• Chair: Stephen Breitstone, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY Real Estate Chair: Ossie Borosh, KPMG LLP, Washington, DC Nuts and Bolts of Opportunity Zones and Qualified Opportunity Funds. This panel will cover the law, regulations, and the practical implementation thereof for Opportunity Zones (“OZs”) and Qualified Opportunity Funds (“QOFs”). It is the perfect panel both for those unfamiliar with OZs and QOFs, as well as those who are familiar with the law and regulations but have not practiced in the area. Additionally, seasoned practitioners will benefit from a discussion of the final regulations with respect to OZs. Moderator: Matthew Rappaport, Falcon Rappaport & Berkman PLLC, Rockville Center, NY Panelists: Richard Blumenreich, KPMG LLP, Washington, DC; Alan S. Lederman, Gunster, Fort Lauderdale, FL; Leila Vaughan, Royer Cooper Cohen Braunfeld LLC, Conshohocken, PA; Julie Hanlon-Bolton, Special Counsel, IRS Associate Chief Counsel (Income Tax & Accounting), Washington, DC Common and Complex Case Studies and Real-World Issues with Opportunity Zones and Qualified Opportunity Funds. The second hour of this program will focus on issues related to funds, raising capital, and dispositions. This discussion will be valuable both for practitioners just learning about OZs and QOFs and for seasoned professionals, as it will incorporate a discussion of transaction structures. Additionally, there will be a further discussion of the final regulations covering OZs. Moderator: Tom West, KPMG LLP, Washington, DC Panelists: Richard Blumenreich, KPMG LLP, Washington, DC; Mark Wilensky, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY; Julie Hanlon-Bolton, Special Counsel, IRS Associate Chief Counsel (Income Tax & Accounting), Washington, DC
  • Chair: Laura Gould, Reed Smith LLP, London, United Kingdom US Activities of Foreigners & Tax Treaties Chair: Summer A. LePree, Bilzin Sumberg Baena Price & Axelrod LLP, Miami, FL Revisiting the BEAT. Following up on the 2018 proposed regulations, Treasury released both final and proposed regulations addressing the BEAT. This panel will focus on some of the changes made by Treasury from the 2018 proposed regulations to the final regulations, including rules relating to the treatment of certain corporate nonrecognition transactions, the treatment of aggregate group members with different tax years and the treatment of built-in loss property in certain transactions. Additionally, this panel will highlight some of the provisions Treasury chose not to adopt in the final regulations. Finally, the panel will provide an overview of the newly proposed regulations that include rules relating to aggregate groups, partnerships and an election to waive deductions. Panelists: Amie Colwell Breslow, Jones Day, Washington, DC; Joseph Calianno, BDO USA LLP, Washington, DC; Lucas Giardelli, Mayer Brown LLP, New York, NY; David Peter Merkle, IRS Office of Associate Chief Counsel (International), Washington, DC (Invited); Douglas Poms, International Tax Counsel, Department of Treasury, Washington, DC (Invited) Opening Pandora’s Box: IP Tax Incentives in the US & Europe. Many OECD countries have adopted patent box regimes or other rules intended to incentivize corporations to hold intellectual property within their jurisdiction, some of which have been the subject of recent reform following the BEPS Reports, and in particular Action 5. Although the 2017 Tax Act did not include a traditional patent box regime, it did add the new foreign-derived intangible income (FDII) rules, which, in connection with other rules added by the 2017 Tax Act, are generally intended to encourage domestic corporations to hold intellectual property in the United States. Using case studies, this panel of experts will explore the differences and similarities between FDII and patent box and similar rules in the UK and certain EU-member countries, as well as the interaction of the FDII rules with certain domestic rules in those countries that can impact IP structuring decisions for multinationals. The panel will also discuss potential international trade reaction to the FDII rules, including from an EU perspective. Moderator: Barbara Rasch, KPMG LLP, Los Angeles, CA Panelists: Sandy Radmanesh, German Tax Attaché, German Embassy, Washington, DC; James Somerville, A&L Goodbody, Dublin, Ireland; Natalie Repyens, Loyens & Loeff CVBA, Brussels, Belgium; Robert Gaut, Proskauer Rose (UK) LLP, London, UK; Romain Tiffon, Atoz Tax Advisers, Luxembourg Foreign Lawyers Forum – Anti-Hybrid Rules: The New World. With the EU setting a January 1, 2020 deadline for the introduction of anti-hybrid rules under ATAD2 and the implementation of anti-hybrid rules under the TCJA, this timely panel will discuss the potential application of anti-hybrid rules. The panel will provide updates on the implementation of the ATAD 2 rules in key EU member states, an update on the application of the US anti-hybrid rules following the publication of the proposed regulations just over a year ago and the UK’s existing and wide-reaching legislation. Through case studies, this expert panel will explore the differences, similarities and interaction between these various rules and highlight traps for the unwary in a sample of typical cross-border structures used by multinationals and fund structures. Moderator: Brian Krause, Skadden Arps Slate Meagher & Flom, New York, NY Panelists: Robert Gaut, Proskauer Rose (UK) LLP, London, UK; David Kilty, Arthur Cox, Dublin, Ireland; Kévin Emeraux, Loyens & Loeff (Luxembourg), New York, NY; Shane M. McCarrick, Attorney-Advisor, IRS Office of Associate Chief Counsel (International), Washington, DC
