Section Luncheon Saturday January am pm Remarks by liaoguiguo

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									                        Section Luncheon:
 Saturday, January 25, 11:45am-12:40pm
    Remarks: Pamela F. Olson, Assistant
    Secretary (Tax Policy), Department of
                Treasury, Washington, DC

                         Plenary Session:
  Saturday, January 25, 12:40pm-1:45pm
International Tax Reform – Where Do We
                          Go From Here?

                        Section Programs:
            Saturday, January 25, 2:00pm

            • Capitalization of Intangibles

    • Current Developments in Individual,
 Corporate, Partnership and Estate & Gift
                                 Taxation

    • Enhanced IRS Enforcement and the
    "Sensitive Issue" Audit: Practical and
                    Ethical Considerations

 • In Light of Recent Circumstances – An
 Updated Look at What Benefits Lawyers
    Need to Know about Securities Laws

          • Tax Planning for International
                           Joint Ventures

                           VITA Training:
Saturday, January 25, 8:30am and 2:00pm
 F     I     N     A      L         P     R      O      G      R     A      M




 TABLE OF CONTENTS
TABLE of CONTENTS
 General Information ............................................. 2
 Programs for Young Lawyers ............................... 6
 Program Schedule ..............................................12
General Information ..........................................................2
  Thursday, Young Lawyers ............................................8
Programs for October 17 ......................................12
                               th


  Friday, October 18 ...........................................13
                         th
Program Schedule ...........................................................15
  Saturday, October 19th ..................................... 52
 Thursday, January 23rd ...................................................15
 Friday, Programs .............................................. 65
 SectionJanuary 24th........................................................16
 Affiliated Organizations .......................................67
 Saturday, January 25h ....................................................58
 Alpha Programs ............................................................73
Section Schedule.................................................. 68
 Future Meetings...............................Inside Back Cover
Alpha Schedule................................................................76
Affiliated Organizations ..................................................82
Future Meetings ...........................................Inside Back Cover
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✯ General Information
                       GENERAL INFORMATION
                        San Antonio welcomes the Section of
                        Taxation to the 2003 Midyear
                        Meeting, January 23-25th. Join us in
                        this historic city and take advantage
                        of the opportunity to meet with
      Herbert N. Beller government officials and the
       Section Chair    country’s leading tax attorneys to
     discuss the latest federal tax policy initiatives,
     regulations, legislative forecasts, and planning ideas.


     DRESS CASUAL
     The dress for the 2003 Midyear Meeting is casual, so
     relax and wear comfortable attire.


     REGISTRATION
     Any Section member attending any part of the 2003
     Midyear Meeting, regardless whether or not 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 registration fee includes one set of meeting
     materials 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 tickets are sold on a first-come,
     first-served basis. Tickets will not be sold at the door
     for any function. All tickets must be purchased in
     advance of the function. Payment may be made by
     check or credit card. The Section accepts American
     Express, MasterCard and VISA.


     REFUND POLICY
     The deadline for refunds was December 19, 2002. No
     further refunds will be made.




 2
                                General Information        ✯
ON-SITE REGISTRATION and TICKET
PURCHASE HOURS
The Registration Desk located in the Foyer on Level 3
of the Marriott Rivercenter will be open during the
following hours:
Thursday               12:00pm–9:00pm
Friday                  6:30am–6:30pm
Saturday                6:30am–4:00pm


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


HOSPITALITY CENTER
Location:         Atrium Lounge, Level 2, Rivercenter
A complimentary breakfast of coffee, tea, juice and
pastries will be served in the morning. Snacks, coffee,
sodas and water will be available in the afternoon.
Hours:            Friday          7:00am–4:00pm
                  Saturday        7:00am–4:00pm


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




                                                           3
✯ General Information
     MEETING MATERIALS
     As is customary, the Section Program Meeting Materials
     will be available at the Midyear Meeting in print form
     and on CD-ROM in PDF and MS Word formats. You will
     receive the format based on what was indicated on
     your Meeting Registration and Ticket Purchase Form.
     Please note that the Meeting Materials contain only the
     material for the Saturday Plenary Session and Section
     Programs. Committee meeting materials are available
     in individual meeting rooms. In addition, materials from
     selected Committee Programs will be compiled and
     made available following the meeting. Both the
     Meeting Materials and Selected Committee Handouts
     print publications are available by subscription and for
     purchase separately.
     All meeting materials including committee program
     material also will be available on Comm-Online – an
     innovative joint project of the Tax Section and
     LexisNexis™, the ABA Section of Taxation’s Primary
     Legal Publishing Sponsor, that gives members FREE
     online access to hundreds of pages of Section
     Program and Committee Meeting Materials. This
     service is available on the Section’s web site
     www.abanet.org/tax/commonline/.


     CLE AND ETHICS CREDIT
     NOTE: You must be registered for the meeting in
     order to be eligible to receive CLE or ethics credit (
     indicates that ethics credit has been requested for this
     program). Accreditation will be requested for this
     meeting from every state with mandatory continuing
     legal education (MCLE) requirements for lawyers. Each
     state has its own rules and regulations, including its
     definition of “CLE.” The Uniform Certificate of
     Attendance will be available at the meeting for both
     attendees and speakers and will be included with the
     Tax Section Meeting Materials. The Section will request
     CLE credit for subcommittee meetings that include a
     program description and names of panelists. Eligible
     subcommittees will be listed on the Uniform Certificate
     of Attendance. Please call the ABA CLE Department in
     Chicago at (312) 988-6217 with any questions
     pertaining to the number of credit hours granted by
     each state.


 4
                                General Information         ✯
REQUIREMENTS FOR NEW YORK ATTORNEYS:
You are responsible for signing in and out of each
session you attend and filling out a New York
Certificate of Attendance Form. The sign-in and out
forms will be available in each meeting room, and the
Certificate of Attendance Form will be available at the
CLE Information Booth located on Level 3 in the Foyer.
In order to receive full credit for all sessions
attended, you must stop by the CLE Information
Booth before you leave the Meeting to obtain an
authorization signature from an ABA staff
member.


AUDIO TAPES
Audiocassette tapes of committee and Section
programs will be available for purchase on-site as
well as following the meeting. Provided by Teach’em,
each program typically consists of two cassettes
and costs only $20. To place an order, contact
Teach’em at 1-800-776-5454, info@Teachem.org,
or www.Teachem.net/ABA.


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


SECTION LUNCHEON and RECEPTION
The Section Reception will take place on Friday,
January 24 from 6:30pm to 8:00pm. The Section
Luncheon will be held on Saturday, January 25 from
11:45am to 12:40pm. Pamela F. Olson, Assistant
Secretary (Tax Policy), Department of Treasury,
Washington, DC, will be the luncheon speaker. Both
events will be held in the Rivercenter.




                                                            5
✯ General Information
     VITA TRAINING (Volunteer Income
     Taxpayer Assistance)
     The Section of Taxation strongly encourages all of its
     members to participate in the Volunteer Income Tax
     Assistance (VITA) program that provides free tax return
     preparation for low-income individuals. A team of IRS
     VITA trainers will lead two training sessions, one on
     Saturday morning from 8:30am until 11:30am and one
     from 2:00pm until 5:00pm. Both sessions will be held in
     Conference Rooms 17 and 18, Level 3, Rivercenter. You
     are urged to take this 3-hour training course and then,
     upon returning home, assist our low income taxpayers
     meet their tax return filing obligations.


     ACTIVITIES and TOURS
     Friday, January 24
     8:00am–9:00am
     JW’s Restaurant, Level 2
     Companions Breakfast (Complimentary)
     9:00am–3:00pm T
     A Heart of D O
                       U
                 San Antonio Art Tile Tour & Luncheon
           S OL
     (Ticketed Event: $75.00)
     Buses will depart promptly at 9:00am from
     the front entrance of the Marriott Rivercenter
     (Bowie Street).
     The tour will begin in the Alamo Plaza. Participants
     will then walk to the Menger Hotel to view the
     Victorian-tile lobby and tile courtyard fountains. The
     tour will then continue through other famous San
     Antonio buildings along the River Walk including La
     Mansion Hotel and La Villita Assembly Hall where
     works from current tile artists will be on display.
     The next stop on the tour will be the McNay Art
     Museum, ranked as one of the top places in the
     world to see decorative tile. Participants will also stop
     at the home of Janie Williams, who specializes in
     designing and creating tiles for kitchens, baths,
     fireplaces, pools, fountains and murals. Today her
     work fills her home and the open courtyard in
     enchanting ways and the basement houses her own
     studio where creativity holds court.



 6
                               General Information         ✯
After enjoying lunch at Club Giraud, participants will
return to the hotel. Please note Club Giraud’s dress
code does not permit jeans, t-shirts, shorts or
sneakers.
Saturday, January 25
                 T
            OU
9:00am–12:00pm
OutlyingD
   SOL
          Missions
(Ticketed Event: $25.00)
Buses will depart promptly at 9:00am from
the front entrance of the Marriott Rivercenter
(Bowie Street).
The tour will begin at Mission San José, known as the
“Queen of the Missions” and established in 1720.
This mission is considered one of the most beautiful,
prosperous and best fortified. The famous “Rosa’s
Window,” although weathered by time, is one of the
finest pieces of Spanish Colonial ornamentation in
the country.
The next stop will be the Mission Concepción, an
unrestored Catholic Church that has stood intact
since 1755. Rare original frescoes are still in evidence
on the interior walls and ceilings. The church was also
used to garrison US troops in the late 1840s, and was
later dedicated to Our Lady of Lourdes and
reopened in 1887.
Please wear comfortable walking shoes and dress
appropriately for the weather.
In the event of inclement weather, please check with
the Section Registration Desk regarding the status of
the tour.




                                                           7
JANUARY 24, 2003
✯ Programs for Young Lawyers
Friday



         PROGRAMS FOR YOUNG LAWYERS
         These programs have been designated as programs of
         particular interest to young lawyers or non-specialists.
         Look for a A symbol by these programs.


         Friday, January 24, 2003
         8:00am – 8:45am                 Conf Rm 16, Level 3
         Employee Benefits New Member Outreach
         Initiative A
         If you have only recently begun attending the
         Employee Benefits Committee meetings, please come
         and get acquainted with other new attendees and learn
         more about the Employee Benefits Committee’s
         programs. Learn how to become involved in the
         subcommittees and what the different subcommittees
         do. Please bring your business cards with e-mail
         addresses so we can add you to the e-mail list for the
         Employee Benefits Committee.

