The 24th annual Federal Tax Institute

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.

Current Case Law & Ruling Developments

Audit Documentation of Income Tax Provision Review and Valuation Allowance Considerations

Not Just Tax Shelters

International Planning Implications of the American Jobs Creation Act of 2004

Current Developments in Executive Compensation

Recent Developments in Corporate Taxation

Loss Disallowance Regulations: Through The Looking Glass Again

Cutting Edge M&A Strategies

Partnerships and LLCs - What’s Hot in 2005

States “Up the Ante”

Keynote Speaker

Director
Office of Professional Responsibility
Internal Revenue Service

Cono R. Namorato was named Director of the Office of Professional Responsibility by IRS Commissioner Mark Everson in December 2003. He came to the Internal Revenue Service from the Washington law firm of Caplin & Drysdale where he had been practicing criminal and civil tax law since 1978. He began his government career in 1963 as an IRS Special Agent in Brooklyn. In 1968, he transferred to the Justice Department’s Tax Division, rising to the position of Deputy Assistant Attorney General prior to joining the private sector in 1978.

While chair of the American Bar Association subcommittee on Criminal Tax Policy, Mr. Namorato co-authored and supervised completion of two reports on the IRS Criminal Investigation Division: The Future of the Criminal Investigation Division (1998) and Redirecting Criminal Tax Enforcement to Improve Voluntary Compliance (1991).

A Brooklyn native, Mr. Namorato earned a bachelor’s degree in accounting summa cum laude from Iona College in New Rochelle, NY, and a law degree from Brooklyn Law School.

The Program

Thursday, April 28, 2005

8:00 a.m.
Registration

8:30-8:45
WELCOME

Harold J. Krent
Dean and Professor of Law,
Chicago-Kent College of Law

Gerald Brown
Director, Graduate Program in Taxation and Clinical Professor of Law, Chicago-Kent College of Law

MODERATORS:

Jeffrey Frishman
Grant Thornton LLP

Todd Maynes
Kirkland & Ellis LLP
Institute Co-Chair

8:45-9:30 Recent Tax Law Developments

»This session will survey recent developments in case law and rulings in the federal income, estate and gift, and employee benefits tax areas

Lydia R.B. Kelley
McDermott, Will & Emery

9:30-11:00 Selected Current Topics in Tax Provisions - Audit Documentation of Income Tax Provision Review and Valuation Allowance Considerations

» Overview of the general standards tax professionals serving as experts on external audit teams use in auditing tax reserves and valuation allowances for multinational organizations

» General workpaper documentation requirements an external audit team must meet

Marilyn Gerdes
Vice President, Tax Dept. Sara Lee Corporation

Michael Gervasio
KPMG, LLP

Kenneth Hayduk
Tax Counsel,General Dynamics Corporation

11:00-11:15
BREAK

11:15-12:30 Not Just Tax Shelters

» Panel discussion on professional standards, Circular 230 and the tax opinion. When is an opinion needed and what good is it?

George W. Craven
Mayer Brown Rowe & Maw LLP

Jeffrey Frishman
Grant Thornton LLP

Hon. Joseph Goeke

United States Tax Court

12:00
LUNCHEON

1:00-2:00
Keynote Speaker
Cono R. Namorato
Director, Office of Professional Responsibility, Internal Revenue Service

MODERATOR:

Michael A. Clark
Sidley Austin Brown & Wood LLP

2:00-2:45 Current Developments in Executive Compensation

»This session will focus on new developments in executive compensation and include an overview of the fundamental changes and expansion of the tax rules and penalties dealing with deferred compensation under Internal Revenue Code §409A, and newly-effective rules requiring expensing of stock options.

»Other new developments in the executive compensation area will be summarized.

Roger C. Siske
Sonnenschein Nath & Rosenthal LLP

2:45-3:45 International Planning Implications of the American Jobs Creation Act of 2004

» Discussion of planning implications and tips aris- ing out of selected interna- tional provisions included in the American Jobs Creation Act of 2004

Barbara M. Angus
International Tax Counsel, U.S. Department of the Treasury

Jay H. Zimbler
Sidley Austin Brown & Wood LLP

3:45-4:00
BREAK

4:00-5:00 States “Up The Ante”

» Given record budget short- falls, states have mounted various efforts intended to increase revenues without raising taxes. Such efforts include closing perceived “loopholes,” cracking down on “tax shelters,” requiring the disclosure of detailed information, increasing penalties and coordinated information sharing programs with other states as well as the IRS.

