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DTSTART;TZID=America/New_York:20221103T183000
DTEND;TZID=America/New_York:20221103T203000
DTSTAMP:20260411T131831
CREATED:20221012T150927Z
LAST-MODIFIED:20221020T174402Z
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SUMMARY:Section on Taxation: Network & Repeat! A Night of Speed Networking and DE&I Discussion
DESCRIPTION:Join us for Network & Repeat! A Night of Networking & DE&I Discussions on Nov. 3\, 2022\, from 6:30 – 8:30 PM ET. This is a coordinated event co-sponsored by Kirkland & Ellis and Weil\, Gotshal\, & Manges. This in-person event will consist of speed networking and discussions focused on DE&I issues and networking. More information concerning the event is in the flyer. Please feel free to share and forward along. We hope to see you there! \nPresented by: Section on Taxation\, DE&I Committee \n\nRSVP\n[RSVP Online]  \nRegistration Rates \n\nComplimentary for FBA Members & Non-Members\n\nRSVPs are being collected by Weil\, Gotshal\, & Manges. \n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\nEvent Liability & Disclaimer\nBy attending this event\, you agree to the following terms and conditions. \nIf you have any questions regarding this program\, please contact christina.king@kirkland.com or Renan.Rodriguez@weil.com \n  \n\n\n\n\n\n\n\nCLE: Please note CLE will not be offered for this event.
URL:https://www.fedbar.org/event/section-on-taxation-network-repeat-a-night-of-speed-networking-and-dei-discussion/
LOCATION:Teddy & The Bully Bar\, 1200 19th St. NW\, Washington\, DC\, 20036\, United States
CATEGORIES:Section on Taxation
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END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20220805T140000
DTEND;TZID=America/New_York:20220805T150000
DTSTAMP:20260411T131831
CREATED:20220610T195700Z
LAST-MODIFIED:20220805T155530Z
UID:250288-1659708000-1659711600@www.fedbar.org
SUMMARY:Webinar: Careers in Tax Law
DESCRIPTION:Young tax practitioners and aspiring students are invited to a career panel organized by the FBA’s Younger Lawyers Division and Section on Taxation. A panel of tax practitioners will speak about the nature of their jobs\, their experience in different areas of tax law\, and what young tax professionals and aspiring students might expect from a career in tax law. \nPresented by the Section on Taxation & Younger Lawyers Division \nRegistration is Closed \n\nPanelists\nRoger Mahon (Moderator) \nRoger Mahon is an Attorney Advisor to the Honorable Juan F. Vasquez at the United States Tax Court. He previously worked as an associate at a small law firm representing clients in tax controversy matters. Roger received his LL.M in Taxation from New York University School of Law and his J.D. from Boston College Law School. \nDan Davidson \nDan is an experienced courtroom advocate\, having appeared in court at all stages of criminal litigation\, from arraignments to evidentiary hearings to sentencings. After receiving his J.D. cum laude from New York University School of Law in 2016\, Dan was hired as a prosecutor by visionary District Attorney Kenneth P. Thompson. \nHis practice at Kostelanetz & Fink\, LLP focuses on white-collar criminal defense and civil and criminal tax controversies. While Dan does not consider himself a tax lawyer\, he is a perfect example of how non-tax lawyers must still have expertise in\, as well as an understanding of\, tax law\, practice\, and procedure. \nNick Zemil \nNick Zemil is a Director in PwC’s Washington National Tax Services group\, specializing in international tax. Nick advises clients and local PwC teams on a variety of international tax planning and controversy issues arising from pre- and post-tax reform provisions\, with a focus on outbound transactions. Prior to joining PwC\, Nick was an associate with a large\, international law firm. Nick is also an experienced adjunct professor\, with a teaching focus in tax and accounting. In addition to teaching\, Nick is a frequent speaker on international tax at various internal and external forums and has authored several publications on domestic and international tax issues. \nTeisha Ruggiero \nTeisha Ruggiero is an attorney with the IRS Office of Associate Chief Counsel (International)\, Branch 3\, where she focuses on developing and drafting foreign tax credit guidance. Before joining the Chief Counsel’s office in July 2021\, she worked at KPMG for seven years. While at KPMG she focused on the substantial statutory and regulatory changes to foreign tax credits and other international tax rules related to the Tax Cuts and Jobs Act. Teisha graduated from McGill University (BA)\, the London School of Economics (MSc in Comparative Politics)\, Brooklyn Law School (JD)\, and New York University School of Law (LLM). \n\nRegistration\nRegistration is Closed \nRegistration for this event will close August 4 at 2 PM ET.  \nRegistration Fees \n\nComplimentary for FBA Members & Non Members\n\n\n\n\n\n\n\n\n\nLive Captioning: Closed captioning is available for all virtual webcasts. \n\n\nInternet Requirements: Virtual programs require suitable internet strength to stream online panels. A minimum internet connection of 800 Kbps is recommended for an optimal attendee experience. Test your connection here.  \n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\nCLE\nPlease note CLE will not be offered for this event.  \n\n\n\n\n\n\n\n\nFrequently Asked Questions\nQ: How do I access the virtual webinar?\nA: Each webinar will have a unique link to watch the live broadcast. Registered attendees will receive login instructions via a calendar invitations 24 hours prior to the webinar. \nQ: Will recordings of the sessions be available after the event?\nA: Approved sessions will be available for registrants to view live and on-demand following the webinar. \nQ: Who do I contact for more information?\nA: Please contact sections@fedbar.org for any other questions. \n\nEmail Communication Policy\nBy registering for this event\, you agree to receive email communications from the Federal Bar Association and affiliated sponsors of the program concerning event details\, Continuing Legal Education certification\, programming changes\, upcoming events\, surveys\, and post-event communications. \nRecording Disclaimer\nBy registering for an online FBA program\, you agree to the recording of audio and visual content presented during the live event and consent to subsequent use of the recording by the FBA. You agree that the recording is the sole property of the FBA and that the recording may be used by the FBA in any manner in its sole and absolute discretion. This recording may include questions and poll responses provided by you during the live event. If you do not consent to the recording and the FBA’s use of the same\, do not register for the event. \nIf you have any questions regarding this program\, please contact Daniel Hamilton\, Program Coordinator\, at dhamilton@fedbar.org
URL:https://www.fedbar.org/event/webinar-careers-careers-in-tax-law/
LOCATION:DC
CATEGORIES:Section on Taxation,Younger Lawyers Division
END:VEVENT
BEGIN:VEVENT
DTSTART;VALUE=DATE:20220602
DTEND;VALUE=DATE:20220604
DTSTAMP:20260411T131831
CREATED:20211027T200147Z
LAST-MODIFIED:20220531T193720Z
UID:178648-1654128000-1654300799@www.fedbar.org
SUMMARY:Insurance Tax Seminar
DESCRIPTION:On-Site Registration is Available\nJoin the Section on Taxation for its annual Insurance Tax Seminar on June 2-3\, 2022 at the JW Marriott in Washington\, DC.\nThis year’s in-person seminar will feature topical tax discussions between industry tax professionals\, tax advisors\, consultants\, and government tax professionals. Attendees will get the latest tax news on IRS guidance and other developments\, and hear real-time commentary and perspectives from numerous industry tax specialists. \nThis year’s agenda will offer 23 sessions—including a couple of “fundamentals” sessions for attendees who are newer to insurance tax. Seminar panels have been crafted to cover a range of viewpoints on the latest insurance company\, insurance product\, international\, and other relevant and timely tax topics—including potential legislation\, recent IRS and OECD guidance\, and post-COVID workplace issues. \nThis event is scheduled to take place in-person without a streaming component. The FBA is committed to creating an event experience where our participants\, partners and employees can safely and effectively conduct business\, network and learn. We will follow current CDC guidelines as well as any applicable protocols that may be required by our venues\, state and local governments. If the event converts to a hybrid experience\, we will share updates on this page and attendees will be notified. \n\nAgenda At-A-Glance\n[View the Full Detailed Agenda]\nSession Times are Subject to Change and posted in Eastern Time Zone.\nCheck back for more detailed panel information.  \nWednesday\, June 1\n[New Time] 5:00 – 7:00 PM | Opening Reception\nHosted by Crowe LLP \nThursday\, June 2\n9:00 – 10:00 AM | 2022 Legislative Update \n10:10 – 11:10 AM | Concurrent Sessions \n\nLife Company Tax\nInternational-Inbound Issues\nEmerging Accounting Topics\n\n11:10 – 11:30 AM | Morning Refreshment Break \n11:30 AM – 12:30 PM | Concurrent Sessions \n\nInternational-Outbound Issues\nCaptive Insurance Primer*\nCryptocurrency\n\n12:30 – 2:00 PM | Keynote Luncheon \n2:00 – 3:00 PM | Concurrent Sessions \n\nP&C Company Tax\nInvestment Taxation\nIRS (and Other) Tax Guidance*\n\n3:10 – 4:10 PM | Concurrent Sessions \n\nHealth Company Tax\nInternational-OECD Developments\nProduct Tax\n\n4:10 – 4:30 PM | Afternoon Refreshment Break \n4:30 – 5:30 PM | Concurrent Sessions \n\nInformation Reporting\nM&A + Transactions\nIRS Procedural/Controversy Topics\n\n5:30 – 7:00 PM | Evening Reception \nFriday\, June 3\n8:30 – 9:10 AM | Insurance Branch Update \n9:20 – 10:20 AM | Concurrent Sessions \n\nPost-COVID Workplace Discussion\nConsolidated Return Issues\nHistory of Annuity Taxation*\n\n10:40 – 11:40 AM | Concurrent Sessions \n\nMultistate Tax Topics of Interest\nESG\nEthics\n\n11:50 AM – 12:30 PM | Takeaways \n12:30 PM | Boxed Lunch Available \n*Denotes primer-level (or refresher) content \n\nRegistration\nAdvance registration for this event is now closed.\nOnsite registration will be available at the JW Marriott on program dates. \n[Full Seminar Package]\nIncludes access to Light Breakfasts\, Refreshment Breaks\, THU Plated Lunch\, THU Welcome Reception\, and FRI Boxed Lunch.\n\n$550 – Sustaining Member           \n$580 – Member\n$730 – Nonmember\n$175 – Government/Academic\n$125 – Law Student\n\n[Basic Seminar Package]\nIncludes access to Light Breakfasts\, Refreshment Breaks\, and THU Welcome Reception. Does not include both lunches.\n\n$475 – Sustaining Member           \n$500 – Member\n$650 – Nonmember\n$150 – Government/Academic\n\nGroup Registrations: Organizations can process group registrations with one payment transaction online using the linked Register Online text above. If coordinating a registration on anyone’s behalf – please ensure you are entering the attendee’s information (not your own). After entering the first registrant’s information and selecting a registration fee\, click Save and Add Another to add additional registrants to the group transaction. After submitting payment information\, you will be directed to a receipt page to print for your records. Each registrant will also receive an auto-confirmation email.\nAccommodations: Please note onsite dietary or accessibility requests within the ADA section of the online registration form.\nCancellation Policy: Full registration refunds will be processed for cancellations received by Friday\, May 20. No-shows will be billed. Please email meetings@fedbar.org with questions and registration change requests.\n\n\nSponsors\nPremier \n \nEvent Partner\n \nConference Contributor \n \nConference Supporter \nBKD CPAs & Advisors \nInterested in sponsoring this event? View our Sponsorship Prospectus and contact sponsor@fedbar.org for more information. \n\nHousing\nA discounted block of rooms has been reserved for conference attendees at the JW Marriott (1331 Pennsylvania Avenue NW\, Washington\, DC 20004).  \n\n$329 (plus tax) – Single Occupancy\n$339 (plus tax) – Double Occupancy\n\nReservations must be made by 5:00 pm ET on May 11 — extended through Friday\, May 16! Any reservations received after the cut-off date or until the block is full\, whichever is sooner\, will be accepted based on a room-type and rate-available basis.  \nCLICK HERE to reserve your room online. To reserve over the phone\, call 800-393-2503 and reference the group name “Federal Bar Association Insurance Tax Seminar.” Please have your arrival/departure dates and credit card information ready to expedite your reservation process.  \nIn order to ensure the success of FBA meetings and programs\, we ask that registrants not book a room until AFTER registering for the even or book more than one room \n\nCLE + CPE Education\nTracking Attendance: Credit will be tracked via an online web application (ConferenceAdit). Attendees requesting credit are required to check-in and check-out of each session. The tracking site can be accessed directly via attendee-issued link. Attendees will login with the email and zip code affiliated with their registration. Certificates will be sent via email approximately two weeks following the event. \nCLE Credit\nAttorneys admitted to state bars having mandatory CLE requirements may receive credit for attending this conference. For 60-minute credit hour states\, up to 8 hours of CLE credit is available\, including 1 hours of ethics credit. For states with 50-minute credit hours\, up to 9.6 hours of CLE credit is available\, including 1.2 hours of ethics. \nCPE Credit\nThe Federal Bar Association is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org.\n Instructional Delivery Method: Group Live; CPE Credit Hours: 8.4; Field of Study: Tax; Prerequisite: None; Program Knowledge Level: Beginner; Advance Preparation: None. \n\n  \nFinancial Assistance: Program registrants (both FBA members and nonmembers) who are unable to afford the registration fee may receive a 50% discount on the member rate. Qualifying attorneys include those who are unemployed or actively seeking employment. A formal letter requesting the discount must be emailed to meetings@fedbar.org. That letter needs to state the reason for the attorney’s interest in the course or activity\, as well as proof of income or an explanation of the financial hardship\, and it must be signed by the requesting lawyer. \nIf you have any questions regarding this program\, please contact meetings@fedbar.org.