  • Sponsored by: Young Lawyers Forum and Diversity A Conversation with… An in-depth discussion with Chief Judge Maurice B. Foley of the US Tax Court, one of the Tax Section’s most distinguished members, detailing his practice, history and the latest developments in tax law. Nuts and Bolts: Introduction to Ethical Considerations for Young Attorneys. This panel will discuss the ethical issues that frequently arise when representing a client before the IRS. This panel will focus on the rules and guidance, including Circular 230 and the ABA Model Rules, that young attorneys should consult when faced with an ethical conundrum. Moderator: Anne Wurtzebach, DLA Piper, New York, NY Panelists: Hon. Ronald L. Buch, US Tax Court, Washington DC (Invited); Joshua Wu, Deputy Assistant Attorney General (Policy and Planning), Department of Justice, Tax Division, Washington, DC; Brianne DeSellier, Crowe LLP, Fort Lauderdale, FL; James Steele, Morgan, Lewis & Bockius LLP, Washington, DC Workin’ On It: Understanding Employment Tax. Employment tax compliance has become an enforcement priority for the IRS and the result has been more civil examinations and criminal investigations. This panel will survey the common issues in the employment arena and approaches in defending an employment tax controversy. The panelists will discuss Section 530 relief, voluntary compliance options, the eggshell audit and the criminal referral process. Moderator: Anson Asbury, Asbury Law Firm, Decatur, GA Panelists: Lu-Ann Dominguez, Gunster, Ft. Lauderdale, FL; Brian Gardner, Taylor English, Atlanta, GA; Marissa Lenius, IRS Senior Attorney, TEGE Division Counsel, Jacksonville, FL Getting to the Truth: Fundamentals of Discovery & Public Records for SALT Lawyers. This panel will delve into a crucial reality for tax lawyers—the exchange of information between taxpayer and tax authority. State and local tax (“SALT”) lawyers encounter this in various contexts: tax audits, discovery during litigation, and requests for public records. The panel will discuss the fundamentals of obtaining information, tips to prevent and resolve disputes about the exchange of information, and protections for confidential information. The panelists represent diverse perspectives of SALT lawyers in private practice and government practice, including a tax appeal hearing officer. Moderator: Michelle DeLappe, Foster Garvey PC, Seattle, WA Panelists: Vincent Kan, Hearing Officer, Board of Appeals at Illinois Department of Revenue, Chicago, IL; Andrea Muse, Legal Reporter, Tax Analysts, Washington, DC; Jennifer Pusch, Fredrikson & Byron PA, Minneapolis, MN; Harriet A. Wessel, Mondrik & Associates, Austin, TX Co-Sponsored by: Court Procedure & Practice
  • Sponsored by: Young Lawyers Forum and Diversity A Conversation with… An in-depth discussion with Chief Judge Maurice B. Foley of the US Tax Court, one of the Tax Section’s most distinguished members, detailing his practice, history and the latest developments in tax law. Nuts and Bolts: Introduction to Ethical Considerations for Young Attorneys. This panel will discuss the ethical issues that frequently arise when representing a client before the IRS. This panel will focus on the rules and guidance, including Circular 230 and the ABA Model Rules, that young attorneys should consult when faced with an ethical conundrum. Moderator: Anne Wurtzebach, DLA Piper, New York, NY Panelists: Hon. Ronald L. Buch, US Tax Court, Washington DC (Invited); Joshua Wu, Deputy Assistant Attorney General (Policy and Planning), Department of Justice, Tax Division, Washington, DC; Brianne DeSellier, Crowe LLP, Fort Lauderdale, FL; James Steele, Morgan, Lewis & Bockius LLP, Washington, DC Workin’ On It: Understanding Employment Tax. Employment tax compliance has become an enforcement priority for the IRS and the result has been more civil examinations and criminal investigations. This panel will survey the common issues in the employment arena and approaches in defending an employment tax controversy. The panelists will discuss Section 530 relief, voluntary compliance options, the eggshell audit and the criminal referral process. Moderator: Anson Asbury, Asbury Law Firm, Decatur, GA Panelists: Lu-Ann Dominguez, Gunster, Ft. Lauderdale, FL; Brian Gardner, Taylor English, Atlanta, GA; Marissa Lenius, IRS Senior Attorney, TEGE Division Counsel, Jacksonville, FL Getting to the Truth: Fundamentals of Discovery & Public Records for SALT Lawyers. This