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2017 Joint Meeting

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(c) [2017] 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 (39) TOTAL sessions
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Event : ABATX37

Session : ABATX1797
Tax Bridge on the Road
Conference : 2017 Joint Fall CLE Meeting
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$60.00

A Conversation with the Honorable Juan F. Vasquez. Judge Vasquez sits down for an in-depth discussion of his time on the bench, his history, and the latest developments in tax law.

The Wonder Years: Navigating the Early Years of Practicing Tax Law. A panel of junior and mid-level attorneys will provide their viewpoints on their profession during the early stages of their practice. The panelists will discuss their experiences in law firms, accounting firms, clerkships, government, and low-income taxpayer clinics. Moderator: Cathy Fung, Office of Chief Counsel (Large Business & International), IRS, Washington, DC Panelists: Matthew S. Cooper, EY, Washington, DC; Katie Drilling, PwC, Dallas, TX; Adrian Ochoa, Chamberlain Hrdlicka, San Antonio, TX; Susanna W. Ratner, SeniorLAW Center, Philadelphia, PA

Employee Benefits: How Taxing Can They Be? The practice of employee benefits permeates the Internal Revenue Code, affecting employers of all sizes. This panel will provide an overview of common employee benefit issues that may arise in your tax practice and how to identify them early to take the necessary steps to bring an employer into compliance. The panelists will discuss issues arising in retirement, health, and welfare plans both in administrative practice and litigation. Moderator: Lany L. Villalobos, Law Clerk, US Tax Court, Washington, DC Panelists: Milan H. Kim, Senior Attorney, Office of Chief Counsel (Tax Exempt and Government Entities Division Counsel), IRS, Dallas, TX; Damarr M. Butler, Office of the General Counsel, Pension Benefit Guaranty Corporation, Washington, DC (Invited); Elverine “Rena” Felton, Mitchell & Titus LLP, Houston, TX

Private Equity: Key US Tax Considerations. The panel will provide an overview of key commercial objectives and US Federal income tax considerations relevant to private equity funds. The panel will highlight the different sensitivities relevant to various categories of investors and discuss how a “typical” private equity fund structure addresses these sensitivities. The panelists will walk-through the life cycle of a portfolio investment and illustrate how tax considerations impact the overall economics of the investment. The discussion will provide an introductory framework of tax rules applicable to private equity. No prior knowledge of or experience with private equity is necessary. Panelists: Alfred Bae, EY, Houston, TX; Wendy L. Kribell, Attorney, Associate Chief Counsel (Passthroughs and Special Industries), IRS, Washington, DC; Amit M. Sachdeva, EY, Houston, TX Co-Sponsored by: Investment Management

International Tax Developments: Cross-Border Tax Issues When Operating in Mexico. This panel will discuss recent developments and selected issues that arise when multinational entities conduct business in Mexico. Panel topics will include the multilateral instrument, the US-Mexico tax treaty, special business entities, transfer pricing and permanent establishment considerations, the manufacturing, maquila, and service industry (Maquiladora) program, employee tax considerations, and the 2005 Competent Authority Agreement on fiscally transparent entities (FTEs). Moderator: Brandon King, Attorney-Adviser for the Honorable Albert G. Lauber, US Tax Court, Washington, DC Panelists: Anne R. Gordon, PwC, Washington, DC; Matthew Mauney, Baker McKenzie, Houston, TX; Professor Bret Wells, University of Houston, Houston, TX; Tracy Villecco, Attorney, Associate Chief Counsel (International), IRS, Washington, DC

Session : ABATX1798
Tax Collections, Bankruptcy & Workouts
Collection Workshop: How to Represent Taxpayers in Collection Matters From the Notice and Demand Through the Notice of Determination
Conference : 2017 Joint Fall CLE Meeting
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$45.00

Collection Workshop: Part 1. This workshop will teach attendees strategies and techniques for effectively resolving collection matters before the IRS without litigation. A panel of experienced government and private bar attorneys will discuss techniques and strategies for responding to IRS collection notices, for presenting financial information to the IRS, and for presenting various collection alternatives, such as offers in compromise on the ground of doubt as to liability, doubt as to collectability, and effective tax administration, installment agreements, currently not collectible status, and innocent spouse. Moderator: Frank Agostino, Agostino & Associates PC, Hackensack, NJ Panelists: Giovanni Alberotanza, Rosenberg Martin Greenberg LLP, Baltimore, MD; Professor Bryan Camp, Texas Tech University School of Law, Lubbock, TX; Jessica Frase Marine, Frost & Associates, Annapolis, MD; Jill MacNabb, Senior Attorney Advisor, Taxpayer Advocate Service, Washington, DC; Sheila R. Pattison, Managing Counsel (Austin), Associate Area Counsel (SBSE), Office of Associate Chief Counsel, IRS, Austin, TX; Wm. Robert Pope Jr., White & Reasor PLC, Nashville, TN