URL:https://www.fedbar.org/event/instax22/
LOCATION:JW Marriott\, 1331 Pennsylvania Ave NW\, Washington\, DC\, 20004
CATEGORIES:Section on Taxation
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END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20220531T120000
DTEND;TZID=America/New_York:20220531T130000
DTSTAMP:20260411T131831
CREATED:20220509T170512Z
LAST-MODIFIED:20220509T171608Z
UID:239277-1653998400-1654002000@www.fedbar.org
SUMMARY:Section on Taxation: Recent Developments in Civil and Criminal Tax Controversies
DESCRIPTION:Mr. Elliott and Mr. Pelak will be covering a wide range of current developments in civil and criminal tax controversies.  Topics include recent IRS budgetary issues\, remote trial procedures in the tax court\, IRS Office of Promoter Investigations\, conservation easements\, virtual currency\, and section 6695A and Form 3520 penalties. \nPresented by: Section on Taxation \n[Register Online] \n\nAbout the Presenters\nW. Curtis Elliott\, Partner\, Culp Elliott & Carpenter\, LLC \nCurtis Elliott has over 30 years of experience litigating civil and criminal tax cases\, including IRS audits and appeals\, and grand jury proceedings. His focus is primarily on civil tax cases\, and he has extensive courtroom trial experience in the U.S. Tax Court\, the Federal District Courts and state courts. His tax advocacy has resolved some of the most complex\, high stakes tax cases for clients. Mr. Elliott’s clients include Fortune 500 companies\, entrepreneurial companies\, trusts and estates and individuals. He works closely with co-counsel and CPA firms. Mr. Elliott is a fellow in the American College of Tax Counsel\, where he has served on the Board of Regents\, and is a fellow in the American College of Trusts and Estates Counsel.  Curtis is very active in the ABA Section of Taxation\, where he has served as past Chair of the Committee on Court Practice and Procedure\, the Committee on Appointments to the Tax Court and Council.  He speaks at conferences across the country on tax controversy topics.  He also co-authored the nationally published workbook entitled “Valuation Practice in Estate Planning and Litigation”  (Clark Boardman Callahan\, 1994). \nRichard A. Pelak\, Partner\, Culp Elliott & Carpenter\, LLC \nRichard A. Pelak serves as the Senior Tax Manager for the Firm’s Tax Compliance Group\, CEC Advisors. Rich’s primary focus is on representing clients in various federal and state tax matters. This includes personal and business tax planning\, consulting and compliance and representation before the IRS and other taxing authorities. He also assists clients in the areas of succession planning\, estate planning and various business transactions. Rich has extensive experience in international tax matters and in recent years has been heavily involved in offshore bank account reporting issues. He has experience in compliance with the offshore voluntary disclosure issues and IRS amnesty programs. He has worked extensively with clients in analyzing foreign accounts and preparing the necessary tax filings. \n\nRegistration & Attendance Information \n[Register Online] \nRegistration for this event will close Monday\, May 30 at 2 PM ET. \nRegistration Fees \n\nFBA Members & Nonmembers: Complimentary Registration\n\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member. \nRegistrants will receive Zoom login details on the day before the event
URL:https://www.fedbar.org/event/section-on-taxation-recent-developments-in-civil-and-criminal-tax-controversies/
LOCATION:DC
CATEGORIES:Section on Taxation
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20220504T120000
DTEND;TZID=America/New_York:20220504T130000
DTSTAMP:20260411T131831
CREATED:20220415T191945Z
LAST-MODIFIED:20220418T153620Z
UID:227409-1651665600-1651669200@www.fedbar.org
SUMMARY:Section on Taxation: Breaking Down Barriers to Effectuate Change in the Legal Field
DESCRIPTION:Join us for a virtual discussion with distinguished judges on the U.S. Tax Court as we discuss how they navigated the legal field throughout their trail-blazing careers and practices that can lead to a more diverse\, inclusive\, and equal environment in the legal field. \nSign language interpreters will be provided. If you require a reasonable accommodation to attend this program please email keona.l.hill@irscounsel.treas.gov. \n\nPanelists\nHon. Maurice B. Foley\, Chief Judge\, U.S. Tax Court\nHon. Courtney D. Jones\, Judge\, U.S. Tax Court\nHon. Juan F. Vasquez\, Judge\, U.S. Tax Court\nHon. Eunkyong Choi\, Special Trial Judge\, U.S. Tax Court \n\nRegistration\nRegister Online (Zoom – Section on Taxation)
URL:https://www.fedbar.org/event/section-on-taxation-breaking-down-barriers-to-effectuate-change-in-the-legal-field/
LOCATION:DC
CATEGORIES:Section on Taxation
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END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20220421T120000
DTEND;TZID=America/New_York:20220421T130000
DTSTAMP:20260411T131831
CREATED:20220329T202738Z
LAST-MODIFIED:20220421T120622Z
UID:221877-1650542400-1650546000@www.fedbar.org
SUMMARY:Section on Taxation: IRS Collections\, CSEDs\, DOJ Reducing Assessments to Judgment and Enforcement Suits
DESCRIPTION:Mr. Pontius will discuss IRS collections for taxpayers with large balances due and review collection alternatives for cases that are near the end of their collection statute expiration dates (CSEDs). If the taxpayer is unable to resolve the balance due with the Revenue Officer and the Revenue Officer has determined that the taxpayer has large collectible assets that the taxpayer will not liquidate to pay the IRS\, then the IRS may refer that case to the Department of Justice to reduce that claim to judgement. Mr. Howlette will share his experience litigating these types of cases and how the Department of Justice handles a typical collection case. \nPresented by: Section on Taxation \nRegistration is Closed \n\nAbout the Presenters\nMr. John Pontius\, Founder\, Pontius Tax Law PLLC \nMr. Pontius regularly represents individual and business clients with sensitive and serious tax matters before the Internal Revenue Service and state taxing authorities. His client base is local\, national and international. Over the course of his career\, Mr. Pontius has represented businesses and individuals with complex tax issues in the following areas: FBAR examinations\, offshore disclosures\, FATCA\, FIRPTA\, tax planning\, unfiled tax returns\, release of tax liens and levies\, trust fund recovery penalty\, IRS and state audit examinations as well as Appeals\, penalty abatement\, US Tax Court litigation along with defense of tax fraud and evasion. \nMr. Jordan Howlette\, Founder\, JD Howlette Law \nLast year Mr. Howlette opened his law firm following a five-year career as a trial attorney in the Tax Division of the United States Department of Justice (DOJ). While at the DOJ\, Mr. Howlette successfully litigated dozens of civil tax cases and controversies on behalf of the United States in federal courts around the country\, securing millions of dollars in favorable judgments while also advocating for equitable justice. He is intimately familiar with the procedures\, strategies\, and processes of litigating in federal court and with resolving multi-faceted civil disputes involving high-dollar amounts\, complex statutory and regulatory provisions\, and diverse parties from different jurisdictions. \n\nRegistration & Attendance Information \nRegistration is Closed \nRegistration for this event will close Wednesday\, April 20 at 5 PM ET. \nRegistration Fees \n\nFBA Members & Nonmembers: Complimentary Registration\n\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member. \nRegistrants will receive Zoom login details on the day before the event
URL:https://www.fedbar.org/event/section-on-taxation-irs-collections-cseds-doj-reducing-assessments-to-judgment-and-enforcement-suits/
LOCATION:DC
CATEGORIES:Section on Taxation
END:VEVENT
BEGIN:VEVENT
DTSTART;VALUE=DATE:20220303
DTEND;VALUE=DATE:20220305
DTSTAMP:20260411T131831
CREATED:20211027T195058Z
LAST-MODIFIED:20220301T235423Z
UID:178575-1646265600-1646438399@www.fedbar.org
SUMMARY:2022 Tax Law Conference
DESCRIPTION:Join the Section on Taxation for the 46th Annual Tax Law Conference on March 3-4\, 2022. This newly formatted two-day program will offer the same great content in-person and online. Programming will be held exclusively in-person on Thursday\, March 3 and exclusively virtually on Friday\, March 4. \nExamine important tax developments and emerging policy issues in nearly 20 educational sessions featuring notable speakers from the Internal Revenue Service\, Treasury Department\, Department of Justice\, White House\, and Congress. Programming will include a keynote address and awards presentations for both the Annual Writing Competition and prestigious Kenneth H. Liles Award for Distinguished Service to an eminent tax practitioner. \n[Update] As of February 15\, DC Mayor has terminated the vaccination requirement for event facilities. Face masks are required in the building and event spaces when not actively eating or drinking\, per event venue policies. \n\nAgenda\nSession Times are Subject to Change\nSessions are posted in Eastern Time Zone \n>>> CLICK HERE for a detailed agenda featuring panel descriptions and confirmed speakers!\n\nThursday\, March 3 | Ronald Reagan Building & International Trade Center\nIn-Person Participation Only – No Streaming\n9:00 a.m. – 5:30 p.m. | Registration & Exhibitor Hours \n9:00 a.m. – 10:00 a.m. | Breakfast \n9:45 a.m. – 10:00 a.m. | Welcome Remarks \n10:00 a.m. – 11:00 a.m. | Legislative Update: Floyd’s Panel \n11:00 a.m. – 11:30 a.m. | Morning Break \n11:30 a.m. – 12:30 p.m. | Cryptocurrency and Blockchain Technologies: An Industry Perspective \n12:30 p.m. – 2:30 p.m. | Luncheon Program \nPresentation of the Donald C. Alexander Tax Law Writing Competition\nKeynote Speaker: Lily Batchelder\, Assistant Secretary for Tax Policy\, U.S. Department of the Treasury\nLily Batchelder was confirmed by the U.S. Senate in September 2021 as Assistant Secretary for Tax Policy at the U.S. Department of the Treasury. Previously she was the Robert C. Kopple Family Professor of Taxation at NYU School of Law and an affiliated professor at the NYU Wagner School of Public Service. From 2014 to 2015\, Batchelder served as Deputy Director of the White House National Economic Council and Deputy Assistant to the President under President Obama. There\, she was responsible for tax and budget issues\, including tax reform\, retirement policy\, and low-income benefits. From 2010 to 2014\, she served as Majority Chief Tax Counsel for the U.S. Senate Committee on Finance\, where she led Chairman Baucus’s work on tax issues\, including tax reform and the fiscal cliffs. \n2:30 p.m. – 3:30 p.m. | Global and U.S. Tax Reform Update \n3:30 p.m. – 4:00 p.m. | Afternoon Break \n4:00 p.m. – 5:00 p.m. | Ethics and Federal Tax Practice \n5:00 – 7:00 p.m. | Reception and Presentation of the Kenneth H. Liles Award \nFriday\, March 4 | Online Virtual Platform\nVirtual Participation Only – No In-Person Attendance\n9:30 am – 10:30 am | Concurrent Educational Panels \nTrack 1 – Enforcement & Criminal | State of IRS: Criminal Investigation\nTrack 2 – Tax Accounting\nTrack 3 – Partnerships & Passthroughs | Partnership Debt Allocations: Balancing Administrative Convenience v. Guard Rails \n11:00 am – 12:00 pm | Concurrent Educational Panels \nTrack 1 – Domestic Corporate | Recent Developments in Corporate Tax\nTrack 2 – Tax Accounting | Current Issues on the Capitalization of Transaction Costs\nTrack 3 – Tax Practice & Procedure | Testing Guidance under the Administrative Procedures Act \n12:30 pm – 1:30 pm | Concurrent Educational Panels \nTrack 1 – Domestic Corporate | Cross-Border M&A Developments\nTrack 2 – Tax Practice & Procedure | Partnership Examinations Under the New Rules\nTrack 3 – International | Transfer Pricing: What Is On The Transfer Pricing Horizon \n2:00 pm – 3:00 pm | Concurrent Educational Panels \nTrack 1 – Enforcement & Criminal | Technology’s Impact on Criminal Tax Enforcement: IRS Cybercrimes 2022\nTrack 2 – Tax Practice & Procedure | Remote Audit and Litigation Tools\, Now and in the Future\nTrack 3 – Employee Benefits & Executive Compensation | Hot Topics in Employee Benefits \n3:30 pm – 4:30 pm | Concurrent Educational Panels \nTrack 1 – Enforcement & Criminal | Hot Topics: IRS Enterprise Compliance Initiatives\nTrack 2 – International | U.S. International Tax Developments\nTrack 3 – Employee Benefits & Executive Compensation | Hot Topics in Executive Compensation \n\nRegistration\nAdvance registration for this event closed on Friday\, February 25\, 2022\nOnsite registration for Thursday\, March 3 will be available at the Ronald Reagan Building \nFull Conference Rates \n$335 — Sustaining Member\n$375 — FBA Member\n$475 — Nonmember\n$95 — Government/Academic\n$95 — Law Student \nDay One: In-Person Rates \n$190 — Sustaining Member\n$200 — FBA Member\n$250  — Nonmember\n$50 — Government/Academic\n$50 — Law Student \nDay Two: Virtual Rates \n$225 — Sustaining Member\n$250 — FBA Member\n$300  — Nonmember\n$50 — Government/Academic\n$50 — Law Student \nRSVP for Thursday’s Social Events\nBoth Social Events are Complimentary for Conference Registrants\nRSVP by selecting “Session” during the check-out process\n— RSVP: Liles Reception\n— RSVP: Thursday Lunch \nAccommodations: Closed captioning will be available for those attending the virtual webcasts. Please contact Caitlin Rider at crider@fedbar.org for onsite dietary or accessibility requests.\nCancellation Policy: Full registration refunds will be processed for cancellations received by Friday\, February 18. Registrants may change their in-person registration to virtual at any time\, and partial refunds will be issued if transfer requests are received by Friday\, February 18. No-shows will be billed. Please email meetings@fedbar.org with questions and registration change requests.\n\nSponsors\nEvent Partner\n \n \nConference Contributor\n \n\n \nWelcome Sponsor \n \nConference Supporter\nIvins\, Phillips & Barker\, Chartered\nLatham & Watkins LLP\nMorgan Lewis & Bockius LLP\nMorrison & Foerster LLP\nSkadden\, Arps\, Slate\, Meagher & Flom LLP \nProgram Patron\nDeloitte Tax LLP\nFox Rothschild LLP \nInterested in sponsoring this event? View our Sponsorship Prospectus and contact sponsor@fedbar.org for more information. \n\nCLE + CPE Education\nTracking Attendance: Credit will be tracked via an online web application (ConferenceAdit) for in-person and virtual attendees. Attendees requesting credit are required to check-in and check-out of each session. The tracking site can be accessed directly via attendee-issued link. Attendees will login with the email and zip code affiliated with their registration. Certificates will be sent via email approximately two weeks following the event. \nVirtual Accreditation: Credit will be available for states that allow live webinar presentations. Attendees must attend the live panel broadcast\, answer engagement polls\, and track attendance via ConferenceAdit site to receive credit (see note above). \nCLE Credit\nAttorneys admitted to state bars having mandatory CLE requirements may receive credit for attending this conference. For 60-minute credit hour states\, up to 8 hours of CLE credit is available\, including 1 hours of ethics credit. For states with 50-minute credit hours\, up to 9.6 hours of CLE credit is available\, including 1.2 hours of ethics. \nCPE Credit\nThe Federal Bar Association is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org.\nThursday\, March 3 — Instructional Delivery Method: Group Live; CPE Credit Hours: 3.0; Field of Study: Tax; Prerequisite: None; Program Knowledge Level: Beginner; Advance Preparation: None.\nFriday\, March 3 — Instructional Delivery Method: Group Internet Based; CPE Credit Hours: 5.0; Field of Study: Tax; Prerequisite: None; Program Knowledge Level: Beginner; Advance Preparation: None. \n\n\nEmail Communication Policy: By registering for this event\, you agree to receive email communications from the Federal Bar Association and affiliated sponsors of the program concerning event details\, Continuing Legal Education certification\, programming changes\, upcoming events\, surveys\, and post-event communications.\nRecording Disclaimer: By registering for an online FBA program\, you agree to the recording of audio and visual content presented during the live event and consent to subsequent use of the recording by the FBA. You agree that the recording is the sole property of the FBA and that the recording may be used by the FBA in any manner in its sole and absolute discretion. This recording may include questions and poll responses provided by you during the live event. If you do not consent to the recording and the FBA’s use of the same\, do not register for the event.\nPhotography Release: Registrants\, instructors\, exhibitors\, and guests attending FBA meetings agree they may be photographed during the event. Photographs are the sole property of the FBA\, which reserves the right to use attendees’ names and likenesses in promotional materials without providing monetary compensation.\nFinancial Assistance: Program registrants (both FBA members and nonmembers) who are unable to afford the registration fee may receive a 50% discount on the member rate. Qualifying attorneys include those who are unemployed or actively seeking employment. A formal letter requesting the discount must be emailed to meetings@fedbar.org. That letter needs to state the reason for the attorney’s interest in the course or activity\, as well as proof of income or an explanation of the financial hardship\, and it must be signed by the requesting lawyer.\nIf you have any questions regarding this program\, please contact meetings@fedbar.org.
