8:45am Opening Remarks by the Chair and
Presentation of the Larry Katz Award.
8:55am What’s New in Substantiality? “Substantial economic effect” has been part of the partnership tax landscape for more than 20 years. The experience gained during that time, coupled with various proposed, temporary, and final amendments to the section 704(b) regulations make it the right time to reflect on where we’ve been and consider where we might be going. Moderator: Terence F. Cuff, Loeb & Loeb LLP, Los Angeles, CA. Panelists: Robert D. Schachat, Ernst & Young LLP, Washington, DC; Beverly M. Katz, Senior Technician Reviewer, Office of the Associate Chief Counsel (Passthroughs & Special Industries), IRS, Washington, DC; Jennifer H. Alexander, Deloitte Tax LLP, Washington, DC.
9:50am Venture Capital and Private Equity – “Topside” Structuring Issues. This panel will explore a number of issues faced in structuring venture capital and private equity funds, including parallel funds, “fill up” and “fill down” allocations, and the myriad of compensation arrangements being employed today. Moderator: Paul H. Asofsky, Weil Gotshal & Manges LLP, Houston, TX. Panelists: Adele M. Karig, Debevoise & Plimpton LLP, New York, NY; Stanley E. Ramsay, Weil Gotshal & Manges LLP, Houston, TX; James H. Lokey, King & Spalding LLP, Atlanta, GA.
10:30am Cross-Border Private Equity Investments. This panel will explore a number of issues faced in structuring venture capital investments abroad, including foreign tax and commercial law issues. Moderator: Michael Hirschfeld, Dechert LLP, New York, NY. Panelist: Eric B. Sloan, Deloitte Tax LLP, New York, NY.
11:15am Hot Topics in Partnerships. This panel will discuss hot topics in partnership taxation, including legislation, regulations, and other administrative guidance. Moderator: William P. Wasserman, Ernst & Young LLP, Los Angeles, CA. Panelists: Heather C. Maloy, Acting Deputy Chief Counsel (Technical), IRS, Washington, DC; Jon G. Finkelstein, Arnold & Porter LLP, Washington, DC.
LLC SUBCOMMITTEE
Date: 5/6/06
Start Time: 8:30AM
End Time: 10:30AM
Chair: John R. Maxfield, Holland & Hart LLP, Denver, CO
TASK FORCE ON SIMPLIFICATION OF SUBCHAPTER K
Date: 5/4/06
Start Time: 4:00PM
End Time: 6:00PM
