• 2020 May Tax Meeting April 30 - May 2, 2020 Marriot Marquis, Washington, DC

     
  • Order audio recordings from the 2020 Midyear Tax Meeting being held January 30 – February 1 in Boca Raton, FL.

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  • Chair: Mary I. Slonina, PwC, Washington, DC 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: Antoinette Ellison, Jones Day, Atlanta, GA Panelists: Chuck Hodges, Jones Day, Atlanta, GA; Kathryn A. Zuba, Associate Chief Counsel, IRS Office of Associate Chief Counsel (Procedure and Administration), Washington, DC Practical Privilege Issues. Would your client rather give their documents to the IRS, the New York Times, or both? This panel will discuss the rules protecting communications from disclosure, using real-world examples. We will also touch on hot topics and best practices. Panelists: Paul Butler, Kostelanetz & Fink LLP, Washington, DC; Abbey Garber, Thompson & Knight, Dallas, TX; Peter K. Reilly, Special Counsel, IRS Office of Associate Chief Counsel (Procedure and Administration), Washington, DC; Melissa Wiley, Ernst & Young LLP, Washington, DC Preparing For and Managing an IRS Examination with Virtual Currency Issues. This panel will discuss IRS efforts in encouraging and reviewing taxpayer reporting of virtual currency transactions, including recent efforts in issuing “educational letters” to taxpayers and the Virtual Currency Compliance Campaign. The panel will also discuss best practices to prepare for and manage an IRS examination of virtual currency issues. Moderator: Daniel Strickland, Eversheds Sutherland, Washington, DC Panelists: Rochelle Hodes, Crowe LLP, Washington, DC; Richard Sapinski, Sills Cummis & Gross, Newark, NJ; Zhanna Ziering, Caplin & Drysdale, New York, NY
  • Chair: Olivia Orobona, PwC, Washington, DC The Interaction of the TCJA and the Intercompany Transaction Regulations. This panel will explore the interplay of the intercompany transaction rules and various TCJA provisions, including section 163(j), section 168(k), section 245A, GILTI, FDII, and BEAT. Moderator: Bryan Collins, Andersen, Washington, DC Panelists: Matthew Gareau, Deloitte Tax LLP, Washington, DC; Andrew Dubroff, EY, Washington, DC; Marie Milnes-Vasquez, Special Counsel, IRS Chief Counsel, Washington, DC Current Developments. This panel will consider current developments affecting affiliated and related corporations, including implications from the expiration of temporary section 385 regulations, as well as the final and proposed BEAT and FTC regulations. Moderator: Don Bakke, EY, Washington, DC Panelists: Andrew Herman, EY, Washington, DC; Ciara Johnson, PwC, McLean, VA; Russell Jones, Senior Counsel, IRS Office of Associate Chief Counsel (Corporate), Washington, DC
  • Chair: Sam Weiler, EY, Columbus, OH Current Developments and Update on Pending Guidance. This panel will cover the important recent developments in the areas of capital recovery and leasing. Moderator: Jessica Hawn, Andersen, Chicago, IL Panelists: Kathy Reed, Branch Chief, Branch 7, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC (Invited); Wendy Friese, Tax Policy Advisor, Department of Treasury, Washington, DC (Invited); Andrew Eisinger, Crowe, Atlanta, GA Transactions and Bonus Depreciation. This panel will discuss various corporate and partnership transactions and their impact on the availability of bonus depreciation under section 168(k). Moderator: Nicole Field, EY, Washington, DC Panelists: Kathy Reed, Branch Chief, Branch 7, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC (Invited); Wendy Friese, Tax Policy Advisor, Department of Treasury, Washington, DC (Invited); Mark Weiss, Branch Chief, Branch 2, Office of Chief Counsel – Corporate, IRS, Washington, DC (Invited); Bryan Rimmke, Attorney-Advisor, Department of Treasury, Washington, DC (Invited); Jason Dexter, KPMG, Washington, DC; Richard Nugent, Jones Day, New York, NY Implementing the Bonus Depreciation Regulations. This panel will be focused on the procedural aspects of implementing the final and re-proposed bonus depreciation regulations under section 168(k), with a specific focus on the issues and opportunities raised by the recent guidance and the actions that taxpayers can take to align their current and prior year return positions with the regulations. Moderator: Jane Rohrs, Deloitte, Washington, DC Panelists: Kathy Reed, Branch Chief, Branch 7, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC (Invited); Wendy Friese, Tax Policy Advisor, Department of Treasury, Washington, DC (Invited); Jaime Park, Attorney, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC (Invited); Andrea Mouw, Eide Bailley, Minneapolis, MN
