2006 May Meeting

ABA SECTION OF TAXATION  • DATE: May 4 - 6, 2006 • LOCATION: Washington, DC
SPONSORS: Section of Taxation

Committee Programs

Tax Exempt Financing

Date:  05/05/06

Start Time:  2:30PM

End Time:  5:30PM

Chair:  Clifford M. Gerber, Sidley Austin Brown & Wood LLP, San Francisco, CA

2:30pm                  Opening Remarks by the Chair.

2:35pm                  IRS and Treasury Update.   This panel will discuss current developments in tax-exempt bonds, as well as the Department of Treasury''s 2005 - 2006 Priority Guidance Plan, including the March 2006 Update.  Panelists:  John J. Cross III, Attorney Advisor, Department of Treasury, Washington, DC; Johanna Som de Cerff, Senior Technician Reviewer, Office of Chief Counsel, IRS, Washington, DC; Aviva Roth, Attorney Advisor, Office of Chief Counsel, IRS, Washington, DC.

3:20pm              Living With the New Private Activity Bond Refunding Regulations. This panel will discuss some of the technical and practical problems encountered by practitioners and their issuer clients under the final private activity bond refunding regulations, including the impact of the regulations on record-keeping

requirements. Panelists: Bruce M. Serchuk, Nixon Peabody LLP, Washington, DC; Scott Lilienthal, Hogan & Hartston LLP, Washington, DC; Johanna Som de Cerff, Senior Technician Reviewer, Office of Chief Counsel, IRS, Washington, DC.

 

4:15pm               Issue Price. This panel will discuss some of the

technical issues that arise in determining a bond''s “issue price” under section 1.148-1, including the idefinition of investing public and the application of the reasonable expectations rule. Panelists: Michael G.

Bailey, Foley & Lardner LLP, Chicago, IL; Scott R. Lilienthal, Hogan & Hartston LLP, Washington, DC;John J. Cross III, Attorney Advisor, Department of Treasury, Washington, DC.

 

4:50pm              Enforcement. This panel will discuss the appeals

process in the tax-exempt bond area, including Revenue Procedure 99-35 and the committee’s project recommending modifications to the process, and will discuss current developments in the IRS’s Office of Tax Exempt Bonds. Panelists: Jeremy A. Spector, Blank

Rome LLP, Philadelphia, PA; Steven Chamberlin, Acting Manager, Office of Outreach, Planning and Review, IRS, St. Louis, MO.

 

LUNCHEON

 

Date:  5/5/06

 

Start Time:  12:30PM

 

End Time:  1:30PM

 

Speaker:  Pamela F. Olson, Skadden Arps Slate Meagher & Flom LLP, Washington, DC

 

Topic:  The Impact of the Tax Reform Commission Proposals on Financial Institutions

Committee Programs

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