brochure for the Fall 2005 Meeting by fsb96139

VIEWS: 9 PAGES: 48

									                              THURSDAY, SEPTEMBER 15
                              LOW INCOME TAXPAYER CLINICS
                              WORKSHOP, 1:00PM - 6:00PM

                              FRIDAY, SEPTEMBER 16
                              JOINT SECTION BREAKFAST, 7:30AM
                              I   SPEAKER: JOSEPH BANKMAN,
                                  RALPH M. PARSONS PROFESSOR OF LAW
                                  AND BUSINESS, STANFORD LAW SCHOOL,
                                  STANFORD, CA
                                  TOPIC: TAX SHELTERS

                              SATURDAY, SEPTEMBER 17
                              SECTION PROGRAMS
                              I   ASSIGNMENT AND SUBLEASING
                                  ROUNDTABLE WORKSHOP
                              I   BUY-SELL AGREEMENTS AND RELATED TAX
                                  ISSUES FOR CLOSELY HELD BUSINESSES
                              I   CURRENT FIDUCIARY AND LITIGATION
                                  ISSUES
                              I   USING LIMITED LIABILITY COMPANIES TO
                                  AVOID LAND LOSS
                              I   TRANSACTION COSTS: TO CAPITALIZE
                                  OR NOT TO CAPITALIZE — IS THERE A
                                  QUESTION?
                              I   VAPOR INTRUSION: DEFINING AND
                                  MANAGING RISKS IN PROPERTY
                                  OWNERSHIP, MANAGEMENT,
                                  REDEVELOPMENT AND USE




For complete program descriptions, visit the Meeting website at
http://meetings.abanet.org/meeting/tax/FALL05


PRELIMINARY PROGRAM
                 The American Bar Association
 Sections of Taxation and Real Property, Probate and Trust Law
Would like to acknowledge the support of our sponsors for their
                       Involvement in the

2005 JOINT FALL CLE MEETING
                              GOLD



             Primary Legal Publishing Sponsor of the
                    ABA Section of Taxation




                             SILVER




                     Taggart
                    & Hawkins
                   A Professional Corporation




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

Activities ....................................................................5

Programs for Young Lawyers.........................................6

Program Schedule .......................................................8

 Thursday, September 15 ..............................................8

 Friday, September 16.................................................10

 Saturday, September 17..............................................23

Alpha Schedule...........................................................31

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




                                                                       San Francisco, CA welcomes the
                                                                       Section of Taxation and the
                                                                       Section of Real Property, Probate
                                                                       & Trust Law to the 2005 Joint
                                                                       Fall CLE Meeting, September
                                                                       15th - 17th. Join us and take
                                                                       advantage of the opportunity to
                          Dennis B. Drapkin       Kevin L. Shepherd    meet with the country’s leading
                           Tax Section Chair      RPPT Section Chair   attorneys and government officials
                                                                       to discuss the latest federal tax
                      policies, initiatives, regulations, legislative forecasts, planning ideas, and
                      network with members of both ABA Sections. The Hyatt Regency will serve
                      as the Headquarters Hotel.

                                             JOINT SECTION BREAKFAST WITH PROFESSOR
                                             JOSEPH BANKMAN
                                                The Sections are pleased to announce that Professor
                                                Joseph Bankman will speak to the attendees of the
                                                2005 Joint Fall CLE Meeting. All Meeting attendees
                                                are invited to attend this complimentary breakfast that
                                                will be held on Friday, September 16 at 7:30am at the
                       Professor Joseph Bankman Hyatt Regency. Although the breakfast is
                          Stanford Law School
                                                complimentary, it will be a ticketed event and attendees
                      must register to attend using the Meeting Registration and Ticket Purchase
                      Form, which can be found in the back of this Preliminary Program, or visit
                      the Meeting website at http://meetings.abanet.org/meeting/tax/FALL05.
                      Please note, tickets to the breakfast will not be available on-site.


                      REGISTRATION
                      Any individual attending any part of the 2005 Joint Fall CLE 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 is applicable.
                      The Sections are pleased to offer a discount to early bird registrants. A
                      completed registration form along with full payment must be postmarked,
                      faxed or submitted on-line by August 11, 2005 to qualify for the early bird
                      registration fee. Registrations will be accepted after the August 11th deadline
                      (until September 8, 2005); however, they will be automatically processed at
                      the higher registration fee.
                      The final deadline for advanced registration is September 8, 2005. A
                      completed registration form along with full payment must be received by
                      September 8th to be pre-registered. Registrations received after the
                      September 8, 2005 final deadline will be returned to the registrant and the
                      registrant will be required to register on-site. Please note that all registrants
                      including those who register between August 11 and September 8, 2005 will
                      pick up their badge and meeting materials at the advanced registration area
                      at the Hyatt Regency.
                      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. No registration will be processed or considered
                      received unless payment is included.




                 2                                For complete program descriptions, visit the Meeting website at
                                                               http://meetings.abanet.org/meeting/tax/FALL05
                                             GENERAL INFORMATION




                                                                                   GENERAL INFORMATION
ON-LINE REGISTRATION
Please use the following link to register on-line:
http://meetings.abanet.org/meeting/tax/FALL05

MEETING REGISTRATION FEE WAIVED
The 2005 Joint Fall CLE Meeting registration fee will be waived for full-
time law students, LLM and MT candidates. Meeting benefits include
Continuing Legal Education (CLE) programs, legal publications, professional
development, networking and access to up-to-date information.

REFUND POLICY
All cancellations and refund requests must have been received in writing and
postmarked, faxed or emailed by August 25, 2005 to receive a refund. All
refund requests will incur a $50 cancellation fee. Please direct all refund
requests to the Meeting Registrar at the Tax Section Office.

ON-SITE REGISTRATION AND TICKET PURCHASE HOURS
The Registration Desk will be open at the Meeting during the following
hours:
Thursday 12:00pm - 7:30pm
Friday      6:30am - 6:30pm
Saturday 6:30am - 2:00pm


TRAVEL INFORMATION
To make airline reservations with ABA preferred airlines, contact:
American Airlines 1-800-433-1790
                  Reference: 17715
Delta                    1-800-241-6760
                         Reference: 207843A
US Airways               1-877-874-7687
                         Reference: 65163236
For car rental, ABA members can receive special rates through Hertz:
Hertz                    1-800-654-2230; TDD 1-800-654-2280
                         Reference: 13000
ABA Membership ID required at the time of rental.


HOTEL RESERVATIONS
The Hyatt Regency will serve as the Headquarters Hotel for the 2005 Joint
Fall CLE Meeting. A small block of rooms has also been reserved at the Park
Hyatt San Francisco, within walking distance of the Headquarters Hotel. The
Hotel Reservation Form is located in the back of this Preliminary Program, or
visit the Meeting website at http://meetings.abanet.org/meeting/tax/FALL05.
To make hotel reservations on-line, please visit the hotel website at
https://resweb.passkey.com/ Resweb.do?mode=welcome_ei_new&
eventID=21619. The deadline for room reservations is Friday, August 5,
2005. Neither room availability nor room rates can be guaranteed after
the August 5th deadline. The Hotel Reservation Form MUST be sent
directly to the hotel; NOT returned to the Section Offices.

DRESS CASUAL
The dress for the 2005 Joint Fall CLE Meeting is business casual, so relax
and bring comfortable attire.


For complete program descriptions, visit the Meeting website at                3
http://meetings.abanet.org/meeting/tax/FALL05
                 GENERAL INFORMATION
GENERAL INFORMATION




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

                      VIRTUALLY PAPERLESS MEETING
                      Sponsored by:

                                      Primary Legal Publishing Sponsor of
                                          the ABA Section of Taxation

                      All Meeting Materials will be available at the 2005 Joint Fall CLE Meeting
                      on CD-ROM in PDF format. These materials will also be made available to
                      meeting registrants on the Meeting website in advance of the meeting. Finally,
                      should you wish to print out any materials at the meeting site, convenient
                      stations will be provided by LexisNexisTM, Primary Legal Publishing Sponsor
                      of the ABA Section of Taxation.
                      Please note that Materials not provided in advance to the Sections will be
                      available in hard copy on-site and will not be on the CD-ROM. These
                      materials, to the extent they are provided to the Sections, and those included
                      on the Meeting Materials CD, will also be made available following the
                      meeting on the Tax Section’s website 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
                      Program 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 will be requested for this meeting
                      from every state with mandatory continuing legal education (MCLE)
                      requirements for lawyers. Please note 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.

                      AUDIO TAPES/AUDIO CDS
                      Audiocassette tapes and Audio CDs of Programs will be available for purchase.


                      JOINT SECTION RECEPTION
                      The Joint Section Reception, will take place on Friday, September 16th, from
                      6:30pm - 8:00pm.

                      HOSPITALITY 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.

                      EXHIBIT
                      The Exhibit will take place on Friday and Saturday. Representatives from a
                      variety of publishers and service providers will demonstrate the latest research
                      methods and exciting new products to aid in your daily practice.

                      PROGRAM SCHEDULE
                      For the complete 2005 Joint Fall CLE Meeting Program Schedule,
                      including dates and times, visit the Meeting website at
                      http://meetings.abanet.org/meeting/tax/FALL05.




                 4                                For complete program descriptions, visit the Meeting website at
                                                               http://meetings.abanet.org/meeting/tax/FALL05
                                                                  ACTIVITIES
Friday, September 16
10:00AM - 3:00PM
Asian Art Museum Tour and Luncheon at the Hayes Street Grill
(Ticketed Event $80)
A docent-guided tour will take guests through one of the largest museums in
the Western world devoted exclusively to Asian art. The spectacular new
Asian Art Museum opened to the public in 2003. Founded in 1966 as a gift
to the City of San Francisco by industrialist Avery Brundage, the museum’s




                                                                                       ACTIVITIES
holdings now include more than 15,000 art objects representing the countries
and cultures throughout Asia and spanning 6,000 years of history.
The museum’s mission is to lead a diverse global audience in discovering the
unique material, aesthetic, and intellectual achievements of Asian art and
culture. The new $160.5 million facility was designed by internationally
renowned Italian architect Gae Aulenti (Musée d’Orsay, Paris; Palazzo Grassi,
Venice; Museu Nacional d’Art de Catalunya, Barcelona) in a 1917 Beaux Arts
landmark, the City’s former Main Library.
After the tour, guests will enjoy a delightful lunch at Hayes Street Grill, a
neo-traditional San Francisco fish house. Specializing in grilled seafood,
Hayes Street Grill serves up some of the best food in town.
After lunch, guests will be transported back to the hotel.




Saturday, September 17
9:30AM - 1:30PM
Backstage at the San Francisco Opera (Ticketed Event $30)
On this tour, guests will take a rare behind the scenes tour of the San
Francisco Opera House. This is a unique opportunity to experience the
history, mystery and the excitement that surrounds the Opera.
San Francisco’s operatic tradition dates to the days of the infamous Barbary
Coast. Music halls sprang up almost instantly during those days, and all
styles of music were appreciated. Opera was the most universal musical form
however, and the greatest passion of the populace. Several operas would run
simultaneously, and the performances were reviewed and discussed at great
length. Thus began the reign of San Francisco as the center for opera on the
West Coast.
The War Memorial Opera House, home to the San Francisco Opera and the
San Francisco Ballet is the only municipally owned opera house in America,
and is located in the center of the Performing Arts - Civic Center complex.
More than a center for the arts and government, it is the center of the
cultural activity of the city. National and international opera, symphony,
modern and classic dance, theater, recitals, plays, exhibits and gala events all
have a place in the Performing Arts Center.
The historic opera house was the setting, in 1945, for the birthplace of the
United Nations. In appearance, the building rivals old world theaters, with
its Greek columns, vaulted and rosette ceilings, marble foyer, candelabra and
sweeping balconies.
After the tour, guests will be transported back to the hotel.




