MIDYEAR MEETING by dandanhuanghuang

VIEWS: 60 PAGES: 90

									  F I N A L                       P R O G R A M

2007
MIDYEAR
MEETING
JANUARY 18 – 20
WESTIN DIPLOMAT RESORT
HOLLYWOOD, FLORIDA
THURSDAY, JANUARY 18TH
LOW INCOME TAXPAYER CLINIC WORKSHOP, 1:00PM – 6:15PM
FRIDAY, JANUARY 19TH
SECTION BREAKFAST, 7:15AM
SPEAKER: MARK W. EVERSON, COMMISSIONER, IRS, WASHINGTON, DC
SATURDAY, JANUARY 20TH
SECTION PROGRAMS
I Application of Foreign Tax Credit "Legal Liability" Rules to Facts Raised
  by Foreign Consolidated Group Systems
I Current Developments in Individual, Corporate, Partnership, and Estate
  & Gift Taxation
I Do You Know Where Your Stock Plan Is? A Compliance Review For
  Stock Plans
I Opinions and Penalties

I Reexamining Section 197 – Practical and Technical Issues




                                                   VITA
                                              CERTIFICATION!
                                                   SEE P. 5
                                                 FOR DETAILS!




S E C T I O N O F TA X AT I O N
  The American Bar Association Section of
Taxation would like to thank our sponsors for
            their support of the
        2007 MIDYEAR
                  MEETING
                          PREMIER


  a Legal Publishing Company, is a Primary Corporate Sponsor of the
                       ABA Section of Taxation




                             GOLD




                            SILVER
                           Taggart
                          & Hawkins
                A Professional Corporation




                          BRONZE
                      Baker & McKenzie
                  Borden Ladner Gervais LLP
               Houlihan Lokey Howard & Zukin
             J.P. Morgan Property Exchange Inc.
          CONTENTS
General Information.......................................................2

Activities.........................................................................7

Programs for Young Lawyers.........................................11

Program Schedule ........................................................14

   Thursday, January 18................................................14

   Friday, January 19.....................................................17

   Saturday, January 20 .............................................57

Section Programs ........................................................72

Affiliated Organizations ..............................................75

Alpha Schedule............................................................76

Future Meetings..................................Inside Back Cover
                  GENERAL INFORMATION
GENERAL INFORMATION




                                           The Section of Taxation welcomes you to the
                                           2007 Midyear Meeting. We are pleased that
                                           you have decided to join us and take
                                           advantage of the opportunity to meet with
                                           the country’s leading attorneys and
                                           government officials to discuss the latest
                                           federal tax policies, initiatives, regulations,
                        SUSAN P. SEROTA    legislative forecasts, planning ideas and
                        SECTION CHAIR      network with Section members. Please make
                      sure to complete and return the evaluation form (which can be
                      found on your Meeting Materials CD-ROM). We welcome your
                      comments!

                                              SECTION BREAKFAST/
                                              PLENARY SESSION WITH IRS
                                              COMMISSIONER, MARK W.
                                              EVERSON
                                             The Section of Taxation is pleased that IRS
                                             Commissioner, Mark W. Everson, will
                                             address attendees of the 2007 Midyear
                       MARK W. EVERSON
                        COMMISSIONER         Meeting at the Section Breakfast. Please note
                                             that you must have pre-registered and
                      requested a ticket to attend the breakfast. Tickets are not available
                      on-site.

                      REGISTRATION
                      Any individual attending any part of the 2007 Midyear Meeting,
                      regardless if he or she speaks, must register and pay the registration
                      fee. Shared registrations are not permitted. Companions are
                      defined as non-Section members not attending substantive
                      meetings. Any companion attending substantive programs must
                      register and pay either the Section member or non-Section
                      member registration fee, whichever applies.
                      The registration fee includes one set of meeting materials on CD-
                      ROM and permits registrants to attend all meetings, sessions and
                      programs; however, it does not include meal functions and social
                      events listed as “Ticketed Event.” All ticketed events are sold on a first-
                      come, first-served basis. Payment may be made by check or credit
                      card. The Section accepts American Express, MasterCard and VISA.

                      REFUND POLICY
                      All cancellations and refund requests must have been received in
                      writing and postmarked, faxed or emailed by January 11, 2007 to
                      receive a refund. All refund requests will incur a $50 cancellation
                      fee. Refunds will not be granted at or after the meeting.

                  2
                     GENERAL INFORMATION




                                                                       GENERAL INFORMATION
ON-SITE REGISTRATION AND TICKET
PURCHASE HOURS
The Registration Desk, located in Grand Foyer, 1st Floor,
Convention Center, will be open during the following hours:
Thursday 12:00pm - 7:30pm
Friday    6:30am - 6:30pm
Saturday 6:30am - 2:00pm

BADGE IDENTIFICATION
RED Bar            Section Officers, Council Members,
                   Committee Chairs, Task Force Chairs, Past
                   Section Chairs
GREEN Bar          Government Officials/Guests
PURPLE Bar         Foreign Lawyers
BLUE Bar           Young Lawyers
GRAY Bar           Law Students and LLM Candidates
YELLOW Bar         First-Time Attendees
ORANGE Bar         Companions
YELLOW Badge Press

VIRTUALLY PAPERLESS MEETING
All Meeting Materials for the 2007 Midyear Meeting are available
on CD-ROM in PDF format. Please note that the Uniform
Certificate of Attendance and the evaluation form are also available
on the CD-ROM. Should you wish to print out any materials,
convenient print stations are located in Grand Foyer, 1st Floor,
Convention Center.
Please note that Materials not provided in advance to the Section
are available in hard copy on-site and are not on the CD-ROM.
These materials, to the extent they are provided to the Section, and
those included on the Meeting Materials CD-ROM, will also be
made available following the meeting on the Tax Section’s web site
www.abanet.org/tax/commonline/ by Comm-Online—an
innovative Tax Section and LexisNexisTM joint project which gives
members FREE online access to hundreds of pages of Section
Program and Committee Meeting Materials.

CLE AND ETHICS CREDIT                     CLE
You must be registered for the meeting in order to attend and be
eligible to receive CLE or ethics credit. Accreditation has been
requested for this meeting from every state with mandatory
continuing legal education (MCLE) requirements for lawyers.
                                                                   3
                  GENERAL INFORMATION
GENERAL INFORMATION




                      Each state has its own rules and regulations, including its
                      definition of “CLE.” The Section has requested CLE credit for
                      subcommittee meetings that include a program description and
                      names of panelists. Eligible subcommittees are listed on the
                      Uniform Certificate of Attendance. The Uniform Certificate of
                      Attendance is included on the Meeting Materials CD-ROM and is
                      available at the CLE Information Booth for both attendees and
                      speakers. Please note that the symbol indicates that Ethics credit
                      has been requested for this program, and the CLE symbol indicates
                      that CLE credit is not available for this program. Call the ABA
                      Section of Taxation at (202)662-8672 with any questions
                      pertaining to the number of credit hours granted by each state.
                      REQUIREMENTS FOR NEW YORK ATTORNEYS: You are
                      responsible for signing in and out of each session you attend so a
                      New York Uniform Certificate of Attendance can be customized
                      for you. The New York sign-in/out sheets are available in each
                      meeting room, and the Uniform Certificate of Attendance Form is
                      available at the CLE Information Booth. In order to receive full
                      credit for all sessions attended, you MUST stop by the CLE
                      Information Booth, located in Grand Foyer, 1st Floor,
                      Convention Center, before you leave the Meeting to obtain a
                      completed Uniform Certificate of Attendance and an
                      authorization signature from an ABA staff member.

                      CLE INFORMATION BOOTH
                      The CLE Information Booth, located in Grand Foyer, 1st Floor,
                      Convention Center, will be open during the following hours:
                      Thursday 12:00pm - 7:30pm
                      Friday    8:00am - 6:30pm
                      Saturday 8:00am - 5:30pm
                      Please direct all questions regarding CLE credit to the CLE
                      Information Booth, not the Registration Desk.

                      AUDIO CDs/MP3s/TAPES
                      Audio CDs and MP3s of Committee Meetings and Section
                      Programs are available for purchase on site. Audio tapes may be
                      ordered after the meeting. To place an order, visit the Digital
                      Conference Providers booth in Grand Foyer, 1st Floor, Convention
                      Center. After the meeting, you may place an order by contacting
                      DCP at (630)963-8311, or by visiting them on the web at
                      https://www.dcporder.com/abatx/.




                  4
                      GENERAL INFORMATION




                                                                        GENERAL INFORMATION
PRO BONO AWARD
The Pro Bono Award was established to recognize one or more
individuals or law firms that have provided meritorious pro bono
service in the representation of low-income taxpayers. The award is
intended to encourage pro bono activities by all members through
public recognition of the pro bono services of the annual award
winner. The Sixth Annual Pro Bono Award will be presented to
Professor Leslie M. Book, Director, Federal Tax Clinic, Villanova
University School of Law, at the Section Breakfast/Plenary Session on
Friday. Former recipients of the award are Elizabeth Atkinson (2002),
Victoria Bjorklund (2002), Peter A. Lowy (2003), Karen L. Hawkins
(2004), Diana L. Leyden (2005), and Janet Spragens (2006).

JOHN S. NOLAN TAX LAW FELLOWS
2006 - 2007
Christopher Condeluci, Groom Law Chartered, Washington, DC;
Jessica Hough, Skadden Arps Slate Meagher & Flom LLP,
Washington, DC; Gregory Lynam, Miller & Chevalier Chartered,
Washington, DC; Veronica Rouse, Attorney, Qualified Plans 1,
IRS, Washington, DC; Bahar A. Schippel, Snell & Wilmer LLP,
Phoenix, AZ; David B. Strong, Holme Roberts & Owen LLP,
Denver, CO.

VOLUNTEER INCOME TAX (VITA)
ON-SITE TRAINING
The ABA Section of Taxation is pleased to offer “one stop
shopping” for all VITA Certification at the 2007 Midyear
Meeting!
Representatives of the IRS and TaxWise (the software used by the
IRS for volunteer income tax preparation) will be present
throughout the meeting to provide hands-on training for members
interested in volunteering to prepare individual income tax returns
for the 2007 filing season through the Volunteer Income Tax
Assistance (VITA) program. Members will be able to obtain their
required certifications to become VITA volunteers by taking the
online examinations in one or more of the IRS “Link & Learn”
modules, i.e., Basic, Wage Earner, and Pension Earner. Members
can also be trained in the use of the TaxWise software by
representatives of the software vendor.
Training will be available on Friday and Saturday from 8:30am to
5:30pm, in Room 205, 1st Floor, Hotel. Training on each module
will take approximately two hours to complete. To register, please
visit the Meeting Registration Booth, located in Grand Foyer, 1st
Floor, Convention Center.


                                                                     5
                  GENERAL INFORMATION
GENERAL INFORMATION




                      SECTION EXHIBIT
                      The Section Exhibit, located in Grand Foyer, 1st Floor,
                      Convention Center, will be open on Friday and Saturday from
                      7:00am - 5:00pm. Representatives from the following entities will
                      demonstrate the latest research methods and exciting new products
                      to aid in your daily practice.
                      Publishers
                      Lexis Nexis
                      Thomson RIA
                      Financial Services
                      Houlihan Lokey Howard & Zukin
                      JP Morgan Property Exchange, Inc.
                      Strategic Property Exchanges
                      Wachovia Exchange Services

                      SECTION RECEPTION/PLENARY SESSION
                      The Section Reception will be on Friday from 6:30pm-8:00pm at
                      the Westin Diplomat Resort.

                      20% MEETING DISCOUNT ON SECTION
                      PUBLICATIONS
                      Stop by the Publications Display, located in Grand Foyer, 1st
                      Floor, Convention Center, to preview the most popular titles from
                      the Section of Taxation and receive a 20% discount on all
                      publication orders. Drop off your completed order form on-site at
                      the Meeting Registration Desk, or fax it to the Section Office at
                      (202)662-8682 to take advantage of this special discount. Please
                      note that the offer expires Friday, January 26, 2007.

                      HOSPITALITY CENTER
                      Location: Grand Foyer, 1st Floor, Convention Center
                      On Friday and Saturday, a complimentary continental breakfast
                      will be served in the morning. Snacks, coffee, sodas and water will
                      be available in the afternoon.
                      Hours:    Friday                7:00am - 4:00pm
                                Saturday              7:00am - 4:00pm

                      DRESS
                      Dress for the 2007 Midyear Meeting is business casual.

                      CHILD CARE SERVICES
                      If you need childcare services, contact the concierge in the hotel
                      where you are registered.
                  6
                                                ACTIVITIES

THURSDAY, JANUARY 18
7:30AM - 1:00PM
GOLF OUTING AT DIPLOMAT COUNTRY CLUB
(Ticketed Event $230)
The Diplomat Country Club & Spa’s championship golf course is
nestled amongst 3,000 coconut and royal palm trees, 50-year-old
shady banyans and lakes guarding 16 of the 18 holes. This par 72,
Joe Lee design offers a challenge to even the most accomplished
golfer, while giving the less advanced player a great excuse to spend




                                                                        ACTIVITIES
a few hours relaxing in the sun. Conveniently located just 5
minutes from the Westin Diplomat Resort, the Diplomat Country
Club golf course provides an unmatched golf experience in the
Hollywood area.
Transportation by shuttle will depart from the convention center
lower lobby at 7:30am to allow time on the driving range and
prepare for an 8:00am shotgun start. Green fees, cart fees, driving
range, bag tag, divot tool, box lunch and transportation are
included in the event fee of $230 per person. Club rental is
available for an additional fee.



FRIDAY, JANUARY 19
9:00AM - 3:00PM
WOMEN’S HERITAGE TRAIL TOUR & LUNCH
(Ticketed Event $125*; limited quantities available)
Delight in the sights and stories of the strong-minded women who
made Miami happen. You will hear about the early eccentric
pioneers and their stories of adventure and hardship in the Florida
wilderness and you will retrace the steps of the “Mothers of
Miami” Julia Tuttle and Mary Brickell who battled a harsh and
lonely existence along the shores of Biscayne Bay and decided to
single-handedly change the history of the whole region by bringing
the lifeline of Flagler’s railroad to South Florida. In addition, you
will experience the hidden places where strong women worked
quietly to bring culture and education to America’s last frontier.
And, finally, you will explore the life of aviation-pioneer Amelia
Earhart and learn of the foresight of environmentalist Marjory
Stoneman Douglas. Find out how now-gleaming South Beach was
saved from being ripped down by the voice and dramatic actions
of preservationist Barbara Capitman. During the tour, you will
visit various historic landmarks that are now famous due to the
women who made Miami happen! Don’t miss out on this behind
the scenes tour led by Dragonfly Expeditions, named by Conde
Nast Traveler magazine as one of the best in the world!

                                                                      7
         ACTIVITIES
             After your experience on the Women’s Heritage Trail, you will
             enjoy lunch at Chispa Restaurant. Chispa is an energetic
             contemporary Latin Restaurant, which offers a unique
             combination of cuisine, ambience and service. The Menu bursts
             with flavorful interpretations of Latin favorites featuring a grand
             selection of innovative dishes reflective of traditional Hispanic food
             customs including an extensive selection of cazuelitas, creative
             ceviches and tartares, crispy flatbreads, unique salads, hearty plates
             and more. Chispa blends authentic cuisines with reflections of Old
             World Culinary culture from the Spanish Caribbean to Latin
             America in a New World setting.
ACTIVITIES




             Buses will depart from the Convention Center lower lobby
             promptly at 9:00am. Please dress appropriately for the weather and
             wear comfortable walking shoes.
             *15% of the gross profits of this tour go directly to the Dade Heritage
             Trust to support their preservation efforts.



             SATURDAY, JANUARY 20
             8:30AM - 12:30PM
             TROPICAL DECO IN A FABLED PLAYGROUND TOUR
             (Art Deco Architecture Tour) (Ticketed Event $95; limited
             quantities available)
             Encounter the Art Deco tour that captures the glitz and glamour
             of the roaring twenties and thirties in our nation’s only Art Deco
             Historic District. This is your chance to experience the thrill of a
             city that defiantly danced ‘til dawn through the prohibition, the
             depression, major hurricanes, and two World Wars. Here the
             Playboy/flapper lifestyle was the only way to live, and as the warm
             breezes tempted you to free yourself of the confines of more formal
             clothes, the incoming tide would hint of the clandestine import
             that you’d be sipping at a swinging speakeasy late into the night.
             Recall the larger than life personalities and world famous events
             that re-shaped society, architecture, and even the island itself.
             During the tour, you will visit many Art Deco landmarks
             including the first hotel ever built on Miami Beach; Casa
             Casuarina, the famous home of Gianni Versace; and the
             imaginative and playful art deco lifeguard stands lining the beach
             like pastel-colored toy soldiers. Chart the evolution of architectural
             styles while unique and evocative Art Deco landmarks serve as
             signposts to an era that looked forward to the future and
             celebrated progress, innovation, adventure, and freedom.




         8
                                                ACTIVITIES
As your guide uncovers the eye-popping history of this unique
destination, you will understand why millionaires, movie stars,
thousands of soldiers, and countless others have fallen under the
magical spell of Miami Beach. Don’t miss out on this behind the
scenes tour led by Dragonfly Expeditions, named by Conde Nast
Traveler magazine as one of the best in the world!
Buses will depart from the Convention Center lower lobby
promptly at 8:30am. Please dress appropriately for the weather and
wear comfortable walking shoes.




                                                                        ACTIVITIES
OTHER ATTRACTIONS
MUSEUM OF ART | FORT LAUDERDALE
Cradle of Christianity: Jewish and Christian Treasures from the
Holy Land
Organized by The Israel Museum, Jerusalem
Cradle of Christianity: Jewish and Christian Treasures from the Holy
Land provides visitors an unprecedented opportunity to learn
about aspects of early Jewish life, the concurrent birth of
Christianity, and how the two faiths influenced each other by
presenting archaeological treasures excavated in Israel during the
last century. This exhibition, which will travel to only two other
venues in the US, will present extraordinary biblical artifacts, many
excavated only within the last 50 years and never before seen on
US soil, including:
   The Temple Scroll (Dead Sea Scroll). Its scale and subject,
   which calls for a new interpretation of the Torah, make the
   Temple Scroll one of the most significant of the Dead Sea
   Scrolls. This section of the Temple Scroll has recently been
   restored, and will be on display for the first time anywhere at
   the Museum of Art | Fort Lauderdale.
   Burial ossuary of Joseph, son of Caiaphas the High Priest.
   According to the New Testament, it was Caiaphas who
   delivered Jesus to the Romans for trial and eventual crucifixion.
   A commemorative inscription bearing the name of Pontius
   Pilate. This inscription and the ossuary of Joseph, son of
   Caiaphas represent the only known surviving physical
   testimonies of these two important figures from the story of the
   trial of Jesus.




                                                                     9
         ACTIVITIES
                Heel bone of Yehohanan, son of Hagkol, punctured by an
                iron nail (replication), is the only tangible evidence of the
                practice of crucifixion to have been discovered in archaeological
                excavations.
                A graffito of the menorah, found in excavations of the Jewish
                Quarter in Jerusalem and dating to the first century BCE (the
                Second Temple Period), is the oldest representation of the
                menorah that stood in the Temple of Jerusalem.
                A full-scale reconstruction of the chancel of a Byzantine-era
                church comprising an original altar, chancel screens,
ACTIVITIES




                baptisterium, reliquary, and pulpit, and adorned by mosaics.
                The two largest three-dimensional menorahs ever found in
                excavation
             To purchase tickets, please visit http://www.moafl.org/06/
             exhibitions/christianity/tickets.htm or call (954) 462-0222 or
             (877) 787-7711. The Museum of Art | Fort Lauderdale is located
             approximately 15 miles or 25 minutes driving time from the
             Westin Diplomat Resort.




         10
  PROGRAMS FOR YOUNG LAWYERS
        = Taped
        = Young Lawyers Program
        = Ethics Credit Requested
  CLE   = No CLE Credit



THURSDAY, JANUARY 18
1:00PM - 6:15PM                   Diplomat 1, 1st Floor, Convention Ctr
LOW INCOME TAXPAYER CLINIC WORKSHOP -
REFUND CLAIM LITIGATION    (Registration Required)
See p. 14 for further details.
6:15PM                            Diplomat 2, 1st Floor, Convention Ctr
LOW INCOME TAXPAYER CLINIC WORKSHOP
RECEPTION CLE
6:30PM - 9:30PM                                          Giorgio’s Grill   PROGRAMS FOR YOUNG LAWYERS
PARTNERSHIPS & LLCs AND REAL ESTATE DINNER
   CLE (Reservations Required)
Members of the Real Estate Committee and the Partnerships &
LLCs Committee will meet for cocktails and dinner at Giorgio’s
Grill, just a short cab ride from the Westin Diplomat
(www.giorgiosgrill.com). Cocktails will begin at 6:30pm, followed
by dinner at 7:30pm. Reservations and advance payment required.



FRIDAY, JANUARY 19
7:00AM - 7:30AM                           Room 307, 2nd Floor, Hotel
YOUNG LAWYERS ORIENTATION                         CLE

7:15AM - 8:30AM                  Grand East, 1st Floor, Convention Ctr
SECTION BREAKFAST/PLENARY SESSION                             CLE
(Ticketed Event; Tickets not available on-site)
8:30AM - 5:30PM                            Room 205, 1st Floor, Hotel
VOLUNTEER INCOME TAX (VITA) ON-SITE
TRAINING CLE
See p. 5 for further details.
9:00AM - 12:00PM                       Room 212 - 214, 1st Floor, Hotel
YOUNG LAWYERS FORUM - 2006 LAW STUDENT
TAX CHALLENGE    CLE
Semi-Final Rounds (Open to the Public)
12:30PM - 1:30PM                 Grand East, 1st Floor, Convention Ctr
PARTNERSHIPS & LLCs AND REAL ESTATE
LUNCHEON CLE (Ticketed Event)
Sponsored by: Baker & McKenzie

                                                                       11
                         PROGRAMS FOR YOUNG LAWYERS
                             1:00PM - 4:00PM                       Room 212 - 214, 1st Floor, Hotel
                             YOUNG LAWYERS FORUM - 2006 LAW STUDENT
                             TAX CHALLENGE    CLE
                             Final Rounds (Open to the Public)
                             1:15PM - 2:15PM                          Room 302, 2nd Floor, Hotel
                             EMPLOYEE BENEFITS YOUNG LAWYERS IN
                             EMPLOYEE BENEFITS FORUM CLE , Presented by the
                             Young Lawyers in Employee Benefits Forum
                             1:30PM - 2:30PM                          Room 308, 2nd Floor, Hotel
                             ESTATE & GIFT TAXES AND FIDUCIARY INCOME TAX
                             YOUNG LAWYERS SUBCOMMITTEE CLE
                             4:00PM - 6:30PM                     Room 312 & 313, 2nd Floor, Hotel
                             DIVERSITY COMMITTEE AND YOUNG LAWYERS
                             FORUM
PROGRAMS FOR YOUNG LAWYERS




                                    4:00pm         Improving Your Writing and Getting
                                                   Published.

