The 21st annual Federal Tax Institute

» Accountants
» Lawyers
» Corporate Tax Directors and Staff

May 2-3, 2002

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.

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

Prior to his confirmation as chief counsel of the Internal Revenue Service in January, 2002, Mr. Williams was a partner at Shearman & Sterling where he represented clients in federal tax controversy and litigation matters. Formerly, Mr. Williams was a United States Tax Court judge, deputy assistant attorney general in the Tax Division of the Justice Department and special assistant to the chief counsel of the Internal Revenue Service. After serving on the bench, Mr. Williams was chairman of the tax section at Morgan, Lewis & Bockius where he led the tax litigation practice for 10 years. Mr. Williams received a B.A. from George Washington University in 1971 and a J.D. from George Washington University Law School in 1974.

THURSDAY, MAY 2, 2002

7:30-8:15
Registration

8:15-8:30
WELCOME
Harold J. Krent, Interim Dean and Professor of Law, 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

8:30-9:20
» Current Case Law & 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

9:20-9:30
BREAK

11:30
LUNCHEON

12:30-1:15
Keynote Speaker
B. John Williams, IRS Chief Counsel

AFTERNOON MODERATOR:
George B. Javaras, Kirkland & Ellis

COMMENTATOR
Jasper L. Cummings, Alston & Bird

1:30-2:15
» What’s New in Tax Free Spin-Offs
Recent developments affecting tax-free corporate spin-offs will be discussed, including new temporary regulations under Code Section 355(e) and significant published and private IRS rulings.
Todd F. Maynes, Kirkland & Ellis
Keith E. Villmow, Kirkland & Ellis

2:15-3:00
» Current Issues in Restructuring and Liquidating Troubled Companies
This presentation will explore current tax planning issues arising out of the restructuring of troubled companies in and out of bankruptcy for such companies, their shareholders and their creditors. It will analyze the important practical ramifications of the repeal of the stock-for-debt exception to cancellation of indebtedness income. The implications of these issues for the organization and operation of healthy companies will be noted. Finally, the specific tax issues arising from the liquidation of troubled companies will also be examined.
André LeDuc, Skadden, Arps, Slate, Meagher & Flom

3:00-3:10
BREAK

3:10-4:00
» Rite Aid: Rx for the Loss Disallowance Blues?
This session will assess the state of Reg. §1502-20 in the aftermath of Rite Aid Corp. v. U.S. Is the Federal Circuit's prescription just what the Doctor ordered, or is the cure simply not worth the treatment? This session will also review other recent developments regarding consolidated returns.
Kevin A. Halloran, Ernst & Young
Richard D. Liebman, Ernst & Young

4:00-5:30
» Defending Tax Advantaged Transactions
This session will cover recent developments in case law and practice before the IRS. The discussion will include strategies for implementing tax advantaged transactions with a view toward potential IRS challenges.
Daniel A. Dumezich, Mayer, Brown, Rowe & Maw
Kenneth L. Harris, Neal, Gerber & Eisenberg
Jonathan Zelnik, IRS Senior Legal Counsel for Tax Shelters, Large & Medium Size Business Division

Friday, May 3, 2002
8:30-9:20

» Partnerships: Hot Topics
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

9:20-9:30
BREAK

9:30-10:20
» Recent Developments in Executive Compensation
Key new developments and trends in executive compensation will be reviewed and analyzed.
Roger C. Siske, Sonnenschein Nath & Rosenthal

10:25-11:20
» Financial Products and Income Measurement
The speakers will discuss various developments in the taxation of financial instruments including the status of the Bank One case (involving valuation of swaps), the OID regulations relating to contingent payment debt, the IRS's recent attacks on stock monetization transactions, and the renewed focus on issuance of financial instruments which are treated as debt for tax purposes and quasi-equity for accounting purposes.
Michael A. Clark, Sidley Austin Brown & Wood
Thomas A. Humphreys, Sidley Austin Brown & Wood

11:20-12:25
BOX LUNCH

AFTERNOON MODERATOR:
Howard M. McCue III, Mayer, Brown, Rowe & Maw

12:30-1:20
» Real Estate Planning Including Use of REITs
The speakers will discuss various topics relating to real estate investment trusts (REITs), including the use of private REITs by pension fund investors to avoid UBTI and by foreign investors to avoid FIRPTA, new rules permitting REITs to engage in non-real estate activities through the formation of taxable REIT subsidiaries, and other recent tax developments affecting REITs.
Gregory R.A. Dahlgren, Piper Marbury Rudnick & Wolfe
Stephen M. Gordon, Piper Marbury Rudnick & Wolfe

1:30-2:20
» Some Random (and not so Random) Thoughts on Estate Planning after EGTRAA 2001
This session will discuss the effect of the new tax law on estate planning, including marital deduction planning and formulas, generation-skipping tax planning, lifetime gifts and other estate planning techniques. The talk will focus on the various scenarios for estate planning and how to plan for a client given the uncertain and changing status of the federal estate and gift tax law.
Richard A. Campbell, Duane Morris & Heckscher
Louis S. Harrison, Lord, Bissell & Brook

2:20-3:30
» Estate Planning for Stock Options and Non-Qualified Deferred Compensation
Both the disposition at death and transfers during lifetime will be considered. Opportunities to exchange one of these benefits for the other or for split dollar life insurance will be explained.
Jere D. McGaffey, Foley & Lardner
Michael H. Woolever, Foley & Lardner

General Information

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 5, 2002; 25% will be charged if notification is received between April 5 and April 26, 2002.  No refunds will be granted after April 26, 2002.

CLE/CPE Credit: 12.6 hours on a “60-minute” credit hour; 15.1 hours on a “50-minute” credit hour.  The actual number of approved hours may vary state to state.

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 W Hotel City Center. 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 W Hotel City Center is $199 for single or double occupancy, plus 14.9% tax.  The Executive Plaza Hotel is a short cab ride to the law school and provides easy access to Michigan Avenue night life and shopping. The W Hotel City Center is within walking distance of the law school. Requests for accommodations made after April 1, 2002 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, telephone or fax:

 The Executive Plaza Hotel                     The W Hotel City Center
 71 East Wacker Drive                           172 W. Adams Street
 Chicago, IL  60601-3706                       Chicago, IL 60603
 (800) 621-4005                                   (877) 946-8357
 Fax (312) 346-2787                              Fax (312) 917–5771

Graduate Program in Taxation Advisory Board

Louis S. Freeman
Partner, Skadden, Arps, Slate, Meagher & Flom

John E. Gaggini
Partner, McDermott, Will & Emery

Howard M. McCue III
Partner, Mayer, Brown, Rowe & Maw

John B. Palmer
Partner, Foley & Lardner

Roger C. Siske
Partner, Sonnenschein Nath and Rosenthal

Federal Tax Institute Advisory Board

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