         8:30am – 11:30am                  Conf Rm 7, Level 3
         Closely Held Businesses A
         Chair: Leslie E. Grodd, Blazzard, Grodd & Hasenauer,
         PC, Westport, CT
         10:25am Tax Aspects of Joining and Leaving a
                 Professional Corporation, i.e., Tax
                 Issues Unique to the Withdrawal of
                 Contingent Liabilities, and Dealing with
                 Issues Associated with the Current
                 Malpractice Insurance Crisis. Moderator:
                 Michael P. Coyne, Waldheger Coyne,
                 Cleveland, OH. Panelist: William P. Prescott,
                 Wickens, Herzer, Panza, Cook & Batista
                 Cleveland, OH.

         8:30am – 11:30am                 Salon D, Level 3
         Partnerships A
         Chair: Stephen L. Owen, Piper Rudnick LLP,
         Baltimore, MD
         9:55am     Drafting Partnership and LLC
                    Agreements. The second of a planned
                    series of programs on drafting issues,
                    approaches and recommended provisions

   8
                                     JANUARY 24, 2003
                    Programs for Young Lawyers            ✯




                                                          Friday
          arising in the preparation of partnership and
          limited liability company agreements.
          Moderator: Terence F. Cuff, Loeb & Loeb
          LLP, Los Angeles, CA. Panelist: Stephen D.
          Rose, Munger Tolles & Olson LLP, Los
          Angeles, CA.

9:00am – 4:00pm                  Conf Rm 6, Level 3
Young Lawyers Forum A
Chair: Christine L. Agnew, Weil, Gotshal & Manges LLP,
New York, NY
2002 Law Student Tax Challenge. Oral Semi-Final
Competition (not open to public) will be held from
9:00am to 12:00pm followed by the Final Oral
Competition from 2:30pm to 4:00pm (open to public).

1:30pm – 2:30pm              Conf Rm 15, Level 3
Estate and Gift Taxes Young Lawyer
Subcommittee A

2:00pm – 5:00pm                      Salon B, Level 3
Formation of Tax Policy A
Chair: Fred F. Murray, Tax Executives Institute, Inc.,
Washington, DC
2:00pm    Increasing Use of Anti-Abuse Rules in
          the US Federal Tax System—What the
          Canadians Have Learned About GAAR.
          Section 101 of H.R. 5095 would introduce a
          broad anti-abuse rule to codify the
          economic substance doctrine. As a
          substantive Code change and a separate
          basis for a penalty for noncompliance, the
          proposals would mark a significant
          departure from our traditional rules-based
          system. The panelists will consider the use
          and functioning of anti-abuse rules in our
          federal tax system and that of Canada, our
          largest trading partner. Moderator: Fred F.
          Murray, Tax Executives Institute, Inc.,
          Washington, DC. Panelists: Gregory F.
          Jenner, Deputy Assistant Secretary (Tax
          Policy), Department of Treasury, Washington,
          DC; Lawrence B. Gibbs, Miller & Chevalier,
          Chartered, Washington, DC; Martin J.
          McMahon, Jr., University of Florida School of

                                                          9
JANUARY 24, 2003
✯ Programs for Young Lawyers
Friday


                   Law, Graduate Tax Program, Gainesville, FL;
                   Alan Wheable, Toronto Dominion Bank,
                   Toronto, Canada.
         3:40pm    Taxing Business Income Once:
                   Integration of the Corporate and
                   Individual Income Tax Systems. The
                   classical system of current rules governing
                   the corporate and individual income tax
                   systems of the US treats corporations and
                   their investors as separate entities and levies
                   tax at both the corporate and shareholder
                   levels on earnings from investments in
                   corporate equity. The panelists will consider
                   the fundamental questions concerning how
                   these rules affect our system and how it
                   might be restructured to reduce tax dis-
                   tortions of important corporate financial
                   decisions. Moderator: Fred F. Murray, Tax
                   Executives Institute, Inc., Washington, DC.
                   Panelists: Gregory F. Jenner, Deputy
                   Assistant Secretary (Tax Policy), Department
                   of Treasury, Washington, DC; Eric M. Zolt,
                   Harvard Law School, Cambridge, MA;
                   George K. Yin, University of Virginia Law
                   School, Charlottesville, VA; Robert P. Hanson,
                   Ernst & Young LLP, Washington, DC.

         2:15pm – 5:30pm                   Conf Rm 7, Level 3
         Closely Held Businesses A
         Chair: Leslie E. Grodd, Blazzard, Grodd & Hasenauer,
         PC, Westport, CT
         3:45pm    Tax Aspects of Divorce and Separation
                   as It Affects Control, Succession and
                   Valuation Issues for a Closely-Held
                   Business Owner. Moderator: Elizabeth J.
                   Atkinson, Kaufman & Canoles, Norfolk, VA.
                   Panelist: Professor Toni Robinson,
                   Quinnipiac University, School of Law,
                   Hamden, CT.




10
                                      JANUARY 24, 2003
                     Programs for Young Lawyers              ✯




                                                             Friday
2:30pm – 5:30pm                    Salon A, Level 3
Real Estate A
Chair: Michael J. Grace, Washington, DC
5:05pm     Tax Issues in Texas Real Estate
           Transactions—A Primer for Non-Texas
           Lawyers. The panel will identify tax issues
           and planning opportunities that non-Texas
           practitioners should consider for transactions
           involving Texas investment and income-
           producing real property. Topics will include
           the impact of the Texas franchise tax on the
           choice of entity, basic property tax and
           transfer tax planning, and other aspects of
           Texas real property law. Moderator: Stanley
           L. Blend, Oppenheimer, Blend, Harrison &
           Tate, Inc., San Antonio, TX. Panelists:
           Barbara de Marigny, Oppenheimer, Blend,
           Harrison & Tate, Inc., San Antonio, TX;
           Mitchell Tiras, Locke Lidell & Sapp LLP,
           Houston, TX.

4:00pm – 6:30pm          Conf Rms 1 & 2, Level 3
Young Lawyers Forum and Diversity
Committee A
Young Lawyers Forum Chair: Christine L. Agnew,
Weil, Gotshal & Manges LLP, New York, NY
Diversity Committee Co-Chairs: Wayne A. Hamilton,
JM Family Enterprises, Inc. Deerfield Beach, FL; Jessica
A. Hough, Skadden, Arps, Slate, Meagher, & Flom LLP,
Washington, DC
4:00pm     Opening Remarks by the Chair.
4:15pm     Rethinking Pro Bono — It’s Not for
           Free. Pro bono opportunities offer young
           lawyers an opportunity to serve their
           communities, but that doesn’t mean that
           young lawyers get nothing in return. In
           addition to giving back to their communities
           and helping others in need, many of these
           opportunities allow young lawyers to do
           things they are often not able to do in
           private, in-house or governmental practice:
           (1) take primary responsibility for a case; (2)
           develop client service and advocacy skills;
           and (3) get involved in exciting cases at a
                                                             11
JANUARY 24, 2003
✯ Programs for Young Lawyers
Friday


                  high level. The panel will discuss issues
                  ranging from how to find pro bono
                  opportunities in your community to how to
                  balance your workload with your pro bono
                  commitments. Moderator: Shannon Nash,
                  Amgen Inc., Thousand Oaks, CA. Panelists:
                  Karen L. Hawkins, Taggart & Hawkins,
                  Oakland, CA; Billy D. Hubbard, SPEC
                  Territory Manager, IRS, Austin, TX; Peter A.
                  Lowy, Shell Oil Company, Houston, TX; Nina
                  E. Olson, National Taxpayer Advocate, IRS,
                  Washington, DC.
         5:30pm   Cocktail Reception. Young lawyers and
                  Tax Section leaders share experiences and
                  network with one another during this
                  cocktail reception and representatives from
                  various Tax Section committees will be there
                  to showcase their committee projects and
                  activities. In addition, the semi-finalists and
                  winners from this year’s Tax Law Challenge
                  will be announced at the reception.

         5:00pm –5:30pm                 Conf Rm 11, Level 3
         Young Lawyers of FAUST Subcommittee A
         Chair: Brent Gregoire, McDermott, Will & Emery,
         Washington, DC
         Inaugural meeting to introduce the subcommitee.




12
                                        JANUARY 25, 2003
                Programs for Young Lawyers                    ✯




                                                              Saturday
Saturday, January 25
7:15am – 8:30am                  Salon A, Level 3
Partnerships and Real Estate “Shop Talking”
Breakfast A (Ticketed Event)
Members of the Real Estate and Partnerships
Committees will gather for the traditional “open mike”
breakfast to share ideas and war stories and to seek
input on technical issues.


12:40pm – 1:45pm                 Salon E, Level 3
PLENARY PANEL
International Tax Reform – Where Do We Go
From Here? A
Territoriality. Competitiveness. Deferral. Capital Export
Neutrality. Capital Import Neutrality. Confused? This
panel will explain those terms (and many others) that
will pepper the emerging debate over the possible
reform of the international tax provisions of the Code.
This debate, long carried on in the deep recesses of
academia and think tanks has now spilled over to the
front pages of the New York Times and the Wall
Street Journal. Sparked by the “corporate inversion”
phenomena and potentially funded by the revenue
effects of the imminent repeal of the “extra-territorial
income” regime (compliments of the WTO), the
prospects for significant reform in the international tax
area are more real than they have been in decades.
This panel, consisting of tax lawyers, economists and
Capital Hill staffers, will analyze some of the alternative
models for such reform in clear and concise fashion.
This panel is an extremely useful primer for those tax
lawyers who, while they might not practice in the
international area, nevertheless want to understand the
issues and stakes in the upcoming reform effort.
Moderator: Leonard Schneidman, Foley Hoag LLP,
           Boston, MA
Panelists:   John L. Buckley, Democratic Chief Tax
             Counsel, House Ways & Means
             Committee, Washington, DC
             Robert Culbertson, King & Spaulding,
             Washington DC
             James R. Hines, Jr., University of Michigan
             Business School, Ann Arbor, MI
                                              (continued)
                                                              13
JANUARY 25, 2003
✯ Programs for Young Lawyers
Saturday


                        Edward McClellan, Republican Tax
                        Counsel, Senate Finance Committee,
                        Washington, DC
                        Stephen E. Shay, Ropes & Gray,
                        Boston, MA


           2:00pm – 5:00pm                     Salon M, Level 3
           Enhanced IRS Enforcement and the “Sensitive Issue”
           Audit: Practical and Ethical Considerations A
           Practical and ethical considerations confronting a
           representative involved in a sensitive issue “eggshell”
           IRS audit. A distinguished panel will lead an open
           discussion on the potential impact of inappropriately
           amending returns, voluntary disclosure practice pitfalls,
           engagement of the Kovel accountant, when/whether
           counsel should “surface” during the audit, and other
           practical considerations that frequently arise, together
           with a detailed overview of enhanced IRS enforcement
           efforts and tools.
           Moderator: Charles P. Rettig, Hochman, Salkin, Rettig,
                      Toscher & Perez, PC, Beverly Hills, CA
           Panelists:   Scott Michel, Caplin & Drysdale,
                        Chartered, Washington, DC
                        Martin A. Schainbaum, Martin A.
                        Schainbaum Professional Law Corporation,
                        San Francisco, CA
                        Bryan Skarlatos, Kostelanetz and Fink LLP,
                        New York, NY
           Sponsored by: Civil and Criminal Tax Penalties
           Committee




14
                                    JANUARY 23, 2003
                                 Program Schedule        ✯




                                                         Thursday
PROGRAM SCHEDULE
The     symbol indicates that the program is being
audio-taped by Teach’em. A A indicates that the
program would appeal to young lawyers and a
indicates that ethics credit has been requested for
this program.