URL:https://www.fedbar.org/event/taxlaw22/
LOCATION:Ronald Reagan Building & International Trade Center\, 1300 Pennsylvania Avenue\, NW\, Washington\, US
CATEGORIES:Section on Taxation
ATTACH;FMTTYPE=image/jpeg:https://www.fedbar.org/wp-content/uploads/2020/11/Tax20-Image.jpg
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20220216T180000
DTEND;TZID=America/New_York:20220216T190000
DTSTAMP:20260411T131831
CREATED:20220128T173025Z
LAST-MODIFIED:20220217T131836Z
UID:201589-1645034400-1645038000@www.fedbar.org
SUMMARY:Section on Taxation: Your Tax Law Career - Pathways to the Profession
DESCRIPTION:This panel of tax attorneys will share their various paths to employment and success in the tax profession. Lessons from interviewing and networking on and off campus will be shared. If you’re an aspiring tax lawyer or simply interested in tax law\, please join us for an informative discussion. \nPresented by: Section on Taxation \nRegistration is Closed \n\nAbout the Presenters\nZenia Memon\, Associate\, Kostelanetz & Fink \nZenia Memon is an associate at Kostelanetz & Fink\, LLP where she specializes in international tax planning and tax controversy. Prior to joining Kostelanetz & Fink\, she was a senior associate at PwC’s National Tax Office\, with their international tax practice. While a law student\, she completed tax externships with Jones Day and Kostelanetz & Fink. She was also a research assistant to Itai Grinberg\, the current deputy assistant secretary for multilateral tax at the Department of the Treasury. \nShe holds a Master of Laws degree in Taxation and a J.D. from Georgetown University Law Center\, and a Bachelor’s degree in Economics and History from Queen’s University. \nJacob Puhl\, Manager of Tax Policy at Meta (formerly Facebook) \nJacob is a Manager of Tax Policy at Meta\, formerly Facebook. He leads Tax Policy for the Middle East\, Africa\, and the US States. Based in Washington\, DC\, he serves as a liaison between business lines and tax functions to remove friction and anticipate challenges. His portfolio spans\nthe globe\, with a focus on promoting workable and consistent tax policy. \nBefore Meta\, Jacob was a Manager at Deloitte’s Washington National Tax practice focusing primarily on US Federal tax policy. He contributed to legislative updates for clients as well as advised foreign entities and embassies on U.S. policy matters. Prior to Deloitte\, Jacob served as a legal intern at the U.S. Treasury Department\, in the Office of the International Tax Counsel. Jacob also served as a law clerk with the tax team for the Senate Finance Committee. \nJacob received his LL.M. in Taxation from Georgetown University Law Center\, his J.D. from Ohio State University\, and his B.A. in Economics from University of Maryland – Baltimore County. \nDaniel Strickland\, Associate\, Eversheds Sutherland \nDaniel Strickland concentrates his practice in the area of federal and international tax controversy\, representing taxpayers in all types of tax controversy matters. Daniel guides clients through IRS audits\, prepares administrative claims and protests of IRS actions\, and litigates tax and tax-related cases throughout the United States. Daniel’s experience covers a wide range of complex tax issues\, including valuation\, foreign and energy tax credits\, classification of investment as debt or equity\, judicial substance doctrines\, and penalty defenses. \nPrior to joining Eversheds Sutherland\, Daniel served as a law clerk at the United States Tax Court for the Honorable Albert G. Lauber\, the Honorable Elizabeth Crewson Paris\, and the Honorable Michael B. Thornton. Daniel holds an LL.M in taxation from Georgetown University Law Center\, where he attended on a merit scholarship. \n \nDaren Gottlieb\, International Tax Senior Manager\, KPMG \nDaren is an International Tax Senior Manager in KPMG’s Washington National Tax practice and advises on a wide range of international tax issues\, for both multinational and private equity clients\, including foreign tax credits\, cross-border restructuring\, tax-efficient repatriation\, and tax treaty application. Daren has also focused his practice on helping clients navigate the implications of U.S. tax reform and the application of U.S. tax laws to transactions involving cryptocurrency/digital assets.\n \nTeisha Ruggiero\, IRS \nTeisha Ruggiero is an attorney with the IRS Office of Associate Chief Counsel (International)\, Branch 3. Before joining the Chief Counsel’s office in July 2021\, she worked at KPMG for seven years. While at KPMG she focused on the substantial statutory and regulatory changes to foreign tax credits and other international tax rules attributable to the Tax Cuts and Jobs Act. Ms. Ruggiero graduated from McGill University (BA)\, the London School of Economics (MSc in Comparative Politics)\, Brooklyn Law School (JD)\, and New York University School of Law (LLM). \n\nRegistration & Attendance Information \n[Register Online] \nRegistration for this event will close Tuesday\, February 15 at 5 PM ET. \nRegistration Fees \n\nFBA Members & Nonmembers: Complimentary Registration\n\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member. \nRegistrants will receive Zoom login details on the day before the event
URL:https://www.fedbar.org/event/section-on-taxation-your-tax-law-career-pathways-to-the-profession/
LOCATION:DC
CATEGORIES:Section on Taxation
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20220126T140000
DTEND;TZID=America/New_York:20220126T151500
DTSTAMP:20260411T131831
CREATED:20220119T195357Z
LAST-MODIFIED:20220125T224857Z
UID:198642-1643205600-1643210100@www.fedbar.org
SUMMARY:Webinar: Protecting Clients’ Information and Data in Your Practice
DESCRIPTION:This panel will discuss a variety of ethical questions relating to data security and best practices using electronic media in IRS examinations and other tax matters.   Examples of specific areas that the panelists will cover include\, among others\, data privacy and ethical issues related to social media and other related business issues\, use of email\, the cloud\, and other media\, tax return related identify theft\, and concerns in interacting with the IRS via online portals or other electronic means. \nLearning Objectives \n\nLearn how Circular 230\, the ABA model rules\, and other ethical rules impose a mandate that a tax practitioner focus on data security and related concerns.\nUnderstand best practices when dealing with secure collaboration spaces\, encryption and cyber security\, social media and other related sites\, identity theft\, and the use of electronic media in IRS exams/appeals.\nDiscuss various hypotheticals and how tax practitioners need to apply these rules to practicing in today’s electronic age.\n\nPresented by the Section on Taxation \n\nAbout the Presenters\nFred Murray\, Special Counsel\, Office of Chief Counsel\, Internal Revenue Service (moderator) \nFred Murray currently serves as a Special Counsel and Lead Professor-in-Residence in the Office of Chief Counsel of the Internal Revenue Service\, as well as Director of the Talent Management Division. Before he returned to Chief Counsel\, he was Director of the Graduate Tax Program and a Professor teaching international tax and tax procedure at the University of Florida Levin College of Law (the Graduate Tax Program is ranked 2nd by U.S. News & World Report). Before that\, he was a tax partner in both a large law firm and the U.S. firm of the 5th largest international public accounting firm\, and taught part-time in law schools and in graduate business schools for more than 30 years. In the large international accounting firm where he was before the University of Florida\, among other duties\, he was a partner-level member of Firm’s TARAS tax accounting services team. His previous government experience also includes service as Deputy Assistant Attorney General in the Tax Division at the U.S. Department of Justice and as a Special Counsel to the Chief Counsel for the U.S. Internal Revenue Service. Fred Murray is an attorney (District of Columbia\, Maryland\, New York\, and Texas (Board Certified in Tax Law\, Texas Board of Legal Specialization)\, and various federal courts) and C.P.A. (Florida\, Texas\, and Maryland). B.A.\, Rice University; J.D. University of Texas at Austin. \nSharyn Fisk\, Director\, Office of Professional Responsibility\, Internal Revenue Service \nSharyn M. Fisk was named Director of the IRS Office of Professional Responsibility (OPR) in January 2020. As Director\, she is responsible for the IRS’ oversight of tax professionals who practice before the IRS as set out in Treasury Circular 230. Sharyn’s extensive background in the tax community brings over 20 years of tax experience to the OPR position. Before coming to the IRS\, Sharyn was Professor of Tax at Cal Poly Pomona and Director of the University’s VITA program. Prior to teaching\, Sharyn was in private practice specializing in tax controversies. As a private practitioner\, Sharyn represented hundreds of individuals\, businesses\, and corporate taxpayers before the IRS\, the Department of Justice Tax Division\, federal and state courts\, and state taxing authorities. These matters involved civil examinations and appeals\, criminal investigations\, and tax collection issues. Before becoming a private practitioner\, Sharyn clerked for the Honorable Maurice Foley\, Judge\, U.S. Tax Court. Sharyn has held leadership roles in several professional organizations. She served as a former Chair of the Tax Policy\, Practice and Legislation Committee for the American Bar Association (ABA). She is a past Chair of the Taxation Section of the Los Angeles County Bar Association and the Taxation Section of the Beverly Hills Bar Association. In 2019\, Sharyn concluded a three-year term as a member of the IRS Advisory Council (IRSAC). She chaired a task force on unenrolled return preparers on behalf of the Standards of Tax Practice Committee for the ABA Taxation Section. She is also a Fellow of the American College of Tax Counsel. Sharyn wrote and spoke extensively before national\, state\, and local tax professional organizations on all aspects of civil and criminal tax controversy issues and ethics in tax practice. Sharyn earned a B.A. in Journalism from San Diego State University\, a J.D. from Rutgers University\, and an LL.M in taxation from the New York University School of Law. \nRobb Longman\, Partner\, Longman & Van Grack\, LLC \nMr. Longman is a managing member at the Bethesda\, Maryland law firm Longman & Van Grack\, LLC. Mr. Longman practice areas include representing his clients’ business matters\, tax planning and litigation\, as well as estate planning. Mr. Longman regularly assists businesses with the drafting of corporate documents\, drafting contracts\, negotiating contracts\, addressing employee agreements\, and formulating succession planning. Additionally\, Mr. Longman has successfully represented many business\, individuals\, and non-profits before the Internal Revenue Service and state taxing agencies. Mr. Longman represents his clients in tax audits\, in the United States Tax Court\, the Maryland Tax Court. He is currently a Council Director of the American Bar Association’s Tax Section and has been the Chair of the Maryland State Bar Association’s Tax Section. \nChristopher S. Rizek\, Member\, Caplin & Drysdale\, Chartered \nChristopher S. Rizek is a member of the law firm of Caplin & Drysdale\, Chartered\, in Washington\, D.C.  He formerly served as Associate Tax Legislative Counsel in the U.S. Treasury Department\, Office of Tax Policy\, where he helped write tax procedural guidance and legislation\, including particularly the Taxpayer Bill of Rights 2 (1996) and the IRS Restructuring and Reform Act of 1998.  He has also previously worked in other Washington law firms and as a Trial Attorney in the U.S. Department of Justice\, Tax Division.  Mr. Rizek has a bachelor’s degree in philosophy from Dartmouth College and received his J.D. and his LL.M. in Taxation from Georgetown University Law Center\, where he is currently an Adjunct Professor.  He has chaired committees and served in numerous other capacities in the D.C. Bar’s Taxation Section\, the American Bar Association Section of Taxation\, and the American College of Tax Counsel.  Mr. Rizek served for eleven years as General Counsel of Caplin & Drysdale\, and for five years as a member and later chairman of the Anne Arundel County Ethics Commission\, and he frequently speaks and writes about tax practice and ethics issues. \nAnita Soucy\, Chief Quality Officer\, Deloitte Tax LLP \nAs Chief Quality Officer of Deloitte Tax LLP\, Anita is responsible for leading the Deloitte’s activities related to matters involving risk\, quality assurance\, and professional and ethical standards applicable to the firm’s tax practitioners. Anita is responsible for consultations regarding tax quality assurance and risk matters\, coordinating quality assurance reviews\, and development of risk and professional practice policies applicable to Deloitte Tax LLP. She is the firm’s lead regulatory liaison with regulators of the tax profession\, including the Internal Revenue Service and the U.S. Department of Treasury. She is responsible for matters pertaining to client confidentiality and privacy for the tax business. She is also responsible for COVID-related business continuity and reopening efforts for Deloitte US Tax. As Deputy Chief Risk Officer of Deloitte LLP\, Anita oversees strategic and reputational risk imperatives\, crisis management\, non-audit regulatory affairs\, independence\, ethics and compliance\, as well as confidentiality and privacy matters. Anita is a frequent lecturer and speaker in tax and legal professional organizations on topics such as aggressive tax evasion and shelter activity\, including litigation and related controversies involving whistleblowers\, professional and ethical standards\, tax penalties and procedure\, as well as privacy and confidentiality regulations and tax-related cyber security topics. \n\nRegistration\nRegistration is now closed. \nRegistration Fees \n\nFBA Member: $0\nNonmember: $75\n\nLive Captioning: Closed captioning is available for all virtual webcasts. \nCancellation Policy: No refunds will be made for cancellations received after the close of business on January 21\, 2022. No-shows will be billed. Substitutions may be made at any time upon notification. Email cancellation requests to meetings@fedbar.org. For more information regarding refund\, complaint and/or program cancellation policies\, please contact our offices at 571-481-9100 or meetings@fedbar.org. \nInternet Requirements: Virtual programs require suitable internet strength to stream online panels. A minimum internet connection of 800 Kbps is recommended for an optimal attendee experience. Test your connection here.  \n\nCLE Credit\nCLE: 1.25 CLE Credit (60min state) / 1.4 CLE Credit (50min state) \nCLE Credit will be processed/reported approximately 4-6 weeks after the event date and available for credit in states that allow credit for live webinar presentations. You must attend the live broadcast\, answer engagement polls\, and accurately enter your bar number in our database to receive credit. Certificates and required documentation for self-reporting states will be issued via email\, upon state bar approval. Thank you in advance for your patience\, as state bars are experiencing significant delays with virtual program processing. \nClick Here for more information on CLE Attendance and Reporting. \nCPE Sponsor\nThe FBA is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors\, 150 Fourth Avenue North\, Suite 700\, Nashville\, TN 37219-2417. Website: www.nasba.org. \nInstructional Delivery Method: Group Live delivered online due to COVID-19; CPE Credit Hours: 1.4; Field of Study: Tax; Prerequisite: None; Program Knowledge Level: Beginner; Advance Preparation: None \n\nEmail Communication Policy: By registering for this event\, you agree to receive email communications from the Federal Bar Association and affiliated sponsors of the program concerning event details\, Continuing Legal Education certification\, programming changes\, upcoming events\, surveys\, and post-event communications. \nRecording Disclaimer: By registering for an FBA webinar\, you agree to the recording of audio and visual content presented during the live event and consent to subsequent use of the recording by the FBA. You agree that the recording is the sole property of the FBA and that the recording may be used by the FBA in any manner in its sole and absolute discretion. This recording may include questions and poll responses provided by you during the live event. If you do not consent to the recording and the FBA’s use of the same\, do not register for the event. \nFinancial Assistance: Program registrants who are unable to afford the registration fee may receive a 50% discount on the member rate. Qualifying attorneys include those who are unemployed or actively seeking employment. A letter requesting the discount must be provided to FBA Staff. That letter needs to state the reason for the attorney’s interest in the course or activity\, as well as proof of income or an explanation of the financial hardship\, and it must be signed by the requesting lawyer. That letter must be accompanied by a complete course registration form. \nIf you have any questions regarding this program\, please contact meetings@fedbar.org. 
URL:https://www.fedbar.org/event/webinar_protecting_clients_information/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20220111T120000
DTEND;TZID=America/New_York:20220111T130000
DTSTAMP:20260411T131831
CREATED:20210806T134340Z
LAST-MODIFIED:20211217T160008Z
UID:154295-1641902400-1641906000@www.fedbar.org
SUMMARY:Section on Taxation: Cryptocurrency Update
DESCRIPTION:Please join us for a cryptocurrency update from the FBA Section on Taxation. Speakers from the IRS\, Eversheds Sutherland\, and Kostelanetz & Fink will discuss current cases and developments in the field\, technology tools and audit streams\, the recent John Doe summonses\, and Operation Hidden Treasure. Topics will also include important changes to the Infrastructure Investment and Jobs Act\, as well as IRS guidance on hard forks and like-kind exchanges.\n\n\n\n  \nAbout the Presenters\nDon Fort\, CPA\, Kostelanetz & Fink\, LLP\nSarah Paul\, Partner\, Eversheds Sutherland\nCarolyn A. Schenck\, National Fraud Counsel and Assistant Division Counsel (International)\, SB/SE Office of Chief Counsel\, Internal Revenue Service \n\nRegistration\n\n\n\nClick to Register (Eversheds Sutherland)\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\nCLE\nEversheds Sutherland is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of group internet based and group live continuing education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org. \nCLE credit available: Up to 1.0 hours for the program\nCPE credit available: Up to 1.2 hours for the program \nCLE credit is approved for this webcast in CA\, GA\, NE\, NY\, PA and TX. CLE credit is pending in IL\, VA and WA. An individual attorney application may be required for attorneys licensed outside these states. Please check with your respective state bar(s) for confirmation. This program’s content is transitional\, and is appropriate for both newly admitted and experienced NY attorneys.\nDistance learning courses should be attended in an educational setting that is free from distractions. \nQuestions about CLE can be directed pamelawimmer@eversheds-sutherland.com.
URL:https://www.fedbar.org/event/section-on-taxation-cryptocurrency-update/
LOCATION:DC
CATEGORIES:Section on Taxation,Younger Lawyers Division
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20210930T120000
DTEND;TZID=America/New_York:20210930T130000
DTSTAMP:20260411T131831
CREATED:20210901T195922Z
LAST-MODIFIED:20210930T153307Z
UID:161828-1633003200-1633006800@www.fedbar.org
SUMMARY:Section on Taxation: Update on Cannabis Tax Compliance\, Structuring\, and Examination Issues
DESCRIPTION:This roundtable will discuss recent experiences with cannabis tax compliance issues\, IRS examinations\, and practical advice for structuring cannabis operations in light of Section 280E. The panelists will cover common mistakes and red flags for IRS audits\, recently resolved issues relating to operational costs and entity structuring\, and issues currently being litigated in various courts around the country. \nPresented by: Section on Taxation \nRegistration is Closed \n\nAbout the Presenters\nJennifer Benda\, Shareholder\, Hall Estill  \nJennifer Benda is a former CPA and tax attorney who focuses on tax controversy matters. Jennifer has spent the last six years advising and defending cannabis businesses\, including representing industry associations Marijuana Industry Group and Cannabis Trade Federation Action in submission of an amicus brief to the Ninth Circuit in Patients Mutual Assistance Collective Corporation\, dba Harborside Health Center v. Commissioner. Jennifer earned a B.B.A. & M.S. (Accounting) at Texas A&M University and J.D.\, with honors\, at George Washington University Law School.  Jennifer has received the following honors: ranked by Chambers USA-Nationwide Cannabis Law: Corporate/Transactional practice & Tax Law (Colorado); Fellow: American College of Tax Counsel; National Law Journal Cannabis Law Trailblazer (2018); 5280 magazine top cannabis lawyer (2021). \n  \nJames Mann\, Owner\, The Law Office of James B. Mann  \nJames Mann has broad-based business tax experience which provides the foundation for his current focus on cannabis tax. He helps his clients with tax planning to minimize current tax liability (restructuring\, tax accounting\, revising intercompany agreements\, transfer pricing) as well as representing them before the IRS and in court. James has a JD from the Harvard Law School\, an MBA in accounting and finance from Columbia University\, and a BA from the Cornell University College of Arts and Sciences. \n  \n\nRegistration & Attendance Information \nRegistration for this event will close Wednesday\, September 29 at 12 PM ET. \nRegistration Fees \n\nFBA Members & Nonmembers: Complimentary Registration\n\nGround Rules \n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.\n\nInterested in Speaking? If you are interested in leading a future monthly call\, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com.