                                    5:30pm         Networking Reception.         CLE
                                                   Room 314, 2nd Floor, Hotel
                                                   Sponsored by: Pillsbury Winthrop Shaw
                                                   Pittman LLP



                             SATURDAY, JANUARY 20
                             7:15AM - 8:30AM                  Diplomat 3, 1st Floor, Convention Ctr
                             PARTNERSHIPS & LLCs/REAL ESTATE/
                             S CORPORATIONS “SHOP TALKING”
                             BREAKFAST CLE (Ticketed Event)
                             Sponsored by: Wachovia Exchange Services
                             8:30AM - 5:30PM                           Room 205, 1st Floor, Hotel
                             VOLUNTEER INCOME TAX (VITA) ON-SITE
                             TRAINING CLE
                             See p. 5 for further details.
                             9:00AM - 10:30AM                 Diplomat 2, 1st Floor, Convention Ctr
                             PRO BONO            CLE

                                    9:00am         Roundtable Discussion.

                             COMMITTEE LUNCHEON
                             12:00PM - 12:30PM                 Regency 3, 1st Floor, Convention Ctr
                             STANDARDS OF TAX PRACTICE AND YOUNG
                             LAWYERS FORUM CLE (Ticketed Event)



                         12
  PROGRAMS FOR YOUNG LAWYERS
12:30PM - 1:30PM                 Regency 3, 1st Floor, Convention Ctr
JOINT SESSION OF STANDARDS OF TAX PRACTICE
AND YOUNG LAWYERS FORUM
Topic: Practical and Ethical Issues Relating to Opinion Practice,
Summons Enforcement Defense, Shelter Advisor Disclosures and
Circular 230 Compliance.
SECTION PROGRAM
2:00PM - 5:00PM                  Regency 2, 1st Floor, Convention Ctr
CURRENT DEVELOPMENTS IN INDIVIDUAL,
CORPORATE, PARTNERSHIP, AND ESTATE & GIFT
TAXATION
A review of the most significant court decisions, rulings and
statutory and regulatory developments during the past 12 months.
       Moderator: Professor Ira B. Shepard, University of
                  Houston Law Center, Houston, TX

       Panelists:   Professor James A. Delaney, University of           PROGRAMS FOR YOUNG LAWYERS
                    Wyoming College of Law, Laramie, WY

                    Professor Martin J. McMahon Jr, University
                    of Florida Fredric G. Levin College of Law,
                    Gainesville, FL

       Sponsored by: Teaching Taxation

2:00PM - 4:30PM                  Regency 1, 1st Floor, Convention Ctr
STANDARDS OF TAX PRACTICE
       2:00pm       Opening Remarks by the Chair.       CLE


       2:10pm       Report from the IRS on Ethics Issues.

       2:35pm       Report from Subcommittee on ABA Formal
                    Opinion 346.

       2:45pm       The Ethics of Compliance: Return
                    Preparation, Sensitive (Eggshell) Audits, and
                    Voluntary Disclosure.




                                                                    13
       THURSDAY, JANUARY 18

           THURSDAY, JANUARY 18
           7:30AM - 1:00PM
           GOLF OUTING AT DIPLOMAT COUNTRY CLUB
           (Ticketed Event)
           See p. 7 for a full description.
           8:30AM - 5:00PM                    Diplomat 3, 1st Floor, Convention Ctr
           OFFICERS AND COUNCIL MEETING CLE (Executive Session)
           1:00PM - 6:15PM                    Diplomat 1, 1st Floor, Convention Ctr
           LOW INCOME TAXPAYER CLINIC WORKSHOP -
           REFUND CLAIM LITIGATION    (Registration Required)
           The Low Income Taxpayer and Pro Bono Committees proudly
           present the annual Tax Workshop for New and Pro Bono tax
           practitioners.
                  1:00pm         Filing Claims for Refund in US Tax Court,
                                 US District Court and the US Court of
                                 Federal Claims. Prior to filing a claim for
                                 refund in the US Tax Court, US District
                                 Court and US Court of Claims, a taxpayer
                                 must exhaust his or her administrative
                                 remedies. This panel will discuss what steps a
                                 taxpayer must take within the IRS as a
                                 jurisdictional requirement to bringing suit
                                 before any court. Moderator: Paul Harrison,
                                 Community Tax Law Project Inc, Richmond,
                                 VA. Panelists: Elizabeth Davis, Trial Attorney,
                                 Department of Justice, Washington, DC;
THURSDAY




                                 Professor Danshera Cords, Capital University
                                 Law School, Columbus, OH; Carol
                                 Nachman, Special Counsel (Procedure &
                                 Administration), Office of Chief Counsel,
                                 IRS, Washington, DC.

                  2:10pm         Choice of Forum. What forum your client
                                 should choose is as much a function of
                                 procedure as it is precedent within the forum.
                                 This panel will discuss the differences in
                                 discovery, pleadings, type of relief afforded,
                                 precedent, the litigating positions of Chief
                                 Counsel attorneys versus Department of
                                 Justice attorneys, and the role of judges in the
                                 settlement process in the US Tax Court, US
                                 District Court and US Court of Federal

       14
                       THURSDAY, JANUARY 18
                     Claims. Moderator: Brian Trauman, Mayer
                     Brown Rowe & Maw LLP, New York, NY.
                     Panelists: Juan F. Vasquez, Chamberlain
                     Hrdlicka White Williams & Martin, Houston,
                     TX; Edward Froelich, Morrison & Foerster
                     LLP, Washington DC; Professor Keith Blair,
                     University of Baltimore School of Law,
                     Baltimore, MD.
Please note: Breakout sessions will run from 3:50pm - 4:50pm. See
below for descriptions.

       5:00pm       Mock Trial of a Claim for Refund in US
                    District Court. This session will focus on
                    litigating an Earned Income Tax Credit frozen
                    refund claim. Panelists: Professor Keith Blair,
                    University of Baltimore School of Law,
                    Baltimore MD; Claudia Hill, Tax Mam Inc,
                    Cupertino, CA.

3:50PM - 4:50PM
LOW INCOME TAXPAYER CLINIC WORKSHOP
BREAKOUT SESSIONS
Procedural Issues.        Diplomat 2, 1st Floor, Convention Ctr
This session will provide a practical guide on how to navigate
through scheduling orders, motions and the rules regarding
student practice before the US Tax Court, US District Court and
US Court of Federal Claims. Moderator: Lena Amanti, McKee
Nelson LLP, Washington, DC.
Claims for Damages         Diplomat 4, 1st Floor, Convention Ctr
Against the IRS.
                                                                      THURSDAY




This session will provide a guide to analyzing and pleading claims
under IRC section 7433, Civil Damages for Certain Unauthorized
Collection Actions, and IRC section 7430, award of attorneys’ fees.
Moderator: Professor Steve Johnson, University of Nevada, Las
Vegas School of Law, Las Vegas, NV. Panelist: Blaise Dusenberry,
Special Counsel (Administrative Provisions & Judicial Practice),
Office of Chief Counsel IRS, Washington, DC.
Trust Fund Penalties. Diplomat 5, 1st Floor, Convention Ctr
This session will provide a guide to litigating the imposition of
trust fund recovery penalties, including trial strategies and
discovery plans. Moderator/Panelist: Professor Jerry Borison,
University of Denver School of Law, Denver, CO. Panelist:
Elizabeth Davis, Trial Attorney, Department of Justice,
Washington, DC.



                                                                 15
       THURSDAY, JANUARY 18
           6:15PM                         Diplomat 2, 1st Floor, Convention Ctr
           LOW INCOME TAXPAYER CLINIC WORKSHOP
           RECEPTION CLE
           6:30PM - 10:00PM                            Chef Allen’s Restaurant
           ADMINISTRATIVE PRACTICE DINNER CLE (Invitation Only)
           6:30PM - 9:30PM                                       Giorgio’s Grill
           PARTNERSHIPS & LLCs AND REAL ESTATE DINNER
              CLE (Reservations Required)
           Members of the Real Estate Committee and the Partnerships &
           LLCs Committee will meet for cocktails and dinner at Giorgio’s
           Grill, just a short cab ride from the Westin Diplomat
           (www.giorgiosgrill.com). Cocktails will begin at 6:30pm, followed
           by dinner at 7:30pm. Reservations and advance payment required.
           6:30PM - 10:00PM
           STATE AND LOCAL TAXES CASH BAR AND
           EXECUTIVE BUSINESS MEETING DINNER CLE
           (Executive Session)
THURSDAY




       16
                      FRIDAY, JANUARY 19 - AM
7:00AM - 7:30AM                           Room 307, 2nd Floor, Hotel
YOUNG LAWYERS ORIENTATION                        CLE

7:15AM - 8:30AM                  Grand East, 1st Floor, Convention Ctr
SECTION BREAKFAST/PLENARY SESSION                            CLE
(Ticketed Event; Tickets not available onsite)
Susan P. Serota, Section Chair, Presiding
       Chair’s Report to the Section
       Susan P. Serota, Section Chair

       Adoption of Consent Calendar
       Bylaw Amendments

       Certificate Presentation
       2006 - 2007 John S. Nolan Tax Law Fellows

       Announcement
       2007 - 2008 John S. Nolan Tax Law Fellows

       Award Presentation
       2007 Pro Bono Award
       Recipient: Professor Leslie M. Book, Director, Federal Tax
       Clinic, Villanova University School of Law, Villanova, PA

       Keynote Speaker
       Mark W. Everson, Commissioner, IRS, Washington, DC

7:30AM - 8:30AM                            Room 220, 1st Floor, Hotel
EXEMPT ORGANIZATIONS SUBCOMMITTEE ON
AUDITS AND APPEALS
Chairs: Marcus S. Owens, Caplin & Drysdale Chartered,
Washington, DC; Robert Louthian, McDermott Will & Emery
LLP, Washington, DC
The subcommittee will discuss recent developments in exempt
organization examinations, including compensation and political
activity projects. Panelists: Marcus S. Owens. Caplin & Drysdale
                                                                         AM
Chartered, Washington, DC; Robert Louthian, McDermott Will
& Emery LLP, Washington, DC.
                                                                         FRIDAY




                                                                    17
     FRIDAY, JANUARY 19 - AM
         7:30AM - 8:30AM                         Room 301, 2nd Floor, Hotel
         EXEMPT ORGANIZATIONS SUBCOMMITTEE ON
         HEALTH-CARE ORGANIZATIONS
         Chairs: Christopher M. Jedrey, McDermott Will & Emery LLP,
         Boston, MA; T.J. Sullivan, Gardner Carton & Douglas LLP,
         Washington, DC
         The subcommittee will discuss recent developments in health-care.
         Panelists: Christopher M. Jedrey, McDermott Will & Emery LLP,
         Boston, MA; T.J. Sullivan, Gardner Carton & Douglas LLP,
         Washington, DC.
         7:30AM - 8:30AM                          Room 314, 2nd Floor, Hotel
         EXEMPT ORGANIZATIONS SUBCOMMITTEE ON
         PRIVATE FOUNDATIONS, UNRELATED BUSINESS
         INCOME, AND INTERNATIONAL PHILANTHROPY
         Chairs: Paul H. Feinberg, Baker & Hostetler LLP, Cleveland, OH;
         Lisa L. Johnsen, Preston Gates & Ellis LLP, Seattle, WA; Laura
         Kalick, Exempt Organization Tax Consulting, Chevy Chase, MD;
         Robert A. Wexler, Silk Adler & Colvin, San Francisco, CA; Victoria
         B. Bjorklund, Simpson Thacher & Bartlett, New York, NY; Betsy
         Buchalter Adler, Silk Adler & Colvin, San Francisco, CA
                Private Foundations Update
                Speakers:   Lisa L. Johnsen, Preston Gates & Ellis LLP,
                            Seattle, WA; Paul H. Feinberg, Baker &
                            Hostetler LLP, Cleveland, OH.

                Briefing on Recent UBIT Private Letter Rulings
                Speakers:   Laura Kalick, Exempt Organization Tax
                            Consulting, Chevy Chase, MD.

                International Philanthropy Update
                Speakers:    Victoria B. Bjorklund, Simpson Thacher &
                             Bartlett, New York, NY; Betsy Buchalter Adler,
                             Silk Adler & Colvin, San Francisco, CA.

         8:00AM - 9:00AM                 Satine Restaurant, Lobby Level, Hotel
AM
         COMPANIONS’ BREAKFAST              CLE (Complimentary)
FRIDAY




     18
                   FRIDAY, JANUARY 19 - AM
8:30AM - 11:30AM                Atlantic 1, 1st Floor, Convention Ctr
ADMINISTRATIVE PRACTICE
Chair: Thomas J. Callahan, Thompson Hine LLP, Cleveland, OH
      8:30am      Opening Remarks by the Chair.        CLE


      8:35am      Important Developments. This panel will
                  discuss important developments in
                  administrative practice that have occurred
                  since the 2006 Joint Fall CLE Meeting.
                  Moderator: Jamie Hartford, Ernst & Young
                  LLP, Washington, DC. Panelists: Rochelle
                  Hodes, PricewaterhouseCoopers LLP,
                  Washington, DC; Deborah A. Butler,
                  Associate Chief Counsel (Procedure &
                  Administration), IRS, Washington, DC.

      9:00am      Impact of FIN 48 Disclosures on IRS
                  Examinations and Administrative Practice.
                  This panel will discuss the implications of the
                  recent FASB disclosure rules concerning
                  uncertain financial positions. Moderator: Sheri
                  Dillon, McKee Nelson LLP, Washington, DC.
                  Panelists: Robert D. Adams, Senior Advisor to
                  the Commissioner (LMSB), IRS, Washington
                  DC; Todd Simmens, Ernst & Young LLP,
                  Washington, DC.

      9:50am      Impact of Litigation on FOIA Responses
                  and Scope of Disclosure by IRS. This panel
                  will discuss how IRS Disclosure coordinates
                  with government litigation teams in
                  responding to FOIA requests, both under CC
                  Notice 2006-16 and otherwise, and how such
                  coordination can affect the level of disclosure.
                  Moderator: John Galotto, McKee Nelson LLP,
                  Washington, DC. Panelists: Charles                    AM
                  Christopher, Branch Chief (Disclosure &
                                                                        FRIDAY




                  Privacy Law), IRS, Washington, DC; Alan S.
                  Kline, Special Trial Attorney (LMSB), IRS,
                  New York, NY; Susan E. Seabrook, Latham &
                  Watkins LLP, Washington, DC.




                                                                  19
     FRIDAY, JANUARY 19 - AM
               10:40am      National Taxpayer Advocate Review:
                            Transparency of IRS. This panel will address
                            IRS transparency questions such as: Are IRS
                            personnel following procedures and guidance
                            that practitioners don’t know about? Is the
                            IRM that is available to the public different
                            from the IRM that IRS personnel are using?
                            Are some IRS personnel relying on legal
                            analysis that is not available to the public?
                            What is the IRS doing to improve its
                            transparency? Moderator: Nina E. Olson,
                            National Taxpayer Advocate, IRS,
                            Washington, DC. Panelists: Eric R. LoPresti,
                            Attorney Advisor to the National Taxpayer
                            Advocate, IRS, Washington, DC; Susan B.
                            Novotny, Director, Office of Servicewide
                            Policy Directives & Electronic Research, IRS,
                            Washington, DC; Christopher Bergin, Tax
                            Analysts, Falls Church, VA.

         8:30AM - 11:30AM                Atlantic 2, 1st Floor, Convention Ctr
         AFFILIATED AND RELATED CORPORATIONS
         Chair: Victor Penico, Deloitte Tax LLP, San Francisco, CA
               8:30am       Loss Disallowance and Loss Duplication
                            Regulations. Eagerly awaited regulations
                            revising the current loss disallowance and loss
                            duplication schemes are expected to be
                            proposed before the meeting. This panel will
                            provide a comprehensive overview of the
                            regulation package. (If the regulations are not
                            filed by the time of the meeting, an alternative
                            program will be presented.) Moderator: Victor
                            Penico, Deloitte Tax LLP, San Francisco, CA.
                            Panelists: Andrew Dubroff, Ernst & Young
                            LLP, Washington, DC; Jonathan Forrest,
AM                          Deloitte Tax LLP, Washington, DC; Theresa
                            Abell, Special Counsel to the Associate Chief
FRIDAY




                            Counsel (Corporate), IRS, Washington, DC;
                            Marc Countryman, Attorney Advisor, Office
                            of Tax Legislative Counsel, Department of
                            Treasury, Washington, DC.




     20
                   FRIDAY, JANUARY 19 - AM
      10:30am     Current Developments. This panel will
                  discuss recent consolidated return
                  developments. Moderator: Derek Cain,
                  PricewaterhouseCoopers LLP, Washington,
                  DC. Panelists: Mark Schneider, Deputy
                  Associate Chief Counsel (Corporate), IRS,
                  Washington, DC.

8:30AM - 11:30AM               Atlantic 3, 1st Floor, Convention Ctr
BANKING AND SAVINGS INSTITUTIONS
Chair: John Ensminger, Law Offices of John Ensminger, New
York, NY
      8:30am      Industry Overview and Audit/Litigation
                  Issues. This session will provide an overview
                  of the financial institutions industry and, in
                  particular, will discuss recent tax controversy
                  developments affecting the industry.
                  Moderator: Michelle M. Henkel, Alston &
                  Bird LLP, Atlanta, GA. Panelist: Barry Shott,
                  Industry Director, Financial Services, IRS,
                  Washington, DC.

      9:30am      Recent Regulatory Developments. This
                  panel will discuss regulatory and other
                  Department of Treasury and IRS
                  pronouncements, and significant case law
                  developments preceding the session.
                  Moderator: Hayden Brown, Mayer Brown
                  Rowe & Maw LLP, Charlotte, NC. Panelists:
                  Bethany Ingwalson, Attorney-Advisor, Office
                  of the Associate Chief Counsel, IRS,
                  Washington, DC; Michael Novey, Associate
                  Tax Legislative Counsel, Department of
                  Treasury, Washington, DC.

      10:30am     FASB Developments. This session will discuss         AM
                  the final guidance issued by FASB on
                                                                       FRIDAY




                  Accounting for Income Taxes (FIN 48) and
                  Accounting for Leases (FAS 13), with an
                  emphasis on the implications to financial
                  institutions. Moderator: Kenneth W. Busey,
                  PricewaterhouseCoopers LLP, Washington,
                  DC. Panelist: Charles M. Wheeler, Alston &
                  Bird LLP, Washington, DC.




                                                                 21
     FRIDAY, JANUARY 19 - AM
         8:30AM - 11:30AM               Diplomat 3, 1st Floor, Convention Ctr
         CLOSELY HELD BUSINESSES AND
         STATE & LOCAL TAXES
         Closely Held Businesses Chair: John O. Tannenbaum, Law Offices
         of John O. Tannenbaum, Hartford, CT
         State & Local Taxes Chair: Stephanie Lipinski Galland, Thompson
         Coburn LLP, Washington, DC
               8:30am       Opening Remarks.     CLE


               8:35am       Nexus - The Power of States to Tax Out of
                            State Businesses and Nonresident Business
                            Owners. This panel will discuss when an
                            expanding closely held business and its owners
                            will become subject to tax in additional states.
                            Moderator: Rick Handel, Senior Administrator
                            and General Counsel for Policy, South
                            Carolina Department of Revenue, Columbia,
                            SC. Panelists: C. Eric Fader, Horwood Marcus
                            & Berk Chartered, Chicago, IL; Shirley K.
                            Sicilian, General Counsel, Multistate Tax
                            Commission, Washington, DC.

               9:20am       Sourcing and Apportionment of Tax Items
                            Related to Pass Through Entities. This panel
                            will discuss how states treat flow through
                            entities and their owners. This discussion will
                            focus on when and how income, credits and
                            apportionment factors pass through the
                            entities to their owners. In addition, the panel
                            will analyze the impact of unitary relationships
                            on the apportionment or allocation of flow
                            through entity income. Moderator: Jordan M.
                            Goodman, Horwood Marcus & Berk
                            Chartered, Chicago, IL. Panelists: Michael T.
                            Donovan, Baker & McKenzie LLP, Chicago,
AM                          IL; Bruce Ely, Bradley Arant Rose & White
                            LLP, Birmingham AL.
FRIDAY




     22
                    FRIDAY, JANUARY 19 - AM
      10:15am      Other State Tax Issues Affecting Expansion
                   into Other States. This panel will explore
                   other state tax issues involved in structuring a
                   business expanding to multistate operations,
                   including transfer tax aspects of entity
                   formations, reorganizations, and dissolutions.
                   Moderator: Robert Joe Hull, Bracewell &
                   Giuliani LLP, Houston, TX. Panelists: John R.
                   Shaughnessy Jr, Robinson & Cole LLP,
                   Hartford, CT; Stewart Weintraub, Schnader
                   Harrison Segal & Lewis LLP, Philadelphia, PA.

8:30AM - 11:30AM                Diplomat 1, 1st Floor, Convention Ctr
ESTATE AND GIFT TAXES
Chair: John F. Bergner, Winstead Sechrest & Minick PC, Dallas, TX
      8:30am       Opening Remarks by the Chair.       CLE


      8:35am       Current Developments. This panel will
                   discuss recent developments in estate and gift
                   tax planning and administration. Speakers: Eric
                   Carter, Giordani Schurig Beckett & Tackett
                   LLP, Austin, TX; Stacey Delich-Gould,
                   Sullivan and Cromwell LLP, New York, NY;
                   Catherine V. Hughes, Estate and Gift Tax
                   Attorney Advisor, Office of Tax Policy,
                   Department of Treasury, Washington, DC.

