Program
Program is preliminary and subject to change
Conference Co-Chairs
John Apadula, Comcast Corporation, Philadelphia, PA
Debbie Martino, Graham Partners, Newtown Square, PA
Friday, October 30
8:00 a.m. – 8:25 a.m.
Registration and Continental Breakfast
8:25 a.m. – 8:30 a.m.
Opening Remarks
Conference Co-Chair: Debbie Martino, Graham Partners, Newtown Square, PA
8:30 a.m. – 9:30 a.m.
Session 1 – Partnership Update: Hot Topics and Transactional Trends
This panel will address recent judicial, legislative, and regulatory developments and market trends affecting partnership taxation. This will include:
- The continuing SECA Saga
- State of partnership tax guidance and enforcement
- BBA audit trends and practical observations
- Developments in fund structuring and sponsor economics
- Emerging transactional trends practitioners are seeing
Panelists:
Eric B. Sloan, Gibson Dunn, New York, NY
Debbie Paul, Sidley Austin, New York, NY
Eytan de Gunzburg, Gibson Dunn, New York, NY
9:30 a.m.-9:45 a.m.
Networking Break
9:45 a.m. – 10:45 a.m.
Session 2 – Corporate Tax Update
This session will cover recent corporate tax developments, including:
- Upcoming Treasury/IRS Guidance
- PLR Practice
- Section 368(a)(1)(F) Reorgs
- Zero Basis
- Corp AMT
- Stock Buyback Excise Tax
- Section 1202/QSBS
Panelists:
Eric Solomon, Ivins, Phillips & Barker, Washington, DC
Rob Liquerman, IRS Associate Chief Counsel (Corporate), Washington, DC
Christina Tacoronti, EY, Washington, DC
Gregory Fairbanks, Grant Thorton, Washington, DC
10:45 a.m. – 11:00 a.m.
Networking Break
11:00 a.m. – 12:00 p.m.
Session 3 – International Tax Update
The session will include an update on IRS priorities and guidance. The panel expects to cover:
- Open OBBBA issues under Section 174 (amortization of R&D expenses) and Stewardship
- A review of proposed regulations under Sections 898 (tax years of foreign corporations) and Section 951(a)(1) (determining a U.S. shareholder’s pro rata share of income inclusion under Subpart F)
- A consideration of recent holdings in Varian Med. Systems, Inc. v. Comm’r, and Siemens Med. Sol. USA Inc. v. Comm’r.
Panelists:
Joan Arnold, Charles Widger Villanova School of Law Graduate Tax Program
Layla Asali, Miller & Chevalier, Washington, DC
Tracy Villecco, IRS Chief Counsel (International), Washington, DC (invited)
John Bates, Deloitte, Washington, DC
12:00 p.m. – 1:30 p.m.
Legislative Update Lunch – Impact of Upcoming Election on Legislative Agenda
Speaker:
John Gimigliano, KPMG, Washington, DC
1:45 p.m. – 2:45 p.m.
Session 4 – Common Traps for the Unwary Under Subchapter K
Real-world mistakes, technical landmines, and unexpected tax consequences.
- Accidental partnership continuations
- Partnership mergers and divisions gone wrong
- Forgotten section 754 elections
- Attribution rule traps
- Anti-churning surprises
- Leveraged distribution issues
- Section 83(b) election pitfalls
- K-1 versus W-2 classification issues
Panelists:
Eric B. Sloan, Gibson Dunn, New York, NY
Sarah Brodie, EY, Washington, DC
Matt Donnelly, Kirkland & Ellis, New York, NY
2:45 p.m. – 3:00 p.m.
Networking Break
3:00 p.m. – 4:00 p.m.
Session 5 – Economic Substance: The Long, Strange Trip Continues
This panel will address recent developments in the economic substance doctrine and offer insights about what to expect in the year ahead.
Panelists:
Eric B. Sloan, Gibson Dunn, New York, NY
Eric Solomon, Ivins, Phillips & Barker, Washington, DC
Nate Pollock, SouthBank Legal, Washington, DC