URL:https://www.fedbar.org/event/section-on-taxation-update-on-cannabis-tax-compliance-structuring-and-examination-issues/
LOCATION:DC
CATEGORIES:Section on Taxation
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20210715T120000
DTEND;TZID=America/New_York:20210715T130000
DTSTAMP:20260411T131831
CREATED:20210701T162608Z
LAST-MODIFIED:20210715T151750Z
UID:143273-1626350400-1626354000@www.fedbar.org
SUMMARY:Section on Taxation Round Table: Update on IRS Partnership Audit Issues and Initiative
DESCRIPTION:This roundtable will address recent experience with IRS audits of partnerships\, including both legacy TEFRA issues and new BBA issues.  The panelists will also discuss the recently announced partnership audit initiative and its potential effects on the future of partnership compliance and examinations going forward. \n\nAbout the Presenters\nKat Saunders Gregor\, Partner\, Ropes & Gray LLP \nKat is a tax partner and co-founder of the Tax Controversy Group. Kat regularly handles disputes with the IRS\, DOL and other administrative bodies\, and assists clients in managing disputes with non-U.S. tax authorities. Kat represents public companies\, private investment funds\, institutional investors\, private companies and high net worth individuals before the U.S. Tax Court\, U.S. Court of Federal Claims and other federal and state courts. \nJoshua Wu\, Counsel\, Latham & Watkins LLP \nJoshua Wu\, former Deputy Assistant Attorney General (DAAG) for Appellate and Review in the Tax Division of the US Department of Justice (DOJ)\, counsels and advocates for companies and high net worth individuals on all aspects of tax controversies and litigation.  Mr. Wu advises on issues ranging from tax accounting disputes\, to corporate and partnership transactional issues\, international questions\, employee benefits matters\, and tax exempt controversies. He brings a unique knowledge base and skillset to his clients\, drawing on his experience both in senior leadership roles in the DOJ’s Tax Division and in private practice. \nMaria Dolan\, Executive Assistant\, Technical (LB&I – Pass Through Entity)\, IRS Office of Chief Counsel \nMaria Dolan has been with the IRS for 16 years and is currently the Executive Assistant\, Technical for the Pass Through Entity Practice Area in LB&I.  Before coming to the IRS\, Maria had 15 years of experience working in large and regional public accounting firms and multi-national corporations.  At the IRS\, Maria has been a Technical Advisor for Financial Accounting Issues\, worked on the implementation of the Affordable Care Act and was Territory Manager for teams in DC\, Virginia and Maryland.  In her current role\, Maria has overseen the implementation of the new centralized partnership procedures commonly referred to as BBA and now overseeing the initiation of LB&I’s Large Partnership Compliance program. \n\nRegistration & Attendance Information \nNote: Registration has closed for this event. \nGround Rules \n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.\n\nInterested in Speaking? If you are interested in leading a future monthly call\, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com.
URL:https://www.fedbar.org/event/section-on-taxation-round-table-update-on-irs-partnership-audit-issues-and-initiative/
LOCATION:DC
CATEGORIES:Section on Taxation
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20210622T123000
DTEND;TZID=America/New_York:20210622T133000
DTSTAMP:20260411T131831
CREATED:20210615T152159Z
LAST-MODIFIED:20210622T135426Z
UID:138259-1624365000-1624368600@www.fedbar.org
SUMMARY:Section on Taxation: The Role of Nutrition for Busy Lawyers (and Everyone)
DESCRIPTION:Tuesday\, June 22\, 2021 | 12:30 PM ET \nCome join the FBA Tax Section for “The Role of Nutrition for Busy Lawyers (and Everyone)” hosted by the Health & Wellness Committee on June 22\, 2021 at 12:30 pm ET! \nThis panel will address the importance of nutrition for busy professionals\, including the impact of nutrition on mental health and wellbeing\, the controversy surrounding fad diets\, and the challenges busy professionals face with identifying and prioritizing good nutrition habits. We will talk with a registered dietitian about how nutrition has a direct impact on mental health\, emotional regulation\, and executive function. The goal of the session is to provide the audience with tools like intuitive eating and flexible meal planning to help with tight deadlines\, hybrid work environments\, and travel for work or pleasure. \nPlease join us and invite your colleagues and friends. \n\nAbout the Speakers\n\nGenevieve Traversa\, MS\, RDN (Masters of Science\, Registered Dietetic Nutritionist)\nLili Kazemi\, Director at PwC\, and Editor of DAOFitLife.com\nJorge M. Oben\, Attorney\, IRS Office of Chief Counsel (Moderator)\nElizabeth A. Kanyer\, Trial Attorney\, Department of Justice\, Tax Division (Moderator)\n\n\nRegistration\nDeadline to register will be Monday\, June 21 2021 at 2 PM ET.  \n\nRegistration for this event is now closed.\n\nThis webinar will be hosted on Zoom. Access information will be provided in the confirmation email once registered. \n\nEmail Communication Policy \nBy registering for this event\, you agree to receive email communications from the Federal Bar Association and affiliated sponsors of the program concerning event details\, Continuing Legal Education certification\, programming changes\, upcoming events\, surveys\, and post-event communications. \n\nIf you have any questions regarding this program\, please contact Elizabeth A. Kanyer\, elizabethkanyer@gmail.com
URL:https://www.fedbar.org/event/section-on-taxation-the-role-of-nutrition-for-busy-lawyers-and-everyone/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20210617T120000
DTEND;TZID=America/New_York:20210617T130000
DTSTAMP:20260411T131831
CREATED:20210610T185704Z
LAST-MODIFIED:20210615T180509Z
UID:136864-1623931200-1623934800@www.fedbar.org
SUMMARY:Section on Taxation Round Table: Biden Administration Political Appointments
DESCRIPTION:This roundtable will discuss the Biden Administration’s political appointment process and Senate confirmation process\, and will provide commentary on the Transition. \n[Register Online] \n\nAbout the Presenter\nAndrew Strelka is currently the Senior Tax Counsel in the Biden-Harris White House. \nIn 2008\, Strelka began his legal career at the Internal Revenue Service through the Presidential Management Fellows Program. Strelka was subsequently detailed to the office of the United States Attorney for the District of Columbia in 2009. In 2010\, Strelka joined the United States Department of Justice Tax Division through the Attorney General’s Honors Program. While at the DOJ Tax Division\, Strelka was named national chair of the FBA’s Tax Section and received the Federal Bar Association’s Younger Federal Lawyer Award. In 2013\, Strelka received the Tax Division’s Outstanding Attorney Award and was detailed to the Obama White House. In 2014\, Strelka left the government and eventually joined the tax controversy group at Latham & Watkins. In 2020\, Strelka left the law firm and served as tax counsel to the Biden-Harris Transition. \n\nRegistration & Attendance Information\nRegistration for this event will close Wednesday\, June 16 at 12 PM ET. \n[Register Online] \nGround Rules \n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.\n\nInterested in Speaking? If you are interested in leading a future monthly call\, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com.
URL:https://www.fedbar.org/event/section-on-taxation-round-table-biden-administration-political-appointments/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;VALUE=DATE:20210527
DTEND;VALUE=DATE:20210529
DTSTAMP:20260411T131831
CREATED:20210407T212318Z
LAST-MODIFIED:20210527T152829Z
UID:117301-1622073600-1622246399@www.fedbar.org
SUMMARY:[Virtual] Insurance Tax Seminar
DESCRIPTION:The FBA Section on Taxation offers another virtual seminar on topics of interest to the insurance industry. The seminar will continue its tradition of providing a forum for a robust dialogue between the insurance industry\, tax practitioners and government sector professionals. The program will be held on May 27-28. Participants will have the opportunity to stay up-to-date on the latest tax developments and guidance by choosing from sixteen different panels. Seminar topics have been carefully curated to cover viewpoints on the latest insurance company\, insurance product\, international\, and other relevant and timely insurance tax topics\, such as the evolving tax function and potential for new tax law changes. \nCLE and CPE Credit Available – Scroll for more information. \nRegistration for this event is now closed. \n\nAgenda\nThursday\, May 27\n10:00 – 11:00 a.m. ET | Opening Session + Keynote Remarks \nKeynote Speaker: Peter Phelan\, President\, Phelan Advisory LLC\nPeter Phelan is the President of Phelan Advisory LLC\, an independent firm offering bespoke advisory services to banks\, asset managers\, non-financial corporates\, private equity firms\, and capital markets businesses. Peter was most recently the Deputy Assistant Secretary for Capital Markets at the U.S. Department of the Treasury\, ending his service in January 2021. As part of the Domestic Finance team\, Peter advised the Secretary and other Department senior leadership on the policy implications and effects of all capital markets activities across the nation. \nGeneral Session Sponsored by BKD CPAs & Advisors \n11:30 a.m. – 12:30 p.m. ET | Session 1 \nProspects for Tax Changes in 2021-2022 \nPresident Biden has proposed sweeping infrastructure projects\, offset in part by corporate\, international\, and individual tax increases.  This panel\, featuring Congressional and Treasury staff\, will give tax professionals an insight into the shape of and prospect for changes\, so they can structure future operations taking the new rules into account.  Additionally\, attendees will learn of counter proposals to the Biden tax plan. They will be prepared to modify foreign and domestic structures as necessary to comply with new requirements.  Finally\, attendees will have a unique experience of Q&A with key stakeholders. \n\nModerator: Pamela Olson\, Consultant\, Tax Policy Services\, PwC\nCourtney Connell\, Senior Tax Counsel\, Senate Finance Committee (R)\nAndrew Grossman\, Chief Tax Counsel\, House Ways and Means Committee (D)\nTiffany Smith\, Chief Tax Counsel\, Senate Finance Committee (D)\nDerek Theurer\, Chief Tax Counsel\, House Ways and Means Committee (R)\nTom West\, Deputy Assistant Secretary (Domestic Business Tax)\, U.S. Department of the Treasury\n\n1:00 – 2:00 p.m. ET | Session 2A & 2B \n2A: Life Insurance Tax Issues and Legislative Update \nThe panel will discuss the income tax issues that were most impactful to life insurers during the past year.  Topics will include reinsurance tax planning strategies\, regulatory capital considerations\, and the section 807(f) regulations.  The panel will further discuss potential legislation\, including U.S. Tax Reform\, OECD Pillar 2\, and other significant legislative proposals.  The panel will discuss key planning ideas and considerations related to the proposed legislation.  Finally\, the panel will discuss the IRS’ Tax Cuts and Jobs Act Campaign. \n\nModerator: Matthew T. Jones\, Managing Director\, Business Tax Services\, KPMG LLP\nMichael Beaty\, Partner\, Financial Services\, EY\nJohn E. Glover\, Senior Counsel\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, IRS\nDaniel Kheel\, Vice President\, Tax Planning & Strategy\, MetLife\nMatthew Lodes\, Partner\, PwC\n\n2B: Hot Topics in Multistate Taxation \nThe panel will present and discuss relevant state and local tax areas of interest including the impact of remote workers in today’s work from home environment\, recent legislative policies and developments as well as current topics facing state and local tax departments. \n\nModerator: Brendon McKibbin\, Partner\, Multistate Tax\, Deloitte Tax LLP\nAbbie Foreman\, Senior Manager\, State & Local Tax\, EY\nTov Haueisen\, Partner\, State & Local Tax\, PwC\n Gerardo (Jerry) Malanga\, Corporate Vice President\, New York Life\n\n2:30 – 3:30 p.m. ET | Session 3A & 3B \n3A: Life Reserves Potpourri \nThis panel will focus on recent guidance relevant to the computation of life insurance reserves.  Panelists will discuss the content\, emerging issues\, and application of post-TCJA reserves guidance including the section 807 final regulations and the recent section 807(f) “change in basis” revenue ruling.  The panel also will address practical issues that arise when applying the change in basis rules. The discussion will include an overview of relevant NAIC guidance\, and cover any updates regarding activity on the two active section 807 LB&I campaigns.  Participants will gain an understanding of the post-TCJA life reserves guidance\, and be able to identify and address practical issues that are encountered in applying IRS and NAIC life reserves guidance in tandem. \n\nModerator: Jean Baxley\, Managing Director\, Deloitte Tax LLP\nRichard Bush\, Senior Vice President\, Ameriprise\nKristin Norberg\, Vice President\, Tax\, Symetra\nDaniel P. Phillips\, Senior Counsel\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nMark Smith\, Managing Director\, PwC\nJeff Stabach\, Tax Actuarial Manager\, EY\n\n3B: Capital Planning & Investments \nA discussion of current trends and motivations of new capital providers to the insurance sector and existing insurers.  The insurance industry has seen many new entrants in recent years\, reinsurers have adapted to the needs of the market and new tax regimes and have modified their offerings beyond traditional product offerings.  Insurers have expanded their investment universe.  What is motivating these changes?  How are these changes impacting the market? What is attracting new investors to the insurance sector? What analysis are insurers doing to select between investment opportunities? \n\nModerator: Wesley Reynolds\, Principal\, PwC\nPete Edgerton\, Partner\, Sidley Austin LLP\nKevin Hovi\, President & Chief Financial Officer\, Kuvare Life Re Ltd.\nRitendra Roy\, Managing Director\, Oppenheimer\n\n4:00 – 5:00 p.m. ET | Session 4A & 4B \n4A: P&C Company Tax \nThis panel will discuss an overview of recent income tax issues that impact property and casualty companies\, including the Coronavirus Aid\, Relief\, and Economic Security Act (the CARES Act)\, domestic provisions of Made in America Tax Plan\, regulations for consolidated net operating losses (CNOLs)\, SSAP 101 developments\, IRS Large Business and International (LB&I) Campaigns overview\, and state tax development impacting P&C companies. \n\nModerator: Timothy Peacock\, Partner\, PwC\nRuth Kelly\, Technical Advisor\, IRS LB&I Enterprise Practice Area\nDaniel Kusaila\, Partner\, Crowe LLP\nSarah Pisacich\, Managing Director\, KPMG\n\n4B: The Evolving Tax Function \nPanelists will draw upon their vast and diverse experiences to share insights into the evolving tax function.  The panel will cover a wide range of topics with an emphasis on the future of tax work in a post pandemic world.  Specific areas addressed will include future staffing models;  talent identification\, recruitment\, and retention;  training\, technology\, operating models\, developing and mentoring employees;  and maintaining culture.  The panel will also address the looming shortage of tax professionals and the ever increasing pace and volume of legislative activity.  Attendees will obtain valuable insights which will provide opportunities to optimize their future tax function. \n\nModerator: Scott W. Rynda\, SVP\, Travelers\nChris Albert\, Partner\, Deloitte Tax LLP\nAnne Farrar\, Partner\, Financial Services Tax\, EY\nJim Shea\, SVP & Chief Tax Officer\, Prudential\nJoe Tedesco\, SVP & Global Head of Tax\, AXA XL\n\nFriday\, May 28\n10:00 – 11:00 a.m. ET | Update from the Insurance Branch \nThis panel features a discussion with several representatives of the Insurance Branch of the Financial Institution and Products Division within the IRS Office of Chief Counsel.  The audience will hear Insurance Branch personnel describe recent tax guidance and significant rulings issued by the Branch within the past year as well as current projects being considered by the Branch.  The panel will include a discussion of final regulations issued under IRC section 807 that provide guidance on the computation of life insurance reserves and the change in basis of computing certain reserves of insurance companies.  The panel will increase the professional competence and skills of the audience in the representation of taxpayers on U.S. federal income tax issues.  A primary learning objective is to give attendees an understanding of the role and responsibilities of the Branch as well as an understanding of how to apply the final regulations under IRC section 807. \n\nModerator: Graham R. Green\, Counsel\, Eversheds Sutherland LLP\nRebecca Baxter\, Acting Branch Chief\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nIan Follansbee\, Attorney Advisor\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nBeth Hill\, Attorney Advisor\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nMegan McGuire\, Attorney Advisor\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nDaniel P. Phillips\, Senior Counsel\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nKathryn M. Sneade\, Senior Technician Reviewer\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\n\n11:30 a.m. – 12:30 p.m. ET | Session 5A & 5B \n5A: Product Tax Update \nThis panel will focus on recent product tax developments.  Among other things\, the panelists will cover the CAA changes to section 7702\, including discussion of the technical changes\, as well as the practicalities involved in implementing them.  The session will also focus on changes that the SECURE Act made to the post-death RMD rules applicable to qualified plans and IRAs and delve into interpretative questions that remain to be addressed.  The panelists will also provide commentary on recent court rulings and administrative guidance involving life insurance\, annuities and pension plan contracts; e.g.\, nonqualified annuities issued to trusts\, split-dollar life insurance\, fee-based annuities and investor control. \n\nModerator: Frederic J. (Rick) Gelfond\, Principal\, Tax\, EY\nRobert Fishbein\, Vice President & Corporate Counsel\, Prudential\nBryan Keene\, Partner\, Davis & Harman\nKim Lunn\, Assistant General Counsel & Assistant Secretary\, Northwestern Mutual\nStephen B. Tackney\, Deputy Associate Chief Counsel (EEE)\, IRS\n\n5B: A Discussion of Current Topics Related to BEAT\, PFIC\, and OECD Initiatives \nThis panel will discuss topics related to BEAT\, PFIC\, and OECD tax initiatives\, in particular Pillar Two.  