31st annual Federal Tax Institute

Transcription

1 31st annual Federal Tax Institute Thursday-Friday, May 17-18, 2012 Nationally recognized tax advisors provide a comprehensive update on cutting-edge legal, legislative and policy developments and their impact on tax planning, compliance and controversy techniques.

2 Keynote Speaker William J. Wilkins Chief Counsel Internal Revenue Service Program Faculty INSTITUTE CHAIR: Thomas Zollo, INSTITUTE VICE-CHAIRS: Gregory W. Gallagher, Kirkland & Ellis LLP David Hoffman, Deloitte Tax LLP Lydia R.B. Kelley, McDermott, Will & Emery LLP INSTITUTE SPEAKERS: William D. Alexander, Internal Revenue Service James R. Barry, Mayer Brown LLP Stefan Beck, Aon Corporation John A. Biek, Neal, Gerber & Eisenberg LLP Theodore R. Bots, Baker & McKenzie LLP Chadwick I. Buttell, Patzik, Frank & Samotny Ltd. Paul D. Carman, Chapman and Cutler LLP Michael R. Fayhee, McDermott, Will & Emery LLP Steven Fortier, Thomas A. Geraghty, Kirkland & Ellis LLP Harry L. Hank Gutman, Lydia R.B. Kelley, McDermott, Will & Emery LLP, Institute Vice-Chair Charles R. Levun, Levun, Goodman & Cohen LLP Maxwell M. Miller, Skadden, Arps, Slate, Meagher & Flom LLP Wendy J. Muchman, Attorney Registration and Disciplinary Commission Kevin R. Pryor, Sidley Austin LLP David S. Raab, Latham & Watkins LLP Donald E. Rocap, Kirkland & Ellis LLP Mark A. Schneider, Deloitte Tax LLP Karen Sewell, Baker & McKenzie LLP Peter F. Simpson, Grant Thornton LLP Martin A. Sullivan, Tax Analysts Thomas Zollo,, Institute Chair

3 About the Institute: The Institute is designed for experienced practitioners. Who should attend: Attorneys, accountants, corporate tax directors and staff Program at a Glance Thursday, May 17 (Interactive Panel Discussions and Breakout Sessions) 9:00a.m.-10:30a.m. Federal Tax Law Developments State & Local Tax Developments 10:45a.m.-12:15p.m. (Breakout Sessions) International Business Restructuring: Tax Considerations Corporate: Fund Formation, Private Equity Overview Partnership Issues 12:15p.m.-1:30p.m. Lunch (must purchase ticket to attend) 1:30p.m.-2:45p.m. (Breakout Sessions) International Business Restructuring: Transfer Pricing Considerations Corporate: Acquisitions and Dispositions 3:00p.m.-4:00p.m. IRS Administration and LB&I Update 4:00p.m.-4:30p.m. Keynote Speaker: William J. Wilkins 4:30p.m.-5:30p.m. Cocktail & Networking Reception Friday, May 18 (Interactive Panel Discussions) 9:00a.m.-10:00a.m. Corporate Tax Developments 10:05a.m.-11:20a.m. Legislative & Tax Reform Update 11:25a.m.-12:25p.m. Ethics: E-Discovery Issues

4 Program Schedule Thursday, May 17, :00 a.m. 8:55 a.m. Registration 8:55 a.m. 9:00 a.m. Welcome Gerald Brown Director, Graduate Program in Taxation, Chicago-Kent College of Law Program Moderator Thomas Zollo 9:00 a.m. 10:30 a.m. Federal Tax Law Developments Update on the most recent developments in case law and rulings in the federal income, estate and gift, and employee benefits tax areas. Michael R. Fayhee McDermott, Will & Emery LLP Lydia R.B. Kelley McDermott, Will & Emery LLP State and Local Tax Developments Taxpayers Under Siege Discussion of significant cases, rulings and legislative developments impacting state income/franchise, sales and use, gross receipts and other taxes throughout the United States. John A. Biek Neal, Gerber & Eisenberg LLP Theodore R. Bots Baker & McKenzie LLP 10:30 a.m. 10:45 a.m. Break 10:45 a.m. 12:15 p.m. BREAKOUT SESSIONS CHOOSE ONE International Business Restructuring: Tax Considerations Multinational enterprises operate in a dynamic environment that forces them to shift research and development, production and distribution across borders to capture competitive advantages. This session will explore the potential tax consequences of such cross-border shifts and potential strategies to manage such consequences. Peter F. Simpson Grant Thornton LLP Thomas Zollo Corporate: Fund Formation, Private Equity Overview This session will discuss the principal structural and tax issues that arise in the formation of a private equity fund and affiliated entities, and provide an overview of certain recent developments. Topics that will be addressed include: Fund sponsor and service provider issues, including carried interest and fee arrangements; Investor issues, including the use of US and offshore entities, taxexempt investors (unrelated business taxable income), and non-us investors (effectively connected income); Updates on the carried interest legislation, proposed regulations addressing sovereign investors,

