33rd annual Federal Tax Institute

33rd annual Federal Tax Institute Thursday-Friday, May 1-2, 2014 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. Continuing Legal Education

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 1 (Interactive Panel Discussions and Breakout Sessions) 9:00a.m.-10:00a.m. Business Tax Reform: What Happens Next? 10:00a.m.-10:30a.m. Penalty Games: Reducing IRS Penalties 10:45a.m.-12:00p.m. (Breakout Sessions) International Topics I: Financial Statement Audit Pitfalls for Multinational Companies Final Repair Regulations: What Has Changed and How Will It Impact You? Hot LLC/Partnership Issues for 2014 12:00p.m.-1:25p.m. Lunch (must purchase ticket to attend) 1:30p.m.-3:00p.m. (Breakout Sessions) International Topics II: Tax Efficient Cross-Border Structures Structuring Considerations in Taxable Acquisitions and Dispositions 3:15p.m.-4:45p.m. Professional Standards in Tax Advice 4:45p.m.-5:45p.m. Cocktail & Networking Reception Friday, May 2 (Interactive Panel Discussions and Keynote Speaker) 8:45a.m.-10:15a.m. Federal Tax Law Developments State & Local Tax Developments 10:30a.m.-11:00a.m. The Evolution of Global Commerce and Tax Policy and Its Implications for the Role of the Tax Executive: Timothy M. McDonald 11:00a.m.-12:30p.m. Corporate Tax Developments

Keynote Speaker Timothy M. McDonald Vice President-Finance & Accounting, Global Taxes The Procter & Gamble Company Program Faculty INSTITUTE CHAIR: Lydia R.B. Kelley, INSTITUTE VICE-CHAIRS: Gregory W. Gallagher, David Hoffman, Deloitte Tax LLP Joseph M. Kronsnoble, Latham & Watkins LLP INSTITUTE SPEAKERS: William D. Alexander, Internal Revenue Service John A. Biek, Neal, Gerber, & Eisenberg LLP Theodore R. Bots, Baker & McKenzie LLP Travis Butler, Chadwick I. Buttell, Patzik, Frank, & Samotny Ltd. Michael R. Fayhee, Harry L. Hank Gutman, KPMG LLP Lydia R.B. Kelley,, Institute Chair Damon M. Lyon, Charles R. Levun, Levun, Goodman, & Cohen LLP Julie M. Marion, Latham & Watkins LLP Timothy M. McDonald, The Procter & Gamble Company Robert E. McKenzie, Arnstein & Lehr LLP Daniel P. Meehan, Lee K. Morlock, Mayer Brown LLP Peter F. Simpson, Thacher Smith, Eric Solomon, Ernst & Young LLP Martin A. Sullivan, Tax Analysts James R. Watson, Deloitte Tax LLP Peter S. Wilson, McGladrey LLP Lowell D. Yoder,

Program Schedule Thursday, May 1, 2014 8:00 a.m. 8:55 a.m. Registration 8:55 a.m. 9:00 a.m. Welcome Gerald Brown Director, Graduate Program in Taxation, IIT Chicago-Kent College of Law Program Moderators Gregory W. Gallagher David Hoffman Deloitte Tax LLP Joseph M. Kronsnoble Latham & Watkins LLP 9:00 a.m. 10:00 a.m. Business Tax Reform: What Happens Next? A discussion and analysis of the factors affecting the reform of the taxation of business income Harry L. Hank Gutman KPMG LLP Martin A. Sullivan Tax Analysts 10:00 a.m. 10:30 a.m. Penalty Games: Reducing IRS Penalties This session will cover the basics of supporting reduction of IRS tax penalties, including: Reasonable cause Ordinary business care and prudence Internal Revenue Service preferred reasons for abatement of penalties A practical approach to seeking abatement of penalties Robert E. McKenzie Arnstein & Lehr LLP 10:30 a.m. 10:45 a.m. Break 10:45 a.m. 12:00 p.m. BREAKOUT SESSIONS CHOOSE ONE International Topics I: Financial Statement Audit Pitfalls for Multinational Companies This session will cover: An overview of the primary causes of financial statement restatements and related difficulties for multinational companies resulting from a deficiency in the accounting for income taxes across their global operations Practical steps companies take, and renewed processes they can employ, to minimize the negative effects of these issues Peter F. Simpson Thacher Smith Final Repair Regulations: What Has Changed and How Will It Impact You? This session will discuss the longawaited final regulations on when costs incurred to acquire, produce, or improve tangible property must be capitalized, or may be deducted, along with the re-proposed regulations regarding dispositions of depreciable property and general asset accounting rules. With significant changes to the previous temporary and proposed rules, the session will focus on such items in the final regulations as: Improvements to tangible property Dispositions De minimis Effective dates Travis Butler

