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8:45am Committee Business by the Chair.
9:00am News from the IRS and Department of Treasury. Representatives from the TE/GE Division of IRS and from the Treasury Department will speak on recent developments and pending guidance. Moderator: Betsy Buchalter Adler, Silk Adler & Colvin, San Francisco, CA. Panelists: Eric San Juan, Attorney-Advisor, Department of the Treasury, Washington, DC; Lois G. Lerner, Director/EO Rulings & Agreements, IRS, Washington, DC; Catherine E. Livingston, Associate Chief Counsel, IRS, Washington, DC.
10:00am Task Force Report: Proposed Regulations under Section 501(c)(3) and Intermediate Sanctions. The Task Force will report on its comments on proposed regulations issued in September 2005 regarding the relationship between the substantive requirements for tax exemption under Section 501(c)(3) and the imposition of Section 4958 excise taxes. Moderator: James Joseph, Arnold & Porter LLP, Washington, DC. Panelists: Lauren K. Mack, Office of Lauren Mack, Foster City, CA; David Levitt, Silk Adler & Colvin, San Francisco, CA; Kelly R. Berg, Holme Roberts & Owen LLP, Denver, CO.
10:45am Task Force Report: Supporting Organization Reform Initiatives. The Task Force
will report on the latest developments affecting supporting organizations under Section 509(a)(3) to address perceived abuses. Panelist: Paul Feinberg, Baker & Hostetler LLP, Cleveland, OH.
11:15am Charities and Economic Development: New Frontiers. Charities are key drivers of
economic development throughout the world. This panel will focus on what makes economic development "charitable," various ways that charities may fund economic development (including grants, loans, equity, loan guarantees), and how the PRI rules apply to private foundation investment in domestic and international economic development. The panel will also discuss recent initiatives with respect to 501(c)(3) organizations that serve as general partners in low income housing tax credit limited partnerships. Moderator: Celia Roady, Morgan Lewis & Bockius, Washington, DC. Panelists: Tomer Inbar, Morgan Lewis & Bockius, Washington, DC; Jane Nober, Council on Foundations, Washington, DC; Catherine E. Livingston, Associate Chief Counsel, IRS, Washington, DC.
12:15pm Luncheon. Speaker: Robert A. Kelly, San Diego Foundation, San Diego, CA.
1:30pm Disaster Relief: How are the Charities and the IRS Doing This Time? The panelists
will discuss legal challenges in the aftermath of the 2005 Gulf Coast Hurricanes and comparisons with lessons learned from the Oklahoma City bombing, 9/11 attacks, and Tsunami. Moderator: Victoria B. Bjorklund, Simpson Thacher & Bartlett, New York, NY. Panelsists: Ty McMains, Baton Rouge Area Foundation, Baton Rouge, LA.
2:15pm Section 501(c)(4) Social Welfare Organizations: ‘Social Welfare’ and Other Mysteries. This panel will analyze current issues and controversies in the 501(c)(4) area, including what really is “social welfare” and how is it different from “charity;” section 501(c)(4) organizations and political campaign activities; and possible gift tax on contributions to Section 501(c)(4) organizations. Moderator: Richard F. Riley Jr., Foley & Lardner LLP, Washington, DC. Panelists: Professor Miriam Galston, George Washington University Law School, Washington, DC; Barbara Rhomberg, Silk Adler & Colvin, San Francisco, CA.
3:15pm UBIT 2006: Sizzling Hot Topics and Pesky Practical Problems. This panel will take a
case study approach to identifying and resolving current issues in unrelated business income tax. Moderator: Robert A. Wexler, Silk Adler & Colvin, San Francisco, CA. Panelists: Laura Kalick, Exempt Organization Tax Consulting, Chevy Chase, MD; J. Patrick Whaley, Musick Peeler & Garrett, Los Angeles, CA.
4:00pm Cash Bar.
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