5 FATCA, and expanded reporting requirements for private equity managers; and Tax and financing issues relating to investments made by private equity funds. Thomas A. Geraghty Kirkland & Ellis LLP Donald E. Rocap Kirkland & Ellis LLP Partnership Issues This session will focus on the hot topics in partnership/llc taxation, including LLC structuring transactions, recent foreign developments and issues pertaining to series LLCs. Chadwick I. Buttell Patzik, Frank & Samotny Ltd. Paul D. Carman Chapman & Cutler LLP Charles R. Levun Levun, Goodman & Cohen LLP 12:15 p.m. 1:30 p.m. Lunch (must purchase ticket to attend) 1:30 p.m. 2:45 p.m. BREAKOUT SESSIONS CHOOSE ONE International Business Restructuring: Transfer Pricing Considerations International business restructurings are increasingly common as multinationals seek to accelerate revenue growth and capture operational efficiencies in a highly competitive global market. This session will address a number of transfer pricing issues surrounding business restructurings, including potential exit charges, postrestructuring pricing and managing tax authority challenges. Stefan Beck Aon Corporation Steven Fortier Corporate: Acquisitions and Dispositions This session will focus on recent Subchapter C issues, including combinations involving disregarded entities, basis issues and other current topics. James R. Barry Mayer Brown LLP Maxwell M. Miller Skadden, Arps, Slate, Meagher & Flom LLP 2:45 p.m. 3:00 p.m. Break 3:00 p.m. 4:00 p.m. IRS Administration and LB&I Update This session will address the current status of the LB&I realignment and other IRS administration matters. Kevin R. Pryor Sidley Austin LLP William J. Wilkins Chief Counsel, Internal Revenue Service

6 4:00 p.m. 4:30 p.m. IRS Focus William J. Wilkins Chief Counsel, Internal Revenue Service 4:30 p.m. 5:30 p.m. Cocktail & Networking Reception Friday, May 18, 2012 Moderator Thomas Zollo 9:00 a.m. 10:00 a.m. Corporate Tax Developments Discussion of corporate tax law developments, including a discussion of recent case law, rulings, and regulatory guidance, including expected IRS guidance. The panel will also explore new developments taking place in the market. William D. Alexander Associate Chief Counsel (Corporate), Internal Revenue Service David S. Raab Latham & Watkins LLP Mark A. Schneider Deloitte Tax LLP 10:00 a.m. 10:05 a.m. Break 10:05 a.m. 11:20 a.m. Legislative & Tax Reform Update The panel will discuss prospects for federal income tax legislation, focusing on the situation as it exists on the day of this presentation, May 18, Topics will include: the President s FY13 Budget, the looming expiration of the individual tax cuts, the state of play with respect to business tax reform and the potential effect of the November elections. Harry L. Hank Gutman Martin A. Sullivan Tax Analysts 11:20 a.m. 11:25 a.m. Break 11:25 a.m. 12:25 p.m. Ethics: E-Discovery Issues Preservation and spoliation (Rule 3.4, FRCP 37(e), Zubulake) The Search for and production of documents (Qualcomm, Rule 1.1, 3.1, 3.4, FRCP 26(b)(2) (B), claw back and quick-peek agreements, collaboration with opposing counsel) Preservation of privilege and attorney-client communications (Rule 1.6, Rule 1.13, Lester v. Allied Concrete, FRE 502) Supervisory responsibilities (Rule , FRCP 11, ABA 2020 proposed comment to Rule 1.1, FRCP 26(g), ABA opinion on outsourcing ) Retention and management of client and case correspondence Wendy J. Muchman Chief of Litigation & Professional Education, Attorney Registration and Disciplinary Commission Karen Sewell Baker & McKenzie LLP