For complete program descriptions, visit the Meeting website at                    5
http://meetings.abanet.org/meeting/tax/FALL05
                       PROGRAMS FOR YOUNG LAWYERS
                             These programs have been designated as programs of particular interest to
                             young lawyers or non-specialists. Look for a    symbol by these programs.
                             Complete descriptions for each of the programs can be found in the Program
                             Schedule, beginning on p. 8.

                                       = Taped by Teach’em
                                       = Young Lawyers Program
                                       = Ethics Credit Requested
                               CLE     = No CLE Credit
                               JT      = Joint Tax and RPPT Program



                             THURSDAY, SEPTEMBER 15
                             1:00PM - 6:00PM
PROGRAMS FOR YOUNG LAWYERS




                             Low Income Taxpayer Clinics Workshop            (Registration Required)
                             Collection of Federal Tax Debt - Rules of the Road
                             See p. 8 for further details.
                             6:30PM - 9:30PM
                             Partnerships & LLCs and Real Estate Dinner     CLE   (Reservations Required)
                             See p. 9 for further details.


                             FRIDAY, SEPTEMBER 16
                             7:00AM - 7:30AM
                             Young Lawyers Orientation       CLE

                             8:00AM - 9:00AM
                             How RPPT Works and the Benefits of Involvement (The Pathways Program)          CLE
                             Sponsored by: Young Lawyers Network (RPPT)
                             8:30AM - 11:30AM
                             Partnerships and LLCs
                             8:35am        Circular 230, Reprised.

                             9:30am        Family Limited Partnerships: Are They Alive and Well?

                             10:10am       Partnerships & LLC Interests Issued in Connection with
                                           Services.

                             11:05am       Hot Topics in Partnerships.

                             12:30PM - 1:30PM
                             Partnerships & LLCs and Real Estate Luncheon      CLE   (Ticketed Event)
                             1:00PM - 2:00PM
                             Employee Benefits Young Lawyers Forum Update          CLE

                             1:30PM - 2:30PM
                             Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers
                             Subcommittee CLE
                             2:30PM - 5:30PM
                             Tax Accounting
                             3:10pm        Utility Tax Accounting Issues.

                             2:30PM - 4:00PM
                             Teaching Taxation
                             2:35pm        The Future of the AMT: Repeal, Reform or Replacement of
                                           the Individual Income Tax.

                       6                                            I Real Property I Probate & Trust
                     PROGRAMS FOR YOUNG LAWYERS
4:00PM - 5:00PM
Alternative Career Paths in Real Property, Probate and Trust Law     CLE
Sponsored by: Young Lawyers Network (RPPT)
4:00PM - 6:30PM
Diversity Committee and Young Lawyers Forum               JT
4:00pm        Unethical Traps for the Wary.

5:30pm        Networking Reception. CLE JT
              Sponsored by: Pillsbury Winthrop Shaw Pittman LLP
              Co-hosted by: Young Lawyers Forum (Tax) and Young Lawyers
              Network (RPPT)

5:30PM - 6:30PM
FAUST and Young Lawyers of FAUST Business Meeting         CLE



SATURDAY, SEPTEMBER 17
                                                                                     PROGRAMS FOR YOUNG LAWYERS
7:15AM - 8:30AM
Real Estate/ Partnerships & LLCs/S Corporations “Shop Talking”
Breakfast CLE (Ticketed Event)

 SECTION PROGRAM
 8:00AM - 9:45AM
 Partnerships and LLCs: Legal and Tax Effects of Charging Orders and
 Foreclosure - The Myths and The Realities          (Basic Track)

9:00AM - 12:00PM
Community Outreach Program: How to Plan and Administer Trusts and Estates

9:00AM - 10:30AM
Pro Bono
10:15am       Roundtable Discussion of Involvement of Young Lawyers,
              Mentoring Opportunities, Continuing Legal Education of Pro
              Bono Work, Rules Applicable to the Tax Section’s Annual Pro
              Bono Award, and Other Tax Section Involvement in the Pro
              Bono Legal Community. CLE

 SECTION PROGRAM
 10:00AM - 11:30AM
 Section 2036: When Do Retained Interests In or Powers Over Transferred Assets
 Require Estate Inclusion? (The Importance of Sections 2036 and 2038 to
 Etstate)         (Basic Track)

1:00PM - 4:00PM
Community Outreach Program: What You Really Ought to Know About Real Estate
But Never Learned in Law School
 SECTION PROGRAM
 2:00PM - 3:30PM
 Selecting the Situs of a Trust: State Fiduciary Income Tax Implications
 (Basic Track)

2:00PM - 5:00PM
Standards of Tax Practice
2:05pm        The Importance of Zealous Advocacy Under the Model Rules
              and Circular 230.

3:15pm        The Crime Fraud Exception to Attorney-Client Privilege and
              its Impact on Practitioner Obligations Under Circular 230.

4:00pm        Important Developments.
 I Tax I Joint Meeting                                                           7
       PROGRAM SCHEDULE
                     = Taped by Teach’em
                     = Young Lawyers Program
                     = Ethics Credit Requested
             CLE     = No CLE Credit
             JT      = Joint Tax and RPPT Program



           THURSDAY, SEPTEMBER 15
           9:00AM - 5:00PM
           Officers and Council Meeting CLE (Executive Session)
           1:00PM - 6:00PM
           Low Income Taxpayer Clinics Workshop             (Registration Required)
           Collection of Federal Tax Debt - Rules of the Road
           The Collection of Federal Tax Debt Workshop, co-sponsored by the Low
           Income Taxpayers and Pro Bono Committees of the ABA Section of Taxation,
           is designed to provide attorneys with basic, hands-on training in the area of
           collections. The workshop is aimed at both attorneys with little or no
           experience in handling tax controversy cases, as well as attorneys with
           extensive experience in this area. This workshop will benefit any attorney
           currently involved with a low income taxpayer clinic (LITC), or any attorney
           looking to get involved in pro bono work.
           The workshop will begin with an opening panel that will provide a road map
           to the Collection of Federal Tax Debt, and will include four workshops
           providing additional information about specific collection topics. The
           workshop will conclude with a session discussing how to handle a US Tax
THURSDAY




           Court case.
           1:00pm        Collection of Federal Tax Debt - Rules of the Road.            This
                         panel will give a general overview of the practice and procedure
                         for collecting federal tax debt, including discussions on how tax
                         debts are assessed; an overview of the life of collecting a tax debt
                         from assessment to litigation; statutes of limitation on
                         collection; full and partial installment payment plans; offers in
                         compromise; currently not collectible status; enforced collection,
                         including liens, levies and seizures; and alternative dispute
                         resolution of tax debts, including fast track mediation.

           BREAKOUT SESSIONS
           2:40PM - 3:40PM
           The ABCs of Liens and Levies.           This panel is aimed at practitioners who
           are relatively new to the work of federal tax liens and levies. The panel
           members will discuss (1) how and when federal tax liens are created; (2) to
           what types of property interests federal liens attach; (3) how federal liens are
           recorded; (4) the rules that determine priority of the federal tax lien to other
           creditors’ liens; (5) the difference between a levy and a lien; (6) property that
           is exempt from levy; (7) how the amount of a levy is determined; (8)
           continuous levies; (9) the federal payment levy program; and (10) getting a
           levy released for economic hardship. The panel members will provide a
           written outline of these topics, as well as examples of IRS notices and letters.




       8                                           I Real Property I Probate & Trust
                                             PROGRAM SCHEDULE
2:40PM - 3:40PM
Bankruptcy vs. OIC.          This panel will review the general rules for filing
Chapter 7 and Chapter 13 bankruptcy cases and will debate when bankruptcy
is a better alternative to offers in compromise.
3:50PM - 4:50PM
Advanced Liens and Levies.       This panel will discuss more advanced
strategies concerning enforced collection, including how to release or
subordinate liens, when an action for wrongful levy is appropriate and how to
calculate damages, and how to respond to seizure of property.
3:50PM - 4:50PM
Collection Due Process Hearings.          This panel will discuss taxpayer rights
afforded by a collection due process hearing, the mechanics for preserving these
rights, and the practical considerations and pitfalls in pursuing such rights.
5:00pm        Tax Court Session.

6:00pm        Reception.      CLE

4:00PM - 6:00PM
Partnerships & LLCs Task Force on Simplification of Subchapter K CLE
5:00PM - 7:30PM
Corporate Offshore Inversions and International Tax Reform Task Force CLE
(Executive Session)
6:30PM - 10:00PM
Administrative Practice Dinner CLE (Invitation Only)
6:30PM - 9:30PM
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 on Thursday, September 15,
2005, at a restaurant near the Hyatt. Cocktails will begin at 6:30pm followed
                                                                                        THURSDAY




by dinner at 7:30pm. Reservations and advance payment required. For details,
please go to www.abanet.org/tax/groups/partnerships/ or
www.abanet.org/tax/groups/realestate/
6:30PM - 10:00PM
State and Local Taxes Cash Bar and Executive Business Meeting Dinner CLE
(Executive Session)




 I Tax I Joint Meeting                                                              9
       PROGRAM SCHEDULE
            FRIDAY, SEPTEMBER 16
            7:00AM - 7:30AM
            Young Lawyers Orientation      CLE

            7:30AM - 8:30AM
            Exempt Organizations Subcommittee on Health Care Organizations
            7:30AM - 8:30AM
            Exempt Organizations Subcommittee on Political & Lobbying Organizations and
            Activities
            7:30AM - 8:30AM
            Exempt Organizations Subcommittee on Private Foundations, Unrelated Business
            Income & International Philanthropy
            7:30AM - 8:30AM
            Exempt Organizations Subcommittee on Religious Organizations
             7:30AM - 8:30AM
             JOINT SECTION BREAKFAST/PLENARY SESSION          CLE   (Ticketed Event)
             Dennis B. Drapkin, Section Chair, Presiding
                                   Chair’s Report to the Section
                                   Dennis B. Drapkin, Section Chair

             Keynote Speaker:      Joseph Bankman
                                   Ralph M. Parsons Professor of Law and Business
                                   Stanford Law School
                                   Stanford, CA

             Topic:                The Tax Shelter “Disease” — Have We Found the
                                   Right Treatments? Can We Live With the
                                   Treatments We’ve Found?

            8:00AM - 10:00AM
            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
            8:00AM - 10:00AM
            Employee Benefits Executive Compensation and Securities Law Update, Presented
            by the Subcommittee on Executive Compensation and the Subcommittee on
| FRIDAY




            Federal Securities Laws Issues
            8:00AM - 10:00AM
            Employee Benefits Welfare Plans, HIPAA and VEBA Update, Presented by the
AM
            Subcommittee on Retiree Health, VEBAs and Other Funding Vehicles, the
            Subcommittee on COBRA & Welfare Plan Design Issues, the Subcommittee
            on HIPAA, the Subcommittee on Welfare Plan Legislation, the
            Subcommittee on State Insurance Plans and Flexible Benefits
            8:00AM - 9:00AM
            How RPPT Works and the Benefits of Involvement
            (The Pathways Program) CLE
            Chair: Hugh Drake, Brown Hay & Stephens, Springfield, IL
            Sponsored by: Young Lawyers Network (RPPT)




       10                                         I Real Property I Probate & Trust
                                            PROGRAM SCHEDULE
8:00AM - 9:45AM
Real Estate Taxation and Governmental Incentives Group
Chair: Michael Hirschfeld, Dechert LLP, New York, NY
Wide (Sometimes) Weird World of “1031” Cases and Rulings.
Surviving Circular 230.
8:00AM - 9:45AM
Special Investors and Investment Structure Group
Chair: Robert J. Krapf, Richards Layton & Finger PA, Wilmington, DE
Saving the Family Farm: A Report from the Property Preservation Task
Force.
Patriot Act Model Provisions.
8:30AM - 11:30AM
Administrative Practice
Chair: Thomas J. Callahan, Thompson Hine LLP, Cleveland, OH
8:30am        Opening Remarks by the Chair.        CLE

8:35am        Important Developments.

