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The 19th annual Federal Tax Institute
A Comprehensive Update by Leading Tax Experts
on Tax Planning, Compliance and Controversy Techniques & Issues for:
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Accountants
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Lawyers
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Corporate Tax Directors and Staff
May 4-5, 2000
Chicago-Kent College of Law
Illinois Institute of Technology
565 West Adams
Chicago, IL 60661-3691
ONLINE REGISTRATION AVAILABLE!
Click here
to register online or print registration information.
The 19th annual
Federal Tax Institute
This two day seminar is designed to keep
attorneys, accountants, corporate tax executives, business and tax advisors,
and other personnel up-to-date on the most current legislation, cases and
rulings affecting the federal tax sector. The Federal Tax Institute
features a comprehensive, yet concise program, presented by a faculty of
leading tax experts.
Program Highlights
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Stay on the cutting edge of federal tax changes
by attending sessions on:
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Current Case Law and Ruling Developments
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State Income Tax Pitfalls in Mergers, Acquisitions
and Dispositions of Businesses
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What’s New in Mergers, Acquisitions and Spin-Offs
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Corporate Tax Shelters: Policy, Planning and
Controversy
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Consolidated Return Planning: Use of LLC’s
and Other Sophisticated Techniques
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International Developments
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What’s New in Executive Compensation
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Partnerships: Planning for the Millennium
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Contingent Payments and Contingent Liabilities
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The State of the Art in Like Kind Exchanges
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Expanding the Frontiers of Creative Estate
Planning:
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Avant Garde Techniques Your Father Didn’t
Tell You About
Luncheon Speaker
Lee Sheppard, attorney, and contributing
editor for Tax Notes.
The Program
THURSDAY, MAY 4, 2000
8:00 - 8:45
REGISTRATION
8:45 - 9:00
WELCOME
Gerald Brown, Associate
Clinical Professor of Law and Director, Graduate Program in Taxation, Chicago-Kent
College of Law
MORNING:
Moderator
Evelyn Brody, Associate
Professor of Law, Chicago-Kent College of Law
9:00 - 10:00
Current Case Law and Ruling Developments
This session will survey 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
Lydia R.B. Kelley, McDermott, Will
& Emery
10:00 - 10:15
BREAK
10:15 - 11:15
State Income Tax Pitfalls in Mergers, Acquisitions
and
Dispositions of Businesses
This session will focus on traps
for the unwary tax practitioner that may arise in reorganizations, purchases,
or sales of a business as a result of differences between federal
tax and state tax laws. Items to be addressed include, issues arising
from different reporting methods (e.g., consolidated, combined, or separate),
the carryover of tax attributes (e.g.,
net operating losses and credits), and other potential pitfalls and opportunities.
John A. Biek, McDermott,
Will &
Emery
Theodore R. Bots, McDermott, Will
& Emery
John E. Gaggini, McDermott, Will
& Emery
11:15 - 12:05 What’s
New in Mergers, Acquisitions and Spin-Offs
Recent developments affecting
taxable and tax-free acquisition and disposition transactions will be discussed,
including repeal of the installment method for
accrual method taxpayers, new regulations under Code Section 1060 and 338
on asset acquisitions and stock purchases treated as asset acquisitions,
and new regulations on tax-free spin-offs
and split-offs regarding disqualifying distributions and related acquisitive
transactions.
Keith E. Villmow, Kirkland
& Ellis
12:15 - 1:45
LUNCHEON
Welcome
Henry H. Perritt,
Jr., Vice President, Illinois
Institute of Technology, Downtown Campus, Dean and Professor, Chicago-Kent
College of Law
Guest Speaker
Lee Sheppard,
Contributing Editor, Tax Notes
AFTERNOON: Moderator
George B. Javaras, Kirkland
& Ellis
Commentator
Jack S. Levin, Kirkland & Ellis
2:00 - 3:45
Corporate Tax Shelters: Policy, Planning and
Controversy
This panel will explore the policy
issues raised by corporate tax shelters and the recent legislative proposals
to address them, the planning parameters for
the use of tax advantaged financial products and related tax shelters and,
finally, the practical issues relating to the defense of corporate tax
shelters.