Thursday, January 23
8:30am – 5:00pm                  Salon D, Level 3
Officers and Council Meeting (Executive Session)

4:00pm – 6:00pm               Conf Rm 5, Level 3
Partnerships Task Force on Simplification of
Subchapter K (Executive Session)

6:30pm – 10:00pm             Conf Rm 17, Level 3
Administrative Practice Cash Bar/Dinner
(Invitation Only)

6:30pm – 9:30pm                Rio Rio Restaurant
Partnerships and Real Estate Dinner “DEEP IN THE
HEART OF TEXAS”
Members of the Partnerships and the Real Estate
Committees will meet for cocktails and dinner at
Rio Rio, a lively Tex-Mex restaurant, within walking
distance of the Marriott Rivercenter and Riverwalk.
Cocktails will begin at 6:30pm followed 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        La Mansion del Rio Hotel
State and Local Taxes Cash Bar and Dinner
(Invitation Only)

7:00pm – 10:00pm      Charles Court Restaurant
FAUST, USAFTT, FLF and Transfer Pricing Dinner
(Invitation Only)
The FAUST, USAFTT, and Transfer Pricing Committees
have scheduled a joint dinner with the following
government guests: Barbara Angus, International Tax
Counsel, Department of Treasury, Washington, DC,
Bernard B. Nelson, Area Counsel, LMSB – Natural
Resources, IRS, Houston, TX; Christina D. Moss, Senior
                                                         15
JANUARY 24, 2003
✯ Program Schedule
Friday


         Attorney – International Cadre Area 4, LMSB, IRS,
         Houston, TX; and John S. Repsis, Associate Area
         Counsel – Manager, International Cadre Area 4, LMSB,
         Dallas, TX. The dinner will begin at 7:00pm at Charles
         Court, 205 S. Presa Street (between Commerce &
         Market Sts.).


         Friday, January 24
         7:00am – 9:00am                       Salon B, Level 3
         Capital Recovery and Leasing
         Chair: Greg R. Riddle, Orrick, Herrington & Sutcliffe LLP,
         San Francisco, CA
         7:00am     Current Events. Speaker: Young J. Kim,
                    Thacher Proffitt & Wood, New York, NY.
         7:15am     Rev. Rul. 2002-69 on LILOs—Back to
                    the Future Interest. Discussion of Rev. Rul.
                    2002-69, released in October 2002, in which
                    the IRS takes the position that LILOs, in
                    substance, confer only a future interest in
                    property, rather than a current leasehold
                    interest. Moderator: James R. Shorter, Jr.,
                    Thacher Proffitt & Wood, New York, NY.
                    Panelists: John Aramburu, Senior Counsel,
                    Office of Associate Chief Counsel (Income
                    Tax & Accounting), IRS, Washington, DC;
                    Michael S. Novey, Associate Tax Legislative
                    Counsel, Office of Tax Policy, Department of
                    Treasury, Washington, DC; Michelle Henkel,
                    Alston & Bird LLP, Atlanta, GA; Greg R.
                    Riddle, Orrick, Herrington & Sutcliffe LLP,
                    San Francisco, CA; David B. Weisblat,
                    Hunton & Williams, New York, NY.
         8:15am     Capitalization of Intangibles — Proposed
                    Regulations. A discussion of any recently
                    released proposed regulations regarding the
                    capitalization of intangibles. Moderator: C.
                    Elizabeth Wagner, KPMG LLP, Washington,
                    DC. Panelists: Jody Brewster, Skadden, Arps,
                    Slate, Meagher & Flom LLP, Washington, DC;
                    Carol Conjura, KPMG LLP, Washington, DC;
                    Andrew J. Keyso, Senior Attorney (Income
                    Tax and Accounting), Office of Chief
                    Counsel, IRS, Washington, DC.
16
                                      JANUARY 24, 2003
                                   Program Schedule          ✯




                                                             Friday
7:00am – 9:00am                       Salon M, Level 3
Teaching Taxation
Chair: Professor Linda Galler, Hofstra University School
of Law, Hempstead, NY
7:30am     What Every Corporate Tax Lawyer (and
           Student) Should Know About State and
           Local Tax. This panel will explore
           constitutional, practical, and tax policy
           concerns relating to state and local taxation
           of corporate transactions. The discussion will
           cover such topics as constitutional
           limitations on the ability of states to tax
           transactions and their participants. Panelists:
           Peter L. Faber, McDermott, Will & Emery,
           New York, NY; Kathleen King Parker, Choate,
           Hall & Stewart, Boston, MA; Janette M.
           Lohman, Blackwell, Sanders, Peper, Martin
           LLP, St. Louis, MO.

7:00am – 8:15am                    Salon I, Level 3
Committee Chairs, Vice Chairs, Officers and Council
Breakfast

7:30am – 8:30am                   Conf Rm 1, Level 3
Exempt Organizations Subcommittees on Health
Care Organizations; State and Local Regulation;
and Tax Exempt Financing
Co-Chairs: Christopher M. Jedrey, McDermott, Will &
Emery, Boston, MA; T. J. Sullivan, Gardner, Carton &
Douglas, Washington, DC; Todd R. Greenwalt, Vinson
& Elkins LLP, Houston, TX
7:15am     Committee Business. Moderators:
           Christopher M. Jedrey, McDermott, Will &
           Emery, Boston, MA; T. J. Sullivan, Gardner,
           Carton & Douglas, Washington, DC.
7:30am     Physician Compensation Update.
           Speaker: T.J. Sullivan, Gardner, Carton &
           Douglas, Washington, DC.
8:00am     HMO Update. Speaker: Christopher M.
           Jedrey, McDermott, Will & Emery,
           Boston, MA.
8:30am     Section 4958 TAM. Speaker: Christopher
           M. Jedrey, McDermott, Will & Emery,
           Boston, MA.
                                                             17
JANUARY 24, 2003
✯ Program Schedule
Friday


         7:30am – 8:30am                  Conf Rm 2, Level 3
         Exempt Organizations Subcommittee on Political
         and Lobbying Activities and Organizations
         Co-Chairs: Greg Colvin, Silk Adler & Colvin, San
         Francisco, CA; Professor Miriam Galston, George
         Washington University Law School, Washington, DC
         7:30am    Roundtable Discussion of First Draft,
                   Report of Task Force on Section
                   501(c)(4) and Politics.

         7:30am – 8:30am                    Conf Rm 3, Level 3
         Exempt Organizations Subcommittees on Private
         Foundations; Unrelated Business Income Tax; and
         International Philanthropy
         Chairs: Paul H. Feinberg, Baker & Hostetler LLP,
         Cleveland, OH (Private Foundations); Lisa L. Johnsen,
         Preston Gates & Ellis LLP, Seattle, WA (Private
         Foundations); Milton Cerny, Caplin & Drysdale,
         Chartered, Washington, DC (International Philanthropy);
         Thomas Silk, Silk Adler & Colvin, San Francisco, CA
         (International Philanthropy); Frederick J. Gerhart,
         Dechert LLP, Philadelphia, PA (Subcommittee on
         Audits, Appeals and Litigation); Marcus S. Owens,
         Caplin & Drysdale, Chartered, Washington, DC (Audits,
         Appeals and Litigation)
         7:30am    Report on Treasury Department’s ‘Anti-
                   Terrorism Financing Guidelines—Best
                   Practices for US-Based Charities.’
                   Speaker: Thomas Silk, Silk Adler & Colvin,
                   San Francisco, CA.
         7:45am    Report on Legislative Developments.
                   Speaker: John Edie, Council on
                   Foundations, Washington, DC.
         8:00am    Discussion of IRS Market Segment
                   Study Approach to Audits, Including
                   Private Foundations Project. Panelists:
                   Frederick Gerhart, Dechert LLP, Philadelphia,
                   PA; Marcus S. Owens, Caplin & Drysdale,
                   Chartered, Washington, DC.

         7:30am – 8:30am                 Conf Rm 4, Level 3
         Exempt Organizations Subcommittee on
         Religious Organizations
         Co-chairs: Deirdre Dessingue, US Conference of
         Catholic Bishops, Washington, DC; Boyd Black, LDS
18       Church, Salt Lake City, UT
                                     JANUARY 24, 2003
                                  Program Schedule          ✯




                                                            Friday
7:30am     Review of IRC Provisions Dealing with
           Churches and Religious Organizations.
           Speaker: Boyd Black, LDS Church, Salt Lake
           City, UT.
7:50am     The IRS Experience—Issues Involving
           Verification of Exemption, Group Ruling
           Maintenance, Determination and PLR
           Issues. Speaker: Deirdre Dessingue, US
           Conference of Catholic Bishops,
           Washington, DC.
8:00am     Regulation of Religious Organization
           Political Activity—FECA v. IRC—
           Legislative Prospects in the New
           Congress. Speaker: Steven Sholk, Gibbons,
           Del Deo, Dolan, Griffinger & Vecchione,
           Newark, NJ.

8:00am – 9:00am        JW’s Restaurant, Level 2
Companions Breakfast (Complimentary)

8:00am – 10:00am                 Conf Rm 10, Level 3
EMPLOYEE BENEFITS: ADMINISTRATIVE
PRACTICE UPDATE, presented by the EPCRS &
Other Administrative Practices Subcommittee and
the Subcommittee on Master, Prototype, and
Volume Submitter Plans
Chairs: Judith McMillin, Deloitte & Touche LLP, Dallas,
TX; David Mustone, Hunton & Williams, McLean, VA
This session will continue previous discussions with IRS
representatives concerning the “White Paper” on the
future of the IRS determination letter program and
current thinking on the subject. Time permitting, the
following also will be discussed in this session: (1) the
pending comment project on “incorporation by
reference,” (2) the status of the GUST/EGTRRA
determination letter programs, and (3) other IRS
matters of current interest. Time will be reserved to
identify issues to be submitted to government agencies
for the annual JCEB visits in May. Panelists: Paul T.
Shultz, Director, Employee Plans Rulings and
Agreements, IRS, Washington, DC; Bruce A. Settell,
Manager - EP Determinations, IRS, Cincinnati, OH.




