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Evolution of the US Tax Base
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Date: 5/6/06
Start Time: 2:00PM
End Time: 4:00PM
Evolution of the US Tax Base: Consumption Tax Aspects of the President’s Reform Commission Report, and Their Impact on International Transactions
Matters such as border adjustability, transfer pricing, and impact on US trade will be discussed.
Panelist: Itai Grinberg, Counsel, President’s Advisory Panel on Federal Tax Reform, Washington, DC
Sponsored by: Value Added Tax and Other Consumption Taxes Committee
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Frozen Refunds and the EITC
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Date: 5/6/06
Start Time: 2:00PM
End Time: 3:30PM
Frozen Refunds and the EITC
The panel will discuss the Frozen Refund Program, including the National Taxpayer Advocate’s Report to Congress, due process issue, direct effects to low income taxpayers and recent developments and alterations to the program.
Moderator: Professor Elizabeth Maresca, Fordham Law School, New York, NY
Sponsored by: Low Income Taxpayers Committee
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Let the Sun Shine In - Disclosing Executive Pay
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Date: 5/6/06
Start Time: 2:00PM
End Time: 4:00PM
Let the Sun Shine In -- Disclosing Executive Pay
An in depth exploration of the SEC’s recent proposal to significantly revise the proxy and other SEC disclosure rules for executive pay and required disclosures for executive compensation under the revised 8-K rules and how the recent proposals will change such requirements . Panelists will review the impact of the proposed rules on the 2006 proxy season, the implications of these rules and the 8-K disclosure requirements for the future and their likely impact on executive compensation.
Moderator: Susan J. Daley, Perkins Coie LLP, Chicago, IL
Panelists:
Mark Borges, Mercer Human Resource Consulting, Washington, DC
Althea R. Day, Morgan Lewis & Bockius LLP, Washington, DC
Charles DeLeon, GTSI Corp., Chantilly, VA
Edward Hauder, Buck Consultants, Chicago, IL
Anne M. Krauskopf, Senior Special Counsel, Office of Chief Counsel, SEC, Washington, DC
Jennifer McGrarey, Verizon, Washington, DC
Patrick McGurn, Insitutional Shareholder Services, Rockville, MD
Gail W. Stewart, Baker Botts LLP, Houston, TX
Sponsored by: Employee Benefits Committee
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Litigating Tax Issues in Bankruptcy Court Workshop
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Date: 5/6/06
Start Time: 2:00PM
End Time: 3:30PM
Litigating Tax Issues in Bankruptcy Court Workshop
Panelists:
Jean Ryan, Law Office of Jean Ryan, Miami, FL
Frances Sheehy, Law Office of Frances Sheehy, Coconut Creek, FL
Sponsored by: Bankruptcy and Workouts Committee
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Privilege and Waiver: How an Auditor Can Affect a Taxpayer's Privilege Claim
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Date: 5/6/06
Start Time: 2:00PM
End Time: 3:30PM
Privilege and Waiver: How an Auditor Can Affect a Taxpayer’s Privilege Claim
An in depth discussion of the attorney-client privilege, the work-product doctrine under the Federal Rules of Civil Procedure, and the tax practitioner privilege under section 7525. The panelists will discuss how the privileges may apply to tax planning and tax controversy matters. Particular emphasis will be placed on how a taxpayer can unintentionally waive a privilege, including whether the production of privileged documents to an outside auditor constitutes a waiver, and the impact of waiving privilege. The panelists’ different backgrounds should make for a lively discussion.
Moderator: Brian Kaufman, Capital One Services Inc., McLean, VA
Panelists:
Thomas J. Kane, Special Counsel, Office of Associate Chief Counsel Procedure & Administration) IRS, Washington, DC
Michael F. Kelleher, McDermott Will & Emery LLP, Washington, DC
Deborah S. Meland, Assistant Chief, Tax Division, Department of Justice, Washington, DC
Todd Simmens, Ernst & Young LLP, Washington, DC
Sponsored by: Court Procedure and Practice Committee
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Redemptions Involving S Corporations
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Date: 5/6/06
Start Time: 2:00PM
End Time: 4:00PM
Redemptions Involving S Corporations
The program consists of a discussion of the tax issues pertaining to redemptions and purchases of S corporation stock, including planning opportunities and pitfalls, and a comparison with redemptions/purchasing rules applicable to partnerships and C corporations.