      9:00am       Relationship Dissolution Planning. This
                   speaker will discuss planning and drafting
                   issues related to dissolution of marriage and
                   domestic partner relationships. This will
                   include prenuptial and postnuptial agreements
                   and issues related to the transfer and re-titling
                   of assets in contemplation of a relationship
                   dissolution. Speaker: Elaine Bucher, Proskauer
                   Rose LLP, Boca Raton, FL.                            AM
                                                                        FRIDAY




      9:35am       Utilization of Defined Valuation
                   Adjustment Clauses. This presentation will
                   discuss the kinds of clauses available, how the
                   IRS reacts to them and their effectiveness.
                   Speaker: Ronald D. Aucutt, McGuireWoods,
                   McLean, VA.




                                                                 23
     FRIDAY, JANUARY 19 - AM
               10:15am      Common Estate Tax Audit Triggers and
                            How to Avoid Them. This presentation will
                            review and analyze ten important Federal
                            Estate Tax Return audit issues (excluding
                            limited partnership issues) and discuss
                            techniques to minimize a taxpayer’s exposure.
                            Speaker: Jill Miller, Jill Miller & Associates
                            PC, New York, NY.

               10:55am      Intellectual Property Rights In Estate Tax
                            Strategies. Attorneys are patenting and trade
                            marking estate and tax planning techniques.
                            This presentation will analyze the efficacy of
                            these patents and trademarks and how attorneys
                            can minimize the risk of infringement. Speaker:
                            William C. Weinsheimer, Foley & Lardner LLP     ,
                            Chicago, IL.

         8:30AM - 10:30AM                Regency 3, 1st Floor, Convention Ctr
         FOREIGN ACTIVITIES OF US TAXPAYERS
         Chair: Giovanna Sparagna, Sutherland Asbill & Brennan LLP,
         Washington, DC
               8:30am       Opening Remarks by the Chair.       CLE


               8:35am       Important Current Issues under Subpart F.
                            This panel will provide a detailed analysis of
                            Subpart F, including an examination of the
                            practical application of the “look-through”
                            rule under section 954(c)(6), and a discussion
                            of the proposed regulations under sections
                            959 and 961. Moderators: Carol Tello,
                            Sutherland Asbill & Brennan LLP,
                            Washington, DC; Lowell Yoder, McDermott
                            Will & Emery LLP, Chicago, IL. Panelists:
                            Camille Evans, Special Counsel, Office of
AM                          Associate Chief Counsel (International), IRS,
                            Washington, DC; John Harrington, Deputy
FRIDAY




                            International Tax Counsel, Department of
                            Treasury, Washington, DC.

               9:35am       Emerging International Merger and
                            Acquisition Issues. This panel will discuss
                            current guidance regarding international tax-
                            free mergers and acquisition transactions
                            including the transfer of intangibles, the
                            treatment of cross-border cash “D”
                            reorganizations and significant issues with

     24
                    FRIDAY, JANUARY 19 - AM
                   respect to gain recognition agreements.
                   Moderator: Nardi Bress, Pricewaterhouse
                                ,
                   Coopers LLP Washington, DC. Panelists: Joe
                                                  ,
                   Calliano, Grant Thornton LLP Washington,
                   DC; Danielle E. Rolfes, Ivins Phillips & Barker
                   Chartered, Washington, DC; Hal Hicks,
                   International Tax Counsel, Department of
                   Treasury, Washington, DC; Michael DiFronzo,
                   Office of the Associate Chief Counsel
                   (International), IRS, Washington, DC.

8:30AM - 11:30AM               Diplomat 4, 1st Floor, Convention Ctr
FORMATION OF TAX POLICY
Chair: Jonathan Talisman, Capitol Tax Partners, Washington, DC
      8:30am       Opening Remarks by the Chair.       CLE


      8:40am       Tax Agenda in the 110th Congress.

      9:40am       Current Developments at the Department
                   of Treasury. Speaker: Michael J. Desmond,
                   Tax Legislative Counsel, Department of
                   Treasury, Washington, DC.

8:30AM - 11:30AM            Great Hall 5, 2nd Floor, Convention Ctr
PARTNERSHIPS & LLCs
Chair: James E. Wreggelsworth, Davis Wright Tremaine LLP,
Seattle, WA
      8:30am       Opening Remarks by the Chair.       CLE


      8:35am       Patenting Tax Advice - Potential
                   Ramifications on Subchapter K. This panel
                   will discuss the recent phenomenon of
                   patenting tax advice. Will this phenomenon
                   expand broadly into partnership structural tax
                   planning, section 704(c) methods, or section
                   704(b) allocations? How might a patent affect       AM
                   our daily practice? Moderator: Blake D.
                                                                       FRIDAY




                   Rubin, Arnold & Porter LLP, Washington,
                   DC. Panelists: Michael J. Desmond, Tax
                   Legislative Counsel, Office of Assistant
                   Secretary for Tax Policy, Department of
                   Treasury, Washington, DC; Professor Michael
                   B. Lang, Chapman University School of Law,
                   Orange, CA; Professor Ellen P. Aprill, Loyola
                   Law School, Los Angeles, CA.



                                                                25
     FRIDAY, JANUARY 19 - AM
          9:25am    Castle Harbour - Who Is A Partner? In
                    August 2006 the Second Circuit ruled in
                    Castle Harbour that a foreign bank with
                    limited residual sharing was not a tax partner.
                    This panel will discuss whether Castle
                    Harbour should make every 99:1 partnership
                    rethink its status as a partnership for federal
                    income tax purposes, or if the case should be
                    read in a more limited fashion. How should
                    taxpayers determine when 1% is enough and
                    when it is not? Moderator: Richard M. Lipton,
                    Baker & McKenzie LLP, Chicago IL.
                    Panelists: N. Jerold Cohen, Sutherland Asbill
                    & Brennan LLP, Atlanta, GA; Heather C.
                    Maloy, Skadden Arps Slate Meagher & Flom
                    LLP, Washington, DC.

          10:05am   Permanent Capital Funds: The Next Wave
                    in Private Equity. Many hedge funds and
                    private equity funds are racing to establish
                    permanent capital vehicles. The issues
                    associated with establishing such vehicles
                    range from choice of entity to choice of
                    jurisdiction and related formation, operating,
                    and compliance issues, both tax and non-tax.
                    This panel will highlight some of the more
                    significant issues and will discuss the more
                    recent transactions. Moderator: Stanley E.
                    Ramsay, Weil Gotshal & Manges LLP, New
                    York, NY. Panelists: Eric Sloan, Deloitte Tax
                    LLP, New York, NY; Dana L. Trier, Davis Polk
                    & Wardwell, New York, NY.

          10:55am   Hot Topics in Partnerships. This panel will
                    discuss recent developments affecting
                    partnerships including legislation, regulations,
AM
                    administrative guidance and noteworthy cases.
FRIDAY




                    Moderator: William H. Caudill, Fulbright &
                    Jaworski LLP, Houston, TX. Panelists: Curtis
                    G. Wilson, Deputy Associate Chief Counsel
                    (Passthroughs & Special Industries), Office of
                    Chief Counsel, IRS, Washington, DC; R.
                    Brent Clifton, Locke Liddell & Sapp LLP,
                    Dallas, TX.




     26
                       FRIDAY, JANUARY 19 - AM
8:30AM - 5:30PM                           Room 205, 1st Floor, Hotel
VOLUNTEER INCOME TAX (VITA) ON-SITE
TRAINING CLE
See p. 5 for further details.
8:45AM - 10:30AM                          Room 314, 2nd Floor, Hotel
EMPLOYEE BENEFITS ADMINISTRATIVE PRACTICES
UPDATE, Presented by the Self-Corrections & Other
Administrative Practices Subcommittee, the Subcommittee on
Master, Prototype, and Volume Submitter Plans and
Determination Letter Task Force
Chairs: Martha L. Hutzelman, Kruchko and Fries, McLean, VA;
Joy M. Mercer, Joy M. Mercer PC, Florham Park, NJ; Lisa
Tavares, Venable LLP, Washington, DC
The subcommittees will discuss the latest generation of EPCRS
and the staggered remedial amendment period process.
8:45AM - 10:30AM                         Room 307, 2nd Floor, Hotel
EMPLOYEE BENEFITS EXECUTIVE COMPENSATION
AND SECURITIES LAW UPDATE, Presented by the
Subcommittee on Executive Compensation and the Subcommittee
on Federal Securities Laws Issues
Chairs: Wayne R. Luepker, Mayer Brown Rowe & Maw LLP,
Chicago, IL; Althea R. Day, Morgan Lewis & Bockius LLP,
Washington, DC; Susan J. Daley, Perkins Coie LLP, Chicago, IL;
Gail W. Stewart, Baker Botts LLP, Houston, TX
The subcommittees will discuss issues on executive compensation
disclosure, recent litigation and enforcement initiatives and other
developments in executive compensation and securities law.
8:45AM - 10:30AM                         Room 301, 2nd Floor, Hotel
EMPLOYEE BENEFITS WELFARE PLANS, HIPAA AND
VEBA UPDATE, Presented by the Subcommittee on COBRA
and Welfare Plan Design Issues, the Subcommittee on HIPAA, the
Subcommittee on State Insurance Regulation of Welfare Plans, the
Subcommittee on Cafeteria Plans and Flexible Benefits, and the
Subcommittee on Retiree Health, VEBAs and Other Funding                AM
Vehicles
                                                                       FRIDAY




Chairs: Alden J. Bianchi, Mintz Levin Cohn Ferris Glovsky and
Popeo PC, Boston, MA; Phyllis C. Borzi, O’Donoghue &
O’Donoghue, Washington, DC; Nancy K. Campbell, Snell &
Wilmer LLP, Phoenix, AZ; Riva T. Johnson, Morgan Lewis &
Bockius LLP, Dallas, TX; Frank Palmieri, Palmieri & Eisenberg,
Princeton, NJ; Mark L. Stember, Kilpatrick Stockton LLP,
Washington, DC; George L. Whitfield, Warner Norcross & Judd
LLP, Grand Rapids, MI



                                                                  27
     FRIDAY, JANUARY 19 - AM
         The subcommittees will discuss recent regulatory and legislative
         developments for health and welfare plans, including the
         application of section 409A to discriminatory health benefits (if
         final regulations are issued), HIPAA nondiscrimination regulations
         (if issued) and the new proposed cafeteria plan regulations (if
         issued) and recent developments in health savings accounts and
         state insurance law.
         8:45AM - 4:30PM                 Regency 2, 1st Floor, Convention Ctr
         EXEMPT ORGANIZATIONS
         Chair: LaVerne Woods, Davis Wright Tremaine LLP, Seattle, WA
                8:45am       Committee Business by the Chair.     CLE


                9:00am       News from the IRS and Department of
                             Treasury. Representatives from the TE/GE
                             Division of IRS and from the Department of
                             Treasury will speak on recent developments
                             and pending guidance. Moderator: Betsy
                             Buchalter Adler, Silk Adler & Colvin, San
                             Francisco, CA. Panelists: Robert S. Choi,
                             Acting Director (Rulings & Agreements),
                             IRS, Washington, DC; Catherine E.
                             Livingston, Assistant Chief Counsel, TE/GE,
                             IRS, Washington, DC; Eric San Juan, Deputy
                             Tax Legislative Counsel (Legislative Affairs),
                             Department of Treasury, Washington, DC.

                10:00am      Donor Advised Funds After the Pension
                             Protection Act of 2006: Still an Attractive
                             Option for Charitable Giving? Legislation in
                             2006 substantially altered the rules under
                             which charities that hold donor advised funds
                             must operate. This panel will examine the
                             changes and consider practical ways to address
                             them, and identify unresolved questions that
                             arise under the new law. Moderator: Frederick
AM                           J. Gerhart, Dechert LLP, Philadelphia, PA.
                             Panelists: Robert Fontenrose, Senior Tax Law
FRIDAY




                             Specialist, Exempt Organizations Division,
                             IRS, Washington, DC; Janne Gallagher,
                             Council on Foundations, Washington, DC;
                             Rochelle Korman, Patterson Belknap Webb &
                             Tyler LLP, New York, NY; Catherine E.
                             Livingston, Assistant Chief Counsel, TE/GE,
                             IRS, Washington, DC.



     28
          FRIDAY, JANUARY 19 - AM
11:00am   Supporting Organizations After the Pension
          Protection Act of 2006: A Second Class of
          Public Charity? The changes to the
          supporting organization rules — new
          categories, new prohibitions, new rules for
          foundations making grants to supporting
          organizations — are among the most
          significant provisions for charities in the 2006
          legislation. This panel will consider how to
          plan and to avoid traps for the unwary under
          the new regime. Moderator: Paul Feinberg,
          Baker & Hostetler LLP, Cleveland, OH.
          Panelists: Robert Fontenrose, Senior Tax Law
          Specialist, Exempt Organizations Division,
          IRS, Washington, DC; Raeburn G. Kennard,
          Kirton & McConkie, Salt Lake City, UT;
          Catherine E. Livingston, Assistant Chief
          Counsel, TE/GE, IRS, Washington, DC; M.
          Ruth M. Madrigal, Caplin & Drysdale
          Chartered, Washington, DC.

12:15pm   Luncheon CLE (Ticketed Event)
          Speaker: Nina E. Olson, National Taxpayer
          Advocate, IRS, Washington, DC
          Topic: Exempt Organization Issues: The
          National Taxpayer Advocate’s Perspective

1:30pm    Community Benefit for Healthcare
          Organizations: What Is It, and How Do We
          Measure It? This panel will discuss the IRS’s
          community benefit checklist initiative and
          provide an update on Senate Finance
          Committee, state and litigation settlement
          activities. Moderator: Christopher M. Jedrey,
          McDermott Will & Emery LLP, Boston, MA.
          Panelists: Anne M. Murphy, Senior Counsel to
                                                             AM
          the Attorney General, Office of Illinois
                                                             FRIDAY




          Attorney General Lisa Madigan, Chicago, IL;
          T.J. Sullivan, Drinker Biddle & Reath LLP,
          Washington, DC; Julie Trocchio, The Catholic
          Health Association, Washington, DC.




                                                       29
     FRIDAY, JANUARY 19 - AM
               2:15pm       Social Enterprise - A Legal Context. Who
                            are social entrepreneurs, and what is social
                            enterprise? And how can we as exempt
                            organizations attorneys help them achieve
                            their goals? Moderator: Robert A. Wexler, Silk
                            Adler & Colvin, San Francisco, CA. Panelists:
                            Ed Diener, Skoll Foundation, Palo Alto, CA;
                            Lisa L. Johnsen, Preston Gates & Ellis LLP,
                            Seattle, WA.

               3:15pm       Changes in the Form 990: In a Relationship
                            or Just Friends? Are your clients capturing the
                            information needed to answer the new
                            questions on the annual information return?
                            How do you define “relationship”? This panel
                            will take an intimate look at the Form 990.
                            Moderator: Eve Borenstein, Borenstein and
                            McVeigh Law Office, Minneapolis, MN.
                            Panelists: Janet E. Gitterman, Senior Tax Law
                            Specialist, 990 Project, IRS, Washington, DC;
                            Ralph E. DeJong, McDermott Will & Emery
                            LLP, Chicago, IL.

               4:15pm       Cash Bar   CLE


         8:45AM - 11:45AM               Diplomat 5, 1st Floor, Convention Ctr
         INDIVIDUAL AND FAMILY TAXATION
         Chair: Professor Roberta F. Mann, Widener University School of
         Law, Wilmington, DE
               8:45am       Opening Remarks by the Chair.       CLE


               8:50am       Will You Still Need Me: Income Tax Issues
                            of Elderly Clients. Elderly clients present
                            many income tax issues, from long-term care
                            insurance to planned giving. This panel will
                            explore selected issues. Moderator: Professor
AM
                            Roberta F. Mann, Widener University School
FRIDAY




                            of Law, Wilmington, DE. Panelists: Nina
                            Olson, National Taxpayer Advocate, IRS,
                            Washington, DC; David L. Rice, David Lee
                            Rice PLC, Torrance, CA; Amy Zipper,
                            Gunster Yoakley & Stewart PA, Ft.
                            Lauderdale, FL.




     30
                      FRIDAY, JANUARY 19 - AM
       10:15am        The Effect of Murphy on Section 104
                      Deductions. On August 22, the DC
                      Circuit Court of Appeals held, in Murphy v.
                      IRS, that section 104 was unconstitutional
                      insofar as it failed to exclude from income an
                      award of damages for emotional distress and
                      loss of reputation when there was no physical
                      injury present. This panel will (a) review the
                      basics of the section 104(a)(2) exclusion for
                      damages “on account of personal physical
                      illness or physical sickness”; (b) examine the
                      state of the section 104 doctrines potentially
                      affected by Murphy; and (c) consider what
                      positions a practitioner may take to be
                      consistent with Circular 230 and legal ethics.
                      Moderator: Professor Bryan T. Camp, Texas
                      Tech University School of Law, Lubbock, TX.
                      Panelists: GJ Stillson MacDonnell, Littler
                      Mendelson, San Francisco, CA; Professor
                      Christopher M. Pietruszkiewicz, Paul M.
                      Hebert Law Center, Louisiana State University,
                      Baton Rouge, LA; William Weissman, Littler
                      Mendelson, San Francisco, CA.

9:00AM - 3:00PM
COMPANIONS’ TOUR AND LUNCHEON CLE (Ticketed Event)
Women’s Heritage Trail Tour & Lunch
Buses will depart promptly at 9:00am from the Convention Center
lower lobby.
See p. 7 for a full description.
9:00AM - 10:00AM                          Room 312, 2nd Floor, Hotel
EMPLOYEE BENEFITS ESOP UPDATE, Presented by the
Subcommittee on ESOPs
                                                   ,
Chair: Gregory K. Brown, Katten Muchin Rosenmen LLP Chicago, IL
This session will discuss recent legislative changes, recent employer AM
stock fiduciary cases, and recent IRS and Department of Labor
                                                                       FRIDAY




rulings and interpretations.




                                                                 31
     FRIDAY, JANUARY 19 - AM
         9:00AM - 12:00PM                    Room 212 - 214, 1st Floor, Hotel
         YOUNG LAWYERS FORUM - 2006 LAW STUDENT
         TAX CHALLENGE    CLE
         Semi-Final Rounds (Open to the Public)
         Three law student teams and two LLM teams will meet with the
         “client” as represented by the judging panel. There will be two
         panels, one judging the law student teams and the other judging
         the LLM teams. The “client” issues the final round scores based on
         presentation, team work and technical skills.
         9:30AM - 12:30PM                Diplomat 2, 1st Floor, Convention Ctr
         INVESTMENT COMPANIES
         Chair: Cathy Heron, Capital Research and Management
         Company, Los Angeles, CA
                9:30am       Opening Remarks by the Chair.       CLE


                9:35am       RIC Preferential Dividends and Mergers
                             Update. This panel will discuss recent
                             developments relating to mutual fund
                             preferential dividends and mergers.
                             Moderator: Raj Tanden, Morrison & Foerster
                             LLP, Los Angeles, CA. Panelists: William
                             Zimmerman, Morgan Lewis & Bockius LLP,
                             Philadelphia, PA; Theodore Press, Kirkpatrick
                             & Lockhart Nicholson Graham LLP,
                             Washington, DC.

                10:30am      Legislative Update and Current
                             Developments for RICs. This panel will
                             discuss recent developments in the RIC area,
                             including legislative proposals to require cost
                             basis reporting. Moderator: Deanna Flores,
                             Vanguard, Valley Forge, PA. Panelists: Michael
                             Novey, Associate Tax Legislative Counsel,
                             Office of Tax Policy, Department of Treasury,
AM                           Washington, DC; Keith Lawson, Investment
                             Company Institute, Washington, DC.
FRIDAY




                11:30am      Hedge Fund Developments. This panel will
                             discuss recent hedge fund developments,
                             including IRS audit activity and deferred
                             compensation for hedge fund managers.
                             Moderator: Ronald Cohn, Ernst & Young LLP,
                             San Francisco, CA. Panelist: Greg Nowak,
                             Pepper Hamilton LLP, Philadelphia, PA.



     32
                     FRIDAY, JANUARY 19 - AM
10:30AM - 12:15PM                      Room 303, 2nd Floor, Hotel
EMPLOYEE BENEFITS FIDUCIARY RESPONSIBILITY
AND LITIGATION UPDATE, Presented by the Subcommittee
on Fiduciary Responsibility, the Subcommittee on Litigation and
the Subcommittee on ESOPs
Chairs: Gregory K. Brown, Katten Muchin Rosenmen LLP,
Chicago, IL; Susan Katz Hoffman, Littler Mendelson PC,
Philadelphia, PA; Andrew Oringer, Clifford Chance US LLP, New
York, NY; Robert F. Pizzo, Law Office of Robert F. Pizzo,
Rochester, NY; John Utz, Utz Miller & Kuhn LLC, Overland
Park, KS
The Subcommittees will meet to review cases and legislative and
regulatory developments of current interest.
10:30AM - 12:15PM                      Room 307, 2nd Floor, Hotel
EMPLOYEE BENEFITS 401(k) UPDATE, Presented by the
Subcommittee on Qualified Cash or Deferred Arrangements
Chairs: Leonard S. Hirsh, Ernst & Young LLP, New York, NY;
Bernard F. O’Hare, Patterson Belknap Webb & Tyler LLP, New
York, NY
The Subcommittee will examine the most recent regulatory activity
with respect to automatic enrollment, including discussion of IRS
and Department of Labor recent and pending guidance. Issues
under the Pension Protection Act and Roth 401(k)s will be
discussed. There will be an informed dialogue with invited
government guests regarding these and other section 401(k) issues.
Speaker: Erin Sweeney, Pension Law Specialist, Employee Benefit
Security Administration, Department of Labor, Washington, DC.
10:30AM - 12:15PM                       Room 312, 2nd Floor, Hotel
EMPLOYEE BENEFITS IRA UPDATE, Presented by the
Subcommittee on IRAs
Chairs: Adam B. Cohen, Sutherland Asbill & Brennan LLP,
Washington, DC; David N. Levine, Groom Law Group
Chartered, Washington, DC
The subcommittee will discuss IRA changes made by the Pension        AM
Protection Act, including technical issues and any IRS guidance;
                                                                     FRIDAY




other recent IRA developments; and whether comments from the
subcommittee to the IRS would be helpful in the areas of nonbank
custodian regulations, IRA disclosure regulations, and/or the IRA
opinion letter process.




