Friday, October 20
2:30PM – 5:30PM
Tax Exempt Financing
Chair: Clifford M. Gerber, Sidley Austin LLP, San Francisco, CA
2:30pm Opening Remarks by the Chair.
2:35pm IRS and Department of Treasury Update. This panel will discuss current developments in tax-exempt bonds, including items in the 2006-2007 Department of Treasury Priority Guidance Plan and recent private letter rulings. Panelists: Rebecca Harrigal, Branch Chief, Office of Associate Chief Counsel (Tax Exempt Bonds), IRS, Washington, DC; Johanna Som de Cerff, Senior Technician Reviewer, Office of Chief Counsel, IRS, Washington, DC.
3:00pm Arbitrage Guidance. This panel will discuss various areas within the section 148 regulations that may merit further guidance, including qualified hedges and “issue price.” Panelists: Scott R. Lilienthal, Hogan & Hartston LLP, Washington, DC; Rebecca Harrigal, Branch Chief, Office of Associate Chief Counsel (Tax Exempt Bonds), IRS, Washington, DC; Johanna Som de Cerff, Senior Technician Reviewer, Office of Chief Counsel, IRS, Washington, DC.
3:25pm IRS Derivatives Initiative. This panel will discuss the status and progress of the IRS’s derivatives initiative, as well as the areas that have become the central focus of the initiative. Panelists: Michael G. Bailey, Foley & Lardner LLP, Chicago, IL; Michael J. Muratore, Senior Tax Law Specialist, Office of Compliance and Program Management, IRS, Washington, DC.
4:10pm Allocation and Accounting Regulations. This panel will discuss the to-be-issued proposed allocation and accounting regulations, including a proposed committee comment project. Moderator: Bruce M. Serchuk, Nixon Peabody LLP, Washington, DC. Panelists: Rebecca Harrigal, Branch Chief, Office of Associate Chief Counsel (Tax Exempt Bonds), IRS, Washington, DC; Johanna Som de Cerff, Senior Technician Reviewer, Office of Chief Counsel, IRS, Washington, DC; Larry Carlile, Kutak Rock LLP, Denver, CO; Richard L. Kornblith, Fulbright & Jaworski LLP, Los Angeles, CA.
