Tax Section

8:45 a.m. – 9:00 a.m.

Business Meeting and Election of Officers

Mercury Ballroom, Third Floor

CONCURRENT MORNING SESSIONS

9:15 a.m. – 10:30 a.m.

1A. Partnership

Mercury Ballroom, Third Floor

This panel will discuss recent and potential guidance relating to partnerships, including basis shifting, allocations, continuations, terminations, self-employment taxes and elections out of subchapter K.

Speaker

Meyer H. Fedida, Esq. | Cleary Gottlieb Steen & Hamilton LLP New York, NY

Jen Ray, Esq. | Deloitte Tax LLP Arlington, VA

David H. Schnabel, Esq. | Davis Polk & Wardwell LLP New York, NY

Richard Blumenreich (Invited) | Special Counsel in the Office of the Associate Chief Counsel (Passthrough & Special Industries Internal Revenue Service)

Sarah Haradon, Esq. (Invited) | Office of Tax Policy, Department of the Treasury Washington D.C.

1.5 Credits in Areas of Professional Practice

9:15 a.m. – 10:30 a.m.

1B. New York State Tax Developments

Rendezvous/Trianon, Third Floor

This panel will address new developments in New York State tax law.

Speaker

Alysse B. McLoughlin, Esq. | Jones Walker LLP New York, NY

Elizabeth Pascal, Esq. | Hodgson Russ LLP New York, NY

Irwin M. Slomka, Esq. | Blank Rome LLP New York, NY

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

1.5 Credits in Areas of Professional Practice

10:30 a.m. – 10:45 a.m.

Break

10:45 a.m. – 12:00 p.m.

2A. Corporate Tax- It Will Never Be Perfect, but Let’s Make It Work Better: Recent Guidance on Spin-Offs and CAMT

Mercury Ballroom, Third Floor

This panel will discuss practical implications of recent guidance issued by the Treasury and the IRS under Section 355 and the CAMT. Section 355 topics will include allocation of liabilities between Distributing and Controlled and other significant ramifications of recent guidance on spin-off planning. CAMT topics will include open questions regarding the treatment of M&A, consolidated returns, and troubled companies.

Speaker

Shane J. Kiggen, Esq. | Ernst & Young LLP Washington D.C.

Davis J. Wang, Esq. | Sullivan & Cromwell LLP New York, NY

Sara Zablotney, Esq. | Kirkland & Ellis LLP New York, NY

Colin Campbell, Esq. (Invited) | Associate Tax Legislative Counsel Department of the Treasury (Office of Tax Policy) Washington D.C.

Mark A. Schneider, Esq. (Invited) | Associate Chief Counsel (Corporate) Internal Revenue Service Washington, DC

1.5 Credits in Areas of Professional Practice

10:45 a.m. – 12:00 p.m.

2B. Debt Financing- To Be or Not to Be . . . a Lender: Tax Issues in Treatment of Capital Providers and their Returns

Rendezvous/Trianon, Third Floor

This panel will discuss tax issues in fact patterns where the treatment of parties providing (or committing to provide) capital as a lender and the income they receive is not entirely clear. The topics will include determination of issue price and related lender-side and issuer-side tax issues in firm commitment underwritings as well as open questions regarding tax treatment of the various fees that a capital provider receives in common, yet complex, fact patterns.

Speaker

Bora Bozkurt, Esq. | Latham & Watkins LLP New York, NY

James R. Brown, Esq. | Ropes & Gray LLP New York, NY

Pamela Lawrence Endreny, Esq. | Gibson Dunn New York, NY

Jeffrey W. Maddrey, Esq. | Pricewaterhouse Coopers LLP Washington D.C.

Erika Nijenhuis, Esq. (Invited) | Senior Counsel, Office of Tax Policy U.S. Department of the Treasury Washington, DC

1.5 Credits in Areas of Professional Practice

12:30 p.m. – 2:00 p.m.

Luncheon (Additional fee applies)

Grand Ballroom, Third Floor

Speaker

Glenn Hubbard | Columbia University

No CLE Credit

AFTERNOON SESSION

2:15 p.m. – 4:00 p.m.

International Tax Guidance in Under the Wire

Grand Ballroom, Third Floor

This panel will discuss the Biden Administration's latest regulatory guidance including the recently proposed regulations on previously taxed earnings and profits, cloud computing and commercial activities under section 892.

Speaker

Kristen Gamboa, Esq. | KPMG LLP Orlando, FL

Ansgar A. Simon, Esq. | Covington & Burling LLP New York, NY

Wade Sutton, Esq. | Pricewaterhouse Coopers LLP Washington D.C.

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

James S. Wang (Invited) | Deputy International Tax Counsel Department of the Treasury

2.0 Credits in Areas of Professional Practice

4:15 p.m. – 5:35 p.m.

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

Murray Hill East, Second Floor

No CLE Credit

Section Chair

Jiyeon Lee-Lim, Esq. | Latham & Watkins LLP | New York, NY