Collection Workshop: Part 2. This workshop will teach attendees strategies and techniques for effectively resolving collection matters before the IRS without litigation. A panel of experienced government and private bar attorneys will discuss techniques and strategies for responding to IRS collection notices, for presenting financial information to the IRS, and for presenting various collection alternatives, such as offers in compromise on the ground of doubt as to liability, doubt as to collectability, and effective tax administration, installment agreements, currently not collectible status, and innocent spouse. Moderator: Frank Agostino, Agostino & Associates PC, Hackensack, NJ Panelists: Giovanni Alberotanza, Rosenberg Martin Greenberg LLP, Baltimore, MD; Professor Bryan Camp, Texas Tech University School of Law, Lubbock, TX; Jessica Frase Marine, Frost & Associates, Annapolis, MD; Jill MacNabb, Senior Attorney Advisor, Taxpayer Advocate Service, Washington, DC; Sheila R. Pattison, Managing Counsel (Austin), Associate Area Counsel (SBSE), Office of Associate Chief Counsel, IRS, Austin, TX; Wm. Robert Pope Jr., White & Reasor PLC, Nashville, TN

Session : ABATX1799
Transfer Pricing (TX)
Conference : 2017 Joint Fall CLE Meeting
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$15.00

Transfer Pricing Methods in Tax Court: Economic Considerations and Implications. Recent judicial decisions in the United States suggest that specific transfer pricing methods should be relied upon – or carefully considered – when valuing intangible property (IP) in the context of controlled transactions; for example, the Comparable Uncontrolled Transaction (CUT) method. In practice, the CUT method is often difficult to apply, on account of the strict comparability criteria under Treas. Reg. section 1.482-4. The transfer pricing methods that practitioners use for purposes of planning and representation in controversies seldom align with the methods applied in landmark transfer pricing judicial decisions. The panel of economists will discuss the impact of recent decisions on how transfer pricing practitioners approach intellectual property (“IP”) planning and controversy, including evaluating hazards of litigation. Specifically, the panel will explore why the courts often use the CUT method although other transfer pricing methods (e.g., the Comparable Profit Split Method) may be more reliable under some circumstances. The panel will also discuss the importance of contractual language in the context of IP ownership and how contractual differences may be taken into account in the economic analysis. Moderator: Tim Gunning, EY, New York, NY Panelists: Clark Chandler, Economics Partners LLC, Washington, DC; Rebel Curd, Charles River Associates, San Francisco, CA; George Korenko, Edgeworth Economics LLC, Washington, DC

Session : ABATX17100
Capital Recovery & Leasing
Conference : 2017 Joint Fall CLE Meeting
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$15.00

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: Kathleen Reed, Branch Chief – Branch 7, Income Tax & Accounting, IRS, Washington, DC; John Shepardson, Crowe Horwath, Atlanta, GA; Scott Dinwiddie, IRS Office of Chief Counsel (Income Tax & Accounting), Washington, DC

Placed in Service Dates and the Stine Case. With the bonus depreciation phase down fast approaching and recent law changes pertaining to items such as qualified improvement property, determining when an asset is placed in service has become a discussion point for many taxpayers. This panel will discuss the various tax determinations and related issues associated with asset placed in service dates, including a discussion of Stine v. U.S., Action on Decision 2017-02, and other related guidance. Moderator: Carol Conjura, KPMG, Washington, DC Panelists: Kathleen Reed, Branch Chief – Branch 7, Income Tax & Accounting, IRS, Washington, DC; Sam Weiler, EY, Columbus, OH; Lynn Afeman, KPMG, Washington, DC; John Eiman, Senior Counsel, Chief Counsel:LB:4, IRS, Houston, TX

Examination Experience with the Tangible Property Regulations. This panel will discuss recent examination experience pertaining to the tangible property regulations. Moderator: Ellen Martin, Grant Thornton LLP, Washington, DC Panelists: John Eiman, Senior Counsel, Chief Counsel:LB:4, IRS, Houston, TX: Marc Nickel, Pacific Gas and Electric Company, San Francisco, CA

Session : ABATX17101
Estate & Gift Taxes and Income & Transfer Tax Planning Group
Conference : 2017 Joint Fall CLE Meeting
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$30.00

Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since May 2017. Panelists: Brian P. Tsu, Henderson Caverly Pum & Charney LLP, San Diego, CA; Helen E. Rogers, Holland & Hart, Denver, CO; Megan M. Curran, Jones Walker LLP, New Orleans, LA; Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC

Family Limited Partnerships – Update. This program will discuss the latest developments in family limited partnerships, both from a regulatory and a case law standpoint. Panelists: Stephanie Loomis-Price, Winstead PC, Houston, TX; Additional Panelists TBD

