The 27th annual Federal Tax Institute
The Institute is an advanced level program designed for experienced practitioners. Attorneys, accountants, corporate tax directors and staff
May 1-2, 2008
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.
Nationally recognized tax advisors provide a comprehensive update on recent developments and their impact on tax planning, compliance and controversy techniques
HIGHLIGHTS
»Federal Tax Law Developments
»State and Local Tax Developments
»Procedural Update: Audits, Appeals, Pre-Filing Agreements, Private Letter Rulings and Joint Committee Review
»Financial Accounting for Tax
»Corporate Reorganizations, Spin Offs, and Merger & Acquisition Transactions: Tax Planning for Healthy Corporations
»Financial Instruments: Taxation of Stock, Debt, Hybrids and Derivatives
»New Incentives: New Energy Credits, Partnership Issues, Castle Harbor, Tax Shelter and Planning Issues
»International Tax Developments
»Circular 230 Ethical Issues
INSTITUTE
MODERATORS AND CO-CHAIRS:
André LeDuc, Skadden, Arps, Slate, Meagher & Flom
LLP
Todd Maynes, Kirkland & Ellis LLP
KEYNOTE
SPEAKER:
Honorable Eric Solomon, Assistant Secretary for Tax Policy,
U.S. Treasury
INSTITUTE
SPEAKERS AND PANELISTS:
John A. Biek, Neal, Gerber & Eisenberg LLP
Theodore R. Bots, Baker & McKenzie LLP
Robert Brazzil, Deloitte
Evelyn Brody, Chicago-Kent College of Law
Michael R. Fayhee, McDermott, Will & Emery LLP
Jeffrey B. Frishman, Grant Thornton, LLP
Stephen Gordon, Cravath, Swaine & Moore LLP
Kenneth L. Harris, Neal Gerber & Eisenberg LLP
Lydia R.B. Kelley, McDermott, Will & Emery LLP
Joseph Kronsnoble, Latham & Watkins, LLP
Simon Moore, Ernst & Young
Sean Moran, Dewey Ballantine LLP
Fred Murray, Grant Thornton LLP
Steven A. Musher, Internal Revenue Service
Andrew Ratts, Winston & Strawn LLP
Edward Sair, Deloitte
Timothy Sherck, Mayer, Brown, Rowe & Maw LLP
Eric Solomon, Assistant Secretary for Tax Policy, U.S. Treasury
Thomas Zollo, KPMG LLP
PROGRAM
SCHEDULE
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
INSTITUTE 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
Michael R. Fayhee, McDermott, Will & Emery LLP
Lydia R.B. Kelley, McDermott, Will & Emery LLP
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
10:30-10:45
BREAK
10:45-12:15
Procedural Update: Audits, Appeals, Pre-Filing Agreements, Private Letter Rulings and Joint Committee Review
» summary and implications of currently evolving practices and procedures at the IRS. Topics will include the new Industry Issue Focus program which is designed to provide national control over the field development and resolution of Tier I, II, and III issues; updates on the penalty administration by the IRS, Fast Track Appeals, Pre-Filing Agreements and the “policy of restraint” regarding tax accrual/Fin 48 workpapers
Robert Brazzil, Deloitte
Financial Accounting for Tax
» recent developments in the presentation of taxes in financial statements with a focus on FIN 48, the more-likely-than-not standard and tax opinions, and other issues affecting tax practitioners who work with auditors and audited clients.