                                                                  33
     FRIDAY, JANUARY 19 - AM
         10:30AM - 12:00PM                 Regency 3, 1st Floor, Convention Ctr
         JOINT SESSION OF FAUST, USAFTT, AND TRANSFER
         PRICING: IMPORTANT DEVELOPMENTS.
                                                         ,
         Moderator: Margie Rollinson, Ernst & Young LLP Washington, DC.
                                                               ,
         Panelists: Nicholas J. DeNovio, Latham & Watkins LLP Washington,
                                                ,
         DC; Gideon Alpert, Alston & Bird LLP New York, NY; Darrin
                                  ,
         Litsky, Deloitte Tax LLP New York, NY; Hal Hicks, International
         Tax Counsel, Department of Treasury, Washington, DC; Steven
         Musher, Associate Chief Counsel, Office of the Chief Counsel, IRS,
         Washington, DC.
         11:00AM - 12:00PM                         Room 301, 2nd Floor, Hotel
         IMPORTANT DEVELOPMENTS WORKSHOP                          CLE
         Mandatory meeting for Committee representatives responsible for
         preparing their Committee’s Annual Report on Important
         Developments.
         11:00AM - 1:00PM                           Room 317, 2nd Floor, Hotel
         TAX SHELTERS        CLE
         Chair: George C. Howell III, Hunton & Williams, Richmond, VA
         11:15AM - 12:15PM                        Room 302, 2nd Floor, Hotel
         EMPLOYEE BENEFITS FRINGE BENEFITS UPDATE,
         Presented by the Subcommittee on Fringe Benefits
         Chairs: Avery E. Neumark, Rosen Seymour Shapps Martin &
         Company, New York, NY; Christopher E. Condeluci, Groom Law
         Group Chartered, Washington, DC
         The subcommittee will provide an update on the latest guidance
         relating to fringe benefits under code section 132; discuss the IRS
         excessive compensation initiative focusing on the use of fringe
         benefits by tax-exempt organizations; and examine possible fringe
         benefit-related issues under code section 409A.
         11:15AM - 12:15PM                         Room 316, 2nd Floor, Hotel
         EMPLOYEE BENEFITS INTERNATIONAL UPDATE,
   Presented by the Subcommittee on Foreign and International
   Issues
AM Chair: Russell E. Hall, Towers Perrin, Valhalla, NY
         The session will focus on current issues in international benefits,
FRIDAY




         including the impact of final code section 409A regulations (if
         issued) and the final section 415 regulations (if issued) treatment
         of nonresident alien compensation.
         11:30AM - 12:30PM                           Room 219, 1st Floor, Hotel
         APPOINTMENTS TO THE TAX COURT                   CLE (Executive
         Session)
         Chair: W. Curtis Elliott Jr, Culp Elliot & Carpenter PLLC,
         Charlotte, NC


     34
                     FRIDAY, JANUARY 19 - PM
COMMITTEE LUNCHEONS                                                      PM
12:00PM - 1:30PM              Great Hall 1, 2nd Floor, Convention Ctr




                                                                         FRIDAY
CORPORATE TAX AND AFFILIATED AND RELATED
CORPORATIONS CLE (Ticketed Event)
12:00PM - 1:30PM               Grand West, 1st Floor, Convention Ctr
FAUST LUNCHEON/BUSINESS MEETING                     CLE
(Ticketed Event)
Speaker: Robert Dilworth, Senior Advisor, Office of Assistant
Secretary of Tax Policy, Department of Treasury, Washington, DC
Topic: International Tax Reform
12:15PM - 1:15PM               Regency 2, 1st Floor, Convention Ctr
EXEMPT ORGANIZATIONS             CLE (Ticketed Event)
Speaker: Nina E. Olson, National Taxpayer Advocate, IRS,
Washington, DC
Topic: Exempt Organization Issues: The National Taxpayer
Advocate’s Perspective
12:30PM - 1:30PM             Great Hall 5, 2nd Floor, Convention Ctr
ADMINISTRATIVE PRACTICE AND COURT
PROCEDURE & PRACTICE CLE (Ticketed Event)
Speaker: Donald L. Korb, Chief Counsel, IRS, Washington, DC
Topic: New TAM Procedures - Rev. Proc. 2007-2
12:30PM - 2:00PM             Great Hall 6, 2nd Floor, Convention Ctr
BANKING AND SAVINGS INSTITUTIONS, FINANCIAL
TRANSACTIONS, INSURANCE COMPANIES,
INVESTMENT COMPANIES, AND TAX EXEMPT
FINANCING CLE (Ticketed Event)
12:30PM - 1:30PM                         Room 318, 2nd Floor, Hotel
BUSINESS COOPERATIVES & AGRICULTURE                       CLE
(Ticketed Event)
12:30PM - 1:30PM                Diplomat 3, 1st Floor, Convention Ctr
CIVIL AND CRIMINAL TAX PENALTIES CLE (Ticketed
Event)
Sponsored by: Taggart and Hawkins, A Professional Corporation
12:30PM - 1:30PM                 Atlantic 3, 1st Floor, Convention Ctr
ESTATE & GIFT TAXES AND FIDUCIARY INCOME
TAX CLE (Ticketed Event)
                                                  ,
Speaker: W. Birch Douglas III, McGuire Woods LLP Richmond, VA
Topic: Gifts of Art and Other Tangibles After PPA 2006




                                                                   35
     FRIDAY, JANUARY 19 - PM
         12:30PM - 1:30PM
PM
         Transfer Pricing - Diplomat 4, 1st Floor, Convention Ctr
FRIDAY




         USAFTT - Diplomat 1, 1st Floor, Convention Ctr
         FLF, TRANSFER PRICING AND USAFTT BUSINESS
         LUNCHEONS CLE (Ticketed Event)
         Please Note: These luncheons will be separate business meetings,
         not a joint luncheon. Transfer Pricing, FAUST (starting at noon)
         and USAFTT will each host their own luncheon/business meeting
         and members of FLF are invited to attend any of the separate
         luncheons/business meetings. FLF will have its business meeting
         from 5:30pm - 6:30pm on Friday.
         The USAFTT luncheon will feature a discussion on recent treaty
         developments and will focus on the recently revised US-Germany
         and US-Belgium treaties. Speakers: Friedhelm Jacob, Hengeler
         Mueller, Frankfurt, Germany; Willem Bongaerts, Loyens & Loeff,
         London, England.
         12:30PM - 1:30PM                  Grand East, 1st Floor, Convention Ctr
         PARTNERSHIPS & LLCs AND REAL ESTATE                            CLE
         (Ticketed Event)
         Speaker: Clarissa C. Potter, Deputy Chief Counsel (Technical),
         Office of Chief Counsel, IRS, Washington, DC
         Sponsored by: Baker & McKenzie
         12:30PM - 1:00PM                     Regency 1, 1st Floor, Convention Ctr
         STATE AND LOCAL TAXES               CLE (Ticketed Event)
         12:00PM - 1:15PM                            Room 305, 2nd Floor, Hotel
         EMPLOYEE BENEFITS CONTINGENT WORKFORCE
         UPDATE, Presented by the Subcommittee on Employee &
         Independent Contractor Status and the Subcommittee on
         Controlled Groups, Affiliated Service Groups & Leased Employees
         Chairs: Peter J. Hunt, Pillsbury Winthrop Shaw Pittman LLP, New
         York, NY; Norman J. Misher, Roberts & Holland LLP, New York,
         NY; Daniel L. Morgan, Dickstein Shapiro LLP, Washington, DC
         This session will review recent court decisions and regulatory
         developments regarding worker classification and employee
         benefits for contingent workers.
         12:00PM - 1:00PM                            Room 320, 2nd Floor, Hotel
         MEMBERSHIP & MARKETING                    CLE
         Chair: Stuart M. Lewis, Buchanan Ingersoll & Rooney PC,
         Washington, DC
         12:00PM - 12:30PM                               Room 220, 1st Floor, Hotel
         STATE AND LOCAL TAXES SUBCOMMITTEE: STATE
         AND LOCAL TAX LAWYER CLE


     36
                      FRIDAY, JANUARY 19 - PM
12:15PM - 1:15PM                          Room 312, 2nd Floor, Hotel
                                                                         PM
EMPLOYEE BENEFITS CORPORATE COUNSEL




                                                                         FRIDAY
FORUM UPDATE, Presented by the Employee Benefits
Corporate Counsel Forum
Chair: Cheryl L. Harwick, Marathon Oil Company, Findlay, OH
12:15PM - 1:15PM                        Room 302, 2nd Floor, Hotel
EMPLOYEE BENEFITS ELECTRONIC
ADMINISTRATION UPDATE, Presented by the Task Force on
Electronic Plan Administration
Chair: Danny A. Martin Jr, Shell Oil Company, Houston, TX
The session will review the final Department of Treasury
regulations on use of electronic media for employee benefit notices,
elections and consents issued October 20, 2006.
1:00PM - 2:00PM                            Room 219, 1st Floor, Hotel
SPONSORSHIPS         CLE
Chair: Rudolph Ramelli, Jones Walker LLP, New Orleans, LA
1:00PM - 1:30PM                   Regency 1, 1st Floor, Convention Ctr
STATE AND LOCAL TAXES: A REVIEW OF CURRENT
STATE TAX DECISIONS
Moderator: Michael W. McLoughlin, Morrison & Foerster LLP,
New York, NY. Panelists: Paul H. Frankel, Morrison & Foerster
LLP, New York, NY; Arthur R. Rosen, McDermott Will & Emery
LLP, New York, NY
Topic: The Results and Repercussions of Two Recent Nexus Cases:
Lanco, Inc. v. Director and Steager v. MBNA America Bank.
1:00PM - 4:00PM                      Room 212 - 214, 1st Floor, Hotel
YOUNG LAWYERS FORUM - 2006 LAW STUDENT
TAX CHALLENGE    CLE
Final Rounds (Open to the Public)
1:15PM - 2:25PM                         Room 305, 2nd Floor, Hotel
EMPLOYEE BENEFITS DISTRIBUTIONS, QDROs AND
QMSCOs UPDATE, Presented by the Subcommittee on
Distributions, the Subcommittee on QDROs, QMSCOs and
Other Domestic Relations Benefits Issues and the Subcommittee
on Estate and Gift Tax Issues
Chairs: Joni L. Andrioff, Jones Day, Chicago, IL; Walter H.
Wingfield, Sutherland Asbill & Brennan LLP, Atlanta, GA; Mark
A. Bodron, Baker Botts LLP, Houston, TX; James C. Mulder,
Mulder Law Group PC, Houston, TX
The session will discuss IRS and Department of Labor regulatory
developments and recent decisions regarding qualified plan
distributions, along with other items of interest to those in
attendance.


                                                                   37
     FRIDAY, JANUARY 19 - PM
         1:15PM - 2:15PM                         Room 320, 2nd Floor, Hotel
PM
         EMPLOYEE BENEFITS EEOC, USERRA, MILITARY AND
         OTHER LEAVES UPDATE, Presented by the Subcommittee on
FRIDAY




         EEOC and FMLA Issues and the Subcommittee on USERRA,
         Military and Other Leaves
         Chairs: Thomas R. Standley, Marathon Oil Company, Findlay,
         OH; Thomas C. Graves, Stinson Morrison Hecker LLP, Kansas
         City, MO
         The program will focus on developments with the Erie County
         case as well as discussion on the impact of the US Supreme
         Court’s decision in Smith v. City of Jackson, 125 S. Ct. 1536
         (2005) on benefit plan litigation. The program will also discuss
         recent developments impacting individuals on military and other
         types of leaves.
         1:15PM - 2:25PM                          Room 317, 2nd Floor, Hotel
         EMPLOYEE BENEFITS GOVERNMENT AND TAX
         EXEMPT PLANS UPDATE, Presented by the Subcommittee on
         Government Plans, the Subcommittee on §457 Issues and the
         Subcommittee on §403(b) and EO Issues
         Chairs: Amy A. Null, WilmerHale, Boston, MA; Michael A.
         Laing, Taft Stettinius & Hollister LLP, Cincinnati, OH; Robert
         Abramowitz, Morgan Lewis & Bockius LLP, Philadelphia, PA
         The subcommittees will discuss recent guidance on 457 (f) plans
         (if issued) and on 403(b) plans (if issued).
         1:15PM - 2:25PM                         Room 303, 2nd Floor, Hotel
         EMPLOYEE BENEFITS MERGERS AND ACQUISITIONS
         UPDATE, Presented by the Subcommittee on Mergers and
         Acquisitions
         Chairs: Susan A. Wetzel, Haynes and Boone LLP, Dallas, TX;
         Christine L. Richardson, Pillsbury Winthrop Shaw Pittman LLP,
         San Francisco, CA; Robert Miller, Calfee Halter & Griswold LLP,
         Cleveland, OH
         The session will discuss the final 409A regulations (if issued) and
         their impact on mergers and acquisitions. If time permits, the
         session will focus on changes in representations, warranties,
         covenants, and indemnification language to address 409A, Pension
         Protection Act and option back-dating issues.




     38
                       FRIDAY, JANUARY 19 - PM
1:15PM - 2:15PM                            Room 312, 2nd Floor, Hotel
                                                                          PM
EMPLOYEE BENEFITS NONDISCRIMINATION




                                                                          FRIDAY
UPDATE, Presented by the Subcommittee on Nondiscrimination
and §415 Issues
Chair: W. Scott Magargee III, Dechert LLP, Philadelphia, PA
The session will discuss issues in the final 415 regulations (if
issued) or other guidance on 415 (if issued) and other
nondiscrimination issues.
1:15PM - 2:15PM                            Room 301, 2nd Floor, Hotel
EMPLOYEE BENEFITS PENSION LEGISLATION
UPDATE, Presented by the Subcommittee on Pension Legislation,
the Pension Simplification Task Force and the Enron Task Force
Chairs: John Utz, Utz Miller & Kuhn LLC, Overland Park, KS;
Keith Mong, Buchanan Ingersoll PC, Washington, DC
The subcommittees will discuss recent legislative developments.
1:15PM - 2:15PM                           Room 302, 2nd Floor, Hotel
EMPLOYEE BENEFITS YOUNG LAWYERS IN
EMPLOYEE BENEFITS FORUM, CLE Presented by the
Young Lawyers in Employee Benefits Forum
                                            ,
Chairs: Gary J. Chase, Roberts & Holland LLP New York, NY;
                                              ,
William Hansen, McDermott Will & Emery LLP Washington, DC
The forum will review the opportunities available to young lawyers
to increase their involvement in the Employee Benefits Committee.
1:30PM - 5:30PM                   Diplomat 2, 1st Floor, Convention Ctr
EMPLOYMENT TAXES
Chair: Thomas H. Meyerer, Ernst & Young LLP, Washington, DC
       1:30pm        Opening Remarks by the Chair.        CLE


       1:45pm        Update from the Executive Branch and
                     Private Practitioners on Emerging
                     Employment Tax Issues. A panel of
                     government representatives and private
                     practitioners will discuss the most significant
                     recent developments affecting employment
                     taxes with a focus on their practical
                     implications. The discussion also will include
                     the appropriateness of any actions to be taken
                     by the Committee in response to those
                     developments. Moderator: Russell A. Hollrah,
                     Hollrah LLC, Washington, DC. Panelists:
                     Catherine Livingston, Assistant Chief Counsel
                     (TE/GE), Office of Chief Counsel, IRS,
                     Washington, DC; Marie Cashman, Special
                     Counsel (TE/GE), Office of Chief Counsel,
                     IRS, Washington, DC.
                                                                    39
     FRIDAY, JANUARY 19 - PM
              3:00pm       Backdating of Stock Options. This panel will
PM
                           discuss various aspects of the backdating of
FRIDAY




                           stock options that are being raised by the IRS
                           as well as by analysts, investors, Audit
                           Committees and Boards of Directors. The tax
                           issues companies are facing are primarily
                           under IRC § 409A and 162(m), and those
                           withholding issues pertaining to ISOs.
                           Moderator: Edward J. Leyden, Law Office of
                           Edward J. Leyden, Bowie, MD. Panelists: J.
                           Bradford Anwyll, Alston & Bird LLP,
                           Washington, DC; Anne G. Batter, Baker &
                           McKenzie, Washington, DC; Elizabeth N.
                           Buchbinder, Ernst & Young LLP, Washington,
                           DC; Phillip A. Pillar, Reed Smith LLP,
                           Philadelphia, PA.

              4:15pm       Employment Tax Practitioners Workshop.
                           Group discussion among practitioners and
                           government representatives of employment-tax
                           issues faced in practice and of important issues
                           that the Committee should consider pursuing.
                           Moderator: Thomas H. Meyerer, Ernst &
                           Young LLP, Washington, DC. (This session
                           will not be taped.)

         1:30PM - 2:30PM                       Room 308, 2nd Floor, Hotel
         ESTATE & GIFT TAXES AND FIDUCIARY INCOME TAX
         YOUNG LAWYERS SUBCOMMITTEE CLE




     40
                    FRIDAY, JANUARY 19 - PM
1:30PM - 3:30PM                Regency 3, 1st Floor, Convention Ctr
                                                                      PM
FOREIGN LAWYERS FORUM




                                                                      FRIDAY
Chair: Friedhelm Jacob, Hengeler Mueller, Frankfurt, Germany
      1:30pm       Opening Remarks by the Chair.      CLE


      1:35pm       Offshore Companies Legislation: CFC Rules
                   Under Attack! Will existing European CFC
                   rules undergo a meaningful revision in the
                   wake of the landmark ECJ ruling in Cadbury-
                   Schweppes? How will it affect US groups? Will
                   group structures under US parents be affected?
                   Could pressure mount to weaken US CFC
                   rules as European CFC rules come under
                   attack? This panel will discuss these and other
                   recent developments in Europe, including
                   issues of non-discrimination pending before
                   the ECJ in the matter of Franked Investment
                   Income Group Litigation. Moderator: Sydney
                   Unger, Kaye Scholer LLP, New York, NY.
                   Panelists: David Glynn, A&L Goodbody,
                   Dublin, Ireland; Klaus Sieker, Flick Gocke
                   Schaumburg, Frankfurt, Germany.

      2:30pm       Beneficial Ownership. Think You Know the
                   Owner of a Cross Border Dividend or
                   Interest Payment? Think Again. Only the
                   “beneficial owner” of a dividend, royalty or
                   interest payment qualifies for reduced
                   withholding tax under tax treaties. But the
                   term “beneficial owner” is not clearly defined
                   in US law. And now the Indofoods case makes
                   the term even more unclear. Partnerships,
                   Financing SPVs, and other structures will be
                   examined. Moderator: Jack Bernstein, Aird
                   and Berlis LLP, Toronto, ON. Panelists:
                   Lodewijk Berger, Loyens & Loeff, Amsterdam,
                   The Netherlands; Michel Collet, CMS Bureau
                   Francis Lefebvre, New York, NY; Marco Rossi,
                   Marco Q. Rossi & Associati, New York, NY;
                   Michael McGowan, Shearman & Sterling
                   LLP, London, England.




                                                                41
     FRIDAY, JANUARY 19 - PM
         1:30PM - 3:00PM                 Diplomat 5, 1st Floor, Convention Ctr
PM
         TEACHING TAXATION
FRIDAY




         Chair: Professor Michael B. Lang, Chapman University School of
         Law, Orange, CA
               1:30pm        Opening Remarks by the Chair.       CLE


               1:40pm        Cross-Border Colloquy: What State/Local
                             and International Tax Lawyers Can Learn
                             from Each Other. Cross-border transactions
                             — whether international or interstate — pose
                             many of the same questions, but the answers
                             are often different. This panel will identify and
                             evaluate the varied answers offered to
                             questions of jurisdiction, sourcing, transfer
                             pricing, tax credits, and inter-jurisdictional
                             cooperation. Both income taxes and
                             transaction taxes will be considered, with a
                             focus on what state/local and international tax
                             planners and policymakers can learn from the
                             rules and developments in the other field.
                             Moderator: Professor John A. Swain,
                             University of Arizona, James E. Rogers
                             College of Law, Tucson, AZ. Panelists:
                             Professor Reuven S. Avi-Yonah, University of
                             Michigan Law School, Ann Arbor, MI;
                             Richard Ainsworth, Taxware, Wakefield, MA.

         2:00PM - 5:00PM                         Room 220, 1st Floor, Hotel
         NOMINATING          (Executive Session)
                           CLE
         Chair: Kenneth W. Gideon, Skadden Arps Slate Meagher & Flom
         LLP, Washington, DC
         2:00PM - 5:30PM                  Atlantic 2, 1st Floor, Convention Ctr
         S CORPORATIONS
         Chair: Carol Kulish Harvey, Deloitte Tax LLP, Washington, DC
               2:00pm        Opening Remarks by the Chair.       CLE


               2:05pm        Important Developments. Discussion of
                             recent legislative, administrative, and judicial
                             developments relating to S corporations and
                             their shareholders. Moderators: Laura Howell-
                             Smith, Deloitte Tax LLP, Washington, DC;
                             Michael Gould, Grant Thornton LLP,
                             Washington, DC.




     42
          FRIDAY, JANUARY 19 - PM
2:35pm   New Charitable Giving Incentives for S
                                                             PM
         Corporations Under the Pension Protection




                                                             FRIDAY
         Act of 2006. This panel will discuss the
         temporary basis adjustment provision for
         charitable contributions of property by S
         corporations contained in the Pension
         Protection Act of 2006. The panel will address
         the potential applicability of the provision as
         well as possible issues raised by the statutory
         language. Moderator: Thomas J. Nichols,
         Meissner Tierney Fisher & Nichols SC,
         Milwaukee, WI. Panelist: Jeanne E. Sullivan,
         KPMG LLP, Washington, DC.