9:00am        Independence of IRS Appeals: A View from the National Tax
              Advocate.

9:50am        Practicalities of Negotiating and Responding to IDRs.

10:40am       Exchange of Information Between IRS and State Taxing
              Authorities.

8:30AM - 11:30AM
Affiliated and Related Corporations
Chair: Bryan P. Collins, Deloitte & Touche LLP, Washington, DC
8:30am        Opening Remarks by the Chair.        CLE

8:35am        New Proposed Dual Consolidated Loss Rules.

9:35am        Recent Developments.

8:30AM - 11:30AM
Banking and Savings Institutions
Chair: John Ensminger, Delta Hedge LLC, Brooklyn, NY
8:30am        Opening Remarks by the Chair and Discussion of
              Technology Committee Decisions Affecting Committee
                                                                                FRIDAY |




              Operations and Uses of Their Websites. CLE

8:35am        California State and Franchise Board Developments.

9:00am        Section 475 Proposed Safe Harbor Regulations and Their            AM
              Frictions with Financial Reporting Valuations and FAS 133.

10:30am       Section 1441 Developments and Other Withholding Issues
              Impacting Banks and Financial Institutions.

8:30AM - 10:30AM
Capital Recovery and Leasing




 I Tax I Joint Meeting                                                     11
       PROGRAM SCHEDULE
            8:30AM - 11:30AM
            Closely Held Businesses (Tax); Business Planning Group (PT); Business
            Cooperatives & Agriculture (Tax); and Litigation & Controversy Group (PT)   JT
            Closely Held Businesses Chair: John O. Tannenbaum, Hartford, CT
            Business Planning Group Chair: Steven B. Gorin, Thompson Coburn LLP, St.
            Louis, MO
            Business Cooperatives & Agriculture Chair: Harvey R. Sorensen, Foulston
            Siefkin LLP, Wichita, KS
            Litigation & Controversy Group Chair: Dominic J. Campisi, Evans Latham
            Campisi, San Francisco, CA
            8:30am        Committee Welcome and Administrative Matters.           CLE

            8:40am        Splitting Up a Family Business: State Law and Litigation
                          Issues.

            9:50am        Splitting Up a Family Business: Estate and Gift Tax Issues,
                          Including Business Succession Planning.

            10:40am       Splitting Up a Family Business: Issues Unique to C
                          Corporations and S Corporations.

            8:30AM - 9:30AM
            Companions’ Breakfast CLE (Complimentary)
            8:30AM - 11:30AM
            Domestic Relations and Low Income Taxpayers
            Domestic Relations Chair: Professor Toni Robinson, Quinnipiac University
            School of Law, Hamden, CT
            Low Income Taxpayers Chair: Elizabeth J. Atkinson, Kaufman and Canoles,
            Norfolk, VA
            8:30am        Important Developments.

            8:45am        An Update on the State of the Innocent Spouse Program.

            8:30AM - 11:30AM
            Estate and Gift Taxes
            Chair: Barbara A. Sloan, McLaughlin & Stern LLP, New York, NY
            8:30am        Opening Remarks by the Chair.       CLE

            8:35am        Current Developments.

            9:05am        Asset Protection Under the New Bankruptcy Act.

            9:35am        Terminating and Splitting Up CRT’s.
| FRIDAY




            10:20am       Charitable Gift Agreements.

            11:15am       Family Limited Partnerships: Current Review of Latest
AM                        Decisions Regarding Section 2036 Issues and Valuation Issue.

            8:30AM - 11:30AM
            Formation of Tax Policy
            Chair: Jonathan Talisman, Capitol Tax Partners, Washington, DC
            8:30am        Opening Remarks by the Chair.       CLE

            8:45am        Current Developments.

            10:00am       Tax Reform and Simplification.




       12                                          I Real Property I Probate & Trust
                                                PROGRAM SCHEDULE
8:30AM - 9:30AM
Membership & Marketing CLE
Chair: Stuart M. Lewis, Buchanan Ingersoll PC, Washington, DC
8:30AM - 11:30AM
Partnerships and LLCs
Chair: Steven G. Frost, Chapman & Cutler LLP, Chicago, IL
8:30am        Opening Remarks by the Chair.         CLE

8:35am        Circular 230, Reprised.

9:30am        Family Limited Partnerships: Are They Alive and Well?

10:10am       Partnerships & LLC Interests Issued in Connection with
              Services.

11:05am       Hot Topics in Partnerships.

8:30AM - 10:30AM
US Activities of Foreigners & Tax Treaties
Chair: Stanley C. Ruchelman, The Ruchelman Law Firm, New York, NY
8:30am        Inbound Financing Techniques.

9:30am        Ethics and the International Tax Practitioner in the Age of
              Circular 230.

8:30AM - 10:30AM
Wealth Planning
Chairs: Donna Barwick, Mellon Private Wealth Management, Atlanta, GA;
Michael Whitty, Winston & Strawn LLP, Chicago, IL
The State of the Art Market Today.
Tax Rules for Acquiring, Holding and Transferring Art.
8:45AM - 5:00PM
Exempt Organizations
Chair: LaVerne Woods, Davis Wright Tremaine LLP, Seattle, WA
8:45am        Committee Business, Updates and Late-Breaking News.      CLE

9:00am        News from the IRS and Treasury.

9:45am        Task Force Report: Revising the Form 990.

10:00am       Task Force Report: Tax Shelters and Tax-Exempt
                                                                                  FRIDAY |




              Organizations.

11:00am       Conservation and Facade Easements: More than Meets the
              Eye?
                                                                                  AM
12:15pm       Luncheon Program.       CLE    (Ticketed Event)

1:30pm        California’s Nonprofit Integrity Act and the Long Arm of the
              Law.

2:15pm        Charitable Giving Update.

3:15pm        Healthcare Today and the Bleeding Edge of Tax-Exempt
              Status.

4:00pm        Cash Bar.   CLE




 I Tax I Joint Meeting                                                       13
       PROGRAM SCHEDULE
            10:00AM - 3:00PM
            Companions’ Tour CLE (Ticketed Event)
            Asian Art Museum Tour and Luncheon at the Hayes Street Grill
            See p. 5 for a full description.
            10:00AM - 12:00PM
            Employee Benefits 401(k) Update, Presented by the Subcommittee on Qualified
            Cash or Deferred Arrangements
            10:00AM - 11:00AM
            Employee Benefits ESOP Update, Presented by the Subcommittee on ESOPs
            10:00AM - 12:00PM
            Employee Benefits Fiduciary Responsibility and Litigation Update, Presented by
            the Subcommittee on Fiduciary Responsibility, the Subcommittee on
            Litigation, the Subcommittee on Prohibited Transactions and the
            Subcommittee on ESOPs
            10:00AM - 11:00AM
            Employee Benefits IRA Update, Presented by the Subcommittee on IRAs
            10:00AM - 12:30PM
            Investment Companies
            Chair: Cathy Heron, Capital Research and Management Company, Los
            Angeles, CA
            10:00am      Opening Remarks by the Chair.      CLE

            10:05am      Mutual Fund Mergers and Other Current Developments.

            11:15am      Hedge Funds Investing in Derivatives: An Update.

            10:00AM - 11:45AM
            Land Use and Environmental Group
            Chair: Roger Schwenke, Carlton Fields PA, Tampa, FL
            Brownfields Development: The New Possibilities.
            10:00AM - 11:45AM
            Real Estate Financing Group
            Chair: Nancy Little, McGuireWoods LLP, Richmond, VA
            Introduction to Defeasance: “Help! I’ve Fallen in My Loan and I Can’t
            Get Out.”
            10:30AM - 12:30PM
            Charitable Planning and Exempt Organizations
            Chair: Jerry J. McCoy, Law Office of Jerry J. McCoy, Washington, DC
| FRIDAY




            Drafting Charitable Gift Agreements.
            Charitable Legislation Update.
AM




       14                                         I Real Property I Probate & Trust
                                             PROGRAM SCHEDULE
10:30AM - 12:30PM
Employee Benefit Plans and Other Compensation Arrangements
Chair: Peter M. Kelly, Blue Cross Blue Shield, Chicago, IL
Executive Compensation, Practical Issues Encountered in Implementing
New Code Section 409A.
Implications of Demographic Shifts for Retirement Plans, Including
Phased Retirement.
Affirmative Disclosure Duties of Fiduciaries & Changes in Fiduciary
Disclosure Practices After Recent ERISA Fiduciary Cases.
10:30AM - 12:00PM
Joint Session of FAUST, FLF, Transfer Pricing and USAFTT
10:30AM - 12:30PM
Non-Tax Estate Planning Consideration
Chair: Christopher H. Gadsden, Gadsden Schneider & Woodward LLP,
King of Prussia, PA
Dynasty Trusts and Their Impact on Families.
Hot Topics.
11:00AM - 12:00PM
Employee Benefits International Update, Presented by the Subcommittee on
Foreign and International Issues
11:30AM - 12:30PM
Appointments to the Tax Court CLE (Executive Session)
Chair: W. Curtis Elliott, Jr., Culp Elliott & Carpenter PLLC, Charlotte, NC
11:30AM - 12:30PM
Important Developments Workshop CLE
Mandatory meeting for Committee representatives responsible for preparing
their Committee’s Annual Report on Important Developments.
11:30AM - 12:30PM
Professional Services and Tax CLE On the Road Planning Meeting CLE
Chair: Charles Lavelle, Greenebaum Doll & McDonald PLLC, Louisville, KY
                                                                                   FRIDAY |




                                                                                   AM




 I Tax I Joint Meeting                                                        15
       PROGRAM SCHEDULE
| FRIDAY




            12:00PM - 1:00PM
            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
PM
            12:00PM - 1:00PM
            Employee Benefits Corporate Counsel Forum Update, Presented by the Employee
            Benefits Corporate Counsel Forum
            12:00PM - 1:00PM
            Employee Benefits Electronic Plan Administration Update, Presented by the Task
            Force on Electronic Plan Administration
            12:30PM - 1:00PM
            Employee Benefits Leadership Meeting/Luncheon CLE (Invitation Only)

             COMMITTEE LUNCHEONS
             11:45AM - 1:15PM
             Real Property Division CLE (Ticketed Event)
             12:00PM - 1:30PM
             Corporate Tax and Affiliated and Related Corporations CLE (Ticketed Event)
             12:00PM - 1:30PM
             FAUST, FLF, Transfer Pricing and USAFTT CLE (Ticketed Event)
             12:15PM - 1:15PM
             Exempt Organizations   CLE   (Ticketed Event)
             12:30PM - 1:30PM
             Administrative Practice and Court Procedure & Practice CLE(Ticketed Event)
             12:30PM - 2:00PM
             Banking and Savings Institutions, Financial Transactions, Insurance Companies,
             Investment Companies, and Tax Exempt Financing CLE (Ticketed Event)
             12:30PM - 1:30PM
             Business Cooperatives & Agriculture CLE (Ticketed Event)
             12:30PM - 1:30PM
             Estate & Gift Taxes and Fiduciary Income Tax CLE (Ticketed Event)
             12:30PM - 1:30PM
             Partnerships & LLCs and Real Estate    CLE (Ticketed   Event)
             12:30PM - 2:30PM
             Probate and Trust Division CLE (Ticketed Event)
             12:30PM - 1:00PM
             State and Local Taxes CLE (Ticketed Event)

            1:00PM - 2:45PM
            Employee Benefits Distributions, QDROs and QMSCOs Update, Presented by the
            Subcommittee on QDROs, QMSCOs and Other Domestic Relations Benefits
            Issues and the Subcommittee on Estate and Gift Tax Issues
            1:00PM - 2:00PM
            Employee Benefits EEOC Update, Presented by the Subcommittee on EEOC Issues
            1:00PM - 2:45PM
            Employee Benefits Government and Tax Exempt Plans Update, Presented by the
            Subcommittee on Government Plans, the Subcommittee on Section 457 Issues
            and the Subcommittee on Section 403(b) and EO Issues


       16                                          I Real Property I Probate & Trust
                                              PROGRAM SCHEDULE




                                                                                   FRIDAY |
1:00PM - 2:45PM
Employee Benefits Mergers & Acquisitions Update, Presented by the
Subcommittee on Mergers & Acquisitions
1:00PM - 2:00PM                                                                    PM
Employee Benefits Nondiscrimination Update, Presented by the Subcommittee
on Nondiscrimination and Section 415 Issues
1:00PM - 2:00PM
Employee Benefits Pension Legislation Update, Presented by the Subcommittee
on Pension Legislation, the Pension Simplification Task Force and the Enron
Task Force
1:00PM - 2:00PM
Employee Benefits Young Lawyers Forum Update          CLE

1:00PM - 5:30PM
S Corporations
Chair: Ronald A. Levitt, Walston Wells Anderson and Birchall LLP,
Birmingham, AL
1:00pm        Opening Remarks by the Chair.        CLE

1:10pm        Important Developments.

