S e c t i o n o f Ta x a t i o n
2012 Midyear Meeting
February 16-18, 2012
Manchester Grand Hyatt · san Diego, CA
Final PROGRAM
A Publishing Sponsor of the ABA Section of Taxation
the ABA Section of Taxation
would like to thank our sponsors for
their support of the 2012 Midyear Meeting
COMMITTEE EVENT SPONSORs
EXHIBITORS
2012 Midyear Meeting
Highlights4
Program Guide
7
Schedule at-a-Glance
Thursday PM
8
8
Friday AM
8
Friday PM
12
Saturday AM
18
Saturday PM
20
Program Schedule
Thursday PM
22
22
Friday AM
23
Friday PM
37
Saturday AM
56
Saturday PM
64
Affiliated Organizations
68
General Information 69
Activities 71
Index72
FloorplanFoldout at back
Future Meetings /
CLE Calendar
Section of Taxation CLE Calendar www.americanbar.org/groups/taxation/events_cle.html
Date
Program
Contact Info
February 22, 2012
Current Developments in Individual, Corporate,
and Partnership Taxation
Tax Section
www.americanbar.org/tax
202.662.8670
CLE Teleconference and Live Audio Webcast
February 29, 2012
Recent Amendments to Circular 230 and
Their Potential Impact on Practitioner
Disciplinary Proceedings
Tax Section
www.americanbar.org/tax
202.662.8670
Ethics CLE Teleconference and Live Audio Webcast
March 19-20, 2012
2012 ABA/IPT Advanced Income Tax Seminar
The Ritz-Carlton New Orleans – New Orleans, LA
March 20-21, 2012
2012 ABA/IPT Advanced Sales/Use Tax Seminar
The Ritz-Carlton New Orleans – New Orleans, LA
March 22-23, 2012
March 28-30, 2012
April 12-13, 2012
Tax Section
www.americanbar.org/tax
202.662.8670
12th Annual Tax Planning Strategies –
US and Europe
Tax Section
www.americanbar.org/tax
202.662.8670
Pillsbury Winthrop Shaw Pittman LLP – Washington, DC
ALI-ABA
www.ali-aba.org
800.CLE.NEWS
ALI-ABA Course of Study: Charitable
Giving Techniques
ALI-ABA
www.ali-aba.org
800.CLE.NEWS
ALI-ABA Course of Study: Corporate Taxation
Millennium Knickerbocker – Chicago, IL
June 13-15, 2012
5th Annual US – Latin American Tax
Planning Strategies Conference
Mandarin Oriental Hotel – Miami, FL
July 18-20, 2012
ALI-ABA Course of Study: Estate Planning for
the Family Business Owner
San Francisco, CA
November 13-14, 2012
Tax Section
www.americanbar.org/tax
202.662.8670
The Ritz-Carlton New Orleans – New Orleans, LA
2012 ABA/IPT Advanced Property Tax Seminar
Hofburg Congress Center – Vienna, Austria
March 28-30, 2012
Tax Section
www.americanbar.org/tax
202.662.8670
23rd Annual Philadelphia Tax Conference
The Union League of Philadelphia – Philadelphia, PA
Section of Taxation Meeting Calendar Tax Section
www.americanbar.org/tax
202.662.8670
ALI-ABA
www.ali-aba.org
800.CLE.NEWS
Tax Section
www.americanbar.org/tax
202.662.8670
www.americanbar.org/groups/taxation/events_cle.html
Date
Program
Location
May 10-12, 2012
May Meeting
Grand Hyatt – Washington, DC
September 13-15, 2012
Joint Fall Cle Meeting
Westin Boston Waterfront – Boston, MA
January 24-26, 2013
Midyear Meeting
Hilton Bonnet Creek & Waldorf Astoria – Orlando, FL
May 9-11, 2013
May Meeting
Grand Hyatt – Washington, DC
September 19-21, 2013
Joint Fall Cle Meeting
Hyatt Regency – San Francisco, CA
January 23-25, 2014
Midyear Meeting
Arizona Biltmore – Phoenix, AZ
May 8-10, 2014
May Meeting
Grand Hyatt – Washington, DC
September 17-19, 2014
Joint Fall Cle Meeting
Sheraton Downtown – Denver, CO
2
Welcome
William M. Paul
Section Chair
The Section of Taxation welcomes you to the 2012 Midyear
Meeting in San Diego, California. We are pleased that you have
decided to join us and take advantage of the opportunity to participate in high-level discussions between private practitioners and
government on the most important issues facing tax lawyers today.
Please note the following meeting highlights:
• Hosted WELCOME RECEPTION on Thursday
• PLENARY SESSION/SECTION LUNCHEON on Saturday
• Saturday afternoon SECTION PROGRAMS on a broad
range of hot topics
Stay connected with our new MOBILE MEETING APPLICATION.
•
View the Final Program and create your personalized agenda
• Access the latest meeting materials
• Find speakers and view fellow attendees
• Check out things to see and do in San Diego
• Receive updates and alerts throughout the meeting
Download the app to your smart phone or tablet
by using your device to scan the QR code or visit
http://ambar.org/taxapps.
We hope you enjoy the meeting and we welcome your comments.
Highlights
WELCOME RECEPTION (Complimentary)
The Tax Section is hosting a complimentary Welcome Reception for all attendees on
Thursday evening, February 16, from 6:00pm – 7:00pm in Manchester D-F. Come early
and meet with your colleagues and with new Section members, network and discuss
current topics of the day.
SECTION LUNCHEON/PLENARY SESSION (Ticketed Event)
The Section is pleased to announce Hon. David M. Walker, Founder and
CEO of the Comeback America Initiative and Former Comptroller General
of the US will address attendees of the 2012 Midyear Meeting at the
Section Luncheon/Plenary Session on Saturday, February 18, at 12:00pm
in Elizabeth A-C. See page 64 for additional information.
SECTION RECEPTION (Ticketed Event)
The Section Reception will take place on Friday, February 17 from 6:30pm – 8:00pm,
and will be held at the San Diego Museum of Art. Enjoy great food and drinks with your
colleagues and friends.
PUBLICATIONS BOOK RELEASE RECEPTION
Meet the contributors and celebrate the release of the 5th Edition of
Effectively Representing Your Client Before the IRS on Friday from
5:30pm – 6:30pm in Molly A. Drop off your business card to be entered
into a drawing for a free copy of the book. Hosted by the Publications, Low
Income Taxpayers, and Pro Bono Committees.
REGISTRATION
Registration will be available at the Registration Desk, Litrenta Foyer, 2nd Level. All
individuals attending any part of the 2012 Midyear Meeting, including speakers, must
register and pay the registration fee. Shared registrations are not permitted. Companions
are defined as non-Section members not attending substantive meetings. Any companion
attending substantive programs must register and pay either the Section member or
non-Section member registration fee, whichever is applicable.
The registration fee includes meeting materials and permits registrants to attend all
meetings, sessions and programs; however, it does not include meal functions and social
events listed as “Ticketed Event.” All ticketed events are sold on a first-come, first-served
basis. Payment may be made by check or credit card. The Section accepts American
Express, MasterCard and VISA.
4
Highlights
ON-SITE REGISTRATION AND TICKET PURCHASE HOURS
The Registration Desk, located in Litrenta Foyer, 2nd Level, will be open during the
following hours:
Thursday:
Friday:
Saturday:
12:00pm – 7:30pm
6:30am – 6:30pm
6:30am – 1:00pm
Please note: Registration will be closing at 1:00 pm on Saturday. Any questions regarding
registration should be directed to the CLE Booth after that time.
JOHN S. NOLAN TAX LAW FELLOWS
The Section will recognize the outgoing 2011 – 2012 fellows and announce the
2012 – 2013 fellows during the Section Luncheon.
2011 – 2012 Chad R. DeGroot, Bryan Cave LLP, St. Louis, MI
Stacey Delich-Gould, Sullivan & Cromwell LLP, New York, NY
Melissa L. Galetto, Skadden Arps Slate Meagher & Flom LLP,
Washington, DC
Vanessa A. Scott, Southerland Asbill & Brennan LLP, Washington, DC
Lisa M. Stern, Proskauer Rose LLP, New York, NY
Mark E. Wilensky, Roberts & Holland LLP, New York, NY
2012 – 2013 Erica L. Brady, The Ferraro Law Firm, Washington, DC
Matthew J. Eickman, Utz Miller & Eickman, Overland Park, KS
Jon Finkelstein, McDermott Will & Emery, Washington, DC
Cathy Fung, Office of Chief Counsel, IRS, Washington, DC
Ivan H. Golden, Schiff Hardin, Chicago, IL
Rachel L. Partain, Caplin & Drysdale, New York, NY
Public Service Fellowship
The Section’s Public Service Fellowship award program was developed in 2008 to address
the need for tax legal service assistance around the country, and to foster an interest in
tax-related public service for those lawyers who participate. Fellowships are open to recent
J.D. and LL.M. graduates and judicial clerks who commit to working in tax-related public
interest, non-profit 501 (c)(3) organizations for two years.
Sean Norton, Pine Tree Legal Assistance, Bangor, ME
Anna Tavis, South Brooklyn Legal Services, Brooklyn, NY
Katie Tolliver, Legal Aid Society of Middle Tennessee and the Cumberlands,
Appalachian Community Partnership for Tax Advocacy, Oak Ridge, TN
5
Highlights
Janet R. Spragens Pro Bono Award
The Janet R. Spragens Pro Bono Award was established to recognize one or more
individuals or law firms that have provided meritorious pro bono service, particularly with
respect to Federal and state tax law. The eleventh annual Janet R. Spragens Pro Bono
Award will be presented at the Section Luncheon/Plenary Session on Saturday.
Former recipients of the award are Fulbright & Jaworski LLP (2011), Caroline Ciraolo &
Juan Vasquez Jr. (2010), Elizabeth A. Copeland (2009), Joseph Barry Schimmel (2008),
Professor Leslie M. Book (2007), Professor Janet R. Spragens (2006), Professor Diana L.
Leyden (2005), Karen L Hawkins (2004), Peter A. Lowy (2003) and Victoria Bjorklund
and Elizabeth Atkinson (2002).
LOCAL EXEMPT ORGANIZATION ASSISTANCE PROGRAM
Co-sponsored by: Exempt Organizations and Pro Bono Committees
On Thursday from 3:00pm – 5:30pm, in Del Mar, 3rd Level, members of the Exempt
Organizations Committee will provide pro bono consultation time to local tax exempt
organizations that hold 501(c)(3) status, who are without sufficient resources to pay
standard legal fees, and to nonprofit organizations that serve low-income individuals. The
attorneys on hand are experienced with Federal exempt organization qualification issues,
filings, compliance rules and governance issues. Participants are required to register in
advance; consults are anticipated to run 30 minutes.
BADGE IDENTIFICATION
6
RED Bar Section Officers, Council Members, Committee Chairs,
Task Force Chairs, Past Section Chairs
GREEN Bar
Government Officials/Guests
BLUE Bar
Young Lawyers
GRAY Bar
Law Students and LLM Candidates
ORANGE Bar
Companions
PURPLE Bar
First-time Attendees
YELLOW Badge
Press
Program Guide
HOW TO USE THIS PROGRAM
The program book is divided into three primary sections: Schedule-at-a-Glance, Program
Schedule and Alpha Index. The following is a description of each of these sections:
SCHEDULE AT-A-GLANCE (p. 8)
Lists all programs chronologically by start time, then alphabetically by committee
name. Subcommittee meetings are listed under their committee. Use this guide to
find programs beginning at a specific time.
Example: To find programs starting on Friday, at 8:30am, go to the Schedule-at-aGlance section and locate the “Friday 8:30AM” programs. Here you can
view the committees meeting at that time, the location, topic and the
page number for the full program description in the Program Schedule.
PROGRAM SCHEDULE (p. 22)
Lists all programs chronologically by the start time, then alphabetically by committee names. Subcommittee meetings are listed under their committees. This section
includes full program descriptions, speakers, locations and start and end times. The
Schedule-at-a-Glance and the Alpha Index will help you locate specific programs in
this section.
ALPHA INDEX (p. 72)
Lists all committee programs alphabetically by committee name. Use this section to
locate all programs hosted by a specific committee.
Example: To find all programs hosted by the Administrative Practice committee,
go to the Alpha Index and locate ‘Administrative Practice.’ You will find a
listing of all meetings and events hosted by the Administrative Practice
committee. Go to the corresponding page number for more information.
 = The Program is Recorded
 = The Program Will Appeal to Young Lawyers or Non-specialists
 = Ethics Credits has Been Requested
= No CLE Credit is Available
7
Schedule
at-a-Glance
 = Taped  = Young Lawyers Program
Committee/Program
 = Ethics Credits Requested
 = No CLE Credit
Location
Topic(s)/Time(s)
Page
Manchester A,
2nd Level
8:30AM – 3:30PM
22
Manchester D,
2nd Level
6:00PM – 7:00PM
22
Chianti,
644 Fifth Ave.
6:30PM – 9:30PM
22
First-Time Attendees
Orientation Dinner 
(Reservations Required)
Annie,
3rd Level
7:00PM – 9:00PM
22
State & Local Taxes Committee
Executive Business Meeting
(Executive Session)
Procopio, Cory,
Hargreaves &
Savitch LLP,
525 B St.
Suite 2200
7:00PM – 9:00PM
22
Del Mar A,
3rd Level
7:00AM – 8:00AM
23
ACTC Board of Regents
Meeting
(Executive
Session)
Emma C,
3rd Level
7:30AM – 9:30AM
68
Committee Chairs, ViceChairs, Officers and Council
Breakfast
Elizabeth F,
2nd Level
7:30AM – 8:15AM
23
Exempt Organizations
Subcommittee on Audits,
Appeals and Litigation
Madeleine C,
3rd Level
7:30AM – 8:30AM
Automatic Termination Project and
Unanticipated Issues; Roundtable Discussion of
Current Developments
23
Exempt Organizations
Subcommittee on Health-Care
Organizations
Madeleine D,
3rd Level
7:30AM – 8:30AM
Roundtable Discussion of
Current Developments
23
Exempt Organizations
Subcommittee on Political and
Lobbying Organizations
Emma B,
3rd Level
7:30AM – 8:30AM
Roundtable Discussion of
Current Developments
23
THURSDAY 8:30AM
Officers & Council Meeting
(Executive Session)
THURSDAY 6:00PM
Welcome Reception
(Complimentary)

THURSDAY 6:30PM
Partnerships & LLCs and Real
Estate Committees Dinner
(Reservations Required)
THURSDAY 7:00PM
FRIDAY 7:00AM
Employee Benefits New
Employee Benefits Attorneys
Forum
FRIDAY 7:30AM
8
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
Exempt Organizations
Subcommittee on Private
Foundations, Unrelated
Business Income, and
International Philanthropy
Madeleine B,
3rd Level
7:30AM – 8:30AM
Roundtable Discussion of
Current Developments
23
Exempt Organizations
Subcommittee on Religious
Organizations
Emma A,
3rd Level
7:30AM – 8:30AM
Roundtable Discussion of
Current Developments
24
Capital Recovery & Leasing 
Elizabeth H,
2nd Level
8:00AM – 10:00AM
8:00a – Current Developments
8:45a – Current Issues and Topics in
Depreciation Methods and Classifications
9:30a – Deduction for Qualified Film and
Television Production Expenditures
24
Companions Breakfast
(Complimentary)
Top of the
Hyatt, 40th
Floor
8:00AM – 9:00AM
24
Employee Benefits
Administrative Practices
Update
Ford AB,
3rd Level
8:00AM – 9:30AM
Presented by the Subcommittee on SelfCorrection, Determination Letters and Other
Administrative Practices
24
Employee Benefits EEOC,
FMLA and Military Leave
Update
Del Mar A,
3rd Level
8:00AM – 9:00AM
Presented by the Subcommittee on EEOC
Issues/FMLA, Military and Other Leaves
25
Employee Benefits Executive
Compensation, Fringe Benefits
and Securities Law Update
Annie,
3rd Level
8:00AM – 9:30AM
Presented by the Subcommittees on Executive
Compensation, Fringe Benefits and Federal
Securities Law Issues and the Subcommittee
on Mergers & Acquisitions
25
Administrative Practice  
Manchester D,
2nd Level
8:30AM – 11:30AM
8:30a – Important Developments 
9:00a – Money Ball: Inside the IRS’s Global
High Wealth Industry Group 
9:50a – The Administrative Procedure Act and
Tax Administration: How Does it Apply? What
Is the Debate? What Do Tax Professionals Need
to Know? 
10:40a – The Technical (or “Terrible?”) Advice
Process: Using “TAM” As an Effective Issue
Resolution Tool 
25
Affiliated & Related
Corporations 
Manchester E,
2nd Level
8:30AM – 12:00PM
8:30a – Application of Section 382 to
Consolidated Groups
10:45a – Current Development
26
FRIDAY 7:30AM (continued)
FRIDAY 8:00AM
FRIDAY 8:30AM
9
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
Banking & Savings
Institutions 
Manchester G,
2nd Level
8:30AM – 11:30AM
8:30a – Foreign Tax Credit Generators,
Economic Substance and the Future
9:30a – Distressed Debt Tax Issues from the
Perspective of Banks
10:30a – Hot Topics in Taxation of Banking:
(1) IRS’s OID Calculation Safe Harbor for Pools
of Credit Cards Receivables – Helpful or
Harmful? (2) Mortgage Servicing Rights –
Capital or Ordinary? Assets or Liabilities?
27
Closely Held Businesses 
Manchester A,
2nd Level
8:30AM – 11:30AM
8:30a – Estate Planning Gone Awry: What
Happens When Things Don’t Work Out the
Way We Planned?
9:30a – Reformation of Estate Documents:
Why Your Documents Are Alive Even After
You’re Dead!
10:30a – Sales of Personal Goodwill
28
Estate & Gift Taxes 
Manchester H,
2nd Level
8:30AM – 11:30AM
8:30a – Current Developments
9:00a – Estate and Income Tax Planning for
the Passage of Family Homes
9:50a – Portability – Plethora of Problems,
Pitfalls and Planning Possibilities
10:40a – Mending Wayward Wealth Transfer
Strategies (With the Help of a $5,000,000
Exclusion Amount)
29
Individual & Family
Taxation  
Gregory,
2nd Level
8:30AM – 11:30AM
8:30a – Am I Really an Independent
Contractor?
Co-sponsored by: Employment Taxes
10:00a – Highlights from the National
Taxpayer Advocate 2011 Annual Report
to Congress
29
Investment Management 
Molly,
2nd Level
8:30AM – 11:30AM
8:30a – Current Hedge Fund and Private
Equity Fund Drafting Issues
9:30a – RICs and PFICs – A Couple That Still
Can’t Get Along
10:30a – Liquidations of Regulated
Investment Committees
30
Partnerships & LLCs 
Manchester B,
2nd Level
8:30AM – 11:30AM
8:30a – The Do’s and Dont’s of Structuring
Leveraged Partnerships
9:15a – Hot Topics
9:55a – Applying Section 118 to Partnerships
– Isn’t It About Time?
10:25a – Hola, Ni Hao, Shalom – Say Hello to
Your Foreign Partner
31
FRIDAY 8:30AM (continued)
10
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
S Corporations 
Manchester I,
2nd Level
8:30AM – 11:30AM
8:30a – Report on Proposals for
Tax Simplification
8:40a – Current Developments
9:00a – Medicare Taxes and S Corporations
10:30a – QSubs: The Basics and Beyond
32
Transfer Pricing 
Elizabeth A,
2nd Level
8:30AM – 10:30AM
8:30a – Comparability and
Economic Adjustments
9:30a – Transfer Pricing for Financial
Institutions and Products
32
US Activities of Foreigners &
Tax Treaties 
Elizabeth DE,
2nd Level
8:30AM – 10:30AM
8:30a – The New Proposed Foreign Account
Tax Compliance Act (“FATCA”) Regulations
9:30a – The Corporate Mixed Marriage
33
Elizabeth BC,
2nd Level
8:45AM – 12:15PM
8:45a – Committee Business
9:00a – News From the IRS and Department
of Treasury
10:00a – Practical Problems and Practical
Solutions for Donor Advised Funds
11:15a – Hybrid Entities: Do They Really Have
a Place in the Charitable Investment World?
33
Employee Benefits
Legislative Update
Madeleine D,
3rd Level
9:00AM – 10:00AM
Presented by the Subcommittee on Employee
Benefits Legislation
34
Young Lawyers Forum –
11th Annual Law Student
Tax Challenge

