http://events.nysba.org/annual-meeting-expo-2020-tax-section/

Date: Tuesday, January 28, 2020

Program Co-Sponsored By:

Business Meeting and Election of Officers: 8:45 a.m. | Trianon Ballroom

Meeting Program: 9:15 a.m. - 4:00 p.m. | Trianon Ballroom, Rendezvous Ballroom, Grand Ballroom, 3rd Floor |5.0 MCLE Credits

[This program is transitional and is suitable for all attorneys including those newly admitted.]

Concurrent Sessions #1

9:15 a.m. - 10:30 a.m. Recent Partnership Tax Developments: Uncertainties and Opportunities (1.5 Credits in Areas of Professional Practice)

This panel will discuss partnership continuations and terminations after the repeal of the technical termination rules, debt allocation rules under the disguised sale regulations and bottom dollar guarantees, carried interests under Section 1061 and the need for guidance and other recent developments in partnership taxation.

Panel Chair: Amanda H. Nussbaum, Esq., Proskauer Rose LLP, New York, NY

Panelists: David W. Mayo, Esq., Paul, Weiss, Rifkind, Wharton & Garrison LLP, New York, NY; Holly Porter, Esq., Associate Chief Counsel (Passthroughs and Special Industries), Internal Revenue Service, Washington, DC [Invited]; John Rooney, Esq., KPMG LLP, Washington, DC

9:15 a.m. - 10:30 a.m. Empire State Update: Recent Developments in New York State Taxes (1.5 Credits in Areas of Professional Practice)

A lot is happening in the area of New York State and local taxation! Join us for a discussion of recent developments, including an update on New York’s draft corporate income tax regulations, newly issued administrative guidance, as well as some important decisions issued by the New York State Division of Tax Appeals and New York State judicial courts.

Panel Chair: Jack Trachtenberg, Esq., Deloitte Tax LLP, New York, NY

Panelists: Megan L. Brackney, Esq., Kostelanetz & Fink LLP, New York, NY; Deborah R. Liebman,Esq., Deputy Counsel, Office of Counsel, New York State Department of Taxation and Finance, Albany, NY [Invited]; Alysse B. McLoughlin, Esq., McDermott Will & Emery LLP, New York, NY

10:30 a.m. - 10:45 a.m. Break

Concurrent Sessions #2

10:45 a.m. - 12:00 p.m. Here Comes the Sun: Coping with Loss and Separation in M&A Tax (1.5 Credits in Areas of Professional Practice)

Join us for a discussion of current topics relevant to M&A taxation. In particular, this panel will address recently proposed regulations under Section 382(h) as well as current developments and other issues impacting corporate separations, including leverage in spin-offs and the continuing role of the “device” prohibition.

Panel Chair: Tijana J. Dvornic, Esq., Wachtell, Lipton, Rosen & Katz, New York, NY

Panelists: Shane J. Kiggen, Esq., Ernst & Young LLP, Washington, DC; David M. Rievman, Esq., Skadden, Arps, Slate, Meagher & Flom LLP,
New York, NY; Robert H. Wellen, Esq., Associate Chief Counsel (Corporate), Internal Revenue Service, Washington, DC [Invited]

10:45 a.m. - 12:00 p.m. New and Perennial Issues in Transactions Involving Financial Instruments (1.5 Credits in Areas of Professional Practice)

This session will discuss selected issues commonly faced in transactions involving debt and other financial instruments. The topics will include deemed exchanges of debt instruments issued by disregarded entities, tax fungibility of debt instruments, the recent IRS guidance on cryptocurrency, and the IBOR transition proposed regulations.

Panel Chair: Jiyeon Lee-Lim, Esq., Latham & Watkins LLP, New York, NY

Panelists: Lucy W. Farr, Esq., Davis Polk & Wardwell LLP, New York, NY; Craig M. Horowitz, Esq., Cahill Gordon & Reindel LLP, New York, NY; Erika W. Nijenhuis, Esq., Senior Counsel, Department of the Treasury, Washington, DC [Invited]

Luncheon: 12:30 p.m. - 2:00 p.m. | Grand Ballroom, 3rd Floor

Speaker: Professor Edward Kleinbard, Robert C. Packard Trustee Chair in Law, University of Southern California Gould School of Law

2:15 p.m. - 4:00 p.m. The End of the Beginning: What's Next in International Tax After the Tax Cuts and Jobs Act (2.0 Credits in Areas of Professional Practice)

The Tax Cuts and Jobs Act is now over two years old and we have received the first round of most, but not all, of the significant guidance needed to implement the international tax provisions of the TCJA. This panel will discuss, among other topics, areas where significant guidance is still needed in the areas of GILTI, PTEP, FDII, BEAT and Sections 163(j) and 245A, including the interaction of these rules with pre-existing law, and will take a look forward at how the future evolution of tax policy, including as a result of the continuing efforts of the OECD/G20 on BEPS, may interact with the international tax provisions of the TCJA.

Panel Chair: Michael T. Mollerus, Esq., Davis Polk & Wardwell LLP, New York, NY

Panelists: Peter H. Blessing, Esq., Associate Chief Counsel (International), Internal Revenue Service, Washington, DC [Invited]; Meyer H. Fedida, Esq., Cleary Gottlieb Steen & Hamilton LLP, New York, NY; Douglas Poms, Esq., International Tax Counsel, Department of the Treasury, Washington, DC [Invited]; Danielle E. Rolfes, Esq., KPMG LLP, Washington, DC; Marjorie Rollinson, Esq., Ernst & Young LLP, Washington, DC

New York City Taxes & New York State Taxes Joint Committee Meeting/High Tea: 4:15 p.m. - 5:35 p.m. | Gibson, 2nd Floor

Section Chair: Deborah L. Paul, Esq. | Wachtell, Lipton, Rosen & Katz | New York, NY

TAX LAW SECTION SCHEDULE

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