1:30pm        S Corporations Pass-Through Taxation Rules: Sections 1355,
              1367 and 1368 - Part 2.

3:00pm        Update on Back to Back Loans.

4:00pm        Built-In Gains Tax Planning.

5:00pm        Committee Discussion on Legislative and Regulatory
              Proposals.

1:00PM - 1:30PM
State and Local Taxes: A Review of Current State Tax Decisions
1:30PM - 5:30PM
Employment Taxes
Chair: GJ Stillson MacDonnell, Littler Mendelson, San Francisco, CA
1:30pm        Opening Remarks by the Chair.        CLE

1:40pm        Update from the Executive Branch on Emerging
              Employment Tax Issues.

2:40pm        Spotlight on California State Employment Taxes Issues.

3:40pm        SUTA Legislation Task Force Update.

4:40pm        Employment Tax Issues and IRS Circular 230.

5:00pm        Employment Tax Practitioners Workshop. This session will
              not be taped.

1:30PM - 2:30PM
Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers
Subcommittee CLE




 I Tax I Joint Meeting                                                        17
       PROGRAM SCHEDULE
| FRIDAY




            1:30PM - 3:30PM
            Foreign Activities of US Taxpayers
            Chair: Peter H. Blessing, Shearman & Sterling LLP, New York, NY
            1:30pm        Opening Remarks by the Chair.       CLE
PM
            1:35pm        Selected Issues Under Proposed DCL Regulations/Other
                          Outbound Guidance.

            2:35pm        Section 965 Planning Under Latest Guidance.

            1:30PM - 3:15PM
            Hospitality, Community Recreation and Common Interest Developments Group
            Chairs: Gary Poliakoff, Becker & Poliakoff PA, Fort Lauderdale, FL;
            Alexandra Cole, Perkins Coie LLC, Chicago, IL
            Hotel Revolution — Are We Becoming a Condo Nation?
            1:30PM - 3:15PM
            Real Estate Transactions and Management Group
            Chair: John C. Murray, First American Title Insurance, Chicago, IL
            Choosing Construction Formats.
            Risk Management for Construction Projects.
            Mechanics Liens and Title Insurance for Construction Loans.
            2:00PM - 5:00PM
            Nominating CLE (Executive Session)
            Chair: Richard A. Shaw, Higgs Fletcher & Mack LLP, San Diego, CA
            2:30PM - 6:00PM
            Closely Held Businesses (Tax); Business Planning Group (PT); Business
            Cooperatives & Agriculture (Tax); and Litigation & Controversy Group (PT)    JT
            Closely Held Businesses Chair: John O. Tannenbaum, Hartford, CT
            Business Planning Group Chair: Steven B. Gorin, Thompson Coburn LLP, St.
            Louis, MO
            Business Cooperatives & Agriculture Chair: Harvey R. Sorensen, Foulston
            Siefkin LLP, Wichita, KS
            Litigation & Controversy Group Chair: Dominic J. Campisi, Evans Latham
            Campisi, San Francisco, CA
            2:30pm        Splitting Up a Family Business: Issues Unique to
                          Partnerships and LLCs.

            3:40pm        Splitting Up a Family Business - Four Scenarios: Family
                          Limited Partnership, Manufacturing or Retail Business,
                          Professional Service Firm and Agricultural Business.

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




       18                                          I Real Property I Probate & Trust
                                          PROGRAM SCHEDULE




                                                                                    FRIDAY |
2:30PM - 5:30PM
Court Procedure and Practice
Chair: Mary McNulty, Thompson & Knight LLP, Dallas, TX
2:30pm        Opening Remarks by the Chair.    CLE
                                                                                    PM
2:35pm        Remarks on Behalf of the Tax Court.

2:50pm        The New Policy on Tax Accrual Work Papers: Transparency
              or Transgression?

3:25pm        Remarks on Behalf of the Office of Chief Counsel, IRS.

3:40pm        Litigating Partnership Issues II: The Debate on Statutes of
              Limitation.

4:10pm        Recent Hot Topics.

4:20pm        Tax Controversy Pro Bono Clinics.

4:30pm        Litigating Tax Cases in Bankruptcy.

5:00pm        Spotlight on Procedure.

2:30PM - 4:30PM
Elder Law and Disability Group
Chair: Katherine Barr, Sirote & Permutt PC, Birmingham, AL
Navigating Between Taxable Income and Benefit Income for Special
Needs Trusts.
Exploring the Uniform Power of Attorney Act.
2:30PM - 5:30PM
Energy and Environmental Taxes
Chair: Robert A. Swiech, Oreck Bradley Crighton Adams & Chase LLC,
Boulder, CO
2:30pm        Opening Remarks by the Chair.    CLE

2:35pm        Current Regulatory, Administrative and Case Law
              Developments.

3:30pm        Tax Issues in Environmental Settlements.

4:30pm        A Primer on Like-Kind Exchanges Involving Mineral
              Properties.

2:30PM - 5:30PM
Financial Transactions
Chair: Kevin M. Keyes, Fried Frank Harris Shriver & Jacobson LLP,
Washington, DC
2:30pm        Update on New Straddle Rules.

3:30pm        Hot Topics in Financial Transactions.

4:30pm        Current Developments.

2:30PM - 4:30PM
Income and Transfer Tax Planning Group
Chairs: Professor Jeffrey Pennell, Emory University Law School, Atlanta, GA;
Susan Porter, US Trust Company of New York, New York, NY
Income and Transfer Tax Planning Roundtable Program.




 I Tax I Joint Meeting                                                         19
       PROGRAM SCHEDULE
| FRIDAY




            2:30PM - 5:30PM
            Insurance Companies
            Chair: Frederick J. Krull, Ernst & Young LLP, Los Angeles, CA
            2:30pm        Opening Remarks by the Chair.    CLE
PM
            2:35pm        Fundamental Tax Reform: Implications of Tax Reform
                          Proposals for the Insurance Industry.

            3:35pm        Tax Shelter, IRS Circular 230 and Other Administrative
                          Matters Update.

            4:35pm        Life Insurance and Property/Casualty Update.

            2:30PM - 5:30PM
            Real Estate
            Chair: James M. Lowy, Ernst & Young LLP, San Francisco, CA
            2:30pm        Opening Remarks by the Chair.    CLE

            2:35pm        Opportunity Funds - Issues for Participants and
                          Co-Venturers.

            3:35pm        Reverse Exchanges Outside the Safe Harbor.

            4:25pm        Real Estate Transactions in California.

            4:45pm        Condominium Development and Conversion Issues.

            2:30PM - 5:30PM
            State and Local Taxes
            Chair: Stephanie Anne Lipinski Galland, Steel Hector & Davis LLP,
            Washington, DC
            2:30pm        Opening Remarks and Announcements.        CLE

            2:40pm        Hot Issues in State Abandoned Property Compliance.

            3:35pm        Public Disclosure of Tax Returns.

            4:30pm        State Tax Opportunities and Traps Arising Out of the
                          American Jobs Creation Act of 2004.

            4:55pm        Questions and Closing Remarks.

            2:30PM - 5:30PM
            Tax Accounting
            Chair: Jack Donovan, Ernst & Young LLP, Washington, DC
            2:30pm        Recent Developments in the Area of Tax Accounting.

            3:10pm        Utility Tax Accounting Issues.

            3:45pm        Regulations Addressing Estimated Tax Liabilities for
                          Corporations.

            4:25pm        The Manufacturing Deduction: A Look at Proposed
                          Regulations Under Section 199.




       20                                        I Real Property I Probate & Trust
                                              PROGRAM SCHEDULE




                                                                                   FRIDAY |
2:30PM - 4:30PM
Tax Practice Management (Tax) and Practice Management Group (PT)         JT
Chairs: James L. Boring, Boring and Pilger PC, Vienna, VA; Terrence M.
Franklin, Sacks Glazier Franklin & Lodise LLP, Los Angeles, CA; Paul E. Van
Horn, McLaughlin & Stern LLP, New York, NY                                         PM
706 Assembly Programs.
Demonstration of Document Assembly Programs for Estate Planners.
2:30PM - 4:00PM
Teaching Taxation
Chair: Professor Michael B. Lang, Chapman University School of Law,
Orange, CA
2:30pm        Opening Remarks by the Chair.       CLE

2:35pm        The Future of the AMT: Repeal, Reform or Replacement of
              the Individual Income Tax.

3:00PM - 5:30PM
Employee Benefits
Chair: James R. Raborn, Baker Botts LLP, Houston, TX
3:00pm        Opening Remarks by the Chair.       CLE

3:05pm        Exploring the Inconceivable: an Overview of the 409A
              Guidance.

4:20pm        Hazards of Health Plan Administration.

5:30pm       Cash Bar. CLE
             Sponsored by: Shook Hardy & Bacon LLP

3:30PM - 5:15PM
Practice Management Group
Chair: Michael D. Goler, Goodman Weiss Miller LLP, Cleveland, OH
Ethics and Professionalism Committee.
Economics, Technology and Practice Methods Committee.
3:30PM - 5:15PM
Residential, Multi-Family and Special Use Group
Chair: Orlando Lucero, Stewart Title, Albuquerque, NM
Hot Topics in Affordable Housing.
3:30PM - 5:30PM
Transfer Pricing
Chair: Steve C. Wrappe, Deloitte Tax LLP, Washington, DC
3:30pm        Opening Remarks.      CLE

3:35pm        Transfer Pricing and Circular 230.

4:05pm        The New Cost Sharing Proposed Regulations.

4:00PM - 5:00PM
Alternative Career Paths in Real Property, Probate and Trust Law   CLE
Chair: Hugh Drake, Brown Hay & Stephens, Springfield, IL
Sponsored by: Young Lawyers Network (RPPT)




 I Tax I Joint Meeting                                                        21
       PROGRAM SCHEDULE
| FRIDAY




            4:00PM - 6:30PM
            Diversity Committee and Young Lawyers Forum               JT
            Diversity Chair: Walter W. Burford, PricewaterhouseCoopers LLP, Atlanta, GA
            Young Lawyers Forum Chair: Allen D. Madison, San Francisco, CA
PM
            4:00pm        Unethical Traps for the Wary.