» This session will discuss these developments and how they are changing the land- scape of state income tax administration and compliance.

John A. Biek
McDermott, Will & Emery

Theodore R. Bots
McDermott, Will & Emery

Friday, April 29, 2005

MODERATOR:

André LeDuc
Skadden, Arps, Slate, Meagher & Flom LLP
Institute Co-Chair

8:30-9:15 Recent Developments in Corporate Taxation

» Discussion of 2005’s recent developments and hot topics in corporate taxation

Christian E. Kimball
Jenner & Block LLP

9:15-10:05 The Loss Disallowance Regulations: Through The Looking Glass Again

» Discussion of recent developments and possible future directions for the Consolidated Return Loss Disallowance Regulations

Don W. Bakke
Ernst & Young LLP

Richard D. Liebman
Ernst & Young LLP

10:05-10:20
BREAK

10:20-11:40 Cutting Edge M&A Strategies

» Discussion of the latest trends in M&A tax structuring, as affected by the American Jobs Creation Act and recent IRS and Treasury pronouncements.

Jeffrey T. Sheffield
Kirkland & Ellis LLP

Eric Solomon
Deputy Assistant Secretary, U.S. Department of the Treasury

Thomas F. Wessel
KPMG LLP

11:40-12:30 Partnerships And LLCs -What’s Hot in 2005

» This session will explore creative tax planning and structuring techniques involving the use of partner- ships and LLCs and will cover 2005’s hot partnership and LLC developments

Steven G. Frost
Chapman & Cutler LLP

Charles R. Levun
Levun, Goodman & Cohen LLP

General Information

Program Location
The conference will be held at Chicago-Kent College of Law, 565 W. Adams Street in Chicago.

Confirmation of Registration
A letter of confirmation will be mailed to the address given on your registration form.

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, 2005; 25% will be charged if notification is received between April 4 and April 21, 2005. No refunds will be granted after April 22, 2005.

CPE Credit
12.6 hours on a “50-minute” credit hour. Chicago-Kent College of Law is a registered public accountant professional education sponsor in Illinois and New York.

MCLE Credit
10.5 hours on a “60-minute” credit hour; 12.6 hours on a “50-minute” credit hour. 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) 906-5090.

Hotel Accommodations
Hotel accommodations have been made at the Millennium Knickerbocker Hotel and the W Hotel City Center. The room rate at the Millennium Knickerbocker is $139 for single or double occupancy, plus 14.9% tax. The
room rate at the W Hotel City Center is $179 for single or double occupancy, plus 14.9% tax. The Millennium Knickerbocker 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 an upscale property located five blocks from the law school. Please make reservations directly with the hotel of your choice. Requests for accommodations cannot be assured if made after March 28, 2005. Please mention to the hotel reservation receptionist that you are attending the Chicago-Kent College of Law Federal Tax Institute. To make reservations:

Millennium Knickerbocker Hotel
163 E. Walton Place
Chicago, IL 60611
(800) 621-8140
Fax (312) 751-9663
www.millenniumhotels.com

W Hotel City Center
172 W. Adams Street
Chicago, IL 60603
(877) 946-8357
Fax (312) 917-5771
www.whotels.com

Registration Fee (per person) Early Registration Fee . . . . . . $365
After April 4, 2005. . . . . . . . . . . . . . . . . . . . . . . . . . . . . $395
(A $15 per person discount is available to groups that register 3 or more individuals at the same time.)
Government Rate. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .$295
(no group discount available)
Chicago-Kent College of Law Alumnae/i Rate . . . . . . . . . . . . $295
(no group discount available)
Fee includes two continental breakfasts, lunch on Thursday and course materials.

Click here to register online or print registration information.

Graduate Program in Taxation Advisory Board

Federal Tax Institute Advisory Board

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