Panelists:
Stephen Looney, Dean Mead Egerton Bloodworth Capouano & Bozarth PA, Orlando, FL
Ronald Levitt, Sirote & Permutt PC, Birmingham, AL
Kevin Anderson, Deloitte Tax LLP, Washington, DC
Sponsored by: S Corporations Committee
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Tax Reform, Tax Policy and Savings in the 21st Century
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Date: 5/6/06
Start Time: 2:00PM
End Time: 3:00PM
Tax Reform, Tax Policy and Savings in the 21st Century--What Do Annuities, Credit Cards, Life Insurance and Mutual Funds Have in Common?
A discussion of current tax law treatment of various savings vehicles as well as suggested changes to current law.
Moderator: Tom Quinn, Law Office of Tom Quinn, Boston, MA
Panelists:
John J. Ensminger, Law Offices of John J. Ensminger, Peoria, AZ
Mark Cantor, American Council of Life Insurers, Washington, DC
Joseph F. McKeever, Davis & Harman LLP, Washington, DC
Lisa Robinson, Investment Company Institute, Washington, DC
Sponsored by: Insurance Companies Committee, Banking and Savings Institutions Committee and Investment Companies Committee
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Use of Hybrid Entities in Cross Border Tax Planning
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Use of Hybrid Entities in Cross Border Tax Planning – A Primer Addressing Tax and Ethical Considerations
“Hybrid entities” is a term that describes business organizations treated as partnerships in one jurisdiction and corporations in a second jurisdiction. That dichotomy of characterization offers tax planners unique opportunities to mix and match various tax rules in order to reduce the overall tax burden. This two-panel mini-program provides an overview of opportunity and risk available to the sophisticated investor. It is intended for practitioners who are not specialists in international taxation and is expected to be the first of a series of programs that will explore various opportunities and issues encountered in the life of a hybrid entity.
2:00pm Use of Hybrid Entities in Inbound Investment Transactions. This panel will discuss the basic uses of hybrid entities for inbound investment into the US. The panel will discuss the use of so-called "domestic reverse hybrids" as well as problems that exist when a foreign hybrid entity claims a tax treaty benefit for dividends, interest, and royalties. Also discussed are new section 1446 withholding regulations for partnerships, corporate issues in the home country of the investor at the time profits are distributed, and ethical considerations inherent in this type of “tax arbitrage” transaction.
Moderator: Sam Kaywood, Alston & Bird LLP, Atlanta, GA
Panelists: Alan I. Appel, Bryan Cave LLP, New York, NY
Joan C. Arnold, Pepper Hamilton LLP, Philadelphia, PA
Jordi Dominguez, Perez Garrigues, New York, NY
3:30pm Use of Hybrid Entities in Outbound Investment Transactions. This panel will discuss uses of hybrid entities for US investment in other countries. Topics include the classification of foreign entities, tax treatment of asset transfers from the US, and structures designed to reduce foreign tax without any offset for immediate US tax under subpart F. Issues identified in foreign countries such as know your client rules and limitation on access to treaties will be addressed as well as emerging European entities and new tax rules that foster use of European hybrid entities.
Moderator: Professor Lawrence A. Lokken, Levin College of Law, University of Florida, Gainesville, FL
Panelists: Werner Heyvaert, Stibbe, Brussels, Belgium
Kathleen Penny, Blake Cassels & Graydon LLP, Toronto, ON
Marco Q. Rossi, Marco Q. Rossi & Associati, New York, NY
Sponsored by: US Activities of Foreigners & Tax Treaties Committee, Foreign Activities of US Taxpayers Committee, Foreign Lawyers Forum
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