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2018 May Meeting

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Showing sessions 1 - 10 of (43) TOTAL sessions
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Event : ABATX39

Session : ABATX1845
Tax Bridge to Practice
Conference : 2018 May Meeting
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$75.00

A Conversation with... Drita Tonuzi, Deputy Chief Counsel (Operations), Internal Revenue Service. Drita Tonuzi serves as the Deputy Chief Counsel (Operations), where she provides legal guidance and litigation support to the Internal Revenue Service (IRS) and the Departments of Treasury and Justice in all matters pertaining to the administration and enforcement of the Internal Revenue laws. She is responsible for all litigation in the United States Tax Court, the management of personnel in 50 field offices nationwide and in headquarters operations in Washington, DC, and supervision of nine IRS Divisions. Tax Bridge to Practice is honored to welcome Ms. Tonuzi as our featured practitioner for its “A Conversation with...” series at the 2018 May Meeting.

A Renewed Focus on CoGS. The exception for Costs of Goods Sold (CoGS) from the new Base Erosion and Anti-Avoidance Tax (BEAT) has brought a renewed interest in understanding the contours of this tax accounting concept. This panel will provide a review of BEAT, section 263A, and CoGS with focus on the mechanics of section 263A (the Uniform Capitalization rules). The panelists also will address the relevant administrative guidance, case law, and the applicability of CoGS to BEAT. Moderator: Anne Gordon, PwC, Washington, DC Panelists: Neville Jiang, Deloitte, Washington, DC; Jeffery Mitchell, Branch Chief, Office of Associate Chief Counsel (International), IRS, Washington, DC; Natasha Mulleneaux, Attorney, Office of Associate Chief Counsel (Income Tax & Accounting), Washington, DC; Elizabeth Stevens, Caplin & Drysdale, Washington, DC Co-Sponsored by: Foreign Activities of US Taxpayers and Tax Accounting

The Ins and Outs of Litigating Penalties. During the 2017 year, the IRS assessed 39 billion separate penalties totaling more than $26.5 billion dollars. Most practitioners are familiar with the negligence and substantial understatement components of the accuracy penalty, which are assessed at 20% of the tax. This panel will address situations where the accuracy penalty may be imposed at a higher rate (30% or 40%), including gross valuation misstatements, undisclosed non-economic substance transactions, undisclosed foreign financial asset understatements and undisclosed listed and other avoidance transactions. The PROGRAM SCHEDULE THURSDAY, MAY 10 21  = Taped  = Young Lawyers Program  = Ethics Credits Requested = No CLE Credit panelists will also discuss the penalties most likely to be encountered in litigation as well as available defenses. In addition to the accuracy-related penalties due to a gross valuation misstatement, the panel will also discuss penalties for an undisclosed foreign financial asset understatement, and undisclosed listed and other avoidance transactions. Moderator: Kelley C. Miller, Reed Smith LLP, Washington, DC Panelists: Lawrence A. Sannicandro, McCarter English, Newark, NJ; Adriana Lofaro, Wirtz Cooley LLP, New York, NY; Lacey Strachan, Hochman Salkin Rettig Toscher & Perez, Los Angeles, CA Co-Sponsored by: Court Procedure & Practice

Dude, Where’s My Refund? An Overview of Joint Committee Review of Tax Refunds. This panel explores the role of the Joint Committee on Taxation (“JCT”) with respect to taxpayer claims for refund. Aside from its important work in advising members of Congress, the JCT also has a statutorily mandated role in reviewing certain large refund claims by taxpayers. Panelists from private practice and government will shed some light on how cases are referred to the JCT, and how the JCT conducts its review. Panelists: Janet E. Kidd, Senior Technician Reviewer, Office of Associate Chief Counsel (Procedure & Administration), IRS, Washington, DC; Kandyce Korotky, Covington & Burling LLP, Washington, DC; Paul McLaughlin, Legislation Counsel, Joint Committee on Taxation, Washington, DC; Mary Slonina, PwC, Washington, DC; Shamik Trivedi, Grant Thornton LLP, Washington, DC Co-Sponsored by: Court Procedure & Practice

