Tax Section Summer Meeting 2023

The Tax Section invites you to join them this Summer from July 14-16, 2023 at the The Ritz Carlton in Philadelphia, PA!

In a city as rich in history as Philadelphia, there is a lot to discover. The Philadelphia Art Museum, where Rocky Balboa ran the steps in triumph. Lincoln Financial Field, the stadium where the NFL's 2018 Super Bowl Champion Eagles play. And Fillmore Philadelphia, a 25,000-sq.-ft. answer to San Francisco’s legendary music venue of the same name. Located near these sights and others like Market Street, The Ritz Carlton offers the perfect starting point for a day of exploration.

The Ritz-Carlton room block for this event has been closed.  If you still need to make a reservation, please reach out directly to Kate Tortora at [email protected] 

Conference Registration Rates: 

Tax Section Member (Early Bird end 6/21): $650

NYSBA Member/Non-Tax Section Member (Early Bird Ends 6/21): $740

Non NYSBA Member: $850

Young Attorney (10 years or less): $300

Guests: $275

What's Included with Registration:

Registration costs include breakfasts, coffee breaks, lunch, 5.0 CLE credits of programming, Friday Welcome Reception and Dinner, Saturday offsite Cocktail Reception and Dinner at Estia, as well as 2 offsite outings on Saturday morning and Saturday afternoon, these outings are currently TBD and will require pre-registration for headcounts, but are of no additional cost.

Agenda

Friday, July 14

4:00 p.m. – 6:00 p.m.      Registration

6:00 p.m. – 7:00 p.m.      Cocktails

7:00 p.m. – 10:00 p.m.    Dinner

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Saturday, July 15

8:00 a.m. – 3:15 p.m.     Registration

8:00 a.m. – 9:30 a.m.     Breakfast

9:00 a.m. – 10:00 a.m.   Optional Morning Tour of Reading Terminal Market 

On this tour, you will explore the Market's rich history, witness the skilled cooking styles passed down from generations, and take in the diverse and mouth-watering scents from the 80+ merchants’ food.

Starting off with a famous Philly snack from one of the merchants, this 45-minute tour is sure to tantalize your taste buds and provide insight into the Market's vibrant history. City Food Tours' expert guides will lead you through the Market's bustling aisles, pointing out must-see spots and sharing stories of the Market's past.

10:15 a.m. – 11:00 a.m. Bringing Out the Best in Nonprofits (Optional Session)

An informal conversation with Professor David Schizer, Dean Emeritus of Columbia Law School, about insights he derived while writing his new book, How to Save the World in Six (Not So Easy) Steps: Bringing Out the Best in Nonprofits. David will talk about practical, thoughtful steps that anyone active in a not-for-profit organization can pursue, in order to address common organizational and motivational challenges that such organizations face.

11:00 a.m. – 11:10 a.m.    Welcoming Remarks

New York State Bar Association Welcome

Richard C. Lewis, Esq., President

Hinman Howard & Kattell, LLP

Binghamton, NY

Tax Section Welcome

Philip Wagman, Esq., Section Chair

Clifford Chance US LLP

New York, NY

11:10 a.m. – 12:00 p.m.    Interactions Between Pillar Two and the U.S. Foreign Tax Credit and GILTI Rules

This panel will explore selected aspects of the interaction between the current U.S. international tax rules and Pillar Two. The panel will discuss the availability, under current law, of a foreign tax credit for a tax imposed under an Income Inclusion Rule, Undertaxed Profits Rule, or Qualified Domestic Minimum Tax adopted by another country. It also will consider whether and how tax imposed under GILTI and Subpart F will be "pushed down" to a controlled foreign corporation, for purposes of computing the Pillar Two top-up tax owed by that corporation.

Moderator

Adam Kool, Esq.

Kirkland & Ellis LLP

New York, NY

Panelists

Richard Reinhold, Esq.  (invited)

Special Counsel (International)

Internal Revenue Service

Washington DC

Danielle Rolfes, Esq.

KPMG LLP

Washington, DC

Ansgar Simon, Esq. 

Covington & Burling LLP 

New York, NY

1.0 Credit in Areas of Professional Practice

12:10 p.m. – 1:00 p.m.    Trends and Developments in New York State and City Tax

This panel will discuss key New York State and City tax developments, including new legislation, administrative and audit policy developments. Specific topics will include the New York State Department of Taxation and Finance’s new right to appeal certain adverse Tax Appeals Tribunal decisions, application of the Metropolitan Commuter Transportation Mobility Tax to owners of an LLC or limited partnership; and a discussion of the State’s and City’s audit positions regarding apportionment, the Unincorporated Business Tax, Qualified Emerging Technology Companies, Qualified New York Manufacturers, and like-kind exchanges.