            5:30pm        Networking Reception.        CLE JT
                          Sponsored by: Pillsbury Winthrop Shaw Pittman LLP
                          Co-hosted by: Young Lawyers Forum (Tax) and Young Lawyers
                          Network (RPPT)

            5:00PM - 6:00PM
            Programs and Meetings CLE
            Chair: Sylvan Siegler, Shook Hardy & Bacon LLP, Kansas City, MO
            5:30PM - 6:30PM
            FAUST and Young Lawyers of FAUST Business Meeting        CLE

            5:30PM - 6:30PM
            US Activities of Foreigners and Tax Treaties Business Meeting CLE

             6:30PM - 8:00PM
             JOINT SECTION RECEPTION CLE (Ticketed Event)




       22                                          I Real Property I Probate & Trust
                                             PROGRAM SCHEDULE
SATURDAY, SEPTEMBER 17
7:00AM - 8:15AM
Employee Benefits Special Defined Benefit Issues Update, Presented by the
Subcommittee on Special Defined Benefit Plan Issues and the Cash Balance
Plan Task Force
7:00AM - 9:00AM
Low Income Taxpayers
Chair: Elizabeth J. Atkinson, Kaufman and Canoles, Norfolk, VA




                                                                                   SATURDAY |
7:00am       Important Developments.

7:15am       A Roundtable on the EITC Certification Program.

8:15am       Navigating the Automated Collection System.
                                                                                   AM
7:15AM - 8:30AM
Real Estate/Partnerships & LLCs/S Corporations “Shop Talking”
Breakfast CLE (Ticketed Event)
Sponsored by: Baker & McKenzie LLP
7:30AM - 8:15AM
Committee Chairs, Vice-Chairs, Officers and Council Breakfast CLE
7:30AM - 8:30AM
Sales, Exchanges & Basis Breakfast CLE
Sponsored by: J.P. Morgan Property Exchange Inc.
7:45AM - 9:00AM
Court Procedure and Practice Officers and Subcommittee Chairs Breakfast CLE
(Ticketed Event)
8:00AM - 9:00AM
Distinguished Service Award CLE (Executive Session)
Chair: Pamela F. Olson, Skadden Arps Slate Meagher & Flom LLP,
Washington, DC

 SECTION PROGRAMS
 8:00AM - 9:45AM
 Partnerships and LLCs: Legal and Tax Effects of Charging Orders and
 Foreclosure - The Myths and The Realities          (Basic Track)
 The panel will discuss legal and tax issues concerning debtor partners and
 LLC members. Panel will address charging order concepts, the legal rights
 of concerned parties in and out of bankruptcy, and the tax results to
 concerned parties of charging orders, foreclosure sales, and bankruptcy.
 Sponsored by: Asset Protection Planning Committee (PT)




 I Tax I Joint Meeting                                                        23
         PROGRAM SCHEDULE
               SECTION PROGRAM
               8:00AM - 9:30AM
               Vapor Intrusion: Defining and Managing Risks in Property Ownership,
               Management, Redevelopment and Use
               This program will explain what vapor intrusion is and what the real estate
               practitioner needs to know about this newest area of sate and federal
               environmental regulation and guidance. Through actual case studies,
               attendees will learn how vapor intrusion is modeled, assessed and
               remediated; and how the risks are managed in the transaction process
               including strategies for identifying and managing these risks.
               Panelists:    Edward L. Stohbehn, Jr., Bingham McCutchen LLP, San
| SATURDAY




                             Francisco, CA

                             Robert Ettinger, GeoSyntec Consultants, Inc., Santa
                             Barbara, CA

                             Todd McAlary, GeoSyntec Consultants, Inc., Guelph,
AM                           Ontario

                             Dan Gallagher, California Environmental Protection Agency,
                             Department of Toxic Substances Control, Sacramento, CA

               Sponsored by: Environmental Committee (RP)

              8:00AM - 9:45AM
              Leasing Group
              Chair: John S. Hollyfield, Fulbright & Jaworski, Houston, TX
              Hot Issues Relating to Operating Expenses.

               SECTION PROGRAM
               8:00AM - 9:45AM
               Property Preservation Task Force: Using Limited Liability Companies to Avoid
               Land Loss     (Lecture Track)
               The program will examine the unstable nature of tenancy in common
               property, with specific reference to the NCCUSL Submission of the
               Property Preservation Task Force on uniform state partition law reform. It
               will give a basic understanding of the use of limited liability companies for
               the avoidance of fractionalization of real estate title and will examine the
               income and transfer tax basics of LLCs in this context.
               Panelists:    David Dietrich, Dietrich & Associates, Billings, MT

                             Steven Gorin, Thompson Coburn LLP, St. Louis, MO

              8:30AM - 11:30AM
              Civil and Criminal Tax Penalties
              Chair: Miriam L. Fisher, Morgan Lewis & Bockius LLP, Washington, DC
              8:30am        Opening Remarks by the Chair.      CLE

              8:35am        Reports of Subcommittees.

              9:00am        ABA Section of Taxation Website Demo.        CLE

              9:10am        The Impact of US v. Pasquantino.

              9:40am        Reliance on Professionals: What is Left of the Penalty
                            Defense?

              10:30am       Hi-Tech Investigation of Financial Crimes, Part III.




         24                                         I Real Property I Probate & Trust
                                             PROGRAM SCHEDULE
8:30AM - 11:30AM
Corporate Tax
Chair: Reginald J. Clark, Sutherland Asbill & Brennan LLP, Atlanta, GA
8:30am       Opening Remarks by the Chair.       CLE

8:35am       Recent Corporate Developments.

10:00am      Section 351 Transactions and Related Issues.

8:30AM - 11:30AM
Employee Benefits
Chair: James R. Raborn, Baker Botts LLP, Houston, TX




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

8:35am       What Benefits Practitioners Need to Know About
             Circular 230.

9:30am       Qualified Plans Update.                                           AM
10:30am      How to Identify Pitfalls and Amend Plans Before Year-End to
             Comply with Section 409A.

8:30AM - 11:30AM
Fiduciary Income Tax
Chair: David Pratt, Pratt & Bucher LLP, Boca Raton, FL
8:30am       Opening Remarks.      CLE

8:35am       Recent Developments.

8:50am       Circular 230: The Final Regulations - An Update for Estate
             Planners and Fiduciaries.

9:40am       Trust Litigation and Fiduciary Liability - Recent Trust
             Litigation Cases and the Drafting Practice Tips They Suggest
             for Practitioners.

10:30am      The Hubert Regulations - Application Today.

8:30AM - 9:30AM
Foreign Tax Credits Task Force CLE (Executive Session)
Chairs: Elinore Richardson, Borden Ladner Gervais LLP, Toronto, Canada;
Lowell Yoder, McDermott Will & Emery LLP, Chicago, IL
8:30AM - 10:30AM
LLC Subcommittee of Partnerships and LLCs
Chair: John R. Maxfield, Holland & Hart LLP, Denver, CO
8:30AM - 11:45AM
Sales, Exchanges and Basis
Chair: Ronold P. Platner, Olympia Companies, Scottsdale, AZ
8:30am       Opening Remarks by the Chair.       CLE

8:35am       Real Estate Exchanges: All State Survey Results.

9:05am       Automation of Rule-Oriented Tax Computations.

9:30am       Final 199 Regulations and How They Affect the Structure of
             Real Estate Transactions.

10:25am      How Cost Segregation Can Affect the Ownership and
             Disposition of Real Estate.



 I Tax I Joint Meeting                                                    25
         PROGRAM SCHEDULE
              10:40am      When is Real Estate an Intangible Asset for Exchange Purposes?

              11:10am      Sales and Exchanges: Current Developments.

              9:00AM - 12:00PM
              Community Outreach Program: How to Plan and Administer Trusts and Estates
              Chair: Marc S. Bekerman, Meltzer Lippe Goldstein & Breitstone LLP,
              Mineola, NY
              For more information, please contact Antonette Smith, (312) 988-5260,
              asmith4@staff.abanet.org.
              9:00AM - 11:30AM
              Individual Income Tax
| SATURDAY




              Chair: Professor Roberta F. Mann, Widener University School of Law,
              Wilmington, DE
              9:00am       Opening Remarks by the Chair.       CLE


AM 9:05am                  Beyond Enforcement: Encouraging Tax Compliance.

              10:05am      Representing Individual Taxpayers: How Practitioners Are
                           Meeting the “Best Practices” and “Covered Opinions”
                           Requirements of Circular 230 Sections 10.33, 10.35, and
                           10.36.
                           Jointly Sponsored by: Standards of Tax Practice Committee (Tax)
              9:00AM - 10:30AM
              Pro Bono
              Chair: Brian P. Trauman, Mayer Brown Rowe & Maw LLP, New York, NY
              9:00am       Opening Remarks by the Chair.       CLE

              9:05am       Volunteer Income Tax Assistance and Provision of Legal
                           Services at VITA Sites.

              9:45am       Low Income Taxpayer Clinics.

              10:00am      Exempt Organizations.

              10:15am      Roundtable Discussion of Involvement of Young Lawyers,
                           Mentoring Opportunities, Continuing Legal Education of
                           Pro Bono Work, Rules Applicable to the Tax Section’s
                           Annual Pro Bono Award, and Other Tax Section
                           Involvement in the Pro Bono Legal Community.        CLE

              9:00AM - 10:30AM
              State and Local Taxes: Practioner’s Roundtable CLE (Executive Session)
              9:30AM - 11:30AM
              Committee on Simplification CLE (Executive Session)
              Chair: Armando Gomez, Skadden Arps Slate Meagher & Flom LLP,
              Washington, DC
              9:30AM - 1:30PM
              Companions’ Tour CLE (Ticketed Event)
              Backstage at the San Francisco Opera
              See p. 5 for a full description.




         26                                         I Real Property I Probate & Trust
                                              PROGRAM SCHEDULE
 SECTION PROGRAMS
 10:00AM - 11:30AM
 Buy-Sell Agreements and Related Tax Issues for Closely Held Businesses
 (Lecture Track)
 A discussion of tax and non-tax issues in drafting buy-sell agreements and
 other issues concerning exit strategies and succession planning for closely
 held businesses.
 10:00AM - 11:30AM
 Current Developments in Assignment of Rents and Other Issues of Interest
 Only to Those Who Value Money
 The Bankruptcy Reform Act of 1994 solved all our problems with




                                                                                         SATURDAY |
 enforcement of assignments of rents, right? Nothing could be further
 from the truth. State case and statutory law continues to be all over the
 map regarding what steps need to be taken to “perfect”, “activate” or
 “enforce” the assignment of rents and what each of these really mean
 under state law and the Bankruptcy Code. Issues remain as to what
 constitutes rents, what relationships are created or avoided by the various             AM
 enforcement methods, what obligations for property related expenses a
 lender may have when it receives the rents and what rights or obligations
 might a tenant have in all of this. NCCUSL has been hard at work in
 drafting a uniform act to take to the states to resolve many of these issues,
 simplify the enforcement process and clarify the rights and obligations of
 the parties to the enforcement process. Join a lively panel debate featuring
 experts that have been involved first-hand in the key issues.
 Panelists:                                            ,
               Ira Waldman, Cox, Castle & Nicholson LLP Los Angeles, CA

               Professor Patrick A. Randolph, Jr., University of Missouri-
               Kansas City School of Law, Kansas City, MO

               Norma J. Williams, Williams & Associates, Los Angeles, CA

 Sponsored by: Workouts, Foreclosures and Bankruptcies Committee (RP)

10:00AM - 11:30AM
Federal Income Taxation of Real Estate Committee (RP) and Capital Recovery and
Leasing Committee (Tax)      JT
Chairs: Michael Hirschfeld, Dechert LLP, New York, NY; Richard G.
Blumenreich, KPMG LLP, Washington, DC
Real Estate Leasing: Tax Opportunities and Pitfalls.