Madeleine A &
Mohsen B,
3rd Level
9:00AM – 12:00PM
Semi-Final Rounds (Open to the Public)
34
Annie,
3rd Level
9:30AM – 11:00AM
Presented by the Subcommittees on Welfare
Plan Design and Funding, Cafeteria Plans and
Reimbursement Accounts and HIPAA, COBRA
& State Insurance Regulation of Welfare Plans
34
Madeleine C,
3rd Level
9:45AM – 10:45AM
Presented by the Subcommittee on Foreign and
International Issues
35
FRIDAY 8:30AM (continued)
FRIDAY 8:45AM
Exempt Organizations 
FRIDAY 9:00AM
FRIDAY 9:30AM
Employee Benefits Welfare
Benefits Design, Funding and
Regulation Update
FRIDAY 9:45AM
Employee Benefits
International Update
11
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
Companions Activity
(Ticketed Event)
Shuttle Bus
will depart
from the main
entrance of the
Hyatt at
9:30am
10:00AM – 2:00PM
Acrylics and Aperture: Private Tours of the
Timken Museum, the Museum of Photographic
Arts and Luncheon at Bertrand at Mister A’s
71
Employee Benefits
Distributions Update
Madeleine B,
3rd Level
10:00AM – 11:15AM
Presented by the Subcommittee
on Distributions
35
Elizabeth DE,
2nd Level
10:30AM – 12:15PM
10:30a – Joint Current International
Developments Panel
36
Distinguished Service Award
(Executive Session)
Emma C,
3rd Level
11:00AM – 12:00PM
36
Employee Benefits Defined
Contribution Plans Update
Ford AB,
3rd Level
11:00AM – 12:30PM
Presented by the Subcommittee on Defined
Contribution Plans
36
Employee Benefits
ESOP Update
Ford C,
3rd Level
11:00AM – 12:00PM
Presented by the Subcommittee on ESOPs
37
Employee Benefits Fiduciary
Regulation Update
Madeleine C,
3rd Level
11:00AM – 12:00PM
Presented by the Subcommittee on Fiduciary
Responsibility/Plan Investments
37
Tax Shelters
Manchester C,
2nd Level
11:00AM – 1:00PM
37
Del Mar B,
3rd Level
11:30AM – 12:30PM
37
Corporate Tax and Affiliated &
Related Corporations
Luncheon
(Ticketed Event)
Elizabeth A,
2nd Level
12:00PM – 1:30PM
Topic: An Open Transactional Discussion led
by Mark Silverman
Speaker: Mark Silverman, Steptoe & Johnson
LLP, Washington, DC
38
Employee Benefits Fiduciary
and Litigation Update
Madeleine B,
3rd Level
12:00PM – 1:30PM
Presented by the Subcommittees on Fiduciary
Responsibility/Plan Investments, Litigation,
and ESOPS
37
Membership & Marketing
Del Mar A,
3rd Level
12:00PM – 1:00PM
37
Nominating
(Executive Session)
Emma AB,
3rd Level
12:00PM – 2:30PM
37
FRIDAY 10:00AM
FRIDAY 10:30AM
Joint Session of FAUST,
USAFTT, FLF and Transfer
Pricing
FRIDAY 11:00AM
FRIDAY 11:30AM
Appointments to the Tax Court
(Executive Session)
FRIDAY 12:00PM
12
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
Elizabeth BC,
2nd Level
12:15PM – 1:45PM
Topic: Breakthroughs in Medicine: Promise,
Policy and Philanthropy
Speakers: Paul Dostart, Dostart Clapp &
Coveney LLP, San Diego, CA; John C. Reed,
Sanford-Burnham Medical Research Institute,
La Jolla, CA
38
Administrative Practice and
Court Procedure & Practice
Luncheon
(Ticketed Event)
Manchester D,
2nd Level
12:30PM – 1:30PM
Speaker: Tamara Ashford, Deputy Assistant
Attorney General, Department of Justice,
Washington, DC
Co-sponsored by: Hochman Salkin Rettig
Toscher & Perez PC and Kostelanetz
& Fink LLP
38
Banking & Savings Institutions,
Financial Transactions,
Insurance Companies,
Investment Management and
Tax Exempt Financing
Luncheon
(Ticketed Event)
Gregory,
2nd Level
12:30PM – 1:30PM
Speaker: Mark Perwien, Special Counsel to
Associate Chief Counsel, Office of Associate
Chief Counsel, IRS, Washington, DC
38
Civil & Criminal Tax Penalties
Luncheon
(Ticketed Event)
Manchester F,
2nd Level
12:30PM – 1:30PM
Co-sponsored by: Hochman Salkin Rettig
Toscher & Perez PC and Kostelanetz &
Fink LLP
38
Employee Benefits Controlled
Groups and Employee Status
Update
Madeleine D,
3rd Level
12:30PM – 1:30PM
Presented by the Subcommittee on Controlled
Groups, Affiliated Service Groups, and
Employee Status
39
Employee Benefits Defined
Benefit Plans Update
Manchester H,
2nd Level
12:30PM – 1:45PM
Presented by the Subcommittee on Defined
Benefit Plans
39
Employee Benefits Government
and Tax Exempt Plans Update
Ford AB,
3rd Level
12:30PM – 1:45PM
Presented by the Subcommittee on Exempt
Organization and Governmental Plans
39
Estate & Gift Taxes and
Fiduciary Income Tax
Luncheon
(Ticketed Event)
Molly,
2nd Level
12:30PM – 1:30PM
Topic: Motivating the Young Adult to be
Financially Responsible: The Financial
Skills Trust
Speakers: Eileen Gallo, Gallo Consulting LLC,
Los Angeles, CA; Jon J. Gallo, Greenberg
Glusker Fields Claman & Machtinger LLP, Los
Angeles, CA
38
FAUST, FLF, Transfer Pricing
and USAFTT Luncheon
(Ticketed Event)
Elizabeth DE,
2nd Level
12:30PM – 1:30PM
Speakers: Steven A. Musher, Associate Chief
Counsel, International, IRS, Washington, DC;
Ginny Chung, Attorney Adviser, International
Tax Counsel, Department of Treasury,
Washington, DC
38
FRIDAY 12:15PM
Exempt Organizations
Luncheon
(Ticketed Event)
FRIDAY 12:30PM
13
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
Partnerships & LLCs and Real
Estate Luncheon
(Ticketed
Event)
Manchester B,
2nd Level
12:30PM – 1:30PM
Speaker: Jennifer H. Alexander, Attorney
Advisor, Office of Tax Policy, Department of
Treasury, Washington, DC
38
State & Local Taxes Luncheon
(Ticketed Event)
Annie,
3rd Level
12:30PM – 1:00PM
38
Indian Tribal Tax 
Madeleine C,
3rd Level
1:00PM – 5:00PM
1:00p – What Tax Lawyers Need to Know
About Federal Indian Law
3:45p – Federal Taxation of Tribes and Their
Members – Fundamental Issues and Hot Topics
40
State & Local Taxes: Current
Developments in California
FTB Settlement Procedures
Annie,
3rd Level
1:00PM – 2:00PM
40
Court Procedure & Practice
Roundtable Discussion 
Manchester I,
2nd Level
1:30PM – 2:30PM
1:30p – Court Procedure Issues In CDP
Judicial Review
40
Employment Taxes 
Manchester E,
2nd Level
1:30PM – 5:30PM
1:30p – Federal Update
2:30p – Employment Tax Issues Relating to
Health Care
3:30p – California Employment Taxes and the
Employment Development Department
4:30p – Practitioner’s Roundtable
41
Estate & Gift Taxes and
Fiduciary Income Tax Young
Lawyers Subcommittee 
Manchester C,
2nd Level
1:30PM – 2:30PM
41
Foreign Lawyers Forum 
Elizabeth DE,
2nd Level
1:30PM – 3:30PM
1:30p – Special Taxes on Financial Institutions
and Transactions
2:30p – Renewed Pursuit of Tax Avoidance
and Evasion
41
Manchester G,
2nd Level
1:30PM – 4:00PM
1:30p – Ethical Issues in Federal Tax Practice
– The Government Perspective 
2:20p – Circular 230’s Range of Disciplinary
Sanctions: How Bad Can it Get & How is it
Determined? 
3:10p – Pro Bono Representations: Ethical
Issues Specific to the Pro Bono Context 
Co-sponsored by: Pro Bono
42
FRIDAY 12:30PM (continued)
FRIDAY 1:00PM
FRIDAY 1:30PM
Standards of Tax Practice 
14
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
Closely Held Businesses 
Manchester A,
2nd Level
2:00PM – 5:30PM
2:00p – Impact of New Health Care Law on
Closely Held Businesses
3:30p – Update on Health Care Reform
5:00p – Closely Held Businesses Committee
Planning Meeting
43
Employee Benefits 
Elizabeth FG,
2nd Level
2:00PM – 6:30PM
2:00p – DOL Disclosure and Reporting Update:
Participant and Plan-Level Fee Disclosures and
EFAST2 and Audit Reporting Issues
3:00p – Practical Considerations in Providing
Benefits and Equity Compensation to a Global
Workforce
4:00p – Hot Topics
5:00p – Fireside Chat
6:00p – Networking Reception
Sponsored by: Practical Law Company
43
Exempt Organizations 
Elizabeth BC,
2nd Level
2:00PM – 4:30PM
2:00p – The Future of the Charitable Deduction
3:00p – VAT and the Tax-Exempt Sector:
Unique US Tax Issues
4:00p – Cash bar
44
Young Lawyers Forum – 11th
Annual Law Student Tax
Challenge

Madeleine A &
Mohsen B,
3rd Level
2:00PM – 5:00PM
Final Rounds (Open to the Public)
45
Bankruptcy & Workouts 
Manchester F,
2nd Level
2:30PM – 5:30PM
2:30p – Tax Court or Bankruptcy Court –
What, Where, How and Why?
4:00p – Acquisition of Troubled Corporations
5:00p – New Developments 2011
45
Court Procedure & Practice 
Manchester I,
2nd Level
2:30PM – 5:30PM
2:30p – Important Developments
3:00p – E-Litigation: Leveraging Technology
Throughout Your Case
3:50p – Parallel Civil Tax Litigation and
Criminal Investigations
4:40p – Litigating R&D Cases
46
Energy & Environmental Taxes

Molly,
2nd Level
2:30PM – 4:30PM
2:30p – Hot Tax Topics for Utilities
3:30p – New Excise Tax on Medical Devices
47
Financial Transactions 
Elizabeth H,
2nd Level
2:30PM – 5:30PM
2:30p – Short Derivatives: Getting Topsy Turvy
3:30p – Contingent Swaps and the New Regime
4:30p – Section 871(m): New Guidance on
Cross-Border Equity Swaps
47
Public Service Fellowship
(Executive Session)
Emma C,
3rd Level
2:30PM – 6:00PM
48
FRIDAY 2:00PM
FRIDAY 2:30PM
15
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
Real Estate 
Manchester B,
2nd Level
2:30PM – 5:30PM
2:30p – Minimizing Gain/Maximizing Loss:
May I Cherry Pick Property?
3:30p – Installment Sales: Interesting and
Unresolved Issues
4:00p – What Is Real Property and Why Do
I Care?
4:35p – Real Estate Funds: A Potpourri of
Issues that Vex the Practical Practitioner
48
State & Local Taxes 
Ford AB,
3rd Level
2:30PM – 6:00PM
2:30p – Current Developments: Series LLCs
3:00p – Subcommittee Reports:
Publications & Seminars
3:15p – Remote Sales & Nexus Issues
4:10p – Apportionment: Sales Factors Based
on Benefit Received
5:05p – Digital Downloads and On-Line
Services – Taxing Issues in the Virtual Realm
49
Tax Accounting 
Gregory,
2nd Level
2:30PM – 5:30PM
2:30p – Recent Developments in
Tax Accounting
3:00p – Inventory: Recent Guidance,
Anticipated Guidance
4:00p – Considering the Proper Tax Accounting
Treatment of Advance Payments in a Corporate
Transaction
4:45p – Issues Arising in Tax Controversies
Involving Tax Accounting Issues
50
Tax Exempt Financing 
Manchester D,
2nd Level
2:30PM – 5:30PM
2:30p – Legislative, Department of Treasury
and IRS Update
3:30p – VCAP and Other Compliance and
Program Management Initiatives
4:30p – Tax Implications of
On-Behalf-Of Financings
51
Diversity 
Elizabeth A,
2nd Level
3:00PM – 4:00PM
3:00p – Could 9-9-9 Ever Really Work?
Considering Alternative Taxation Structures on
the Road to a Fairer, Simpler Tax System
52
Insurance Companies 
Manchester C,
2nd Level
3:00PM – 6:00PM
3:00p – Transfer Pricing and Insurance
3:50p – Health Care Reform – Tax and Fee
Implementation Issues Affecting the Insurance
Industry and the Scope of “Health Insurance”
4:40p – DOMA vs. the States, with Tax Rules
in the Middle
5:30p – Update on Recent Tax Developments
and Projects on the IRS Priority Guidance Plan
52
FRIDAY 2:30PM (continued)
FRIDAY 3:00PM
16
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
Ford C,
3rd Level
3:00PM – 4:00PM
53
Elizabeth DE,
2nd Level
3:30PM – 5:30PM
3:30p – Foreign Tax Credits
53
Elizabeth A,
2nd Level
4:00PM – 6:30PM
4:00p – Making a Difference As a
Tax Lawyer
5:30p – Young Lawyers Forum and Diversity
Networking Reception 
54
Professional Services
Emma AB,
3rd Level
5:00PM – 6:00PM
54
Programs & Meetings
Ford C,
3rd Level
5:00PM – 5:30PM
54
Molly A,
2nd Level
5:30PM – 6:30PM
Meet the contributors and celebrate the release
of the 5th Edition of Effectively Representing
Your Client Before the IRS. Hosted by the
Publications, Low Income Taxpayers, and Pro
Bono Committees.
54
Foreign Activities of US
Taxpayers Business Meeting
Madeleine B,
3rd Level
5:45PM – 6:30PM
54
Foreign Lawyers Forum
Business Meeting
Madeleine D,
3rd Level
5:45PM – 6:30PM
55
US Activities of Foreigners and
Tax Treaties Business Meeting
Ford C,
3rd Level
5:45PM – 6:30PM
55
San Diego
Museum of Art
6:30PM – 8:00PM
Buses begin departing at 6:15pm from the
main entrance of the Manchester Grand Hyatt
55
FRIDAY 3:00PM (continued)
Sponsorships
FRIDAY 3:30PM
Foreign Activities of US
Taxpayers 
FRIDAY 4:00PM
Young Lawyers Forum 
FRIDAY 5:00PM
FRIDAY 5:30PM
Publications Book Release
Reception
FRIDAY 5:45PM
FRIDAY 6:30PM
Section Reception
(Ticketed Event)

17
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
Salvatore's
Cucina
Italiana,
750 Front St.
8:00PM – 10:30PM
Members of the FAUST, FLF, Transfer Pricing
and USAFTT Committees will meet for
cocktails and dinner. First-time attendees are
welcome and encouraged to attend.
55
Elizabeth G,
2nd Level
7:00AM – 8:30AM
7:00a – Informal Discussion and
Complimentary Breakfast 
7:30a – Get Inspired! Motivational Stories of
Success from Tax Professionals 
56
Manchester
AB, 2nd Level
7:15AM – 8:30AM
Members of the Partnerships and LLCs, Real
Estate, and S Corporations Committees will
gather for the traditional “open mic” breakfast
to share ideas and war stories and to seek
input on technical issues.
56
Ford AB,
3rd Level
7:45AM – 9:00AM
56
Corporate Tax 
Elizabeth H,
2nd Level
8:30AM – 11:30AM
8:30a – North-South Transactions, Section
355 and Other Step Transaction Issues
10:00a – Tax Opinions: What Does It Cost You
and What Is It Worth to Your Client?
56
Employee Benefits 
Elizabeth E,
2nd Level
8:30AM – 11:30AM
8:30a – Plan Drafting and Administrative
Issues After Amara
9:30a – Worker Classification Issues Under
Renewed Focus
10:30a – Proxy Disclosure 2012: Same As
Last Year or New Year, New Challenges?
57
Elizabeth F,
2nd Level
8:30AM – 11:30AM
8:30a – Recent Developments
8:50a – Anatomy of a Form 1041, Fiduciary
Income Tax Return
9:40a – Making Retirement Benefits Payable
to Trusts
10:30a – Ethical Issues For Trust and
Estate Practitioners 
58
FRIDAY 8:00PM
Joint International Committees
Dinner (Reservations
Required)
SATURDAY 7:00AM
Tax Practice Management,
Diversity and Young Lawyers
Forum

SATURDAY 7:15AM
Partnerships & LLCs, Real
Estate and S Corporations
“Shop Talking Breakfast”
(Ticketed Event)
SATURDAY 7:45AM
Court Procedure & Practice
Officers and Subcommittee
Chairs Breakfast
(Ticketed Event)
SATURDAY 8:30AM
Fiduciary Income Tax 
18
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
SATURDAY 8:30AM (continued)
LLCs and LLPs Subcommittee
of Partnerships & LLCs
Molly,
2nd Level
8:30AM – 10:30AM
8:30a – Employee Benefits Implications of the
Proposed Series LLCs Regulations
9:30a – To Regard or Not to Regard Your Entity
58
Low Income Taxpayers 
Gregory,
2nd Level
8:30AM – 10:30AM
8:30a – Introductory Remarks and
Administrative Issues
8:35a – National Taxpayer Advocate’s Annual
Report to Congress
9:15a – Dealing with Tax Issues Following
a Disaster
9:45a – Innocent Spouse – We Won, but
Where Are We Now?
59
Sales, Exchanges & Basis 
Manchester F,
2nd Level
8:30AM – 11:30AM
8:30a – Current Developments in Sales,
Exchanges and Basis Other Than Sections
1031 & 1033 
8:55a – Is It Treated As a Sale? Lease?
Financing? Constructive Sale? Option?
Something Else? – Part I 
9:35a – Involuntary Conversions and
Qualification of Replacement Property 
10:10a – Build-to-Suit or Full-of-Boot:
Analyzing Exchanges Involving Leasehold
Improvements Constructed by a QI or EAT
10:50a – Current Developments in Section
1031 and Section 1033 Transactions
59
Tax Policy & Simplification 
Manchester D,
2nd Level
8:30AM – 10:45AM
8:30a – Perspectives on Tax Reform: Taxation
of Capital Gains and Dividend Income
9:35a – Perspectives on Tax Reform: Charitable
Contributions and the Nonprofit Sector
60
Elizabeth D,
2nd Level
8:45AM – 11:45AM
8:45a – Reports of Subcommittees on
Important Developments
9:15a – Should You Blow Your Whistle?
10:05a – Integrity of Domestic and Offshore
Accounts: The United States Perspective
10:55a – Sentencing – How to Make the Best
of a Bad Situation
61
Mohsen,
3rd Level
9:00AM – 10:30AM
62
Manchester C,
2nd Level
9:00AM – 10:30AM
9:00a – Tax and the First Amendment
62
SATURDAY 8:45AM
Civil & Criminal Tax Penalties 
SATURDAY 9:00AM
State & Local Taxes
Practitioner’s Roundtable
Teaching Taxation 

19
Schedule
at-a-Glance
Committee/Program
Location
Topic(s)/Time(s)
Page
Pro Bono 
Gregory,
2nd Level
10:30AM – 12:00PM
10:30a – Pro Bono Matters: Why? Ethical and
Economic Reflections on ABA Model Rule 6.1
“Voluntary Pro Bono Publico Service”
63
The State and Local Tax Lawyer
Publications Subcommittee 
Mohsen,
3rd Level
10:30AM – 11:30AM
63
Elizabeth ABC,
2nd Level
12:00PM – 1:30PM
Topic: Restoring Fiscal Sanity
Speaker: Hon. David M. Walker, Founder and
CEO of the Comeback America Initiative and
Former Comptroller General of the US
64
Section Program presented by
Real Estate and Partnerships &
LLCs 
Del Mar,
3rd Level
2:00PM – 4:00PM
Drafting Real Estate Partnership and LLC
Agreements – Part 2
65
Section Program presented by
Tax Accounting and Capital
Recovery & Leasing 
Edward ABC,
2nd Level
2:00PM – 5:00PM
Repair Regs Re-Do: Review of the New
Guidance Regarding Tangible Property
66
Section Program presented by
Teaching Taxation 
Mohsen,
3rd Level
2:00PM – 5:00PM
Current Developments in Individual, Corporate,
Partnership and Estate & Gift Taxation 
64
Section Program presented by
US Activities of Foreigners and
Tax Treaties, Banking & Savings
Institutions, Insurance
Companies and Tax Shelters 
Ford AB,
3rd Level
2:00PM – 4:00PM
The Far-Reaching Impact of FATCA Across
Borders and Across Industries
65
Madeleine,
3rd Level
5:00PM – 5:30PM
68
Madeleine,
3rd Level
5:30PM – 6:30PM
68
Sally’s Seafood
on the Water,
1 Market Place
7:00PM – 10:00PM
68
Del Mar,
3rd Level
7:30AM – 9:00AM
Speaker: Nina Olson, National Taxpayer
Advocate, IRS, Washington, DC
68
SATURDAY 10:30AM
SATURDAY 12:00PM
Section Luncheon & Plenary
Session