Moderator

Alysse B. McLoughlin, Esq.

Jones Walker LLP 

New York, NY

Panelists

Paul R. Comeau, Esq.

Hodgson Russ LLP

New York, NY

Elizabeth Pascal, Esq.

Hodgson Russ LLP 

New York, NY

Marc Simonetti, Esq.

State Tax Law LLC

New York, NY

1.0 Credit in Areas of Professional Practice

1:00 p.m. – 2:00 p.m.    Lunch

1:00 p.m. – 2:00 p.m.    Lunch and Discussion with Mark Schneider, Esq., Associate Chief Counsel (Corporate) of the Internal Revenue Service (invited)

During lunch, Mark Schneider, the recently appointed Associate Chief Counsel (Corporate) of the Internal Revenue Service, will provide an overview of his goals in this position, including potential areas for future guidance. He may (time permitting) address questions and comments from members of the audience.

2:00 p.m. – 3:15 p.m.    Tax Bar of Tomorrow

This panel will consider how several converging trends impact the practice of tax law, the potential future shape and direction of the tax bar, and the mission and priorities of the NYSBA Tax Section. As U.S. tax law becomes more complex (including increasingly drawing on rules from other disciplines and other countries), tax lawyers are incentivized to become more specialized, and may find it increasingly hard (and have weaker incentives) to see the broader landscape of the tax. At the same time, at the federal level, obstacles to passage of tax legislation present potential challenges to efforts to improve the law, further add to complexity, and pose challenges to the NYSBA and others who seek to offer guidance on tax reform. In addition, the pool of law school graduates is becoming more diverse, so there are new opportunities (and challenges) in enhancing the diversity of the tax bar. This panel explores how the tax bar can respond to these issues, while at the same time maintaining a commitment to public service and building on contributions from tax practitioners from different backgrounds.

Moderator:

David Schizer, Esq.

Dean Emeritus & Harvey R. Miller Professor of Law

Columbia Law School

New York, NY

Panelists

Erika Nijenhuis, Esq.  (invited)

Senior Counsel, Office of Tax Policy 

U.S. Department of the Treasury 

Washington, DC

Lilian V. Faulhaber

Ralph H. Dwan Chair in Taxation

Associate Dean for Research and Academic Programs

Georgetown University Law Center

Arvind Ravichandran, Esq.

Cravath Swaine & Moore LLP

New York, NY

1.5 Credit in Areas of Professional Practice

3:30 p.m. – 5:30 p.m.    Optional Guided Tour of the Barnes Foundation

A docent-led tour is the ultimate way to experience the Barnes and understand the principles that founder Albert Barnes called the “universal language of art.” Enjoy a 60-minute tour with a specially trained docents (one docent provided per six people; subject to change with capacity restrictions). Includes self-guided access for the remainder of your visit.

Shuttle service to and from the Museum will be provided

6:00 p.m. – 7:00 p.m.    Cocktail Reception (Estia Restaurant, 1405-1407 Locust Street)

7:00 p.m. – 10:00 p.m.   Dinner (Estia Restaurant, 1405 – 1407 Locust Street)

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Sunday, July 16

8:00 a.m.    Registration

8:00 a.m. – 9:00 a.m.     Executive Committee Meeting

8:00 a.m. – 10:00 a.m.   Breakfast

9:15 a.m. – 10:30 a.m.   CAMT: International Tax Issues

This panel will explore selected international tax issues raised by the new corporate alternative minimum tax (CAMT) imposed on adjusted financial statement income.  The panel will discuss how the CAMT addresses foreign corporations’ financial statement income and their distributions to their domestic parents.  The panel will also explore foreign tax credit issues and how mergers and acquisition transactions are affected by the CAMT.  

Moderator

Libin Zhang, Esq. 

Fried, Frank, Harris, Shriver & Jacobson LLP

New York, NY

Panelists

Paul McLaughlin, Esq. (invited)

Special Counsel (International) 

Internal Revenue Service 

Washington, DC

Tijana J. Dvornic, Esq.

Wachtell, Lipton, Rosen & Katz 

New York, NY

Wade Sutton, Esq.

PwC US

Washington, DC

1.5 Credit in Areas of Professional Practice

10:30 a.m.    Adjourn    

Cancellation Notice:

Cancellations received by Tuesday, July 4, 2023 – 100% refund

Cancellations received between Wednesday, July 5, 2023- Thursday, July 13, 2023 -50% refund

Cancellations received from Friday July 14, 2023 onwards – NO refund