Crypto-Currency: Disclosure & Audits, What to Do and How to Handle. Cryptocurrencies have gained significant attention since the introduction of Bitcoin in 2009, the first decentralized cryptocurrency, from which hundreds more cryptocurrencies have been derived. Concurrent with the evolution of the cryptocurrencies, the U.S. Department of Treasury and the Internal Revenue Service have focused on taxpayers who have unreported foreign financial assets and accounts. Cryptocurrency-related tax liabilities are at estimated to be $25 billion as a result of $92 billion of taxable gains for U.S. cryptocurrency investors during 2017 alone. This panel, comprised of many of the authors of the Section’s recent comments on cryptocurrency and disclosure, will provide an overview of virtual currencies, the IRS guidance related to the same, how cryptocurrency should be dealt with during an audit, reporting compliance and options for taxpayer disclosure of cryptocurrencies. Moderator: Kelley C. Miller, Reed Smith LLP, Washington, DC Panelists: James P. Beatty, Attorney, Office of Associate Chief Counsel (Income Tax & Accounting), Washington, DC; Bridget E. Tombul, Branch Chief, Office of Associate Chief Counsel (Income Tax & Accounting), Washington, DC; Hasnain Valika, KPMG, Houston, TX; Lawrence Sannicandro, McCarter English, Newark, NJ; Michael Sardar, Kostelantz and Fink, New York, NY; Sahel Assar, Buchannan Ingersoll, Washington, DC; Michel Stein, Hochman Salkin Rettig Toscher & Perez, Los Angeles, CA; Carina C. Federico, Steptoe & Johnson LLP, Washington, DC Co-Sponsored by: Tax Accounting

Session : ABATX1846
Low Income Taxpayer Representation Workshop
Conference : 2018 May Meeting
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The 2017 Tax Act and Low-Income Families. Panelists will explain aspects of the 2017 Tax Act that Low-Income Taxpayer Representatives need to know in order to effectively advise and represent their clients in individual income tax matters, including changes to taxation of alimony, child-related tax benefits, and filing thresholds. Moderator: Tamara A. Borland, IRS Taxpayer Advocate Service, Washington, DC Panelists: Joshua R. Beck, IRS Taxpayer Advocate Service, Des Moines, IA; Phyllis Horn Epstein, Epstein Shapiro & Epstein PC, Philadelphia PA; Lisa Sperow, Cal Poly Low Income Taxpayer Clinic, San Luis Obispo, CA Co-Sponsored by: Individual & Family Tax

The 2017 Tax Act and Self-Employed Workers. This panel will discuss new code section 199A as well as tax planning issues for self-employed and “gig economy” workers in light of the changes made by the 2017 Tax Act. Moderator: Caleb Smith, Ronald M. Mankoff Tax Clinic, University of Minnesota Law School, Minneapolis, MN Panelists: Jennifer Brown, American University Kogod School of Business, Washington, DC; Caroline Bruckner, American University Kogod School of Business, Washington, DC; Eric LoPresti, IRS Taxpayer Advocate Service, Washington, DC; Gina DeConcini, Moss & Barnett, Minneapolis, MN

History and Context: “Tax Reform” Efforts of the Past 50 Years. Panelists will provide valuable context and historical perspective on recent tax law changes and ongoing tax reform efforts. Moderator: Professor Sonya Watson, Rosenblum Family Foundation Tax Clinic, University of Nevada, Las Vegas, Las Vegas, NV Panelists: Armando Gomez, Skadden Arps Slate Meagher & Flom LLP, Washington, DC; Gregory F. Jenner, Stoel Rives LLP, Washington, DC; Nina E. Olson, National Taxpayer Advocate, IRS Taxpayer Advocate Service, Washington, DC; Alexander L. Reid, Morgan Lewis & Bockius LLP, Washington, DC

Session : ABATX1847
Capital Recovery & Leasing
Conference : 2018 May Meeting
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TTax Reform and Its Implications for Leasing Transactions. This panel will discuss the various tax issues related to tax reform and its impact on leasing transactions. Sample topics of discussion include section 451(b) and the exception for section 467, section 163(j), the elimination of certain like kind exchanges, net operating losses, 100 percent bonus depreciation, section 199A and sale/lease back planning. Moderator: Glenn Johnson, EY, Washington, DC Panelists: Kate Abdoo, PwC, Stamford, CT; Scott Dinwiddie, Associate Chief Counsel, IRS – Income Tax & Accounting, Washington, DC; Brinton Warren, Special Counsel, IRS – Income Tax & Accounting, Office of Associate Chief Counsel, Washington, DC; Forest Boone, Branch 5, IRS – Income Tax & Accounting, Washington, DC