                                                            19
JANUARY 24, 2003
✯ Program Schedule
Friday


         8:00am – 10:00am              Conf Rm 11, Level 3
         EMPLOYEE BENEFITS: EXECUTIVE
         COMPENSATION UPDATE, presented by the
         Subcommittee on Executive Compensation and the
         Subcommittee on Federal Securities Laws Issues
         Chairs: Wayne R. Luepker, Mayer, Brown, Rowe &
         Maw, Chicago, IL; Susan J. Daley, Altheimer & Gray,
         Chicago, IL
         This session will examine developments in corporate
         governance affecting executive compensation,
         including the ramifications of the Sarbanes-Oxley Act
         and the stock exchange requirements for equity
         compensation plans. In addition, the session will
         address the current status of the Committee’s
         comments on golden parachutes and split dollar life
         insurance. Time will be reserved to identify issues to be
         submitted to government agencies for the annual JCEB
         visits in May.

         8:00am – 8:45am          Conf Rm 16, Level 3
         Employee Benefits New Member Outreach
         Initiative A
         If you have only recently begun attending the
         Employee Benefits Committee meetings, please come
         and get acquainted with other new attendees and learn
         more about the Employee Benefits Committee’s
         programs. Learn how to become involved in the
         subcommittees and what the different subcommittees
         do. Please bring your business cards with e-mail
         addresses so we can add you to the e-mail list for the
         Employee Benefits Committee.

         8:30am – 11:30am                    Salon C, Level 3
         Administrative Practice
         Chair: Melissa E. Welch, Vanderpool, Frostick &
         Nishanian, PC, Manassas, VA
         8:30am     Opening Remarks by the Chair.
         8:35am     Important Developments. Speakers:
                    Phillip Pillar, Ernst & Young LLP, Philadelphia,
                    PA; Sheri Dillon, McKee Nelson LLP,
                    Washington, DC; Gregory J. Gawlik,
                    Thompson Hine LLP, Cleveland, OH;
                    Deborah A. Butler, Associate Chief Counsel,
                    (Procedure & Administration), IRS,
                    Washington, DC.

20
                                     JANUARY 24, 2003
                                  Program Schedule          ✯




                                                            Friday
9:05am   The Dark Side of Stock Options. This
         panel will discuss the economic devastation
         caused by tax rules, which require income
         recognition on the exercise of stock options,
         even though the value of the stock falls
         sharply due to market conditions. This panel
         will also discuss alternatives for resolving the
         tax debts including offers-in-compromise
         and bankruptcy. Moderator: Robert E.
         McKenzie, Arnstein & Lehr, Chicago, IL.
         Panelists: Nina E. Olson, National Taxpayer
         Advocate, IRS, Washington, DC; Claudia E.
         Hill, Tax Mam, Inc., Cupertino, CA; Jeffrey
         Chou, Reform AMT, Foster, CA.
9:50am   New LMSB Audit Initiatives. This panel
         will discuss the new Large and Mid-Size
         Business Division’s audit initiatives including
         the “Limited Issue Focused Examination,”
         and the panel will also discuss alternative
         dispute resolution tools for both tax-shelter
         and non-tax-shelter issues. Moderators:
         Thomas J. Callahan, Thompson Hine LLP,
         Cleveland, OH; Donald L. Korb, Thompson
         Hine LLP, Cleveland, OH. Panelists: Larry R.
         Langdon, Commissioner – LMSB, IRS,
         Washington, DC; Deborah M. Nolan,
         Deputy Commissioner, LMSB, IRS,
         Washington, DC; Frank Y. Ng, Director, Pre-
         Filing & Technical Guidance, IRS,
         Washington, DC; Bobby E. Scott, Industry
         Director, Natural Resources & Construction,
         IRS, Houston, TX.

8:30am – 11:30am             Conf Rm 12, Level 3
Affiliated and Related Corporations
Chair: Gordon E. Warnke, Dewey Ballantine LLP, New
York, NY
8:30am   Loss Disallowance Issues. This panel will
         focus on loss disallowance issues, including
         the proposed loss duplication regulations
         issued in October 2002 and current and
         potential future regulations addressing loss
         disallowance issues in the context of
         General Utilities repeal. Moderator: Gordon
         E. Warnke, Dewey Ballantine LLP, New York,
                                                            21
JANUARY 24, 2003
✯ Program Schedule
Friday


                   NY. Panelists: Theresa A. Abell, Special
                   Counsel, Office of Associate Chief Counsel
                   (Corporate), IRS, Washington, DC; Audrey
                   Nacamuli, Attorney - Advisor, Office of Tax
                   Legislative Counsel, Department of Treasury,
                   Washington, DC; Andrew J. Dubroff, Ernst &
                   Young LLP, Washington, DC; Laynie Pavio,
                   Ernst & Young LLP, Washington, DC.
         10:30am Separate versus Single Entity
                 Principles. This panel will focus on separate
                 versus single entity principles applied in the
                 consolidated return setting, and how these
                 principles and their application have evolved
                 and continue to evolve, including in the
                 context of recent consolidated return
                 regulations and current legislative proposals
                 with respect to the Rite Aid decision.
                 Moderator: Herbert H. Alpert, Feingold &
                 Alpert, New York, NY. Panelists: Edward S.
                 Cohen, Branch Chief, Branch 2, Office of the
                 Associate Chief Counsel (Corporate), IRS,
                 Washington, DC; John Broadbent, Ernst &
                 Young LLP, Washington, DC; Irving Salem,
                 Latham & Watkins, New York, NY.

         8:30am – 11:30am               Conf Rm 5, Level 3
         Banking and Savings Institutions
         Chair: Hayden D. Brown, Mayer, Brown, Rowe & Maw,
         Charlotte, NC
         8:30am    Opening Remarks and Committee
                   Business by the Chair.
         8:40am    Problems in Valuing Securities for
                   Purposes of the Mark-to-Market Rules,
                   and Possible Administrative Guidance.
                   Moderator: Steven M. Rosenthal, Miller &
                   Chevalier, Chartered, Washington, DC.
                   Panelist: Michael S. Novey, Associate Tax
                   Legislative Counsel, Department of Treasury,
                   Washington DC.
         9:30am    Tax Shelter Listing and Disclosure Rules
                   and their Potential Burdens on Financial
                   Institutions. Moderator: Hayden D. Brown,
                   Mayer, Brown, Rowe & Maw, Charlotte, NC.

22
                                   JANUARY 24, 2003
                                Program Schedule        ✯




                                                        Friday
          Panelists: Mark H. Leeds, Deutsche Bank
          AG, New York, NY; Charles W. Wheeler,
          Alston & Bird LLP, Washington, DC.
10:30am Treatment of Supervisory Goodwill.
        This panel will discuss the deductibility or
        amortization of goodwill acquired in
        connection with supervised acquisitions of
        failing banks and savings and loans.
        Panelists: William P. Boulet, Jr., Deloitte &
        Touche LLP, Denver, CO; Hayden Brown,
        Mayer, Brown, Rowe & Maw, Charlotte, NC.

8:30am – 11:30am                  Conf Rm 7, Level 3
Closely Held Businesses A
Chair: Leslie E. Grodd, Blazzard, Grodd & Hasenauer,
PC, Westport, CT
8:30am    Committee Administrative Matters,
          Opening Remarks and Review of
          Committee Business by the Chair.
8:40am    Tax Issues Presented in Mergers and
          Conversions Involving Pass-Through
          Entities. Moderator: Gregory M. Marks,
          Greenberg, Traurig, Miami, FL. Panelists:
          Sydney S. Traum, Sydney S. Traum PA and
          of Counsel to Levy, Airan, Brownstein &
          Shevin, Miami, FL; Jim Sowell, Deloitte &
          Touche LLP, Washington, DC.
10:10am Break
10:25am Tax Aspects of Joining and Leaving a
        Professional Corporation, i.e., Tax
        Issues Unique to the Withdrawal of
        Contingent Liabilities, and Dealing with
        Issues Associated with the Current
        Malpractice Insurance Crisis. Moderator:
        Michael P. Coyne, Waldheger Coyne,
        Cleveland, OH. Panelist: William P. Prescott,
        Wickens, Herzer, Panza, Cook & Batista,
        Cleveland, OH.

8:30am – 11:30am                   Salon L, Level 3
Domestic Relations
Chair: Cindy Lynn Wofford, Washington, DC
8:30am    Opening Remarks by the Chair.
                                                        23
JANUARY 24, 2003
✯ Program Schedule
Friday


         8:45am     Panel Discussion: Taxation of Transfers
                    of Business Interests and Section 83
                    Property at Divorce: An Update.
                    Moderator: Professor Toni Robinson,
                    Quinnipiac University, School of Law,
                    Hamden, CT. Panelists: Jerald David August,
                    August and Kulunas, PA, West Palm Beach,
                    FL; Professor David Rosettenstein,
                    Quinnipiac University, School of Law,
                    Hamden, CT; C. Wells Hall III, Mayer, Brown,
                    Rowe, and Maw, Charlotte, NC.
         11:00am Overview of the Final Section 1041
                 Regulations. Following the panel
                 discusssion, a representative from the Depart-
                 ment of Treasury will discuss the recently
                 published final section 1041 regulations and
                 join the panelists and committee members in
                 a discussion of issues raised during the first
                 segment. Speaker: Stephanie Johnson,
                 Attorney-Advisor (Tax Policy), Department of
                 Treasury, Washington, DC.