Fred Murray, Grant Thornton LLP
12:20-1:20
LUNCHEON
Institute Moderator
André LeDuc, Skadden, Arps, Slate, Meagher & Flom LLP, Institute Co-Chair
1:30-2:15
KEYNOTE
Edward Kleinbard, Chief of Staff, Joint Committee on Taxation
2:15-4:15
Corporate Reorganizations, Spin Offs and Merger & Acquisition Transactions: Tax Planning for Healthy Corporations
» problems and issues arising from new and proposed regulations and proposals dealing with reorganization transactions, section 351 exchanges and section 355 spin-offs
Stephen Gordon, Cravath, Swaine & Moore LLP
Timothy Sherck, Mayer, Brown, Rowe & Maw LLP
Eric Solomon, Assistant Secretary for Tax Policy, U.S. Treasury
4:15-5:15
Financial Instruments: Current Topics in the Taxation of Stock, Debt, Hybrids & Derivatives
» discussion of prepaid forward contracts, total return swaps, convertible note – board hedges, distressed debt and other current topics
Joseph Kronsnoble, Latham & Watkins LLP
Edward Sair, Deloitte
5:15-5:30
QUESTIONS & ANSWERS
Friday, May 2, 2008
Institute Moderator
Evelyn Brody, Chicago-Kent College of Law
8:45-10:00
New Incentives in the Current Environment: New Energy Credits, Partnership Issues, Castle Harbor, Tax Shelter and Planning Issues
» recent legislation and IRS pronouncements relating to energy and infrastructure assets, with an emphasis on the impact such new law has on investments in renewables (e.g., wind, solar and geothermal facilities)
Sean Moran, Dewey Ballantine LLP
Andrew Ratts, Winston & Strawn
10:00-10:15
BREAK
10:15-11:45
International Tax Developments
» current developments in U.S. international taxation, including those with respect to contract manufacturing, accounting for foreign tax credits, outbound transfers of intangibles, and costs sharing
Simon Moore, Ernst & Young
Steven A. Musher, Associate Chief Counsel, International, Internal Revenue Service
Thomas Zollo, KPMG LLP
11:45-1:00
Circular 230 Ethical Issues: Return Preparer Standards and Circular 230 Ethical Issues – The Continued Emphasis on Accountability in Professional Behavior
» the professional standards landscape in tax matters continues to evolve with the enactment of increased tax return preparer standards under Internal Revenue Code section 6694 and robust oversight of tax professionals under Treasury Circular 230 through the Office of Professional Responsibility. What does the continuing focus on standards mean for tax professionals, taxpayer clients, and the relationship between them? This session will address significant issues in tax ethics underscoring the government’s drive for accountability for professional behavior in tax matters
Jeffrey B. Frishman, Grant Thornton LLP
Kenneth L. Harris, Neal Gerber & Eisenberg 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, 2008; 25% will be charged if notification is received between April 4 and April 25, 2008. No refunds will be granted after April 25, 2008. 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
13.0 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 11.0 IL MCLE hours, including 1.0 hour of ethics. 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. The room rate at the Crowne Plaza Chicago Metro is $179 for single or double occupancy, plus 15.4% tax. 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. Requests for accommodations cannot be assured if made after April 2, 2008. 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
Please mention to the hotel reservation receptionist that you are attending the “Chicago-Kent College of Law Federal Tax Institute”
Registration Fee (per person)
Early Registration Fee . . . . . . . . . . . . . .
. . . . . . . . . . . . $430
After March 31, 2008 . . . . . . . . . . . . . . . . . . . . . . . . . . .$450
(A $15 per person discount is available to groups that register 3 or more individuals at the same time.)
Government Rate . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . .$355
(no group discount available)
Chicago-Kent College of Law Alumnae/i Rate . . . . . . . . . .
. .$355
(no group discount available & non-transferable)
Click
here to register online or print registration information.
LL.M. Program in Taxation Advisory Board
Michael A. Clark
Partner, Sidley Austin LLP
Daniel A. Dumezich
Mayer, Brown, Rowe & Maw LLP
Louis S. Freeman
Partner, Skadden, Arps, Slate, Meagher & Flom LLP & Affiliates
John E. Gaggini
Partner, McDermott, Will & Emery
Todd F. Maynes
Partner, Kirkland & Ellis LLP
Howard M. McCue III
Partner, Mayer, Brown, Rowe & Maw LLP
John B. Palmer III
Partner, Foley & Lardner
FEDERAL TAX INSTITUTE PLANNING COMMITTEE
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John A. Biek
Neil, Gerber & Eisenberg LLP
Theodore R. Bots
Baker & McKenzie LLP
Evelyn Brody
Chicago-Kent College of Law
Gerald Brown
Chicago-Kent College of Law
Michael A. Clark
Sidley Austin LLP
Denis J. Conlon
Martin, Brown & Sullivan, Ltd.
Daniel A. Dumezich
Mayer, Brown, Rowe & Maw LLP
Louis S. Freeman
Skadden, Arps, Slate, Meagher & Flom LLP
Jeffrey B. Frishman
Grant Thornton LLP
Steven G. Frost
Chapman & Cutler LLP
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Gregory W. Gallagher
Kirkland & Ellis LLP
David Hoffman
Deloitte
Lydia R. B. Kelley
McDermott, Will & Emery
Joseph M. Kronsnoble
Latham & Watkins, LLP
André LeDuc
Skadden, Arps, Slate,
Meagher & Flom LLP,
Institute Co-Chair
Charles R. Levun
Levun, Goodman & Cohen, LLP
Richard D. Liebman
Ernst & Young LLP
Todd F. Maynes
Kirkland & Ellis LLP
Institute Co-Chair
Howard M. McCue III
Mayer, Brown, Rowe & Maw LLP
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Jeffrey L. Olin
Grant Thornton LLP
John B. Palmer III
Foley & Lardner
Kevin R. Pryor
Sidley Austin LLP
Michael Robinson
Winston & Strawn LLP
Steven W. Swibel
Schwartz Cooper Greenberger & Krauss
Deborah T. Villa
Chicago-Kent College of Law
Louis J. Weber III
Winston & Strawn LLP
Thomas Zollo
KPMG LLP
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