Moving to Tax Paradise: Three Options for the Mobile Taxpayer. This program will explore the benefits and challenges associated with three options for taxpayers who have had enough of their current high tax location. We will discuss moving to a no tax state, a deceptively simple idea that requires a thorough understanding of income tax residence and domicile. We will then consider expatriating, which has significant practical and tax consequences, some of which remain unsettled. Finally, the unique benefits of becoming a resident of Puerto Rico will prove to be the ideal solution for the right taxpayer, but will disappoint many unfamiliar with the finer points of this tax regime. Panelists: Stephen Liss, UBS Financial Services Inc., New York, NY; Edgar-Rios Mendez, Pietrantoni Mendez & Alvarez, San Juan, PR; George D. Karibjanian, Franklin Karibjanian & Law PLLC, Boca Raton, FL

Step It Up – Don’t Waste Your Basis or Your Parent’s GST Exemption. This program will discuss two separate planning issues with regards to basis. First, the presenter will discuss how to preserve, or perhaps create, basis with married couples leaving Community Property states to non-Community Property states; second, the presenter will discuss how to create and use a Power of Appointment Support Trust (POAST) as a mechanism to care for parents, if necessary, create basis, and effectively use a senior generation’s otherwise unused GST exemption. This presentation will also explain how the POAST could be used as the vehicle to receive assets from GRATs and CLATs (after they have matured) in such a way that it may be more beneficial than using other planning vehicles. Panelist: Lester B. Law, Franklin Karibjanian & Law PLLC, Naples, FL

Session : ABATX17103
Affiliated & Related Corporations
Conference : 2017 Joint Fall CLE Meeting
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$30.00

Section 267: More than Granite Trust. This panel will focus on the operation of section 267, and in particular section 267(f), in the context of transactions involving members of an expanded affiliated group, including controlled foreign corporations. Remember, loss deferral might not end with a triggering event under Treas. Reg. § 1.1502-13! Moderator: Matthew White, KPMG LLP, Nashville, TN Panelists: Marie Milnes-Vasquez, IRS Office of Associate Chief Counsel (Corporate), Washington, DC; Tim Devetski, EY, Houston, TX; Victor Penico, Deloitte Tax LLP, San Francisco, CA

Current Developments. This panel will discuss current developments for consolidated groups, reviewing some of the latest private letter rulings, regulations, and cases. If applicable, the panel will also consider proposed tax legislation and its effect on affiliated corporations and consolidated groups. Moderator: Professor Don Leatherman, University of Tennessee, Knoxville, TN Panelists: Jerry Fleming, IRS Office of Associate Chief Counsel (Corporate), Washington, DC; Rebecca Holtje, KPMG, Washington, DC; Brian Peabody, EY, Washington, DC

Session : ABATX17104
Investment Management
Conference : 2017 Joint Fall CLE Meeting
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$30.00

Grecian Magnesite: Exiting Private Funds with ECI Investments. This panel will discuss Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, 149 T.C. No. 3 (2017), in which the Tax Court, rejecting the approach of Revenue Ruling 91-32, held that a foreign partner is not subject to U.S. tax on gain from the redemption of an interest in a partnership that is engaged in a US trade or business. The panel will discuss the possible impact of the decision on structuring private funds and exits. Moderator: Raj Tanden, Foley & Lardner LLP, Los Angeles, CA Panelists: Michael J. Miller, Roberts & Holland LLP, New York, NY; Amanda H. Nussbaum, Proskauer Rose LLP, New York, NY

Current Issues for Funds Making Energy-Related Investments. This panel will explore a variety of tax issues that arise when investment funds make energy-related investments. Topics will include structures to avoid UBTI and ECI, structures using blockers and issues arising on the sale or IPO of blocked and non-blocked investments. Moderator: Cheryl Coe, Latham & Watkins LLP, Washington, DC Panelists: R. David Wheat, KMPG, Dallas, TX; Nancy Mehlman, Simpson Thacher & Bartlett LLP, New York, NY

RIC Liquidations. This panel will discuss the tax issues that arise when a regulated investment company is liquidated. Topics will include final distributions, equalization accounting, personal holding company issues and the use of liquidating trusts. Moderator: Jeff Sion, Dechert LLP, New York, NY Panelist: Chris Scarpa, Stradley Ronon Stevens & Young LLP, Philadelphia, PA

Session : ABATX17105
Administrative Practice
Conference : 2017 Joint Fall CLE Meeting
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$30.00

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 and other items germane to tax administration. Moderator: Shamik Trivedi, Grant Thornton LLP, Washington, DC Panelists: Brendan O’Dell, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Robert Wearing, Office of Chief Counsel, Associate Chief Counsel (Procedure & Administration), IRS, Washington, DC; Kevin Stults, Skadden Arps Slate Meagher & Flom LLP, Washington, DC