2:55pm   Update on Back-to-Back Loans and Debt
         Basis. This panel will discuss structuring loans
         to obtain basis for S corporation shareholders,
         including back-to-back loans, with a particular
         emphasis on recent case law and rulings.
         Moderator: Stephen R. Looney, Dean Mead
         Egerton Bloodworth Capouano & Bozarth
         PA, Orlando, FL. Panelist: Ronald A. Levitt,
         Sirote & Permutt PC, Birmingham, AL.

3:30pm   Stock and Stock-Based Compensation Paid
         by S Corporations. This panel will examine
         the impact of issuing stock or stock-based
         compensation on an S corporation’s election
         and allocations of profits and losses. The panel
         also will discuss the application of section 409A
         to stock and stock-based compensation paid by
         an S corporation. Moderator: John Truskowski,
         Lord Bissell & Brook, Chicago, IL. Panelist:
         Carol A. Weiser, Sutherland Asbill & Brennan
         LLP, Washington, DC.

4:30pm   Taxable Acquisitions of S Corporations. This
         panel will discuss issues that arise in
          structuring a taxable purchase of an S
         corporation, with a focus on both the buyer’s
         and the seller’s perspective. Moderator: William
         D. Klein, Gray Plan Mooty Mooty & Bennett
         PA, Minneapolis, MN. Panelist: John S. Harper,
                                    ,
         Morrison & Foerster LLP McLean, VA.




                                                       43
     FRIDAY, JANUARY 19 - PM
         2:30PM - 5:30PM                Diplomat 4, 1st Floor, Convention Ctr
PM
         BANKRUPTCY AND WORKOUTS
FRIDAY




         Chair: Mark S. Wallace, Stutman Treister & Glatt PC, Los
         Angeles, CA
               2:30pm       Opening Remarks by the Chair.        CLE


               2:35pm       Current Developments. Highlights of recent
                            developments. Speaker: Kenneth C. Weil,
                            Law Office of Kenneth C. Weil, Seattle, WA.

                3:15pm      Are There Geographical Limitations to
                            Bankruptcy and Federal Tax Practice?
                            The panel will discuss the rules of
                            multijurisdictional practice of bankruptcy and
                            tax law and how they apply to practicing
                            outside the state in which you are licensed.
                            Moderator: Frances D. Sheehy, Law Office of
                            Frances D. Sheehy, Coconut Creek, FL.
                            Panelists: Paul Singerman, Berger Singerman
                            PA, Miami, FL; Paul Battista, Genovese
                             Joblove & Battista PA, Miami, FL.

                4:30pm      Preserving NOLs in Bankruptcy: How,
                            When and Why? This panel will discuss the
                            present state of the law regarding the
                            preservation of corporate net operating losses
                            (NOLs) in bankruptcy proceedings, including a
                            discussion of when NOLs can be preserved,
                            why disputes arise over the preservation of
                            NOLs and mechanically how NOLs may be
                            preserved in plans of reorganization. Also
                            discussed will be the impact of NOL
                            preservation on state tax issues given the varying
                            rules relating to this issue at the state level.
                            Moderator: Jennifer R. Noel, Young Conaway
                                                     ,
                            Stargatt & Taylor LLP Wilmington, DE.
                            Panelists: Annette M. Ahlers, Pepper Hamilton,
                                                          .
                            Washington, DC; David P Madden, KPMG
                                ,
                            LLP Washington, DC; Laurie Stoeckman, Ernst
                                           ,
                            & Young LLP New York, NY.




     44
                   FRIDAY, JANUARY 19 - PM
2:30PM - 6:00PM               Diplomat 3, 1st Floor, Convention Ctr
                                                                      PM
CLOSELY HELD BUSINESSES




                                                                      FRIDAY
Chair: John O. Tannenbaum, Law Offices of John O.
Tannenbaum, Hartford, CT
      2:30pm      Alternatives to IRC Section 355. A panel
                  discussion of planning ideas to separate
                  businesses in a tax efficient manner without
                  relying on the complex limitations of IRC
                  section 355. Moderator: Gregory R. Wilson,
                  Titchell Maltzman Mark & Ohleyer PC, San
                  Francisco, CA. Panelists: Steven M. Flanagan,
                  Ernst & Young LLP, Washington, DC; John
                  N. Geracimos, KPMG LLP, Washington, DC.

      3:30pm      Disregarded Entities and Series LLCs - Can
                  They Also Be Disregarded by Creditors? A
                  panel discussion regarding the status of the
                  law and opinions of practitioners regarding
                  the liability protection provided by single
                  member LLCs and series LLCs including a
                  review of the cases on this topic. Moderator:
                  Christopher M. Riser, Riser Adkisson LLP,
                  Atlanta, GA. Panelists: Robert Keatinge,
                  Holland & Hart LLP, Denver, CO; Allan
                  Donn, Willcox & Savage PC, Norfolk, VA.

      4:30pm      Conflicts of Interest and Related Ethical
                  Considerations in Representing the Closely
                  Held Business and Its Owners. The owners
                  of a closely-held business often think of the
                  lawyer who represents the business as their
                  personal lawyer as well. This client attitude is
                  fraught with ethical problems for the lawyer.
                  These and other related issues will be discussed
                  by this panel, which will also look at examples
                  of engagement letters used by lawyers entering
                  into such joint representation. Moderator:
                  Professor Michael B. Lang, Chapman University
                  School of Law, Orange, CA. Panelists: Professor
                  Mona L. Hymel, University of Arizona College
                  of Law, Tucson, AZ; A. Thomas Skallas,
                                        ,
                  Arnstein & Lehr LLP Chicago, IL; Samuel C.
                  Ullman, Bilzin Sumberg Baena Price & Axelrod
                      ,
                  LLP Miami, FL.

      5:30pm      Closely Held Business Committee Planning
                  Meeting. CLE

                                                                45
     FRIDAY, JANUARY 19 - PM
         2:30PM - 5:30PM              Grand East, 1st Floor, Convention Ctr
PM
         COURT PROCEDURE AND PRACTICE
FRIDAY




         Chair: Mary McNulty, Thompson & Knight LLP, Dallas, TX
               2:30pm      Opening Remarks by the Chair.      CLE


               2:35pm      Remarks on Behalf of the Tax Court.

               2:50pm      5th Amendment Claims in Civil Litigation.
                           This panel will consider the use and impact of
                           a witness invoking the 5th Amendment in a
                           civil tax proceeding and the ramifications of
                           the invocation of the 5th Amendment in
                           parallel proceedings. Moderator: Jonathan
                           Strouse, Holland & Knight LLP, Chicago, IL.
                           Panelists: Professor Christopher M.
                           Pietruszkiewicz, Paul M. Hebert Law Center,
                           Louisiana State University, Baton Rouge, LA;
                           Thomas J. Kane, Special Counsel (Procedure
                           and Administration), Office of Chief Counsel,
                           IRS, Washington, DC.

               3:25pm      Remarks on Behalf of the Office of Chief
                           Counsel, IRS. Speaker: Deborah A. Butler,
                           Associate Chief Counsel (Procedure and
                           Administration), IRS, Washington, DC.

               3:40pm      Current Summons Enforcement Issues. This
                           panel will focus on recent trends in summons
                           enforcement including the procedural
                           requirements and statute of limitations for
                           third-party summons, trends in seeking third-
                           party taxpayer information, summonses for
                           tax accrual work papers and associated
                           privilege issues. Moderator: Nicole M.
                           Bielawski, Mayer Brown Rowe & Maw LLP,
                           Washington, DC. Panelists: Kathryn A. Zuba,
                           Special Counsel (Procedure and
                           Administration), Office of Chief Counsel,
                           IRS, Washington, DC; Anita C. Soucy,
                           Attorney-Advisor, Department of Treasury,
                           Washington, DC; Alan J.J. Swirski, Skadden
                           Arps Slate Meagher & Flom LLP, Washington,
                           DC; Ann Reid, Assistant Chief, Central
                           Region, Tax Division, Department of Justice,
                           Washington, DC.



     46
                    FRIDAY, JANUARY 19 - PM
      4:20pm      Current Developments. Speaker: Juan F.
                                                                     PM
                  Vasquez Jr, Chamberlain Hdrlicka White




                                                                     FRIDAY
                  Williams & Martin, Houston, TX.

      4:35pm      FOIA Litigation Issues and Strategies. The
                  panel will focus on practitioner strategies for
                  use of FOIA requests to prepare for litigation
                  and considerations on whether to appeal a
                  denial of a request. The panel will also discuss
                  the recent Notice concerning coordination
                  between disclosure and chief counsel on how
                  the IRS responds to FOIA requests and
                  defends litigation of denials. Moderator: Amber
                  S. Hoffman, Baker & McKenzie LLP, Chicago,
                  IL. Panelists: Henry S. Schneiderman, Special
                  Counsel, Office of the Associate Chief Counsel
                  (Procedure and Administration), IRS,
                  Washington, DC; David M. Katinsky, Trial
                  Attorney, Tax Division, Department of Justice,
                  Washington, DC.

      5:15pm      Spotlight on Procedure: Privilege Issues in
                  Email “Chains”. Speaker: Charles M.
                  Ruchelman, Caplin & Drysdale Chartered,
                  Washington, DC.

2:30PM - 6:30PM              Grand West, 1st Floor, Convention Ctr
EMPLOYEE BENEFITS
Chair: Greta E. Cowart, Haynes & Boone LLP, Dallas, TX
      2:30pm      Opening Remarks by the Chair.      CLE


      2:35pm      Defined Benefit Plans and the Pension
                  Protection Act of 2006 (PPA). This program
                  will discuss current issues for defined benefit
                  plans, focusing on compliance with the
                  funding and related provisions of the PPA,
                  and legal issues facing cash balance and other
                  hybrid plans in light of the PPA, including
                  issues relating to prior years and the
                  determination letter process. Moderator: Kurt
                  L.P. Lawson, Pillsbury Winthrop Shaw
                  Pittman LLP, Washington, DC. Panelists: W.
                  Thomas Reeder, Acting Benefits Tax Counsel,
                  Office of Benefits Tax Counsel, Department
                  of Treasury, Washington, DC; Harlan M.
                  Weller, Government Actuary, Office of Tax
                  Policy, Department of Treasury, Washington,

                                                               47
     FRIDAY, JANUARY 19 - PM
                   DC; Howard Shapiro, Proskauer Rose LLP,
PM
                   New Orleans, LA; Richard C. Shea,
FRIDAY




                   Covington & Burling LLP, Washington, DC;
                   Lawrence J. Sher, Buck Consultants Inc, New
                   York, NY.

          3:35pm   Increased Savings, Diversity and Portability
                   — PPA Changes for Defined Contribution
                   Plans. This session will focus on the Pension
                   Protection Act changes to defined
                   contribution plans, including automatic
                   enrollment, diversification and new
                   distribution rules. Moderator: Eleanor
                   Banister, King & Spalding LLP, Atlanta, GA.
                   Panelists: Willam Bortz, Associate Benefits
                   Counsel, Office of Tax Policy, Department of
                   Treasury, Washington, DC; Gregory K.
                   Brown, Katten Muchin Rosenman LLP,
                   Chicago, IL; Mark A. Bodron, Baker Botts
                   LLP, Houston, TX.

          4:35pm   Emerging Fiduciary and Other Title I
                   Issues. In this panel, experienced practitioners
                   and Department of Labor representatives will
                   explore the recent participant-directed
                   investment guidance, Department of Labor’s
                   plan fee initiatives, the new fiduciary and
                   prohibited transaction rules under the Pension
                   Protection Act of 2006 and other recent
                   trends and developments under Title I.
                   Moderator: David Mustone, Hunton &
                   Williams LLP, McLean VA. Panelists: Louis
                   Campagna, Chief, Division of Fiduciary
                   Interpretations, Office of Regulations and
                   Interpretations, Employee Benefits Security
                   Administration, Department of Labor,
                   Washington, DC; Brian O’Hare, Patterson
                   Belknap Webb & Tyler LLP, New York, NY;
                   Andrew Oringer, Clifford Chance US LLP,
                   New York, NY.

          5:35pm   Government Guest Reception and Cash
                   Bar. CLE




     48
                    FRIDAY, JANUARY 19 - PM
2:30PM - 5:30PM                 Atlantic 3, 1st Floor, Convention Ctr
                                                                        PM
FINANCIAL TRANSACTIONS




                                                                        FRIDAY
                                               ,
Chair: Jeff Maddrey, PricewaterhouseCoopers LLP Washington, DC
      2:30pm      Derivatives with Respect to Alternative
                  Assets. This panel will discuss tax issues
                  associated with derivatives over alternative
                  assets such as hedge fund interests and
                  managed accounts. Moderator: David Miller,
                  Cadwalader Wickersham & Taft LLP, New
                  York, NY.

      3:30pm      The “New” Identified Straddle Rules. This
                  panel will explore practical issues with the
                  “new” identified straddle regime of section
                  1092(a)(2). Moderator: Bill Paul, Covington
                  & Burling LLP, Washington, DC. Panelists:
                  Michael S. Novey, Associate Tax Legislative
                  Counsel, Department of Treasury,
                  Washington, DC.

      4:30pm      Update on Current Financial Products
                  Issues. This panel will address current
                  developments in financial products.
                  Moderator: Mark Price, KPMG LLP,
                  Washington, DC.

2:30PM - 5:30PM                        Room 307, 2nd Floor, Hotel
INSURANCE COMPANIES
Chair: Kirk Van Brunt, Davis & Harman LLP, Washington, DC
      2:30pm      Opening Remarks by the Chair.        CLE


      2:35pm      2006: The Year in Review. Panelists will
                  briefly review and discuss recent developments
                  regarding insurance company and insurance
                  product tax issues. Topics to be covered
                  include (but are not limited to) recently
                  proposed regulations on exchanges involving
                  private annuities, investor control, cell captive
                  arrangements, COLI best practices, and
                  closing agreements for failed insurance
                  contracts. Moderator: Jean M. Baxley, Crowell
                  & Moring LLP, Washington, DC. Panelists:
                  Mark S. Smith, Branch Chief, Branch 4,
                  Office of Chief Counsel, Department of
                  Treasury, Washington, DC; Susan Seabrook,
                  Latham & Watkins LLP, Washington, DC.

                                                                 49
     FRIDAY, JANUARY 19 - PM
               3:35pm      Reflections on Risk. This panel will address
PM
                           insurance risk transfer and distribution issues
FRIDAY




                           and the definition of insurance, as well as the
                           new FASB proposal on bifurcation of
                           contracts. Moderator: Dick Bromley, Foley &
                           Lardner LLP, Chicago, IL. Panelist:
                           Christopher E. Nelson, Navigant Consulting,
                           Chicago, IL.

               4:35pm      Stranger Owned Life Insurance/Life
                           Settlements: What Should Be Permitted/
                           What Should Not? This panel will address
                           generally the holding of life insurance by
                           persons lacking an insurable interest in the life
                           of the insured, and explore recent efforts to
                           proscribe “stranger owned” life insurance and
                           how to distinguish STOLI situations from
                           legitimate secondary market transactions.
                           Moderator: Tom Quinn, Law Office of Tom
                           Quinn, Boston, MA.

         2:30PM - 5:30PM            Great Hall 5, 2nd Floor, Convention Ctr
         REAL ESTATE
         Chair: James M. Lowy, Ernst & Young LLP, San Francisco, CA
               2:30pm      Opening Remarks by the Chair.       CLE


               2:35pm      Related Party Exchange Transactions. This
                           panel will explore guidance regarding the
                           application of section 1031(f ) and explore the
                           parameters of the exception in section
                           1031(f )(2)(C). Moderator: Howard J. Levine,
                           Roberts & Holland LLP, Washington DC.
                           Panelists: Todd D. Keator, Thompson &
                           Knight LLP, Dallas, TX; Edward S. Cohen,
                           Deputy Associate Chief Counsel, Income Tax
                           & Accounting, IRS, Washington, DC; Steve
                           Toomey, Senior Counsel, Income Tax &
                           Accounting, Branch 4, IRS, Washington, DC.

               3:20pm      Goodwill in Real Estate Transactions. The
                           panel will explore the allocation of purchase
                           price to goodwill and other intangibles in real
                           estate transactions. The tax consequences of
                           such allocations will be examined, including
                           the impact on REITs and other institutional
                           investors. Moderator: David Miller, Ernst &
                           Young LLP, Dallas, TX.

     50
                   FRIDAY, JANUARY 19 - PM
      3:45pm      Charitable Contributions of Facade
                                                                      PM
                  Easements and Other Real Estate Interests.




                                                                      FRIDAY
                  This panel will discuss charitable
                  contributions of various real estate interests
                  to charity, including facade and conservation
                  easements. Moderator: William D. Elliott,
                  Attorney at Law, Dallas, TX. Panelists:
                  Elizabeth Paris, Tax Counsel, Senate Finance
                  Committee, Washington, DC; Scott Y.
                  Barnes, Warren & Sinkler LLP, Charleston,
                  SC; Suzanne Ross McDowell, Steptoe &
                  Johnson LLP, Washington DC.

      4:20pm      Section 470 Update and Other Hot Topics.
                  This panel will discuss recent legislative
                  developments with respect to section 470 and
                  other developments in real estate taxation.
                  Moderator: James B. Sowell, Deloitte Tax LLP,
                  Washington DC. Panelists: William P. Bowers,
                  Senior Counsel, Office of Assistant Secretary
                  for Tax Policy, Department of Treasury,
                  Washington DC; Carol Kulish Harvey,
                  Deloitte Tax LLP, Washington DC.

      4:50pm      REIT Privatization Transactions. This panel
                  will explore the recent trend in transactions
                  involving private buyers of public REITs and
                  the numerous tax issues (REIT, partnership,
                  and other) that arise in these transactions.
                  Moderator: A. Christina Arumi, Hogan &
                  Hartson LLP, Washington DC. Panelists: John
                  Napoli, Seyfarth Shaw LLP, New York, NY;
                  Lary Wolf, Roberts & Holland LLP, New
                  York, NY.

2:30PM - 5:30PM                Regency 1, 1st Floor, Convention Ctr
STATE AND LOCAL TAXES
Chair: Stephanie Anne Lipinksi Galland, Thompson Coburn LLP,
Washington, DC
      2:30pm      Federal Preemption and State and Local
                  Taxation.

      3:30pm      FIN 48 and State and Local Tax.




                                                                 51
     FRIDAY, JANUARY 19 - PM
               4:30pm       Penalties: The State Tax Community’s
PM
                            Version of “Capital Punishment”. Penalties
FRIDAY




                            for state and local taxes are increasing in range,
                            cost, and imposition rules. This session will
                            discuss several of the current issues
                            surrounding the increased use of various types
                            of penalties. The panel will include reviews of
                            current challenges to newly enacted retroactive
                            penalties imposed during tax amnesty periods;
                            the validity of statutory non-appealability of
                            tax shelter associated penalties; the problems
                            associated with strict-liability penalties for
                            reportable transaction disclosure; and whether
                            there are constitutional limitations to the
                            amount of penalties imposed for a transaction.

         2:30PM - 5:30PM                 Diplomat 1, 1st Floor, Convention Ctr
         TAX ACCOUNTING
         Chair: Jody Brewster, Skadden Arps Slate Meagher & Flom LLP,
         Washington, DC
               2:30pm       Recent Developments in the Area of Tax
                            Accounting. This program will cover
                            important recent developments in the tax
                            accounting area since the 2006 Joint Fall CLE
                            Meeting in Denver, Colorado, with
                            commentary and input from our government
                            guests from the Department of Treasury’s
                            Office of Tax Policy and the IRS. Moderator:
                            Colleen O’Connor, Ernst & Young LLP,
                            Washington, DC.

               3:30pm       Recent Developments of Interest to Public
                            Utilities. This program will discuss recent
                            developments which have a unique impact on
                            public utilities, with commentary and input
                            from our government guests from the
                            Department of Treasury’s Office of Tax Policy
                            and the IRS. Moderator: Gerald Towne,
                            Thelen Reid Brown Raysman & Steiner LLP,
                            Washington, DC. Panelists: James Warren,
                            Thelen Reid Brown Raysman & Steiner LLP,
                            New York, NY; Martha Graves Pugh, Thelen
                            Reid Brown Raysman & Steiner LLP,
                            Washington, DC.




     52
                     FRIDAY, JANUARY 19 - PM
       3:50pm      Advance Trade Discounts - Confusion or
                                                                         PM
                   Consternation? This panel will discuss recent




                                                                         FRIDAY
                   decisions addressing the treatment of trade
                   discounts (Westpac — advance trade discounts
                   are not reportable income; Karns — advance
                   trade discounts are not loans), as well as
                   administrative guidance expected to be
                   released before the Midyear Meeting, with
                   commentary and input from our government
                   guests from the Department of Treasury’s
                   Office of Tax Policy and the IRS. Included in
                   the discussion will be the different types of
                   advance trade discounts, possible differing
                   treatment, and planning considerations.
                   Moderator: Jack Donovan, Ernst & Young
                   LLP, Washington, DC. Panelists: Les
                   Schneider, Ivins Phillips & Barker Chartered,
                   Washington, DC; Carol Conjura, KPMG
                   LLP, Washington, DC.

      4:40pm       Recovery of Capital Transaction Costs. The
                   Department of Treasury’s business plan
                   includes issuing guidance on the treatment of
                   capitalized transaction costs. This panel will
                   explore the current rules and discuss proposed
                   solutions to this decades-old issue, with
                   commentary and input from our government
                   guests from the Department of Treasury’s
                   Office of Tax Policy and the IRS. Moderator:
                   Ellen MacNeil, Deloitte Tax LLP, Washington,
                   DC. Panelist: Emily Lam, Skadden Arps Slate
                   Meagher & Flom LLP, Washington, DC.

