Tax Section

8:45 a.m. – 9:00 a.m.

Business Meeting and Election of Officers

Mercury Ballroom, Third Floor

9:15 a.m. – 10:30 a.m.

CONCURRENT MORNING CLE SESSIONS

1A. Partnerships and Other Pass-Through Entities Mercury Ballroom, Third Floor The panel will discuss recent developments of general interest in the law of partnership taxation, including the partnership tax-related provisions in the One Big Beautiful Bill Act, updates on the ongoing SECA litigation, and the status of IRS and Treasury guidance on related-party basis adjustments. The panel will also discuss recent significant changes to the treatment of partnership transactions under the corporate alternative minimum tax (or CAMT).

Speaker

Craig Gerson, Esq. | Pricewaterhouse Coopers LLP Washington D.C.

Aliza Slansky, Esq. | Davis Polk & Wardwell LLP New York, NY

Moderator

Matthew Donnelly, Esq. | Gibson, Dunn & Crutcher LLP New York, NY

1.5 Credits in Areas of Professional Practice

1B. New York State and City Tax

Rendezvous / Trianon, Third Floor The panel will address hot topics and recent developments in New York State and New York City taxation, focusing on the question of how New York State and City and other conformity states treat amounts included in income for federal purposes under the so-called GILTI regime for controlled foreign corporations and whether, in particular following recent changes to the regime under the “One Big Beautiful Bill Act,” state approaches need to be reevaluated.

Speaker

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

Stephen Massed, Esq. | KPMG LLP Boston, MA

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

Moderator

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, M&A

Mercury Ballroom, Third Floor The panel will address M&A-related issues and developments, focusing on “F” reorganizations and related issues that arise in “inbound”/domestication transactions, for example under section 367 and FIRPTA (some of which have been addressed by IRS Notice 2025-45). The panel will also assess the guidance landscape for spinoffs following the recent withdrawal of proposed regulations under section 355 (REG-112261-24) and discuss issues practitioners are grappling with.

Speaker

Robert Liquerman, Esq. (Invited) | Special Counsel, IRS Office of the Associate Chief Counsel, Corporate

Karen Gilbreath Sowell, Esq. | Ernst & Young LLP Washington D.C.

Theron West, Esq. (Invited) | Attorney-Advisor, Office of Tax Policy, Department of the Treasury

Libin Zhang, Esq. | Fried, Frank, Harris, Shriver & Jacobson LLP New York, NY

Moderator

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

1.5 Credits in Areas of Professional Practice

2B. Financial Products and Transactions

Rendezvous/Trianon, Third Floor The panel will address recent developments of general interest to the financial services industry and practitioners, including IRS Notice 2025-63 (addressing the source of securities borrow fees) , and Private Letter Ruling 202536015 (addressing loan origination) The panel will also address topics specific to digital assets, including IRS Revenue Procedure 2025-31 (addressing the treatment of staked crypto ETFs), the source of staking rewards and the treatment of crypto lending transactions and crypto lending fees.

Speaker

Michael Shulman, Esq. | Fidelity Investments Boston, MA

Rebecca Lee | Dechert LLP Washington, D.C.

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

Lucy Farr, Esq. | Davis Polk & Wardwell LLP New York, NY

Moderator

Lorenz Haselberger, Esq. | A&O Shearman LLP New York, NY

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

Kevin Salinger, Esq. | Deputy Assistant Secretary for Tax Policy Department of the Treasury Washington, D.C.

No CLE Credit

2:30 p.m. – 4:00 p.m.

Afternoon CLE Session

Grand Ballroom, Third Floor International The panel will address recent developments on the international tax front. Topics of focus will include guidance implementing the OBBBA rules, such as the new pro rata shares rules under subpart F, rules for allocating foreign income taxes from a change in taxable years, changes to the foreign-derived deduction eligible income rules, and the application of the 10% foreign tax credit haircut to distributions of previously taxed earnings. The panel will also provide an update on the status of the OECD negotiations on the side-by-side system for U.S. coexistence with Pillar Two.

Speaker

Teisha Ruggiero Esq. (Invited) | Attorney Advisor Detailee Office of the International Tax Counsel Department of the Treasury Washington D.C.

Raymond Stahl, Esq. | Ernst & Young LLP Washington D.C.

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

Moderator

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

1.5 Credits in Areas of Professional Practice

4:15 p.m. – 5:30 p.m.

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

Gramercy East | Second Floor

No CLE Credit