 SECTION PROGRAM
 10:00AM - 11:30AM
 Section 2036: When Do Retained Interests In or Powers Over Transferred Assets
 Require Estate Inclusion? (The Importance of Sections 2036 and 2038
 to Estate)         (Basic Track)
 Knowing what retained interests or powers over transferred assets will cause
 inclusion of those assets in the gross estate for estate tax purposes is central
 to structuring the powers of trustees. When will mere implied interests or
 powers cause problems? These issues are increasingly important in other
 areas as well, such as designing family limited partnerships.


10:30AM - 11:00AM
State and Local Taxes Subcommittee: State and Local Tax Lawyer CLE




 I Tax I Joint Meeting                                                              27
         PROGRAM SCHEDULE
               COMMITTEE LUNCHEONS
               12:00PM - 1:30PM
               Civil & Criminal Tax Penalties and Standards of Tax Practice   CLE
               (Ticketed Event)
               Sponsored by: Taggart & Hawkins
               12:00PM - 1:30PM
               Diversity CLE JT (Ticketed Event)
               Speaker: Josephine Rick, The Sloane Group, Inc., Silver Spring, MD
               Topic: Capitalizing on Differences
               12:00PM - 1:30PM
               Employee Benefits   CLE   (Ticketed Event)

              1:00PM - 4:00PM
              Community Outreach Program: What You Really Ought to Know About Real Estate
              But Never Learned in Law School
              Chair: Emanuel B. Halper, American Development & Consulting Corp.,
              Greenvale, NY and Hofstra University Law School, Hempstead, NY
              For more information, please contact Antonette Smith, (312) 988-5260,
              asmith4@staff.abanet.org.

               SECTION PROGRAM
               1:45PM - 2:45PM
| SATURDAY




               Assignment and Subleasing Roundtable Workshop
               Participate in a table discussion on one of our topics and then learn
               about all topics in table reports. Topics include the impact of the 2005
               Bankruptcy Code amendments on lease assignments; credit criteria for
               assignees and releasing assignors; profit-sharing upon subleasing and
PM             assignments; and carving-up leases by partial assignments of rights and
               privileges. Additionally, authors of chapters from The Complete Book of
               Subleasing and Assignments, new from ABA Publishing, will be available
               to discuss their chapters.
               Panelists:    Jasleen K. Anand, Jasleen K. Anand Attorney at Law, Valley
                             Stream, NY

                             Thomas C. Barbuti, Whiteford Taylor & Preston LLP,
                             Baltimore, MD

                             Richard M. Frome, The Law Office of Richard M. Frome,
                             New York, NY

                             Brent Shaffer, Young Conaway Stargatt & Taylor LLP,
                             Wilmington, DE

               Sponsored by: Assignment and Subleasing Committee (RP)




         28                                          I Real Property I Probate & Trust
                                             PROGRAM SCHEDULE
SECTION PROGRAMS
1:45PM - 2:45PM
Opinions on Personal Property Security Interests
A discussion regarding legal opinions covering personal property security
interests with emphasis on UCC legal opinions and real estate
transactions that involve significant personal property.
Panelists:    Mary Aronov, Baker Donelson Berman Caldwell &
              Berkowitz PC, Memphis, TN

              Brooks R. Smith, Boult Cummings Conners & Berry PLC,
              Nashville, TN

              Steven O. Weiss, Heller Ehrman LLP, Los Angeles, CA

              Sterling Scott Willis, Correro Fishman Haygood Phelps
              Walmsley & Casteix LLP, New Orleans, LA

Sponsored by: Legal Opinions Committee (RP)
2:00PM - 3:30PM
Charitable Remainder Trusts - A Review and What’s New      (Lecture Track)
This program will review the IRC provisions, Department of Treasury
Regulations and IRS guidance regarding charitable remainder trusts,
including current developments. It will also provide practical charitable
planning strategies for your clients.
                                                                                      SATURDAY |




Panelists:    Jonathan Lander, PNC Advisors, Philadelphia, PA
              Roberta Barsotti, PNC Advisors, Philadelphia, PA

Sponsored by: Fiduciary Income Tax Committee (PT)
2:00PM - 4:00PM                                                                       PM
Current Fiduciary and Litigation Issues     JT
This program will discuss the implications of the developing case law for
the structure of plans and the activities of fiduciaries. Panelists will offer
advice on “how to” comply with duties and responsibilities and reduce
exposure to liability, considering employer securities investments, statute
of limitations (including self adopted), remedies, arbitration and standard
of review of plan administrator determinations.
Moderators: Peter M. Kelly, BlueCross BlueShield Association, Chicago, IL

              David E. Gordon, Clark Consulting, Los Angeles, CA

Co-Sponsored by: Employee Benefits Committee (Tax), Employee
Benefits Group (RPPT)
2:00PM - 3:30PM
Selecting the Situs of a Trust: State Fiduciary Income Tax Implications
(Basic Track)
Since fiduciary income tax can be a significant expense for trusts, situs
can often be selected or changed to take advantage of differences in tax
laws across jurisdictions. Not all states tax trust income by relying solely
on the grantor’s residence. In certain states several factors combine to
determine a trust’s liability for state income tax: the location of a trust’s
assets, beneficiaries, trustees, and grantor. Depending on the terms of the
trust, a conscious reordering of these elements can often provide
significant financial gain to the trust.
Sponsored by: Non-Tax Issues Affecting the Planning and Administration
of Estates and Trusts Committee (PT)




I Tax I Joint Meeting                                                            29
         PROGRAM SCHEDULE
              2:00PM - 5:00PM
              Standards of Tax Practice
              Chair: Kathryn Keneally, Fulbright & Jaworski LLP, New York, NY
              2:00pm        Opening Remarks by the Chair.         CLE

              2:05pm        The Importance of Zealous Advocacy Under the Model
                            Rules and Circular 230.

              3:15pm        The Crime Fraud Exception to Attorney-Client Privilege and
                            its Impact on Practitioner Obligations Under Circular 230.


              4:00pm        Important Developments.

              2:00PM - 3:30PM
              Technology Committee CLE
              Chair: Thomas A. Jorgensen, Calfee Halter & Griswold LLP, Cleveland, OH

               SECTION PROGRAM
               2:00PM - 4:30PM
               Transaction Costs: To Capitalize or Not to Capitalize - Is There a Question?
               This program will explore issues that arise in reviewing the proper tax
               treatment of transaction costs. First, the program will review practice issues
               that have been identified regarding the deduction or capitalization of
               transaction costs, including for example, how to substantiate the deduction
| SATURDAY




               of success-based fees, whether particular transactions are properly
               considered within the ambit of the covered transactions, and how to define
               an accounting method for deal costs. Second, the program will review the
               issues that the government is considering as part of the publication project
               for Notice 2004-18, which will address the recovery of capitalized
PM             transaction costs. The program also will discuss various transactions that are
               being considered within an IRS-Treasury “study group.” There will be a
               review of general objectives regarding consistency (e.g., across transactions,
               with respect to acquirer and target, and taxable v. nontaxable transaction)
               that are being considered as part of this project. Finally, the program will
               consider statutory to recovery, including 197(e)(7), 362(b), and 162(k).
               Sponsored by: Tax Accounting Committee (Tax)




         30                                            I Real Property I Probate & Trust
                                                              ALPHA SCHEDULE
The      symbol indicates that the program is being audio-taped by Teach’em; 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;
and the JT indicates that this program is jointly sponsored by Tax and RPPT.

COMMTTEE NAME                                                         DAY        TIME

                            SECTION OF TAXATION BY COMMITTEE
Administrative Practice                                               Fri.       8:30a-11:30a
Dinner CLE (Invitation Only)                                          Thu.       6:30p-10:00p
Luncheon CLE (Ticketed)                                               Fri.       12:30p-1:30p

Affiliated & Related Corporations                                     Fri.       8:30a-11:30a
Luncheon CLE (Ticketed)                                               Fri.       12:00p-1:30p

Appointments to the Tax Court CLE (Executive Session)                 Fri.       11:30a-12:30p

Banking and Savings Institutions                                      Fri.       8:30a-11:30a
Luncheon CLE (Ticketed)                                               Fri.       12:30p-2:00p

Bankruptcy & Workouts                                                 NOT MEETING

Business Cooperatives & Agriculture        JT                         Fri.       2:30p-5:30p
Joint Program    JT                                                   Fri.       8:30a-11:30a
Luncheon CLE (Ticketed)                                               Fri.       12:30p-1:30p

Capital Recovery & Leasing                                            Fri.       8:30a-10:30a
Joint Program    JT                                                   Sat.       10:00a-11:30a

Civil and Criminal Tax Penalties                                      Sat.       8:30a-11:30a
Luncheon CLE (Ticketed)                                               Sat.       12:00p-1:30p

Closely Held Businesses        JT                                     Fri.       8:30a-11:30a
                                                                      Fri.       2:30p-6:00p

Committee on Simplification CLE (Executive Session)                   Sat.       9:30a-11:30a

Committees                                                            NOT MEETING

Corporate Offshore Inversions and International                       Thu.       5:00p-7:30p
Tax Reform Task Force CLE (Executive Session)

Corporate Tax                                                         Sat.       8:30a-11:30a
Luncheon CLE (Ticketed)                                               Fri.       12:00p-1:30p

Court Procedure & Practice                                            Fri.       2:30p-5:30p
Luncheon CLE (Ticketed)                                               Fri.       12:30p-1:30p
Officers & Subcommittee Chairs                                        Sat.       7:45a-9:00a
Breakfast CLE (Ticketed)

Distinguished Service Award CLE (Executive Session)                   Sat.       8:00a-9:00a

Diversity         JT                                                  Fri.       4:00p-6:30p
                                                                                                      ALPHA SCHEDULE




Luncheon CLE JT (Ticketed)                                            Sat.       12:00p-1:30p
Reception   CLE JT                                                    Fri.       5:30p-6:30p

Domestic Relations                                                    Fri.       8:30a-11:30a

Employee Benefits                                                     Fri.       3:00p-5:30p
                                                                      Sat.       8:30a-11:30a
Cash Bar CLE                                                          Fri.       5:30p
Leadership Meeting/Luncheon CLE (Invitation)                          Fri.       12:30p-1:00p
Luncheon CLE (Ticketed)                                               Sat.       12:00p-1:30p
Young Lawyers Forum     CLE                                           Fri.       1:00p-2:00p




For complete program descriptions, visit the Meeting website at                                  31
http://meetings.abanet.org/meeting/tax/FALL05
            ALPHA SCHEDULE
                 Employee Benefits Subcommittees and Task Force Update Programs:
                 Corporate Counsel Forum                                      Fri.               12:00p-1:00p

                 EEOC Issues                                                          Fri.       1:00p-2:00p

                 Employee and Independent Contractor Status; Controlled               Fri.       12:00p-1:00p
                 Groups, Affiliated Service Groups & Leased Employees

                 ESOPs                                                                Fri.       10:00a-11:00a

                 Executive Compensation; Federal Securities Laws Issues               Fri.       8:00a-10:00a

                 Fiduciary Responsibility; Litigation;                                Fri.       10:00a-12:00p
                 Prohibited Transactions; and ESOPs

                 Foreign & International Issues                                       Fri.       11:00a-12:00p

                 Government Plans; Section 457 Issues; and                            Fri.       1:00p-2:45p
                 Section 403(b) & EO Issues

                 IRAs                                                                 Fri.       10:00a-11:00a

                 Mergers & Acquisitions                                               Fri.       1:00p-2:45p

                 Nondiscrimination & Section 415 Issues                               Fri.       1:00p-2:00p

                 Pension Legislation; Pension Simplification                          Fri.       1:00p-2:00p
                 Task Force; and Enron Task Force