The panel also will discuss current Biden administration and Congressional proposals related to these topics. Presenters will explain the current BEAT rules and the proposals for revising or replacing those rules. The panel will examine the final and proposed PFIC regulations and the comments addressing those regulations. Lastly\, discussion will explore OECD Pillar Two and how it could impact insurance companies. \n\nModerator: M. Kristan Rizzolo\, Partner\, Eversheds Sutherland LLP\nJason Kaplan\, Principal\, Deloitte Tax LLP\nSurjya Mitra\, Managing Director\, PwC\nJoy Tegtmeyer\, SVP\, Head of Group Tax\, Renaissance Re\nAngela J. Walitt\, Attorney-Advisor\, Office of Tax Policy\, U.S. Department of the Treasury\n\n1:00 – 2:00 p.m. ET | Session 6A & 6B \n6A: Information Reporting and Withholding \nThis panel will discuss the dramatic changes being proposed to the withholding regimes for periodic and non-periodic payments\, the open reporting and withholding issues with respect to amounts escheated to state unclaimed property funds\, industry issues concerning the deposit of withheld taxes\, and international issues relating to FATCA\, the EU’s Mandatory Disclosure Regime\, Luxembourg’s new register of actions requirement\, and payments made outside the US. \n\nModerator: Mark E. Griffin\, Partner\, Davis & Harman\nAnthony Calabrese\, Managing Director\, EY\nErin Campbell\, Manager\, Global Information Reporting\, Deloitte Tax LLP\nSarah Lashley\, Assistant General Counsel\, Transamerica\nMat Momen\, Vice President & Associate General Counsel\, Metlife\nStephen B. Tackney\, Deputy Associate Chief Counsel (EEE)\, I.R.S.\n\n6B: Current Outbound Insurance Issues: A Practical Illustration \nThis panel will explore\, in a case study format\, the current\, proposed\, and possible future considerations with respect to outbound insurance issues in the US federal tax context. The panel will focus on the interaction of Subpart F\, GILTI\, related person insurance income\, section 954(i) and foreign tax credits both in today’s environment and under various legislative proposals put forth in the past few months. The panel will also explore considerations around section 953(d) companies and the dual consolidated loss regime. \n\nModerator: Chris Ocasal\, Principal\, EY\nPaul Aronoff\, Vice President & Tax Counsel\, Prudential\nJanet Glendening\, VP – International Tax\, RGA\nJohn Owsley\, EY\nElena Raffensperger\, SVP & Senior Director – International Taxation\, Liberty Mutual\nChris Riffle\, Director\, PwC\nAngela J. Walitt\, Attorney-Advisor\, Office of Tax Policy\, U.S. Department of the Treasury\n\n2:30 – 3:30 p.m. ET | Session 7A & 7B \n7A: Talkin’ ’Bout Consolidation – An Update on Consolidated Return Issues Impacting Insurance Companies \nThe purpose of this panel is to discuss current consolidated return issues affecting both life and nonlife insurance companies.  Panelists will provide an overview of recently completed IRS regulatory projects addressing consolidated return matters\, including the final regulations applying the net operating loss (NOL) provisions\, as amended by the Tax Cuts and Jobs Act and the CARES Act\, to consolidated groups\, with a focus on the special rules applicable to nonlife insurance companies.  The panel also will discuss the latest developments involving the life/nonlife consolidated return regulations and what may be on the horizon for those regulations.  Moreover\, the panelists will provide a brief review of other ongoing consolidated return projects at the IRS that may affect insurance companies in certain instances.  Panelists will share their insights on these topics\, along with practice pointers. \n\nModerator: Lori Jones\, Partner\, Scribner Hall & Thompson LLP\nWill Burhop\, Senior Technician\, Branch 5\, Office of Chief Counsel (CORP)\, I.R.S.\nWilliam Pauls\, Principal\, Deloitte Tax LLP\nFrederick Peurye\, Vice President – Taxation\, Empower\nAnna Rubinstein\, Tax Director\, AIG\n\n7B: Health Company Tax \nThis panel will discuss tax issues that were most impactful in the past year for health insurers.  Topics covered will include significant judicial developments\, regulations under section 162(f) as applied to the health insurance industry\, and developments with respect to risk corridor payments.  The panel also plans to discuss the applicability of section 165(i) to COVID-related losses.  In addition\, the panel will highlight certain health-related compensation and benefits developments\, including any potential legislative proposals involving COBRA and other similar health benefits.  Finally\, panelists will address some state tax proposals and recently enacted state tax laws directly affecting health insurers. \n\nModerator: Lori A. Robbins\, Managing Director\, KPMG LLP\nDaniel P. Bartholet\, Vice President – State Taxes\, UnitedHealth Group\nMark Halpin\, Managing Director\, KPMG LLP\nChad A. Hamann\, Vice President – Tax\, UnitedHealth Group\nJason Stern\, Tax Partner\, Deloitte Tax LLP\nFred von Rueden\, Executive Director\, Plan Tax and Financial Regulatory Services\, Blue Cross Blue Shield Association\n\n4:00 – 5:00 p.m. ET | Session 8A & 8B \n8A: Ethics\, Diversity\, and Inclusion in Tax and the Tax Department \nDiversity and inclusion is increasingly an area of focus in companies\, the legal community\, and the government.  Attendees will be informed about current developments relating to ethics\, diversity\, and inclusion and how they relate to the tax law\, the practice of law\, and business.  In this session\, we will discuss: \n\nWhy diversity and inclusion is an area of significant attention;\nHow diversity and elimination of discrimination is being addressed in legal ethics rules;\nDevelopments and statistics relating to diversity in law\, tax\, and companies;\nWhat workplaces are doing to address diversity and inclusion.\n\nModerator: Amanda Varma\, Partner\, Steptoe & Johnson LLP\nMarcia Persaud\, Associate General Counsel\, New York Life Insurance Company\n\n\n\n8B: Reinsurance Basics Panel \nAn introduction to reinsurance transactions. This presentation will introduce basic definitional concepts\, including the purposes and forms of reinsurance used by P&C and life and annuity companies. We will also discuss the tax requirements of reinsurance\, and the tax consequences of various forms of reinsurance transaction\, including in relation to applicable statutory and financial accounting rules. \n\nModerator: Peter Schuur\, Partner\, Debevoise & Plimpton LLP\nEdward Clabault\, Senior Tax Manager\, EY\nTodd Doyle\, VP & Tax Counsel\, Nassau Re\nRob Finnegan\, PwC\n\n*Subject to Panelist Confirmation \n\nRegistration\nRegistration is now closed for this event.\nAttendees will receive access information via welcome email and panel calendar invitations on Monday\, May 24. \n\nLive Captioning: Closed captioning is available for all virtual webcasts. \n\n\nCancellation Policy: No refunds will be made for cancellations received after the close of business on Friday\, May 21. Please contact Ariel White at awhite@fedbar.org with cancellation and/or substitution requests. \nInternet Requirements: Virtual Conferences require suitable internet strength to stream online panels. A minimum internet connection of 800 Kbps is recommended for an optimal attendee experience. Test your connection here.  \n\nCLE / CPE Updates\nCLE CREDIT \nAttendees can receive up to 9 CLE credits (10.8 credits for 50-min states). \nCLE Credit will be processed/reported approximately 4-6 weeks after the event date and available for credit in states that allow credit for live webinar presentations. You must attend the live broadcast\, answer engagement polls\, and accurately enter your bar number in our database to receive credit. Certificates and required documentation for self-reporting states will be issued via email\, upon state bar approval. Thank you in advance for your patience\, as state bars are experiencing significant delays with virtual program processing. \nClick Here for more information on CLE Attendance and Reporting. \nCPE SPONSOR \nThe Federal Bar Association is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors maybe submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org. For more information regarding administrative policies such as refunds\, cancellations and complaints\, please contact the Federal Bar Association at 571-481-9100. Prerequisite: None; Program Level: Basic; Advanced Prep: None;\nField of Study: Taxes; Delivery Method: Group Live delivered online due to COVID-19; Credit Hours: 10.8. \nTo qualify for CPE Credit\, attendees must attend the panel’s live broadcast\, answer all pop-up engagement polls\, and accurately enter his/her information into each panel’s entry form. Certificates will be issued approximately 4-6 weeks after the event date. \n\n\n\nSponsors\nPREMIER SPONSOR \n \nEVENT PARTNER \nBKD CPA’s & Advisors \nEmail sponsor@fedbar.org if you’re interested in sponsoring this event. View our Virtual Sponsorship Prospectus for current offerings. \n\nFrequently Asked Questions\nQ: What type of educational credit will be offered in the virtual format?\nA: Attendees can receive up to 8 CLE credits (9.6 credits for 50-min states). Please check with your respective state(s) for distance learning CLE requirements. CPE Credit has been approved for this event. \nQ: How do I obtain CLE Credit?\nA: All registrants will be prompted to submit state bar information prior to the virtual series to ensure accurate CLE reporting. Credits will be processed/reported within 4-6 weeks of the webinar event date and available for credit in states that allow credit for live webinar presentations. Your bar number must be accurate in our database to receive credit. We will share detailed instructions with registrants for CLE reporting. \nQ: How do I access the virtual panels?\nA: Virtual panels will each have a unique link to watch the live broadcast. Registered attendees will receive login instructions via a welcome email and calendar invitations the week of the conference. \nQ: Will recordings of the sessions be available after the event?\nA: Sessions will be available for registrants to view live and on-demand following the conference. Please note that CLE credit will only be submitted for attendees that watch the live broadcast. \nQ: Who do I contact for more information?\nA: Please contact meetings@fedbar.org for any other questions. \n\nEmail Communication Policy\nBy registering for this event\, you agree to receive email communications from the Federal Bar Association and affiliated sponsors of the program concerning event details\, Continuing Legal Education certification\, programming changes\, upcoming events\, surveys\, and post-event communications. \nRecording Disclaimer\nBy registering for an online FBA program\, you agree to the recording of audio and visual content presented during the live event and consent to subsequent use of the recording by the FBA. You agree that the recording is the sole property of the FBA and that the recording may be used by the FBA in any manner in its sole and absolute discretion. This recording may include questions and poll responses provided by you during the live event. If you do not consent to the recording and the FBA’s use of the same\, do not register for the event. \nFinancial Assistance\nProgram registrants (both FBA members and nonmembers) who are unable to afford the registration fee may receive a 50% discount on the member rate. Qualifying attorneys include those who are unemployed or actively seeking employment. A formal letter requesting the discount must be emailed to meetings@fedbar.org. That letter needs to state the reason for the attorney’s interest in the course or activity\, as well as proof of income or an explanation of the financial hardship\, and it must be signed by the requesting lawyer.
URL:https://www.fedbar.org/event/instax21/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
ATTACH;FMTTYPE=image/jpeg:https://www.fedbar.org/wp-content/uploads/2021/04/iStock_49625586_XLARGE-scaled.jpg
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20210520T120000
DTEND;TZID=America/New_York:20210520T130000
DTSTAMP:20260411T131831
CREATED:20210430T175005Z
LAST-MODIFIED:20210503T143803Z
UID:125124-1621512000-1621515600@www.fedbar.org
SUMMARY:Section on Taxation Round Table: Update on IRS High Net Worth Audit Campaign and Other Initiatives
DESCRIPTION:This roundtable will discuss recent and ongoing IRS tax enforcement measures targeted towards high net worth individuals\, including the Global High-Wealth Audits campaign.  Attendees will hear about where the IRS is focusing its resources\, coordination between civil and criminal investigations\, potential effects of the Biden Administration’s push to make high net worth individuals pay their fair share of taxes\, and future compliance targets by revenue agents. \n[Registration Online] \n\nAbout the Presenters\n \nEdward L. Froelich\, Of Counsel\, Morrison & Foerster LLP \nEdward Froelich represents clients in audit and litigation and is the lead of the firm’s Federal tax controversy group. He is a former trial attorney of the Department of Justice Tax Division where he litigated numerous cases\, including complex corporate refund cases. In private practice he continues to litigate cases and represents clients in administrative controversies at both the audit and appeals level before the IRS. His experience has been crucial to securing favorable resolutions of matters with the IRS Appeals Office and in the field. Ed represents domestic and foreign public companies\, privately-held companies\, partnerships\, trusts\, and individuals. Many of his clients are in the financial\, technology\, and real estate industries. He has successfully dealt with a variety of issues including international tax\, transfer pricing\, income tax accounting\, employment tax\, accounting method and penalty issues. Ed also regularly advises on privilege and work product questions and on various procedural issues including the obligation to file information returns such as those relating to many of the Form 1099 series\, FATCA and employment taxes. \nJennifer M. O’Brien\, Counsel\, Fox Rothschild LLP \nJennifer is an experienced advisor who routinely advises and represents financial institutions and high-net-worth individuals on complex international and federal tax matters. Her practice covers all facets of the tax dispute resolution process\, including IRS examinations and appeals\, litigation of civil and criminal tax matters\, and governmental investigations. With corporate and individual clients spanning five continents\, Jennifer has extensive experience managing U.S. compliance and enforcement issues arising from international and offshore circumstances as well as undeclared virtual currency. Having practiced in Switzerland for nearly five years\, Jennifer brings a unique perspective to her clients’ dealings with U.S. and foreign tax authorities. She also counsels clients on relinquishment of U.S. citizenship and abandonment of lawful permanent resident status. \n\nRegistration & Attendance Information\n[Registration Online] \nCall In Information \nJoin on your computer or mobile app \nClick here to join the meeting \nOr call in (audio only) \n+1 571-616-0550 \nPhone Conference ID: 153 328 787# \nGround Rules \n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.\n\nInterested in Speaking? If you are interested in leading a future monthly call\, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com.
URL:https://www.fedbar.org/event/section-on-taxation-round-table-update-on-irs-high-net-worth-audit-campaign-and-other-initiatives/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20210408T130000
DTEND;TZID=America/New_York:20210408T140000
DTSTAMP:20260411T131831
CREATED:20210308T154350Z
LAST-MODIFIED:20210323T190216Z
UID:108578-1617886800-1617890400@www.fedbar.org
SUMMARY:Section on Taxation: IRS Criminal and Civil Enforcement of Cryptocurrency
DESCRIPTION:Thursday\, April 8 | 10 AM  PT / 1 PM ET* \nCryptocurrency is a hot-button issue for IRS enforcement. Cryptocurrency presents practitioners with accounting and reporting challenges. Further\, a tool for illicit conduct\, cryptocurrency presents potential criminal concerns for every client. This presentation outlines civil and criminal investigation triggers and issues related to cryptocurrency \n\nAbout the Speakers\nAlexander H. Kugelman is a tax and cryptocurrency attorney and founder of San Francisco-based Kugelman Law\, a firm concentrating on cryptocurrency\, tax controversies\, domestic and international tax compliance\, and tax collection defense. Mr. Kugelman counsels and represents individuals\, small businesses\, and estates. \nHis experience includes four years of federal government court experience at the U.S. Tax Court and as a Judicial Law Clerk at the U.S. District Court of Eastern Michigan. That background blends substantive tax law knowledge with administrative and litigation experience. \nAlexander’s expertise in the growing niche area of cryptocurrency has enabled him and his firm to become industry leaders in accounting\, reporting\, and audit representation for cryptocurrency matters. \n  \nChristopher Wajda is the managing director at the Black Raven Advisory Group LLC\, a private investigative firm that specializes in complex forensic financial investigations and/or reconstruction in criminal and civil cases. \nIn August of 2019 Christopher Wajda retired from the Internal Revenue Service – Criminal Investigation as an Assistant Special Agent in Charge (ASAC) of the Washington D.C. Field office. As the ASAC he led and guided some of the most significant white-collar criminal investigations in the nation that today are still making headlines. \nHe has over 32 years of experience in complex criminal and civil financial investigations. He has developed a deep understanding and knowledge to efficiently investigate and lead complex criminal financial investigations and assist in related judicial proceedings. This expertise extends to criminal and civil white collar criminal defenses when individual and/or entities are accused of financial wrongdoings. \n\nRegistration\nRegister Online \nDeadline to register will be April 7\, 2021 at 2 PM ET.  \n\nFBA Members – $0\nNonmembers – $75\n\nThis webinar will be hosted on Zoom. Access information will be provided in the confirmation email once registered. \n\nEmail Communication Policy \nBy registering for this event\, you agree to receive email communications from the Federal Bar Association and affiliated sponsors of the program concerning event details\, Continuing Legal Education certification\, programming changes\, upcoming events\, surveys\, and post-event communications. \n\nIf you have any questions regarding this program\, please contact Alex Kugelman\, alex@kugelmanlaw.com. 