         8:30am – 11:30am                    Salon A, Level 3
         Estate & Gift Taxes
         Chair: Douglas Siegler, Sutherland Asbill & Brennan
         LLP, Washington, DC
         Estate Planning with Distressed Assets:
         Underwater Stock Options, Partnership and LLC
         Interests with Negative Capital Accounts,
         Property with Debt in Excess of Basis.
         Opportunities and pitfalls of estate planning with
         distressed assets. Panelists: Jerald August, August &
         Kulunas PA, West Palm Beach, FL; Robert M.
         Weylandt, JP Morgan Chase & Co., Houston, TX.
         Valuation Update. A review and analysis of recent
         valuation decisions, including Hackl, Harper,
         Thompson, Fontana, and others. Speaker: Louis
         Mezzullo, Mezzullo & Guare PLC, Richmond, VA;
         Ronald D. Aucutt, McGuire Woods, McLean, VA.
         Current/ Recent Developments. This panel
         discussion will bring us up to date on recent
         developments (including legislation, regulations,
         judicial decisions, and rulings and other guidance from
         IRS) relevant to our practice area. Panelists: Jordan L.
         Klingsberg, Steptoe & Johnson LLP, Washington, DC;
         A. Christopher Sega, Venable LLP, Washington, DC.
24
                                       JANUARY 24, 2003
                                    Program Schedule           ✯




                                                               Friday
8:30am – 10:30am                       Salon F, Level 3
Foreign Activities of US Taxpayers
Chair: Joe O. Luby, Jr., Exxon Mobil Corporation, Irving, TX
8:30am     Contract Manufacturing. A panel discussion
           of the latest developments concerning
           contract manufacturing. Moderator: Carol
           Tello, Sutherland, Asbill & Brennan LLP,
           Washington, DC. Panelists: Lowell Yoder,
           McDermott Will & Emery, Chicago, IL;
           Professor Eric Laity, Oklahoma City University
           School of Law, Oklahoma City, OK.
9:30am     Maximizing the Extraterritorial Income
           Exclusion. A discussion of the current state
           of the World Trade Organization controversy,
           legislative updates, explanation of the ETI
           regime, and continuing planning opportuni-
           ties. Speaker: Margie Martin, KPMG LLP,
           Miami, FL.
10:00am Choice of Entity in the International
        Context: Important Tax Consequences
        Arising from Permanent Establishments.
        An overview of the major US and foreign tax
        consequences arising from a key concept in
        international taxation, the “permanent
        establishment” or taxable presence.
        Speaker: Mark Klitgaard, Deloitte & Touche
        LLP, San Jose, CA.

8:30am – 11:30am                   Salon D, Level 3
Partnerships A
Chair: Stephen L. Owen, Piper Rudnick LLP,
Baltimore, MD
8:30am     Opening Remarks by the Chair.
8:40am     Hot Topics in Partnership Taxation. A
           discussion of recent legislation, decisions,
           rulings and current Treasury projects bearing
           on “cutting edge” partnership taxation
           issues. Moderator: Charles R. Levun, Levun
           Goodman & Cohen, Northbrook, IL.
           Panelists: Mark A. Luscombe, CCH Incor-
           porated, Deerfield, IL; Deborah A.
           Harrington, Attorney-Advisor, Office of Tax
           Legislative Counsel, Department of Treasury,
           Washington, DC.
                                                               25
JANUARY 24, 2003
✯ Program Schedule
Friday


         9:05am     Joint Ventures with Tax-Exempt
                    Entities. This panel will explore tax issues
                    created by partnerships having both taxable
                    and tax-exempt partners, including section
                    704(b) allocation issues, unrelated business
                    taxable income and unrelated debt financed
                    income, fractions rule compliance by real
                    estate partnerships and techniques for
                    shielding tax-exempt partners from UBTI,
                    including the use of blocker corporations,
                    feeder entities, insurance company
                    segregated asset accounts and other
                    structures. Moderator: Paul H. Asofsky, Weil,
                    Gotshal & Manges LLP, Houston, TX.
                    Panelists: Adele Karig, Debevoise &
                    Plimpton, New York, NY; Thomas
                    Wisialowski, Paul, Hastings, Janofsky &
                    Walker LLP, Los Angeles, CA; Lary Wolf,
                    Roberts & Holland LLP, New York, NY.
         9:55am     Drafting Partnership and LLC
                    Agreements.A The second of a planned
                    series of programs on drafting issues,
                    approaches and recommended provisions
                    arising in the preparation of partnership and
                    limited liability company agreements.
                    Moderator: Terence F. Cuff, Loeb & Loeb
                    LLP, Los Angeles, CA. Panelist: Stephen D.
                    Rose, Munger Tolles & Olson LLP, Los
                    Angeles, CA.
         10:30am The Future of the Transactional Tax
                 Lawyer. ABA Model Rules of Professional
                 Conduct 2.01 and 6.4 provide, respectively,
                 that (a) in rendering advice, lawyers are
                 allowed to refer not only to the law but also
                 to economic and social factors, and (b)
                 lawyers are also allowed to serve as members
                 of organizations involved with the reform of
                 the law or its administration. Our panelists will
                 discuss the economic and social factors
                 impacting the future of the transactional tax
                 lawyer, as well as potential reforms in the
                 administration of such practices. Moderators:
                 Stefan Tucker, Venable LLP, Washington, DC;
                 Stanley L. Blend, Oppenheimer, Blend,
                 Harrison & Tate, Inc., San Antonio, TX.
26
                                    JANUARY 24, 2003
                                Program Schedule         ✯




                                                         Friday
8:45am – 4:00pm                      Salon E, Level 3
Exempt Organizations
Chair: Victoria B. Bjorklund, Simpson Thacher &
Bartlett, New York, NY
8:45am    Committee Business Matters.
9:15am    News from the Internal Revenue
          Service. Moderator: Michael A. Clark,
          Sidley Austin Brown & Wood, Chicago, IL.
          Panelist: Steven T. Miller, Director, Exempt
          Organizations, TE/GE, IRS, Washington, DC.
9:55am    The Uniform Management of
          Institutional Funds Act: New
          Developments. Moderator: Professor Ellen
          Aprill, Loyola Law School, Los Angeles, CA.
          Panelists: Janne Gallagher, Council on
          Foundations, Washington, DC; Carol G.
          Kroch, The Robert Wood Johnson
          Foundation, Princeton, NJ; Carolyn (Morey)
          Ward, Morgan Lewis & Bockius LLP,
          Washington, DC.
10:45am Break
11:00am The Use of For-Profit Subsidiaries by
        Exempt Organizations. Moderators:
        Joseph Lundy, PricewaterhouseCoopers LLP,
        Philadelphia, PA; Suzanne Ross McDowell,
        Steptoe & Johnson LLP, Washington, DC.
11:50am Update from a Task Force of the
        Subcommittee on Political and
        Lobbying Activities and Organizations.
        Moderators: Greg Colvin, Silk Adler &
        Colvin, San Francisco, CA; Professor Miriam
        Galston, George Washington University Law
        School, Washington, DC. Panelist: Elizabeth
        J. Kingsley, Harmon, Curran, Spielberg &
        Eisenberg LLP, Washington, DC.
12:30pm Luncheon Program. (Ticketed Event)
        Speaker: Jody Blazek, Blazek & Vetterling
        LLP, Houston, TX. Topic: When Tax
        Compliance Issues, the Law and GAAP
        Collide—Using Checklists to Search for
        Problems.
1:45pm    Break
                                                         27
JANUARY 24, 2003
✯ Program Schedule
Friday


         2:00pm    Update from the Form 1023 Task Force.
                   Moderators: Eve Borenstein, Tax Exempt Law
                   Office, Minneapolis, MN; LaVerne G. Woods,
                   Davis Wright Tremaine, Seattle, WA. Panelists:
                   Betsy Buchalter Adler, Silk Adler & Colvin, San
                   Francisco, CA; Michael A. Clark, Sidley Austin
                   Brown & Wood, Chicago, IL; Jennifer L.
                   Franklin, Simpson Thacher & Bartlett, New
                   York, NY; Lauren K. Mack, Foster City, CA.
         2:40pm    Issues Facing Academic Medical Centers.
                   Moderator: Christopher Jedrey, McDermott
                   Will & Emery, Boston, MA. Panelists: James K.
                   Hasson, Jr., Sutherland Asbill & Brennan LLP,
                   Atlanta, GA; T.J. Sullivan, Gardner Carton &
                   Douglas, Washington, DC.
         3:30pm    Cash Bar (No Host)

         9:00am – 11:00am                Conf Rm 15, Level 3
         Committees (Executive Session)
         Chair: Richard A. Shaw, Higgs, Fletcher & Mack LLP,
         San Diego, CA

         9:00am – 3:00pm
         Companions Tour and Luncheon (Ticketed Event)
         A Heart of San Antonio Art Tile Tour and
                                   T
                              OU
         Luncheon at Club Giraud. (See page 6 for a
                          D will depart from the front entrance
                   SOL
         description.) Buses
         of the Marriott Rivercenter promptly at 9:00am.
         Please note Club Giraud’s dress code does not
         permit jeans, t-shirts, shorts or sneakers.

         9:00am – 10:00am               Conf Rm 17, Level 3
         EMPLOYEE BENEFITS: VEBA UPDATE, presented
         by the Subcommittee on Retiree Health, VEBAs
         and Other Funding Vehicles
         Chair: George L. Whitfield, Warner Norcross & Judd
         LLP, Grand Rapids, MI
         This session will address comments on the proposed
         regulations under section 419A(f)(6) on ten or more
         employer welfare benefit funds, including comments
         received by the IRS at the public hearing. Government
         guests are invited and William Sweetnam, Benefits Tax
         Counsel, Department of Treasury, Washington, DC, will
         attend. We also will identify questions to be submitted
         to the IRS and Treasury for the annual JCEB visits in
28
                                     JANUARY 24, 2003
                                  Program Schedule          ✯




                                                            Friday
May. The Subcommittee will join the Welfare Plan
Update program for continued discussion of Health
Reimbursement Arrangements (HRAs).

9:00am – 4:00pm                   Conf Rm 6, Level 3
Young Lawyers Forum A
Chair: Christine L. Agnew, Weil, Gotshal & Manges LLP,
New York, NY
2002 Law Student Tax Challenge. Semi-Final
Competition (not open to the public) will be held from
9:00am to 12:00pm followed by the Final Competition
from 2:30pm to 4:00pm (open to public).

9:30am – 11:00am                   Conf Rm 3, Level 3
EMPLOYEE BENEFITS: DISTRIBUTIONS UPDATE,
presented by the Subcommittee on Distributions,
the Subcommittee on QDROs, QMSCOs and
Other Domestic Relations Benefits Issues and the
Subcommittee on Estate and Gift Tax Issues
Chairs: Joni L. Andrioff, Jones, Day, Reavis & Pogue,
Chicago, IL; Walter H. Wingfield, Sutherland Asbill &
Brennan LLP, Atlanta, GA; James C. Mulder, Strother,
Keiter & Mulder, PC, Houston, TX
This session will focus on the draft comment being
prepared with respect to required disclosures on lump
sum distributions under section 417(a)(3). The session
also will cover practical problems for qualified plans in
implementing the final required minimum distribution
regulations under section 401(a)(9) and the final plan
loan regulations (if issued). Time will be reserved to
identify issues to be submitted to government agencies
for the annual JCEB visits in May.