                 QDROs, QMSCOs, Other Domestic Relations                              Fri.       1:00p-2:45p
                 Benefits Issues; and Estate & Gift Tax Issues

                 Qualified Cash or Deferred Arrangements                              Fri.       10:00a-12:00p

                 Retiree Health, VEBAs & Other Funding                                Fri.       8:00a-10:00a
                 Vehicles; COBRA and Welfare Plan Design
                 Issues; HIPAA; Welfare Plan Legislation;
                 State Insurance Plans and Flexible Benefits

                 Self-Corrections & Other Administrative Practices;                   Fri.       8:00a-10:00a
                 Master, Prototype and Volume Submitter Plans and
                 Determination Letter Task Force

                 Special Defined Benefit Plan Issues; Cash Balance Plan Task Force Sat.          7:00a-8:15a

                 Task Force on Electronic Plan Administration                         Fri.       12:00p-1:00p

                 Employment Taxes                                                     Fri.       1:30p-5:30p
                 Practitioner’s Workshop (not taped)                                  Fri.       5:00p-5:30p

                 Energy & Environmental Taxes                                         Fri.       2:30p-5:30p

                 Estate & Gift Taxes                                                  Fri.       8:30a-11:30a
                 Luncheon CLE (Ticketed)                                              Fri.       12:30p-1:30p
ALPHA SCHEDULE




                 Young Lawyer Subcommittee          CLE                               Fri.       1:30p-2:30p

                 Exempt Organizations                                                 Fri.       8:45a-5:00p
                 Luncheon CLE (Ticketed)                                              Fri.       12:15p-1:15p




            32                                    For complete program descriptions, visit the Meeting website at
                                                               http://meetings.abanet.org/meeting/tax/FALL05
                                                            ALPHA SCHEDULE
Exempt Organizations Subcommittees:
Health Care Organizations                                         Fri.    7:30a-8:30a

Political & Lobbying Organizations and Activities                 Fri.    7:30a-8:30a

Private Foundations; Unrelated Business                           Fri.    7:30a-8:30a
Income; and International Philanthropy

Religious Organizations                                           Fri.    7:30a-8:30a

Fiduciary Income Tax                                              Sat.    8:30a-11:30a
Luncheon CLE (Ticketed)                                           Fri.    12:30p-1:30p
Young Lawyers Subcommittee           CLE                          Fri.    1:30p-2:30p

Financial Transactions                                            Fri.    2:30p-5:30p
Luncheon CLE (Ticketed)                                           Fri.    12:30p-2:00p

Foreign Activities of US Taxpayers                                Fri.    1:30p-3:30p
Business Meeting       CLE                                        Fri.    5:30p-6:30p
Joint Program                                                     Fri.    10:30a-12:00p
Luncheon CLE (Ticketed)                                           Fri.    12:00p-1:30p
Young Lawyers Subcommittee         CLE                            Fri.    5:30p-6:30p

Foreign Lawyers Forum                                             NOT MEETING
Joint Program                                                     Fri.   10:30a-12:00p
Luncheon CLE (Ticketed)                                           Fri.   12:00p-1:30p

Foreign Tax Credits Task Force CLE (Executive Session)            Sat.    8:30a-9:30a

Formation of Tax Policy                                           Fri.    8:30a-11:30a

Government Relations                                              NOT MEETING

Government Submissions                                            NOT MEETING

Important Developments Workshop CLE                               Fri.    11:30a-12:30p

Individual Income Tax                                             Sat.    9:00a-11:30a

Insurance Companies                                               Fri.    2:30p-5:30p
Luncheon CLE (Ticketed)                                           Fri.    12:30p-2:00p

Investment Companies                                              Fri.    10:00a-12:30p
Luncheon CLE (Ticketed)                                           Fri.    12:30p-2:00p

Low Income Taxpayers                                              Sat.    7:00a-9:00a
Joint Program                                                     Fri.    8:30a-11:30a
Low Income Taxpayer Clinics Workshop                              Thu.    1:00p-6:00p
(Registration Required)

Membership & Marketing CLE                                        Fri.    8:30a-9:30a

NewsQuarterly Editorial Board                                     NOT MEETING
                                                                                               ALPHA SCHEDULE




Nominating CLE (Executive Session)                                Fri.    2:00p-5:00p

Officers and Council Meeting CLE (Executive Session)              Thu.    9:00a-5:00p

Partnerships & LLCs                                               Fri.    8:30a-11:30a
Breakfast    CLE (Ticketed)                                       Sat.    7:15a-8:30a
Dinner     CLE (Reservations)                                     Thu.    6:30p-9:30p
LLC Subcommittee                                                  Sat.    8:30a-10:30a
Luncheon      CLE (Ticketed)                                      Fri.    12:30p-1:30p
Task Force on Simplification of Subchapter K CLE                  Thu.    4:00p-6:00p

Pro Bono                                                          Sat.    9:00a-10:30a
Low Income Taxpayer Clinics Workshop                              Thu.    1:00p-6:00p
(Registration Required)




For complete program descriptions, visit the Meeting website at                           33
http://meetings.abanet.org/meeting/tax/FALL05
            ALPHA SCHEDULE
                 Professional Services CLE                                             Fri.       11:30a-12:30p

                 Programs & Meetings CLE                                               Fri.       5:00p-6:00p

                 Real Estate                                                           Fri.       2:30p-5:30p
                 Breakfast     CLE (Ticketed)                                          Sat.       7:15a-8:30a
                 Dinner      CLE (Reservations)                                        Thu.       6:30p-9:30p
                 Luncheon       CLE (Ticketed)                                         Fri.       12:30p-1:30p

                 Resolutions                                                           NOT MEETING

                 S Corporations                                                        Fri.       1:00p-5:30p
                 Breakfast   CLE (Ticketed)                                            Sat.       7:15a-8:30a

                 Sales, Exchanges and Basis                                            Sat.       8:30a-11:45a
                 Breakfast CLE                                                         Sat.       7:30a-8:30a

                 Special Projects                                                       NOT MEETING

                 Standards of Tax Practice                                             Sat.       2:00p-5:00p
                 Joint Program                                                         Sat.       10:05a-11:30a
                 Luncheon CLE (Ticketed)                                               Sat.       12:00p-1:30p

                 State and Local Taxes                                                 Fri.       2:30p-5:30p
                 A Review of Current State Tax Decisions                               Fri.       1:00p-1:30p
                 Cash Bar & Executive Business Meeting                                 Thu.       6:30p-10:00p
                 Dinner CLE (Executive Session)
                 Luncheon CLE (Ticketed)                                               Fri.       12:30p-1:00p
                 Practitioners’ Roundtable CLE (Executive Session)                     Sat.       9:00a-10:30a
                 State & Local Tax Lawyer CLE                                          Sat.       10:30a-11:00a

                 Tax Accounting                                                        Fri.       2:30p-5:30p

                 Tax CLE On the Road Planning Meeting         CLE                      Fri.       11:30a-12:30p

                 Tax Exempt Financing                                                  NOT MEETING
                 Luncheon CLE (Ticketed)                                               Fri.   12:30p-2:00p

                 Tax Practice Management          JT                                   Fri.       2:30p-4:30p

                 Teaching Taxation                                                     Fri.       2:30p-4:00p

                 Technology Committee CLE                                              Sat.       2:00p-3:30p

                 Transfer Pricing                                                      Fri.       3:30p-5:30p
                 Joint Program                                                         Fri.       10:30a-12:00p
                 Luncheon CLE (Ticketed)                                               Fri.       12:00p-1:30p

                 US Activities of Foreigners & Tax Treaties                            Fri.       8:30a-10:30a
                 Business Meeting CLE                                                  Fri.       5:30p-6:30p
                 Joint Program                                                         Fri.       10:30a-12:00p
                 Luncheon CLE (Ticketed)                                               Fri.       12:00p-1:30p

                 VAT & Other Consumption Taxes                                         NOT MEETING
ALPHA SCHEDULE




                 Young Lawyers Forum                   JT                              Fri.       4:00p-6:30p
                 Orientation   CLE                                                     Fri.       7:00a-7:30a
                 Reception   CLE JT                                                    Fri.       5:30p-6:30p

                                                   PROBATE & TRUST DIVISION
                 Alternative Career Paths in Real Property, Probate & Trust            Fri.       4:00p-5:00p
                 Law       CLE


                 Business Planning Group          JT                                   Fri.       8:30a-11:30a
                                                                                       Fri.       2:30p-5:30p

                 Charitable Planning and Exempt Organizations                          Fri.       10:30a-12:30p




            34                                     For complete program descriptions, visit the Meeting website at
                                                                http://meetings.abanet.org/meeting/tax/FALL05
                                                              ALPHA SCHEDULE
Community Outreach Program                                        Sat.   9:00a-12:00p

Diversity Luncheon CLE JT (Ticketed)                              Sat.   12:00p-1:30p

Elder Law and Disability Group                                    Fri.   2:30p-4:30p

Employee Benefit Plans and Other                                  Fri.   10:30a-12:30p
Compensation Arrangements

How RPPT Works and the Benefits of Involvement          CLE       Fri.   8:00a-9:00a

Income and Transfer Tax Planning                                  Fri.   2:30p-4:30p

Litigation and Controversy Group       JT                         Fri.   8:30a-11:30a
                                                                  Fri.   2:30p-5:30p

Non-Tax Estate Planning Consideration                             Fri.   10:30a-12:30p

Practice Management Group        JT                               Fri.   2:30p-4:30p

Probate & Trust Division Luncheon CLE (Ticketed)                  Fri.   12:30p-2:30p

Wealth Planning                                                   Fri.   8:30a-10:30a

Young Lawyers Network
Reception   CLE JT                                                Fri.   5:30p-6:30p

                                 REAL PROPERTY DIVISION
Alternative Career Paths in Real Property, Probate & Trust        Fri.   4:00p-5:00p
Law      CLE


Community Outreach Program                                        Sat.   1:00p-4:00p

Diversity Luncheon CLE JT (Ticketed)                              Sat.   12:00p-1:30p

Federal Income Taxation of Real Estate Committee        JT        Sat.   10:00a-11:30a

Hospitality, Community Recreation                                 Fri.   1:30p-3:15p
& Common Interest Development Group

How RPPT Works and the Benefits of Involvement          CLE       Fri.   8:00a-9:00a

Land Use and Environmental Group                                  Fri.   10:00a-11:45a

Leasing Group                                                     Sat.   8:00a-9:45a

Practice Management Group                                         Fri.   3:30p-5:15p

Real Estate Financing Group                                       Fri.   10:00a-11:45a

Real Estate Taxation and Governmental                             Fri.   8:00a-9:45a
Incentives Group
                                                                                              ALPHA SCHEDULE




Real Estate Transactions and Management Group                     Fri.   1:30p-3:15p

Real Property Division Luncheon CLE (Ticketed)                    Fri.   11:45a-1:15p

Residential, Multi-Family and Special Use Group                   Fri.   3:30p-5:15p

Special Investors and Investment Structure Group                  Fri.   8:00a-9:45a

Young Lawyers Network
Reception   CLE JT                                                Fri.   5:30p-6:30p




For complete program descriptions, visit the Meeting website at                          35
http://meetings.abanet.org/meeting/tax/FALL05
            ALPHA SCHEDULE
                                                       SECTION PROGRAMS
                 Assignment and Subleasing Roundtable                                 Sat.      1:45p-2:45p
                 Workshop      (RP)

                 Buy-Sell Agreements and Tax Related Issues for Closely               Sat.      10:00a-11:30a
                 Held Businesses    (Lecture Track) (PT)

                 Charitable Remainder Trusts - A Review                               Sat.      2:00p-3:30p
                 And What’s New       (Lecture Track) (PT)

                 Current Developments in Assignment of Rents and Other                Sat.      10:00a-11:30a
                 Issues of Interest Only to Those Who Value Money   (RP)