(Ticketed Event)
SATURDAY 2:00PM
SATURDAY 5:00PM
ACTC Annual Business
Meeting
(ACTC Members
Only)
SATURDAY 5:30PM
ACTC 2012 Griswold Lecture
(Open Session)
SATURDAY 7:00PM
ACTC Reception and Dinner
(ACTC Members and
Guests)
SUNDAY 7:30AM
ACTC Fellows Breakfast and
Roundtable Discussion
(ACTC Members Only)
20
Program
Schedule
Program Schedule
Thursday, February 16
8:30AM – 3:30PM
Officers & Council Meeting
6:00PM – 7:00PM
Welcome Reception
Manchester A, 2nd Level
(Executive Session)
Manchester D, 2nd Level
 (Complimentary)
Chianti
6:30PM – 9:30PM
(Reservations Required)
Partnerships & LLCs and Real Estate Committees Dinner
Members of the Partnerships and LLCs Committee and Real Estate Committee will meet for
cocktails and dinner at Chianti, 644 Fifth Avenue, San Diego, CA which is about a half mile
walk (or a short cab ride) from the hotel. Cocktails (cash bar) will begin at 6:30pm, followed by
dinner at 7:30pm. Reservations and advanced payment required.
7:00PM – 9:00PM
First-Time Attendees Orientation Dinner
Annie, 3rd Level
 (Reservations Required)
7:00PM – 9:00PM
Procopio, Cory, Hargreaves & Savitch LLP
(Executive Session)
State & Local Taxes Committee Executive Business Meeting
Meeting of Committee Officers & Subcommittee Chairs and invited guests
Chair: Bill Prugh, Polsinelli Shughart PC, Kansas City, MO
22
Program Schedule
Thursday,
Friday, February
January 17
20
7:00AM – 8:00AM
Del Mar A, 3rd Level
Employee Benefits New Employee Benefits Attorneys Forum
Co-Chairs: Sarah J. Touzalin, Seyfarth Shaw LLP, Chicago, IL; Brian A. Benko, McDermott Will &
Emery LLP, Washington, DC
7:00AM – 4:00PM
Elizabeth Foyer, 2nd Level
Hospitality Center
(Complimentary)
Complimentary continental breakfast will be served in the morning. Snacks, coffee, sodas and
water will be available in the afternoon.
7:30AM – 9:30AM
ACTC Board of Regents Meeting
Emma C, 3rd Level
(Executive Session)
7:30AM – 8:15AM Committee Chairs, Vice-Chairs, Officers and Council Breakfast
Elizabeth F, 2nd Level
7:30AM – 8:30AM
Madeleine C, 3rd Level
Exempt Organizations Subcommittee on Audits, Appeals and Litigation
Chairs: Diara M. Holmes, Caplin & Drysdale, Washington, DC; Michael A. Clark, Sidley Austin,
Chicago, IL; Marcus Owes, Caplin & Drysdale, Washington, DC
7:30am Automatic Termination Project and Unanticipated Issues Roundtable
Discussion of Current Developments.
7:30AM – 8:30AM
Madeleine D, 3rd Level
Exempt Organizations Subcommittee on Health-Care Organizations
Chairs: T.J. Sullivan, Drinker Biddle & Reath LLP, Washington, DC; Robert W. Friz,
PricewaterhouseCoopers LLP, Philadelphia, PA
7:30am Roundtable Discussion of Current Developments.
7:30AM – 8:30AM
Emma B, 3rd Level
Exempt Organizations Subcommittee on Political and Lobbying Organizations
Chairs: Rosemary E. Fei, Adler & Colvin, San Francisco, CA; Elizabeth J. Kingsley, Harmon Curran
Spielberg & Eisenberg LLP, Washington, DC
7:30am Roundtable Discussion of Current Developments.
501(c)(4) organizations.
Focus on section
7:30AM – 8:30AM
Madeleine B, 3rd Level
Exempt Organizations Subcommittee on Private Foundations, Unrelated Business Income, and
International Philanthropy
Chairs: LaVerne Woods, Davis Wright Tremaine LLP, Seattle, WA; Lisa L. Johnsen, Bill & Melinda
Gates Foundation, Seattle, WA; Carolyn O. (Morey) Ward, Ropes & Gray LLP, Washington, DC;
Anne Battle, Morgan Lewis & Bockius, Washington, DC; Laura Kalick, BDO Seidman, Bethesda,
MD; Betsy Buchalter Adler, Adler & Colvin, San Francisco, CA; Victoria Bjorklund, Simpson
Thacher & Bartlett, New York, NY
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
23
Program Schedule
Thursday,
Friday,
February
January
1720
7:30am Roundtable Discussion of Current Developments.
7:30AM – 8:30AM
Emma A, 3rd Level
Exempt Organizations Subcommittee on Religious Organizations
Chairs: Boyd J. Black, The Church of Jesus Christ of Latter-day Saints, Salt Lake City, UT; Thomas
E. Wetmore, General Conference of Seventh-Day Adventists, Silver Spring, MD
7:30am Roundtable Discussion of Current Developments.
8:00AM – 10:00AM
Capital Recovery & Leasing 
Chair: Katherine Breaks, KPMG LLP, Washington, DC
Elizabeth H, 2nd Level
8:00am Current Developments. This program will cover important recent developments
in the area of capital recovery and leasing with a special focus on the final
repair regulations.
Moderator: Jane Rohrs, Deloitte Tax LLP, Washington, DC
Panelists: Sam Weiler, Ernst & Young LLP, Columbus, OH; Colleen O’Connor,
KPMG LLP, Washington, DC; Scott Dinwiddie, Special Counsel, Office of Chief
Counsel, IRS, Washington, DC; Kathleen Reed, Branch Chief, Branch VII, Office of
Chief Counsel, IRS, Washington, DC
8:45am Current Issues and Topics in Depreciation Methods and Classifications.
This panel will address issues associated with asset classification, placed in
service determinations and cost recovery, discussing both opportunities for
planning and exposure areas under IRS exam. The panel will also discuss current
issues faced by taxpayers in properly navigating a variety of cost recovery issues
related to tangible assets, especially in light of the looming expiration of bonus
depreciation and changes in unit of property determinations.
Moderator: Alison Jones, Ernst & Young LLP, Washington, DC
9:30am Deduction for Qualified Film and Television Production Expenditures. The
deduction for qualified film and television production expenditures provides an
immediate deduction for certain film and television production expenses as long
as the production occurred in the United States. It was originally enacted as a
temporary provision as part of the American Jobs Creation Act of 2004, but has
since been extended in 2008 and 2010. Temporary regulations were issued
under the provision in February of 2007. Panelists will discuss qualification
requirements, the definition of “production,” and the available methods for
determining whether services have been provided in the United States.
Moderator: Christopher J. Ohmes, Ernst & Young LLP, Washington, DC
8:00AM – 9:00AM
Companions Breakfast
Top of the Hyatt, 40th Floor
(Complimentary)
8:00AM – 9:30AM Ford AB, 3rd Level
Employee Benefits Administrative Practices Update
Presented by the Subcommittee on Self-Correction, Determination Letters and Other
Administrative Practices
Chair: Lisa Tavares, Venable LLP, Washington, DC
Vice-Chair: Stefan P. Smith, Locke Lord Bissell & Liddell LLP, Dallas, TX
24
Program Schedule
Thursday,
Friday, February
January 17
20
Young Lawyer Liaison: Christina Crockett, Hunton & Williams LLP, McLean, VA
The panelists will discuss the status of the determination letter program, the qualified plan
interim amendment requirements, and the status of updates to the Employee Plans Compliance
Resolution System (“EPCRS”).
Panelist: Ingrid Grinde, Office of Rulings and Agreements, IRS, Washington, DC
8:00AM – 9:00AM
Employee Benefits EEOC, FMLA and Military Leave Update
Del Mar A, 3rd Level
Presented by the Subcommittee on EEOC Issues/FMLA, Military and Other Leaves
Chair: William Mark Freedman, Dinsmore & Shohl LLP, Cincinnati, OH
Vice-Chair: Helena Darrow, Dinsmore & Shohl LLP, Cincinnati, OH
The Subcommittee will review EEOC developments affecting employment benefit plans and
practices. The Committee will also review recent developments in the area of FMLA, Military and
Other Leaves.
8:00AM – 9:30AM Annie, 3rd Level
Employee Benefits Executive Compensation, Fringe Benefits and Securities Law Update
Presented by the Subcommittees on Executive Compensation, Fringe Benefits and Federal
Securities Law Issues and the Subcommittee on Mergers & Acquisitions.
The meeting will include a discussion of executive compensation issues in mergers and
acquisitions. Topics will include the treatment of equity compensation, securities disclosure,
and related matters. We will also have an update from government panelists on executive
compensation developments at the Department of Treasury and the IRS.
Panelists: Jeremy L. Goldstein, Wachtell Lipton Rosen & Katz, New York, NY; George Bostick,
Benefits Tax Counsel, Department of Treasury, Washington, DC; Stephen Tackney, Special Counsel,
Office of Division Counsel, Associate Chief Counsel, TE/GE, IRS, Washington, DC
8:30AM – 11:30AM
Administrative Practice  
Chair: Sheri Dillon, Bingham McCutchen LLP, Washington, DC
Manchester D, 2nd Level
8:30am Important Developments.The panelists will discuss the most significant recent
developments in the area of administrative practice, including recently issued
guidance and court decisions.
Moderator: Bryon Christensen, Skadden Arps Slate Meagher & Flom LLP,
Washington, DC
Panelists: Thomas J. Kane, Counselor to the Associate Chief Counsel, Procedure
and Administration, IRS, Washington, DC; Alexandra Minkovich, Attorney-Advisor,
Office of Tax Policy, Department of Treasury, Washington, DC
9:00am Money Ball: Inside the IRS’s Global High Wealth Industry Group. This panel
will explore how this new IRS audit program really works. With the experience
of auditing major multinational corporations and the entire toolkit available
to the Large Business & International Division, the current examinations of
“family offices” bear no resemblance to their historic IRS audit experiences.
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
25
Program Schedule
Thursday,
Friday,
February
January
1720
The program will separate myth from fact through dialogue among
practitioners who have experience with these audits, the GHWI IRS Industry
Counsel and other IRS officials.
Moderator: Phillip Pillar, Greenberg Traurig LLP, Washington, DC
Panelists: James Fee, Office of Chief Counsel, IRS, Philadelphia, PA; Thomas V.
Collins, Territory Manager, Global High Wealth, Ogden, UT; Kurt Brune, WTAS
LLC, Los Angeles, CA
9:50am The Administrative Procedure Act and Tax Administration: How Does it
Apply? What Is the Debate? What Do Tax Professionals Need to Know? 
This panel will examine whether and how the Administrative Procedure Act
applies to IRS actions in the wake of the Supreme Court’s decision in Mayo
Foundation for Medical Education and Research v. United States and the
DC Circuit’s en banc opinion in Cohen v. United States. Topics for discussion
include: What do tax professionals need to learn about the APA? Should the
IRS now be treated the same as any other agency under the APA? How should
different forms of tax guidance (temporary regulations, PLRs, Notices, etc.)
issued by the IRS be interpreted under Chevron and its progeny (e.g., Mead)?
What questions remain unanswered?
Moderator: Kevin Stults, Bingham McCutchen LLP, Washington, DC
Panelists: Professor Kristin Hickman, University of Minnesota Law School,
Minneapolis, MN; Patrick Smith, Ivins Phillips & Barker, Washington, DC;
Honorable Judge James Halpern, US Tax Court, Washington, DC; Gilbert
Rothenberg, Chief, Appellate Section, Tax Division, Department of Justice,
Washington, DC
10:40am The Technical (or “Terrible?”) Advice Process: Using “TAM” As an Effective
Issue Resolution Tool.  A technical advice memorandum (“TAM”) can be an
effective tool to resolve technical issues during an examination or appeal. This
panel will explore, through both the perspectives of practitioners and the IRS,
practical approaches to the TAM process that can facilitate or impede the successful
resolution of a technical or procedural question that has developed during a
proceeding. The discussion will include what issues are most appropriate for the
TAM process, what makes a good TAM submission, what practitioners can expect
during the submission and consideration process, and how practitioners can best
represent their clients during the process. The panel will also examine situations
where guidance may have already been issued during the pendency of the
proceeding, in the form of a Field Service Advice (“FSA”) or a Chief Counsel Advice
(“CCA”), including what the impact of the prior advice has on the TAM process.
Moderator: Daniel J. Wiles, PricewaterhouseCoopers LLP, Washington, DC
Panelists: Sara Coe, Deputy Division Counsel, SBSE, Washington, DC; Gerald
Kafka, Latham & Watkins LLP, Washington, DC; Beth Williams, Bingham
McCutchen LLP, Palo Alto, CA; Curt Wilson, Associate Chief Counsel, P&SI, IRS,
Washington, DC; Laurel Robinson, LB&I Area Counsel, Office of Chief Counsel,
IRS, Oakland, CA
8:30AM – 12:00PM Affiliated & Related Corporations 
Chair: Mark Schneider, Deloitte Tax, Washington, DC
26
Manchester E, 2nd Level
Program Schedule
Thursday,
Friday, February
January 17
20
8:30am Application of Section 382 to Consolidated Groups. This panel will discuss the
basics of applying section 382 to consolidated groups and will then focus on the
challenges faced by practitioners in applying recent guidance.
Panelist: Theresa Abell, Counsel to the Associate Chief Counsel, Corporate,
Washington, DC
10:45am Current Developments. This panel will discuss current trends and authority
pertaining to consolidated groups.
Panelist: Marie Milnes-Vasquez, Senior Technical Reviewer, Office of Chief
Counsel, IRS, Washington, DC
8:30AM – 11:30AM
Manchester G, 2nd Level
Banking & Savings Institutions 
Chair: Yoram Keinan, Shareholder, Greenberg Traurig LLP, New York, NY
8:30am Foreign Tax Credit Generators, Economic Substance and the Future. Government
recently won its first case involving “foreign tax credit generators” this past fall, in
Pritired 1 LLC v United States. At least four other cases involving different types
of foreign tax credit generators are docketed or have been tried and are awaiting
decisions. Many more are likely in audit or appeals. Unlike previous coordinated
issues such as LILOs and Son-of-BOSS transactions, foreign tax credit generators
come in many varieties and often have no features in common with one another.
In addition, the structures often use long accepted tax structuring techniques.
For this reason, the outcome of these litigations may have far-reaching effects on
a range of current assumptions in tax planning. This panel will explore several
of the current generators being challenged, and discuss the possible effects of
government or taxpayer victories on tax planning.
Moderator: Stow Lovejoy, Kostelanetz & Fink, LLP, New York, NY
Panelists: Yoram Keinan, Shareholder, Greenberg Traurig LLP, New York, NY;
Michael I. Gilman, Senior Counsel, Office of Chief Counsel, IRS, Washington, DC;
Mark Perwien, Special Counsel to Associate Chief Counsel, Office of Associate
Chief Counsel, IRS, Washington, DC
9:30am Distressed Debt Tax Issues from the Perspective of Banks. This panel will
consider the various tax issues that arise for banks with respect to distressed debt,
including both loans originated by the bank and loans acquired at a discount.
The tax issues include (1) when it is proper to cease interest accruals, (2) issues
relating to the computation of the book charge-off and tax bad debt deduction, and
(3) book-tax conformity on bad debt losses for non-bank affiliates of banks.
Moderator: David C. Garlock, Ernst & Young LLP, Washington, DC
Panelists: Daniel Mayo, KPMG LLP, Washington, DC; John W. Rogers,
Financial Institutions and Products, Office of Chief Counsel, IRS,
Washington, DC; Francisca N. Mordi, American Bankers Association,
Washington, DC
10:30am Hot Topics in Taxation of Banking: (1) IRS’s OID Calculation Safe Harbor for
Pools of Credit Cards Receivables – Helpful or Harmful? (2) Mortgage Servicing
Rights – Capital or Ordinary? Assets or Liabilities? This panel will discuss two
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
27
Program Schedule
Thursday,
Friday,
February
January
1720
hot topics in taxation of banking banking industry. First it will discuss a proposed
revenue procedure pursuant to which banks and credit card companies will
be able to rely on the proportional method for accounting for OID on a pool
of credit card receivables. Second, it will discuss the economics and business
aspects of mortgage servicing rights, and will consider the fundamental US tax
considerations involved in retaining, acquiring, holding and disposing of mortgage
servicing rights.
Moderator: Clay Littlefield, Alston & Bird LLP, Charlotte, NC
Panelists: Louis J. Garday, Carrington Holding Company, LLC, Greenwich,
CT; Scott Brown, Financial Institutions and Products, Office of Chief Counsel,
IRS, Washington, DC; Francisca N. Mordi, American Bankers Association,
Washington, DC
8:30AM – 11:30AM
Closely Held Businesses 
Chair: Eric Green, Convicer Percy & Green LLP, Glastonbury, CT
Manchester A, 2nd Level
8:30am Estate Planning Gone Awry: What Happens When Things Don’t Work Out the
Way We Planned? While certain estate tax planning strategies may be effective
in minimizing state and federal taxes, and may provide clients with a certain
level of comfort and satisfaction, these strategies may result in unanticipated
consequences for the beneficiaries either during a client’s lifetime or after the
client’s death. This panel will discuss three types of trusts commonly used in
estate tax planning (the QPRT, the ILIT, and the GRAT), and will consider some
of the non-tax and familial issues that may arise in attempting to administer
such trusts.
Panelists: Eric Green, Convicer Percy & Green LLP, Glastonbury, CT; Alfred
Casella, Murtha Cullina LLP, Hartford, CT; Shelby Wilson, Berchem Moses &
Devlin PC, Westport, CT
9:30am Reformation of Estate Documents: Why Your Documents Are Alive Even
After You’re Dead! This panel will address litigation issues involving closely
held businesses, taxes, and wills and trusts, including litigating reformation of
wills and trusts. It will include a discussion of national trends, common estate
planning pitfalls, and best practices to avoid future litigation or disputes involving
your legal work.
Panelist: John Pankauski, Attorney, West Palm Beach, FL
10:30am Sales of Personal Goodwill. This presentation will focus on the nature of
personal goodwill as distinguished from business/practice goodwill, when a
sale of personal goodwill is advantageous, how it is accomplished, the role of
an appraisal, and various other issues, such as application of the anti-churning
rules. Court cases on personal goodwill, including recent cases, will
be discussed.
Panelists: William Prescott, Wickens Herzer Panza Cook & Batista Co, Avon, OH;
Alson Martin, Lathrop & Gage LLP, Overland Park, KS; Morton Harris, Hatcher
Stubbs Land Hollis & Rothschild LLP, Columbus, GA
28
Program Schedule
Thursday,
Friday, February
January 17
20
8:30AM – 11:30AM
Estate & Gift Taxes 
Chair: Paul E. Van Horn, McLaughlin & Stern LLP, New York, NY
Manchester H, 2nd Level
8:30am Current Developments. This panel will review developments in the federal estate,
gift and generation-skipping transfer tax laws since October, 2011.
Panelists: Catherine V. Hughes, Office of Tax Policy, Department of Treasury,
Washington, DC; George D. Karibjanian, Proskauer Rose LLP, Boca Raton, FL;
Hannah W. Mensch, McLaughlin & Stern LLP, New York, NY
9:00am Estate and Income Tax Planning for the Passage of Family Homes. For many
families, a family home is among the most cherished assets, but preserving that
property as a family asset for the use and enjoyment of successive generations can
present significant challenges to the estate planner. This presentation addresses
some of the key issues to consider in planning for intergenerational succession for
family homes using QPRTs, split interest purchases, family LLCs, dynasty trusts,
and other strategies. In addition to the estate, gift and GST tax considerations
involved in the transfer of a family home, the presentation will also discuss
how to anticipate and avoid common disputes that arise in the context of the
co-ownership of family properties and means for resolving disputes if and when
they do arise.
Panelist: Nancy C. Henderson, Henderson Caverly Pum & Charney LLP, San
Diego, CA
9:50am Portability – Plethora of Problems, Pitfalls and Planning Possibilities. Although
enacted a little more than one year ago, the implementation of “Portability” has
been questioned and debated by many of the most astute minds in the estate
planning community. This presentation will trace the history of Portability from
proposal to enactment, discuss the law as enacted, illustrate perceived problems
with the current enactment, propose solutions to correct such problems and
present planning options, problems and solutions for 2012.
Panelists: George D. Karibjanian, Proskauer Rose LLP, Boca Raton, FL; Lester B.
Law, US Trust, Naples, FL
10:40am Mending Wayward Wealth Transfer Strategies (With the Help of a $5,000,000
Exclusion Amount). GRATs, installment sales, intrafamily loans and QPRTs often
transfer wealth in a tax-efficient manner. Sometimes, they may not yield the
expected results. Unsuccessful economic performance, changes in circumstances,
drafting errors and other events may require an “exit” strategy. Ben Carter will
discuss various exit strategies, particularly in light of the (possibly fleeting)
$5 million federal gift tax exclusion and planning for an exit strategy before
problems arise.
Panelist: Benjamin G. Carter, Winstead PC, Dallas, TX
8:30AM – 11:30AM
Gregory, 2nd Level
Individual & Family Taxation  
Chair: Professor David L. Rice, California State Polytechnic University, Pomona, CA
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
29
Program Schedule
Thursday,
Friday,
February
January
1720
8:30am Am I Really an Independent Contractor?  The IRS, US Department of Labor
and states agencies have all taken a renewed interest in the question of whether a
worker is an employee or independent contractor. In addition, the IRS has enacted
a new Voluntary Compliance Settlement Program that could clearly reduce the
amount of exposure to those businesses that have misclassified their employees.
The benefits and pitfalls of this new program will be discussed. This is a great
opportunity to hear from the IRS and well versed tax practitioners on how the IRS
evaluates the status of workers and what steps potential employers can take to
ensure they have correctly classified them.
Panelists: William Hays Weissman, Littler Mendelson, Walnut Creek, CA;
Elizabeth Nelson, Law Offices of David Lee Rice APLC, Torrance, CA; Paul Carlino,
Branch Chief, Office of Chief Counsel, IRS, Washington, DC; Dan Boeskin,
PricewaterhouseCoopers LLP, Washington, DC
Co-sponsored by: Employment Taxes
10:00am Highlights from the National Taxpayer Advocate 2011 Annual Report to
Congress.  The National Taxpayer Advocate will discuss items from her
2011 annual report that are of interest to and impact individuals and families.
The National Taxpayer Advocate’s Annual Report includes a summary of the
most serious problems encountered by taxpayers, recommendations for solving
these problems, and other IRS efforts to improve customer service and reduce
taxpayer burden.
Panelists: Laura Baek, Taxpayer Advocate Service, IRS, Washington, DC; Nina
Olson, National Taxpayer Advocate, IRS, Washington, DC
8:30AM – 11:30AM
Investment Management 
Chair: Raj Tanden, Proskauer Rose LLP, Los Angeles, CA
Molly, 2nd Level
8:30am Current Hedge Fund and Private Equity Fund Drafting Issues. This panel will
focus on selected topics arising under tax, securities, and state laws, as well
as business issues to be considered in the drafting of operating agreements
and limited partnership agreements for private funds, including private equity,
hedge, venture and SBIC funds. Specific topics to include (i) the factors to
consider in utilizing capital accounts versus partnership interests (including
target allocations) in the partnership allocation methodologies; (ii) the nuances
of drafting and negotiating performance allocations (carry), as well as the
proper application of preferred return (hurdle rate) provisions; and (iii) the
different arrangements regarding clawbacks in terms of amount, character and
other aspects.
Moderator: Gregory J. Nowak, Pepper Hamilton LLP, Philadelphia, PA
9:30am RICs and PFICs – A Couple That Still Can’t Get Along. This panel will review the
history of regulated investment companies making investments in passive foreign
investment companies. Attention will be given to the difficulties reconciling the RIC
and PFIC regimes, and the panel will review the issues that continue to bedevil
RICs when they invest in foreign corporations that are themselves or hold indirect
interests in PFICs.
Moderator: Paul Murphy, Deloitte LLP, Boston, MA
30
Program Schedule
Thursday,
Friday, February
January 17
20
10:30am Liquidations of Regulated Investment Committees. This panel will focus on
tax issues that result from liquidations of regulated investment companies,
including circumstances where the fund has not previously paid out all of its
income and gains to its investors, or has accrued but not deducted expenses, as
well as compensation issues for the board of the liquidating company, and the
interaction of the reporting regimes applicable to RIC liquidations under the tax
and securities laws.
Moderator: Raj Tanden, Proskauer Rose LLP, Los Angeles, CA
Panelists: Dale Collinson, KPMG LLP, Washington, DC; Theodore L. Press, K&L
Gates LLP, Washington, DC; Keith Lawson, Investment Company Institute,
Washington, DC
8:30AM – 11:30AM
Partnerships & LLCs 
Chair: Bahar Schippel, Snell & Wilmer LLP, Phoenix, AZ
Manchester B, 2nd Level
8:30am The Do’s and Dont’s of Structuring Leveraged Partnerships. Leveraged
partnerships are alive and well for a variety of valid business reasons. This panel
(not another Canal panel) will discuss a number of issues that must be considered
when a leveraged partnership structure is utilized to accomplish a taxpayer’s
business objectives.
Moderator: Andrea Macintosh Whiteway, McDermott Will & Emory,
Washington, DC
Panelists: Patricia W. McDonald, Baker & McKenzie LLP, Chicago, IL; Dawn
Duncan, Ernst & Young LLP, Washington, DC
9:15am Hot Topics. This panel will discuss recent developments, including legislation,
regulations, administrative guidance and noteworthy cases.
Moderator: Jeanne Sullivan, KPMG LLP, Washington, DC
Panelists: Curtis G. Wilson, Associate Chief Counsel, Passthroughs and Special
Industries, IRS, Washington, DC; Jennifer H. Alexander, Attorney-Advisor, Office of
Tax Policy, Department of Treasury, Washington, DC
9:55am Applying Section 118 to Partnerships – Isn’t It About Time? On its face, section
118 does not apply to partnerships. This panel will discuss whether pre-section
118 case law affords non-partner contributions to the capital of partnerships
treatment similar to the treatment section 118 affords non-shareholder
contributions to the capital of a corporation. The panel will also discuss whether
section 118 should be expanded to cover non-partner contributions to the capital
of partnerships.
Moderator: Todd D. Golub, Ernst & Young LLP, Chicago, IL
Panelists: Eliot L. Kaplan, Squire Sanders, Phoenix, AZ; Patricia Ann Metzer,
Vacovec Mayotte & Singer LLP, Newton, MA
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
31
Program Schedule
Thursday,
Friday,
February
January
1720
10:25am Hola, Ni Hao, Shalom – Say Hello to Your Foreign Partner. Non-US taxpayers
often invest into US through one or more partnerships for a variety of reasons. This
panel will discuss a number of issues arising when non-US persons invest in the
US through one or more partnerships, including section 1446 issues, the recently
proposed section 892 regulations, partnership specific FIRPTA issues, and more.
Moderator: Professor Noel P. Brock, West Virginia University, Morgantown, WV
Panelists: Alan I. Appel, Bryan Cave LLP, New York, NY; Joseph M. Calianno,
Grant Thornton LLP, Washington, DC; Julie M. Marion, Latham & Watkins LLP,
Chicago, IL
8:30AM – 11:30AM
S Corporations 
Chair: John B. Truskowski, Locke Lord LLP, Chicago, IL
Manchester I, 2nd Level
8:30am Report on Proposals for Tax Simplification.
Moderator: John B. Truskowski, Locke Lord LLP, Chicago, IL
8:40am Current Developments. Discussion of recent legislative, administrative and judicial
developments relating to S corporations.
Moderator: Dana Lasley, Deloitte Tax LLP, St. Louis, MO
Panelist: William Klein, Gray Plant Mooty, Minneapolis, MN
9:00am Medicare Taxes and S Corporations. Discussion of the impending increase in the
Medicare tax and its impact on S corporations.
Moderator: C. Wells Hall, Mayer Brown LLP, Charlotte, NC
Panelists: Cornelia Schnyder, Attorney Advisor, Department of Treasury,
Washington, DC; Thomas J. Nichols, Meissner Tierney Fisher & Nichols SC,
Milwaukee, WI
10:30pm QSubs: The Basics and Beyond. Discussion of the basics of QSubs and
consideration of specific issues involving QSubs as disregarded entities.
Moderator: John B. Truskowski, Locke Lord LLP, Chicago, IL
Panelists: Don S. Kovacic, Attorney, Ramona, CA; Tim Glasgow, Holme Roberts &
Owen LLP, Denver, CO
8:30AM – 10:30AM
Transfer Pricing 
Chair: Sean Foley, KPMG LLP, Washington, DC
Elizabeth A, 2nd Level
8:30am Comparability and Economic Adjustments. This panel will discuss economic
adjustments in light of turbulent and divergent global economic conditions. United
States and OECD principles espouse economic adjustments to be made to improve
comparability, and the reliability of arm’s length result. Panel discussion of various
types of adjustments, the rationale (and evidence) in support of an adjustment,
as well as the circumstances were adjustments may not be warranted. The panel
will also consider the standard economic adjustments made by the IRS Advance
Pricing Agreement (APA) Program.
Moderator: Miller Williams, Ernst & Young LLP, Atlanta, GA
Panelists: Jeffrey Bethard, Allergan, Irvine, CA; John Wills, Wills Consulting, San
Jose, CA; Michael Aarstol, Office of Chief Counsel, IRS, San Francisco, CA
32
Program Schedule
Thursday,
Friday, February
January 17
20
9:30am Transfer Pricing for Financial Institutions and Products. Discussion of the
particular issues associated with transfer pricing for financial institutions and
financial products, including recent experience with the IRS Advance Pricing
Agreement (APA) program.
Moderator: Lucia Fedina, KPMG LLP, New York, NY
8:30AM – 10:30AM
US Activities of Foreigners & Tax Treaties  
Chair: Alan Appel, Bryan Cave LLP, New York, NY
Elizabeth DE, 2nd Level
8:30am The New Proposed Foreign Account Tax Compliance Act (“FATCA”) Regulations.
 Financial and non-financial foreign entities of all sorts will be greatly impacted
by the new Foreign Account Tax Compliance Act (“FATCA”) information reporting
and withholding rules. The IRS has previously released three notices that contain
important preliminary guidance on the new rules. The IRS has recently issued
proposed regulations that more fully explain how FATCA will be implemented. The
panel will provide an overview of FATCA and the important points developed by
the guidance, and an update on related enforcement issues.
Panelists: Michael Hirschfeld, Dechert LLP, New York, NY; Fred Murray, Grant
Thornton LLP, Washington, DC; Michael H. Plowgian, Attorney-Advisor, Office
of the International Tax Counsel, Office of Tax Policy, Department of Treasury,
Washington, DC; John Sweeney, Senior Technical Reviewer, Office of Associate
Chief Counsel, IRS, Washington, DC
9:30am The Corporate Mixed Marriage.  This panel will explore inbound international
tax considerations arising when a corporate executive of a foreign parent
corporation works for a US subsidiary, and similar foreign tax considerations
arising when a US corporate executive works for an affiliated foreign corporation.
The panel will focus on US trade or business and permanent establishment
issues, but will also consider privilege and related issues that arise when working
across borders.
Moderator: David Shapiro, Shapiro Tax Law LLC, Philadelphia, PA
Panelists: Diana Wollman, Sullivan & Cromwell LLP, New York, NY; Friedhelm
Jacob, Hengeler Mueller, Frankfurt am Main, Germany; Stuart Chessman, Vivendi
SA, New York, NY; Lara A. Banjanin, Attorney Advisor, Office of Associate Chief
Counsel, IRS, Washington, DC
Elizabeth BC, 2nd Level
8:45AM – 12:15PM
Exempt Organizations 
Chair: Suzanne Ross McDowell, Steptoe & Johnson LLP, Washington, DC
8:45am Committee Business.
9:00am News from the IRS and Department of Treasury. Representatives from the
IRS and the Department of the Treasury will speak on recent developments and
pending guidance.
Moderator: Ronald J. Schultz, PricewaterhouseCoopers, Washington, DC
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
33
Program Schedule
Thursday,
Friday,
February
January
1720
Panelists: Victoria A. Judson, Division Counsel/Associate Chief Counsel, TEGE,
IRS, Washington, DC; M. Ruth M. Madrigal, Attorney-Advisor, Office of Tax
Policy, Department of Treasury, Washington, DC; Preston J. Quesenberry, Senior
Technician Reviewer, Office of Chief Counsel, Washington, DC
10:00am Practical Problems and Practical Solutions for Donor Advised Funds. Panelists
will discuss practical problems that arise in complying with new rules for donor
advised funds under the Pension Protection Act of 2006 and suggest practical
solutions for dealing with these issues.
Moderator: Emily M. Lam, Skadden Arps Slate Meagher & Flom LLP,
Washington, DC
Panelists: Kelly Shipp-Simone, Council on Foundations, Arlington, VA; Jennifer
Franklin, Simpson Thacher & Bartlett LLP, New York, NY; Edward Chaney,
Morgan, Lewis & Bockius, Washington, DC
11:15am Hybrid Entities: Do They Really Have a Place in the Charitable Investment
World? This panel will briefly describe the different types of hybrid entities
currently available, potential benefits and pitfalls of section 501(c)(3)
organizations using these entities, and proposed federal legislation.
Moderator: Celia Roady, Morgan Lewis & Bockius, Washington, DC
Panelists: Robert A. Wexler, Adler & Colvin, San Francisco, CA; William P.
Fitzpatrick, Omidyar Network, Redwood City, CA
9:00AM – 10:00AM Madeleine D, 3rd Level
Employee Benefits Legislative Update
Presented by the Subcommittee on Employee Benefits Legislation
Chair: David N. Levine, Groom Law Group, Washington, DC
Vice-Chair: Gary Chase, Towers Watson, New York, NY
Young Lawyer Liaison: Michael Bartolic, Law Offices of Michael Bartolic LLC, Chicago, IL
9:00AM – 12:00PM
Madeleine A & Mohsen B, 3rd Level

