Date: 05/06/06
Start Time: 8:30AM
End Time: 11:45AM
Chair: Ronold P. Platner, Olympia Companies, Scottsdale, AZ
8:30am Opening Remarks by the Chair.
8:35am Sales and Exchanges: Current Developments. Presentation of new cases and rulings affecting sales, exchanges and basis (other than section 1031). Panelists: Professor Erik Jensen, Case Western Reserve University School of Law, Cleveland, OH; Professor Brad Borden, Washburn University School of Law, Topeka, KS.
9:00am Sale and Exchanges of Leasehold Interests (Part I). This panel will analyze section 1031 issues arising in exchanges involving leasehold interests (real estate, as well as oil and gas), leasehold improvements and lease terminations. Moderator: David Shechtman, Montgomery McCracken Walker & Rhoads LLP, Philadelphia, PA. Panelists: Professor Brad Borden, Washburn University School of Law, Topeka, KS; Kelly Alton, Deloitte & Touche LLP, Washington, DC.
9:40am Timing is Everything - Realization and Open Transaction Issues Involving Financial Products. The panel will examine recent developments affecting taxation of financial products including a widely-publicized TAM analyzing a popular prepaid forward contract structure and the Tax Court’s recent opinion in Federal Home Loan Board regarding “prior approval” purchase contracts. Moderator: Paul L.B. McKenney, Raymond & Prokop PC, Southfield, MI. Panelists: Michael S. Novey, Associate Tax Legislative Counsel, Office of Tax Policy, Department of Treasury, Washington, DC; Todd B. Reinstein, Pepper Hamilton LLP, Washington, DC.
10:40am 468B Regs. Moderator: Kelly Alton, Deloitte & Touche LLP, Washington, DC. Panelists: David Shectman, Montgomery McCracken Walker & Rhoads LLP, Philadelphia, PA; Andrew F. Gelson, Compass Exchange Advisors LLC, Kingston, MA.
11:10am 1031 Current Developments. The panel will present an update on the section 1031 state tax survey and will discuss other recent section 1031 developments. Panelists: Kelly Alton, Deloitte & Touche LLP, Washington, DC; Donna Crisalli, Special Counsel to Associate Chief Counsel, IRS, Washington, DC; David Shechtman, Montgomery McCracken Walker & Rhoads LLP, Philadelphia, PA; Carlene Miller, Snell & Wilmer LLP, Phoenix, AZ.
BREAKFAST
Date: 5/6/06
Start Time: 7:30AM
End Time: 8:30AM
