The 20th annual Federal Tax Institute
A Comprehensive Update by Leading Tax Experts on Tax Planning, Compliance and Controversy Techniques
& Issues for:
- Accountants
- Lawyers
- Corporate Tax Directors and Staff
May 3-4, 2001
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 20th 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
- Current Case Law and
Ruling Developments
- Future Benefits and
Other Tax Accounting Mysteries
- Recent Developments
in Executive Compensation
- What’s New in Mergers,
Acquisitions and Spin-Offs
- Consolidated Returns
- Corporate Tax Shelters:
Filing the Return and Defending It
- Impact of IRS Restructuring
on Audits and Compliance
- Joint Venture Planning:
Tax-Advantageous ECommerce
- Structuring Techniques
- State and Local Tax
Aspects of ECommerce
- International Joint
Ventures: Including the Rise of ECommerce
- Recent Developments
Affecting S Corporations
- Year 2001: What’s Really
New (and Important) in Estate Planning?
Luncheon Speaker
Kenneth J. Kies,
PricewaterhouseCoopers LLP
Mr. Kies is a co-managing
partner of the PricewaterhouseCoopers LLP Washington National Tax Services
office in Washington, D.C. He is chair of the Federal Tax Policy Group
which provides sophisticated, strategic, and technical tax advice on tax
policy matters before the Congress, the U.S. Treasury Department, the Internal
Revenue Service, and the OECD. Mr. Kies served as the chief-of-staff of
the Congressional Joint Committee on Taxation from 1995-1998. Prior to
becoming chief-of-staff of the Joint Committee on Taxation, he was the
firmwide chair of the tax practice for Baker
& Hostetler.
The Program
THURSDAY, MAY
3, 2001
8:00 - 8:45
REGISTRATION
8:45 - 9:00
WELCOME
Henry H. Perritt, Jr.,
Vice President, Illinois Institute of Technology, Downtown Campus, Dean
and Professor, Chicago-Kent College of Law
MORNING:
Moderator
Gerald
Brown, Associate Clinical Professor of Law and Director, Graduate Program
in Taxation, Chicago-Kent College of Law
9:00 - 9:50
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
9:50
- 10:00 BREAK
10:00
- 10:55 Future Benefits
and Other Tax Accounting Mysteries
This presentation
will examine recent developments affecting the timing
of reporting items of income and deduction. It will include an in-depth
focus on recent cases that dramatically narrow the scope of the Supreme
Court’s INDOPCO decision, including the Norwest and PNC Bancorp decisions.
John
B. Palmer III, Foley & Lardner
10:55 - 11:50
Recent Developments in Executive Compensation
Key new
developments and trends in executive compensation will be reviewed and
analyzed.
Roger
Siske, Sonnenschein, Nath & Rosenthal
12:00
- 1:00
LUNCHEON
1:00 - 1:40
Keynote Speaker
Kenneth
J. Kies,
PricewaterhouseCoopers
LLP
AFTERNOON:
Moderator
George
B. Javaras, Kirkland & Ellis
Commentator
Robert Willens, Lehman Brothers
1:50 - 2:40
What’s New in Mergers, Acquisitions and Spin-Offs
Recent developments
affecting taxable and tax-free acquisition and disposition transactions
will be discussed, including reinstatement of the installment method for
accrual method taxpayers, new regulations under Code Section 368 on the
continuity-of-interest requirement and the use of disregarded entities
in tax-free reorganizations, and replacement of 1999 proposed regulations
under Code Section 355(e) on tax-free spin-offs and split-offs with new,
substantially revised proposed regulations.
Keith
E. Villmow, Kirkland & Ellis
Robert
Willens, Lehman Brothers
2:40 - 3:20
Consolidated Returns
A review
of recent developments and other topics including the uses and abuses of
tax sharing agreements.
Kevin
A. Halloran, Ernst & Young LLP
Richard D. Liebman,
Ernst
& Young LLP
3:20
- 3:30
BREAK
3:30 - 5:00
Corporate Tax Shelters: Filing the Return and Defending
It
This panel discussion will explore
the IRS’s definition of a corporate tax shelter, tax return disclosure
of corporate tax shelters required by the IRS, and strategies for resolvingcorporate
tax shelter issues raised by the IRS.