9:30am – 12:00pm                  Conf Rm 1, Level 3
EMPLOYEE BENEFITS: WELFARE PLANS
UPDATE, presented by the Subcommittee on
COBRA and Welfare Plan Design Issues, the
Subcommittee on Welfare Plan Legislation, the
Subcommittee on State Insurance Regulation of
Welfare Plans and the Subcommittee on Cafeteria
Plans and Flexible Benefits
Chairs: Phyllis C. Borzi, O’Donoghue & O’Donoghue,
Washington, DC; William (Ken) Kenworthy, Baker
Donelson et al., Birmingham, AL; Mark L. Stember,
Kilpatrick Stockton, Washington, DC; Francis W.
Palmieri, Palmieri & Eisenberg, Princeton, NJ

                                                            29
JANUARY 24, 2003
✯ Program Schedule
Friday


         The first part of the session will focus on Health
         Reimbursement Arrangements (HRAs). The HRA
         discussion will be followed by a practitioners’
         roundtable focusing on various HIPAA privacy issues,
         including drafting of business associate agreements for
         attorneys, individual authorizations, policies and
         procedures. The discussion also will address various
         issues regarding the application of the HIPAA privacy
         rules. The session will conclude with a review of the
         recent COBRA cases and new developments involving
         cafeteria plans and flexible benefits. Time will be
         reserved to identify issues to be submitted to
         government agencies for the annual JCEB visits in May.

         10:00am – 11:00am               Conf Rm 16, Level 3
         Employee Benefits Corporate Counsel Forum
         Chair: Cherly L. Harwick, Marathon Oil Company,
         Findlay, OH

         10:00am – 11:00am                Conf Rm 14, Level 3
         EMPLOYEE BENEFITS: INTERNATIONAL UPDATE,
         presented by the Subcommittee on Foreign and
         International Issues
         Chair: Russell E. Hall, Towers Perrin, Valhalla, NY
         This session will focus on the current provisions of the
         code relating to foreign trusts that can potentially affect
         benefit or compensation arrangements (e.g., 671, 672
         and 679) and proposals to change the law respecting
         the use of foreign trusts to secure deferred
         compensation (e.g., S. 1971 and H.R. 5095). Time will
         be reserved to gather questions that can be posed to
         the IRS or other government agencies by JCEB
         representatives in May.

         10:00am – 12:30pm                 Conf Rm 9, Level 3
         Regulated Investment Companies
         Chair: Paul M. Murphy, Fidelity Investments, Boston MA
         The program will include a presentation on the impact
         of new tax shelter reporting regulations on regulated
         investment companies by Steven M. Rosenthal, Miller &
         Chevalier, Chartered, Washington, DC. The program
         will also feature presentations by Ronald S. Cohn,
         PricewaterhouseCoopers LLP, San Francisco, CA, on
         non-RIC investment company issues, J. Ronald Shiff,
         Gordon, Feinblatt, Rothman, Hoffberger & Hollander,
         Baltimore, MD, on anti-money laundering rules, and by
         Theodore L. Press, Kirkpatrick & Lockhart, Washington,
         DC, on RIC merger issues.
30
                                      JANUARY 24, 2003
                                  Program Schedule          ✯




                                                            Friday
10:30am – 12:00pm                  Conf Rm 2, Level 3
EMPLOYEE BENEFITS: MERGERS AND
ACQUISITIONS UPDATE, presented by the
Subcommittee on Mergers and Acquisitions
Chairs: Eleanor F. Banister, King & Spalding, Atlanta,
GA; Christine L. Richardson, Littler Mendelson, San
Francisco, CA
This session will provide a forum for addressing and
discussing current issues of interest to practitioners in
connection with business mergers, acquisitions, spin-
offs and similar transactions. In particular, the session
will include a discussion of the practical impact of the
Sarbanes-Oxley legislation, successor liability in
connection with acquisitions, particularly with respect
to who is an “employee,” and the value of utilizing
indemnities, escrow accounts and holdbacks for benefit
concerns. Time will be reserved to identify issues to be
submitted to government agencies for the annual
JCEB visits in May.

10:30am – 12:00pm                   Salon F, Level 3
Joint Session of Foreign Activities of US Taxpayers,
Foreign Lawyers Forum, Transfer Pricing and US
Activities of Foreigners and Tax Treaties
10:30am Important Developments Panel. A panel
        discussion of the US and international
        developments that have an impact on the
        foreign activities of US persons and the US
        activities of foreign persons. Moderator:
        Andrew Breslow, Exxon Mobil Corporation,
        Irving, TX. Panelists: Craig Boise, Thompson
        Hine LLP, Cleveland, OH; Jason Bazar,
        Mayer, Brown, Rowe & Maw, New York, NY:
        Barbara Angus, International Tax Counsel,
        Department of Treasury, Washington, DC;
        John Staples, Associate Chief Counsel
        (International), IRS, Washington, DC.

10:30am – 12:30pm            Conf Room 17, Level 3
Tax Shelters Task Force
Chair: William M. Paul, Covington & Burling,
Washington, DC

11:00am – 12:00pm             Conf Rm 18, Level 3
Business Activities Nexus Task Force


                                                            31
JANUARY 24, 2003
✯ Program Schedule
Friday


         Co-Chairs: Steven C. Salch, Fulbright & Jaworski
         LLP, Houston, TX; Linda Holman, WorldCom,
         Washington, DC

         11:00am – 1:00pm             Conf Rm 4, Level 3
         Employee Benefits Leadership Meeting/Lunch
         (Invitation Only)

         11:00am – 12:00pm              Conf Rm 8, Level 3
         EMPLOYEE BENEFITS: ESOP UPDATE, presented
         by the Subcommittee on ESOPs
         Chair: Gregory K. Brown, Gardner Carton & Douglas,
         Chicago, IL
         This session will examine recent court cases and
         proposed legislation affecting employee stock
         ownership plans (ESOPs). Time will be reserved to
         gather questions that can be posed to the IRS or other
         government agencies by JCEB representatives in May.

         11:00am – 12:00pm              Conf Rm 11, Level 3
         EMPLOYEE BENEFITS: ELECTRONIC
         ADMINISTRATION UPDATE, presented by the Task
         Force On Electronic Plan Administration
         Chair: Danny A. Martin, Shell Oil Company,
         Houston, TX
         This session will continue the discussion from the
         October, 2002, meeting regarding the following
         comment projects and subject areas: Comment paper
         requesting that proposed regulations under section
         417(a)(3) be revised to permit transmission of “written”
         explanation of the QJSA and QPSA through electronic
         media; comment paper requesting that regulations
         under section 401(a)(14) be revised to permit deferral
         elections through electronic media; government and
         plan sponsor expectations for future plan audits of
         paperless plan records, including current audit
         experiences; and whether a summary 402(f) notice is
         possible using voice response (and, if so, possible
         examples for the IRS to consider). Time will be reserved
         to identify issues to be submitted to government
         agencies for the annual JCEB visits in May.

         11:30am – 12:30pm               Conf Rm 13, Level 3
         Appointments to the Tax Court (Executive Session)
         Chair: F. Brook Voght, Sutherland, Asbill & Brennan LLP,
         Washington, DC

32
                                       JANUARY 24, 2003
                                   Program Schedule          ✯




                                                             Friday
11:30am – 12:30pm                 Conf Rm 15, Level 3
Membership & Marketing
Chair: Susan P. Serota, Pillsbury Winthrop, New York, NY


Committee Luncheons
12:00pm – 1:30pm                 Salon G, Level 3
Corporate Tax and Affiliated and Related
Corporations (Ticketed Event)

12:00pm – 1:00pm                       Salon J, Level 3
S Corporations (Ticketed Event)

12:30pm – 1:30pm                     Salon A, Level 3
Administrative Practice and Court Procedure and
Practice (Ticketed Event)
Speaker: Deborah A. Butler, Associate Chief Counsel
(Procedure and Administration), IRS, Washington, DC

12:30pm – 1:30pm                 Conf Rm 16, Level 3
Agriculture (Ticketed Event)

12:30pm – 2:00pm               Conf Rm 5, Level 3
Banking and Savings Institutions, Financial
Transactions, Regulated Investment Companies,
and Tax Exempt Financing (Ticketed Event)
Speaker: Gary Wilcox, Deputy Chief Counsel -
Technical, IRS, Washington, DC

12:30pm – 1:30pm                        Salon M, Level 3
Civil and Criminal Tax Penalties (Ticketed Event)
Speakers: Charles J. Muller, III, Strasburger & Price LLP,
San Antonio, TX; Michael McCrum, McCrum & McCrum,
San Antonio, TX; Alan Brown, San Antonio, TX.
Topic: Recent Successful Rule 41(e) Motion – District
Court Finds “Reprehensible Conduct” by an IRS Agent

12:30pm – 1:30pm                    Salon E, Level 3
Exempt Organizations (Ticketed Event)
Speaker: Jody Blazek, Blazek & Vetterling LLP,
Houston, TX
Topic: When Tax Compliance Issues, the Law and
GAAP Collide – Using Checklists to Search for
Problems



                                                             33
JANUARY 24, 2003
✯ Program Schedule
Friday


         12:30pm – 1:30pm                      Salon L, Level 3
         Estate and Gift Taxes and Fiduciary Income Tax
         (Ticketed Event)
         Speaker: Cathy Hughes, Attorney Advisor, Office of Tax
         Legislative Counsel (Tax Policy), Department of
         Treasury, Washington, DC
         Topic: Life at Treasury

         12:30pm – 1:30pm            Salon F, Level 3
         Foreign Activities of US Taxpayers, Foreign
         Lawyers Forum, Transfer Pricing and US Activities
         of Foreigners and Tax Treaties (Ticketed Event)
         Speakers: Brent Gregoire, McDermott, Will & Emery,
         Washington, DC; Greg Nickerson, International Tax
         Counsel, House Ways & Means Committee, Washington,
         DC; Ronald de Gier, NautaDutilh, New York, NY; David
         G. Shapiro, Dechert LLP, Philadelphia, PA.
         Topic: Evolving Global Tax Policies: International Tax
         Aspects of Recently Proposed U.S. Legislation
         Luncheon Panel sponsored by the Young Lawyers
         of FAUST.

