. Snyder, The Vanguard Group Inc., Malvern, PA

Unrelated Debt-Financed Income Issues for Private Investment Funds. This panel will examine the current issues faced by private investment funds relating to unrelated debt-financed income ("UDFI"). The panelists will consider, among other things, the circumstances under which a funds use of debt can give rise to UDFI and the effectiveness of the current structures used to minimize UDFI. Moderator: Laura D. Warren, Hamilton Lane, Bala Cynwyd, PA Panelists: Michael Bolotin, Debevoise & Plimpton LLP, New York, NY; Adam Feuerstein, PwC, Washington, DC; Melanie Levy, EIG Global Energy Partners, Washington, DC; Justin J. Lowe, EY, Washington, DC

Select Partnership Issues and Private Investment Funds. This panel will focus on select developments in the partnership area that are relevant to private investment funds. Questions addressed will include, among others, when targeted allocations might not make sense and how investors and funds should consider protecting themselves in light of the new partnership audit rules. Moderator: James R. Brown, Willkie Farr & Gallagher LLP, New York, NY Panelists: Glenn E. Dance, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries), IRS Office of Chief Counsel, Washington, DC; Adam Greenwood, Ropes & Gray LLP, New York, NY; Maximilian Pakaluk, EY, Washington, DC

Updates from the Internal Revenue Service and Investment Company Institute. Representatives from the IRS and the Investment Company Institute will discuss recent guidance and other topics of current interest to investment companies, including Notice 2016-10, "Guidance Relating to Refunds of Foreign Tax for Which an Election Was Made Under Section 853," and Money Market Fund reform. Moderator: Karen Gibian, Investment Company Institute, Washington, DC Panelists: Steven Harrison, Branch Chief, Branch 1 (Financial Institutions and Products), IRS Office of Chief Counsel, Washington, DC; Helen Hubbard, Associate Chief Counsel (Financial Institutions and Products), IRS Office of Chief Counsel, Washington, DC; Keith Lawson, Investment Company Institute, Washington, DC; Ryan Lovin, Investment Company Institute, Washington, DC; Larry Pounders, Attorney, Branch 3, IRS Office of Associate Chief Counsel (International), Washington, DC

Session : ABATX1659
Real Estate
Conference : 2016 May Meeting
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Chair: Robert D. Schachat, EY, Washington, DC

Hot Topics. This panel will discuss recent and upcoming regulations, court decisions and guidance affecting real estate and partnerships. Moderator: Julie M. Marion, Latham & Watkins, Chicago, IL Panelists: Ossie Borosh, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; David R. Haglund, Branch Chief, Passthroughs & Special Industries, IRS Office of Chief Counsel, Washington, DC

PATH Act FIRPTA, REIT Technical and Spin-Offs. This panel will discuss the new FIRPTA exemptions and clarifications and changes to the REIT provisions included in the PATH Act, including the new restrictions for REITs in tax-free spin-offs, as well as address any anticipated guidance. Moderator: Tony Edwards, National Association of Real Estate Investment Trusts, Washington, DC Panelists: Ana G. OBrien, Latham & Watkins, Los Angeles, CA; Mark C. Van Deusen, Deloitte Tax LLP, Richmond, VA

Bad Boys: Whatcha Gonna Do? This panel will discuss "bad boy" or nonrecourse carve-out guarantees of real estate loans and the effect on debt allocations under section 752 and at-risk amounts under section 465 in light of CCA 201606027. Moderator: Blake D. Rubin, EY, Washington, DC Panelist: James A. Quinn, Senior Counsel, Branch 3, Passthroughs & Special Industries, IRS Office of Chief Counsel, Washington, DC

New Partnership Audit Provisions Drafting Considerations. This panel will lead an interactive discussion of the new partnership audit provisions, focusing on drafting issues. Participation and contributions from the audience are highly encouraged. Moderator: Kate Kraus, EY, Los Angeles, CA Panelist: Sarah K. Ritchey, Holland & Hart, Denver, CO

Session : ABATX1660
US Activities of Foreigners & Tax Treaties
Conference : 2016 May Meeting
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Chair: Michael J. Miller, Roberts & Holland LLP, New York, NY

Whats New in the 2016 US Model Treaty? On February 17, 2016, the Department of Treasury released a new US Model Treaty, including an updated Limitation on Benefits article and new rules dealing with exempt permanent establishments, special tax regimes, payments by expatriated entities, and subsequent changes in law that are intended to limit the use of tax treaties to create instances of low or no taxation. The panel will discuss the provisions of the new Model, including the new arbitration provision, with an emphasis on how they relate to the OECDs BEPS initiatives and the initiative to develop a multilateral instrument to implement BEPS-related changes. Moderator: Professor Patricia A. Brown, University of Miami School of Law, Miami, FL Panelists: David G. Shapiro, Saul Ewing LLP, Philadelphia, PA; Gretchen Sierra, Deloitte Tax LLP, Washington, DC; Lori Hellkamp, Jones Day, Washington, DC; Jason Yen, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC; Danielle Rolfes, International Tax Counsel, Department of Treasury, Washington, DC

The FIRPTA Provisions of the PATH Act. This panel will address recent changes to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA), including an expanded exemption for publicly traded REIT stock, a new exemption for REIT stock owned by qualified shareholders; and a free pass from FIRPTA altogether for certain foreign pension funds. The panel will focus on planning under the new rules, as well as a few quirks and traps for the unwary. Moderator: Kimberly S. Blanchard, Weil Gotshal & Manges LLP, New York, NY Panelists: Scott Semer, Torys LLP, New York, NY; Matthew A. McDonald, Mayer Brown LLP, New York, NY; Charles P. Besecky, Branch Chief, Branch 4, IRS Office of Associate Chief Counsel (International), Washington, DC; Jason Yen, Attorney Advisor, Office of International Tax Counsel, Department of Treasury, Washington, DC

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