                 Current Fiduciary and Litigation Issues       JT                     Sat.      2:00p-4:00p

                 Opinions on Personal Property Security                               Sat.      1:45p-2:45p
                 Interests  (RP)

                 Partnerships and LLCs: Legal and Tax Effects of Charging             Sat.      8:00a-9:45a
                 Orders and Foreclosure        (Basic Track) (PT)

                 Property Preservation Task Force: Using Limited Liability            Sat.      8:00a-9:45a
                 Companies to Avoid Land Loss       (Lecture Track) (PT)

                 Section 2036: When Do Retained Interests In or                       Sat.      10:00a-11:30a
                 Powers Over Transferred Assets Require Estate Inclusion?
                        (Basic Track) (PT)

                 Selecting the Situs of a Trust: State Fiduciary                      Sat.      2:00p-3:30p
                 Income Tax Implications         (Basic Track) (PT)

                 Transaction Costs: To Capitalize or Not                              Sat.      2:00p-4:30p
                 to Capitalize - Is There a Question?    (Tax)

                 Vapor Intrusion: Defining and Managing Risks in Property             Sat.      8:00a-9:30a
                 Ownership, Management, Redevelopment and Use        (RP)

                                   ACTIVITIES/NETWORKING/ADDITIONAL PROGRAMMING
                 Committee Chairs, Vice Chairs, Officers                              Sat.       7:30a-8:15a
                 and Council Breakfast CLE

                 Companions’ Breakfast CLE (Complimentary)                            Fri.      8:30a-9:30a

                 Companions’ Activities:
                 Asian Art Museum Tour & Luncheon CLE (Ticketed)                      Fri.      10:00a-3:00p
                 Backstage at the San Francisco Opera CLE (Ticketed)                  Sat.      9:30a-1:30p

                 Joint Session Breakfast/Plenary Session      CLE     (Ticketed)      Fri.      7:30a-8:30a

                 Joint Section Reception CLE (Ticketed)                               Fri.      6:30p-8:00p
ALPHA SCHEDULE




            36                                    For complete program descriptions, visit the Meeting website at
                                                               http://meetings.abanet.org/meeting/tax/FALL05
                                2005 Joint Fall CLE Meeting R
       ABA Sections of Taxation and Real Property, Probate an
                                EARLY BIRD DEADLINE: August 11, 2005
                                    CANCELLATIONS: $50 processing fee.
Return to: Meeting Registrar
ABA Section of Taxation, 740 15th Street, NW, Washington, DC 20005
Fax: (202) 662-8682
ONLINE REGISTRATION:
http://meetings.abanet.org/meeting/tax/fall05/


                            INFORMATION
(Please type or print clearly.)
Attendee Name: ____________________________________________
__________________________________________________________
Badge Nickname: ___________________________________________
ABA ID No.: _______________________________________________
Indicate the Section to which you belong:
I Tax I RPPT I Tax & RPPT I None
Please check here if you need CLE Credit in one of the following states:
I NY I PA I TX I DE
Companion Name: _________________________________________
Firm or Agency: ____________________________________________
Business Address: ____________________________________________
City/State/Zip: _____________________________________________
Daytime Telephone: _________________________________________
Fax: ______________________________________________________
E-mail*: ___________________________________________________
*Confirmation will be sent by e-mail.
Check below if you require ADA services:
 I Audio I Visual I Mobile

                         REGISTRATION FEE
If Postmarked or Faxed                               by         after
                                                  8/11/05      8/11/05
Check one:
Section Member/Associate                          I   $440     I   $490
Non-Section Member                                I   $500     I   $550
Foreign Lawyer                                    I   $440     I   $490
Young Lawyer                                      I   $340     I   $390
 (Admitted to the Bar less than 3 years)
Full-Time Law Professor                           I   $140     I   $150
Government Official                               I   $140     I   $150
Full-Time LITC Employee                           I   $140     I   $150
Full-Time J.D./LL.M./MT Candidate                 I   waived   I   waived

       LOW INCOME TAXPAYER CLINICS WORKSHOP
            THURSDAY, SEPTEMBER 15, 2005
General Registration Fee                                       I $25
Full-Time LITC Employee Registration Fee                       I $12
              UNABLE TO ATTEND THE MEETING?
Mail the following materials after the Meeting:
I Meeting Materials CD-ROM                        $60.00 + $12.95 S/H

 For Tax Section Use Only
 Check # ________ Amount Rec’d $ ________ Initials ________

(PL)
                            REGISTRATION AND TICKET FORM
 Registration and Ticket Form




                                                                                        REGISTRATION AND TICKET FORM
nd Trust Law      San Francisco, CA – September 15-17
      FINAL REGISTRATION DEADLINE: September 8, 2005
      NO REFUNDS after August 25, 2005

                                    TICKETED EVENTS
       FRIDAY, September 16
       TOUR/ACTIVITY
       1 Asian Art Museum Tour & Luncheon               ___ at $80 each = $_____


                                                        I Yes, I will attend.
       SECTION BREAKFAST

                                                        I No, I will not attend.
       2 Professor Joseph Bankman
          (Complimentary – 1 per registrant)

       LUNCHEONS
       3 Administrative Practice and
          Court Procedure & Practice                    ___ at $46 each = $_____
       4 Banking & Savings, Financial Transactions,
          Insurance Companies, Investment Companies
          and Tax Exempt Financing                      ___ at $46 each = $_____
       5 Business Cooperatives & Agriculture            ___ at $46 each = $_____
       6 Corporate Tax and Affiliated
          & Related Corporations                        ___ at $46 each = $_____
       7 Estate & Gift Taxes and Fiduciary Income Tax   ___ at $46 each = $_____
       8 Exempt Organizations                           ___ at $46 each = $_____
       9 FAUST, FLF, Transfer Pricing and USAFTT        ___ at $46 each = $_____
       10 Partnerships & LLCs and Real Estate           ___ at $46 each = $_____
       11 Probate & Trust Division                      ___ at $46 each = $_____
       12 Real Property Division                        ___ at $46 each = $_____
       13 State & Local Taxes                           ___ at $46 each = $_____

       SECTION RECEPTION
       14 Joint Section Reception                       ___ at $70 each = $_____

       SATURDAY, September 17
       BREAKFASTS
       15 Court Procedure & Practice
          Officers & Subcommittee Chairs                ___ at $33 each = $_____
       16 Partnerships & LLCs, Real Estate
          and S Corporations                            ___ at $33 each = $_____

       LUNCHEONS
       17 Civil & Criminal Tax Penalties
          and Standards of Tax Practice                 ___ at $46 each = $_____
       18 Diversity (RPPT)                              ___ at $46 each = $_____
       19 Employee Benefits                             ___ at $46 each = $_____

       TOUR
       20 Backstage at the San Francisco Opera          ___ at $30 each = $_____

                               PAYMENT INFORMATION
       TOTALS:
       Registration Fee                                 $ ________________
       Ticketed Events Total                            $ ________________
       LITC Registration Fee                            $ ________________
       TOTAL PAYMENT:                                   $ ________________
       Make checks payable to ABA SECTION OF TAXATION or fill in the
       credit card information below. Signature is required for credit card
       payment.
       Check One:       I Master Card         I VISA       I AmEx
       CARD NO.: _________________________________________
       EXP. DATE: _________________________________________
       CC Verification Code*:_________________________________
       * THIS IS A REQUIRED FIELD. For Visa & MC, the 3 digits on the
       back of the card in the signature line. For AmEx, the 4 digits located on
       the front of the card on the right hand side above the card number
       I Billing Address is the same as Business Address on this form.
       Billing Address:       ________________________________________
                              ________________________________________
                              ________________________________________
       SIGNATURE: _________________________________________                        38
                       Please complete the FORM and
                                     DEADLINE: AU
        We urge you to make your reservations early, as th
Group:                ABA Section of Taxation and Real Property, Probate and Trust L
Group Dates:          09/14/2005 - 09/18/2005
Name: ___________________________________________________________
Co-Affiliation: _____________________________________________________
Address:    ________________________________________________________
            ________________________________________________________
City, State, Zip: ____________________________________________________
Phone: ___________________________________________________
E-mail: ___________________________________________________________
Arrival Date and Time: ______________________________________

                                                                          ROOM RE
Please circle your preference:
King Bed              2 Double Beds                 Non-Smoking

                                                                              HOTE
HEADQUARTERS HOTEL
Hyatt Regency San Francisco               Park Hyatt San Francisco
5 Embarcadero Center                      333 Battery Street
San Francisco, CA 94111                   San Francisco, CA 94111
Phone: 415-788-1234                       Phone: 415-392-1234
Fax: 415-398-2567                         Fax: 415-421-2433


Guarantee Policy: Please note a deposit of one night’s room and
tax (currently 14%) will be required to hold all reservations. You
will receive a confirmation within five (5) days from the date on
which the hotel receives the reservation.



                                                                  PAYMENT INF

Credit Card Type:     _____ Visa _____ Mastercard _____ AMEX

Card Number: _____________________________________________

Exp Date: _________________________________________________

Signature: _________________________________________________

Check Enclosed: $___________



                                      RESERVE YOUR HOTE
                      https://resweb.passkey.com/Resweb.do?m
                                     HOTEL RESERVATION FORM
d return to the HOTEL directly
UGUST 5, 2005
he hotel frequently sells out prior to the deadline.
 Law – 2005 Joint Fall CLE Meeting


________________________________________________________________
________________________________________________________________
________________________________________________________________




                                                                                   HOTEL RESERVATION FORM
________________________________________________________________
________________________________________________________________
          Fax: ___________________________________________________
________________________________________________________________
          Departure Date and Time: _________________________________

EQUESTS


          Smoking             Handicapped Accessible

 ELS
                            GROUP RATE:
       Single Occupancy     $259.00
       Double Occupancy     $259.00

       Rates are per night and subject to a 14% tax. Check in time is after
       3:00pm. Check out time is 12:00noon. Cancellations or modifications
       must be made by 3:00pm the day prior to scheduled day of arrival to
       avoid a no show charge.




 FORMATION




 EL ROOM ONLINE!!!
mode=welcome_ei_new&eventID=21619
                                                                              42
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


2005
Joint Fall CLE Meeting
September 15-17
Park Hyatt & Hyatt Regency, San Francisco, CA
(Co-Sponsored with RPPT)

2006
Midyear Meeting
January 19-21
Sheraton, New Orleans, LA

May Meeting
May 4-6
Grand Hyatt, Washington, DC

Joint Fall CLE Meeting
October 19-21
Hyatt Regency, Denver, CO
(Co-Sponsored with RPPT)



SECTION OF REAL PROPERTY, PROBATE AND TRUST LAW
Please check for updates and additional information on the RPPT
Section website at www.abanet.org/rppt or the ABA CLE website at
www.abanet.org/cle


2005
Joint Fall CLE Meeting
September 15-17
Park Hyatt & Hyatt Regency, San Francisco, CA
(Co-Sponsored with TAX)


2006
Spring CLE and Council Meeting
May 4-7
Manchester Grand Hyatt, San Diego, CA

Joint Fall CLE Meeting
October 19-21
Hyatt Regency, Denver, CO
(Co-Sponsored with TAX)
Section of Taxation                                                             Non Profit Org.
American Bar Association                                                         U.S. Postage
                                                                                    PAID
740 15th Street, NW                                                             Washington, DC
Washington, DC 20005                                                             American Bar
(202) 662-8670                                                                    Association




                                                                               adline
                                                                         ird De
                                                                  Early B 11, 2005!
                                                                         t
                                                                   Augus er Now!
                                                                     Regist




For complete program descriptions, visit the Meeting website at
http://meetings.abanet.org/meeting/tax/FALL05

								
To top