2:30PM - 5:30PM                  Atlantic 1, 1st Floor, Convention Ctr
TAX EXEMPT FINANCING
Chair: Clifford M. Gerber, Sidley Austin LLP, San Francisco, CA
      2:30pm       Opening Remarks by the Chair.        CLE




                                                                   53
     FRIDAY, JANUARY 19 - PM
          2:35pm   IRS and Department of Treasury Update.
PM
                   This panel will discuss current developments
FRIDAY




                   in tax-exempt bonds, including the progress of
                   items in the 2006-2007 Priority Guidance
                   Plan. Panelists: John J. Cross III, Associate Tax
                   Legislative Counsel, Office of Tax Policy,
                   Department of Treasury, Washington, DC;
                   Rebecca Harrigal, Branch Chief, IRS,
                   Washington, DC.

          3:05pm   Allocation and Accounting Regulations
                   Project. This panel will update the committee
                   on the progress of the comment project on the
                   proposed allocation and accounting
                   regulations, including a discussion of any new
                   issues. Panelist: Bruce M. Serchuk, Nixon
                   Peabody LLP, Washington, DC.

          3:20pm   PILOT Regulations Project. This panel will
                   update the committee on the progress of the
                   comment project on the proposed payment in
                   lieu of taxes (“PILOT”) regulations, including
                   a discussion of any new issues. Panelist: Linda
                   B. Schakel, Ballard Spahr Andrews & Ingersoll
                   LLP, Washington, DC.

          3:35pm   Essential Governmental Functions of States
                   and Tribes. This panel will discuss the varying
                   interpretations of the term “essential
                   governmental function” as applied to states
                   and tribal governments. Panelists: Professor
                   Ellen P. Aprill, Loyola Law School, Los
                   Angeles, CA; John J. Cross III, Associate Tax
                   Legislative Counsel, Office of Tax Policy,
                   Department of Treasury, Washington, DC.

          4:15pm   Derivatives and Investment Products. This
                   panel will discuss current developments in
                   derivatives and investment products. Panelists:
                   John T. Lutz, McDermott Will & Emery LLP,
                   New York, NY; Michael G. Bailey, Foley &
                   Lardner LLP, Chicago, IL.




     54
                    FRIDAY, JANUARY 19 - PM
      4:50pm       IRS Enforcement. This panel will update the
                                                                      PM
                   committee on current IRS enforcement




                                                                      FRIDAY
                   initiatives. The panel will also discuss, among
                   other topics, the prospects for utilization of
                   various alternative dispute resolution programs
                   in the tax-exempt bond area. Panelists: Jeremy
                   A. Spector, Blank Rome LLP, Philadelphia,
                   PA; Clifford J. Gannett, Director, Tax-Exempt
                   Bonds, IRS, Washington, DC; Steven
                   Chamberlin, Acting Manager, Office of
                   Compliance and Program Management, IRS,
                   St. Louis, MO.

3:30PM - 5:30PM                Regency 3, 1st Floor, Convention Ctr
US ACTIVITIES OF FOREIGNERS AND TAX
TREATIES
Chair: William S. Dixon, Citigroup Global Markets Inc, New
York, NY
      3:30pm       US Trade or Business Issues in Lending
                   Transactions. The panel will examine the tax
                   considerations associated with a non-US
                   person entering into various types of lending-
                   related agreements or relationships in the US.
                   Moderator: William S. Dixon, Citigroup
                   Global Markets Inc, New York, NY. Panelists:
                   Daniel C. Kolb, Ropes & Gray LLP, New
                   York, NY; David S. Miller, Cadwalader
                   Wickersham & Taft LLP, New York, NY; W.
                   Kirk Wallace, Skadden Arps Slate Meagher &
                   Flom LLP, New York, NY.

      4:30pm       Portfolio Interest. This panel will survey a
                   number of vexing issues surrounding the
                   interpretation and application of the rules
                   pertaining to portfolio interest in a number of
                   contemporary situations. Moderator: Timothy
                   J. Devetski, Vinson & Elkins LLP, Houston,
                   TX. Panelists: Peter H. Blessing, Shearman &
                   Sterling LLP, New York, NY; Stephen Land,
                   Linklaters, New York, NY.

4:00PM - 6:30PM                  Room 312 & 313, 2nd Floor, Hotel
DIVERSITY COMMITTEE AND YOUNG LAWYERS
FORUM
Diversity Chair: Walter W. Burford, PricewaterhouseCoopers LLP,
Washington, DC
Young Lawyers Forum Chair: Allen D. Madison, Washington, DC

                                                                55
     FRIDAY, JANUARY 19 - PM
                4:00pm       Improving Your Writing and Getting
PM
                             Published. This workshop is designed to
FRIDAY




                             assist tax practitioners with enhancing their
                             writing skills and getting their articles
                             published. The workshop will provide quick
                             tips for improving your writing skills and will
                             provide detailed information about the
                             publishing process. Among the publishing
                             process questions that will be answered are:
                             “How do I get started? What topics are
                             appropriate? How lengthy should the article
                             be? Where should I send my potential article
                             for publication? How long does the process
                             typically take?” Moderator: Walter W. Burford,
                             PricewaterhouseCoopers LLP, Washington,
                             DC. Panelists: Louis A. Mezzullo, Luce
                             Forward Hamilton & Scripps, Rancho Santa
                             Fe, CA; Samuel L. Braunstein, Braunstein &
                             Todisco PC, Fairfield, CT.
                                                          CLE
                5:30pm       Networking Reception             Room 314,
                             2nd Floor, Hotel. All law students competing
                             in the Law Student Tax Challenge will be
                             recognized as well as the announcement of 1st,
                             2nd and 3rd place teams and best written brief.
                             Sponsored by: Pillsbury Winthrop Shaw
                             Pittman LLP

         5:00PM - 6:00PM                          Room 302, 2nd Floor, Hotel
         PROFESSIONAL SERVICES              CLE
         Chair: Charles J. Lavelle, Greenebaum Doll & McDonald PLLC,
         Louisville, KY
         5:00PM - 6:00PM                             Room 219, 1st Floor, Hotel
         PROGRAMS AND MEETINGS                CLE
         Chair: Rudolph R. Ramelli, Jones Walker, New Orleans, LA
         5:30PM - 6:30PM                          Room 305, 2nd Floor, Hotel
         FOREIGN LAWYERS FORUM BUSINESS MEETING                           CLE

         6:30PM - 8:00PM           Great Hall 1 & 2, 2nd Floor, Convention Ctr
         SECTION RECEPTION/PLENARY SESSION                      CLE
         (Ticketed Event)
         Susan P. Serota, Section Chair, Presiding
                   Nominating Committee Report
                   Kenneth W. Gideon, Committee Chair




     56
            SATURDAY, JANUARY 20 - AM

SATURDAY, JANUARY 20
7:00AM - 9:00AM            Great Hall 2, 2nd Floor, Convention Ctr
CAPITAL RECOVERY AND LEASING                                         AM
Chair: Kevin D. Anderson, Washington, DC




                                                                     SATURDAY
      7:00am      Current Developments Report and Update
                  on Pending Guidance Projects. This program
                  will cover the important recent developments
                  in the areas of capital recovery and leasing
                  since the 2006 Joint Fall CLE Meeting in
                  Denver, Colorado, and provide an update on
                  guidance projects in these areas. Moderator:
                  Katherine Breaks, KPMG LLP, Washington,
                  DC. Panelists: Sharon Kay, Taxation Specialist,
                  Office of Tax Legislative Counsel, Department
                  of Treasury, Washington, DC; Dennis Tingey,
                  Taxation Specialist, Office of Tax Legislative
                  Counsel, Department of Treasury,
                  Washington, DC; Glenn Johnson, Ernst &
                  Young LLP, Washington, DC.

      8:00am      Recent Developments in Proposed Tangible
                  Property Repair Regulations. This panel will
                  discuss the most recent developments in the
                  proposed regulations concerning the
                  capitalization of costs related to tangible
                  property issued in August 2006, including a
                  review of the comments filed in response to
                  the proposed regulations and the issues
                  discussed at the public hearing in December
                  2006. Moderator: Susan Grais, Ernst & Young
                  LLP, Washington, DC. Panelists: Sharon Kay,
                  Taxation Specialist, Office of Tax Legislative
                  Counsel, Department of Treasury,
                  Washington, DC; Kimberly Koch, Special
                  Counsel to the Associate Chief Counsel
                  (Income Tax and Accounting), IRS,
                  Washington, DC.




                                                               57
       SATURDAY, JANUARY 20 - AM
           7:00AM - 8:15AM                  Diplomat 1, 1st Floor, Convention Ctr
           EMPLOYEE BENEFITS SPECIAL DEFINED BENEFIT
           PLAN ISSUES UPDATE, Presented by the Subcommittee on
   Special Defined Benefit Plan Issues and the Cash Balance Plan
   Task Force
AM
   Chairs: Elizabeth E. Drigotas, Deloitte Tax LLP, Washington, DC;
   Seth H. Tievsky, Ernst & Young LLP, Washington, DC
SATURDAY




           The subcommittees will be discussing the Pension Protection Act
           of 2006 changes to funding, potential comments regarding
           proposed regulations, and updates regarding guidance under
           section 411(d)(6), cash balance and hybrid plans and in other areas
           impacting defined benefit plans.
           7:00AM - 9:00AM                  Diplomat 2, 1st Floor, Convention Ctr
           LOW INCOME TAXPAYERS
           Chair: Elizabeth J. Atkinson, Kaufman & Canoles PC, Norfolk, VA
                  7:00am       Opening Remarks by the Chair.         CLE


                  7:05am       Report of the National Taxpayer Advocate.
                               This panel will discuss the National Taxpayer
                               Advocate’s 2006 Report to Congress. Speaker:
                               Nina E. Olson, National Taxpayer Advocate,
                               IRS, Washington, DC.

                  7:50am       Three C’s: OIC, CNC and Bankruptcy —
                               Legal and Ethical Issues. This panel will
                               address differences among these collections
                               alternatives, which are best for taxpayers. Issues
                               addressed will include allowable expense
                               guidelines, asset valuation and exemptions.
                               Moderator: Joseph Barry Schimmel, Cohen
                               Chase Hoffman & Schimmel PA, Miami, FL.
                               Panelists: Frances D. Sheehy, Law Office of
                               Frances Diane Sheehy, Coconut Creek, FL;
                               Michael Allen Frank, Miami, FL; Daria Zubil,
                               Manager, Bankruptcy/Insolvency Unit, South
                               Florida Area, IRS, Plantation, FL.




       58
             SATURDAY, JANUARY 20 - AM
7:00AM - 8:30AM                 Diplomat 4, 1st Floor, Convention Ctr
TAX PRACTICE MANAGEMENT
Chair: David A. Berek, Credit Suisse, Chicago, IL
       7:00am       Informal Discussion and Complimentary
                    Breakfast. CLE
                                                                        AM
       7:25am       Opening Remarks by the Chair and Report




                                                                        SATURDAY
                    on Committee Chairs and Vice Chairs
                    Breakfast. CLE

       7:35am       What Every Estate Planning Attorney
                    Should Know About Florida. The speaker
                    will present important information and tips
                    concerning Florida estate planning and
                    probate issues that are likely to arise in a tax
                    practice. Speaker: Bruce M. Stone, Goldman
                    Felcoski & Stone PA, Coral Gables, FL.

7:15AM - 8:30AM                 Diplomat 3, 1st Floor, Convention Ctr
PARTNERSHIPS & LLCs/REAL ESTATE/
S CORPORATIONS “SHOP TALKING”
BREAKFAST CLE (Ticketed Event)
Sponsored by: Wachovia Exchange Services
Members of the Real Estate, Partnerships & LLCs and S
Corporations Committees will gather for the traditional “open
mic” breakfast to share ideas and war stories and to seek input on
technical issues.
7:30AM - 9:30AM                          Room 303, 2nd Floor, Hotel
ACTC BOARD OF REGENTS MEETING                  CLE (Executive
Session)
7:30AM - 8:15AM                  Regency 3, 1st Floor, Convention Ctr
COMMITTEE CHAIRS, VICE CHAIRS, OFFICERS AND
COUNCIL BREAKFAST CLE
Sponsored by: Borden Ladner Gervais LLP
7:30AM - 8:30AM                 Diplomat 5, 1st Floor, Convention Ctr
SALES, EXCHANGES AND BASIS BREAKFAST                      CLE
Sponsored by: J.P. Morgan Property Exchange, Inc.
7:45AM - 9:00AM                          Room 307, 2nd Floor, Hotel
COURT PROCEDURE AND PRACTICE OFFICERS AND
SUBCOMMITTEE CHAIRS BREAKFAST CLE (Ticketed Event)




                                                                   59
       SATURDAY, JANUARY 20 - AM
           8:30AM - 11:30AM                Regency 1, 1st Floor, Convention Ctr
           CIVIL & CRIMINAL TAX PENALTIES
           Chair: Miriam L. Fisher, Morgan Lewis & Bockius LLP,
           Washington, DC
                 8:30am      Opening Remarks by the Chair.       CLE
AM
                 8:35am      Reports of Subcommittees. Attorney-Client
SATURDAY




                             and Constitutional Privileges, Bradley L.
                             Williams, Ice Miller, Indianapolis, IN;
                             Important Developments - Civil, Charles P.
                             Rettig, Hochman Salkin Rettig Toscher &
                             Perez, Beverly Hills, CA; Important
                             Developments - Criminal, Caroline D.
                             Ciraolo, Rosenberg Martin Funk Greenberg,
                             Baltimore, MD; Sentencing Guidelines, Niles
                             Elber, Caplin & Drysdale Chartered,
                             Washington, DC; Monetary Violations and
                             Forfeitures, James N. Mastracchio, Morgan
                             Lewis & Bockius LLP, Washington, DC;
                             Legislative and Administrative Developments,
                             John Colvin, Chicoine & Hallett, Seattle,
                             WA; International Tax Enforcement, Scott A.
                             Harty, Smith Gambrell & Russell LLP,
                             Atlanta, GA; IRS Investigations and Practices,
                             Josh Ungerman, Meadows Owens Collier
                             Reed Cousins & Blau, Dallas, TX.

                 9:05am      IRS Chief Counsel Penalty Update. Speaker:
                             Deborah A. Butler, Associate Chief Counsel
                             (Procedure and Administration), Office of
                             Chief Counsel, IRS, Washington, DC.

                 9:30am      Penalty Computation Disputes — The
                             Devil’s in the Details. A discussion of case
                             developments and ambiguities in recent penalty
                             legislation as to the type of infractions covered
                             and how civil penalties should be calculated.
                             Panelists: M. Carr Ferguson, Davis Polk &
                             Wardwell, New York, NY; Mario J. Verdolini,
                             Davis Polk & Wardwell, New York, NY.

                 10:00am     Queen for A Day? Proffer Practice. The
                             panel will discuss the strategic pros and cons
                             of letting a client talk to prosecutors with the
                             increasingly limited protections afforded by a
                             proffer agreement. Moderator: Brent J.
                             Gurney, Wilmer Hale, Washington, DC.

       60
              SATURDAY, JANUARY 20 - AM
                      Panelists: Dana J. Boente, Principle Deputy
                      Assistant Attorney General, Tax Division,
                      Department of Justice, Washington, DC;
                      Justin A. Thornton, Law Offices of Justin
                      Thornton, Washington, DC.
                                                                          AM
       10:40am        When Does a Lawyer Need a Lawyer? The




                                                                          SATURDAY
                      panel will consider a case study exploring
                      practical and legal risks for practitioners whose
                      clients may have illegal-source income.
                      Moderator: Ian M. Comisky, Blank Rome
                      Comisky & McCauley, Philadelphia, PA.
                      Panelists: Michael E. Yasofsky, Special Agent-
                      In-Charge, Criminal Investigation Division,
                      IRS, Tampa, FL; Harvey M. Silets, Katten
                      Muchin Rosenman LLP, Chicago, IL; Michael
                      D. Shepard, Deloitte Financial Advisory
                      Services LLP, New York, NY; Miriam L.
                      Fisher, Morgan Lewis & Bockius LLP,
                      Washington, DC.

8:30AM - 12:30PM
COMPANIONS’ TOUR CLE (Ticketed Event)
Tropical Deco in a Fabled Playground Tour (Art Deco
Architecture)
Buses will depart promptly at 8:30am from the Convention Center
lower lobby.
See p. 8 for a full description.
8:30AM - 11:45AM                   Regency 2, 1st Floor, Convention Ctr
CORPORATE TAX
                                                ,
Chair: Karen Gilbreath Sowell, Ernst & Young LLP Washington, DC
       8:30am         An Evolving Theory of Basis? Exploring
                      Recent Guidance. This panel will discuss the
                      final regulations under section 358 and other
                      basis recovery issues that are implicated by
                      recent guidance. Moderator: Karen Gilbreath
                      Sowell, Ernst & Young LLP, Washington, DC.
                      Panelists: William D. Alexander, Associate
                      Chief Counsel (Corporate), Office of Chief
                      Counsel, IRS, Washington, DC; Marc A.
                      Countryman, Attorney Advisor, Office of Tax
                      Legislative Counsel, Department of Treasury,
                      Washington, DC; Steven Harrison, Dewey
                      Ballantine LLP, New York, NY; David H.
                      Schnabel, Debevoise & Plimpton LLP, New
                      York, NY.
                                                                     61
       SATURDAY, JANUARY 20 - AM
                 9:45am      Analyzing Transactions after Recent Shelter
                             Cases. The panel will consider the impact of
                             Coltec and Black & Decker on transaction
                             planning and on audit, controversy and
                             litigation matters. Moderator: Mark J.
AM
                             Silverman, Steptoe & Johnson LLP,
                             Washington, DC. Panelists: Glen A. Kohl,
SATURDAY




                             Electronic Arts, Redwood City, CA; Matthew
                             D. Lerner, Steptoe & Johnson LLP,
                             Washington, DC; Gerald V. Thomas II,
                             Alston & Bird LLP, Atlanta, GA.

                  11:00am    Current Developments. This panel will
                             explore recent guidance, including issues
                             related to section 362(e)(2) and “D”
                             reorganizations. Moderator: Milton B.
                             Hyman, Irell & Manella LLP, Los Angeles,
                             CA. Panelists: Marc A. Countryman, Attorney
                             Advisor, Office of Tax Legislative Counsel,
                             Department of Treasury, Washington, DC;
                             Mark A. Schneider, Deputy Associate Chief
                             Counsel (Corporate), Office of Chief Counsel,
                             IRS, Washington, DC; Kirsten L. Simpson,
                             Ernst & Young LLP, Washington, DC.

           8:30AM - 11:30AM             Grand West, 1st Floor, Convention Ctr
           EMPLOYEE BENEFITS
           Chair: Greta E. Cowart, Haynes and Boone LLP, Dallas, TX
                 8:30am      Opening Remarks by the Chair.       CLE


                 8:35am      Fiduciary Exposure: Litigation and Other
                             Trends. Panel will analyze developments that
                             may increase or mitigate fiduciary liability,
                             including plan expenses, fund performance,
                             and plan provisions. Moderator: James R.
                             Raborn, Baker Botts LLP, Houston, TX.
                             Panelists: T. David Cowart, Jenkens &
                             Gilchrist a Professional Corporation, Dallas,
                             TX; Helen Morrison, Deloitte Tax LLP,
                             Chicago, IL; Rene` Thorne, Proskauer Rose
                             LLP, New Orleans, LA.

                 9:35am      The Latest Twist on 409A. The panel will
                             discuss the latest guidance on Code section
                             409A, including the tax and withholding
                             guidance and the final regulations (if issued).
                             The panel will explore design and drafting

       62
            SATURDAY, JANUARY 20 - AM
                   opportunities that remain. Moderators: John
                   L. Utz, Utz Miller & Kuhn LLC, Overland
                   Park, KS; Carol A. Weiser, Sutherland Asbill
                   & Brennan LLP, Washington, DC. Panelists:
                   Daniel L. Hogans, Attorney Advisor, Office of
                   Benefits Tax Counsel, Department of Treasury,        AM
                   Washington, DC; Stephen B. Tackney,




                                                                        SATURDAY
                   Attorney Advisor, Office of Chief Counsel,
                   IRS, Washington, DC; Linda Wilkins, Locke
                   Lidell & Sapp, Dallas, TX; Max Schwartz,
                   Sullivan & Cromwell LLP, New York, NY.

      10:30am      The New World of Proxy Disclosures:
                   Understanding and Complying with the
                   New SEC Rules for Proxy Statements. With
                   proxy season in full swing, the panel intends
                   to focus on some of the more troublesome
                   questions being faced by issuers in this first
                   season under the new proxy rules. Issues to be
                   discussed include drafting the Compensation
                   Discussion and Analysis, determining what
                   must be disclosed, and how and where to
                   disclose it. Moderator: David E. Gordon,
                   Clark Consulting/Pearl Meyer & Partners, Los
                   Angeles, CA. Panelists: Pamela Baker,
                   Sonnenschein Nath & Rosenthal LLP,
                   Chicago, IL; Mark A. Borges, Mercer Human
                   Resource Consulting, Washington, DC;
                   Deborah Walker, Deloitte Tax LLP,
                   Washington, DC; David M. Lynn, Chief
                   Counsel, Division of Corporate Finance,
                   United States Securities and Exchange
                   Commission, Washington, DC.

8:30AM - 11:30AM                Diplomat 1, 1st Floor, Convention Ctr
FIDUCIARY INCOME TAX
Chair: David Pratt, Proskauer Rose LLP, Boca Raton, FL
      8:30am       Opening Remarks. CLE Report on committee
                   chairs and vice-chairs breakfast topics and other
                   committee business. Speaker: A. Christopher
                                     ,
                   Sega, Venable LLP Washington, DC.

      8:40am       Recent Developments. Report on Recent
                   Developments Affecting the Income Taxation
                   of Trusts and Estates. Speaker: Jeanne L.
                                        ,
                   Newlon, Venable LLP Washington, DC.


                                                                  63
       SATURDAY, JANUARY 20 - AM
            8:55am    Trust Performance under Different Payout
                      Scenarios — 1986-2005. This is an analysis
                      of what would have happened to the income
                      beneficiary and remainderman of a trust
                      created in 1986 and terminating in 2005 had
AM
                      the trustee had the options that now exist
                      under the Principal and Income Act and
SATURDAY




                      chosen, respectively, a 3% payout, a 4%
                      payout, and payout of the trust’s yield. Its
                      purpose is to test the theory of the Principal
                      and Income (and Prudent Investor) Acts
                      against the backdrop of real market outcomes.
                      Speaker: Jordan Sprechman, JP Morgan, New
                      York, NY.