Dawn of a New Era – the New Partnership Audit Rules Will Soon Be Upon Us. The rules and procedures for auditing partnerships will change dramatically for partnership years that start after December 2017. Proposed Regulations have been released but many questions still remain. This panel will discuss the new rules and procedures with a focus on how partnerships can prepare themselves to effectively manage the audit under these new procedures. Moderator: George Hani, Miller & Chevalier, Washington, DC Panelists: Brendan O’Dell, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Rochelle Hodes, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC; Daniel Baucum, Munsch Hardt Kopf & Harr PC, Dallas, TX

Information Gathering in a Tech-Savvy and Interconnected Tax World. This panel will examine the ways that the IRS and other taxing authorities can now obtain and exchange information in an increasingly interconnected world. It will also discuss new ways that taxpayers are communicating within their organizations (e.g. instant messaging and file sharing applications), and the effect of using these new communication methods on audits and the maintenance of privilege. Moderator: Gary Wilcox, Mayer Brown, Washington, DC Panelists: Roger Benesch, Acting ADCI Program Manager, LB&I, Farmers Branch, TX; Jeremiah Coder, OECD, Paris, France; Kiara Rankin, Eaton Corporation, Houston, TX

Session : ABATX17106
Closely Held Businesses and Business Planning Group (morning)
Conference : 2017 Joint Fall CLE Meeting
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Partnership Audit Rules: Update and Practical Considerations for Closely Held Businesses. This panel will discuss the recent developments in the partnership audit rules with an emphasis on drafting techniques and planning considerations for closely held businesses. Panelists: Shawn McIntire, Ballard Spahr LLP, Denver, CO; Allie Petrova, Petrova Law, Greensboro, NC; Ivan Golden, Schiff Hardin, Chicago, IL

Recent Self-Employment Cases and Planning Implications. This panel will discuss the recent Tax Court self-employment cases Castigliola, Fleischer and Hardy and their impact on planning for self-employed individuals. Panelists: Adam Abrahams, Meyers Hurvitz Abrahams LLC, Rockville, MD; Sabrina Strand, Law Offices of Joseph H. Thibodeau PC, Denver, CO; Kevin Bender, McGuireWoods, Richmond, VA

New Issues in Partnership Freezes. Partnership freeze structure can be deployed in a variety of ways in addition to the typical estate planning usage. This panel will discuss the use of partnership freezes in estate planning, as well as various other uses for the same or similar freeze structures, including planning for employee equity compensation, structuring payments to departing S corporation shareholders or partners, and providing a holding device for S corporations subject to the BIG tax. Panelists: Elizabeth Fialkowski Stieff, Venable LLP, Baltimore, MD; Brian Masterson, Butler Snow, Nashville, TN; Jeffrey Gonya, Venable LLP, Baltimore, MD

Session : ABATX17107
Real Estate
Conference : 2017 Joint Fall CLE Meeting
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Hot Topics. This panel will discuss recent developments, including legislation, regulations, administrative guidance, and noteworthy cases in the area of real estate and partnership tax. Moderator: Jessica Millett, Duval & Stachenfeld, New York, NY Panelists: Monisha Santamaria, EY, Los Angeles, CA; Clifford Warren, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries), IRS Office of Chief Counsel, Washington, DC; Adam Handler, PwC, Los Angeles, CA

Health Care Property REIT Structures and Issues. RIDEA provided REITs with new opportunities to invest in health care properties. This panel will describe the RIDEA structures and highlight issues and risks for REITs that use it. Moderator: Joseph G. Howe III, Arnold & Porter Kaye Scholer, Washington, DC Panelists: Dianne Umberger, EY, Washington, DC; Nickolas Gianou, Skadden, Chicago, IL; Andrea M. Hoffenson, Chief, Branch 2, Associate Chief Counsel (Financial Institutions and Products), IRS Office of Chief Counsel, Washington, DC

Tax Protection Agreements and the “New” Section 752 Regulations. The temporary section 752 regulations eliminated “bottom dollar” guarantees and changed the way liabilities are allocated under section 752. This panel will explore how these changes impact industry standard tax protection agreements and similar limited partner protections. Moderator: Maher Haddad, Baker & McKenzie, Chicago, IL Panelists: Nicole D. Brown, Hogan Lovells, Washington, DC; Clifford Warren, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries), IRS Office of Chief Counsel, Washington, DC

Applying the New Partnership Audit Rules to Real Estate Investment Structures. This panel will discuss issues in applying the new partnership audit rules to common real estate investment structures. Moderator: Kate Kraus, EY, Los Angeles, CA Panelists: Michael J. Hauswirth, PwC, Washington, DC; Brendan O’Dell, Attorney-Advisor, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Glenn E. Dance, Grant Thornton, Arlington, VA

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