  • Chair: Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC Vice Chairs: Jenny Johnson Ware, Johnson Moore, Chicago, IL; Michael A. Villa Jr., Meadows Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TX; Brian C. McManus, Latham & Watkins LLP, Boston, MA Reports of Subcommittees on Important Developments. Important Developments (Civil) – Michelle F. Schwerin, Capes Sokol, St. Louis, MO and Claire H. Taylor, Stokes Lawrence, Seattle, WA; Important Developments (Criminal) – Evan J. Davis, Hochman Salkin Toscher & Perez PC, Beverly Hills, CA and Sara G. Neill, Capes Sokol, St. Louis, MO; International Tax Enforcement – Bruce Zagaris, Berliner Corcoran & Rowe LLP, Washington, DC, Sahel A. Assar, Buchanan Ingersoll & Rooney, PC, Washington, DC, and Joseph M. Erwin, Dallas, TX; IRS Investigations and Practices – Mary Wood, Meadows Collier Reed Cousins Crouch & Ungerman LLP, Dallas, TX and Eric L. Green, Green & Sklarz LLC, New Haven, CT; Legislative and Administrative Developments – Beverly Winstead, The Law Office of Beverly Winstead, LLC and Robert J. Kovacev, Steptoe & Johnson, Washington, DC; Monetary Violations and Forfeitures – Chad Nardiello, Nardiello Law Firm, Los Angeles, CA, Joseph A. Rillotta, Drinker Biddle & Reath LLP, Washington, DC, and Matthew D. Lee, Fox Rothschild, LLP; Offshore Compliance and Enforcement – Arielle Borsos, Office of Chief Counsel, IRS, Washington, DC, Victor Jaramillo, Caplin & Drysdale, Chtd, Washington, DC, and Michael Sardar, Kostelanetz & Fink LLP, New York, NY; Sentencing Guidelines – Phillip Colasanto, Agostino & Associates, PC, Hackensack, NJ, and Jeffrey A. Neiman, Marcus Neiman Rashbaum & Pineiro, LLP, Fort Lauderdale, FL Update: Tax Division, U.S. Department of Justice. Moderator: Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC Panelist: Richard Zuckerman, Principal Deputy Assistant Attorney General, Tax Division, Department of Justice, Washington, DC The Long Road: Laying the Foundation for Trial during the Audit. With an eye towards the courtroom, this panel will discuss what tactics and strategies that need to be considered as early as the initial letter commencing an audit, including how to respond to IDR, whether to insist on the issuance of a summons, does it make sense to quash/not respond to a summons, should the Taxpayer agree to be interviewed and should the Taxpayer answer substantive questions. And then once the trial begins, the panel will discuss how to subpoena government witnesses, whether to stipulate to certain facts, how to deal with the admissibility of foreign records, and how best to prepare your client to testify. Moderator: Jeffrey A. Neiman, Marcus Neiman Rashbaum & Pineiro LLP, Ft. Lauderdale, FL Panelists: Nicole Elliott, Holland & Knight LLP, Washington, DC; Sandy Boxerman, Capes Sokol, St. Louis, MO; Frank Agostino, Agostino & Associates, Hackensack, NJ; Kevin Downing, Law Office of Kevin Downing, Washington, DC The Age of Promoter Penalties: Fighting the Good Fight. Tax and other professionals often give advice on things like how to structure an investment in a business venture, sell an asset, plan for retirement or pass wealth to the next generation. Sometimes a practitioner’s tax advice turns out to be wrong and the IRS assesses a tax deficiency against the taxpayer. In today’s enforcement environment, with a heightened focus on captive insurance companies, syndicated conservation easements, foreign trust arrangements, and other tax advantaged structures, it is critical to understand the various promoter penalties, available defenses, and best