Hot LLC / Partnership Issues for 2014 This session will analyze 2014 LLC/ partnership pressure points and planning opportunities, including the newly proposed regulations treating disguised sales of property and guarantees of partnership debt, and the final and proposed regulations relating to the net investment income tax under Code Section 1441. Chadwick I. Buttell Patzik, Frank, & Samotny Ltd. Charles R. Levun Levun, Goodman, & Cohen LLP 12:00 p.m. 1:25 p.m. Lunch (must purchase ticket to attend) 1:30 p.m. 3:00 p.m. BREAKOUT SESSIONS CHOOSE ONE International Topics II: Tax Efficient Cross-Border Structures Topics include: Cross-border M&A Inversions Global financing Low-tax principal structures Damon M. Lyon Lee K. Morlock Mayer Brown LLP Lowell D. Yoder Practical application of acquisition structuring matters, including the use of disregarded entities and other planning techniques Julie M. Marion Latham & Watkins LLP James R. Watson Deloitte Tax LLP 3:00 p.m. 3:15 p.m. Break 3:15 p.m. 4:45 p.m. Professional Standards in Tax Advice This session will address the professional standards and ethical considerations in providing tax advice that apply to Circular 230 practitioners attorneys, CPAs, and enrolled agents. It will also address selected issues that affect tax advice to clients, including civil penalty standards, non-signing preparer obligations, the Section 7525 tax practitioner privilege, and related risk management considerations. Peter S. Wilson McGladrey LLP 4:45 p.m. 5:45 p.m. Cocktail & Networking Reception Structuring Considerations in Taxable Acquisitions and Dispositions This session will discuss: Developments relating to asset basis step-up transactions, including application of recent regulations for Section 336(e)

Friday, May 2, 2014 Program Moderators Gregory W. Gallagher David Hoffman Deloitte Tax LLP Joseph M. Kronsnoble Latham & Watkins LLP 8:45 a.m. 10:15 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 Lydia R.B. Kelley State and Local Tax Developments 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. 11:00 a.m. KEYNOTE SPEAKER The Evolution of Global Commerce and Tax Policy and Its Implications for the Role of the Tax Executive Timothy M. McDonald The Procter & Gamble Company 11:00 p.m. 12:30 p.m. Corporate Tax Developments The panel will focus on recent developments in corporate taxation, including IRS regulations and other guidance, as well as interesting private letter rulings, regarding taxable and tax-free transactions. William D. Alexander Associate Chief Counsel (Corporate) Internal Revenue Service Daniel P. Meehan Eric Solomon Ernst & Young LLP 10:15a.m. 10:30 a.m. Break

Federal Tax Institute Planning Committee James R. Barry Mayer Brown LLP John A. Biek Neal, Gerber, & Eisenberg LLP Theodore R. Bots Baker & McKenzie LLP Evelyn Brody Gerald Brown Michael A. Clark Sidley Austin LLP Kevin J. Coenen Rebecca Coke Ernst & Young LLP Rick Emich PricewaterhouseCoopers LLP Louis S. Freeman Skadden, Arps, Slate, Meagher, & Flom LLP Jeffrey B. Frishman Gregory W. Gallagher Institute Vice-Chair Michael R. Gervasio KPMG LLP David Hoffman Deloitte Tax LLP Institute Vice-Chair Lydia R.B. Kelley Institute Chair LL.M. Program in Taxation Thomas J. Kinzler PricewaterhouseCoopers LLP Joseph M. Kronsnoble Latham & Watkins LLP Institute Vice-Chair Charles R. Levun Levun, Goodman, & Cohen LLP David F. Levy Skadden, Arps, Slate, Meagher, & Flom LLP Richard D. Liebman Lee K. Morlock Mayer Brown LLP John B. Palmer III Foley & Lardner LLP Lisa M. Pekkala Dentons US LLP Valerie C. Perera Kevin R. Pryor Sidley Austin LLP Leigh D. Roadman Martin, Brown, Sullivan, Roadman, & Hartnett Ltd. Peter F. Simpson Louis J. Weber III Winston & Strawn LLP Thomas Zollo KPMG LLP The Graduate Program in Taxation at 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) 906-5360 or send an email to admissions@kentlaw.iit.edu.

General Information Program Location The conference will be held at IIT Chicago-Kent College of Law, 565 West Adams Street in Chicago. Confirmation of Registration A letter of confirmation will be emailed to the address given on your registration form. If you do not receive an email confirmation after registering and before the conference please contact the Office of Continuing Legal & Professional Education at cle@kentlaw.iit.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 4, 2014; 25% will be charged if notification is received between April 4 and April 25, 2014. No refunds will be granted after April 25, 2014. MCLE Credit is an accredited provider for IL & PA MCLE. This conference is eligible for 8.75 hours of IL MCLE and includes 1.5 hours 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, IIT Chicago- Kent College of Law, (312) 906-5090, or send an email to cle@kentlaw.iit.edu. CPE Credit 10.5 hours on a 50-minute credit hour. IIT 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 Crowne Plaza Chicago Metro. The room rate at the Crowne Plaza Chicago Metro is $155 for single or double occupancy, plus 16.4% tax. The Crowne is located four blocks west 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, 2014. To Make Reservations: Crowne Plaza Chicago Metro 733 W. Madison Street Chicago, IL 60601 (312) 829-5000 Voice (312) 602-2180 Fax www.crowneplaza.com/chicagometro When booking online enter group code: CKT Please mention to the hotel reservation receptionist that you are with the Federal Tax Institute. Registration Fee (per person) Early Registration Fee: $440 After April 4, 2014: $460 Government Agency Rate: $355 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) 906-5090 for super discount pricing.

Registration Form: Federal Tax Institute 3 Easy Ways to Register Online: cle.kentlaw.edu Mail: Office of Continuing Legal & Professional Education 565 West Adams St. Chicago, IL 60661-3691 Phone: (312) 906-5090 Name (please print) Professional Title Firm Address City State Zip Telephone Fax Email Attorney Registration # Luncheon Ticket: qcheck here if you are purchasing a luncheon ticket for Thursday, May 1. 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: ) q Payment by credit card. Amount enclosed $ q VISA q MasterCard q American Express q Discover Card # Exp. Date Security Code Signature