URL:https://www.fedbar.org/event/section-on-taxation-irs-criminal-and-civil-enforcement-of-cryptocurrency/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;VALUE=DATE:20210303
DTEND;VALUE=DATE:20210306
DTSTAMP:20260411T131831
CREATED:20201119T225346Z
LAST-MODIFIED:20210610T162810Z
UID:82265-1614729600-1614988799@www.fedbar.org
SUMMARY:[Virtual] Tax Law Conference
DESCRIPTION:Join the Section on Taxation for the 45th Annual Tax Law Conference on March 3-5\, 2021. This newly formatted three-day virtual program will offer the same great content online. Examine important tax developments and emerging policy issues in over 30 educational sessions featuring notable speakers from the Internal Revenue Service\, Treasury Department\, Department of Justice\, White House\, and Congress. Programming will include a keynote address and awards presentations for both the Annual Writing Competition and prestigious Kenneth H. Liles Award for Distinguished Service to an eminent tax practitioner. \nRegistration for this event has now closed.  \n\nAgenda\nAll Times Noted in Eastern Standard Time (EST) \nWednesday\, March 3\n11:00 a.m. – 12:30 p.m. | Opening Session \n\nWelcome Remarks by Section and Conference Chairs\nKeynote Introduction: Charles “Chuck” Rettig\, Commissioner\, IRS\nDay in the Life: Internal Revenue Service Executives Roundtable Discussion\nPresentation of the 2021 Donald C. Alexander Tax Law Writing Competition\nHonoring Floyd Williams\, former IRS Director of Legislative Affairs\n\n1:00 – 2:00 p.m. | Floyd’s Panel: Legislative Update\nSenior staff from the House Committee on Ways and Means\, the Senate Committee on Finance and the Joint Committee on Taxation will provide their perspectives on the tax legislative outlook for 2021 and upcoming policy priorities. \n2:30 – 3:30 p.m. | Concurrent Symposia Programming \n\n[Employee Benefits & Executive Compensation] Hot Topics in Executive Compensation\n[Hot Topics] Recent Developments in Conservation Easements\n[Young Tax Lawyers] Deficiencies\, Determinations\, Assessments\, and More:  What Does It All Mean?\n\n4:00 – 5:00 p.m. | Concurrent Symposia Programming \n\n[Employee Benefits & Executive Compensation] Hot Topics in Employee Benefits\n[Hot Topics] Hot Topics in Tax Controversy: TCJA to TFA to CARES and Beyond\n[Young Tax Lawyers] The TCJA 3 Years Later:  Where Do We Stand Now?\n\n5:30 -6:30 p.m. | Virtual Young Tax Lawyer Happy Hour (Zoom Platform) \nThursday\, March 4\n10:00 – 11:00 a.m. | Ethics: Lawyers as Gatekeepers \n11:30 a.m. – 12:30 p.m. | Concurrent Symposia Programming \n\n[Domestic Corporate Tax] Section 163(j) Update\n[Pro Bono] Representing the “Disabled” Taxpayer\n[Tax Practice and Procedure] Alternative Dispute Resolution: Speaking to the Mediators\n\n1:00 – 2:00 p.m. | Concurrent Symposia Programming \n\n[Domestic Corporate Tax] Section 168(k) Update\n[Pro Bono] Representing the Undocumented Worker\n[Tax Practice and Procedure] Keep it Between Us: Recent Developments in Attorney/Client and Tax Practitioner Privileges and Work Product Protections in Tax Cases\n\n2:30 – 3:30 p.m. | Concurrent Symposia Programming \n\n[Domestic Corporate Tax] Section 245A Update\n[Partnerships & Passthroughs] Holding (“Dry”) Partnerships\n[Tax Practice and Procedure] BBA Centralized Partnership Audit Regime:  Recent Developments and Hot Topics\n\n4:00 – 5:00 p.m. | Concurrent Symposia Programming \n\n[Domestic Corporate Tax] Recent Developments Governing Net Operating Loss Utilization\n[Partnerships & Passthroughs] Rev. Rul. 99-6 (Symmetrical vs Asymmetrical Approach) and S Corporation Update\n[Tax Practice and Procedure] Virtual Proceedings in the Digital Age (Part One): Tax Court Litigation\n\n5:30 -6:30 p.m. | Virtual Reception and Presentation of the 2021 Kenneth H. Liles Award (Zoom Platform)\nRecipient: Thomas J. Kane\, Director\, KPMG LLP \nFriday\, March 5\n10:00 – 11:00 a.m. | Current Ethical Issues \n11:30 a.m. – 12:30 p.m. | Concurrent Symposia Programming \n\n[Enforcement and Criminal Tax] Fraud Enforcement Office\n[Hot Topics] Virtual Proceedings in the Digital Age (Part 2): Litigation in District and Appellate Courts\n[International Tax] Transfer Pricing: Looking Beyond the Pandemic and Other Current Developments\n\n1:00 – 2:00 p.m. | Concurrent Symposia Programming \n\n[Enforcement and Criminal Tax] Cannabis is Going National – Opportunities and Pitfalls\n[International Tax] International Tax Developments (Outbound)\n[Tax Accounting] An Overview of the Section 451 Final Regulations Package\n\n2:30 – 3:30 p.m. | Concurrent Symposia Programming \n\n[Enforcement and Criminal Tax] IRS CI – Here and Abroad\n[International Tax] International Tax Policy – New Administration\, New Direction?\n[Tax Accounting] An Update on Section 162(f)/6050X Guidance\n\n4:00 – 5:00 p.m. | Concurrent Symposia Programming \n\n[Enforcement and Criminal Tax] Force Multipliers: The Increased Use of Data Analytics to Identify Subjects of Civil and Criminal Enforcement Actions\n[International Tax] International Tax Developments (Inbound)\n[Tax Accounting] An Overview of the Small Business Taxpayer Accounting Methods Regulations\n\n5:30 -6:30 p.m. | Virtual Section on Taxation Happy Hour (Zoom Platform) \n\nRegistration\nRegistration for this event has now closed.  \n\n\n\n\n\n\n\n\nLive Captioning\nShould you request live captioning or another accommodation in order to participate in this webinar\, please contact meetings@fedbar.org at least 10 days before the event so we may make the necessary arrangements. \n\n\nCancellation Policy\nNo substitutions or refunds will be made for cancellations received after the close of business on Friday\, February 26. Please contact Ariel White at awhite@fedbar.org with requests. \n\n\n\n\n\n\n\n\n\n  \nSponsorship\nThought Leader\n                    \n           \nEvent Partner\nBaker & McKenzie LLP\nCovington & Burling LLP\nKPMG LLP \nGeneral Session Sponsors\nMorrison & Foerster LLP\nSkadden\, Arps\, Slate\, Meagher & Flom LLP \nLegacy Sponsor\nBDO USA LLP \nExhibit Session Sponsor\nBrownstein Hyatt Farber Schreck\, LLP \nContact Melissa Badami (sponsor@fedbar.org) if you’re interested in sponsoring this event.\nView our Virtual Sponsorship Prospectus for current offerings. \n\nFrequently Asked Questions\nQ: How do I access the virtual panels?\nA: Virtual panels will each have a unique link to watch the live broadcast. Registered attendees will receive login instructions via a welcome email and calendar invitations the week of the conference. \nQ: Will recordings of the sessions be available after the event?\nA: Sessions will be available for registrants to view live and on-demand following the conference. Please note that credit will only be submitted for attendees that watch the live broadcast. \nQ: Who do I contact for more information?\nA: Please contact meetings@fedbar.org for any other questions. \n\nEmail Communication Policy\nBy registering for this event\, you agree to receive email communications from the Federal Bar Association and affiliated sponsors of the program concerning event details\, Continuing Legal Education certification\, programming changes\, upcoming events\, surveys\, and post-event communications. \nRecording Disclaimer\nBy registering for an online FBA program\, you agree to the recording of audio and visual content presented during the live event and consent to subsequent use of the recording by the FBA. You agree that the recording is the sole property of the FBA and that the recording may be used by the FBA in any manner in its sole and absolute discretion. This recording may include questions and poll responses provided by you during the live event. If you do not consent to the recording and the FBA’s use of the same\, do not register for the event. \nFinancial Assistance\nProgram registrants (both FBA members and nonmembers) who are unable to afford the registration fee may receive a 50% discount on the member rate. Qualifying attorneys include those who are unemployed or actively seeking employment. A formal letter requesting the discount must be emailed to meetings@fedbar.org. That letter needs to state the reason for the attorney’s interest in the course or activity\, as well as proof of income or an explanation of the financial hardship\, and it must be signed by the requesting lawyer.
URL:https://www.fedbar.org/event/taxlaw21/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
ATTACH;FMTTYPE=image/jpeg:https://www.fedbar.org/wp-content/uploads/2020/11/Tax20-Image.jpg
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20210218T120000
DTEND;TZID=America/New_York:20210218T130000
DTSTAMP:20260411T131831
CREATED:20210212T154750Z
LAST-MODIFIED:20210212T155210Z
UID:102899-1613649600-1613653200@www.fedbar.org
SUMMARY:Tax Practice and Procedure Roundtable: Update on IRS Administrative and Litigation Collection Efforts
DESCRIPTION:This roundtable will discuss recent and ongoing common tax collection matters\, including collection alternatives under IR-2020-248 and changes to collection procedures under the People First Initiative\, including passport revocation certifications. The panel will also discuss unique challenges that occur with respect to international information return reporting and winding down business enterprises. \nSpeakers\nJohn Pontius\, Founder\, Pontius Tax Law\, PLLC\nMr. Pontius regularly represents individual and business clients with sensitive and serious tax matters before the Internal Revenue Service and state taxing authorities. His client base is local\, national and international. Over the course of his career\, Mr. Pontius has represented businesses and individuals with complex tax issues in the following areas: FBAR examinations\, offshore disclosures\, FATCA\, tax planning\, unfiled tax returns\, release of tax liens and levies\, trust fund recovery penalty\, IRS and state audit examinations as well as Appeals\, penalty abatement\, US Tax Court litigation along with defense of tax fraud and evasion. \nPhilip Colasanto\, Associate\, Agostino & Associates P.C.\nMr. Colasanto is a tax controversy and litigation lawyer who concentrates on civil and criminal tax controversies. Mr. Colasanto represents both individuals and businesses\, domestically and internationally\, before the United States Tax Court\, United States District Court\, and United States Courts of Appeal. \nBeverly Winstead\, Founder and Managing Member\, The Law Office of Beverly Winstead\nBeverly L. Winstead is the founder and manager of the tax law firm Law Office of Beverly Winstead\, LLC\, specializing in tax resolution\, estate planning and sports and entertainment law. In 2018\, she was honored as one of the National Bar Association’s Top “40 Under 40” lawyers in the country. That same year\, she made history as the first Black woman chair of the Maryland State Bar Association’s Tax Section. \n\nCall In Information \nJoin on your computer or mobile app \nClick here to join the meeting \nOr call in (audio only) \n+1 571-616-0550 \nPhone Conference ID: 153 328 787# \nGround Rules \n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.\n\n  \nInterested in Speaking? If you are interested in leading a future monthly call\, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com.
URL:https://www.fedbar.org/event/tax-practice-and-procedure-roundtable-update-on-irs-administrative-and-litigation-collection-efforts/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20210211T170000
DTEND;TZID=America/New_York:20210211T180000
DTSTAMP:20260411T131831
CREATED:20210210T155052Z
LAST-MODIFIED:20210210T155234Z
UID:102399-1613062800-1613066400@www.fedbar.org
SUMMARY:Section on Taxation Presents: Choose Your Own Adventure – Careers in Tax Law
DESCRIPTION:Young Tax Lawyers Series:\nChoose Your Own Adventure – Careers in Tax Law\nAhead of TIP\, join the FBA Section on Taxation on February 11th at 5 pm to hear from a panel of attorneys with experience working at law firms\, accounting firms\, the IRS and the US Tax Court.  The panelists will discuss what a typical day is like for them\, offer insights into the paths that lead to their jobs and provide tips for interviewing virtually.  The panel will be followed by a virtual happy hour where attendees will have the opportunity to network with panelists and other young tax attorneys.  The meeting link and access information is below: \nJoin Zoom Meeting \nhttps://us02web.zoom.us/j/88641264448?pwd=dlhKRnc2VFFENVVkL2R3TTlBRDl5UT09 \nMeeting ID: 886 4126 4448 \nPasscode: 021121 \nOne tap mobile \n+19292056099\,\,88641264448#\,\,\,\,*021121# US (New York) \n+13017158592\,\,88641264448#\,\,\,\,*021121# US (Washington DC) \nDial by your location \n+1 929 205 6099 US (New York) \n+1 301 715 8592 US (Washington DC) \n+1 312 626 6799 US (Chicago) \n+1 669 900 6833 US (San Jose) \n+1 253 215 8782 US (Tacoma) \n+1 346 248 7799 US (Houston) \nMeeting ID: 886 4126 4448 \nPasscode: 021121 \nFind your local number: https://us02web.zoom.us/u/kdH4IEI5un
URL:https://www.fedbar.org/event/section-on-taxation-presents-choose-your-own-adventure-careers-in-tax-law/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20210121T120000
DTEND;TZID=America/New_York:20210121T130000
DTSTAMP:20260411T131831
CREATED:20210112T144915Z
LAST-MODIFIED:20210120T214633Z
UID:95081-1611230400-1611234000@www.fedbar.org
SUMMARY:Tax Law Section: Practice & Procedure Roundtable - Update on Criminal Tax Enforcement Matters
DESCRIPTION:This roundtable will discuss the current state of various criminal tax matters and provide an update on recent developments with respect to IRS enforcement priorities.  The panelists will also give a brief overview of the structure and workings of the IRS’s Criminal Investigation division. \nRegistration for this event is now closed. \n\nAbout the Speakers\nDon Fort\, Director of Investigations\, Kostelanetz & Fink\, LLP \nJohn D. (Don) Fort is the Director of Investigations at Kostelanetz & Fink\, LLP\, and the immediate past Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division. Having spent nearly 30 years in law enforcement for the federal government\, Mr. Fort has deep expertise in financial crimes\, and has developed an extensive network of connections both within the government and in private industry. \nGuinevere Moore\, Managing Member\, Moore Tax Law Group LLC \nGuinevere Marie Moore is a tax litigator who represents taxpayers in civil and criminal tax controversies.  She is a Founding Partner of Johnson | Moore and advocates for taxpayers at the IRS examination and appeals levels and\, if a settlement with the IRS cannot be reached\, in litigation. She is also the Executive Director of US Partnership Representative\, Inc.\, and in that role she serves as a professional partnership representative. \nJay Weill\, Partner\, Sideman & Bancroft LLP \nJay Weill concentrates his practice on civil and criminal tax controversy matters\, white collar defense and complex commercial litigation. Mr. Weill was a trial attorney with the Tax Division of the U.S. Department of Justice from 1970 – 1975. In 1978 he became an Assistant U.S. Attorney in the Tax Division of the U.S. Attorney’s Office in San Francisco. In 1982\, he was appointed by the U.S. Attorney to be Chief of the Division\, where he remained as Chief for 25 years. \n\nRegistration\nRegistration for this event is now closed. \n\nTax Law Section Member – Complimentary \nFBA Member – $25\nNonmember – Join the FBA to access this roundtable discussion!\n\n\nGround Rules for Roundtable Meeting: \n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nThis particular Roundtable should be limited to practitioners that focus their practice on plaintiff issues to foster open communication between participants and speakers.\n\n\nIf you have any questions regarding this program\, please contact sections@fedbar.org 
URL:https://www.fedbar.org/event/tax-law-section-practice-procedure-roundtable-update-on-criminal-tax-enforcement-matters/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20201217T120000
DTEND;TZID=America/New_York:20201217T130000
DTSTAMP:20260411T131831
CREATED:20201210T212307Z
LAST-MODIFIED:20201214T232701Z
UID:87413-1608206400-1608210000@www.fedbar.org
SUMMARY:Section on Taxation: Developments in FBAR Litigation and Enforcement
DESCRIPTION:This roundtable will discuss recent developments in FBAR Litigation and Enforcement. Topics will include the current state of the willfulness standard pursuant to recent cases\, the current state of multiple non-willful penalties per year\, and the Bernstein Fifth Amendment FBAR litigation. \n\nAbout the Speakers\nThomas Cole\, Trial Attorney\, Department of Justice Tax Division \nMr. Cole has been a civil trial attorney with the Department of Justice\, Tax Division since 1998 and the Division’s Civil FBAR Coordinator since 2017. In addition to coordinating the Division’s FBAR civil litigation program\, he has served as a trial attorney on many FBAR cases. \nZhanna A. Ziering\, Member\, Caplin & Drysdale \nMs. Ziering is a Member in Caplin & Drysdale’s New York office. She offers guidance to individual and corporate clients who require sophisticated tax advice concerning their domestic tax issues\, offshore assets\, and U.S. reporting requirements. \n\nGround Rules\n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.\n\n\nInterested in Speaking?\nIf you are interested in leading a future monthly call\, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com \n\nIf you have any questions regarding this program\, please contact sections@fedbar.org 
URL:https://www.fedbar.org/event/section-on-taxation-developments-in-fbar-litigation-and-enforcement/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20201119T120000
DTEND;TZID=America/New_York:20201119T130000
DTSTAMP:20260411T131831
CREATED:20201112T172558Z
LAST-MODIFIED:20201112T180110Z
UID:80487-1605787200-1605790800@www.fedbar.org
SUMMARY:Section on Taxation: Views on LB&I’s Proposal to Obsolete Revenue Procedure 94-69