practices. The panel will also discuss possible options for extricating clients from such transactions. Moderator: Matthew Mueller, Wiand Guerra King, Tampa, FL Panelists: Lawrence A. Sannicandro, McCarter & English LLP, Newark, NJ; Lewis A. Booth, Office of Chief Counsel, Internal Revenue Service, Houston, TX; Jenny Johnson, Johnson | Moore, Chicago, IL A Client with a Cryptocurrency Issue Just Called – What Now? With the issuance of Revenue Ruling 2019-24 and new FAQs regarding the tax treatment of cryptocurrencies, the IRS obtaining information from various sources identifying taxpayers who own cryptocurrencies, IRS Field Collection requiring disclosure of cryptocurrencies on Forms 433-A, Collection Information Statements, and pending criminal investigations, taxpayers who formerly resided in the shadows are coming to the surface and seeking advice. The panelists will discuss what you need to know before your first meeting with a client facing cryptocurrency issues, including the latest IRS and FinCEN guidance on crypto-currencies, crypto-related issues arising in examinations and criminal investigations, and available paths for the non-compliant. Moderator: Sandra R. Brown, Hochman Salkin Toscher & Perez PC, Beverly Hills, CA Panelists: Jason B. Freeman, Freeman Law PLLC, Frisco, TX; Victor Jaramillo, Caplin & Drysdale Chtd., Washington, DC; Michael DePalma, Special Agent in Charge, Criminal Investigation, IRS, Miami, FL; Christopher Wrobel, Special Counsel, IRS Office of Chief Counsel, Income Tax and Accounting, Washington, DC
  • Closely Held Businesses Chair: Galina “Allie” P. Petrova, Petrova Law PLLC, Greensboro, NC TCJA – Hot Topics for Closely Held Businesses. Now that the 2018 filing season is behind us, this panel will take a look at the impact of the TCJA on closely held businesses. A roundtable of practitioners will address frequent client issues and questions relating to section 199A, section 163(j), and other new provisions and changes, as well as “real life” answers and planning solutions. Panelists: Elizabeth Stieff, Venable LLP, Baltimore, MD; Adam Abrahams, Meyers Hurvitz Abrahams LLC, Rockville, MD; Alan Gassman, Gassman Crotty & Denicolo PA, Clearwater, FL The IRS’s Increased Focus and Enforcement of Payroll Tax Debts. Payroll taxes represent nearly 70% of all revenues into the United States Treasury. Closely held businesses that fail to properly report and pay over those taxes have found themselves increasingly in the IRS and Department of Justice’s crosshairs. This panel will review the various changes in enforcement that business owners and their representatives can expect to see from the government, including increased use of injunctions, suits by the Department of Justice, and increased criminal referrals. Moderator: Eric L. Green, Green & Sklarz LLC, New Haven, CT Panelists: Frank Agostino, Agostino & Associates LLC, Hackensack, NJ; Noelle Geiger, Green & Sklarz LLC, New York, NY; Frederick W. Schindler, Director, Collection Headquarters, Small Business/Self-Employed Division, IRS, Washington, DC
  • Chair: Galina “Allie” P. Petrova, Petrova Law PLLC, Greensboro, NC Basis for Comparison: How Income Tax Management Is Changing the Face of Estate Planning. The basic exclusion amount now stands at $11.4 million, meaning that only about 1-in-1500 American families are likely to face federal estate tax. For this and other reasons, income tax planning has taken on much greater importance. This presentation will use the case study format to focus on how income tax basis can be created and shifted in ways that optimize economic outcomes for our clients. Panelist: Thomas J. Pauloski, Bernstein Private Wealth Management, Chicago, IL Hot Topics for Closely Held Businesses. This panel will discuss recent developments in legislation, regulatory guidance, and noteworthy cases impacting closely held businesses. The panelists will also address the impact of Boyle in the electronic age (Haynes v. United States and Intress v. United States) and new developments with passport decertifications. Panelists: Sabrina Strand, Joseph H. Thibodeau PC, Denver, CO; Jeffrey