Tax Section 2024 Summer Meeting

ACCOMODATIONS

The Statler Hotel at Cornell University

130 Statler Dr, Ithaca, NY 14853 

607-254-2500

The hotel room block is now closed.  If you are looking to book a room at the Statler Hotel, please contact them directly at (607) 254-2500 to check on availability. 

Hotel Information and Policies

Check-In Time- 4:00 p.m. | Check-Out Time-12:00 p.m.

Guest Parking/Airport Transportation:

Overnight parking fee for guest vehicles parked at The Statler Hotel is currently $35.00 per night per vehicle, subject to change. Parking is limited to overnight guests. Day-guest parking must be arranged in advance with your catering/conference planner, based on availability. A day-guest parking fee will be applicable.

The Statler Hotel provides shuttle service to and from the Ithaca Tompkins Regional Airport 7 days per week. This

complimentary service is provided for our overnight guests. Advance reservations are required and can be arranged through your Catering/Conference Planning Manager or by contacting our Front Office.

Nearby Airports

Ithaca (ITH) Airport, just 3 mil away. 

Other nearby airports include Syracuse (SYR) Airport (50mil), Rochester (ROC) Airport (76 mil), Scranton/Wilkes-Barre (AVP) Airport (86 mil) 

REGISTRATION

Main Conference Registration (inclusive of CLE programming, breakfast, lunch, coffee breaks, and evening receptions and dinners)

Tax Section Member- $675 (Before June 21)  $725 (After June21)

NYSBA Member- $750 (Before June 21) $825 (After June 21)

Non-Member-$875

Young Attorneys (10 years or less)- $275

Spouse/Guest Pass-$350

VISIT ITHACA

https://statlerhotel.cornell.edu/step-outside/local-experiences

QUESTIONS/ASSISTANCE:

For registration questions or assistance, please reach out to our Member Resource Center (MRC) at [email protected] or at 800-582-2452/ 518-463-3724.

AGENDA:

Please note the agenda is subject to slight changes.

Friday, July 12, 2024

4:00 p.m. – 6:00 p.m. Registration

6:00 p.m. – 7:00 p.m. Welcome Cocktail Reception – Hotel Statler, Ballroom

7:00p.m. – 9:00 p.m.  Dinner – Hotel Statler, Ballroom

Saturday, July 13, 2024

8:00 a.m. – 3:15 p.m.  Registration

7:30 a.m. – 9:30 a.m.  Breakfast-Taylor A&B

9:30 a.m. – 9:45 a.m. Welcoming Remarks

Jiyeon Lee-Lim, Section Chair

Latham & Watkins LLP

New York, NY

9:45 a.m. – 11:00 a.m.                     

IRS Guidance on Spin-Offs:  What Does the Future Hold?

The IRS recently released Revenue Procedure 2024-24 and Notice 2024-38 containing new private letter ruling procedures for spin-offs and a request for public feedback with an eye toward developing published guidance.  In this session, we will discuss key elements of those IRS pronouncements, including, de-leveraging of the distributing corporation, retention of controlled corporation shares, and solvency considerations.

Moderator

Deborah L. Paul 

Wachtell, Lipton, Rosen & Katz New York, NY

Panelists

Austin Diamond- Jones (invited)

Internal Revenue Service

Washington DC

Colin Campbell (invited)

Associate Tax Legislative Counsel

Department of the Treasury (Office of Tax Policy)

Washington, DC

Nicole Field

Earnst & Young LLP

Washington DC

Richard Nugent 

Jones Day 

New York

11:00 a.m.- 12:00 p.m. 

Trends and Developments in New York State and City Tax

Moderator

Jack Trachtenberg, Esq. 

Deloitte Tax LLP 

New York, NY

Panelists

Doran Gittelman

Deloitte Tax LLP 

New York, NY

Chelsea Marmor

Eversheds Sutherland (US) LLP

New York, NY

Elizabeth Pascal, Esq.

Hodgson Russ LLP 

New York, NY

12:00 p.m. – 1:00 p.m. Lunch – Terrace Restaurant

1:15 p.m. – 2:30 p.m. 

Roundtable Discussion on Moore and Liberty Global

Moderator:
Sara Zablotney 

Kirkland & Ellis LLP

New York, NY

Panelists

Peter Blessing

Associate Chief Counsel (International)
Internal Revenue Service

Washington, DC

David Schizer, Esq.

Dean Emeritus & Harvey R. Miller Professor of Law

Columbia Law School

New York, NY

Michael Mollerus

Davis Polk & Wardwell LLP 

New York, NY

Phillip Wagman

Clifford Chance US LLP

New York, NY

2:30 p.m. – 5:30 p.m. Optional Afternoon Activity

Enjoy a beautiful afternoon at the Taughannock Falls.  Taughannock Falls carves a 400-foot gorge through layers of sandstone, shale and limestone that were once the bed of an ancient sea. With a 215-foot plunge, this waterfall stands three stories taller than Niagara Falls. Transportation will be provided.  To learn more about the falls, visit here.

6:00 p.m. – 7:00 p.m. Cocktail Reception (Offsite) – McCormick’s at Moakley House 

Transportation will be Provided

7:00 p.m. – 9:00 p.m.    Dinner (Offsite) – McCormick’s at Moakley House 

Sunday, July 14, 2024

8:00 a.m. Registration

8:00 a.m. – 9:00 a.m. Executive Committee Meeting – Yale/Princeton

7:30 a.m. – 9:30 a.m. Breakfast – Taylor A&B

9:15 a.m. – 10:30 a.m. 

Pillar 2 Ruminations: Exploring the Impact of GloBE on Transactions

The Pillar 2 global anti-base erosion (“GloBE”) rules generally impose a top-up tax to ensure that each multinational company is taxed at 15% in each jurisdiction in which it operates. Countries have been implementing these rules into their national legislation at an accelerated pace; many multinationals are already subject to them in 2024 in at least one jurisdiction, and many more will feel their bite in 2025.  As the GloBE Rules come online, they will have a significant and multifaceted impact on M&A transactions and deal structuring. The focus of the panel will be on the practical impact of the GloBE rules on M&A transactions. The panel will examine the key Pillar 2 considerations that M&A practitioners should be aware of, including the application of the transition rules, the interaction of GloBE and regular tax attributes, and structuring joint ventures in a Pillar 2 world                   

Moderator

Gary Scanlon 

KPMG LLP

Washington, DC

Panelists
Richard L. Reinhold (invited)

Special Counsel, Office of Associate Chief Counsel (International)

Internal Revenue Service

Washington, DC

Shane J. Kiggen

Earnst & Young LLP

Washington, DC

Adam Kool

Kirkland & Ellis LLP

New York, NY

Kara Mungovan 

Davis Polk & Wardwell LLP

New York, NY

10:30 a.m. Adjourn