TTax Reform and Its Implications for Fixed Assets. This panel will discuss the various tax issues related to tax reform and how it will impact taxpayer requirements for capital recovery. Sample topics covered will include what constitutes used property, implications for property with a long production period, and binding contract rules. Moderator: Richard Shevak, CohnReznick LLP, Roseland, NJ Panelists: Jane Rohrs, Deloitte, Washington, DC; Kathleen Reed, Branch Chief 7, IRS – Income Tax & Accounting, Washington, DC; Elizabeth Binder, Branch 7, IRS – Income Tax & Accounting, Washington, DC; Natalie Tucker, Legislative Tax Accountant, Joint Committee on Taxation, 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: Ryan Corcoran, RSM, Madison, WI Panelists: Andrea Mouw, Eide Bailly, Minneapolis, MN; Scott Dinwiddie, Associate Chief Counsel, IRS – Income Tax & Accounting, Washington, DC; Kathleen Reed, Branch Chief 7, IRS – Income Tax & Accounting, Washington, DC; Ellen Martin, Tax Policy Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited)

Session : ABATX1848
Administrative Practice
Conference : 2018 May Meeting
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Important Developments. This panel will discuss current developments and topics of immediate interest in tax administrative practice. Panel will focus on recent legislative efforts impacting tax law and the IRS, Treasury and IRS guidance, court decisions, ongoing litigation and other items germane to tax administration. Moderator: Kat Gregor, Ropes & Gray, Boston, MA Panelists: Kathryn Zuba, Associate Chief Counsel (Procedure and Administration), IRS, Washington, DC; Brendan O’Dell, Department of Treasury, Washington, DC; James Gadwood, Miller & Chevalier, Washington, DC

A Day in the Life of a Partnership Representative. Under the new partnership audit regime, the “Partnership Representative” or “PR” has a lot power when it comes to an IRS examination of a partnership. This panel will examine the roles and the responsibilities of this important position and options for how partnerships, their partners and the partnership representative could structure this relationship, including the ways the parties may wish to document the relationship, with contracts or other agreements. Moderator: Chuck Hodges, Jones Day, Atlanta, GA Panelists: Joy Gerdy-Zogby, Attorney, Office of Associate Chief Counsel (Procedure & Administration), Washington, DC; Dave Straub, CSC Global, Wilmington, DE; Sarah Brodie, Morgan Lewis & Bockius LLP, Washington, DC

Tips and Best Practices for Holding an Effective Virtual Appeals Conference. Battling resource constraints, Appeals requires campus case hearings to be conducted telephonically. For some taxpayers and their representatives, even if a face-to-face conference is available, their hearing many not be scheduled in close proximity to where they reside and travel may not be feasible for one reason or another, making a virtual conference mandatory. While most practitioners agree there is no substitute for a face-to-face conference, there are best practices to ensure the parties achieve the best communication possible. This panel will discuss tips and techniques to effectively participate in a virtual appeals conference. Moderator: Mary Slonina, PwC, Washington, DC Panelists: Andrew Keyso, Deputy Chief, Appeals, IRS, Washington, DC; Robert Bryant, Appeals Team Manager, IRS, Washington, DC; Matt Cooper, EY, Washington, DC; Carol Luttati, The Law Offices of Carol Luttati, New York, NY

Session : ABATX1849
Banking & Savings Institutions
Conference : 2018 May Meeting
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Tax Considerations for Credit/Loan and Security Agreements. Credit/loan and security agreements entered into between taxpayers and financial institutions generally contain similar tax-related provisions. Professional associations have published model credit agreements, which provide a form of agreement that is often used in financing transactions. This panel is going to discuss tax aspects of credit agreement, with a discussion of provisions that have been affected by the 2017 Tax Act. Moderator: James H. Combs, Honigman Miller Schwartz and Cohn LLP, Detroit, MI Panelist: Elena Romanova, Latham & Watkins LLP, New York, NY

Tax Issues for Banking and Savings Institutions Dealing in Cryptocurrency. Cryptocurrencies and ICOs continue to proliferate. This panel will consider issues pertinent to banks and other financial institutions raised by cryptocurrencies, including amount, character, timing and source of income and deductions from cryptocurrency loans and borrowings, treatment of cryptocurrency derivatives, and reporting and withholding obligations. Additionally, unique tax issues associated with ICOs will also be addressed. Panelists: Stow Lovejoy, Kostelanetz & Fink LLP, New York, NY; Anthony Tuths, KPMG, New York, NY; Stevie D. Conlon, Wolters Kluwer Financial Services, Arlington Heights, IL

Session : ABATX1850
Estate & Gift Taxes
Conference : 2018 May Meeting
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Current Developments. This panel will review developments in federal estate, gift and generation-skipping transfer tax laws since January 2018. Panelists: Brian P. Tsu, Henderson Caverly Pum & Charney LLP, San Diego, CA; Helen E. Rogers, Holland & Hart, Denver, CO; Megan M. Curran, Fiduciary Counselling Inc., Tacoma, WA; Catherine V. Hughes, Office of Tax Policy, Department of Treasury, Washington, DC