DESCRIPTION:This roundtable will discuss the status of Revenue Procedure 94-69. In August\, the LB&I announced that it is considering rescinding Rev. Proc. 94-69. Rev. Proc. 94-69 provides special procedures for taxpayers that are subject to the former Coordinated Examination Program to show additional tax due or make disclosures to avoid the imposition of accuracy-related penalties for negligence\, disregard of rules or regulations\, or substantial understatement of income tax under IRC section 6662(b)(1) and (b)(2). Those who support retaining Rev. Proc. 94-69 argue that it ensures that taxpayers with large and complex returns are able to efficiently report and fix errors\, which encourages compliance. Critics have noted that Rev. Proc. 94-69 creates disparity among LB&I taxpayers and fails to support the broader tax administration effort to improve the accuracy and reliability of returns at the time of filing. The panel will discuss their views on how this proposed change would affect taxpayers and comments that were submitted to the IRS. \n\nAbout the Speakers\nLee Meyercord focuses her practice on federal\, state\, and local taxation of corporations\, partnerships\, individuals\, and nonprofit organizations. She provides clients with tax planning advice on mergers and acquisitions\, the operation and dispositions of partnerships and limited liability companies\, and private equity transactions\, and represents taxpayers in IRS audits\, appeals\, and federal income tax litigation. Lee also counsels clients on the organization\, operation\, and termination of nonprofit corporations and trusts\, and obtaining and maintaining exemptions for these organizations from federal income\, state franchise\, sales and use\, and local ad valorem taxes. \n  \nKevin Stults concentrates his practice on federal tax controversy and litigation. He represents large financial institutions\, multinational corporations and individuals at various stages of federal income tax controversies\, including audits\, administrative appeals and judicial proceedings. Mr. Stults’ substantive experience encompasses a variety of complex tax issues\, including foreign tax credits\, economic substance/business purpose\, corporate restructurings\, life insurance\, various partnership issues\, IRS promoter examinations\, pre-filing agreements\, and the TEFRA partnership audit and litigation procedures. \n  \n\nGround Rules\n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.\n\n\nInterested in Speaking?\nIf you are interested in leading a future monthly call\, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com \n\nIf you have any questions regarding this program\, please contact sections@fedbar.org
URL:https://www.fedbar.org/event/section-on-taxation-views-on-lbis-proposal-to-obsolete-revenue-procedure-94-69/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20201015T120000
DTEND;TZID=America/New_York:20201015T130000
DTSTAMP:20260411T131831
CREATED:20201002T210013Z
LAST-MODIFIED:20201002T210142Z
UID:71900-1602763200-1602766800@www.fedbar.org
SUMMARY:Section on Taxation: Tax Practice and Procedure Roundtable: What’s Really Stopping Taxpayers?  A Discussion of CIC Services and the Anti-Injunction Act
DESCRIPTION:This roundtable will discuss the current status of the CIC Services case\, the arguments that each side and amici presented\, and thoughts on the Supreme Court’s upcoming ruling. The discussion will also provide helpful background on the Anti-Injunction Act\, historical developments with respect to the Anti-Injunction Act\, and will provide strategic considerations for practitioners wishing to overcome an Anti-Injunction Act defense made by the government. \n\nAbout the Speakers\nJoseph (Jud) B. Judkins\, partner at Baker & McKenzie LLP\, centers his practice on federal tax controversy matters at every phase of a dispute\, including audit\, IRS Appeals\, and litigation. The application of administrative law principles to Treasury regulations and IRS guidance is a core component of his practice. Jud advises clients on a broad spectrum of international and domestic tax matters\, including challenges to the validity of regulations\, participation in the agency rulemaking process through the submission of comments and testimony at public hearings\, the scope and application of TCJA regulations\, transfer pricing disputes\, tax statutory and regulatory interpretation\, and other domestic and international tax issues. Prior to joining Baker & McKenzie\, Jud was a law clerk at the United States Tax Court and a member of the US Navy JAG Corps. Jud received his LL.M. from Georgetown University Law Center and his J.D. from Wake Forest University. \n  \nDavid W. Foster\, partner at Skadden Arps LLP\, focuses his practice on federal tax controversy matters. David represents a broad range of clients\, including large corporations\, private equity firms and hedge funds\, estates\, exempt organizations and individuals\, many of whom are subject to the IRS’ global high wealth initiative. His practice covers a diverse range of tax issues\, including international tax\, taxation of financial products\, estate and gift taxes\, proposed exempt status revocations\, voluntary disclosures and criminal tax. David received his J.D. from Harvard Law School and his A.B. from Harvard University. \n  \n\nGround Rules\n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.\n\n\nInterested in Speaking?\nIf you are interested in leading a future monthly call\, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com \n\nIf you have any questions regarding this program\, please contact Laura Mulhern\, Sections and Divisions Manager.
URL:https://www.fedbar.org/event/section-on-taxation-tax-practice-and-procedure-roundtable-whats-really-stopping-taxpayers-a-discussion-of-cic-services-and-the-anti-injunction-act/
LOCATION:DC
CATEGORIES:Section on Taxation
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20200917T120000
DTEND;TZID=America/New_York:20200917T130000
DTSTAMP:20260411T131831
CREATED:20200904T180625Z
LAST-MODIFIED:20200904T182140Z
UID:65889-1600344000-1600347600@www.fedbar.org
SUMMARY:Section on Taxation: Tax Practice and Procedure Roundtable: Tax Legislative Update -  Employer Tax Credits Under the CARES and HEALS Acts; 2020 Presidential Election Considerations
DESCRIPTION:This roundtable will address refundable payroll tax credits made available to employers by CARES and HEALS.  The focus will be on the Employee Retention Tax Credit and the Safe and Healthy Workplace Tax Credit.   The panel will also offer a more general legislative outlook\, particularly in light of the upcoming election\, which will highlight candidates’ policy proposals and discuss potential impacts on existing tax policy. \n\nAbout the Speakers\nAndre J. Barnett is Tax Counsel for the Senate Finance Committee where he is responsible for corporate and international tax matters. Before joining the Senate Finance Committee\, Andre was part of the transaction tax team at Ernst & Young\, LLP where he focused on the tax aspects of corporate transactions\, including U.S. and cross-border mergers and acquisitions\, spin-offs\, bankruptcy and corporate restructuring. Andre received his LL.M from Georgetown University Law Center\, his J.D. from the University of the District of Columbia David A. Clarke School of Law and his B.A. from the University of North Carolina at Charlotte. \nLoren Ponds\, member of Miller & Chevalier\, centers her practice on providing strategic counsel to clients on legislative\, regulatory\, and other tax policy issues\, as well as advising on technical tax matters related to transfer pricing and other international tax topics.  She advises clients on the impacts of tax policy\, such as the implementation of the Tax Cuts and Jobs Act of 2017 (TCJA)\, and issues related to technical corrections\, administrative guidance\, and legislative amendments to various provisions. Prior to joining Miller & Chevalier\, Loren served as Majority Tax Counsel to the U.S. House of Representatives Committee on Ways and Means\, where she developed\, analyzed\, and refined the international tax provisions of the TCJA. Loren received her LL.M. from Georgetown University Law Center and her J.D. from American University Washington College of Law. \nMonisha Santamaria is a Legislation Counsel at the Joint Committee of Taxation\, assisting congressional tax-writing committees and members of Congress with the development and analysis of legislative proposals.  Her primary focus is on domestic businesses.  Previously\, Monisha was a senior manager in Ernst & Young LLP’s National Tax Department\, advising clients on a wide range of U.S. federal income tax issues impacting domestic and foreign partnerships; a tax associate at Skadden\, Arps\, Slate\, Meagher & Flom LLP\, primarily counseling multinational corporations on the U.S. federal income tax aspects of joint ventures\, mergers\, acquisitions\, and divestitures; and a tax planning associate at Bingham McCutchen LLP\, chiefly serving Fortune 50\, financial sector\, and energy industry clients. Monisha holds a J.D. from Stanford Law School. \n\nGround Rules\n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.\n\n\nInterested in Speaking?\nIf you are interested in leading a future monthly call\, please contact cfederico@crowell.com or brandon.king@bakermckenzie.com \n\nIf you have any questions regarding this program\, please contact Laura Mulhern\, Sections and Divisions Manager.
URL:https://www.fedbar.org/event/section-on-taxation-tax-practice-and-procedure-roundtable-tax-legislative-update-employer-tax-credits-under-the-cares-and-heals-acts-2020-presidential-election-considerations/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20200827T120000
DTEND;TZID=America/New_York:20200827T130000
DTSTAMP:20260411T131831
CREATED:20200812T192308Z
LAST-MODIFIED:20200814T151432Z
UID:61199-1598529600-1598533200@www.fedbar.org
SUMMARY:Section on Taxation - Diversity & Inclusion Committee: [VIRTUAL] Inclusify: Maximizing Uniqueness and Belonging to Build More Innovative Teams with  Dr. Stefanie K. Johnson
DESCRIPTION:The FBA Section on Taxation Diversity & Inclusion Committee\ninvite you to virtually attend \nInclusify: Maximizing Uniqueness and Belonging to Build More Innovative Teams\nwith Dr. Stefanie K. Johnson\, Author of WSJ Bestseller\, Inclusify\nDr. Stefanie K. Johnson is an author\, professor\, and keynote speaker who studies the intersection of leadership and diversity\, focusing on how unconscious bias affects the evaluation of leaders and strategies that leaders can use to mitigate bias. She has extensive consulting experience and has created and delivered leadership development training with an emphasis on evidence-based practice. Her research and experience was the basis for her first book Inclusify: The Power of Uniqueness and Belonging to Build Innovative Teams. \nShe is also passionate about disseminating her work more broadly and has taught two LinkedIn Learning courses on how to increase diversity and inclusion in corporations. She has published over 70 journal articles and book chapters in outlets such as Harvard Business Review and Journal of Applied Psychology and her work has been featured in media outlets such as Forbes\, The Economist\, Time\, and the Wall Street Journal. \nRegister Online \n\nAbout the Presenters\nDr. Stefanie K. Johnson\, Author of WSJ Bestseller\, Inclusify \nDr. Stefanie K. Johnson is an author\, professor\, and keynote speaker who studies the intersection of leadership and diversity\, focusing on (1) how unconscious bias affects the evaluation of leaders and (2) strategies that leaders can use to mitigate bias. \nHer new Harper Collins book\, Inclusify: Harnessing the power of uniqueness and belonging to build innovative teams\, shares the surprising ways the leaders undermine inclusion and provides actionable ways that leaders can pivot to build more inclusive teams. \nDr. Johnson is a member of the MG 100 Coaches and was selected for the 2020 Thinkers50 Radar List\, comprising 30 international management scholars whose work will shape the future of how organizations are managed and led. She works with the best companies in the world to create more inclusive leaders. She has extensive consulting experience and has created and delivered leadership development training with an emphasis on evidence-based practice. \nAs an associate professor at the University of Colorado Boulder’s Leeds School of Business\, Dr. Johnson teaches undergraduate and graduate students focused on leadership and inclusion. She holds the Andrea and Michael Leeds Research Fellowship\, is the Director of CU Boulder’s Daniels Fund Ethics Initiative at Leeds\, and is a 2020 CU Boulder RIO Fellow. She is a fellow in the Society of Industrial Organizational Psychologists (SIOP) and the American Psychological Society (APS). She is also passionate about disseminating her work more broadly and has taught two LinkedIn Learning courses on how to increase diversity and inclusion in corporations. \nShe has received $3\,800\,000 in external grant funding to study leadership and create leadership development programs. Her safety leadership course was adopted by the OSHA 30 and taken by 70\,000 students in its first two years. She is an active researcher and has published 60 journa \nl articles and book chapters in outlets Journal of Applied Psychology and The Academy of Management Journal. \nDr. Johnson is also a frequent contributor to Harvard Business Review and an in-demand keynote speaker. She has presented her work at over 170 meetings around the world including at the White House for a 2016 summit on diversity in corporate America on National Equal Pay Day. \nMedia outlets featuring Stefanie’s work include: Forbes\, The Economist\, Newsweek\, Time\, Wall Street Journal\, Bloomberg\, HuffPost\, Washington Post\, Quartz\, Discover\, CNN\, ABC\, NBC\, CNBC. She has appeared on Fox\, ABC\, NBC\, CNN\, and CNN International. She lives in the Boulder Bubble with her Biology Professor husband\, two young kiddos\, and two old kitties. \n\nRegistration\nRegister Online \nYour confirmation email will include instructions on how to receive a complimentary copy of Inclusify (while supplies last). \nRegistration Fees \nRegistration is Complimentary  \n\nCLE\nPlease note that CLE credit is not offered for this webinar. \n 
URL:https://www.fedbar.org/event/section-on-taxation-diversity-inclusion-committee-inclusify-maximizing-uniqueness-and-belonging-to-build-more-innovative-teams-with-dr-stefanie-k-johnson/
LOCATION:Online\, US
CATEGORIES:Section on Taxation
GEO:37.09024;-95.712891
END:VEVENT
BEGIN:VEVENT
DTSTART;VALUE=DATE:20200527
DTEND;VALUE=DATE:20200530
DTSTAMP:20260411T131831
CREATED:20191220T204830Z
LAST-MODIFIED:20200527T144626Z
UID:16579-1590537600-1590796799@www.fedbar.org
SUMMARY:Virtual 2020 Insurance Tax Seminar
DESCRIPTION:The insurance industry is constantly evolving through industry tax issues\, globalization\, and now a nationwide pandemic. Industry tax professionals\, consultants\, and IRS representatives are navigating through a new environment of uncertainty. The FBA Section on Taxation will move forward to facilitate a virtual dialogue between the insurance industry and government sector professionals on May 27-29\, covering viewpoints on myriad insurance company\, insurance product\, international\, and other relevant and timely insurance tax topics. Participants will have the opportunity to stay up-to-date on the latest tax developments and guidance through a virtual seminar series\, featuring six panels that will navigate the current tax environment and examine recent developments the industry is facing. \nEducational Credit Update: We are only able to offer CLE credit for this year’s virtual seminar. No CPE Credit will be provided. \nRegistered Attendees: Check your email each morning for links to access the day’s sessions. If you pre-selected panels to attend\, you should have also received a calendar invitation with the same access link. \n\n\nAgenda\nAll Times Below are in Eastern Daylight Time (EDT) \n\nWednesday\, May 27\, 2020\n[12:45 p.m. – 1:00 p.m.] Opening Remarks \n\nJean Baxley\, Private Sector\, Seminar Co-Chair\nDaniel J. Kusaila\, Crowe LLP\nAlexis A. MacIvor\, Public Sector\, Seminar Co-Chair\nSurjya Mitra\, Private Sector\, Seminar Co-Chair\n\n[1:00 p.m. – 2:30 p.m.] Update from the Insurance Branch\n \nThis 90-minute panel will include a discussion with several representatives of the Insurance Branch of the Financial Institution and Products division within the IRS Office of Chief Counsel.  Attendees will hear Insurance Branch personnel describe recent tax guidance and significant rulings issued by the Branch within the past year as well as current projects being considered by the Branch. \n\nLori Robbins\, Managing Director\, KPMG LLP (moderator)\nRebecca L. Baxter\, Senior Technician Reviewer\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nJohn E. Glover\, Senior Counsel\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nAlexis A. MacIvor\, Branch Chief\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nDaniel P. Phillips\, Senior Counsel\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nKathryn M. Sneade\, Senior Technician Reviewer\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\n\n[3:00 p.m. – 4:30 p.m.] Insurance Company Tax Issues \nThe panel will discuss Federal income tax issues that were most impactful in the past year for life\, property and casualty\, and health insurers\, including proposed regulations under section 807\, changes in the determination of discounted unpaid losses\, and generally-applicable developments that are especially important to insurers.  Issues arising under the Coronavirus Aid\, Relief\, and Economic Security Act (the CARES Act) will be discussed on a different panel. \n\nMark Smith\, Managing Director\, PwC (moderator)\nPam Biesecker\, Senior Vice President\, Chief Tax Officer\, Nationwide Mutual Insurance Company\nDaniel P. Phillips\, Senior Counsel\, Insurance Branch\, Office of the Associate Chief Counsel (FI&P)\, I.R.S.