Tax Section

8:45 a.m. – 9:00 a.m.

Business Meeting and Election of Officers

Trianon Ballroom, Third Floor

9:15 a.m. – 10:30 a.m.

The Corporate AMT: Open Questions | Trianon Ballroom, Third Floor

This panel will discuss, among other things, some of the areas where significant guidance is needed in the near term so that corporations can determine whether they are subject to the new tax regime and the consequences of engaging in various activities, with particular focus on M&A transactions.

Speaker

Ashby T. Corum | KPMG LLP Washington, DC

Kevin M. Jacobs, Esq. | Alvarez & Marsal Taxand, LLC Washington, DC

Monisha Santamaria, Esq. | KPMG LLP Washington, DC

Brett York, Esq. | Deputy Tax Legislative Counsel Department of the Treasury Washington, DC

Moderator

Kara L. Mungovan, Esq. | Davis Polk & Wardwell LLP New York, NY

9:15 a.m. – 10:30 a.m.

Energy, Climate, National Security, and the Brave New World of [Saleable] Tax Credits | Rendevous Ballroom, Third Floor

The Inflation Reduction Act includes an unprecedented level of funding for clean energy initiatives, including through the tax code. Join us for a discussion of these various credits--what they support and why--as well as a close look at how to transfer and monetize them and, more generally, how they will affect your practice.

Speaker

Drew Batkin, Esq. | Milbank, Tweed, Hadley & McCloy LLP New York, NY

Peter Connors, Esq. | Orrick, Herrington & Sutcliffe LLP New York, NY

Sarah Ritchey Haradon, Esq. (Presenting via Zoom) | Attorney Advisor, Office of Tax Policy, Department of the Treasury, Washington, D.C.

Eli M. Katz, Esq. | Latham & Watkins LLP New York, NY

Julie M. Marion, Esq. | KPMG LLP Chicago, IL

Moderator

David M. Schizer, Esq. | Dean Emeritus & Harvey R. Miller Professor of Law Columbia Law School New York, NY

10:30 a.m. – 10:45 a.m.

Break

10:45 a.m. – 12:00 p.m.

Section 4501 Stock Buyback Excise Tax | Trianon Ballroom, Third Floor

This panel will discuss the potential scope of the stock excise buyback tax and explore ways in which it might be implemented.

Speaker

Colin Campbell, Jr., Esq. | Attorney Advisor Office of Tax Policy Department of the Treasury Washington, DC

Daniel Hemel, Esq. | Professor of Law, New York University School of Law New York, NY

Vadim Mahmoudov, Esq. | Willkie Farr & Gallagher LLP New York, NY

Sophie A. Staples, Esq. | Simpson Thacher & Bartlett LLP New York, NY

Moderator

David M. Rievman, Esq. | Skadden, Arps, Slate, Meagher & Flom LLP New York, NY

10:45 a.m. – 12:00 p.m.

New York State Tax Developments | Rendevous Ballroom, Third Floor

This panel will discuss recent developments in New York State taxation.

Speaker

Joseph Carzo | Director, Audit Division, New York State Department of Taxation and Finance, Albany, NY

Elizabeth Pascal, Esq. | Hodgson Russ LLP Buffalo, NY

Jennifer S. White, Esq. | Reed Smith LLP New York, NY

Moderator

Jack Trachtenberg, Esq. | Deloitte Tax LLP New York, NY

12:30 p.m. – 2:00 p.m.

Luncheon | Grand Ballroom, Third Floor

Additional fee applies

Speaker

Rebecca Kysar, Esq. | Professor of Law, Fordham University School of Law New York, NY

2:15 p.m. – 4:00 p.m.

Order Out of Chaos: Planning in an Increasingly Complex International System | Grand Ballroom, Third Floor

The international tax system is becoming more complex by the day. With the introduction of novel extraterritorial taxes and the ensuing changes to the U.S. foreign tax credit regulations as well as the proliferation of minimum taxes aimed at profit-shifting—BEAT, GILTI, CAMT, and Pillar 2—the number of interrelated factors affecting a multinational group’s tax liability is mushrooming. This panel explores the practical implications of this complexity, focusing on how the elements of the system interact to produce different planning incentives in a range of common contexts, from M&A to IP ownership to internal group restructurings.

Speaker

Peter Blessing, Esq. | Associate Chief Counsel (International) Internal Revenue Service Washington, DC

Tijana J. Dvornic, Esq. | Wachtell, Lipton, Rosen & Katz New York, NY

Gary Scanlon, Esq. | KPMG LLP Washington, DC

Moshe Spinowitz, Esq. | Skadden, Arps, Slate, Meagher & Flom, LLP Boston, MA

Moderator

Shane Kiggen, Esq. | Ernst & Young Washington, DC

4:15 p.m. – 5:35 p.m.

New York City Taxes & New York State Taxes Joint Committee Meeting/High Tea

Gibson, Second Floor