Moderator: André LeDuc,
Skadden, Arps, Slate, Meagher & Flom
Kenneth W. Gideon, Wilmer, Cutler
& Pickering, Washington, D.C.
Lee Sheppard, Tax Notes, New York
Sharp Sorensen, Sidley & Austin
Albert H. Turkus, Skadden, Arps,
Slate, Meagher & Flom, Washington, D.C.
3:45 - 4:00
BREAK
4:00 - 4:50
Consolidated Return Planning: Use of LLC’s and Other
Sophisticated Techniques
A discussion of the use of limited
liability companies by groups filing consolidated federal income tax returns
and other advanced planning techniques.
Richard D. Liebman, Ernst
& Young
FRIDAY, MAY 5, 2000
8:30 - 9:00
CONTINENTAL BREAKFAST
MORNING:
Moderator
Gerald Brown, Associate
Clinical Professor of Law and Director, Graduate Program in Taxation, Chicago-Kent
College of Law
9:00 - 9:50
International Developments
Recent significant regulations
and IRS pronouncements concerning Subpart F, foreign tax credits, and the
check-the-box rules, and judicial trends in applying substance-over-form
doctrines to international transactions and structures.
Lowell D. Yoder, McDermott,
Will & Emery
9:50 - 10:45
What’s New in Executive Compensation
A review of new developments,
planning opportunities as well as tax and accounting developments in the
executive compensation arena. Discussions will include
stock option exercises with deferred taxation and the FASB changes of equity
accounting rules under the repairs and maintenance project (which is
reinterpreting APB No. 25).
Michael Kesner, Arthur
Andersen
Roger Siske, Sonnenschein, Nath
& Rosenthal
10:45 - 11:00
BREAK
11:00 - 11:50
Partnerships: Planning for the Millenium
This session will explore creative
tax planning techniques involving the use of partnerships and LLCs and
hot partnership and LLC developments.
Charles R. Levun, Levun,
Goodman & Cohen
12:00 - 1:15
LUNCH ON YOUR OWN
AFTERNOON: Moderator
Bradford L. Ferguson, Sidley
& Austin
1:30 - 2:30
Contingent Payments and Contingent Liabilities
This session will consider the
tax treatment of contingencies in the case of income, deductions, and sales
of assets. Recent developments will be considered, including proposed
regulations under section 338(h)(10) and the repeal of the installment
method for accrual basis taxpayers.
Michael L. Schler, Cravath,
Swaine & Moore, New York
2:30-2:45
BREAK
2:45 - 3:45
The State of the Art in Like-Kind Exchanges
There has been a renewed interest
in like-kind exchanges because such transactions are one of the few remaining
avenues available for taxpayers to defer taxation.
This presentation will address the major issues in like-kind exchanges
and practical means that have been
developed to resolve potential problems.
Richard M. Lipton, McDermott,
Will & Emery
3:45 - 4:45
Expanding the Frontiers of Creative Estate Planning:
Avant
Garde Techniques Your Father Didn’t Tell You About
This segment will explore five
estate tax strategies not currently discussed in published literature
or in other sources. The intent is to introduce and discuss new gift
and estate tax strategies, many of which are of yet unfamiliar to most
estate and tax practitioners. The strategies will be discussed using
both text and spreadsheet analysis. The underlying mathematics of
certain of these strategies will be explored in detail. As these
concepts have not yet been reviewed or ruled on by the Service, potential
concerns in this area will be evaluated. The last part of the discussion
will be on the prototype to use for
each of these strategies.
Louis S. Harrison, Lord,
Bissell & Brook
General Information
Confirmation of Registration: A
letter will be mailed to you at the address given on your registration
form. No other confirmation of your registration will be provided.
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 7, 2000; 25% will be charged
if notification is received between April 7 and April 28, 2000. No
refunds will be granted after April 28, 2000.
CLE/CPE Credit: 11.0 hours on a
“60-minute” credit hour; 13.2 hours on a
“50-minute” credit hour.
