The 26th 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.

»Federal Tax Law Developments

»State and Local Tax Developments

»Compensation Update

»Procedural Developments: Audits, Appeals, Pre-Filing Agreements, Private Letter Rulings and Joint Committee Review

»Accounting for Income Taxes

»Corporate Reorganizations, Spin Offs, and Merger & Acquisition Transactions: Tax Planning for Healthy Corporations

»Current Planning Opportunities with Partnerships

»Dealing with the New IRS: Lessons for the Mainstream from the First Decade after ACM

»International Tax Developments

Thursday, May 3, 2007

8:00 a.m.
REGISTRATION

8:35-8:45
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

MODERATOR: Todd Maynes, Kirkland & Ellis LLP, Institute Co-Chair

8:45-10:15

Federal Tax Law Developments
» 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

State and Local Tax Developments
» current hot-button issues in state taxation and recent legislative and case law developments

John A. Biek, Neal, Gerber & Eisenberg LLP
Theodore R. Bots, Baker & McKenzie LLP

10:15-10:30
BREAK

10:30-12:00

Compensation Update
» the latest developments in executive compensation including the highly anticipated 409A regulations which are scheduled to be released in early 2007

Diane V. Dygert, Seyfarth Shaw LLP

Procedural Developments: Audits, Appeals, Pre-Filing Agreements, Private Letter Rulings and Joint Committee Review
» current approach to tax compliance by the IRS, including its comprehensive transparency regime, use of more effective processes, targeting of specific issues for scrutiny and collaboration with other tax authorities and use of alternative dispute resolution options to resolve tax disputes earlier in the controversy process

Vincent S. Canciello, Ernst & Young LLP

Developments in Accounting for Income Taxes
» an overview of FASB Interpretation No. 48. This interpretation clarifies the accounting for uncertainty in income taxes recognized in an enterprise’s financial statements in accordance with FASB Statement No. 109, Accounting for Income Taxes. This interpretation prescribes a recognition threshold for the financial statement recognition and measurement of a tax position taken or expected to be taken in a tax return. Moreover, this Interpretation prescribes detailed disclosure requirements related to the recognition and derecognition of tax benefits in financial statements.

Michael Gervasio, KPMG LLP

12:00
LUNCHEON

1:15-2:00

KEYNOTE
Current Developments at the Treasury Department
Honorable Eric Solomon, Assistant Secretary for Tax Policy, U.S. Treasury

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

2:10-4:00

Corporate Reorganizations, Spin Offs and Merger & Acquisition Transactions: Tax Planning for Healthy Corporations
» focus on recent developments relating to corporate transactions, including regulations and rulings concerning tax-free reorganizations, spinoffs, section 351, and consolidated returns

Donald Rocap, Kirkland & Ellis LLP
Michael Schler, Cravath, Swaine & Moore LLP
Eric Solomon, Assistant Secretary for Tax Policy, U.S. Treasury

4:00-4:15
BREAK

4:15-5:30

Current Planning Opportunities with Partnerships
» discussion of the current issues, pitfalls and techniques for private equity and hedge funds as well as other current planning issues

Paul D. Carman, Chapman & Cutler LLP
Jeffrey A. Greenblatt, Skadden, Arps, Slate, Meagher & Flom LLP
Charles R. Levun, Levun, Goodman & Cohen, LLP, Moderator
William S. McKee, McKee Nelson LLP, Commentator

5:30-5:45
QUESTIONS

Friday, May 4, 2007

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

8:45-10:45

Dealing with the New IRS: Lessons for the Mainstream from the First Decade after ACM

The IRS Perspective

Donald Korb, Chief Counsel, Internal Revenue Service

The Judicial Perspective
Diane L. Kroupa, Judge, U.S. Tax Court

The Taxpayer’s Perspective
James M. Lynch, Winston & Strawn LLP

The Economic Substance Doctrine
» current state of play in economic substance doctrine, including recent trends, where the doctrine may be headed, and what it means for tax planning

Daniel Shaviro, Wayne Perry Professor of Taxation, New York University School of Law

10:45-11:00
BREAK

11:00-12:30

International Tax Developments
» hot topics will include: foreign tax credit; transfer pricing (services, global dealing, cost sharing, and outbound reorganizations under section 367 (d)); subpart F (CFC lookthru under section 954 (c)(6), substantial assistance, contract manufacturing); loss limitations (section 1503(d), section 987)

Karen Cederoth, Deloitte

John Harrington, Deputy International Tax Counsel, U.S. Treasury

Hal Hicks, Skadden, Arps, Slate, Meagher & Flom LLP

Steven A. Musher, Associate Chief Counsel, International,
Internal Revenue Service

12:30-12:45
QUESTIONS

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 6, 2007; 25% will be charged if notification is received between April 6 and April 27, 2007. No refunds will be granted after April 27, 2007. If you register with a purchase order or a voucher and do not cancel your registration in accordance with this policy, you will be charged 25% of the registration fee.

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

MCLE Credit
Chicago-Kent College of Law is an accredited CLE provider for Illinois MCLE. This conference is eligible for 10.0 hours on a “60-minute” credit hour; 12.0 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, or send an email to clestaff@kentlaw.edu.

Hotel Accommodations
Hotel accommodations have been made at the Crowne Plaza Chicago Metro and the Club Quarters, Central Loop. The room rate at the Crowne Plaza Chicago Metro is $175 for single or double occupancy, plus 15.4% tax. The room rate at the Club Quarters is $148 for a Superior room plus 15.4% tax. The Club Quarters, Central Loop is a no frills accommodation located in the heart of the financial district just minutes from Michigan Avenue and a short walk to Symphony Center, the Art Institute, and Board of Trade. The Crowne Plaza Chicago Metro is a trendy newly renovated property located four blocks west of the law school.

Please make reservations directly with the hotel of your choice. Requests for accommodations cannot be assured if made after April 2, 2007 at the Crowne Plaza Chicago Metro and March 22, 2007 at the Club Quarters. Please mention to the hotel reservation receptionist that you are attending the
Chicago-Kent College of Law Federal Tax Institute.

To make reservations:

Crowne Plaza Chicago Metro
733 W. Madison
Chicago, IL 60661
(312) 829-5000
Fax (312) 602-2180
www.crowneplaza.com/chicagometro

Club Quarters, Central Loop
111 W. Adams Street
Chicago, IL 60603
(312) 214-6400
Fax (312) 601-3300
www.clubquarters.com
To make reservations with the Club Quarters:
Please use group code “IIT502”

Registration Fee (per person)
Early Registration Fee . . . . . . . . . . . . . . . . . . . . . . . . . . $425
After March 30, 2007 . . . . . . . . . . . . . . . . . . . . . . . . . . .$450
(A $15 per person discount is available to groups that register 3 or more individuals at the same time.)
Government Rate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .$350
(no group discount available)
Chicago-Kent College of Law Alumnae/i Rate . . . . . . . . . . . .$350
(no group discount available)

Click here to register online or print registration information.

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