Chair: Alexandra Minkovich, Baker & McKenzie, Washington, DC
This panel will include a report from the Tax Court, discussion of significant IRS guidance and litigation, an update on Tax Division priorities, a report from Treasury, and a discussion of significant pending litigation. The panel will also briefly discuss the final rules promulgated by the Court concerning BBA issues with partnership cases.
Moderator: Jeffrey M. Glassman, Meadows Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TX
Panelists: Chief Judge Maurice B. Foley, US Tax Court, Washington, DC (Invited); Richard G. Goldman, Deputy Associate Chief Counsel, IRS Office of Associate Chief Counsel (Procedure and Administration), Washington, DC (Invited); Joshua Wu, Deputy Assistant Attorney General (Policy and Planning), Department of Justice, Tax Division, Washington, DC
Collections of Foreign Tax Judgments: When Your Other Problems Come Home.
This panel will explore the means and methods by which foreign governments come onshore to try and collect their tax determinations and judgments in the United States, including through the use of bilateral tax treaties and US judicial proceedings. The panel will also identify the defenses and limitations to such actions, including through jurisdictional limits such as the Revenue Rule a longstanding principle of the US and international law that prohibits one sovereign from using courts of another sovereign to enforce its revenue laws.
Moderator: Mark D. Allison, Caplin & Drysdale Chartered, New York, NY
Panelists: Nathaniel B. Parker, Senior Counsel, IRS Office of Associate Chief Counsel (International), Washington, DC (Invited); Zhanna A. Ziering, Caplin & Drysdale Chartered, New York, NY; Lawrence A. Sannicandro, McCarter & English LLP, Newark, NJ
Conservation Easements – Trying Times.
Conservation easements have been under extraordinary IRS scrutiny in recent years resulting in numerous examinations. Many of those examinations are now in litigation or headed toward litigation. From that perspective, this panel will discuss what it takes to try a conservation easement case. The panelists will discuss relevant expert witnesses, expert reports, key fact witnesses, and other considerations for the litigating counsel.
Moderator: Anson Asbury, Asbury Law Firm, Decatur, GA
Panelists: Frank Agostino, Agostino & Associates, Hackensack, NJ; Jenny Ware Johnson, Johnson & Moore, Chicago, IL; Ronald Levitt, Sirote & Permutt, Birmingham, AL