Young Lawyers Forum – 11th Annual Law Student Tax Challenge
Semi-Final Rounds (Open to the Public)
Six teams of JD semi-finalists, selected for their written submissions, will compete before a
panel of judges who will role-play as a “client” and then as a “senior partner” in the firm. The
two-member teams present their solutions to the tax planning problem and, based on their oral
presentations, will be selected to compete in the afternoon final rounds.
9:30AM – 11:00AM Annie, 3rd Level
Employee Benefits Welfare Benefits Design, Funding and Regulation Update
Presented by the Subcommittees on Welfare Plan Design and Funding, Cafeteria Plans and
Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans
Chairs: Andy R. Anderson, Morgan Lewis, Chicago, IL; Alden J. Bianchi, Mintz Levin Cohn Ferris
Glovsky and Popeo PC, Boston, MA; Julie Burbank, Trucker Huss, San Francisco, CA; Mark L.
Stember, Kilpatrick Townsend & Stockton LLP, Washington, DC
Vice-Chairs: Eugene Holmes, Proskauer Rose LLP, Washington, DC; Linda Mendel, Vorys Sater
Seymour & Pease LLP, Columbus, OH
Young Lawyer Liaisons: Chad R. DeGroot, Bryan Cave LLP, St. Louis, MO; Gabriel Marinaro,
Dykema Bloomfield Hills, MI; Jeremy M. Pelphrey, Bruċker Morra, Los Angeles, CA
34
Program Schedule
Thursday,
Friday, February
January 17
20
This meeting will focus on regulatory and sub-regulatory developments issued under the
Affordable Care Act, including recent guidance on the effective date for the summary of benefits
and coverage, HHS FAQs on implementation of the Exchanges, and the Medical Loss Ratio
Requirements. Additionally, we will discuss emerging models of funding, products and other
new trends based on current and anticipated changes under the Affordable Care Act. We will
also discuss non-Affordable Care Act developments, including recent guidance under the Mental
Health Parity Act regarding nonquantitative treatment limitations, the EEOC letter regarding
coordination of an employee’s current health benefits with Medicare, the extension of the Health
Coverage Tax Credit for trade-displaced workers and certain retirees, and recent MEWA guidance
issued by the DOL.
Panelists: Andy R. Anderson, Morgan Lewis, Chicago, IL; Alden J. Bianchi, Mintz Levin Cohn Ferris
Glovsky and Popeo PC, Boston, MA; Julie Burbank, Trucker Huss, San Francisco, CA; Eugene
Holmes, Proskauer Rose LLP, Washington, DC; Linda Mendel, Vorys Sater Seymour & Pease LLP,
Columbus, OH; Mark L. Stember, Kilpatrick Townsend & Stockton LLP, Washington, DC; Kevin
Knopf, Attorney-Advisor, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC;
Russell E. Weinheimer, Senior Counsel, Health and Welfare Branch, Office of Division Counsel/
Associate Chief Counsel, TEGE, IRS, Washington, DC
9:45AM – 10:45AM Madeleine C, 3rd Level
Employee Benefits International Update
Presented by the Subcommittee on Foreign and International Issues
Chair: Andrew C. Liazos, McDermott, Will & Emery, Boston, MA
Vice-Chair: Sandra Cohen, Osler Hoskin & Harcourt LLP, New York, NY
Young Lawyer Liaison: Mark C. Jones, Pillsbury Winthrop Shaw Pittman LLP, Los Angeles, CA
This meeting will address plan design and compliance considerations when structuring
compensation recovery (or “clawback”) provisions for equity and incentive compensation plans
covering employees outside the United States. We will also discuss recent changes under Puerto
Rico law that affect retirement plans intended to qualify for favorable tax treatment under the
laws of Puerto Rico and expected additional guidance on Puerto Rican plans participating in
group trusts.
Panelists: Juan L. Alonso, McConnell Valdos LLC, Hato Rey, Puerto Rico; David W. Ellis, Baker &
McKenzie LLP; Mark C. Jones, Pillsbury Winthrop Shaw Pittman LLP, Los Angeles, CA; Andrew C.
Liazos, McDermott Will & Emery, Boston, MA
10:00AM – 2:00PM
Companions Activity – Acrylics and Aperture: Private Tours of the Timken Museum, the
(Ticketed Event)
Museum of Photographic Arts and Luncheon at Bertrand at Mister A’s
Shuttle bus will depart promptly at 9:30am from the main entrance of the Hyatt. See p. 71
for a full description.
10:00AM – 11:15AM
Employee Benefits Distributions Update
Presented by the Subcommittee on Distributions
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
Madeleine B, 3rd Level
 = No CLE Credit
35
Program Schedule
Thursday,
Friday,
February
January
1720
Chairs: Professor Kathryn J. Kennedy, The John Marshall Law School, Chicago, IL; Linda Griffey,
O’Melveny & Meyer LLP, Los Angeles, CA
Vice-Chair: Jose Juan Valcarce, Shell Oil Company, Houston, TX
Young Lawyer Liaison: Anne M. Meyer, Snell & Wilmer LLP, Phoenix, AZ
In light of the issuance of Notice 2011-96, the Distributions Subcommittee will be conducting
a review of the pension benefit restrictions of IRC §436, including the particulars of the sample
plan amendment issued by the IRS on November 29th. The review will also include options that
plan sponsors may use to avoid the benefit restrictions, including additional contributions, use of
credit balances and posting of security.
Moderator: Professor Kathryn J. Kennedy, The John Marshall Law School, Chicago, IL
Panelists: William Evans, Attorney-Advisor, Office of the Benefits Tax Counsel, Office of Tax Policy,
Department of Treasury, Washington, DC; Stuart Sirkin, Segal Company, Washington, DC; Professor
Kathryn J. Kennedy, The John Marshall Law School, Chicago, IL
10:30AM – 12:15PM
Elizabeth DE, 2nd Level
Joint Session of Foreign Activities of US Taxpayers, US Activities of Foreigners & Tax Treaties,
Foreign Lawyers Forum, and Transfer Pricing 
10:30am Joint Current International Developments Panel. 
Moderators: Len Schneidman, WTAS, Boston, MA; Janine Burman, The
Ruchelman Law Firm, New York, NY
Panelists: Lewis Greenwald, Sullivan & Worcester LLP, Boston, MA; Michael
McGowan, Sullivan & Cromwell LLP, London, UK; John Woodruff, Gardere
Wynne Sewell LLP, Houston, TX; Michael Plowgian, Attorney Advisor, Office of
the International Tax Counsel, Department of Treasury, Washington, DC; John J.
Merrick, Special Counsel, Office of Associate Chief Counsel, IRS, Washington, DC
11:00AM – 12:00PM
Distinguished Service Award
(Executive Session)
Chair: Richard A. Shaw, Higgs Fletcher & Mack LLP, San Diego, CA
Emma C, 3rd Level
11:00AM – 12:30PM Ford AB, 3rd Level
Employee Benefits Defined Contribution Plans Update
Presented by the Subcommittee on Defined Contribution Plans
Chairs: Bret Hamlin, Hill Ward Henderson, Tampa, FL; Robert Miller, Calfee Halter & Griswold LLP,
Cleveland, OH
Vice-Chair: Matthew Eickman, Utz Miller & Eickman LLC, Overland Park, KS
Young Lawyer Liaison: Puneet K. Arora, TE/GE, IRS, Washington, DC
This meeting will examine recent and pending legislative and regulatory activity relating
to section 401(k) plans and other defined contribution plans. Recent litigation will also
be discussed.
Panelists: Allison E. Wielobob, Office of Regulations and Interpretations, US Department of Labor,
Washington, DC; William Evans, Attorney-Advisor, Office of the Benefits Tax Counsel, Office of Tax
Policy, IRS, Washington, DC
36
Program Schedule
Thursday,
Friday, February
January 17
20
11:00AM – 12:00PM Ford C, 3rd Level
Employee Benefits ESOP Update
Presented by the Subcommittee on ESOPs
Chair: W. Waldan Lloyd, Callister Nebeker & McCullough, Salt Lake City, UT
Vice-Chair: Erin Turley, Morgan Lewis & Bockius LLP, Dallas, TX
Young Lawyer Liaison: Douglas W. Dahl II, Attorney, Health and Welfare, Office of Chief Counsel,
IRS, Washington, DC
11:00AM – 12:00PM Madeleine C, 3rd Level
Employee Benefits Fiduciary Regulation Update
Presented by the Subcommittee on Fiduciary Responsibility/Plan Investments
Chair: Andrew L. Oringer, Ropes & Gray, New York, NY
Vice-Chair: Erin M. Sweeney, Dickstein Shapiro LLP, Washington, DC
Young Lawyer Liaisons: Daniel R. Salemi, Franczek Radelet PC, Chicago, IL; Joshua Erlich,
McTigue & Veis LLP, Washington, DC; Douglas W. Dahl II, Attorney, Health and Welfare, Office of
Chief Counsel, IRS, Washington, DC
11:00AM – 1:00PM
Manchester C, 2nd Level
Tax Shelters
Chair: Michael J. Desmond, Law Offices of Michael J. Desmond APC, Washington, DC
11:30AM – 12:30PM
(Executive Session)
Appointments to the Tax Court
Chair: Robin Greenhouse, McDermott Will & Emery, Washington, DC
Del Mar B, 3rd Level
12:00PM – 1:30PM Madeleine B, 3rd Level
Employee Benefits Fiduciary and Litigation Update
Presented by the Subcommittees on Fiduciary Responsibility/Plan Investments, Litigation, and ESOPs
Chairs: Andrew L. Oringer, Ropes & Gray, New York, NY; Benjamin J. Evans, Greenebaum
Doll & McDonald PLLC, Louisville, KY; W. Waldan Lloyd, Callister Nebeker & McCullough,
Salt Lake City, UT
Vice-Chairs: Erin M. Sweeney, Dickstein Shapiro LLP, Washington, DC; Sara Pikofsky, Jones Day,
Washington, DC; Erin Turley, Morgan Lewis & Bockius, Dallas, TX
Young Lawyer Liaisons: Daniel R. Salemi, Franczek Radelet PC, Chicago, IL; Joshua Erlich,
McTigue & Veis LLP, Washington, DC; Douglas W. Dahl II, Attorney, Health and Welfare, Office of
Chief Counsel, IRS, Washington, DC
The panel will discuss recent ERISA litigation cases.
12:00PM – 1:00PM
Membership & Marketing
Chair: Elaine K. Church, PricewaterhouseCoopers LLP, Washington, DC
Del Mar A, 3rd Level
12:00PM – 2:30PM
Emma AB, 3rd Level
(Executive Session)
Nominating
Chair: Charles H. Egerton, Dean Mead Egerton Bloodworth Capouano & Bozarth PA, Orlando, FL
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
37
Program Schedule
Thursday,
Friday,
February
January
1720
COMMITTEE LUNCHEONS
12:00PM – 1:30PM
Elizabeth A, 2nd Level
(Ticketed Event)
Corporate Tax and Affiliated & Related Corporations
Topic: An Open Transactional Discussion led by Mark Silverman
Speaker: Mark Silverman, Steptoe & Johnson LLP, Washington, DC
12:15PM – 1:45PM Elizabeth BC, 2nd Level
(Ticketed Event)
Exempt Organizations
Topic: Breakthroughs in Medicine: Promise, Policy and Philanthropy
SpeakerS: Paul Dostart, Dostart Clapp & Coveney LLP, San Diego, CA; John C. Reed, SanfordBurnham Medical Research Institute, La Jolla, CA
12:30PM – 1:30PM
Manchester D, 2nd Level
(Ticketed Event)
Administrative Practice and Court Procedure & Practice
Speaker: Tamara Ashford, Deputy Assistant Attorney General, Department of Justice,
Washington, DC
Co-sponsored by: Hochman Salkin Rettig Toscher & Perez PC and Kostelanetz & Fink LLP
12:30PM – 1:30PM
Gregory, 2nd Level
Banking & Savings Institutions, Financial Transactions, Insurance Companies, Investment
(Ticketed Event)
Management and Tax Exempt Financing
Speaker: Mark Perwien, Special Counsel to Associate Chief Counsel, Office of Associate Chief
Counsel, IRS, Washington, DC
12:30PM – 1:30PM
Manchester F, 2nd Level
(Ticketed Event)
Civil & Criminal Tax Penalties
Co-sponsored by: Hochman Salkin Rettig Toscher & Perez PC and Kostelanetz & Fink LLP
12:30PM – 1:30PM
Molly, 2nd Level
(Ticketed Event)
Estate & Gift Taxes and Fiduciary Income Tax
Topic: Motivating the Young Adult to be Financially Responsible: The Financial Skills Trust
Speakers: Eileen Gallo, Gallo Consulting LLC, Los Angeles, CA; Jon J. Gallo, Greenberg
Glusker Fields Claman & Machtinger LLP, Los Angeles, CA
12:30PM – 1:30PM
Elizabeth DE, 2nd Level
Foreign Activities of US Taxpayers, Foreign Lawyers Forum, Transfer Pricing and US
(Ticketed Event)
Activities of Foreigners & Tax Treaties
Speakers: Steven A. Musher, Associate Chief Counsel, International, IRS, Washington,
DC; Ginny Chung, Attorney Adviser, International Tax Counsel, Department of Treasury,
Washington, DC
12:30PM – 1:30PM
Manchester B, 2nd Level
(Ticketed Event)
Partnerships & LLCs and Real Estate
Speaker: Jennifer H. Alexander, Attorney Advisor, Office of Tax Policy, Department of Treasury,
Washington, DC
12:30PM – 1:00PM
(Ticketed Event)
State & Local Taxes
38
Annie, 3rd Level
Program Schedule
Thursday,
Friday, February
January 17
20
12:30PM – 1:30PM Madeleine D, 3rd Level
Employee Benefits Controlled Groups and Employee Status Update
Presented by the Subcommittee on Controlled Groups, Affiliated Service Groups, and
Employee Status
Co-Chairs: Peter J. Hunt, Pillsbury Winthrop Shaw Pittman LLP, New York, NY; Daniel L. Morgan,
Dickstein Shapiro LLP, Washington, DC
Vice-Chair: Elizabeth Drigotas, Deloitte Tax LLP, Washington, DC
Young Lawyer Liaison: Sarah J. Touzalin, Seyfarth Shaw LLP, Chicago, IL
In addition to reviewing recent court decisions and regulatory developments regarding worker
classification, controlled group determinations and employee benefits for contingent workers
generally, our Subcommittee will discuss the Department of Treasury’s request for comments on
the proposed series organization regulations.
12:30PM – 1:45PM Manchester H, 2nd Level
Employee Benefits Defined Benefit Plans Update
Presented by the Subcommittee on Defined Benefit Plans
Co-Chairs: Harold J. Ashner, Keightley & Ashner LLP, Washington, DC; Stuart A. Sirkin, Segal
Company, Washington, DC
Vice-Chair: Serena Simons, Segal Company, Washington, DC
Young Lawyer Liaison: Sarah E. Fry, Morgan Lewis & Bockius LLP, Dallas, TX
We will address significant Department of Treasury, IRS, and PBGC regulatory, enforcement, and
litigation developments, and expect to have the participation of several government guests.
Panelists: Harold J. Ashner, Keightley & Ashner LLP, Washington, DC; William K. Bortz, Associate
Benefits Tax Counsel, Office of Benefits Tax Counsel, Office of Tax Policy, Department of Treasury,
Washington, DC; William M. Evans, Attorney-Advisor, Office of Benefits Tax Counsel, Office of
Tax Policy, Department of Treasury, Washington, DC; Sarah E. Fry, Morgan Lewis & Bockius LLP,
Dallas, TX; Rhonda Migdail, Manager, Employee Plans, IRS, Washington, DC; Serena Simons,
Segal Company, Washington, DC; Stuart A. Sirkin, Segal Company, Washington, DC; Harlan Weller,
Office of Benefits Tax Counsel, Office of Tax Policy, Department of Treasury, Washington, DC; James
Eggeman, Assistant Chief Counsel, Pension Benefit Guaranty Corporation, Washington, DC
12:30PM – 1:45PM Ford AB, 3rd Level
Employee Benefits Government and Tax Exempt Plans Update
Presented by the Subcommittee on Exempt Organization and Governmental Plans
Chair: David W. Powell, Groom Law Group Chartered, Washington, DC
Vice-Chair: Craig R. Pett, Alston & Bird, Atlanta, GA
Young Lawyer Liaison: Meghan Lynch, TEGE, IRS, Washington, DC
Panelist: Pamela Kinard, Assistant Branch Chief, Qualified Plans, Office of Chief Counsel, IRS,
Washington, DC
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
39
Program Schedule
Thursday,
Friday,
February
January
1720
1:00PM – 5:00PM
Indian Tribal Tax 
Chair: Wendy S. Pearson, Pearson Law Offices, Seattle, WA
Madeleine C, 3rd Level
1:00pm What Tax Lawyers Need to Know About Federal Indian Law. A primer on
federal Indian Law to include the history and background of federal Indian policy;
canons of construction in defining and regulating the relationship between tribal
sovereign governments, state governments and the federal government; basic
definitions within Indian law that set the general boundaries for the field in terms
of political units, individuals, and territory, including a description of “Indian
Country”; a description of authority, structure, and operation of tribal governments;
and a survey of the sources of federal and state power over Indians and tribal
governments, specifically as it relates to federal and state taxation.
Panelists: Joe Lennihan, Santa Fe, NM; Will Micklin, CEO, Ewiiaapaayp Band of
Kumeyaay Indians, Alpine, CA
3:45pm Federal Taxation of Tribes and Their Members – Fundamental Issues and Hot
Topics. This panel will discuss fundamental concepts governing federal income,
employment and excise taxation of tribal governments and their members, such as
the federal tax status of tribes and tribal entities, federal tax treatment of income
earned by tribal members, the tax status of tribal government-sponsored employee
plans, and special tax issues such as minors trusts, general welfare doctrine, and
tribal tax exempt bonds; panelists will also address the latest developments and
hot topics in these areas of federal tax law.
Moderator: Wendy Pearson, Pearson Law Offices, Seattle, WA
Panelists: Kathleen Nilles, Holland & Knight LLP, Washington, DC; John Dossett,
General Counsel, National Congress of American Indians, Washington, DC; Mary
Streitz, Dorsey & Whitney LLP, Minneapolis, MN
Annie, 3rd Level
1:00PM – 2:00PM State & Local Taxes: Current Developments in California FTB Settlement Procedures
The Director of the Settlement Bureau of the California Franchise Tax Board (FTB) will provide
an overview of the FTB settlement processes and procedures and discuss the FTB administrative
appeal process.
Moderator: Debra Herman, Morrison & Foerster, New York, NY
Speaker: Patrick Bittner, Assistant Chief Counsel, Director Settlement Bureau, California Franchise
Tax Board, Rancho Cordova, CA
1:30PM – 2:30PM
Court Procedure & Practice Roundtable Discussion 
Chair: Pete Lowy, Shell Oil Company, Houston, TX
Manchester I, 2nd Level
1:30pm Court Procedure Issues In CDP Judicial Review. This panel will discuss the
procedural issues involved in the Tax Court’s review of the IRS’s determinations in
CDP cases, including jurisdictional issues and the standard of review.
Moderator: Zhanna A. Ziering, Caplin & Drysdale Chartered, New York, NY
Speakers: Honorable Peter J. Panuthos, Chief Special Trial Judge, US Tax Court,
Washington, DC; Susan T. Mosley, Branch Chief, Office of Chief Counsel Procedure
and Administration, IRS, Washington, DC; Juan F. Vasquez, Chamberlain Hrdlicka
White Williams & Aughtry, Houston, TX
40
Program Schedule
Thursday,
Friday, February
January 17
20
1:30PM – 5:30PM
Manchester E, 2nd Level
Employment Taxes 
Chair: William Hays Weissman, Littler Mendelson PC, Walnut Creek, CA
1:30pm Federal Update. An overview of developments affecting employment taxation from
the Department of Treasury and the IRS.
Moderator: Chaya Kundra, Kundra & Associates, Rockville, MD
Panelist: Paul Carlino, Branch Chief, Office of Chief Counsel, IRS, Washington, DC
2:30pm Employment Tax Issues Relating to Health Care. The health care law affected
employment taxes and related reporting requirements as well. Panelists will
discuss current employment tax issues relating to health care as well as
changes under the PPACA, such as the new W-2 reporting requirements
for employers.
Moderator: GJ Stillson MacDonnell, Littler Mendelson PC, San Francisco, CA
Panelists: Paul Carlino, Branch Chief, Office of Chief Counsel, IRS,
Washington, DC; Stephen Tackney, Special Counsel to Division Counsel, Office of
Chief Counsel, IRS, Washington, DC
3:30pm California Employment Taxes and the Employment Development Department.
Did you know that the California Employment Development Department is actually
the largest tax agency in California and one of the largest in the United States?
This panel will discuss the current goings on at the EDD.
Moderator: William Hays Weissman, Littler Mendelson PC, Walnut Creek, CA
Panelists: Shanon Pavao, Empolyment Development Department, Sacramento,
CA; Jennifer Gillette, Employment Development Department, Escondido, CA
4:30pm Practitioner’s Roundtable.
This program is an opportunity to ask your
colleagues and IRS representatives your most vexing employment tax questions
and share information on an informal basis. This program is not recorded and
there is no CLE. The IRS is not bound to answer any questions and its informal
guidance is not binding on the IRS.
1:30PM – 2:30PM
Manchester C, 2nd Level
Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittee

1:30PM – 3:30PM
Foreign Lawyers Forum 
Chair: Thomas B. Akin, McCarthy Tétrault LLP, Toronto, ON
Elizabeth DE, 2nd Level
1:30pm Special Taxes on Financial Institutions and Transactions. This session will focus
on special bank and financial transactions taxes which have been or are proposed
to be introduced as a response to the financial crisis. The EU Commission has
proposed a Financial Transactions Tax to raise funds from the financial services
sector, and various EU Member States have already introduced special taxes for
banks and financial institutions.
Moderator: Steven M. Rosenthal, Visiting Fellow, Tax Policy Center,
Washington, DC
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
41
Program Schedule
Thursday,
Friday,
February
January
1720
Panelists: Lodewijk Berger, Loyens & Loeff, New York, NY; Michael T. McGowan,
Sullivan & Cromwell LLP, London, England; Michel Collett, CMS Bureau Francis
Lefebvre, Neuilly-sur-Seine, France
2:30pm Renewed Pursuit of Tax Avoidance and Evasion. This session will focus on the
special efforts of governments and tax authorities to increase the collection of
taxes by cracking down on cross border tax avoidance and evasion. The US has
introduced FATCA, but other countries also are introducing initiatives to try to
collect tax in respect of income and assets held by their taxpayers abroad.
The panel will cover topics such as the OECD’s Global Forum developments
relating to tax transparency and exchange of information, the current state of
information exchange treaties, voluntary disclosure facilities, other bilateral and
multilateral treaty initiatives, the current status of the EU savings directive and
enhanced cooperation between tax authorities.
Moderator: Alan W. Granwell, DLA Piper LLP, Washington, DC
Panelists: Thierry Boitelle, Bonnard Lawson International, Geneva, Switzerland;
Bruce Zagaris, Berliner Corcoran & Rowe LLP, Washington, DC
1:30PM – 4:00PM
Standards of Tax Practice  
Chair: Diana L. Erbsen, DLA Piper LLP (US), New York, NY
Manchester G, 2nd Level
1:30pm Ethical Issues in Federal Tax Practice – The Government Perspective.  The
panelists will provide an update on recent guidance from the IRS and Department
of Treasury on ethical issues and recent developments at the Office of Professional
Responsibility. Topics will include recent amendments to and interpretations of
Circular 230.
Panelists: Karen L. Hawkins, Director, Office of Professional Responsibility,
IRS, Washington, DC; Deborah A. Butler, Associate Chief Counsel, Procedure
and Administration, IRS, Washington, DC; Richard Goldstein, Special Counsel,
Procedure and Administration, IRS, Washington, DC; Matt Lucey, Attorney,
Procedure and Administration, IRS, Washington, DC; Matt Cooper, Senior
Technical Reviewer, Procedure and Administration, IRS, Washington, DC
2:20pm Circular 230’s Range of Disciplinary Sanctions: How Bad Can it Get &
How is it Determined?  Circular 230 provides that the Commissioner or his
delegate has discretion to propose a range of discipline, including reprimands,
suspensions, and disbarments, on practitioners who fail to meet the standards
set forth therein and discretion to impose additional terms and conditions as a
condition of reinstatement following discipline. The panelists will discuss how the
Office of Professional Responsibility, as the Commissioner’s delegate, exercises
that discretion and what mitigating and aggravating factors may be taken into
account in a determination of the appropriate sanction or in imposing conditions
for reinstatement.
Moderator: Jeremiah Coder, Tax Analysts, Washington, DC
Panelists: Karen L. Hawkins, Director, Office of Professional Responsibility, IRS,
Washington, DC; Rita A. Cavanagh, Latham & Watkins LLP, Washington, DC;
Matthew C. Hicks, Caplin & Drysdale, Washington, DC
42
Program Schedule
Thursday,
Friday, February
January 17
20
3:10pm Pro Bono Representations: Ethical Issues Specific to the Pro Bono Context. 
A practical discussion of ethical issues involved in representing taxpayers in pro
bono tax cases. This panel will focus on issues that arise repeatedly in this arena,
including the potential conflict between the taxpayer’s right to a day in Court and
counsel’s ability to argue certain positions.
Moderator: Frank Agostino, Frank Agostino & Associates, Hackensack, NJ
Panelists: Honorable Diane L. Kroupa, Judge, US Tax Court, Washington, DC;
Monica Koch, IRS Counsel, Westbury, NY
Co-sponsored by: Pro Bono
2:00PM – 5:30PM
Closely Held Businesses 
Chair: Eric Green, Convicer Percy & Green LLP, Glastonbury, CT
Manchester A, 2nd Level
2:00pm Impact of New Health Care Law on Closely Held Businesses. This panel will
focus on the landmark 2010 health care law as it affects employers. The panel
will discuss what issues are before the US Supreme Court, what changes occur
for employers and when, what changes in the original law and/or its effective
dates have occurred since its enactment, the applicability and calculation of, and
exceptions from, the employer and individual “mandates,” what health benefits are
unaffected by health reform, the significance of grandfathered plans and Simple
cafeteria plans, the new premium tax credit and its impact on employers, the new
small employer tax credit, the new state health insurance exchanges, and changes
in FSAs, Medicare taxes and other related tax changes.
Moderator: Ronald Levitt, Sirote & Permutt PC, Birmingham, AL
Panelists: Thomas Nichols, Meissner Tierney Fisher & Nichols SC, Milwaukee,
WI; Stephen Looney, Dean Mead Egerton Bloodworth Capouano & Bozarth PA,
Orlando, FL; Alson Martin, Lathrop & Gage LLP, Overland Park, KS
3:30pm Update on Health Care Reform. The Panel will discuss the continuing efforts of
the IRS to implement Health Care Reform in light of coordination with HHS, the
DOL and the states.
Moderator: William Prescott, Wickens Herzer Panza Cook & Batista Co, Avon, OH
Panelists: Michala Irons, Passthrough & Special Entities, Office of Chief Counsel,
IRS, Washington, DC; Robin Tuczak, Senior Program Analyst, IRS, Davenport, IA;
Thomas Nichols, Meissner Tierney Fisher & Nichols SC, Wilwaukee, WI
5:00pm Closely Held Businesses Committee Planning Meeting.
our committee’s CLE programs for future meetings.
2:00PM – 6:30PM
Employee Benefits 
Chair: Joni L. Andrioff, Littler Mendelson PC, Chicago, IL
Join us to help plan
Elizabeth FG, 2nd Level
2:00pm DOL Disclosure and Reporting Update: Participant and Plan-Level Fee
Disclosures and EFAST2 and Audit Reporting Issues. This panel of government
representatives and practitioners will discuss current Department of Labor plan
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
43
Program Schedule
Thursday,
Friday,
February
January
1720
disclosure and reporting topics. Included in the discussion will be a review of
regulatory requirements and practical issues to consider as the first participantlevel fee disclosures under ERISA section 404(a) and (c) and plan-level fee
disclosures under ERISA section 408(b)(2) are developed. The panel will also
review annual plan reporting issues under EFAST2, including the treatment of late,
missing or deficient independent audit reports.
Moderator: Martha L. Hutzelman, Kruchko & Fries, McLean, VA
Panelists: Allison Wielobob, Office of Regulations and Interpretations, Employee
Benefits Security Administration, US Department of Labor, Washington, DC;
Bertha Minnihan, Moss Adams LLP, Santa Clara, CA; Ronald J. Triche, Trucker
Huss, San Francisco, CA 3:00pm Practical Considerations in Providing Benefits and Equity Compensation to
a Global Workforce. As the world continues to shrink, benefit practitioners are
increasingly asked to address questions that impact employees both in and
outside the United States. This panel will discuss issues practitioners should
consider in various jurisdictions around the world when addressing benefit issues
and will provide practical tips for advising clients with respect to benefit plans that
have a global reach. In addition, this panel will discuss issues associated with
design and implementation of equity plans on a global scale.
Moderator: Susan A. Wetzel, Haynes and Boone, LLP, Dallas, TX
Panelists: Todd A. Solomon, McDermott Will & Emery, Chicago, IL; Mark C.
Jones, Pillsbury Winthrop Shaw Pittman LLP, Los Angeles, CA
4:00pm Hot Topics. Representatives from the agencies will review recent guidance from,
and current developments at, their agencies impacting employee benefits.
Moderator: John Utz, Utz Miller & Eickman LLC, Overland Park, KS
Panelists: George H. Bostick, Benefits Tax Counsel, Department of Treasury,
Washington, DC; J. Mark Iwry, Senior Adviser to the Secretary and Deputy
Assistant Secretary for Retirement and Health Policy, Department of Treasury,
Washington, DC; Ingrid Grinde, Office of Rulings and Agreements, IRS,
Washington, DC; Victoria Judson, Division Counsel/Associate Chief Counsel,
TEGE, IRS, Washington, DC; Alan Tawshunsky, Deputy Division Counsel/Deputy
Associate Chief Counsel, Employee Benefits, Office of Division Counsel/Associate
Chief Counsel, TEGE, IRS, Washington, DC
5:00pm Fireside Chat.
Informal discussion with Department of Treasury and IRS
representatives on topics of interest to attendees.
6:00pm Networking Reception.
Sponsored by: Practical Law Company
Elizabeth Foyer, 2nd Level
2:00PM – 4:30PM
Elizabeth BC, 2nd Level
Exempt Organizations 
Chair: Suzanne Ross McDowell, Steptoe & Johnson LLP, Washington, DC
44
Program Schedule
Thursday,
Friday, February
January 17
20
2:00pm The Future of the Charitable Deduction. A discussion of likely limits on the
charitable contribution deduction in the future in the United States, comparing the
President’s proposal with other significant proposals, employing statistical data to
demonstrate the impact of different levels of change, and suggesting ways that the
charitable community can respond.
Moderator: Professor Ellen Aprill, Loyola Law School, Los Angeles, CA
Panelist: Reynolds Cafferata, Rodriguez Horii Choi & Cafferata, Los Angeles, CA
3:00pm VAT and the Tax-Exempt Sector: Unique US Tax Issues. A value added tax
(VAT) is a topic that frequently comes up in discussions of tax reform in the
United States. This presentation, based on the work of Harley Duncan and Walter
Hellerstein, will discuss the policy, economic and administrative issues involved in
dealing with nonprofit and charitable entities under a value added tax, including
different approaches taken in selected countries. It will also briefly examine the
unique intergovernmental and constitutional issues that would arise if a VAT were
applied to governmental entities.
Moderator: Suzanne Ross McDowell, Steptoe & Johnson LLP, Washington, DC
Panelist: Harley Duncan, KPMG LLP, Washington, DC
4:00pm Cash bar.
Elizabeth Foyer, 2nd Level
2:00PM – 5:00PM
Madeleine A & Mohsen B, 3rd Level