panel will delve into a crucial reality for tax lawyers—the exchange of information between taxpayer and tax authority. State and local tax (“SALT”) lawyers encounter this in various contexts: tax audits, discovery during litigation, and requests for public records. The panel will discuss the fundamentals of obtaining information, tips to prevent and resolve disputes about the exchange of information, and protections for confidential information. The panelists represent diverse perspectives of SALT lawyers in private practice and government practice, including a tax appeal hearing officer. Moderator: Michelle DeLappe, Foster Garvey PC, Seattle, WA Panelists: Vincent Kan, Hearing Officer, Board of Appeals at Illinois Department of Revenue, Chicago, IL; Andrea Muse, Legal Reporter, Tax Analysts, Washington, DC; Jennifer Pusch, Fredrikson & Byron PA, Minneapolis, MN; Harriet A. Wessel, Mondrik & Associates, Austin, TX Co-Sponsored by: Court Procedure & Practice
  • Sponsored by: Young Lawyers Forum and Diversity A Conversation with… An in-depth discussion with Chief Judge Maurice B. Foley of the US Tax Court, one of the Tax Section’s most distinguished members, detailing his practice, history and the latest developments in tax law. Nuts and Bolts: Introduction to Ethical Considerations for Young Attorneys. This panel will discuss the ethical issues that frequently arise when representing a client before the IRS. This panel will focus on the rules and guidance, including Circular 230 and the ABA Model Rules, that young attorneys should consult when faced with an ethical conundrum. Moderator: Anne Wurtzebach, DLA Piper, New York, NY Panelists: Hon. Ronald L. Buch, US Tax Court, Washington DC (Invited); Joshua Wu, Deputy Assistant Attorney General (Policy and Planning), Department of Justice, Tax Division, Washington, DC; Brianne DeSellier, Crowe LLP, Fort Lauderdale, FL; James Steele, Morgan, Lewis & Bockius LLP, Washington, DC Workin’ On It: Understanding Employment Tax. Employment tax compliance has become an enforcement priority for the IRS and the result has been more civil examinations and criminal investigations. This panel will survey the common issues in the employment arena and approaches in defending an employment tax controversy. The panelists will discuss Section 530 relief, voluntary compliance options, the eggshell audit and the criminal referral process. Moderator: Anson Asbury, Asbury Law Firm, Decatur, GA Panelists: Lu-Ann Dominguez, Gunster, Ft. Lauderdale, FL; Brian Gardner, Taylor English, Atlanta, GA; Marissa Lenius, IRS Senior Attorney, TEGE Division Counsel, Jacksonville, FL Getting to the Truth: Fundamentals of Discovery & Public Records for SALT Lawyers. This panel will delve into a crucial reality for tax lawyers—the exchange of information between taxpayer and tax authority. State and local tax (“SALT”) lawyers encounter this in various contexts: tax audits, discovery during litigation, and requests for public records. The panel will discuss the fundamentals of obtaining information, tips to prevent and resolve disputes about the exchange of information, and protections for confidential information. The panelists represent diverse perspectives of SALT lawyers in private practice and government practice, including a tax appeal hearing officer. Moderator: Michelle DeLappe, Foster Garvey PC, Seattle, WA Panelists: Vincent Kan, Hearing Officer, Board of Appeals at Illinois Department of Revenue, Chicago, IL; Andrea Muse, Legal Reporter, Tax Analysts, Washington, DC; Jennifer Pusch, Fredrikson & Byron PA, Minneapolis, MN; Harriet A. Wessel, Mondrik & Associates, Austin, TX Co-Sponsored by: Court Procedure & Practice
  • 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: Ossie Borosh, KPMG LLP, Washington, DC Opportunity Zones – Structuring Issues. This panel will discuss new guidance, various structuring techniques, and planning pitfalls relating to opportunity zones. Moderator: Tom West, KPMG LLP, Washington, DC Panelists: Colin Campbell, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited); Bryan Rimmke, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited); Lisa Starczewski, Buchanan Ingersoll & Rooney PC, Washington, DC Joint Venturing with a REIT. This panel will address the tax issues that arise when a REIT is a partner in a joint venture. The discussion will address the concerns from both the JV partner’s and the REIT’s perspective, including the related party tenant issues for the REIT. Moderator: Mark Van Deusen, Deloitte Tax LLP, Washington, DC Panelists: Julanne Allen, PwC, Washington, DC; Cristina Arumi, Hogan Lovells LLP, Washington, DC Partnership Liabilities under Section 707 and 752. This panel will discuss recent guidance on the treatment of partnership liabilities under the disguised sale rules and section 752. Moderator: Jennifer Ray, Deloitte Tax LLP, Washington, DC Panelists: Audrey Ellis, PwC, Washington, DC; Caroline Hay, IRS Office of Chief Counsel (Passthroughs & Special Industries), Washington, DC; Richard Lipton, Baker & McKenzie LLP, Chicago, IL