For Additional Information: Please
call the Office of Continuing Legal and Professional Education, Chicago-Kent
College of Law, (312) 906-5090.
Hotel Accommodations: Hotel accommodations
have been made at The Executive
Plaza Hotel and The
Regal Knickerbocker Hotel. Registrants are responsible for making
their own reservations. The room rate at the Executive Plaza is $119 for
single or double occupancy, plus 14.9% tax. The room rate at the Regal
Knickerbocker is $185 for single or double occupancy, plus 14.9% tax.
Both hotels are a short cab ride to the law school and provide easy access
to Michigan Avenue night life and shopping. Requests for accommodations
made after April 3, 2000 cannot be assured. Be sure to tell the
hotel reservation receptionist that you are attending the Chicago-Kent
College of Law Federal Tax Institute. To make reservations, fax or
telephone:
The Executive Plaza Hotel
The Regal Knickerbocker Hotel
71 East Wacker Drive
163 E. Walton Place
Chicago, IL 60601-3706
Chicago, IL 60611
(800) 621 - 4005
(800) 621 - 8140
Fax (312) 346 - 2787
Fax (312) 751 – 9663
Can't Attend
r I am unable
to attend, but wish to order the course materials
(Cost- $100. Payment must be remitted
in advance)
r I am unable
to attend, but wish to order the audiocassette(s)
(Cost-$35 per session. Payment must
be remitted in advance)
List sessions:
Graduate
Program in Taxation Advisory Board
George B. Javaras,
Graduate Program Chair
Chairman of the Institute Planning Committee,
Partner, Kirkland & Ellis
Bradford L. Ferguson
Partner, Sidley & Austin
Louis S. Freeman
Partner, Skadden, Arps, Slate, Meagher
& Flom
John E. Gaggini
Partner, McDermott, Will & Emery
Frederic W. Hickman
Of Counsel, Hopkins & Sutter
Howard M. McCue III
Partner, Mayer, Brown & Platt
John B. Palmer
Partner, Hopkins & Sutter
John S. Pennell
Of Counsel, McDermott, Will & Emery
Roger C. Siske
Partner, Sonnenschein Nath and Rosenthal
Federal Tax Institute
Advisory Board
John A. Biek
McDermott, Will & Emery
Gerald Brown
Chicago-Kent College of Law
Richard A. Campbell
Jenner & Block
Michael A. Clark
Sidley & Austin
Denis J. Conlon
Ernst & Young
Phyllis A. Ewer
Sonnenschein Nath and Rosenthal
Kevin J. Feeley
McDermott, Will & Emery
Bradford L. Ferguson
Sidley & Austin
Louis S. Freeman
Skadden, Arps, Slate, Meagher & Flom
John E. Gaggini
McDermott, Will & Emery
Frederic W. Hickman
Hopkins & Sutter
George B. Javaras
Kirkland & Ellis
Lydia R. B. Kelley
McDermott, Will & Emery
Leslie A. Klein
Sonnenschein Nath and Rosenthal
André LeDuc
Skadden, Arps, Slate, Meagher & Flom
Charles R. Levun
Levun, Goodman & Cohen
Richard D. Liebman
Ernst & Young
Todd F. Maynes
Kirkland & Ellis
Howard M. McCue III
Mayer, Brown & Platt
Nicholas R. Minear
Rudnick & Wolfe
John B. Palmer III
Hopkins & Sutter
Annette M. Rehmke
Deloitte & Touche
Jeffrey G. Sherman
Chicago-Kent College of Law
Harvey M. Silets
Katten, Muchin & Zavis
Roger C. Siske
Sonnenschein Nath and Rosenthal
Thomas M. Stephens
Sonnenschein Nath & Rosenthal
Steven W. Swibel
Schwartz, Cooper, Greenberger & Krauss,
Chartered
Keith E. Villmow
Kirkland & Ellis
Jeffrey C. Wagner
McDermott, Will & Emery
Joel W. Williamson
Mayer, Brown & Platt
Lowell D. Yoder
McDermott, Will & Emery
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