2006 Midyear Meeting

ABA SECTION OF TAXATION  • DATE: February 2 - 4, 2006 • LOCATION: San Diego, CA
SPONSORS: Section of Taxation

Committee Programs

Tax Accounting

Date: 2/03/2006
Start Time: 2:30 PM
End Time: 5:30 PM
Chair: Jack Donovan, Ernst & Young LLP, Washington, DC
Agenda:

2:30pm   Recent Developments in the Area of Tax Accounting. This program will cover
important recent developments in the tax accounting area since the May 2005 meeting in Washington, DC, with commentary and input from our Government guests.  Moderator:  David Auclair, Grant Thorton LLP, Washington, DC.  Panelists:  Robert M. Brown, Associate Chief Counsel ( Income Tax & Accounting), IRS, Washington, DC; George Manousos, Taxation Specialist, Office of Tax Legislative Counsel, Treasury Department, Washington, DC; Sharon Kay, Taxation Specialist, Office of Tax Legislative Counsel, Treasury Department, Washington, DC ; Monique Reid, Ernst & Young LLP, Washington, DC.

3:10pm   Regulations Addressing Estimated Tax Liabilities for Corporations. This program
will discuss regulations expected to be released by the meeting addressing computation of estimated taxes by corporations, with particular emphasis on the determination of taxable income for short periods within the taxable year.  The regulations will likely be replete with tax accounting principles applied to the determination of a corporation’s income for such periods.  Moderator: Kevin D. Anderson, Deloitte Tax LLP, Washington, DC.  Panelists:  Robert M. Brown, Associate Chief Counsel (Income Tax & Accounting), IRS, Washington, DC; George Manousos, Taxation Specialist, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC.

3:50pm   Environmental Remediation Costs and § 263A:  A Discussion of Rev. Rul. 2005-42 and Rev. Rul. 2004-18.  Rev. Rul. 2004-18 held that costs incurred to clean up land contaminated by a taxpayer’s past manufacturing activities are includible in inventory costs under § 263A.  Rev. Rul. 2005-42 held that such costs are properly allocable to inventory produced during the taxable year.  This panel will take a look at these rulings, including their relationship to prior rulings regarding the deductibility of environmental remediation costs, their consistency with § 263A principles generally, and the impact the rulings may have on other areas of the Code.  Moderator: Elizabeth P. Askey, Pillsbury Winthrop Shaw Pittman LLP, Washington, DC.  Panelists: Robert M. Brown, Associate Chief Counsel (Income Tax & Accounting), IRS, Washington, DC; Sharon Kay, Taxation Specialist, Office of Tax Legislative Counsel, Treasury Department, Washington, DC; Leslie J. Schneider, Ivins, Phillips & Barker Chtd., Washington, DC; Colleen M. O’Connor, Ernst & Young LLP, Washington, DC.

4:25pm   The Manufacturing Deduction:  A Look at Proposed Regulations Under I.R.C. § 199. This program will focus on the proposed regulations under I.R.C. § 199 promulgated in October 2004.  In particular the panel will detail the new rules provided in the proposed regulations and will provide insight as to the how the rules set forth in the proposed regulations differ from those rules outlined in Notice 2005-14.  This panel will examine the reasoning behind particular rules (from the perspective of the Administration and the perspective of Congress) and will explore how the proposed regulations address many of the issues raised by taxpayers and practitioners after the release of Notice 2005-14.  The panelists will include individuals at the Treasury Department and Internal Revenue Service working on the guidance project. Moderator: Beth M. Benko, Ernst & Young LLP, Washington, DC.  Panelists:  Heather Maloy, Associate Chief Counsel (Passthroughs & Special Industries),IRS, Washington, DC; George Manousos, Taxation Specialist, Office of Tax Legislative Counsel, Department of Treasury, Washington, DC; Ellen MacNeil, Deloitte Tax LLP, Washington, DC; James Atkinson, Miller & Chevalier, Washington, DC; Ray Beeman, Venable LLP, Washington, DC.

 


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