7 Federal Tax Institute Planning Committee John A. Biek Neal, Gerber & Eisenberg LLP Theodore R. Bots Baker & McKenzie LLP Evelyn Brody Chicago-Kent College of Law Gerald Brown Chicago-Kent College of Law Michael A. Clark Sidley Austin LLP Denis J. Conlon Martin, Brown, Sullivan, Roadman & Hartnett Ltd. Louis S. Freeman Skadden, Arps, Slate, Meagher & Flom LLP Jeffrey B. Frishman Grant Thornton LLP Steven G. Frost Chapman and Cutler LLP Gregory W. Gallagher Kirkland & Ellis LLP Institute Vice-Chair Michael Gervasio David Hoffman Deloitte Tax LLP Institute Vice-Chair Lydia R.B. Kelley McDermott, Will & Emery LLP Institute Vice-Chair Joseph M. Kronsnoble Latham & Watkins LLP Charles R. Levun Levun, Goodman & Cohen LLP William A. Levy Kirkland & Ellis LLP Richard D. Liebman Grant Thornton LLP John B. Palmer III Foley & Lardner LLP Kevin R. Pryor Sidley Austin LLP Saul E. Rudo Katten Muchin Rosenman LLP Steven W. Swibel Dykema Gossett PLLC Deborah T. Villa Chicago-Kent College of Law Louis J. Weber III Winston & Strawn LLP Thomas Zollo Institute Chair LL.M. Program in Taxation The Graduate Program in Taxation at Chicago-Kent College of Law is designed to meet the needs of full-time, part-time or non-degree students seeking the best in both a theoretical and practical graduate tax education. The program faculty are partners in major Chicago law firms, attorneys in the tax groups of national accounting firms, and full-time Chicago-Kent faculty. Classes offer in-depth knowledge of tax issues involved in business and financial transactions and the skills necessary to plan the transactions by faculty routinely involved in planning, resolving and litigating critical tax issues. For more information, please contact the Office of Graduate Admissions at (312) or send an to admit@kentlaw.edu.

8 General Information Program Location The conference will be held at Chicago-Kent College of Law, 565 West Adams Street in Chicago. Confirmation of Registration A letter of confirmation will be ed to the address given on your registration form. If you do not receive an confirmation after registering and before the conference please contact the Office of Continuing Legal & Professional Education at cle@kentlaw.edu. Confirmation of Attendance A certificate of attendance will be provided at registration. Cancellations and Refunds Written notification of cancellation is required. A full tuition refund is available if notification is received prior to April 20, 2012; 25% will be charged if notification is received between April 20 and May 11, No refunds will be granted after May 11, MCLE Credit Chicago-Kent College of Law is an accredited provider for IL & PA MCLE. This conference is eligible for 9.0 hours of IL MCLE and includes 1.0 hour of ethics credit (pending approval). The actual number of approved hours may vary from state to state. For additional information: please call the Office of Continuing Legal and Professional Education, Chicago-Kent College of Law, (312) , or send an to cle@kentlaw.edu. CPE Credit 11.0 hours on a 50-minute credit hour. Chicago-Kent College of Law is a registered public accountant professional education sponsor in Illinois. Hotel Accommodations Hotel accommodations for the convenience of out-of-town guests have been made at the Club Quarters, Central Loop. The room rate at the Club Quarters, Central Loop is $179 for single occupancy, plus 15.4% tax. The Club Quarters is a private, no frills hotel designed specifically for the business traveler and is located five blocks east of the law school within easy walking distance. Please make reservations directly with the hotel. Requests for accommodations cannot be assured if made after April 2, To Make Reservations: Club Quarters, Central Loop 111 W Adams Street Chicago, IL (203) Voice (203) Fax aspx Please mention to the hotel reservation receptionist that you are with the Illinois Institute of Technology and use group code IIT516 Registration Fee (per person) Early Registration Fee: $435 After April 18, 2012: $455 Government Rate: $355 Chicago-Kent College of Law Alumni Rate: $355 Luncheon Ticket: $30 Multiple Registrant Firm Ticket: Do you have 4 or more persons from your firm planning to attend? Call (312) for super discount pricing.

9 Registration Form: Federal Tax Institute 3 Easy Ways to Register Online: Mail: cle.kentlaw.edu Office of Continuing Legal & Professional Education IIT Chicago-Kent College of Law 565 West Adams St. Chicago, IL Phone: (312) Name (please print) Professional Title Firm Address City State Zip Telephone Fax Attorney Registration # Luncheon Ticket: q Check here if you are purchsing a luncheon ticket for Thursday, May 17. If Chicago-Kent Alumni, list month and year of graduation: Month Year q Please check here if you have any special needs and a CLE staff member will contact you. Payment Information q Payment by check. Amount enclosed $ (Make check payable to: Chicago-Kent College of Law) q Payment by credit card. q VISA q MasterCard q American Express q Discover Amount enclosed $ Card # Exp. Date Security Code Signature