         12:30pm – 1:30pm                       Salon I, Level 3
         Partnerships and Real Estate (Ticketed Event)
         Speaker: Pamela F. Olson, Assistant Secretary (Tax
         Policy), Department of Treasury, Washington, DC
         Topic: The Administration’s Tax Policy Priorities:
         An Overview

         12:30pm – 1:00pm                  Salon K, Level 3
         State and Local Taxes (Ticketed Event)


         12:30pm – 2:15pm                  Conf Rm 2, Level 3
         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
         Chairs: Gregory K. Brown, Gardner Carton & Douglas,
         Chicago, IL; David E. Gordon, O’Melveny & Myers LLP,
         Los Angeles, CA; Susan Katz Hoffman, Pepper Hamilton
         LLP, Philadelphia, PA; Donald J. Myers, Reed Smith LLP,
         Washington, DC; Robert Pizzo, Rochester, NY
         The session will review cases and legislative and
         regulatory developments of current interest.
34
                                      JANUARY 24, 2003
                                  Program Schedule         ✯




                                                           Friday
12:30pm – 2:15pm                  Conf Rm 1, Level 3
EMPLOYEE BENEFITS: 401(k) UPDATE, presented
by the Subcommittee On Qualified Cash Or
Deferred Arrangements
Chairs: Leonard S. Hirsh, Ernst & Young LLP, New York,
NY; Bernard F. O’Hare, Patterson, Belknap, Webb &
Tyler LLP, New York, NY
This session will examine anticipated Code Section
401(k) and 401(m) regulations, as well as pending
pension reform legislative changes that may affect
Section 401(k) plans. Treasury and IRS representatives
have been invited to attend the program and
participate in the discussion. Further, the program will
include a discussion of the impact of the Sarbanes-
Oxley Act on Section 401(k) loans, as well as the impact
of the Act’s black-out provisions on Section 401(k)
plans. Time will be reserved to identify issues to be
submitted to government agencies for the annual
JCEB visits in May.

1:00pm – 1:30pm                   Salon K, Level 3
State and Local Taxes: Current State Tax Decisions:
A Review

1:00pm – 5:30pm                       Salon J, Level 3
S Corporations
Chair: Steven I. Klein, Sher Garner Cahill Richter Klein
McAlister & Hilbert, LLC, New Orleans, LA
1:00pm     Opening Remarks and Report on
           Committee Business by the Chair.
1:10pm     Important Developments. Speaker:
           Stephen M. Nechemias, Taft Stettinius &
           Hollister, Cincinnati, OH.
1:40pm     Coggins Automotive Corporation: Is
           LIFO Recapture a Dead Letter? This
           panel will discuss Coggins Automotive
           Corporation and its impact on LIFO
           recapture under section 1363(d), including
           the validity of Reg. 1.1363-2(a)(2) that
           expands LIFO recapture to situations other
           than the election of S corporation status by
           a C corporation. Moderator: Carol Kulish-
           Harvey, Deloitte & Touche LLP, Washington,
           DC. Panelists: James P. Dawson, IRS, Office
           of Chief Counsel, Miami, FL; Stephen R.
                                                           35
JANUARY 24, 2003
✯ Program Schedule
Friday


                   Looney, Dean, Mead, Egerton, Bloodworth,
                   Capuano & Bozarth, PA, Orlando, FL; Steven
                   I. Klein, Sher Garner Cahill Richter Klein
                   McAlister & Hilbert, LLC, New Orleans, LA;
                   Eric Sloan, Deloitte & Touche LLP,
                   Washington, DC.
         3:25pm    Valuations of S Corporations and
                   Interests in S Corporations. This panel
                   will discuss Gross, TCM 1999-254, aff’d, 272
                   F.3d 333 (6th Cir. 2001), Heck, TCM 2002-34
                   and Adams, TCM 2002-80 and the debate
                   these cases have raised in valuing stock of S
                   corporations versus stock of C corporations.
                   Moderator: John M. Carnahan, III, Carnahan,
                   Evans, Cantwell & Brown, PC, Springfield,
                   MO. Panelists: Z. Christopher Mercer,
                   Mercer Capital, Memphis, TN.
         5:00pm    Report on Banks as S Corporations and
                   QSubs Task Force. The Task Force will
                   present a preliminary report on issues to be
                   addressed by the Task Force. Speaker:
                   Kevin Anderson, Deloitte & Touche LLP,
                   Washington, DC.
         5:15pm    Report on Proposals for Revenue
                   Rulings. The Subcommittee will present
                   a report on a proposed revenue ruling
                   addressing whether special adjustment
                   of net unrealized built-in gain should be
                   required in connection with a section
                   332 liquidation of a C corporation
                   subsidiary. Speaker: William D. Klein,
                   Gray, Plant, Mooty, Mooty & Bennett, PA,
                   Minneapolis, MN.

         1:15pm – 2:15pm                 Conf Rm 14, Level 3
         EMPLOYEE BENEFITS: NONDISCRIMINATION
         UPDATE, presented by the Subcommittee on
         Nondiscrimination and section 415 Issues
         Chair: W. Scott Magargee III, Dechert LLP,
         Philadelphia, PA
         This session will discuss section 415 limits under
         EGTRRA and other recent developments. Time will be
         reserved to identify issues to be submitted to
         government agencies for the annual JCEB visits in May.
36
                                      JANUARY 24, 2003
                                  Program Schedule          ✯




                                                            Friday
1:15pm – 2:15pm                 Conf Rm 10, Level 3
EMPLOYEE BENEFITS: IRA UPDATE, presented by
the Subcommittee on IRAs
Chair: Joel E. Horowtiz, Pepper Hamilton LLP,
Philadelphia, PA
This session will discuss recent IRA developments.
Government representatives will be invited to attend.
Time will be reserved to identify issues to be
submitted to government agencies for the annual
JCEB visits in May.

1:15pm – 2:15pm                 Conf Rm 11, Level 3
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
Chairs: Riva T. Johnson, Jenkens & Gilchrist, Dallas, TX;
Michael A. Laing, Steel Hector & Davis LLP, Miami, FL;
Robert L. Abramowitz, Morgan, Lewis & Bockius,
Philadelphia, PA
This session will discuss recent developments regarding
sections 403(b) and 457 and government plans. Time
will be reserved to identify issues to be submitted to
government agencies for the annual JCEB visits in May.

1:30pm – 5:30pm                   Conf Rm 8, Level 3
Employment Taxes
Chair: Russell A. Hollrah, Hahn Kyle & Hollrah LLP,
Washington, DC
1:30pm     Opening Remarks by the Chair.
1:40pm     Social Security Reform: Prospects and
           Implications. What do the recent
           Congressional elections mean for the future
           of Social Security taxation? This panel will
           consider the prospects for Social Security
           privatization and its implications for the
           future of Social Security taxation. This panel
           will also consider the regressivity of payroll
           taxes and consider a variety of possible
           payroll and income tax reforms. Moderator:
           Professor Jonathan Barry Forman, University
           of Oklahoma College of Law, Norman, OK.
           Panelists: Professor Deborah A. Geier,
           Cleveland State University, Cleveland-
                                                            37
JANUARY 24, 2003
✯ Program Schedule
Friday


                  Marshall College of Law, Cleveland, OH;
                  Deborah Walker, Deloitte & Touche LLP,
                  Washington, DC; J. Mark Iwry, former
                  Benefits Tax Counsel, Department of
                  Treasury, Washington, DC.
         2:40pm   Significant Developments Affecting
                  Employment Taxes. A panel of
                  practitioners and government
                  representatives will discuss the most
                  significant recent developments affecting
                  employment taxes – with a focus on their
                  practical implications. The discussion also
                  will include the appropriateness of any
                  actions to be taken by the Committee in
                  response to those developments. Panelists:
                  John Richards, Senior Tax Counsel, IRS,
                  Washington, DC; Thomas R. Burger, SBSE
                  Headquarters Program Manager,
                  Employment Tax, IRS, Washington, DC; Larry
                  A. Campagna, Chamberlain Hrdlicka,
                  Houston, TX; George E. Marifian, Mathis,
                  Marifian et al, Belleville, IL; GJ Stillson
                  MacDonnell, Littler Mendelson PC, San
                  Francisco, CA.
         3:10pm   Unintended Consequences of Taxpayer-
                  Friendly IRS Administrative Programs for
                  Resolving Employment-Tax Disputes. A
                  panel of private-sector and government
                  guests will offer a critical review and
                  assessment of the Classification Settlement
                  Program, the Early Referral Program and other
                  administrative programs implemented by the
                  IRS during the past several years from the
                  perspective of how taxpayers have fared
                  under such programs and whether any
                  changes are appropriate. Moderator: Harvey
                  Shulman, Expert Advice & Counsel,
                  Washington, DC; Thomas R. Burger, SBSE
                  Headquarters Program Manager, Employment
                  Tax, IRS, Washington, DC.
         3:50pm   Employment-Tax Insights from the Lone
                  Star State. Highly experienced
                  employment-tax practitioners and state and
                  federal government officials who are located
38
                                     JANUARY 24, 2003
                                 Program Schedule           ✯




                                                            Friday
          in Texas will offer their insights and views on
          handling federal and state employment-tax
          controversies. The program will include an
          insider’s perspective on the Austin
          operations of the IRS Form SS-8 program
          and on the IRS’ expanded criminal focus on
          certain employment-tax violations. The
          panel will provide a unique opportunity to
          meet government representatives from the
          host state of Texas. Moderator: GJ Stillson
          MacDonnell, Littler Mendelson, PC, San
          Francisco, CA. Panelists: Sandra Mabbett,
          Manager, SS-8 Program Team, Austin, TX.
4:25pm    Committee Discussion of Legislative
          and Regulatory Submissions. Discussion
          and debate on legislative and regulatory
          submissions worked on by Committee
          Members subsequent to the October 2002
          meeting. Moderator: Russell A. Hollrah,
          Hahn Kyle & Hollrah LLP, Washington, DC.
4:30pm    Employment-Tax Practitioners
          Workshop. Group discussion among
          practitioners and government
          representatives of employment-tax issues
          faced in practice and of important issues
          that the Committee should consider
          pursuing. Moderator: Russell A. Hollrah,
          Hahn Kyle & Hollrah LLP, Washington, DC.
          This session will not be taped.

1:30pm – 2:30pm              Conf Rm 15, Level 3
Estate & Gift Taxes Young Lawyer Subcommittee A

1:30pm – 3:30pm                     Salon F, Level 3
US Activities of Foreigners and Tax Treaties
Chair: Joan C. Arnold, Pepper Hamilton LLP,
Philadelphia, PA
1:30pm    Update on Committee Activities
          by the Chair.
1:35pm    Permanent Establishments in the US. As
          electronic commerce has illustrated, the tax
          concept of PE still needs to be developed in
          certain key and common areas of economic
          activity, most notably the services industry.
                                                            39
JANUARY 24, 2003
✯ Program Schedule
Friday


                   The panel will focus on these and related
                   issues (e.g., PE-related issues presented by
                   the use single member LLCs), from a US
                   perspective. Moderator: Professor Reuven S.
                   Avi-Yonah, University of Michigan School of
                   Law, Ann Arbor, MI. Panelists: William L.
                   Bricker, Jr., Curtis, Mallet-Prevost, Colt &
                   Mosle LLP, New York, NY; Philip West,
                   Steptoe & Johnson LLP, Washington DC.
         2:50pm    Competent Authority—How to Access
                   it, When to Use it, How it Works, What
                   Doesn’t Work. Moderator: Harold L.
                   Adrion, The Ruchelman Law Firm, New York,
                   NY. Panelists: Friedhelm Jacob, Hengeler
                   Mueller, Frankfurt, Germany.

