Representatives from the government and private practitioners will gather for high-level discussions on the most important issues facing tax and trust and estate lawyers today, including the latest federal tax policies, initiatives, regulations, legislative forecasts and planning ideas.
Program highlights:
-Joint Plenary Session and Section Luncheon, featuring keynote speaker Barbara M. Angus, chief tax counsel of the House Committee on Ways and Means - Angus previously served as the international tax counsel for the Office of Tax Policy at the Department of the Treasury. In that position, she was the federal government's principal legal adviser on all aspects of international tax policy.
-"Potential State Tax Implications of Proposed IRC 385 Debt/Equity Regulations" - In April, the Department of Treasury proposed comprehensive regulations under section 385 of the Internal Revenue Code. Although Treasury indicated that the regulations were issued in the context of addressing corporate inversions, if adopted in their present form, the regulations would apply well beyond corporate inversions to a broad range of related-party transactions. The proposed regulations would authorize the IRS to treat certain related-party interests that would otherwise be treated as indebtedness as stock for federal tax purposes (or as part stock and part debt) and establish extensive documentation requirements for intra-group indebtedness. This panel will provide an overview of the proposed regulations and discusses potential state and local tax implications.
-"They're Finally Here! Unpacking the Proposed Regulations under Section 2704(b)" - Panelists David Handler of Kirkland & Ellis in Chicago; Christine R.W. Quigley of Schiff Hardin LLP in Chicago; and William Sanderson of McGuire Woods in Washington, D.C. will explore and analyze key elements of Section 2704(b) regulations, which were released on Aug. 2, 2016.
Published: Mon, Sep 26, 2016