Young Lawyers Forum – 11th Annual Law Student Tax Challenge
Final Rounds (Open to the Public)
Two separate competitions – one for JD finalists and one for LLM teams – will be held before
separate panels of judges. Based on their oral presentations of solutions to the tax planning and
client counseling problem, winners from each division will be chosen and announced at the
Diversity and Young Lawyers Reception.
2:30PM – 5:30PM
Bankruptcy & Workouts  
Chair: Kenneth Weil, Law Office of Kenneth C Weil, Seattle, WA
Manchester F, 2nd Level
2:30pm Tax Court or Bankruptcy Court – What, Where, How and Why?  This
panel will explore the nuances of litigating in Bankruptcy Court as compared to
Tax Court.
Moderator: Bob Pope, White & Reasor, Nashville, TN
Panelists: Frances Sheehy, Law Office of Frances Sheehy, Coconut Creek, FL;
Honorable Judge Mark Wallace, US Bankruptcy Court, Santa Ana, CA; Ellen
Friberg, Area Counsel, SBSE, Area 3, Office of Chief Counsel, IRS, Jacksonville,
FL; Kathryn Meyer, Special Assistant US Attorney, IRS, Los Angeles, CA;
Honorable Peter J. Panuthos, Chief Special Trial Judge, US Tax Court, Washington,
DC; Mitchell Horowitz, Fowler White Doggs, Tampa, FL
4:00pm Acquisition of Troubled Corporations. The panel will focus on diligence
and structuring issues related to the acquisition of troubled companies and
corporations with significant NOLs.
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
45
Program Schedule
Thursday,
Friday,
February
January
1720
Moderator: Professor Don Leatherman, University of Tennessee College of Law,
Knoxville, TN
Panelists: Dana Lasley, Deloitte Tax LLP, St. Louis, MO; Suresh Advani, Sidley &
Austin, Chicago, IL
5:00pm New Developments 2011. Panel will discuss cases, regulations, and rulings from
2011 that are related to bankruptcy and workouts.
Panelists: Kenneth Weil, Law Office of Kenneth Weil, Seattle, WA; Lee Zimet,
Deloitte Tax LLP, New York, NY
2:30PM – 5:30PM
Court Procedure & Practice 
Chair: Pete Lowy, Shell Oil Company, Houston, TX
Manchester I, 2nd Level
2:30pm Important Developments. This panel will provide an update on recent
developments and remarks from the US Tax Court and IRS Chief Counsel. It will
also discuss recent cases and rule changes of particular interest to tax litigators.
Moderator: Pete Lowy, Shell Oil Company, Houston, TX
Speakers: Honorable John Colvin, Chief Judge, US Tax Court, Washington, DC;
Deborah A. Butler, Associate Chief Counsel, Procedure and Administration, IRS,
Washington, DC; Rachel Partain, Caplin & Drysdale Chartered, New York, NY
3:00pm E-Litigation: Leveraging Technology Throughout Your Case. Technology has
changed the way cases – including tax cases – are litigated. Although many recent
presentations have focused on the burdens of “e-discovery,” this presentation
focuses on the opportunities of “e-litigation.” If leveraged properly, technology
can improve the quality and efficiency of your case preparation and presentation.
A demonstration of current software programs and what they can do for your
practice will be provided through a series of PowerPoint examples. The panel
will discuss how technology can be leveraged during every stage of your case –
including discovery, motion practice, and trial. Simplicity and cost-effectiveness
will be emphasized.
Moderator: Grover Hartt, Senior Litigation Counsel, US Department of Justice, Tax
Division, Dallas, TX
Panelist: Christopher R. Egan, Trial Attorney, Southwestern Civil Trial Section,
Department of Justice, Tax Division, Dallas, TX
3:50pm Parallel Civil Tax Litigation and Criminal Investigations. This panel will
examine the issues that arise when litigating civil tax cases while parallel
criminal investigations are ongoing involving the taxpayer and/or key witnesses,
including consideration of the invocation of 5th Amendment privileges, the effect
on discovery, requests for continuances of trial, enforcement of trial subpoenas,
admissibility of evidence, and the prejudicial impact of such investigations on the
trier of fact.
Moderator: Mark D. Allison, Caplin & Drysdale, New York, NY Speakers: Honorable Peter J. Panuthos, Chief Special Trial Judge, US Tax Court,
Washington, DC; Bruce Meneely, Deputy Area Counsel, SB/SE, IRS, Kansas City,
MO; Bryan Skarlatos, Kostelanetz & Fink LLP, New York, NY
46
Program Schedule
Thursday,
Friday, February
January 17
20
4:40pm Litigating R&D Cases. The panelists will discuss their recent experiences
litigating significant Research & Development tax credit cases for both
taxpayers and the government and strategic considerations including sampling
methodologies, substantiation of research activities and expenses, pretrial
discovery, summary judgment, stipulations and exhibits, fact and expert
witnesses, and electronic courtroom technology.
Moderator: Alex Sadler, Ivins Phillips & Barker Chartered, Washington, DC
Speakers: Michael Powell, Tax Division, US Department of Justice, Dallas, TX;
Mary Monahan, Sutherland Asbill & Brennan LLP, Washington, DC; Jeffrey
Moeller, Ivins Phillips & Barker Chartered, Washington, DC
2:30PM – 4:30PM
Energy & Environmental Taxes  
Chair: Deborah Gordon, KPMG, Washington, DC
Molly, 2nd Level
2:30pm Hot Tax Topics for Utilities. The panel will discuss recent developments, including
the tax treatment of appreciated power purchase agreements in renewable
acquisition transactions, treatment of network assets under the repair regulations,
deal structures in a post 1603 treasury grant environment, and various state and
local issues.
Moderator: Todd Reinstein, Pepper Hamilton LLP, Washington, DC
Panelist: Benjamin Haas, Exelon Corporation, Philadelphia, PA; Courtney Sandifer,
PricewaterhouseCoopers, Washington, DC
3:30pm New Excise Tax on Medical Devices.  Discussion of the new medical device
excise tax that applies to sales by manufacturers and importers of taxable medical
devices beginning January 1, 2013, and how companies in the medical device
industry can prepare for it.
Moderator: Deborah Gordon, KPMG LLP, Washington, DC
Panelists: Taylor Cortright, KPMG LLP, Washington, DC; Stephanie Bland, Senior
Technician Reviewer, Office of Chief Counsel, IRS, Washington, DC
2:30PM – 5:30PM
Financial Transactions 
Chair: Lucy Farr, Davis Polk & Wardwell LLP, New York, NY
Elizabeth H, 2nd Level
2:30pm Short Derivatives: Getting Topsy Turvy. This panel will discuss the issues unique
to derivatives that provide a “short” exposure to property, including short sales,
short swaps and short options. The rules addressing these instruments are
outdated and in some instances inconsistent, and the application of other rules
(such as the wash sale rules and the taxable modification rules of section 1001)
to these positions is often unclear.
Moderator: Robert Scarborough, Freshfields Bruckhaus Deringer LLP,
New York, NY
Panelists: Eileen Marshall, Wilson Sonsini Goodrich & Rosati, Washington, DC;
Michael Novey, Associate Tax Legislative Counsel, Department of Treasury,
Washington, DC
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
47
Program Schedule
Thursday,
Friday,
February
January
1720
3:30pm Contingent Swaps and the New Regime. This panel will discuss contingent
notional principal contracts and related derivatives, such as prepaid forwards and
bullet swaps, that have contingent payments, with a focus on the anticipated
guidance to be issued by the IRS and Department of Treasury on these contracts.
In particular, the panel will address the definition of “notional principal contract”
and the new timing and character rules.
Moderator: David Garlock, Ernst & Young LLP, Washington, DC
Panelists: Stephen Larson, Associate Chief Counsel, Office of Chief Counsel, IRS,
Washington, DC; Rebecca Lee, PricewaterhouseCoopers LLP, San Francisco, CA
4:30pm Section 871(m): New Guidance on Cross-Border Equity Swaps. This panel will
address the expected new rules regarding withholding on dividend-equivalent
payments on equity swaps and other similar equity derivatives. In particular,
the panel will explore the types of swaps subject to the withholding regime, the
scope of other derivatives subject to the regime, and other related issues such as
cascading withholding obligations and the characterization of dividend equivalents
for treaty purposes.
Moderator: Rachel Kleinberg, Davis Polk & Wardwell LLP, Menlo Park, CA
Panelists: L.G. (Chip) Harter, PricewaterhouseCoopers LLP, Washington, DC; Peter
Merkel, Attorney-Advisor, Office of Chief Counsel, IRS, Washington, DC; Karl Walli,
Senior Counsel, Financial Products, Department of Treasury, Washington, DC
2:30PM – 6:00PM
Public Service Fellowship
(Executive Session)
Chair: Susan P. Serota, Pilsbury Winthrop Shaw Pittman LLP, New York, NY
2:30PM – 5:30PM
Real Estate 
Chair: Eliot L. Kaplan, Squire, Sanders & Dempsey LLP, Phoenix, AZ
Emma C, 3rd Level
Manchester B, 2nd Level
2:30pm Minimizing Gain/Maximizing Loss: May I Cherry Pick Property? This panel
will explore the art of and ability to sell high basis property and transfer
in a tax-deferred transaction low basis property under sections 351, 453,
721(a) and 1031.
Moderator: Michael G. Frankel, Ernst & Young LLP, Miami, FL
Panelists: Terence F. Cuff, Loeb & Loeb LLP, Los Angeles, CA; Louis S. Weller,
Deloitte Tax LLP, San Francisco, CA
3:30pm Installment Sales: Interesting and Unresolved Issues. This panel will review
installment sale issues, including earn-outs, significant modifications of an
installment note under section 453 and Reg. section 1.1001-3, reacquisitions
under section 1038 and consequences to a distributee partner after the
distribution of an installment note from a partnership.
Moderator: Jill E. Darrow, Katten Muchin Rosenman LLP, New York, NY
Panelist: Adam Handler, PricewaterhouseCoopers LLP, Los Angeles, CA
48
4:00pm What Is Real Property and Why Do I Care? This panel will focus on the
definition of real property for purposes of sections 512, 856, 897 and 1031,
including the proper classification of various infrastructure assets, valuation issues
and the classification of intangible assets associated with real estate.
Moderator: David A. Miller, Ernst & Young LLP, Dallas, TX
Program Schedule
Thursday,
Friday, February
January 17
20
Panelists: James H. Lokey, King & Spalding LLP, Atlanta, GA; Gino J. Bianchini,
Greenberg Traurig LLP, Irvine, CA
4:35pm Real Estate Funds: A Potpourri of Issues that Vex the Practical Practitioner.
This panel will discuss a variety of issues that arise in connection with real estate
funds, including open ended fund issues, potential capital shifts, disguised sale
issues, super partnership issues, deduction of management fees under section
162 v. 212 under Rev. Rul. 2008-39, foreign government exemption under
section 892 and taxable mortgage pools under section 7701(i).
Moderator: Pardis Zomorodi, Latham & Watkins LLP, Los Angeles, CA
Panelists: Darryl Steinhause, DLA Piper, San Diego, CA; Thomas S. Wisialowski,
Paul Hastings LLP, Palo Alto, CA
2:30PM – 6:00PM State & Local Taxes 
Chair: Bill Prugh, Polsinelli Shughart PC, Kansas City, MO
Ford AB, 3rd Level
2:30pm Current Developments: Series LLCs.
An update on the states’ tax treatment
of series LLCs, including a summary of state revenue department’ responses to a
recent questionnaire from the SALT Committee on that topic.
Moderator: Bruce P. Ely, Bradley Arant Boult Cummings LLP, Birmingham, AL
Panelists: J. Leigh Griffith, Waller Landsen Dortch & Davis LLP, Nashville, TN;
James E. Long, Jr., Bradley Arant Boult Cummings LLP, Birmingham, AL
3:00pm Subcommittee Reports: Publications & Seminars.
A brief report by the
subcommittees on the Committee’s Sales & Use Tax Deskbook and the ABA-IPT
Advanced Tax Seminars in 2012.
Moderator: John H. (Jay) Simpson, Shook Hardy & Bacon, Kansas City, MO
Panelists: Gregg D. Barton, Perkins & Coie, Seattle, WA; Doug Sigel, Scott Douglas
& McConnico LLP, Austin, TX
3:15pm Remote Sales & Nexus Issues. May 26, 2012 is the 20th Anniversary of the Quill
decision in which the US Supreme Court upheld the requirement that a remote
seller must have physical presence before being required to collect use tax. The
states have been challenging the physical presence requirement for some time,
but the efforts to overturn Quill have intensified recently. Current efforts to expand
the obligations of out-of-state sellers to collect use tax include several competing
bills in Congress. “Amazon click-through nexus statutes,” and state statutes
demanding identification of in-state customers when no use tax is collected. The
panelists will provide insight into what is happening across the county and where
the process seems to be heading.
Moderator: Edward J. Bernert, Baker & Hostettler, Columbus, OH
Panelists: George Isaacson, Brann & Isaacson, Lewiston, ME; R. Bruce Johnson,
Utah State Tax Commission, Salt Lake City, UT; Kurt A. Lamp, Amazon.com,
Seattle, WA
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
49
Program Schedule
Thursday,
Friday,
February
January
1720
4:10pm Apportionment: Sales Factors Based on Benefit Received. A new trend in
apportionment and the determination of the numerator of the sales factor for other
than the sale of tangible personal property (in other words, services), is to assign
gross receipts to the numerator based upon where the benefit of the service is
received. Examples include California, Georgia, Wisconsin, Michigan, Ohio and
Washington. However, despite statutory and regulatory provisions, the concept of
determining where the benefit is received may be elusive. This panel will look at
these provisions, the guidance provided by the states, and try to make sense of it.
Additionally, the panel will raise issues about the fairness and constitutionality of
such a method or component of the apportionment factor.
Moderator: Gregg D. Barton, Perkins Coie LLP, Seattle WA
Panelists: Bob Mahon, Perkins Coie LLP, Seattle, WA; David Shipley, McCarter &
English LLP, Philadelphia, PA; Giles Sutton, Grant Thornton LLP, Charlotte, NC
5:05pm Digital Downloads and On-Line Services – Taxing Issues in the Virtual Realm.
Digital downloads and on-line services create unique state and local tax issues.
Traditional principles of taxation don’t easily resolve issues arising in a virtual
economy made possible by technological advances. This panel will discuss trends
and developments in this rapidly evolving era.
Moderator: Jaye Calhoun, McGlinchey Stafford PLLC, New Orleans, LA
Panelists: Arthur Rosen, McDermott Will & Emery, New York, NY; Kelley C. Miller,
Reed Smith LLP, Philadelphia, PA
2:30PM – 5:30PM
Tax Accounting 
Chair: Ellen McElroy, Pepper Hamilton LLP, Washington, DC
Gregory, 2nd Level
2:30pm Recent Developments in Tax Accounting. This panel will cover important recent
developments in the tax accounting area since the October 2011 meeting in
Denver. Additionally, the panel will review ongoing projects and anticipated
guidance, with commentary and input from our guests from the Treasury Office of
Tax Policy (Department of Treasury) and the Internal Revenue Service (IRS).
Moderator: Sam Weiller, Ernst & Young, Columbus, OH
Panelists: Andrew J. Keyso, Deputy Associate Chief Counsel, Income Tax and
Accounting, Office of Chief Counsel, IRS, Washington, DC; Scott Dinwiddie,
Special Counsel to the Associate Chief Counsel, Income Tax and Accounting,
Office of Chief Counsel, IRS, Washington, DC; Alexa Claybon, Office of Tax Policy,
Department of Treasury, Washington, DC; Natalie Tucker, McGladrey & Pullen LLP,
Jacksonville, FL
3:00pm Inventory: Recent Guidance, Anticipated Guidance. The government has issued
recent guidance concerning inventory valuation and continues to work to address
inventory issues. This panel will include a review of recent and anticipated
guidance on a variety of issues, including sales-based royalties and vendor
allowances; the retail inventory method; and uniform capitalization.
Moderator: Scott Vance, KPMG, Washington, DC
Panelists: Rich Shevak, Grant Thornton, Seattle, WA; Alice Joseffer, Hodgson
Russ, Buffalo, NY; Martin Scully, Senior Counsel, Branch 6, Office of Chief
Counsel, IRS, Washington, DC
50
Program Schedule
Thursday,
Friday, February
January 17
20
4:00pm Considering the Proper Tax Accounting Treatment of Advance Payments in a
Corporate Transaction. One question that arises in Taxable Asset Acquisitions
is the treatment of advance payments. Although some professionals believe the
buyer is taxed on the advance payments in the same way as the seller, others
believe the advance payment is not taxable income to the buyer on the basis that
the seller would have reported the advance payments, with an offsetting deduction
under the Pierce case. This panel will discuss these issues and the authorities
supporting various positions.
Moderator: Carol Conjura, KPMG, Washington, DC
Panelists: John Moriarty, Branch Chief, Branch 1, Office of Chief Counsel, IRS,
Washington, DC; Alexa Claybon, Office of Tax Policy, Department of Treasury,
Washington, DC; Barbara J. Young, Marriott International, Bethesda, MD; Annette
Ahlers, Pepper Hamilton LLP, Washington, DC
4:45pm Issues Arising in Tax Controversies Involving Tax Accounting Issues. Recently,
there has been an increase in the examination of tax accounting issues. This
panel will address the range of tax accounting issues that have been seen in
recent examinations. They will also provide recommendations for preparing for
examinations involving tax accounting issues, as well as strategic considerations
and recommendations for resolution.
Moderator: Rita Cavanagh, Latham & Watkins, Washington, DC
Panelists: Mark Mesler, Ernst & Young, Atlanta, GA; Stephen F. Gertzman, Miller
& Chevalier, Washington, DC
2:30PM – 5:30PM
Tax Exempt Financing 
Chair: John Swendseid, Sherman & Howard LLC, Reno, NV
Manchester D, 2nd Level
2:30pm Legislative, Department of Treasury and IRS Update. This panel will discuss
new legislative initiatives that may affect tax-exempt financing, and new
Department of Treasury and IRS regulations and other guidance in the tax-exempt
bond area.
Moderator: John Swendseid, Sherman & Howard, Reno, NV
Panelists: Perry Israel, Law Office of Perry Israel, Sacramento, CA; James Polfer,
Chief, Branch 5, Financial Institutions and Products, Office of Chief Counsel, IRS,
Washington, DC; Stefano Taverna, McCall Parkhurst & Horton LLP, Dallas, TX
3:30pm VCAP and Other Compliance and Program Management Initiatives. This panel
will discuss the new VCAP procedures released in 2011, approaches that are
helpful in dealing with VCAP and ones that are not helpful, the use and results of
the advance refunding questionnaire that was distributed last year, and the results
and use of other CPM Initiatives.
Moderator: Christie Martin, Edwards Wildman Palmer LLP, Boston, MA
Panelists: Todd Mitchell, Group Manager, Compliance and Program Management,
Tax-Exempt Bonds, IRS, El Segundo, CA; Perry Israel, Law Office of Perry Israel,
Sacramento, CA; Steve Watson, Fulbright & Jaworski LLP, Washington, DC
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
51
Program Schedule
Thursday,
Friday,
February
January
1720
4:30pm Tax Implications of On-Behalf-Of Financings. This panel will focus on various
tax aspects of on behalf of financings. Issues to be discussed will include the
various requirements for a successful on behalf of financing, including primarily
what types of activities are essentially public in nature; the different ways that a
governmental unit can meet the requirement that it have a beneficial interest in
the on behalf of corporation; the requirement that the governmental unit obtain
legal title to the financed property once the obligations are retired; the tangible
real or tangible personal property rules; and the other rules relating to on behalf
of financings in Rev. Proc. 82 26 and other guidance. The panel will also discuss
other implications on the nonprofit organization itself, such as the necessity to file
income tax returns (Form 990 or Form 1120) to the extent the corporation is not a
governmental unit itself.
Moderator: Nancy Lashnits, Steptoe & Johnson PLLC, Phoenix, AZ
Panelists: James Polfer, Branch Chief, Branch 5, Financial Institutions and
Products, Office of Chief Counsel, IRS, Washington, DC; Carol Lew, Stradling
Yocca Carlson & Rauth, Newport Beach, CA
3:00PM – 4:00PM Elizabeth A, 2nd Level
Diversity 
Chair: Vanessa A. Scott, Sutherland Asbill & Brennan LLP, Washington, DC
3:00pm Could 9-9-9 Ever Really Work? Considering Alternative Taxation Structures
on the Road to a Fairer, Simpler Tax System. Given the recent debate over the
deficit, massive tax reform will likely be at the top of the Congressional agenda in
2012. In addition to raising revenue, legislators have expressed a desire to move
toward a fairer, simpler tax system for both individuals and corporations. But who
wins and who loses under some of the proposals that we’ve heard about? Could
a flat and/or a consumption tax work? How does politics factor into the proposals?
The panel will discuss the benefits and drawbacks of certain alternative taxation
regimes, the rhetoric and consequences associated with tax reform, and the
impact that the debate could have on various classes of taxpayers.
Moderator: Cathy Fung, Attorney, Office of Associate Chief Counsel, Financial
Institutions & Products, IRS, Washington, DC
Panelists: Professor Linda M. Beale, Wayne State University Law School, Detroit,
MI; Professor Julie Manasfi, Whittier Law School, Costa Mesa, CA
3:00PM – 6:00PM
Insurance Companies  
Chair: Craig Springfield, Davis & Harman LLP, Washington, DC
Manchester C, 2nd Level
3:00pm Transfer Pricing and Insurance. The globalization of the insurance industry
coupled with new and evolving regulatory and legislative requirements has
resulted in a complex transfer pricing environment for multinational insurance
companies. Add to this mix the urgent need for revenue by fiscal authorities in the
US and throughout the globe, and the result is a complex web of compliance and
controversy issues that insurance tax professionals are charged with navigating.
This panel will address the transfer pricing issues that insurance tax professionals
should be aware of and provide practical advice on how to meet the global tax and
regulatory requirements in this arena.
Moderator: Mark Smith, PricewaterhouseCoopers LLP, Washington, DC
52
Program Schedule
Thursday,
Friday, February
January 17
20
Panelists: Frank Douglass, PricewaterhouseCoopers LLP, New York, NY; Julia
Sceats, AIG, United Kingdom
3:50pm Health Care Reform – Tax and Fee Implementation Issues Affecting the
Insurance Industry and the Scope of “Health Insurance.” The panel will
explore selected issues regarding taxes and fees imposed by the Affordable
Care Act and the challenges faced by the insurance industry in connection with
their implementation, including the new limits on excessive compensation, the
annual health insurer fee, and the Patient-Centered Outcomes Research Fee.
The panel will examine the scope of “health insurance” in various contexts, and
will particularly discuss issues in connection with stop loss coverage. Finally, the
panel will touch on other tax and fee implementation issues associated with health
care reform.
Moderator: Craig Springfield, Davis & Harman LLP, Washington, DC
Panelists: Allison Ullman, Crowell & Moring LLP, Washington, DC; Frederick
Schindler, Director, Implementation Oversight Affordable Care Act Office, IRS,
Washington, DC
4:40pm DOMA vs. the States, with Tax Rules in the Middle.  This panel will discuss
the interaction of tax-required distribution rules under sections 401(a)(9) and
72(s), the Defense of Marriage Act, and state definitions of “spouse.” The panel
also will discuss the interaction of tax, DOMA, and state rules in other insurance
product contexts, such as in connection with LTC annuity combination products
and the meaning of family term coverage under section 7702.
Moderator: Alison Peak, Davis & Harman LLP, Washington, DC
Panelist: Professor Patricia Cain, Santa Clara University, Santa Clara, CA
5:30pm Update on Recent Tax Developments and Projects on the IRS Priority
Guidance Plan. This panel will discuss recent guidance issued by the IRS
and the issues involved with projects relating to insurance on the IRS Priority
Guidance Plan.
Moderator: Jean Baxley, KPMG LLP, Washington, DC
Panelist: Lori Robbins, Department of Treasury, Washington, DC
3:00PM – 4:00PM
Sponsorships
Chair: Fred T. Witt, Deloitte Tax LLP, Phoenix, AZ
3:30PM – 5:30PM
Foreign Activities of US Taxpayers 
Chair: Carol Tello, Sutherland Asbill & Brennan LLP, Washington, DC
Ford C, 3rd Level
Elizabeth DE, 2nd Level
3:30pm Foreign Tax Credits. In late 2010, the IRS and Department of Treasury issued
Notice 2010-92 on the application of section 909 to foreign income taxes paid or
accrued by a section 902 corporation in taxable years beginning before January
1, 2011. Since then, taxpayers have been waiting for additional guidance on
the application of section 909 as well as section 901(m). This 2-hour panel will
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
53
Program Schedule
Thursday,
Friday,
February
January
1720
analyze recent foreign tax credit guidance, including the expected guidance to
be issued under sections 909 and 901(m), and will explore the impact of this
guidance on taxpayers and their business operations.
Moderators: Martin Collins, PricewaterhouseCoopers LLP, Washington, DC; Natan
Leyva, Ernst & Young LLP, Washington, DC
Panelists: Ginny Chung, Attorney Advisor, Office of Tax Policy, Department of
Treasury, Washington, DC; Brenda Zent, Attorney Advisor, Office of Tax Policy,
Department of Treasury, Washington, DC; Anne O. Devereaux, Senior Technical
Reviewer, Branch 3, Office of Associate Chief Counsel, IRS, Washington, DC; John
Merrick, Special Counsel to the Associate Chief Counsel, IRS, Washington, DC;
Professor Mark S. Hoose, University of San Diego Law School, San Diego, CA
4:00PM – 6:30PM
Elizabeth A, 2nd Level
Young Lawyers Forum  
Chair: Katherine David, Strasburger Price Oppenheimer Blend, San Antonio, TX
4:00pm Making a Difference As a Tax Lawyer.  Was making more time for pro bono
one of your New Year’s resolutions? Always been curious about how tax lawyers
can help those in need of legal services? Join the Young Lawyers Forum for a
discussion of the various ways tax lawyers can use their specialized skills to
provide pro bono services to individuals and non-profit organizations. The panel
will also provide an overview of the Section’s pro bono programs and how young
lawyers can get involved.
Moderator: Catherine B. Engell, DLA Piper LLP, New York, NY
Panelists: Robb A. Longman, McMillan Metro, Rockville, MD; Rachel Ney,
American Bar Association Section of Taxation, Washington, DC; Joseph Barry
Schimmel, Cohen Chase Hoffman & Schimmel PA, Miami, FL
5:30pm Young Lawyers Forum and Diversity Networking Reception.

5:00PM – 6:00PM Professional Services
Chair: John O. Tannenbaum, Attorney at Law, Hartford, CT
5:00PM – 5:30PM
Programs & Meetings
Chair: Fred T. Witt, Deloitte Tax LLP, Phoenix, AZ
Gallery, Ground Level
Emma AB, 3rd Level
Ford C, 3rd Level
5:30PM – 6:30PM
Molly A, 2nd Level
Publications Book Release Reception
Meet the contributors and celebrate the release of the 5th Edition of Effectively Representing
Your Client Before the IRS. Drop off your business card to be entered into a drawing for a free
copy of the book. Hosted by the Publications, Low Income Taxpayers, and Pro Bono Committees.
5:45PM – 6:30PM
Foreign Activities of US Taxpayers Business Meeting
54
Madeleine B, 3rd Level
Program Schedule
Thursday,
Friday, February
January 17
20
5:45PM – 6:30pm Foreign Lawyers Forum Business Meeting
Madeleine D, 3rd Level
5:45PM – 6:30pm US Activities of Foreigners & Tax Treaties Business Meeting
Ford C, 3rd Level
6:30PM – 8:00PM
San Diego Museum of Art
 (Ticketed Event)
Section Reception
Buses being departing at 6:15pm from the main entrance of the Manchester Grand Hyatt.
Tickets must be purchased in advance at the registration desk. Tickets will not be available at
the San Diego Museum of Art.
8:00PM – 10:30PM
Salvatore’s Cucina Italiana, 750 Front St.
Joint International Committees Dinner
 (Reservations Required)
Members of the FAUST, FLF, Transfer Pricing and USAFTT Committees will meet for cocktails
and dinner. First-time attendees are welcome and encouraged to attend.
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
55
Program Schedule
Thursday, February
saturday,
January 20
18
7:00AM – 4:00PM
Elizabeth Foyer, 2nd Level
Hospitality Center
(Complimentary)
Complimentary continental breakfast will be served in the morning. Snacks, coffee, sodas and
water will be available in the afternoon.
7:00AM – 8:30AM
Elizabeth G, 2nd Level
Tax Practice Management, Diversity and Young Lawyers Forum

Tax Practice Management Chair: Jill L. Miller, Jill Miller & Associates PC, New York, NY
Diversity Committee Chair: Vanessa A. Scott, Sutherland Asbill & Brennan LLP, Washington, DC
Young Lawyers Forum Chair: Katherine E. David, Strasburger Price Oppenheimer Blend, San
Antonio, TX
7:00am Informal Discussion and Complimentary Breakfast

7:30am Get Inspired! Motivational Stories of Success from Tax Professionals.