Dirmann, Agostino & Associates, Hackensack, NJ; Kandyce Korotky, Covington & Burling LLP, Washington, DC The Tax Fallout of Business Breakups. Some things do not go quite as well as the founders had hoped, and now the business, their relationships and even their own financial plans are quickly dissolving into a mess. This panel will discuss the various tax and planning issues clients will need to face when the business breaks up and how practitioners can help their clients navigate the situation and avoid it becoming more of a mess than it already is. Panelists: Shelby Wilson, Green & Sklarz LLC, New Haven, CT; Robert Turnipseed, Armbrecht Jackson LLP, Mobile, AL; William P. Prescott, Wickens Herzer Panza, Avon, OH; Sabrina Conyers, Nelson Mullins Riley & Scarborough LLP, Charlotte, NC
  • Chair: William Alexander, Skadden Arps Slate Meagher & Flom LLP, Washington, DC Current Developments in Corporate Taxation. This panel will discuss the latest developments in corporate taxation, including a discussion of the treatment of various corporate transactions under the BEAT, in the context of qualified opportunity funds and section 355(e). Moderator: Angela R. Russo, KPMG LLP, San Francisco, CA Panelists: Colin D. Campbell, Jr., Department of Treasury, Washington, DC (Invited); David H. Saltzman, Ropes & Gray LLP, Boston, MA; Lisa M. Zarlenga, Steptoe & Johnson LLP, Washington, DC Section 367(b) in a Post-TCJA World. This panel will discuss the continued relevance of section 367(b) post-TCJA. The speakers will discuss how changes made by the TCJA affect the policy considerations of section 367(b), how the changes to the repatriation and basis importation rules might affect the principles underlying Treas. Reg. 1.367(b)-3 and the triangular reorganization provisions, the heightened importance of attribute carryover and allocation under Treas. Reg. 1.367(b)-7 and Prop. Treas. Reg. 1.367(b)-8, and other issues relating to the changed incentives and disincentives in light of TCJA’s overhaul of the international tax rules. Moderator: Scott M. Levine, Jones Day, Washington, DC Panelists: Joshua Rutland, EY, Washington, DC; Gretchen Sierra, Deloitte, Washington, DC; Laura Williams, Branch Chief, Associate Chief Counsel (International), Branch 4, IRS, Washington, DC (Invited); Brenda Zent, Special Advisor on International Taxation, Office of Tax Policy, Department of Treasury, Washington, DC (Invited)
  • Chair: Alexandra Minkovich, Baker & McKenzie, Washington, DC Current Developments. 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
  • Chair: Alexandra Minkovich, Baker & McKenzie, Washington, DC Limited Scope Representation: Expanding Access to Legal Services. In May of 2019, the Tax Court announced that it adopted procedures to permit practitioners to enter a limited appearance at scheduled trial sessions. The procedures recently took effect at the beginning of the 2019 Fall Term. This panel will discuss the rules regarding the Tax Court’s new procedure as well as compare and contrast those rules and similar rules in other jurisdictions. This panel will also address the practical considerations and implications of representing a taxpayer under a limited scope appearance. Moderator: Annie Wurtzebach, DLA Piper, New York, NY Panelists: Special Trial Judge Diana L. Leyden, US Tax Court, Washington DC; Derek Richman, Senior Attorney, IRS Office of Chief Counsel, Miami, FL (Invited); Mitchell I. Horowitz, Buchanan Ingersoll & Rooney PC, Tampa, FL; Phillip Colasanto, Agostino & Associates, Hackensack, NJ
  • Sponsored by: Teaching Taxation This session will review the most significant statutory enactments, judicial decisions, IRS rulings, and Treasury regulations promulgated during the last twelve months that affect general income taxation, corporate taxation, partnership taxation, wealth transfer taxation, and tax procedure. Moderator: Professor Bruce A. McGovern, South Texas College of Law Houston, Houston, TX Panelists: Professor Elaine Hightower Gagliardi, University of Montana School of Law, Missoula, MT; Professor James M. Delaney, University of Wyoming College of Law, Laramie, WY