            9:45am    Funding Trusts in the Crossfire of
                      Conflicting Estate Tax, Income Tax and
                      ERISA Laws: What’s the Use of Happiness If
                      It Can’t Buy You Money? Funding trusts with
                      retirement assets requires an estate planner to
                      integrate three distinct sets of laws: income tax
                      laws, estate tax laws and ERISA mandatory
                      distribution laws. This program will examine
                      how these laws interact to create special
                      problems, especially for bypass and QTIP
                      trusts and will explore solutions. The program
                      will examine basic planning strategies,
                      especially in light of pending estate tax
                      changes, as well as the most recent IRS rulings
                      on the subject. Speaker: Professor Christopher
                      R. Hoyt, University of Missouri (Kansas City)
                      School of Law, Kansas City, MO.

            10:35am   Insurance and the Transfer for Value Rule.
                      This presentation will examine the transfer for
                      value exception to the general rule of section
                      101 of the Code that life insurance death
                      proceeds are received income-tax free. In
                      addition to discussing the transfer for value
                      rule itself, the presentation will analyze its
                      application to a series of common transactions,
                      including buy-sell planning, retirement
                      planning, general business planning, and
                      personal planning. Speaker: Lawrence Brody,
                      Bryan Cave LLP, St. Louis, MO.



       64
            SATURDAY, JANUARY 20 - AM
8:30AM - 10:30AM                        Room 312, 2nd Floor, Hotel
LLC SUBCOMMITTEE OF PARTNERSHIPS & LLCs
Chair: Bahar Schippel, Snell & Wilmer LLP, Phoenix, AZ
8:30AM - 11:45AM                Atlantic 2, 1st Floor, Convention Ctr
SALES, EXCHANGES AND BASIS
Chair: David Shechtman, Drinker Biddle & Reath LLP,                     AM
Philadelphia, PA




                                                                        SATURDAY
      8:30am       Opening Remarks by the Chair.       CLE


      8:35am       Sales and Exchanges: Current
                   Developments. Presentation of new cases and
                   rulings affecting sales, exchanges and basis
                   (other than section 1031). Moderator:
                   Professor Erik Jensen, Case Western Reserve
                   University School of Law, Cleveland, OH;
                   Professor Brad Borden, Washburn University
                   School of Law, Topeka, KS.

      9:00am       Sales and Exchanges of Leasehold Interests.
                   This panel will continue its examination of
                   the tax issues related to selling and exchanging
                   leases. The discussion will focus on the tax
                   significance of tenant improvements, lease
                   modifications, and the definition of “lease” in
                   the context of sales and exchanges. Moderator:
                   Professor Brad Borden, Washburn University
                   School of Law, Topeka, KS; Panelists: Kelly
                   Alton, Deloitte Tax LLP, Washington, DC;
                   Glenn Johnson, Ernst & Young LLP,
                   Washington, DC.

      9:30am       Practical Implication of Proposed Tangible
                   Asset Capitalization Regulations. This panel
                   will address select issues under the recently
                   proposed regulations under section 263(a)
                   with a particular focus on items fostering
                   increased complexity for taxpayers. Panelists:
                   Todd B. Reinstein, Pepper Hamilton LLP,
                   Washington, DC; George Manousos,
                   PricewaterhouseCoopers LLP, Washington,
                   DC; Heather Johnson, General Dynamics,
                   Falls Church, VA.




                                                                  65
       SATURDAY, JANUARY 20 - AM
                 10:10am     Swap and Defease; Can it be Done with Ease?
                             This panel will examine like-kind exchange
                             transactions in which there is a requirement to
                             defease a conduit loan with a focus on
                             techniques for minimizing taxable “boot.”
AM
                             Moderator: Andrea M. Whiteway, Arnold &
                                        ,
                             Porter LLP Washington, DC. Panelists: David
SATURDAY




                             Shechtman, Drinker Biddle & Reath LLP     ,
                             Philadelphia, PA; Virginia Stevenson, Kennedy
                                                                   ,
                             Covington Lobdell & Hickman LLP Charlotte,
                             NC; Andrea Whiteway, Arnold & Porter LLP      ,
                             Washington, DC.

                 11:00am     1031 Current Development. The panel will
                             discuss recent rulings, cases and other section
                             1031 developments. Panelists: Max Hansen,
                             American Equity Exchange, Dillon, MT;
                             David Shechtman, Drinker Biddle & Reath
                             LLP, Philadelphia, PA; Carlene Miller, Snell &
                             Wilmer, Phoenix, AZ.

           8:30AM - 10:30AM                Atlantic 3, 1st Floor, Convention Ctr
           TRANSFER PRICING
           Chair: David J. Canale, Ernst & Young LLP, Washington, DC
                 8:30am      Tax Provisions and Transfer Pricing:
                             Implications of FIN 48 on Intercompany
                             Transactions. Overview of the financial
                             accounting principles governing uncertain tax
                             positions as those principles apply to transfer
                             pricing, including a discussion of FASB
                             Interpretation No. 48 on the application of
                             FAS 109. The program includes a discussion
                             of practical implications for establishing and
                             removing tax reserves for transfer pricing
                             transactions. Moderator: Dean Jorgensen,
                             Grant Thornton, Washington, DC. Panelists:
                             Steven C. Wrappe, Mayer Brown Rowe &
                             Maw LLP, Washington, DC; Anthony
                             O’Donnell, Schering-Plough, Kenilworth, NJ.

                 9:30am      Management of Corporate Transfer Pricing
                             Issues. In-house transfer pricing professionals
                             will discuss the issues they face in dealing with
                             intercompany transactions. Topics to include
                             planning, documenting for tax and financial
                             statement purposes, defending in multiple


       66
             SATURDAY, JANUARY 20 - AM
                    jurisdictions and how outside advisors can best
                    assist them. Moderator: Clisson Rexford,
                    Akzo-Nobel Inc, Chicago, IL. Panelist:
                    Anthony O’Donnell, Schering-Plough,
                    Kenilworth, NJ.
                                                                          AM
8:30AM - 11:00AM                  Atlantic 1, 1st Floor, Convention Ctr
VAT AND OTHER CONSUMPTION TAXES




                                                                          SATURDAY
Chair: Victoria Perry, International Monetary Fund, Washington, DC
       8:30am       Opening Remarks by the Chair.        CLE


       8:45am       VAT and the US Foreign Tax Credit. This
                    panel will discuss whether VATs can ever be
                    creditable for US tax purposes. The line
                    between income and consumption taxes is
                    unclear, and there have been proposals in
                    various countries suggesting that certain types
                    of VATs are (or can be made to be) creditable.
                    The panel will discuss these proposals and
                    their practical and policy implications.
                    Moderator: Professor Reuven Avi-Yonah,
                    University of Michigan Law School, Ann
                    Arbor, MI. Panelists: Martin B. Tittle, Law
                    Office of Martin B. Tittle, Washington, DC;
                    Philip R. West, Steptoe & Johnson LLP,
                    Washington, DC.

       10:00am      Progressive Consumption Taxes. Could a
                    progressive consumption tax similar to the
                    Flat Tax or the X-tax be implemented using a
                    credit-invoice system similar to those
                    employed in almost all VATs worldwide?
                    What advantages or disadvantages would such
                    a system have relative to the subtraction-
                    method upon which most progressive
                    consumption tax proposals are based? The
                    discussion will focus on the “credit-method X-
                    tax,” and what this alternative highlights about
                    the relative attractions of the credit-method
                    versus the subtraction-method for
                    consumption taxes generally. Moderator:
                    Victoria Perry, International Monetary Fund,
                    Washington, DC. Panelists: Itai Grinberg,
                    Skadden Arps Slate Meagher & Flom LLP,
                    Washington, DC; Yoram Keinan, Ernst &
                    Young LLP, Washington, DC.


                                                                    67
       SATURDAY, JANUARY 20 - AM
           8:30AM - 5:30PM                           Room 205, 1st Floor, Hotel
           VOLUNTEER INCOME TAX (VITA) ON-SITE
           TRAINING CLE
           See p.5 for further details.
           9:00AM - 10:30AM                 Diplomat 2, 1st Floor, Convention Ctr
AM         PRO BONO            CLE
           Chair: Brian P. Trauman, Mayer Brown Rowe & Maw LLP, New
SATURDAY




           York, NY
                  9:00am         Roundtable Discussion. Topics to include (i)
                                 Volunteer Income Tax Assistance for the 2006
                                 taxable year; (ii) Low Income Taxpayer Clinics
                                 and Pro Bono Referral Panels; (iii) Exempt
                                 Organizations; and (iv) Updates to Effective
                                 Representation Before the IRS. Moderator:
                                 Brian P. Trauman, Mayer Brown Rowe &
                                 Maw LLP, New York, NY.

           9:00AM - 10:30AM                 Diplomat 5, 1st Floor, Convention Ctr
           STATE AND LOCAL TAXES PRACTITIONER’S
           ROUNDTABLE CLE (Executive Session)
           9:30AM - 11:30AM                      Room 316, 2nd Floor, Hotel
           SIMPLIFICATION        (Executive Session)
                                  CLE
           Chair: Armando Gomez, Skadden Arps Slate Meagher & Flom
           LLP, Washington, DC
           11:00AM - 12:00PM                       Room 303, 2nd Floor, Hotel
           DISTINGUISHED SERVICE AWARD               CLE (Executive Session)
                                                            ,
           Chair: Richard A. Shaw, Higgs Fletcher & Mack LLP San Diego, CA




       68
             SATURDAY, JANUARY 20 - PM
COMMITTEE LUNCHEON
12:00PM - 12:30PM              Regency 3, 1st Floor, Convention Ctr
STANDARDS OF TAX PRACTICE AND YOUNG
LAWYERS FORUM CLE (Ticketed Event)
12:30PM - 1:30PM               Regency 3, 1st Floor, Convention Ctr
JOINT SESSION OF STANDARDS OF TAX PRACTICE
AND YOUNG LAWYERS FORUM
Practical and Ethical Issues Relating to Opinion Practice,
Summons Enforcement Defense, Shelter Advisor Disclosures
and Circular 230 Compliance. Moderator: Jeffrey H. Paravano,
Baker & Hostetler LLP, Cleveland, OH. Panelists: Katherine E.
David, Oppenheimer Blend Harrison & Tate Inc, San Antonio,            PM
TX; Gregory Lynam, Miller & Chevalier Chartered, Washington,



                                                                      SATURDAY
DC; Paul M. Schmidt, Baker & Hostetler, Washington, DC; Brian
P. Trauman, Mayer Brown Rowe & Maw LLP, New York, NY.
2:00PM - 4:30PM                Regency 1, 1st Floor, Convention Ctr
STANDARDS OF TAX PRACTICE
Chair: Kathryn Keneally, Fulbright & Jaworski LLP, New York, NY
      2:00pm       Opening Remarks by the Chair.      CLE


      2:05pm       Report from the IRS on Ethics Issues.
                   Standards of practice are continuing areas of
                   attention by the IRS. This program will
                   provide a report on the current activities,
                   including the status of Circular 230 and its
                   proposed amendments. Panelists: Stephen A.
                   Whitlock, Acting Director, Office of
                   Professional Responsibility, IRS, Washington,
                   DC; Deborah Butler, Associate Chief Counsel
                   (Procedure & Administration), Office of
                   Chief Counsel, IRS, Washington, DC.

      2:35pm       Report from the Subcommittee on ABA
                   Formal Opinion 346.           Formal Opinion
                   346 (revised) of the ABA Standing Committee
                   on Ethics and Professional Responsibility
                   addresses tax law opinions in tax shelter
                   investment offerings. Last revised in 1982,
                   Formal Opinion 346 predates significant
                   changes to Circular 230, which are in turn
                   subject to ongoing review. This program will
                   provide a report from the subcommittee
                   formed to present the Committee’s proposals
                   for addressing ABA Formal Opinion 346.
                   Speaker: Armando Gomez, Skadden Arps
                   Slate Meagher & Flom LLP, Washington, DC.
                                                                69
       SATURDAY, JANUARY 20 - PM
            2:45pm   The Ethics of Compliance: Return
                     Preparation, Sensitive (Eggshell) Audits, and
                     Voluntary Disclosure.          This panel will
                     examine the tension between provisions
                     under Circular 230 and other ethical
                     principles that would seek to impose a degree
                     of candor in the tax system with the duties of
                     a representative to act in the best interests of
                     the client and to protect client
                     confidentiality. The panelists will focus on
                     the issues that arise in examinations in which
                     the taxpayer and the representative may
PM                   know of a sensitive issue that may escape
                     attention by the revenue agent. The panelists
SATURDAY




                     will also consider the preparer’s or
                     representative’s duty or need to know
                     information, and issues concerning willful
                     blindness. The discussion will also include
                     the considerations in deciding when and how
                     to be forthcoming on a sensitive issue
                     through voluntary disclosure. Moderator:
                     Lawrence S. Horn, Sills Cummis Epstein &
                     Gross PC, Newark, NJ. Panelists: J. Allen
                     Kosowsky, J. Allen Kosowsky PC, Shelton,
                     CT; Scott D. Michel, Caplin & Drysdale
                     Chartered, Washington, DC; Richard J.
                     Sapinski, Sills Cummis Epstein & Gross PC,
                     Newark, NJ.

            3:35pm   The Ethics of Witness Preparation.
                     The conduct of a Transportation Security
                     Administration attorney during the penalty
                     phase proceedings in United States v.
                     Moussaoui highlights a need to review ethical
                     principles governing lawyers as they prepare
                     witnesses to testify. This panel will address
                     the question of when legitimate witness
                     preparation may cross the line and become
                     improper coaching. Panelists will discuss
                     general principles and also will focus on
                     issues arising specifically with respect to
                     expert witnesses, e.g., to what extent may a
                     lawyer suggest actual language for an expert’s
                     written testimony. Moderator: Professor Linda
                     Galler, Hofstra University School of Law,



       70
             SATURDAY, JANUARY 20 - PM
                   Hempstead, NY. Panelists: Donald P. Lan Jr,
                   Kroney Morse Lan PC, Dallas, TX; Brinton
                   Warren, Special Counsel (Administrative
                   Provisions and Judicial Practice), Office of
                   Chief Counsel, IRS, Washington, DC.

2:00PM - 3:30PM                          Room 316, 2nd Floor, Hotel
TECHNOLOGY COMMITTEE               CLE
Chair: Thomas A. Jorgensen, Calfee Halter & Griswold LLP,
Cleveland, OH
      2:00pm       Welcome and Introductions by the Chair.

      2:05pm       What’s New In Technology from the ABA.             PM
                   Speaker: Karen Gee, American Bar



                                                                      SATURDAY
                   Association, Washington, DC.

      2:50pm       Questions on What’s New in Technology
                   from the ABA.

      3:00pm       Open Forum on Technology Issues.




                                                                 71
               SECTION PROGRAMS

                   SATURDAY, JANUARY 20
                   2:00PM - 4:00PM                  Diplomat 1, 1st Floor, Convention Ctr
                   APPLICATION OF FOREIGN TAX CREDIT "LEGAL
                   LIABILITY" RULES TO FACTS RAISED BY FOREIGN
                   CONSOLIDATED GROUP SYSTEMS
                   This program will discuss the foreign tax credit “legal liability”
                   regulations issued under section 901. The panelists will also
                   describe the relevant features of various consolidated group systems
                   outside the US. They will discuss the application of the new
                   regulations to each such consolidated group fact pattern.
                          Moderators: Friedhelm Jacob, Hengeler Mueller, Frankfurt,
                                      Germany

                                       Rebecca Rosenberg, Caplin & Drysdale
                                       Chartered, Washington, DC
SECTION PROGRAMS




                          Panelists:   Professor Reuven Avi-Yonah, University of
                                       Michigan Law School, Ann Arbor, MI

                                       Bethany Ingwalson, Senior Counsel, Branch 3,
                                       Office of Associate Chief Counsel
                                       (International), Washington, DC

                                       Andrea Silvestri, Bonelli Erede Pappalardo,
                                       Rome, Italy

                          Sponsored by: Foreign Activities of US Taxpayers and
                                        Foreign Lawyers Forum

                   2:00PM - 5:00PM                  Regency 2, 1st Floor, Convention Ctr
                   CURRENT DEVELOPMENTS IN INDIVIDUAL,
                   CORPORATE, PARTNERSHIP, AND ESTATE & GIFT
                   TAXATION
                   A review of the most significant court decisions, rulings and
                   statutory and regulatory developments during the past 12 months.
                          Moderator: Professor Ira B. Shepard, University of
                                     Houston Law Center, Houston, TX

                          Panelists:   Professor James A. Delaney, University of
                                       Wyoming College of Law, Laramie, WY

                                       Professor Martin J. McMahon Jr, University
                                       of Florida Fredric G. Levin College of Law,
                                       Gainesville, FL
                          Sponsored by: Teaching Taxation

               72
                            SECTION PROGRAMS
2:00PM - 3:00PM                 Grand West, 1st Floor, Convention Ctr
DO YOU KNOW WHERE YOUR STOCK PLAN IS?
A COMPLIANCE REVIEW FOR STOCK PLANS
The panel will discuss the tax, corporate, securities, SOX and other
issues that should be reviewed for a stock or other incentive plan.
It will discuss approaching the issues raised in a compliance review.
                                                      ,
       Moderator: Priscilla E. Ryan, Sidley Austin LLP Chicago, IL

       Panelists:    William F. Colgin Jr, Morgan Lewis &
                     Bockius LLP, Palo Alto, CA

                     Tim England, Assistant Director of
                     Enforcement, United States Securities
                     Exchange Commission, Washington, DC

                     Kristin Graham Koehler, Sidley Austin LLP,
                     Washington, DC
                                                                         SECTION PROGRAMS
                     William C. Schmidt, Compensation Branch
                     Senior Counsel, Office of Chief Counsel, IRS,
                     Washington, DC

       Sponsored by: Employee Benefits

2:00PM - 4:00PM                  Diplomat 2, 1st Floor, Convention Ctr
OPINIONS AND PENALTIES
This timely program will explore the use of opinion letters for
penalty protection at the administrative level, especially in IRS
Appeals, and in litigation. Panelists will discuss when opinions may
be used for penalty protection, covering the recent changes to
section 6664 and new section 6662A, the changes to Circular 230,
and Long Term Capital and other recent cases.
       Moderators: Joshua D. Odintz, McDermott Will & Emery
                   LLP, Washington, DC

                     Cary D. Pugh, Skadden Arps Slate Meagher
                     & Flom LLP, Washington, DC

       Panelists:    Emily Parker, Thompson & Knight LLP,
                     Dallas, TX

                     Peter Reilly, Special Counsel, Branch 3, Office
                     of Chief Counsel, IRS, Washington, DC




                                                                   73
               SECTION PROGRAMS
                                       Diane Ryan, Director -Technical Services,
                                       Office of Appeals, IRS, Washington, DC

                                       Gary Wilcox, Morgan Lewis & Bockius LLP,
                                       Washington, DC

                          Sponsored by: Court Procedure & Practice and
                                       Administrative Practice

                   2:00PM - 4:00PM                 Diplomat 4, 1st Floor, Convention Ctr
                   REEXAMINING SECTION 197 - PRACTICAL AND
                   TECHNICAL ISSUES
                   The enactment of section 197 in 1993 revolutionized the world of
                   mergers and acquisitions by permitting, for the first time, the
                   amortization of goodwill, going concern value, and other business
                   intangible assets. Comprehensive final regulations were issued in
                   2000, but seven years of experience with the final regulations
                   indicate that important issues remain unresolved. This program
                   will discuss some of the more common issues encountered in this
SECTION PROGRAMS




                   area, including the anti-churning rules, loss disallowance rules,
                   section 197 exclusions, and the application of section 197 to
                   specific corporate and partnership transactions. Planning ideas and
                   potential solutions to these common issues will also be discussed.
                          Moderator: Kevin D. Anderson, Washington, DC

                          Panelists:   Richard Blumenreich, KPMG LLP,
                                       Washington, DC

                                       Kim Golightly, Ernst & Young LLP,
                                       Washington, DC

                                       Kathleen Reed, Senior Technician Reviewer,
                                       Office of Associate Chief Counsel
                                       (Passthroughs and Special Industries), IRS,
                                       Washington, DC

                          Sponsored by: Capital Recovery and Leasing Committee




               74
            AFFILIATED ORGANIZATIONS
AMERICAN COLLEGE OF
TAX COUNSEL

SATURDAY, JANUARY 20
7:30AM - 9:30AM                 Room 303, 2nd Floor, Hotel
ACTC BOARD OF REGENTS MEETING (Executive Session)
5:30PM - 6:00PM          Atlantic 3, 1st Floor, Convention Ctr
ACTC ANNUAL BUSINESS MEETING (ACTC Members
only)
6:00PM - 7:00PM          Atlantic 3, 1st Floor, Convention Ctr
2006 GRISWOLD LECTURE (Open Session)
By: Pamela F. Olson



SUNDAY, JANUARY 21
7:30AM - 8:30AM                 Room 307, 2nd Floor, Hotel
CONTINENTAL BREAKFAST (ACTC Members only)
                                                                 AFFILIATED ORGANIZATIONS




8:30AM - 9:30AM                 Room 307, 2nd Floor, Hotel
PANEL DISCUSSION (ACTC Members only)




                                                           75
             ALPHA SCHEDULE
ALPHA SCHEDULE




                          = Taped
                          = Young Lawyers Program
                          = Ethics Credit Requested
                    CLE   = No CLE Credit

                 The      symbol indicates that the program is being audio-taped; the
                 indicates that the program would appeal to young lawyers; the      indicates that
                 ethics has been requested for this program; the CLE indicates that this program
                 is not eligible for CLE credit.