GRRR (Gift Return Reporting Requirements): Taming the Wild 709 Tiger. This presentation will provide an overview of the rules regarding reporting gifts on IRS Form 709 for both gift and generation-skipping transfer tax purposes. Furthermore, the presentation will highlight the importance of adequate disclosure and discuss common Form 709 reporting errors. Panelist: Christine Wakeman, Winstead PC, Dallas, TX

The Anatomy of the 706 – An Overview of the Federal Estate Tax Return and Tips on Reporting Entries. This presentation will provide an explanatory overview of the 706 and its schedules, and will include some "not-so-well-known" tips on how to report certain assets and deductions. Panelists: George D. Karibjanian, Franklin Karibjanian & Law PLLC, Boca Raton, FL; Beth Kerwin, Paul Weiss Rifkind Wharton & Garrison LLP, New York, NY

Dirt and Taxes: Estate Planning for Real Estate Investors. Join us for a discussion of gift and estate planning for real estate entrepreneurs and investors, with the important interface of key income tax issues – including the deal structure, utilizing discounts in value and grantor trusts, negative capital accounts, the essential 754 election and liquidity issues. Panelists: Stefan F. Tucker, Venable LLP, Washington, DC; Sarah Moore Johnson, Birchstone Moore LLC, Washington, DC

Session : ABATX1851
Investment Management
Conference : 2018 May Meeting
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Treaty Issues for Offshore Funds and Foreign Investments. The panel will discuss: 1) the use of tax treaty “independent agent” structures for funds that desire to participate in loan origination activities in the United States and 2) the “Multilateral Instrument” (MLI), which grew out of the BEPS process and has now been approved by over 100 countries; the MLI will trigger a significant change in the ground rules for interpreting and applying tax treaties world-wide; in particular, the so-called “principal purpose test” (PPT) will require close analysis of the entitlement to treaty benefits in many cases. Moderator: Rick Reinhold, Willkie Farr & Gallagher LLP, New York, NY Panelist: David Lawless, Dillon Eustace, Dublin, Ireland

Planning for Fund Managers and GPs after Tax Reform. The panel will explore various tax planning opportunities for fund managers and general partners after tax reform. Moderator: David S. Miller, Proskauer Rose LLP, New York, NY Panelists: Stuart E. Leblang, Akin Gump Strauss Hauer & Feld LLP, New York, NY; Jeffrey W. Maddrey, PwC, Washington, DC;

Updates from the Internal Revenue Service and Investment Company Institute. Representatives from the IRS and the Investment Company Institute will discuss provisions of interest to investment companies under the Tax Cuts and Jobs Act and requests for guidance.Moderator: Katie Sunderland, Investment Company Institute, Washington, DC Panelists: Karen Gibian, Investment Company Institute, Washington, DC; Mark Erwin, Financial Institutions & Products, IRS Office of Chief Counsel, Washington, DC; Steven Harrison, Financial Institutions & Products, IRS Office of Chief Counsel, Washington, DC

Session : ABATX1852
Real Estate
Conference : 2018 May Meeting
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Hot Topics. This panel will focus on new judicial, legislative, and administrative guidance and other recent developments relating to the taxation of real estate and partnerships. Moderator: Eric B. Sloan, Gibson Dunn, New York, NY Panelists: Sam Kamyans, Baker McKenzie, Washington, DC; Holly Porter, Associate Chief Counsel (Passthroughs and Special Industries), IRS, Washington, DC; Bryan A. Rimmke, Attorney-Advisor, Department of Treasury, Office of the Tax Legislative Counsel, Washington, DC (Invited)

Conducting a Real Estate Business Under the 2017 Tax Act. This panel will provide an overview of the key changes from the 2017 Tax Act impacting various real estate businesses. Moderator: Adam S. Feuerstein, PwC, Washington, DC Panelist: Kimberly Arndt, PwC, McLean, VA

Tax Reform – Section 163(j), Part I. This panel will provide a detailed discussion of the limitation on deductions for interest under new section 163(j), focusing on its application to partnerships and real estate trades or businesses. Part II will take place during the Partnerships and LLCs Committee meeting and will focus on applying the provision to partnerships and their partners. Moderator: Amanda H. Nussbaum, Proskauer, New York, NY Panelists: Monisha Santamaria, EY, Los Angeles, CA; Craig A. Gerson, PwC, Washington, DC; Brett York, Associate International Tax Counsel, Department of Treasury, Washington, DC (Invited)