“A Presentation of Inspiring Personal Stories, Focusing on How Difficult Challenges
Were Overcome and the Beneficial Life Lessons Learned.”
Four unique speakers will share stories of their journeys to success, focusing on
difficult or inspirational challenges they have overcome along their career paths
and their perspectives on life’s lessons learned.
Moderator: Professor Michael B. Lang, Chapman University School of Law,
Orange, CA
Panelists: Richard Nenno, Wilmington Trust Corporation, Wilmington, DE;
Honorable Judge Juan F. Vasquez, US Tax Court, Washington, DC; Karen L.
Hawkins, Director, Office of Professional Responsibility, IRS, Washington, DC;
Bahar Schippel, Snell & Wilmer LLP, Phoenix, AZ
7:15AM – 8:30AM
Manchester AB, 2nd Level
Partnerships & LLCs, Real Estate and S Corporations “Shop Talking” Breakfast
(Ticketed Event)
Members of the Partnerships and LLCs, Real Estate, and S Corporations Committees will gather
for the traditional “open mic” breakfast to share ideas and war stories and to seek input on
technical issues.
7:45AM – 9:00AM
Court Procedure & Practice Officers and Subcommittee Chairs Breakfast
8:30AM – 11:30AM
Corporate Tax 
Chair: Joseph Pari, Dewey & LeBoeuf LLP, Washington, DC
Ford AB, 3rd Level
(Ticketed Event)
Elizabeth H, 2nd Level
8:30am North-South Transactions, Section 355 and Other Step Transaction Issues.
The panel will explore various step transaction issues, including so-called “northsouth” transactions (as part of and independent of section 355) in which property
is contributed to, and distributed from, a corporation.
Moderator: Mark Silverman, Steptoe & Johnson LLP, Washington, DC
Panelists: William Alexander, Associate Chief Counsel, Office of Chief Counsel,
IRS, Washington, DC; Glen Kohl, Amazon, Seattle, WA; Joseph Pari, Dewey &
LeBoeuf LLP, Washington, DC; Michael Schler, Cravath Swaine & Moore LLP, New
56
Program Schedule
Saturday,
Thursday,February
January 18
20
York, New York; Karen Gilbreath Sowell, Ernst & Young LLP, Washington, DC;
Thomas Wessel, KPMG LLP, Washington, DC
10:00am Tax Opinions: What Does It Cost You and What Is It Worth to Your Client? This
panel will explore recent guidance related to the tax opinion practice, including
SEC Staff Legal Bulletin 19 (Oct. 14, 2011) related to tax opinions in publicly filed
transactions and Canal Corp. v. Comm’r, as relates to the benefit clients receive
from receiving tax opinions and how that could affect the practice of tax law from
the perspective of outside advisors.
Moderator: Daniel White, BryanCave, St. Louis, MO
Panelist: Jasper Cummings, Alston & Bird, Durham, NC
8:30AM – 11:30AM
Employee Benefits 
Chair: Joni L. Andrioff, Littler Mendelson PC, Chicago, IL
Elizabeth E, 2nd Level
8:30am Plan Drafting and Administrative Issues After Amara. The Supreme Court’s
decision in CIGNA v. Amara may have thrown the proverbial “monkey wrench into
the works” in the areas of plan drafting and administration. The panel will review
the Amara decision and then discuss its impact on qualified and welfare plans,
including the role of the SPD and other employee communications, and claims
for benefits.
Moderator: Mark Bodron, Baker Botts LLP, Houston, TX
Panelists: Eugene Holmes, Proskauer Rose LLP, Washington, DC; Thomas G.
Moukawsher, Moukawsher & Walsh LLC, Groton, CT; Henry Talavera, Hunton &
Williams LLP, Dallas, TX; J. Randal Wexler, Sidley Austin LLP, Chicago, IL
9:30am Worker Classification Issues Under Renewed Focus. This panel will explore
recent developments in worker classification issues, including Department of
Labor, IRS and state agency initiatives to address potential abuses,including
the IRS Voluntary Classification Settlement Program, as well as legislation at
the federal and state levels. The panel will also discuss the impact of worker
classification issues and developments on employee benefit plans.
Moderator: Robert A. Miller, Calfee Halter & Griswold LLP, Cleveland, OH
Panelists: Daniel L. Morgan, Dickstein Shapiro LLP,
Washington, DC; Peter J. Hunt, Pillsbury Winthrop Shaw Pittman LLP;
Victoria Judson, Division Counsel/Associate Chief Counsel, TEGE, IRS,
Washington, DC; Daniel N. Janich, Greensfelder Hemker & Gale PC, Chicago, IL
10:30am Proxy Disclosure 2012: Same As Last Year or New Year, New Challenges? With
the implementation of Say-On-Pay votes in 2011, many companies felt the need
to revisit and revamp their Compensation Discussion and Analysis (CD&A) and
other compensation disclosures in their proxy statements. Now that much of the
Dodd-Frank rulemaking has been delayed, for 2012 will it be sufficient to merely
update last year’s disclosures? Or is there still a lot of hard work ahead? Panelists
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
57
Program Schedule
Thursday, February
saturday,
January 20
18
will discuss current trends in best practices and what steps companies and their
advisors should be taking to respond to continuing pressure from proxy advisors
and how to best position themselves for anticipated SEC rulemaking.
Moderator: Martha N. Steinman, Dewey & LeBoeuf LLP, New York, NY
Panelists: Amy Blackman, Fried Frank, New York, NY; Mark Borges, Compensia
Inc, Corte Madeira, CA; Laura Thatcher, Alston & Bird, Atlanta, GA
8:30AM – 11:30AM
Fiduciary Income Tax 
Chair: Lisa M. Stern, Proskauer Rose LLP, New York, NY
Elizabeth F, 2nd Level
8:30am Recent Developments. Report on recent developments affecting the income
taxation of trusts and estates.
Panelist: Rachel D. Burke, Furey Doolan & Abell LLP, Chevy Chase, MD
8:50am Anatomy of a Form 1041, Fiduciary Income Tax Return. This presentation will
explain practical issues practitioners should consider when preparing or reviewing
Form 1041, US Income Tax Return for Estates and Trusts and provide a practical
checklist of filing issues for practitioners, including discussion of issues arising
from multi-national activities.
Panelist: Aaron Hawthorne, WTAS, Washington, DC
9:40am Making Retirement Benefits Payable to Trusts. This presentation will discuss
making retirement benefits payable to a trust, including QTIP and Credit Shelter
Trusts. Presenters will discuss three (3) comprehensive checklists to consider
when (1) drafting/evaluating the beneficiary designation form, (2) drafting the trust
as beneficiary (or trusteed IRA) and (3) administering a trust that receives such
benefits post-mortem.
Panelists: Edwin P. Morrow III, Key Private Bank, Dayton, OH; Salvatore J.
Lamendola, Giarmarco Mullins & Horton PC, Troy, MI
10:30am Ethical Issues for Trust and Estate Practitioners.  This panel will provide an
overview of the Circular 230 regulations governing practice before the Internal
Revenue Service and how these regulations specifically impact trust and estate
practitioners. The panel also will address the most frequent ethical issues that
arise in everyday tax practice, including due diligence, competence, tax opinion
standards, and conflicts of interest.
Panelists: Karen L. Hawkins, Director, Office of Professional Responsibility, IRS,
Washington, DC; Matthew S. Cooper, Senior Technical Reviewer, Office of the
Associate Chief Counsel, Procedure and Administration, IRS, Washington, DC;
David A. Berek, Handler Thayer LLP, Chicago, IL
8:30AM – 10:30AM
LLCs and LLPs Subcommittee of Partnerhips & LLCs
Chair: Paul Carman, Chapman and Cutler LLP, Chicago, IL
Molly, 2nd Level
8:30am Employee Benefits Implications of the Proposed Series LLCs Regulations.
This panel will discuss the employee benefits issues implicated by the proposed
series LLCs regulations.
Moderator: Elizabeth Drigotas, Deloitte Tax LLP, Washington, DC
58
Program Schedule
Saturday,
Thursday,February
January 18
20
9:30am To Regard or Not to Regard Your Entity.
This panel will discuss of the extent
to which disregarded entities are disregarded for various purposes under the Code.
8:30AM – 10:30AM
Low Income Taxpayers 
Chair: Professor Keith Fogg, Villanova Law School, Villanova, PA
Gregory, 2nd Level
8:30am Introductory Remarks and Administrative Issues.
Panelist: Professor Keith Fogg, Villanova University Law School, Villanova, PA
8:35am National Taxpayer Advocate’s Annual Report to Congress. This annual event
brings Nina Olson to the Committee to talk about her annual report to Congress
and to highlight the most important features of that report.
Panelist: Nina Olson, National Taxpayer Advocate, IRS, Washington, DC
9:15am Dealing with Tax Issues Following a Disaster. This panel seeks to explore the
tax issues raised as a result of disaster. The panelists were the authors of a new
chapter in “Effectively Representing Your Client Before the IRS” on this subject.
One of the panelist, Mark Moreau, has spent the past several years of his career
dealing with the aftermath of Katrina on his clients in New Orleans.
Moderator: Sean Norton, Pine Tree Legal Services, Bangor, ME
Panelists: Mark Moreau, Southeast Louisiana Legal Services, New Orleans, LA;
Mandi Matlock, Texas RioGrande Legal Aid Inc, Austin, TX
9:45am Innocent Spouse – We Won, but Where Are We Now? The great victory of
2011 on the issue of IRC 6015(f) and the two year collection rule left the clinical
community feeling validated and on top of the innocent spouse world. Yet, several
issues remain to be resolved and many clients still have innocent spouse issues
and fights with the IRS. This panel will discuss the Wilson case pending in the 9th
Circuit and the challenge it poses to those claiming innocent spouse status.
Moderator: Anna Tavis, South Brooklyn Legal Services, Brooklyn, NY
Panelists: Professor Carl Smith, Cardozo Law School, New York, NY; Jill MacNabb,
Attorney Advisor, National Taxpayer Advocate, IRS, Washington, DC; Lavar Taylor,
Law Offices of A. Lavar Taylor, Santa Ana, CA
8:30AM – 11:30AM
Manchester F, 2nd Level
Sales, Exchanges & Basis 
Chair: Paul L. B. McKenney, Varnum Riddering Schmidt Howlett LLP, Novi, MI
8:30am Current Developments in Sales, Exchanges and Basis Other Than Sections
1031 & 1033.  Both case law and guidance on sale, exchange and basis
issues other than like-kind exchanges and involuntary conversions will be
addressed.
Moderator: Professor Erik Jensen, Case Western Reserve University School of Law,
Cleveland, OH
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
59
Program Schedule
Thursday, February
saturday,
January 20
18
8:55am Is It Treated As a Sale? Lease? Financing? Constructive Sale? Option?
Something Else? – Part I.  This is the first of a multipart series exploring
perennially reappearing issues regarding - what tax pigeon hole should a
transaction or series of transactions properly be assigned? Taxpayers seek to
monetize now and defer tax until later. Constructive sale rules in general, and
prepaid forward contracts after Anschutz in particular, will be addressed.
Moderator: Paul McKenney, Varnum LLP, Novi, MI
Panelist: Mark Leeds, Greenberg Traurig LLP, New York, NY
9:35am Involuntary Conversions and Qualification of Replacement Property.  Under
existing law, depending on the circumstances of the conversion, taxpayers
suffering an involuntary conversion of property used in a trade or business or held
for rental can be subject to markedly different replacement standards in applying
the nonrecognition provisions of section 1033. This panel will discuss the existing
legal framework for replacement of involuntarily converted property and consider
ways to simplify the existing standards for replacement for trade or business or
rental property.
Moderator: Mark Wilensky, Roberts & Holland LLP, New York, NY
Panelist: Kelly Alton, NES Financial Corp, San Jose, CA
10:10am Build-to-Suit or Full-of-Boot: Analyzing Exchanges Involving Leasehold
Improvements Constructed by a QI or EAT. Almost ten years after two private
rulings approved exchanges involving leasehold improvements constructed by an
EAT on land owned by a party related to the taxpayer, and almost 8 years after the
IRS stated in Rev. Proc. 2004-51 that it intended to “study the issue,” questions
remain regarding how to structure these type of transactions. The panel will
explore technical and practical issues in these types of construction exchanges.
Moderator: David Shechtman, Drinker Biddle & Reath LLP, Philadelphia, PA
Panelist: Professor Bradley Borden, Brooklyn Law School, Brooklyn, NY
10:50am Current Developments in Section 1031 and Section 1033 Transactions. The
more expansive tax deferral opportunities potentially available under sections
1033 or 1031 by reason of federal disaster designation, illustrated by TAM
201111004, will be reviewed. Also PLR 201027036 will be discussed as will
the potential ability of US taxpayers to simultaneously achieve both US and
Canadian non-recognition on their exchange of Canadian property under sections
1031 or 1033 in the US and under the Canadian rollover provisions in Canada.
Moderator: Alan Lederman, Gunster, Ft. Lauderdale, FL
Panelists: Kelly E. Alton, NES Financial Corp, San Jose, CA; James Hutchinson,
Miller Thomson, Toronto, Ontario, Canada
8:30AM – 10:45AM
Tax Policy & Simplification 
Chair: Professor Roberta F. Mann, University of Oregon, Eugene, OR
60
Manchester D, 2nd Level
Program Schedule
Saturday,
Thursday,February
January 18
20
8:30am Perspectives on Tax Reform: Taxation of Capital Gains and Dividend Income.
Tax rates on capital gains and dividend income are at historic lows. Capital gains
and dividend income flow disproportionately to the upper reaches of the income
distribution. When searching for revenue, is it time to turn to capital gains and
dividend income? Join us as our panel discusses these timely issues.
Moderator: Professor Roberta F. Mann, University of Oregon, Eugene, OR
Panelists: Professor Len Burman, Syracuse University, Syracuse, NY; Professor
Ed Kleinbard, University of Southern California, Los Angeles, CA; Professor Sam
Thompson, Penn State University, University Park, PA
9:35am Perspectives on Tax Reform: Charitable Contributions and the Nonprofit Sector.
As Washington policymakers contemplate tax reform and look for more revenue,
the nonprofit sector is drawing increasing attention. Should we raise revenues
by curtailing the charitable contribution deduction or, perhaps, replacing it with
a credit? Should we expand the definition of unrelated business income to raise
more revenue from nonprofit businesses and passive investments? How can we
keep nonprofits from participating in tax shelters? Join us as our panel discusses
these and other tax reforms for the nonprofit sector.
Moderator: Professor Jonathan B. Forman, University of Oklahoma, Norman, OK
Panelists: Professor Roger Colinvaux, Catholic University of America,
Washington, DC; Professor Miranda P. Fleischer, University of Colorado, Boulder,
CO; Professor Brian Galle, Boston College, Newton, MA
Elizabeth D, 2nd Level
8:45AM – 11:45AM
Civil & Criminal Tax Penalties 
Chair: Larry A. Campagna, Chamberlain Hrdlicka White Williams & Aughtry, Houston, TX
8:45am Reports of Subcommittees on Important Developments.
Panelists: Michel Stein, Hochman Salkin Rettig Toscher & Perez PC, Beverly
Hills, CA; Cory Stigile, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills,
CA; Shane Lord, Sutherland Asbill & Brennan LLP, Atlanta, GA; John M. Colvin,
Chicoine & Hallett PS, Seattle, WA; David F. Axelrod, Axelrod LLC, Columbus, OH;
Niles Elber, Caplin & Drysdale Chartered, Washington, DC; Jeffrey A. Neiman,
Law Offices of Jeffrey A. Neiman, Fort Lauderdale, FL; Bruce Zagaris, Berliner
Corcoran & Rowe LLP, Washington, DC
9:15am Should You Blow Your Whistle? The stage is set for whistleblowers to become
an important element of tax enforcement. The IRS Whistleblower Office continues
to receive large numbers of tips and the day is coming when some large awards
will be paid. At the same time, the procedure for processing and reviewing claims
continues to evolve. This panel will provide an update on what is happening at the
IRS Whistleblower Office and will discuss some of the most important issues on
how claims are being handled.
Moderator: Bryan C. Skarlatos, Kostelanetz & Fink LLP, New York, NY
Panelists: Eli J. Dicker, Tax Executives Institute Inc, Washington, DC; Steven A.
Whitlock, Director, Whistleblower Office, IRS, Washington, DC; Erika A. Kelton,
Phillips & Cohen LLP, Washington, DC
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
61
Program Schedule
Thursday, February
saturday,
January 20
18
10:05am Integrity of Domestic and Offshore Accounts: The United States Perspective.
This panel will address a hypothetical set of facts that exposes both US
taxpayers and their financial institutions to risks as a result of the handling of
offshore accounts.
Moderator: Ian M. Comisky, Blank Rome LLP, Philadelphia, PA
Panelists: Robert S. Fink, Kostelanetz & Fink LLP, New York, NY; Miriam L. Fisher,
Morgan Lewis & Bockius LLP, Washington, DC; Rick Raven, Assistant Chief,
Criminal Investigation, IRS, Washington, DC; Steven R. Toscher, Hochman Salkin
Rettig Toscher & Perez PC, Beverly Hills, CA
10:55am Sentencing – How to Make the Best of a Bad Situation. This panel will
discuss issues critical to the presentence investigation, sentencing advocacy, the
continuing evolution of the sentencing guidelines, how to use the 3553(a) factors
to your client’s advantage, and what lawyers and clients really need to know about
the Bureau of Prisons but were afraid to ask.
Moderator: Niles A. Elber, Caplin & Drysdale Chartered, Washington, DC
Panelists: Honorable Judge Larry Alan Burns, US District Court for the Southern
District of California, San Diego, CA; Robert S. Huie, Assistant US Attorney, US
Attorney’s Office, Southern District of California, San Diego, CA; Jeffrey A. Neiman,
Law Offices of Jeffrey A. Neiman, Fort Lauderdale, FL; Herbert J. Hoelter, National
Center on Institutions and Alternatives, Baltimore, MD
Mohsen, 3rd Level
9:00AM – 10:30AM
State & Local Taxes Practitioner’s Roundtable

An informal discussion of current developments, recent cases and tax problems faced by the
tax practitioner. Tough questions are allowed, and answers or solutions are encouraged. The
exchange of ideas is not recorded and is intended to be an informal means for networking with
other SALT lawyers.
Moderator: Steve Young, Holland & Hart LLP, Salt Lake City, UT
9:00AM – 10:30AM
Teaching Taxation  
Chair: Adam Chodorow, Arizona State University, Tempe, AZ
Manchester C, 2nd Level
9:00am Tax and the First Amendment.  This program explores the intersection of tax
and the First Amendment. The panel will consider both the Establishment and
Free Speech Clauses as well as the possible impact of Citizens United. Panelists
will discuss such issues as the constitutionality of excluding from income a
minister’s parsonage or housing allowance, of limiting the ability of section 501(c)
(3) organizations, including churches, to engage in more than insubstantial
lobbying or participate to any extent in electioneering, and of imposing the gift
tax on contributions to section 501(c)(4) social welfare organizations engaged in
political activities and further regulating their political activities.
Panelists: Professor Ellen Aprill, Loyola Law School, Los Angeles, CA; Dean and
Professor Erwin Chemerinsky, University of California, Irvine School of Law, Irvine,
CA; Professor Donald Tobin, The Ohio State University, Moritz College of Law,
Columbus, OH
62
Program Schedule
Saturday,
Thursday,February
January 18
20
10:30AM – 12:00PM Gregory, 2nd Level
Pro Bono 
Chair: Professor Francine J. Lipman, Chapman University School of Law, Orange, CA
10:30am Pro Bono Matters: Why? Ethical and Economic Reflections on ABA Model Rule
6.1 “Voluntary Pro Bono Publico Service.” The ABA Model Rules of Professional
Conduct identify providing service for the needy as a lawyer’s obligation. Rule
6.1, Voluntary Pro Bono Publico Service, establishes that every lawyer has the
“professional responsibility to provide legal services to those unable to pay . . .
aspir[ing] to render at least (50) hours of pro bono public legal services per year”
including a “substantial majority” of pro bono work assisting “persons of limited
means” or charities that address the needs of the poor. The preamble to the Model
Rules emphasizes access to justice stating, “[a] lawyer should be mindful . . . of
the fact that the poor …cannot afford adequate legal assistance. Therefore, all
lawyers should devote professional time and resources and use civic influence
to ensure equal access to our system of justice for all those who because of
economic or social barriers cannot afford or secure adequate legal counsel.” The
moderator and a variety of panelists from private law and accounting practices,
state and federal government and the academy will reflect on the ethical and
economic reasons that pro bono matters in 2012 and beyond.
Moderator: Thomas D. Greenaway, KPMG LLP, Boston, MA
Panelists: Deborah A. Butler, Associate Chief Counsel, Procedure & Administration,
Washington, DC; Dean Stephen C. Ferruolo, University of San Diego School of
Law, San Diego, CA; Armando Gomez, Skadden Arps Slate Meagher & Flom LLP,
Washington, DC; Marcy Jo Mandel, Deputy Controller, Taxation, Office of the
California Controller, Los Angeles, CA
Mohsen, 3rd Level
10:30AM – 11:30AM
The State and Local Tax Lawyer Publications Subcommittee