Joseph Bankman, Stanford
Law School
Linda B. Burke,
Internal
Revenue Service
Kenneth J. Kies,
PricewaterhouseCoopers
LLP
Joel V. Williamson,
Mayer, Brown & Platt
5:00 - 5:30
Impact of IRS Restructuring on Audits and Compliance
Linda B. Burke, Internal
Revenue Service
FRIDAY, MAY 4, 2001
8:00 - 8:30
CONTINENTAL BREAKFAST
MORNING:
Moderator
Evelyn
Brody, Associate Professor of Law, Chicago-Kent College of Law
8:30 - 9:20
Joint Venture Planning: Tax-Advantageous
ECommerce
Structuring Techniques
This session
will discuss the use of LLCs and partnerships in conjunction with C corporations
and S corporations to facilitate the creation of tax-advantageous ECommerce
enterprises.
Charles
R. Levun, Levun, Goodman & Cohen
9:25 - 10:15
State
and Local Tax Aspects of ECommerce
The rise
of electronic commerce has created a host of difficult state and local
tax issues for ECommerce businesses, tax administrators and tax practitioners.
Many Internet start-up joint ventures and retail websites for established
businesses are being set up without adequate attention to the state tax
ramifications of these business structures. This session will explore
nexus, allocation/apportionment and related planning issues affecting ECommerce
businesses and their owners.
John A. Biek, McDermott, Will & Emery
Theodore R. Bots, McDermott, Will & Emery
10:15
- 10:30 BREAK
10:30 - 11:20
International Joint Ventures
With the
rise of ECommerce and its global reach, international joint ventures have
become a necessity, especially in the B2B space. This session will
discuss significant international tax considerations of joint ventures
including Sec. 367, Subpart F and foreign tax credits. The session
will also focus on special issues that arise with ECommerce,
including the choice of entity/ jurisdiction issues,
income source and characterization issues, taxable presence determinations
and planning for
the ownership of
intangibles.
Annette M. Rehmke, Deloitte & Touche
Lowell D. Yoder, McDermott, Will & Emery
11:30
- 1:00 LUNCH ON YOUR OWN
AFTERNOON:
Moderator
Howard
M. McCue III, Mayer, Brown & Platt
1:00 - 1:50
Recent Developments Affecting S Corporations
This presentation
will discuss recent developments affecting the taxation of S corporations
and their shareholders, and the continuing utility of S corporations.
Nicholas
R. Minear, Piper Marbury Rudnick & Wolfe
1:50
- 2:00 BREAK
2:00 - 2:50
Year 2001: What’s Really New (and Important)
in Estate
Planning?
The panel
will answer your questions on any estate planning topics and discuss the
latest in advanced planning techniques, including new legislation (if any),
gift tax valuation cases, and other cases and rulings. You may submit
questions in advance of the Tax Institute to any of the panel members at:
sbart@sidley.com, lharrison@lordbissell.com, or steven.b.weinstein@us.arthurandersen.com.
Susan
T. Bart, Sidley Austin Brown & Wood
Louis S. Harrison,
Lord, Bissell & Brook
Steven B. Weinstein,
Arthur
Andersen
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 6, 2001; 25% will be charged
if notification is received between April 6 and April 27, 2001. No
refunds will be granted after April 27, 2001.
CLE/CPE Credit: 11.0 hours on a
“60-minute” credit hour; 13.0 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 Knickerbocker
Hotel. Registrants are responsible for making their own reservations.
The room rate at the Executive Plaza is $129 for single or double occupancy,
plus 14.9% tax. The room rate at the 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, 2001 cannot
be assured. The Knickerbocker Hotel has a 48 hour cancellation policy.
Be sure to tell the hotel reservation receptionist that you are attending
the Chicago-Kent College of Law Federal Tax Institute. To make reservations,
telephone or fax:
The Executive Plaza Hotel
The 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- $105. Payment must be remitted
in advance)
r I am unable
to attend, but wish to order the audiocassette(s)
(Cost-$ 40 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 Brown & Wood
Louis S. Freeman
Partner, Skadden, Arps, Slate, Meagher
& Flom
John E. Gaggini
Partner, McDermott, Will & Emery
Howard M. McCue III
Partner, Mayer, Brown & Platt
John B. Palmer
Partner, Foley & Lardner
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
Duane Morris & Heckscher LLP
Michael A. Clark
Sidley Austin Brown & Wood
Denis J. Conlon
Ernst & Young
Phyllis A. Ewer
Sonnenschein Nath and Rosenthal
Kevin J. Feeley
McDermott, Will & Emery
Bradford L. Ferguson
Sidley Austin Brown & Wood
Louis S. Freeman
Skadden, Arps, Slate, Meagher & Flom
John E. Gaggini
McDermott, Will & Emery
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
Foley & Lardner
Annette M. Rehmke
Deloitte & Touche
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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