Tax Reform – Section 168(k). The panel will provide a detailed discussion of new section 168(k) regarding temporary 100 percent expensing for certain business assets, with an emphasis on applications to real estate. Moderator: Jason Dexter, KPMG, Washington, DC Panelists: Kathleen Reed, Branch Chief, IRS – Income Tax & Accounting, Branch 7 Washington, DC; Ellen McElroy, Eversheds Sutherland, Washington, DC; Richard G. Blumenreich, KPMG, LLP, Washington, DC

Session : ABATX1853
Individual & Family Taxation
Conference : 2018 May Meeting
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Helping the Gig Workforce – Practice and Policy Perspectives. A review of federal, state and local taxes relevant to gig workers, tax issues, and policy considerations in modernizing our tax systems to address a growing work pattern. Panelists: Jennifer Brown, Kogod Tax Policy Center, American University, Washington, DC; Caroline Bruckner, Kogod Tax Policy Center, American University, Washington, DC; Annette Nellen, San Jose State University, San Jose, CA

Taxpayer Rights: To What End (Part 1). In 2014, IRS adopted a taxpayer bill of rights and in 2015 Congress codified those rights by requiring that the Commissioner ensure that IRS employees are familiar with and act in accord with those rights. IRC § 7803(a)(3). In this panel, we will examine the use of the taxpayer bill of rights (TBOR) in tax controversies generally, as well as consider its application in the context of recent high-profile litigation between Facebook and the IRS, the application of similar legislation in state controversies, and the implications of the absence of a specific remedy associated with rights violations. This is the first of a two-part panel and is cosponsored by the Tax Clinics and Pro Bono Committee and the Individual & Family Tax Committee. Part Two, which will focus more on issues relating to lower income taxpayers and also consider recent National Taxpayer Advocate initiatives and recommendations, will be held Saturday morning at the Pro Bono and Tax Clinics Committee. Moderator: Professor Alice Abreu, Temple University Beasley School of Law, Philadelphia, PA Panelists: Peter Faber, McDermott Will and Emery, New York, NY; Professor Richard K. Greenstein, Temple University Beasley School of Law, Philadelphia, PA; Professor Leandra Lederman, Indiana University Maurer School of Law, Bloomington, IN; Christopher S. Rizek, Caplin & Drysdale, Washington, DC

Nudging and Educating Taxpayers to Comply: Reevaluating Traditional Approaches to Taxpayer Compliance. Traditional approaches to ensuring tax compliance have largely assumed that taxpayers make rational economic decisions based on sanctions and likelihood of detection in deciding whether to comply. Recently, there has been increased attention toward wider range of behavioral factors that may contribute to tax compliance. In this panel, we will explore (i) the theoretical background for these more recent insights, (ii) government efforts to test these insights, including a recent Taxpayer Advocate Service study that examines whether written communications with taxpayers improved subsequent compliance with the earned income tax credit (EITC), and (iii) scholarship that suggests that the government should supplement traditional compliance measures with approaches that apply insights from the field of behavioral economics. Moderator: Lany L. Villalobos, Law Clerk, US Tax Court, Washington, DC Panelists: Dave Williams, Intuit, San Diego, CA; Jeff Wilson, Senior Advisor, IRS Taxpayer Advocate Service, Indianapolis, IN; Professor Leslie Book, Villanova University Charles Widger School of Law, Villanova, PA; Emily Schmitt, Department of Health and Human Services, Washington, DC

Session : ABATX1854
Affiliated & Related Corporations
Conference : 2018 May Meeting
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Applying the 2017 Tax Act to Troubled Companies Filing Consolidated Returns— Selected Issues. The panel will discuss selected issues raised when applying the provisions in the 2017 Tax Act to troubled companies filing consolidated returns. Topics covered will include the application of new section 163(j), the new NOL rules under section 172, and consolidated section 382. Moderator: Jonathan Forrest, Deloitte Tax, Washington, DC Panelists: Olivia Orobona, PwC, Washington, DC; David Wheat, KPMG, Dallas, TX; Kevin Jacobs, IRS Office of Associate Chief Counsel (Corporate), Washington, DC

Current Developments and 2017 Tax Act Guidance Themes. This panel will consider current developments affecting affiliated and related corporations. Relatedly, the panel will consider common issues and themes for possible 2017 Tax Act guidance projects, with a particular focus on groups with foreign affiliates. Moderator: Donald W. Bakke, EY, Washington, DC Panelists: Britt Haxton, McDermott Will and Emery, Washington, DC; Cody Forgey, EY, Washington, DC; Brett York, Office of Tax Policy, Department of Treasury, Washington DC; Julie Wang, IRS Office of Associate Chief Counsel (Corporate), Washington, DC

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