\nRegina Rose\, Senior Vice President\, Taxes & Retirement Security\, American Council of Life Insurers\nFred von Rueden\, Blue Cross Blue Shield Association\nChristopher W. Schoen\, Counsel\, Eversheds Sutherland LLP\n\nThursday\, May 28\, 2020\n[1:00 p.m. – 2:30 p.m.] International Tax Issues \nThe international tax panel will provide an overview of the latest U.S. international tax developments relevant to global insurance and reinsurance companies. Panelists will discuss the tax implications of the Coronavirus Aid\, Relief\, and Economic Security (CARES) Act\, including the interplay of the expanded net operating losses carryback provisions with the U.S. international tax rules (covering FTCs\, the Section 250 deduction and GILTI).  The panel also will discuss the tax implications of COVID-19 travel restrictions and will examine recent U.S. tax legislative updates\, including with respect to BEAT\, PFICs\, Section 954(i)\, and Section 807 reserves. \n\nJason Kaplan\, Principal\, International Tax\, Deloitte Tax LLP (moderator)\nEric Lopata\, Vice President\, Corporate Counsel\, Prudential Financial\, Inc.\nSurjya Mitra\, Managing Director\, PwC\nChris Ocasal\, Principal\, EY\n\n[3:00 p.m. – 4:30 p.m.] Product Tax Update \nThe panel will discuss the recently enacted Setting Every Community Up For Retirement Enhancement Act (SECURE Act) and how the new provisions affect annuity contracts\, with a particular focus on the new after-death distribution requirements in section 401(a)(9).  The panel will explore what changes might be needed to annuity contracts in order to comply with these new rules.  In addition\, the panel will address the temporary retirement plan relief provided by the recently enacted Coronavirus Aid\, Relief\, and Economic Security (CARES Act).  The panel will also review some of the issues presented by the required minimum distribution rules under section 401(a)(9)\, including the application of the minimum income threshold test set forth in Treas. Reg. sec. 1.401(a)(9)-6 to certain types of annuity payment options.  The panel will discuss the final regulations relating to the new reportable policy sale rules in section 6050Y and the new transfer for value rules in section 101 and the issues they present for life insurance contracts.  Finally\, the panel will review the new advisor fee private letter rulings for non-qualified annuity contracts under section 72 that were recently issued by the IRS. \n\nAlison R. Peak\, Partner\, Davis & Harman LLP (moderator)\nGraham R. Green\, Counsel\, Eversheds Sutherland LLP\nMark Rush\, Head of Product Tax Legal\, MassMutual\nTamara Saverine\, Vice President\, Corporate Counsel (Tax)\, Prudential Financial Inc.\n\nFriday\, May 29\, 2020\n[1:00 p.m. – 2:30 p.m.] The COVID-19 Pandemic: Relevant Tax Legislation and Other Considerations for Insurers \nThis panel will discuss corporate and individual tax provisions of the CARES Act and other coronavirus legislative proposals that impact the insurance industry. The panel will consider the impact of corporate tax provisions of the CARES Act\, including\, among other things\, the new carryback rules and the changes to section 163(j). The panel will also discuss individual provisions of interest to the insurance industry\, such as the retirement changes. Finally\, the panel will consider pending law changes that may be included in future legislation. \n\nAnn Cammack\, Principal\, EY (moderator)\nEric Solomon\, Partner\, Steptoe & Johnson LLP (moderator)\nLori J. Jones\, Partner\, Scribner Hall & Thompson LLP\nDaniel Kusaila\, Partner\, Insurance Tax Practice\, Crowe LLP\nJames J. (Jim) Shea\, Vice President\, Chief Tax Officer\, Prudential Financial Inc.\n\n[3:00 p.m. – 4:30 p.m.] Multi-state Hot Topics \nThis panel will discuss current multi-state issues related to the TCJA\, the CARES Act\, Wayfair and economic nexus issues\, COVID-19 compliance considerations\, and indirect tax issues that impact the insurance industry.  The speakers will discuss state tax conformity and decoupling issues related to the TCJA and CARES Act including Sec. 163j business interest limitations\, NOL treatment and other conformity issues.  The panel will also analyze income and other tax considerations regarding economic nexus that insurance industry companies and their advisors need to consider in the post-Wayfair tax environment.  The panel will also discuss the state tax compliance issues associated with COVID-19.  Finally\, the panel will consider indirect tax issues that are significantly impacting the tax and business operations of insurance companies and their non-insurance related entities. \n\nArthur “Art” Burkard\, Managing Director\, State and Local Tax Services\, Grant Thornton LLP (moderator)\nJosie Lowman\, Managing Director\, Insurance State Tax Leader\, PwC\nBrendon J. McKibbin\, Partner\, State & Local Tax\, Deloitte Tax LLP\n\n[4:30 p.m. – 4:45 p.m.] Closing Remarks \n\n \n\n\n\n\n\n\n\n\n\nRegistration\nRegistration is now closed for this event. \n\n\n\nAttendance Policy\nIndividuals are limited to attending the number of sessions within their paid registration package. For example\, the “2 Pack” rate allows access to two virtual panels over the course of three days. Registrants that have been found to attend more than their permitted registration package will be invoiced for a $100 fee per extra session attended.  \nCancellation Policy\nNo refunds will be made for cancellations received after the close of business on Friday\, May 1\, 2020. Please contact Ariel White at awhite@fedbar.org with cancellation and/or substitution requests. \n\n\n\n\n\n\n\n\n\nSponsors\n[PREMIER]\n \n  \n[EVENT PARTNER] \nBKD\nCPAs & Advisors\n  \n[BREAK] \nJohnson Lambert LLP\n  \nContact Elizabeth Johnson if you are interested in sponsoring this event. \n\nFrequently Asked Questions\nQ: Are you cancelling the Insurance Tax Seminar?\nA: We are turning this year’s event into a virtual seminar series exclusively available online. Tune into six CLE panels on May 27-29. We are excited to offer educational programing in the safety of your own home. \nQ: Will the in-person Insurance Tax Seminar be rescheduled to another date?\nWe will not reschedule the in-person program in Washington\, DC for 2020. While we are disappointed not to be gathering in person this year\, we are excited to host the seminar online this May 27-29\, 2020. We plan to return to the in-person format in June 2021. \nQ: What type of educational credit will be offered in the virtual format?\nA: We are only able to offer Continuing Legal Education (CLE) credit for this year’s virtual seminar. Attendees can receive up to 9 CLE credits (10.8 credits for 50-min states). Please check with your own state(s) for distance learning CLE requirements. \nThe Federal Bar Association is not able to offer Continuing Professional Education (CPE) credit this year via distance learning due to NASBA policies. We plan to return to offering both credit options in-person next year. \nQ: How do I obtain CLE Credit?\nA: All registrants will be prompted to submit state bar information prior to the virtual series to ensure accurate CLE reporting post-event. We will share detailed instructions with registrants for CLE reporting. \nQ: Will recordings of the sessions be available after the seminar?\nA: Sessions will be distributed exclusively via the live broadcast. We do not have recordings available at this time. \nQ: Who do I contact for more information?\nA: Please contact meetings@fedbar.org for any other questions.
URL:https://www.fedbar.org/event/instax20/
LOCATION:DC
CATEGORIES:Section on Taxation
ATTACH;FMTTYPE=image/jpeg:https://www.fedbar.org/wp-content/uploads/2019/12/iStock_49625586_XLARGE.jpg
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20200430T173000
DTEND;TZID=America/New_York:20200430T193000
DTSTAMP:20260411T131831
CREATED:20200219T190859Z
LAST-MODIFIED:20200325T195916Z
UID:27625-1588267800-1588275000@www.fedbar.org
SUMMARY:CANCELLED: Section on Taxation: Boston Tax Section Spring Gathering
DESCRIPTION:Join the Tax Section for a happy hour and social gathering in Boston! Network and connect with Boston tax professionals and fellow FBA members. Feel free to bring your peers and colleagues! A variety of hors d’oeuvres will be served. \n\nRegistration\nPlease RSVP to Alea Al-Aghbari at aalaghbari@fedbar.org by April 29\, 2020.
URL:https://www.fedbar.org/event/section-on-taxation-boston-tax-section-spring-gathering/
LOCATION:State Street Provisions\, 255 State Street\, Boston\, MA\, 02109\, United States
CATEGORIES:Massachusetts Chapter,Section on Taxation
GEO:42.3593857;-71.0513553
X-APPLE-STRUCTURED-LOCATION;VALUE=URI;X-ADDRESS=State Street Provisions 255 State Street Boston MA 02109 United States;X-APPLE-RADIUS=500;X-TITLE=255 State Street:geo:-71.0513553,42.3593857
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20200429T140000
DTEND;TZID=America/New_York:20200429T150000
DTSTAMP:20260411T131831
CREATED:20200331T225433Z
LAST-MODIFIED:20200428T182504Z
UID:35257-1588168800-1588172400@www.fedbar.org
SUMMARY:Webinar: Foreign Tax Credits
DESCRIPTION:Join the FBA Tax Section and Eversheds Sutherland for an in-depth discussion of the impact of the recent proposed and final Foreign Tax Credit regulations. Panelists will discuss both the proposed and final regulations\, how they impact taxpayers\, and how the government addressed comments made in response to the original proposed regulations. \nRegistration is now closed \n\nAbout the Presenters\nMartin Milner\, Principal\, Ernst & Young LLP\nMartin Milner is a principal in Ernst & Young LLP’s International Tax Services practice and is part of the National Tax Department. He is based in Washington\, D.C.\, and advises clients on all aspects of US international taxation\, particularly cross-border acquisitions\, dispositions and restructurings. \nPrior to joining Ernst & Young LLP\, Martin was a partner at a major international law firm where he represented multinational corporations and high net worth individuals on international tax matters and cross-border acquisitions. \nMartin is a former Chair of the Federal Bar Association Section of Taxation and was an adjunct professor at Georgetown University Law Center where he taught Advanced International Taxation. \nMartin received a Masters of Law (LLM) in Taxation at New York University Law School and a juris doctor at Emory University School of Law. Prior to law school\, Martin received a BA from Washington and Lee University. He is a member of District of Columbia Bar Association\, the Georgia Bar Association\, the Louisiana Bar Association and the Mississippi Bar Association. Martin is a frequent contributor to tax publications and he often speaks at Tax seminars on various international tax topics. \n \nAaron Payne\, Partner\, Eversheds Sutherland\nAaron Payne represents publicly traded global corporations in the area of federal corporate taxation with respect to domestic and international planning\, transactions and compliance. Aaron analyzes global issues and then structures deals accordingly in the context of acquisitions\, dispositions and reorganizations. He advises clients regarding repatriation techniques\, currency transactions\, principal and finance company arrangements and financial instruments with cross-border facets. Aaron works with clients to manage the international taxation implications of their M&A endeavors by crafting deals to create transaction and legal entity structures that optimize the company’s tax outcomes. \nOn the internal planning side\, Aaron advises on repatriation structures to help clients efficiently meet their cash-flow needs as well as how to organize their international legal entities such that they are efficiently postured for U.S. tax purposes. In the area of corporate tax planning\, Aaron advises multinational Fortune 100 clients in all aspects of their cross-border transactions. This activity includes subpart F planning\, as well as tax compliance and tax information reporting. \nCarol Tello\, Partner\, Eversheds Sutherland\nWith a career that spans both government and private practice\, Carol Tello helps multinational companies and individuals navigate the complex and rigorous realm of international taxation. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy matters\, including compliance with the Foreign Account Tax Compliance Act (FATCA). Balancing the concurrent goals of minimizing tax consequences and complying with the law\, Carol brings experience in cross-border restructuring transactions\, inbound corporate transactions\, withholding matters and treaty interpretation issues\, as well as cross-border taxation of corporate executives and the U.S. taxation of non-U.S. citizens. She also advises clients on tax issues involving intellectual property transactions. \nBefore joining Eversheds Sutherland (US)\, Carol worked in the IRS Office of Associate Chief Counsel (International) and as a Special Assistant to the Assistant Commissioner (International). She participated in a number of income tax treaty negotiations\, was the IRS National Office adviser in several U.S. Tax Court cases\, and worked on various regulations and other guidance\, including significant participation in developing regulations concerning the taxation of software transactions. \n\nRegistration\nRegistration will close 24 hours prior to event start \nRegistration Fees \n\nFBA Member: $0\nNonmember: $75\n\nHow to Register \nRegistration is now closed \nCancellation Policy \nNo refunds will be made for cancellations received after the close of business on Wednesday\, April 15\, 2020. No-shows will be billed. Substitutions may be made at any time upon notification. Please contact Laura Mulhern at lmulhern@fedbar.org with cancellation and/or substitution requests. \n\nCLE\nCLE Credits provided by Eversheds Sutherland \n\nIf you have any questions regarding this program\, please contact Laura Mulhern\, Sections and Divisions Manager.
URL:https://www.fedbar.org/event/webinar-foreign-tax-credits/
LOCATION:DC
CATEGORIES:Section on Taxation
END:VEVENT
BEGIN:VEVENT
DTSTART;TZID=America/New_York:20200319T120000
DTEND;TZID=America/New_York:20200319T130000
DTSTAMP:20260411T131831
CREATED:20200310T131553Z
LAST-MODIFIED:20200310T131553Z
UID:31300-1584619200-1584622800@www.fedbar.org
SUMMARY:Tax Section: Practice and Procedure Roundtable Call: Current Issues in FBAR Litigation
DESCRIPTION:The FBA Tax Section is excited to host a discussion of the current state of FBAR litigation from the private practitioner and government viewpoint. Speakers Brian McManus and Joshua Wu will give a brief overview of the FBAR reporting requirements\, examinations\, and administrative appeals before turning to litigation. They will also discuss the development of FBAR case law\, issues currently in litigation\, and strategies for handling FBAR cases in litigation. This is one call you don’t want to miss! \n\nAbout the Speakers\nBrian McManus\, a partner in the Tax Department of Latham & Watkins\, focuses his practice on civil and criminal tax litigation and controversies. Mr. McManus litigates high stakes tax cases before federal and state courts. He also represents taxpayers in Internal Revenue Service (IRS) audits\, appeals\, and criminal investigations with the objective of confidentially resolving tax controversies and avoiding litigation. With nearly two decades of “inside the beltway” experience in Washington\, Mr. McManus frequently handles controversy matters with broader tax policy implications. Mr. McManus’ litigation and controversy practice extends to all areas of federal and state taxation\, with an emphasis on disputes involving cross-border and international tax matters\, sophisticated corporate transactions\, enterprise and asset valuations\, transfer pricing\, partnerships\, oil and gas taxation\, tax shelters\, and promoter penalty defense. \nMr. McManus frequently handles sensitive tax matters involving allegations of fraud and potential criminal tax charges. He has helped clients avoid severe civil penalties and criminal prosecution\, and he regularly advises on voluntary disclosure of domestic and offshore filing errors.  His clients include numerous multinational and Fortune 500 companies in diverse industries such as banking\, insurance\, technology\, energy\, pharmaceuticals\, airlines\, and retail. Mr. McManus has represented several global law and accounting firms\, as well as international charitable organizations\, trust companies\, offshore corporate service providers\, and high net worth families. Mr. McManus is admitted to practice before the US Court of Appeals for Federal Claims\, and the US District Court for the District of Massachusetts. \n  \nJoshua Wu is the Deputy Assistant Attorney General for Policy and Planning at the U.S. Department of Justice\, Tax Division. Prior to joining the Tax Division\, Josh worked for several international law firms and represented clients in an array of tax controversies and tax litigation matters before the IRS\, the U.S. Tax Court\, the U.S. Court of Federal Claims\, the U.S. District Court for the Eastern District of Texas\, and the U.S. Court of Appeals for the Federal Circuit.  Josh received his B.A. from the University of Virginia\, his J.D from Syracuse University College of Law\, and his LL.M. from the Georgetown University Law Center. \n\nGround Rules\n\nStatements made by government employees are made in their personal capacity and may not be relied upon as an authorized statement of any government agency.\nNo recording devices allowed.\nFBA Tax Section membership is not required to participate\, but you are encouraged to visit https://www.fedbar.org/membership/for information on becoming a member.\n\n\nInterested in Speaking?\nIf you are interested in leading a future monthly call\, please contact john.pontius@pontiustaxlaw.com or danielstrickland@eversheds-sutherland.com. \n\nFor call-in information\, please contact Alea Al-Aghbari. \n 
URL:https://www.fedbar.org/event/tax-section-practice-and-procedure-roundtable-call-current-issues-in-fbar-litigation/
LOCATION:DC
CATEGORIES:Section on Taxation
END:VEVENT
END:VCALENDAR