                 COMMTTEE NAME                 DAY TIME              LOCATION

                 ACTC Board of Regents CLE Sat.       7:30a-9:30a    Room 303, 2nd Floor, Hotel
                 (Executive Session)

                 Administrative Practice       Fri.8:30a-11:30a Atlantic 1, 1st Floor,
                                                                Convention Ctr
                 Dinner CLE (Invitation Only) Thu. 6:30p-10:00p Chef Allen’s Restaurant
                 Luncheon CLE (Ticketed)       Fri.   12:30p-1:30p Great Hall 5, 2nd Floor,
                                                                   Convention Ctr

                 Affiliated & Related          Fri.   8:30a-11:30a Atlantic 2, 1st Floor,
                 Corporations                                      Convention Ctr
                 Luncheon CLE (Ticketed)       Fri.   12:00p-1:30p Great Hall 1, 2nd Floor,
                                                                   Convention Ctr

                 Appointments to the Tax       Fri.   11:30a-12:30p Room 219, 1st Floor, Hotel
                 Court CLE (Executive Session)

                 Banking and Savings           Fri.   8:30a-11:30a Atlantic 3, 1st Floor,
                 Institutions                                      Convention Ctr
                 Luncheon CLE (Ticketed)       Fri.   12:30p-2:00p Great Hall 6, 2nd Floor,
                                                                   Convention Ctr

                 Bankruptcy &                  Fri.   2:30p-5:30p    Diplomat 4, 1st Floor,
                 Workouts                                            Convention Ctr

                 Business Cooperatives         NOT MEETING
                 & Agriculture
                 Luncheon CLE (Ticketed)       Fri.   12:30p-1:30p Room 318, 2nd Floor, Hotel

                 Capital Recovery & Leasing    Sat.   7:00a-9:00a    Great Hall 2, 2nd Floor,
                                                                     Convention Ctr

                 Civil and Criminal Tax        Sat.   8:30a-11:30a Regency 1, 1st Floor,
                 Penalties                                         Convention Ctr
                 Luncheon CLE (Ticketed)       Fri.   12:30p-1:30p Diplomat 3, 1st Floor,
                                                                   Convention Ctr




             76
                                           ALPHA SCHEDULE
Closely Held Businesses         Fri.   2:30p-6:00p  Diplomat 3, 1st Floor,




                                                                                   ALPHA SCHEDULE
                                                    Convention Ctr
Joint Meeting                   Fri.   8:30a-11:30a Diplomat 3, 1st Floor,
                                                    Convention Ctr
Planning Meeting CLE            Fri.   5:30p-6:00p Diplomat 3, 1st Floor,
                                                    Convention Ctr
Committee Chairs,         Sat.         7:30a-8:15a Regency 3, 1st Floor,
Vice Chairs, Officers                               Convention Ctr
and Council Breakfast CLE

Committees                      NOT MEETING

Companions’ Breakfast CLE Fri.         8:00a-9:00a    Satine Restaurant, Lobby
(Complimentary)                                       Level, Hotel

Companions’ Activities:
Tour & Luncheon CLE             Fri.   9:00a-3:00p
(Ticketed)
Tour CLE (Ticketed)             Sat.   8:30a-12:30p

Corporate Tax                   Sat.   8:30a-11:45a Regency 2, 1st Floor,
                                                    Convention Ctr
Luncheon CLE (Ticketed)         Fri.   12:00p-1:30p Great Hall 1, 2nd Floor,
                                                    Convention Ctr

Court Procedure & Practice      Fri.   2:30p-5:30p  Grand East, 1st Floor,
                                                    Convention Ctr
Luncheon CLE (Ticketed)         Fri.   12:30p-1:30p Great Hall 5, 2nd Floor,
                                                    Convention Ctr
Officers & Subcommittee Sat.           7:45a-9:00a Room 307, 2nd Floor, Hotel
Chairs Breakfast CLE (Ticketed)

Distinguished Service         Sat.     11:00a-12:00p Room 303, 2nd Floor, Hotel
Award CLE (Executive Session)

Diversity                       Fri.   4:00p-6:30p    Room 312&313, 2nd Floor,
                                                      Hotel
Reception       CLE             Fri.   5:30p-6:30p    Room 314, 2nd Floor, Hotel

Employee Benefits               Fri.   2:30p-6:30p  Grand West, 1st Floor,
                                                    Convention Ctr
                                Sat.   8:30a-11:30a Grand West, 1st Floor,
                                                    Convention Ctr
Young Lawyers Forum       CLE   Fri.   1:15p-2:15p Room 302, 2nd Floor, Hotel
Reception/Cash Bar CLE          Fri.   5:35p-6:30p    Grand West, 1st Floor,
                                                      Convention Ctr

Employee Benefits Subcommittees and Task Force Update Programs:
COBRA and Welfare Plan Fri. 8:45a-10:30a Room 301, 2nd Floor, Hotel
Design Issues; HIPPA; State
Insurance Regulation of Welfare Plans;
Cafeteria Plans and Flexible Benefits; Retiree
Health, VEBAs & Other Funding Vehicles



                                                                                 77
             ALPHA SCHEDULE
                 Corporate Counsel Forum        Fri.   12:15p-1:15p Room 312, 2nd Floor, Hotel
ALPHA SCHEDULE




                 Distributions; QDROs,        Fri.     1:15p-2:25p   Room 305, 2nd Floor, Hotel
                 QMSCOs, Other Domestic
                 Relations Benefits Issues;
                 and Estate & Gift Tax Issues

                 EEOC & FMLA Issues;            Fri.   1:15p-2:15p   Room 320, 2nd Floor, Hotel
                 USERRA, Military
                 And Other Leaves

                 Employee and Independent Fri. 12:00p-1:15p Room 305, 2nd Floor, Hotel
                 Contractor Status; Controlled
                 Groups, Affiliated Service Groups
                 & Leased Employees

                 ESOPs                          Fri.   9:00a-10:00a Room 312, 2nd Floor, Hotel

                 Executive Compensation        Fri. 8:45a-10:30a Room 307, 2nd Floor, Hotel
                 and Federal Securities Laws Issues

                 Fiduciary Responsibility;      Fri.   10:30a-12:15p Room 303, 2nd Floor, Hotel
                 Litigation; and ESOPs

                 Foreign & International Issues Fri.   11:15a-12:15p Room 316, 2nd Floor, Hotel

                 Fringe Benefits                Fri.   11:15a-12:15p Room 302, 2nd Floor, Hotel

                 Government Plans; Section Fri.        1:15p-2:25p   Room 317, 2nd Floor, Hotel
                 457 Issues; and Section
                 403(b) & EO Issues

                 IRAs                           Fri.   10:30a-12:15p Room 312, 2nd Floor, Hotel

                 Mergers & Acquisitions         Fri.   1:15p-2:25p   Room 303, 2nd Floor, Hotel

                 Nondiscrimination &            Fri.   1:15p-2:15p   Room 312, 2nd Floor, Hotel
                 Section 415 Issues

                 Pension Legislation; Pension Fri.     1:15p-2:15p   Room 301, 2nd Floor, Hotel
                 Simplification Task Force;
                 and Enron Task Force

                 Qualified Cash or Deferred Fri.       10:30a-12:15p Room 307, 2nd Floor, Hotel
                 Arrangements

                 Self-Corrections & Other Fri. 8:45a-10:30a Room 314, 2nd Floor, Hotel
                 Administrative Practices;
                 Master, Prototype and Volume
                 Submitter Plans and Determination
                 Letter Task Force




             78
                                          ALPHA SCHEDULE
Special Defined Benefit Plan Sat.     7:00a-8:15a   Diplomat 1, 1st Floor,




                                                                                 ALPHA SCHEDULE
Issues; Cash Balance Plan                           Convention Ctr
Task Force

Task Force on Electronic       Fri.   12:15p-1:15p Room 302, 2nd Floor, Hotel
Plan Administration

Employment Taxes               Fri.   1:30p-5:30p   Diplomat 2, 1st Floor,
                                                    Convention Ctr
Practitioners Workshop         Fri.   4:15p-5:30p   Diplomat 2, 1st Floor,
(not taped)                                         Convention Ctr

Energy & Environmental         NOT MEETING
Taxes

Estate & Gift Taxes            Fri.   8:30a-11:30a Diplomat 1, 1st Floor,
                                                   Convention Ctr
Luncheon CLE (Ticketed)        Fri.   12:30p-1:30p Atlantic 3, 1st Floor,
                                                   Convention Ctr
Young Lawyers                  Fri.   1:30p-2:30p Room 308, 2nd Floor, Hotel
Subcommittee       CLE


Exempt Organizations           Fri.   8:45a-4:15p  Regency 2, 1st Floor,
                                                   Convention Ctr
Cash Bar CLE                   Fri.   4:15p-4:30p Regency 2, 1st Floor,
                                                   Convention Ctr
Luncheon CLE (Ticketed)        Fri.   12:15p-1:15p Regency 2, 1st Floor,
                                                   Convention Ctr

Exempt Organizations Subcommittees:
Audits and Appeals        Fri. 7:30a-8:30a          Room 220, 1st Floor, Hotel

Health Care Organizations Fri.        7:30a-8:30a   Room 301, 2nd Floor, Hotel

Private Foundations; Unrelated Fri.   7:30a-8:30a   Room 314, 2nd Floor, Hotel
Business Income; and
International Philanthropy

Fiduciary Income Tax           Sat.   8:30a-11:30a Diplomat 1, 1st Floor,
                                                   Convention Ctr
Luncheon CLE (Ticketed)        Fri.   12:30p-1:30p Atlantic 3, 1st Floor,
                                                   Convention Ctr
Young Lawyers                  Fri.   1:30p-2:30p Room 308, 2nd Floor, Hotel
Subcommittee       CLE


Financial Transactions         Fri.   2:30p-5:30p  Atlantic 3, 1st Floor,
                                                   Convention Ctr
Luncheon CLE (Ticketed)        Fri.   12:30p-2:00p Great Hall 6, 2nd Floor,
                                                   Convention Ctr




                                                                              79
             ALPHA SCHEDULE
                 Foreign Activities of US   Fri.   8:30a-10:30a Regency 3, 1st Floor,
ALPHA SCHEDULE




                 Taxpayers                                       Convention Ctr
                 Joint Program              Fri.   10:30a-12:00p Regency 3, 1st Floor,
                                                                 Convention Ctr
                 Luncheon/Business          Fri.   12:00p-1:30p Grand West, 1st Floor,
                 Meeting CLE (Ticketed)                          Convention Ctr

                 Foreign Lawyers Forum      Fri.   1:30p-3:30p   Regency 3, 1st Floor,
                                                                 Convention Ctr
                 Business Meeting CLE       Fri.   5:30p-6:30p   Room 305, 2nd Floor, Hotel

                 Formation of Tax Policy    Fri.   8:30a-11:30a Diplomat 4, 1st Floor,
                                                                Convention Ctr

                 Golf Outing (Ticketed)     Thu. 7:30a-1:00p     Diplomat Country Club

                 Government Relations       NOT MEETING

                 Government Submissions     NOT MEETING

                 Important Developments     Fri.   11:00a-12:00p Room 301, 2nd Floor, Hotel
                 Workshop CLE

                 Individual & Family        Fri.   8:45a-11:45a Diplomat 5, 1st Floor,
                 Taxation                                       Convention Ctr

                 Insurance Companies        Fri.   2:30p-5:30p Room 307, 2nd Floor, Hotel
                 Luncheon CLE (Ticketed)    Fri.   12:30p-2:00p Great Hall 6, 2nd Floor,
                                                                Convention Ctr

                 Investment Companies       Fri.   9:30a-12:30p Diplomat 2, 1st Floor,
                                                                Convention Ctr
                 Luncheon CLE (Ticketed)    Fri.   12:30p-2:00p Great Hall 6, 2nd Floor,
                                                                Convention Ctr

                 Low Income Taxpayers       Sat.   7:00a-9:00a   Diplomat 2, 1st Floor,
                                                                 Convention Ctr
                 Low Income Taxpayer        Thu. 1:00p-6:15p     Diplomat 1, 1st Floor,
                 Clinic Workshop                                 Convention Ctr
                 (Registration Required)
                 Reception CLE              Thu. 6:15p           Diplomat 2, 1st Floor,
                                                                 Convention Ctr

                 Membership                 Fri.   12:00p-1:00p Room 320, 2nd Floor, Hotel
                 & Marketing CLE

                 NewsQuarterly Editorial Board NOT MEETING

                 Nominating CLE             Fri.   2:00p-5:00p   Room 220, 1st Floor, Hotel
                 (Executive Session)




             80
                                              ALPHA SCHEDULE
Officers and Council          Thu. 8:30a-5:00p          Diplomat 3, 1st Floor,




                                                                                     ALPHA SCHEDULE
Meeting CLE (Executive Session)                         Convention Ctr

Partnerships & LLCs               8:30a-11:30a Great Hall 5, 2nd Floor,
                                   Fri.
                                               Convention Ctr
Breakfast  CLE (Ticketed) Sat. 7:15a-8:30a     Diplomat 3, 1st Floor,
                                               Convention Ctr
Dinner    CLE (Reservations) Thu. 6:30p-9:30p Giorgio’s Grill
LLC Subcommittee             Sat. 8:30a-10:30a Room 312, 2nd Floor, Hotel
Luncheon    CLE (Ticketed) Fri. 12:30p-1:30p Grand East, 1st Floor,
                                               Convention Ctr

Patenting Tax Strategies Task Force                     NOT MEETING

Pro Bono        CLE                Sat. 9:00a-10:30a Diplomat 2, 1st Floor,
                                                     Convention Ctr
Low Income Taxpayer                Thu. 1:00p-6:15p Diplomat 1, 1st Floor,
Clinic Workshop                                      Convention Ctr
(Registration Required)

Professional Services CLE          Fri.   5:00p-6:00p   Room 302, 2nd Floor, Hotel

Programs & Meetings CLE Fri.              5:00p-6:00p   Room 219, 1st Floor, Hotel

Real Estate                        Fri.   2:30p-5:30p   Great Hall 5, 2nd Floor,
                                                        Convention Ctr
Breakfast      CLE (Ticketed)      Sat.   7:15a-8:30a   Diplomat 3, 1st Floor,
                                                        Convention Ctr
Dinner        CLE (Reservations)   Thu. 6:30p-9:30p     Giorgio’s Grill
Luncheon        CLE (Ticketed)     Fri.   12:30p-1:30p Grand East, 1st Floor,
                                                       Convention Ctr

Resolutions                        NOT MEETING

S Corporations                     Fri.   2:00p-5:30p   Atlantic 2, 1st Floor,
                                                        Convention Ctr
Breakfast      CLE (Ticketed)      Sat.   7:15a-8:30a   Diplomat 3, 1st Floor,
                                                        Convention Ctr

Sales, Exchanges and Basis         Sat.   8:30a-11:45a Atlantic 2, 1st Floor,
                                                       Convention Ctr
Breakfast CLE                      Sat.   7:30a-8:30a Diplomat 5, 1st Floor,
                                                       Convention Ctr

Section Breakfast/           Fri.         7:15a-8:30a   Grand East, 1st Floor,
Plenary       CLE (Ticketed)                            Convention Ctr

Section Reception/                 Fri.   6:30p-8:00p   Great Hall 1&2, 2nd Floor,
Plenary CLE (Ticketed)                                  Convention Ctr

Simplification CLE                 Sat.   9:30a-11:30a Room 316, 2nd Floor, Hotel
(Executive Session)




                                                                                   81
             ALPHA SCHEDULE
                 Special Projects                 NOT MEETING
ALPHA SCHEDULE




                 Sponsorships CLE                 Fri. 1:00p-2:00p     Room 219, 1st Floor, Hotel

                 Standards of Tax                 Sat.   2:00p-4:30p  Regency 1, 1st Floor,
                 Practice                                             Convention Ctr
                 Joint Meeting                    Sat.   12:30p-1:30p Regency 3, 1st Floor,
                                                                      Convention Ctr
                 Luncheon        CLE (Ticketed)   Sat.   12:00p-12:30pRegency 3, 1st Floor,
                                                                      Convention Ctr

                 State and Local Taxes            Fri.   2:30p-5:30p   Regency 1, 1st Floor,
                                                                       Convention Ctr
                 A Review of Current State Fri. 1:00p-1:30p            Regency 1, 1st Floor,
                 Tax Decisions                                         Convention Ctr
                 Cash Bar & Executive          Thu. 6:30p-10:00p
                 Business Meeting
                 Dinner CLE (Executive Session)
                 Joint Meeting                 Fri. 8:30a-11:30a Diplomat 3, 1st Floor,
                                                                 Convention Ctr
                 Luncheon CLE (Ticketed)       Fri. 12:30p-1:00p Regency 1, 1st Floor,
                                                                 Convention Ctr
                 Practitioners’ Roundtable CLE Sat. 9:00a-10:30a Diplomat 5, 1st Floor,
                 (Executive Session)                             Convention Ctr
                 State & Local Tax Lawyer CLE Fri. 12:00p-12:30pRoom 220, 1st Floor, Hotel

                 Tax Accounting                   Fri.   2:30p-5:30p   Diplomat 1, 1st Floor,
                                                                       Convention Ctr

                 Tax Exempt Financing             Fri.   2:30p-5:30p  Atlantic 1, 1st Floor,
                                                                      Convention Ctr
                 Luncheon CLE (Ticketed)          Fri.   12:30p-2:00p Great Hall 6, 2nd Floor,
                                                                      Convention Ctr

                 Tax Practice Management          Sat.   7:00a-8:30a   Diplomat 4, 1st Floor,
                                                                       Convention Ctr

                 Tax Shelters CLE                 Fri.   11:00a-1:00p Room 317, 2nd Floor, Hotel

                 Teaching Taxation                Fri.   1:30p-3:00p   Diplomat 5, 1st Floor,
                                                                       Convention Ctr

                 Technology Committee CLE Sat.           2:00p-3:30p   Room 316, 2nd Floor, Hotel

                 The Tax Lawyer                   NOT MEETING

                 Transfer Pricing                 Sat.   8:30a-10:30a Atlantic 3, 1st Floor,
                                                                       Convention Ctr
                 Joint Program                    Fri.   10:30a-12:00p Regency 3, 1st
                                                                       Floor, Convention Ctr
                 Luncheon CLE (Ticketed)          Fri.   12:30p-1:30p Diplomat 4, 1st Floor,
                                                                       Convention Ctr




             82
                                            ALPHA SCHEDULE
US Activities of Foreigners     Fri.    3:30p-5:30p   Regency 3, 1st Floor,




                                                                                   ALPHA SCHEDULE
& Tax Treaties                                        Convention Ctr
Joint Program                   Fri.    10:30a-12:00p Regency 3, 1st Floor,
                                                      Convention Ctr
Luncheon CLE (Ticketed)         Fri.    12:30p-1:30p Diplomat 1, 1st Floor,
                                                      Convention Ctr

VAT & Other                     Sat.    8:30a-11:00a Atlantic 1, 1st Floor,
Consumption Taxes                                    Convention Ctr

VITA Training         CLE       Fri.    8:30a-5:30p   Room 205, 1st Floor, Hotel
                                Sat.    8:30a-5:30p   Room 205, 1st Floor, Hotel

Young Lawyers Forum             Fri.    4:00p-6:30p   Room 312&313, 2nd Floor,
                                                      Hotel
2006 Law Student Tax Challenge              CLE
Semi-Final Rounds             Fri.      9:00a-12:00p Room 212-214, 1st Floor,
(Open to Public)                                     Hotel
Final Rounds (Open to Public) Fri.      1:00p-4:00p Room 212-214, 1st Floor,
                                                     Hotel
Joint Meeting                   Sat.    12:30p-1:30p Regency 3, 1st Floor,
                                                     Convention Ctr
Luncheon        CLE   (Ticketed) Sat.   12:00p-12:30pRegency 3, 1st Floor,
                                                     Convention Ctr
Orientation      CLE            Fri.    7:00a-7:30a Room 307, 2nd Floor, Hotel
Reception       CLE             Fri.    5:30p-6:30p Room 314, 2nd Floor, Hotel

SECTION PROGRAMS
Application of Foreign Tax Sat.         2:00p-4:00p   Diplomat 1, 1st Floor,
Credit “Legal Liability”                              Convention Ctr
Rules to Facts Raised by
Foreign Consolidated
Group Systems

Current Developments in Sat. 2:00p-5:00p              Regency 2, 1st Floor,
Individual, Corporate, Partnership,                   Convention Ctr
and Estate & Gift Taxation

Do You Know Where Your Sat.             2:00p-3:00p   Grand West, 1st Floor,
Stock Plan Is? A Compliance                           Convention Ctr
Review For Stock Plans

Opinions and Penalties          Sat.    2:00p-4:00p   Diplomat 2, 1st Floor,
                                                      Convention Ctr

Reexamining Section 197         Sat.    2:00p-4:00p   Diplomat 4, 1st Floor,
— Practical and                                       Convention Ctr
Technical Issues




                                                                               83
    NOTES
NOTES




    84
NOTES




    NOTES




   85
FUTURE MEETINGS
SECTION OF TAXATION
Please check for updates and additional information on the Tax
Section website at www.abanet.org/tax or the ABA CLE website
at www.abanet.org/cle


Advanced Income Tax Seminar
March 5 – 6
The Ritz Carlton, New Orleans, LA
(Co-Sponsored with IPT)



Advanced Sales/Use Tax Seminar
March 6 – 7
The Ritz Carlton, New Orleans, LA
(Co-Sponsored with IPT)



Advanced Property Tax Seminar
March 8 – 9
The Ritz Carlton, New Orleans, LA
(Co-Sponsored with IPT)



7th Annual Tax Planning Strategies – US & Europe
April 19 – 20
Deutsche Bank, Frankfurt, Germany
(Co-Sponsored with IBA, IFA – Germany)



May Meeting
May 10 – 12
Grand Hyatt, Washington, DC


Joint Fall CLE Meeting
September 27 – 29
Hyatt Regency/Fairmont, Vancouver, British Columbia
(Co-Sponsored with RPPT)
SECTION OF TAXATION
AMERICAN BAR ASSOCIATION
740 15TH STREET, NW
WASHINGTON, DC 20005




VISIT THE TAX SECTION’S WEBSITE AT:
www.abanet.org/tax/
Your source for important Tax Section
information, including:

I   Section NewsQuarterly and The Tax Lawyer Online

I   News about upcoming Section Meetings and online
    registration

I   Recent Government Submissions and Testimony

I   Comm-Online (online, searchable database of
    committee program materials)

I   Membership Directory

I   Extensive links to other helpful tax sites

								
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