An informal meeting of editors, authors and interested persons to discuss publication of The
State and Local Tax Lawyer by the Tax Section.
Moderator: Jeff Glickman, Alston & Bird LLP, Atlanta, GA
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
63
Program Schedule
Thursday, February
saturday,
January 20
18
12:00PM – 1:30PM
Section Luncheon & Plenary Session
Elizabeth ABC, 2nd Level
 (Ticketed Event)
William M. Paul, Section Chair, Presiding
Chair’s Report to the Section
William M. Paul, Section Chair
Report of Nominating Committee
Charles H. Egerton, Chair, Nominating Committee
Acknowledgement of John S. Nolan Tax Law Fellows
2011 – 2012 Fellows
2012 – 2013 Fellows
Acknowledgement of Public Service Fellows
2010 – 2011 Fellows
2011 – 2012 Fellows
Janet Spragens 2012 Pro Bono Award Presentation
Recipient: Frank Agostino, Frank Agostino & Associates, Hackensack, NJ
Speaker
Hon. David M. Walker
Founder and CEO of the Comeback America Initiative
and Former Comptroller General of the U.S.
Topic: Restoring Fiscal Sanity
America is at a critical crossroads and the choices that our elected officials
make in connection with the role of government and its finances over the
next 5 years will largely determine whether our collective future will be
better than our past. Dave Walker will outline the facts and offer a range of
sensible solutions to help ensure that America stays great and the American
Dream stays alive for our families and future generations of Americans. This
will include budget, social insurance, tax, and other reforms.
SECTION PROGRAM
2:00PM – 5:00PM
Mohsen, 3rd Level
Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation  
This session will review the most significant statutory enactments, judicial decisions, IRS
rulings, and Department of Treasury regulations promulgated during the last twelve months
that affect general income taxation, corporate taxation, partnership taxation, wealth transfer
taxation, and tax procedure.
Moderator: Professor Martin J. McMahon Jr., University of Florida College of Law,
Gainesville, FL
Panelists: Professor Ira B. Shepard, University of Houston Law Center, Houston, TX
Professor Daniel L. Simmons, University of California at Davis School of Law,
Davis, CA
Professor Elaine Hightower Gagliardi, University of Montana School of Law,
Missoula, MT
Sponsored by: Teaching Taxation
64
Program Schedule
Saturday,
Thursday,February
January 18
20
SECTION PROGRAM
Del Mar, 3rd Level
2:00PM – 4:00PM Drafting Real Estate Partnership and LLC Agreements – Part 2 
This panel is a continuation of the panel from May 2011 and will explore the general tax
considerations and common mistakes in drafting partnership or LLC agreements for real
estate partnerships. Your most burning questions will be answered, such as: Do I need that
incoherent tax boilerplate and why? Should I liquidate in accordance with capital accounts?
What is a tax distribution and when do I need one?
Moderator: Brian O’Connor, Venable LLP, Baltimore, MD
Panelists: Terence Cuff, Loeb & Loeb LLP, Los Angeles, CA
Steven R. Schneider, Goulston & Storrs PC, Washington, DC
Robb Longman, McMillan Metro PC, Rockville, MD
Co-sponsored by: Real Estate and Partnerships & LLCs
SECTION PROGRAM
2:00PM – 4:00PM
Ford AB, 3rd Level
The Far-Reaching Impact of FATCA Across Borders and Across Industries 
Enacted as part of the HIRE Act in 2010, FATCA creates an entirely new reporting and
withholding regime for a broad category of US payments. Given the breadth and scope
of FATCA, including its global reach, the task of providing guidance to implement the law
has proven to be a significant undertaking for government policymakers. Since 2010, the
government issued several notices and requests for comments. More guidance is expected
soon. For their part, affected parties, industry groups, tax practitioners, and others have
responded with comments and suggestions for how the rules should be crafted. This program
will explore the latest government pronouncements on FATCA and provide insights from a
variety of industry perspectives, including banking, insurance, and funds. While each industry
and affected party has specific concerns, there are many aspects of FATCA that cut across
borders and industries. This program should have something for everyone as panelists will
discuss issues common to affected parties, as well as those that are more specific.
Moderator: Rochelle Hodes, PricewaterhouseCoopers LLP, Washington, DC
Panelists: Joan Arnold, Pepper Hamilton LLP, Philadelphia, PA
Michael Hirschfeld, Dechert LLP, New York, NY
Yoram Keinan, Greenberg Traurig LLP, New York, NY
Rebecca Lee, PricewaterhouseCoopers LLP, San Francisco, CA
Susan Seabrook, Skadden Arps Slate Meagher & Flom LLP, Washington, DC
John Sweeney, Senior Technical Reviewer, Branch 2, Office of Associate Chief
Counsel, IRS, Washington, DC
Danielle Nishida, Attorney-Advisor, Branch 2, Office of Associate Chief Counsel,
IRS, Washington, DC
Co-sponsored by: US Activities of Foreigners & Tax Treaties, Banking & Savings Institutions,
Insurance Companies and Tax Shelters
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
65
Program Schedule
Thursday, February
saturday,
January 20
18
SECTION PROGRAM
Edward ABC, 2nd Level
2:00PM – 5:00PM
Repair Regs Re-Do: Review of the New Guidance Regarding Tangible Property 
On December 23, 2011, the Department of Treasury and IRS issued a broad and
comprehensive regulatory package addressing the deductibility and capitalization of amounts
paid for repair, maintenance, and improvement of tangible property. These temporary and
proposed regulations reflect eight years of proposed, withdrawn, and re-proposed regulations
addressing costs associated with tangible property and unique issues related to repair,
maintenance, and improvements to such property interests. The program will include insight
and observations from government guests as well as case study review of a range of issues
presented by this new guidance from practitioners. The program promises to provide a
thorough evaluation of this significant guidance.
Panelists: Andrew J. Keyso, Acting Associate Chief Counsel, Income Tax & Accounting,
IRS, Washington, DC
Scott Dinwiddie, Special Counsel, Income Tax & Accounting, IRS,
Washington, DC
Kathy Reed, Branch Chief, Branch 7, Income Tax & Accounting, IRS,
Washington, DC
Alan S. Williams, Attorney, Branch 3, Income Tax & Accounting, IRS,
Washington, DC
Patrick Clinton, Attorney, Branch 7, Income Tax & Accounting, IRS,
Washington, DC
Ellen McElroy, Pepper Hamilton LLP, Washington, DC
Susan Grais, Ernst & Young LLP, Washington, DC
Natalie Tucker, McGladrey & Pullen LLP, Jacksonville, FL
Jody Brewster, Skadden Arps Slate Meagher & Flom LLP, Washington, DC
Carol Conjura, KPMG LLP, Washington, DC
Stephen F. Gertzman, Miller & Chevalier, Washington, DC
David AuClair, Grant Thornton LLP, Washington, DC
James Liechty, PricewaterhouseCoopers LLP, Washington, DC
Scott MacKay, Deloitte Tax LLP, Washington, DC
Co-sponsored by: Tax Accounting and Capital Recovery & Leasing
5:00PM – 5:30PM
ACTC Annual Business Meeting
5:30PM – 6:30PM
ACTC 2012 Griswold Lecture
7:00PM – 10:00PM
ACTC Reception and Dinner
66
Madeleine, 3rd Level
(ACTC Members Only)
Madeleine, 3rd Level
(Open Session)
Sally’s Seafood on the Water, 1 Market Place
(ACTC Members and Guests)
Program Schedule
Thursday,
Sunday, February
January 19
20
7:30AM – 9:00AM
Del Mar, 3rd Level
(ACTC Members Only)
ACTC Fellows Breakfast & Roundtable Discussion
Speaker: Nina Olson, National Taxpayer Advocate, IRS, Washington, DC
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
 = No CLE Credit
67
Affiliated Organizations
American College of Tax Counsel
FRIDAY, FEBRUARY 17
7:30AM – 9:30AM
ACTC Board of Regents Meeting (Executive Session)
Emma C, 3rd Level
SATURDAY, FEBRUARY 18
5:00PM – 5:30PM
ACTC Annual Business Meeting (ACTC Members Only)
Madeleine, 3rd Level
5:30PM – 6:30PM
ACTC 2012 Griswold Lecture (Open Session)
Madeleine, 3rd Level
7:00PM – 10:00PM
Sally’s Seafood on the Water, 1 Market Place
ACTC Reception and Dinner (ACTC Members and Guests)
SUNDAY, FEBRUARY 19
7:30AM – 9:00AM
ACTC Fellows Breakfast and Roundtable Discussion (ACTC Members Only)
Speaker: Nina Olson, National Taxpayer Advocate, IRS, Washington, DC
68
Del Mar, 3rd Level
General Information
AUDIO CDS and MP3 Instant Downloads
Audio CDs and MP3s of Committee Meetings and Section Programs are available for purchase
on site.
To place an order, visit the Digital Conference Providers (DCP) booth located in Elizabeth Foyer,
2nd Level. After the meeting visit: www.dcporder.com/abatx/ for mail order audio CDs or
www.dcprovidersonline.com/abatx/ for instant downloads.
20% MEETING DISCOUNT ON SECTION PUBLICATIONS
Stop by the Publications Display, located in Elizabeth Foyer, 2nd Level to preview the most
popular titles from the Section of Taxation and receive a 20% discount on all publication orders.
Use the source code: TX11AMIDPUB in the webstore. You can also drop off your completed
order form on-site at the Meeting Registration Desk, or fax it to the Section Office at
202-662-8682 to take advantage of this special discount. Please note that the offer expires
Friday, February 24th, 2012.
REFUND POLICY
The deadline for refunds was Feb. 9, 2012. All refund requests incur a $50 cancellation fee.
Refunds will not be granted at or after the meeting.
ABA OPEN MEETINGS POLICY
In accordance with the ABA Open Meetings Policy, all ABA programs are open to the media
unless they are to conduct business sessions of a confidential nature. The Association
encourages media coverage of its activities. If you have questions about this policy, please
contact the Sections’ main office at 202-662-8670.
Please note: By attending the conference, attendees have agreed to the terms of the American
Bar Association Image/Audio/Video Release Form, which allows images, audio and video
recorded on site to be used for educational and promotional purposes.
70
Activities
Friday, February 17th
10:00AM – 2:00PM
Acrylics and Aperture: Private Tours of the Timken Museum, the Museum of Photographic Arts
and Luncheon at Bertrand at Mister A’s
(Ticketed Event $80)
The Timken Museum of Art, located in San Diego’s Balboa Park, is the permanent home of the
highly acclaimed Putnam Foundation’s world-class collection of European and American art and
Russian icons. Begin your day exploring the collection that spans 700 years of history. The private,
docent-led tour will highlight 14th century altarpieces, 18th century portraits and landscapes and
19th century still lifes. The works of Italian, Dutch, Flemish, French and American painters are
represented, including those of Veronese, Il Guercino, Petrus Christus, Rembrandt, Jacques-Louis
David and John Singleton Copley.
After touring the intimate yet highly-acclaimed Timken Museum, you will cross the street and
change mediums at the Museum of Photographic Arts. Home to one of the largest collections of
photography in the world, MOPA presents both photographic art and the history of photography
throughout its custom-designed museum space. A private, docent-led tour will take you through
the esteemed collection and give you a glimpse into the life of the museum’s curator. View images
not on public display, learn about upcoming exhibits and their installations and discover the
intricate details included in the job description of a curator tasked with overseeing 7,000 images.
At the conclusion of your morning in Balboa Park, head to Bertrand at Mister A’s for lunch. Enjoy
modern American cuisine while looking out across the San Diego skyline, with views of San Diego
Bay, Coronado and Point Loma.
The shuttle bus will depart promptly from the Manchester Grand Hyatt at 9:30am. After lunch, the
bus will return guests to the Hyatt.
71
Index
 = Taped  = Young Lawyers Program
 = Ethics Credits Requested
A
 = No CLE Credit
C
ACTC
Capital Recovery & Leasing
(Open Session) 68
2012 Griswold Lecture
Committee Meeting  24
Annual Business Meeting
(ACTC Members Only) 68
Section Program: Repair Regs Re-Do:
Review of the New Guidance Regarding
Tangible Property  66
Board of Regents Meeting
(Executive Session) 68
Fellows Breakfast and Roundtable Discussion
(ACTC Members Only) 68
Civil & Criminal Tax Penalties
Committee Meeting  61
Luncheon
Reception and Dinner
(ACTC
Members and Guests) 68
Closely Held Businesses
Administrative Practice
Committee Meeting AM  28
Committee Meeting   25
Committee Meeting PM  43
Luncheon with Court Procedure &
Practice
(Ticketed) 38
Affiliated & Related Corporations
Committee Meeting  26
Luncheon with Corporate Tax
Committee Chairs, Vice-Chairs, Officers
23
and Council Breakfast
Committees
Committee NOT MEETING
(Ticketed) 38
Appointments to the Tax Court
Committee Meeting
(Ticketed) 38
Companions Activities
Acrylics and Aperture: Private Tours
of the Timken Museum, the Museum
of Photographic Arts and Luncheon at
Bertrand at Mister A’s
(Ticketed) 71
(Executive Session) 37
B
Breakfast
Banking & Savings Institutions
Committee Meeting  27
Corporate Tax
Committee Meeting  56
Luncheon with Financial Transactions, Insurance
Companies, Investment Management and
Tax Exempt Financing
(Ticketed) 38
Section Program: The Far-Reaching
Impact of FATCA Across Borders
and Across Industries.  65
(Complimentary) 24
Luncheon with Affiliated & Related
Corporations
(Ticketed) 38
Court Procedure & Practice
Committee Meeting  46
Luncheon with Administrative
Practice
(Ticketed) 38
Bankruptcy & Workouts
Committee Meeting   45
Officers and Subcommittee Chairs
Breakfast
(Ticketed) 56
Business Cooperatives & Agriculture
Roundtable Discussion  40
Committee NOT MEETING
D
Distinguished Service Award
Committee Meeting
72
(Executive Session) 36
Index
Diversity
Estate & Gift Taxes
Committee Meeting  52
Committee Meeting  29
Joint Session with Tax Practice Management
and Young Lawyers Forum 
 56
Estate & Gift Taxes and Fiduciary Income Tax
Young Lawyers Subcommittee
41
Networking Reception with Young
Lawyers Forum
 54
Luncheon with Fiduciary Income
Tax
(Ticketed) 38
E
Exempt Organizations
Cash bar
Employee Benefits
45
Committee Meeting AM  33
Friday Committee Meeting  43
Committee Meeting PM  44
Networking Reception
Luncheon
44
Saturday Committee Meeting  57
(Ticketed) 38
Exempt Organizations Subcommittees
Employee Benefits Subcommittees
Audits, Appeals and Litigation
23
Administrative Practices 24
Health-Care Organizations
Cafeteria Plans & Reimbursement Accounts 34
Political and Lobbying Organizations
Controlled Groups and Employee Status 39
Private Foundations, Unrelated Business
Income, and International Philanthropy
Defined Benefit Plans 39
Religious Organizations
Defined Contribution Plans 36
Distributions 35
Committee Meeting   58
37
Estate & Gift Taxes and Fiduciary Income Tax
Young Lawyers Subcommittee
 41
Executive Compensation, Fringe Benefits
and Federal Securities Law Issues 25
Luncheon with Estate & Gift
Taxes
(Ticketed) 38
Exempt Organization and
Governmental Plans
39
37
Luncheon with Banking & Savings Institutions,
Insurance Companies, Investment Management
and Tax Exempt Financing
(Ticketed) 38
International 35
Legislation
34
First-Time Attendees
37
Mergers & Acquisitions 25
New Employee Benefits Attorneys Forum
Welfare Plan Design & Funding 34
Employment Taxes
Financial Transactions
Committee Meeting  47
HIPAA, COBRA and State Insurance
Regulation of Welfare Plans 34
Litigation
23
Orientation Dinner

(Reservations Required) 22
Foreign Activities of US Taxpayers
Business Meeting
54
Committee Meeting  41
Committee Meeting  53
Joint Panel with Individual &
Family Taxation   29
Dinner with FLF, Transfer Pricing and
USAFTT
 (Reservations Required) 55
Energy & Environmental Taxes
Committee Meeting   47
23
24
Fiduciary Income Tax
Employee Benefits Legislation 34
Fiduciary Responsibility/Plan Investments
23
F
EEOC Issues/FMLA, Military and
Other Leaves
25
ESOPs
23
Joint Session with FLF, Transfer
Pricing and USAFTT 36
Luncheon with FLF, Transfer Pricing
and USAFTT
(Ticketed) 38
73
Index
Foreign Lawyers Forum
Business Meeting
55
Committee Meeting  41
L
Low Income Taxpayers
Committee Meeting  59
Dinner with FAUST, Transfer Pricing and
USAFTT
 (Reservations Required) 55
Joint Session with FAUST, Transfer
Pricing and USAFTT  36
Luncheon with FAUST, Transfer Pricing
and USAFTT
(Ticketed) 38
Publications Book Release Reception
M
Membership & Marketing
Committee Meeting
G
Government Relations
Committee NOT MEETING
H
News Quarterly
Committee NOT MEETING
Nominating
Committee Meeting
Hospitality
(Complimentary) 23, 56
I
37
N
Government Submissions
Committee NOT MEETING
(Executive Session) 37
O
Officers & Council Meeting
(Executive Session) 22
Indian Tribal Tax
Committee Meeting  40
Individual & Family Taxation
Committee Meeting  29
Insurance Companies
Committee Meeting  52
Luncheon with Banking & Savings Institutions,
Financial Transactions, Investment Management
and Tax Exempt Financing
(Ticketed) 38
Section Program: The Far-Reaching
Impact of FATCA Across Borders
and Across Industries  65
Investment Management
Committee Meeting  30
Luncheon with Banking & Savings Institutions,
Financial Transactions, Insurance Companies
and Tax Exempt Financing
(Ticketed) 38
P
Partnerships & LLCs
Breakfast with Real Estate and S
Corporations
(Ticketed) 56
Committee Meeting  31
Dinner with Real Estate
(Reservations Required) 22
LLCs and LLPs Subcommittee
Luncheon with Real Estate
58
(Ticketed) 38
Section Program: Drafting Real Estate Partnership
and LLC Agreements – Part 2  65
Pro Bono
Committee Meeting  63
Joint Panel with Standards of
Tax Practice   42
Publications Book Release Reception
Professional Services
Committee Meeting
74
54
54
54
Index
Programs & Meetings
State & Local Taxes
Committee Meeting
54
Committee Meeting  49
Current Developments in California
FTB Settlement Procedures 40
Publications
Book Release Reception
54
Executive Business Meeting
(Executive Session) 22
Committee NOT MEETING
Luncheon
Public Service Fellowship
Committee Meeting
(Executive Session) 48
R
(Ticketed) 38
Practitioner’s Roundtable
Publications Subcommittee
 62
 63
T
Real Estate
Breakfast with Partnerships & LLCs and
S Corporations
(Ticketed) 56
Committee Meeting  48
Dinner with Partnerships & LLCs
(Reservations Required) 22
Luncheon with Partnerships &
LLCs
(Ticketed) 38
Section Program: Drafting Real Estate Partnership
and LLC Agreements – Part 2  65
Task Force on Patenting Tax Strategy
Committee NOT MEETING
Tax Accounting
Committee Meeting  50
Section Program: Repair Regs Re-Do:
Review of the New Guidance Regarding
Tangible Property  66
Tax Exempt Financing
Committee Meeting  51
Resolutions
Committee NOT MEETING
S
Luncheon with Banking & Savings Institutions,
Financial Transactions, Insurance Companies
and Investment Management
(Ticketed) 38
The Tax Lawyer
S Corporations
Committee NOT MEETING
Breakfast with Partnerships & LLCs and
Real Estate
(Ticketed Event) 56
Tax Policy & Simplification
Committee Meeting  32
Committee Meeting  60
Sales, Exchanges & Basis
Tax Practice Management
Committee Meeting   59
Section Luncheon/Plenary Session
 (Ticketed) 64
Section Reception
 (Ticketed) 55
Sponsorships
Committee Meeting
53
Standards of Tax Practice
Committee Meeting   42
Joint Session with Diversity and Young
Lawyers Forum
 56
Tax Shelters
Committee Meeting
37
Section Program: The Far-Reaching
Impact of FATCA Across Borders
and Across Industries  65
Teaching Taxation
Committee Meeting   62
Section Program: Current Developments
in Individual, Corporate, Partnership
and Estate & Gift Taxation   64
75
Index
W
Transfer Pricing
Committee Meeting  32
Dinner with FAUST, FLF and USAFTT
(Reservations Required) 55

Joint Session with FAUST, FLF and USAFTT  36
Luncheon with FAUST, FLF and
USAFTT
(Ticketed) 38
U

Y
Young Lawyers Forum
11th Annual Law Student Tax Challenge SemiFinal Rounds (Open to the Public)
 34
US Activities of Foreigners and Tax Treaties
Business Meeting
55
Committee Meeting   33
Dinner with FAUST, FLF and Transfer
Pricing
 (Reservations Required) 55
Joint Session with FAUST, FLF
and Transfer Pricing  36
Luncheon with FAUST, FLF and
Transfer Pricing
(Ticketed) 38
Section Program: The Far-Reaching
Impact of FATCA Across Borders
and Across Industries  65
76
Welcome Reception
(Complimentary) 22
11th Annual Law Student Tax Challenge Final
Rounds (Open to the Public)
 45
Committee Meeting   54
First-Time Attendees Orientation Dinner
 (Reservations Required) 22
Joint Session with Diversity and Tax
Practice Management
 56
Networking Reception with Diversity
 54
Notes
Index
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Index
NOTES
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78
NOTES
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S e c t i o n o f Ta x at i o n
..................................................................
2012 May Meeting
..................................................................
May 10-12, 2012
..................................................................
..................................................................
..................................................................
Thank you for joining us at the Midyear Meeting. We look forward to seeing
you at the May Meeting in Washington, DC.
..................................................................
< Please fold back page to the left fo find the hotel floorplan.
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79
floor plans
Manchester Grand Hyatt
FOYER
THIRD LEVEL
C
POOL TERRACE
SPA POOL
B
FOYER
WHIRL POOL
ESCALATORS
A
EMMA
B
A
ESCALATORS
ANNIE MAGGIE
RE
ELEVATORS
OXFORD
KIN SPA
ST
RO
O
M
S
FREIGHT
ELEVATORS
GEORGE BUSH
FORD
A
RESTROOMS
CONNAUGHT
B
C
MOHSEN
B
DEL
MAR
MADELEINE
A
A
B
C
A
D
B
PSAV OFFICE
RESTROOMS
SHOW MANAGER
OFFICE 3
MANCHESTER
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B
ELIZABETH BALLROOM
A
C
ESCALATORS
C
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MANCHESTER
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RESTROOMS
RESTROOMS
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LITRENTA
FOYER
PALM
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MANCHESTER
FOYER
G
ELIZABETH TERRACE
SHOW MANAGER
OFFICE 5
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SHOW MANAGER
OFFICE 1
SHOW MANAGER
OFFICE 2
BETSY
ELEVATORS
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SHOW MANAGER
OFFICE 4
C
FREIGHT
ELEVATORS
MOLLY
B
B
GREGORY
EDWARD
A
A
C
A
B
D
PAVILION LOAD-IN
GROUND LEVEL
RESTROOMS
RESTROOMS
SALLY’S SEAFOOD ON THE WATER
LOADING
DOCK
LAEL’S RESTAURANT
ANN-MARIES COFFEE HOUSE
D
GALLERY
RETAIL
PROMENADE
C
B
FREIGHT
ELEVATORS
A
DOUGLAS PAVILION
ESCALATORS
TOP OF THE HYATT
(ELEVATOR TO THE 40TH FLOOR)
DOUGLAS FOYER
RESTROOMS
CONCIERGE
DESK
GRAND
LOBBY BAR
CONVENTION
CENTER
CAR RENTAL
DESK
DOWNTOWN AND
GASLAMP DISTRICT
ELEVATORS
ENTRANCE
FRONT DESK
BUSINESS CENTER
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