         2:00pm – 5:00pm                      Salon D, Level 3
         Court Procedure and Practice
         Chair: Robert T. Duffy, Mayer, Brown, Rowe & Maw,
         Charlotte, NC
         2:00pm    Opening Remarks by the Chair.
         2:05pm    Remarks on behalf of the United States
                   Tax Court. The Honorable Thomas B.
                   Wells, Chief Judge, US Tax Court,
                   Washington, DC.
         2:20pm    Tax Court Proceedings Under Seal—
                   Practical Issues. This panel will discuss the
                   more practical aspects of submitting
                   documents or evidence under seal, dealing
                   with testimony under seal, and filing a
                   petition anonymously. Moderator: Kevin L.
                   Kenworthy, Miller & Chevalier, Chartered,
                   Washington, DC. Panelists: Deborah A.
                   Butler, Associate Chief Counsel (Procedure
                   and Administration), IRS, Washington, DC;
                   The Honorable Juan F. Vasquez, US Tax
                   Court, Washington, DC.
         2:50pm    Electronic Documents and Spoliation.
                   This panel will discuss the discovery of
                   electronic information, including obligations
                   to retain and search for electronic
                   information. Moderator: Robin L.
                   Greenhouse, McDermott, Will & Emery,

40
                                   JANUARY 24, 2003
                               Program Schedule          ✯




                                                         Friday
         Washington, DC. Panelists: David J. Curtin,
         McKee Nelson LLP, Washington, DC; The
         Honorable Stephen J. Swift, US Tax Court,
         Washington, DC; Richard Goldman, Office
         of Chief Counsel (Procedure and
         Administration), IRS, Washington, DC.
3:30pm   Remarks on behalf of the Office of
         Chief Counsel, Internal Revenue
         Service. Speaker: Deborah A. Butler,
         Associate Chief Counsel (Procedure and
         Administration), IRS, Washington, DC.
3:35pm   Disclosure of Tax Returns in Non-Tax
         Litigation. This panel will discuss the
         strategies for obtaining and objecting to
         discovery requests for tax returns in non-tax
         litigation and the circumstances under which
         tax returns may be available from the IRS,
         including the practical aspects of how the
         return should be requested. Moderator:
         Christopher M. Pietruszkiewicz, Assistant
         Professor of Law, Paul M. Hebert Law
         Center, Louisiana State University, Baton
         Rouge, LA. Panelists: Michael J. Salem, Tax
         Division, Department of Justice,
         Washington, DC; Sarah Ann Duckers, Vinson
         & Elkins LLP, Houston, TX; Nancy T. Bowen,
         Fulbright & Jaworski LLP, Houston, TX.
3:55pm   Perpetuating Testimony. This panel will
         discuss perpetuating the testimony of
         witnesses who are unavailable for trial.
         Moderator: David A. Roman, Miller &
         Chevalier, Chartered, Washington, DC.
         Panelists: Winston J. Krause, Krause &
         Associates LLP, Austin, TX; Sanford W. Stark,
         McKee Nelson LLP, Washington, DC.
4:15pm   Current Developments. Speaker: Allen D.
         Madison, Fenwick & West LLP, Palo Alto, CA.
4:25pm   Informal Discovery in the Tax Court.
         This panel will discuss informal discovery in
         the Tax Court, including required
         consultation by the parties, Branerton
         letters, and the Tax Court’s recent decision
         in Schneider Interests, L.P. v. Commissioner,
                                                         41
JANUARY 24, 2003
✯ Program Schedule
Friday


                   119 T.C. No. 8 (Sept. 30, 2002). Panelists:
                   Richard G. Goldman, Chief, Branch 3, Office
                   of Assistant Chief Counsel (Administrative
                   Provisions and Judicial Practice), IRS,
                   Washington, DC; Jonathan Z. Ackerman,
                   McKee Nelson, LLP, Washington, DC.
         4:45pm    Introducing Internet Evidence. This
                   panel will discuss how to introduce into
                   evidence information obtained from the
                   Internet. Moderator: Greg Lynam, Baker &
                   McKenzie, Chicago, IL.

         2:00pm – 5:00pm                       Salon B, Level 3
         Formation of Tax Policy A
         Chair: Fred F. Murray, Tax Executives Institute, Inc.,
         Washington, DC
         2:00pm    Increasing Use of Anti-Abuse Rules in
                   the US Federal Tax System—What the
                   Canadians Have Learned About GAAR.
                   Section 101 of H.R. 5095 would introduce a
                   broad anti-abuse rule to codify the
                   economic substance doctrine. As a
                   substantive Code change and a separate
                   basis for a penalty for noncompliance, the
                   proposals would mark a significant
                   departure from our traditional rules-based
                   system. The panelists will consider the use
                   and functioning of anti-abuse rules in our
                   federal tax system and that of Canada, our
                   largest trading partner. Moderator: Fred F.
                   Murray, Tax Executives Institute, Inc.,
                   Washington, DC. Panelists: Julian Kim,
                   Attorney Advisor (Tax Policy), Department of
                   Treasury, Washington, DC; Lawrence B.
                   Gibbs, Miller & Chevalier, Chartered,
                   Washington, DC; Martin J. McMahon, Jr.,
                   University of Florida School of Law,
                   Graduate Tax Program, Gainesville, FL;
                   Alan Wheable, Toronto Dominion Bank,
                   Toronto, Canada.
         3:40pm    Taxing Business Income Once:
                   Integration of the Corporate and
                   Individual Income Tax Systems. The
                   classical system of current rules governing
                   the corporate and individual income tax
42
                                     JANUARY 24, 2003
                                 Program Schedule           ✯




                                                            Friday
          systems of the US treats corporations and
          their investors as separate entities and levies
          tax at both the corporate and shareholder
          levels on earnings from investments in
          corporate equity. The panelists will consider
          the fundamental questions concerning how
          these rules affect our system and how it
          might be restructured to reduce tax
          distortions of important corporate financial
          decisions. Moderator: Fred F. Murray, Tax
          Executives Institute, Inc., Washington, DC.
          Panelists: Gregory F. Jenner, Deputy
          Assistant Secretary (Tax Policy), Department
          of Treasury, Washington, DC; Eric M. Zolt,
          Harvard Law School, Cambridge, MA;
          George K. Yin, University of Virginia Law
          School, Charlottesville, VA; Robert P. Hanson,
          Ernst & Young LLP, Washington, DC.

2:00pm – 5:00pm                 Conf Rm 13, Level 3
Nominating (Executive Session)
Chair: Richard M. Lipton, Chicago, IL

2:15pm – 5:30pm                   Conf Rm 7, Level 3
Closely-Held Businesses A
Chair: Leslie E. Grodd, Blazzard, Grodd & Hasenauer,
PC, Westport, CT
2:15pm    Buy-Sell Agreements and Related Tax
          Issues for Closely-Held Business
          Owners. Factors to consider in designing
          and implementing buy-sell agreements;
          types of buy-sell agreements; establishing
          value for estate tax purposes and other tax
          considerations; funding with life insurance
          and other methods; special considerations
          for S corporations, partnerships or
          professional corporations; issues for family-
          owned businesses. Moderator: Susan M.
          Harmon, Susan M. Harmon and Associates,
          Bala Cynwyd, PA. Panelist: Louis A.
          Mezzullo, Mezzullo & Guare, PLC,
          Richmond, VA.
3:30pm    Break


                                                            43
JANUARY 24, 2003
✯ Program Schedule
Friday


         3:45pm   Tax Aspects of Divorce and Separation
                  as it Affects Control, Succession and
                  Valuation Issues for a Closely-Held
                  Business Owner. Moderator: Elizabeth J.
                  Atkinson, Kaufman & Canoles, Norfolk, VA.
                  Panelist: Professor Toni Robinson,
                  Quinnipiac University, School of Law,
                  Hamden, CT.

         2:30pm – 5:30pm                Conf Rm 9, Level 3
         Agriculture
         Chair: James A. Nepple, Nepple Law Offices, PLC,
         Rock Island, IL
         2:30pm   Federal Legislative Update. Report on
                  recent and anticipated federal legislative
                  developments affecting the agriculture
                  industry. Moderator: James A. Nepple,
                  Nepple Law Offices, PLC, Rock Island, IL.
                  Panelist: Elizabeth Crewson Paris, Tax
                  Counsel, Senate Finance Committee,
                  Washington, DC.
         3:00pm   Federal Legislative and Regulatory
                  Proposals. Report on legislative and
                  regulatory proposals affecting the agriculture
                  industry to be presented by members of the
                  Committee to legislators and their staff or
                  the IRS as a part of their annual courtesy
                  visits prior to the May Meeting. Moderators:
                  Harvey R. Sorensen, Foulston & Siefkin LLP,
                  Wichita, KS; Craig A. Houghton, Baker,
                  Manock & Jensen, Fresno, CA.
         3:30pm   Cooperatives—Not Just for Crops Grown
                  Down on the Farm—Part II. The first part
                  of this program will discuss the advantages
                  and disadvantages of a cooperative as a
                  business form and will be an introduction to
                  the federal income taxation of both exempt
                  and non-exempt cooperatives. The second
                  part of this program will discuss current hot
                  issues in cooperative law and taxation and the
                  emerging use of cooperatives in service and
                  other non-agriculture businesses. Moderator:
                  Craig A. Houghton, Baker, Manock & Jensen,
                  Fresno, CA. Panelists: Donald W. Butwill,
                  Deloitte & Touche LLP, San Francisco, CA;
44
                                      JANUARY 24, 2003
                                  Program Schedule           ✯




                                                             Friday
          Teresa H. Castanias, KPMG LLP, Sacramento,
          CA; Kendall L. Manock, Baker, Manock &
          Jensen, Fresno, CA.

2:30pm – 5:30pm                 Conf Rm 18, Level 3
Bankruptcy Task Force
Chair: Bob Pope, Gullett, Sanford, Robinson & Martin,
PLLC, Nashville, TN

2:30pm – 6:30pm                    Salon G, Level 3
Employee Benefits
Chair: Thomas R. Hoecker, Snell & Wilmer LLP,
Phoenix, AZ
2:30pm    Opening Remarks by the Chair.
2:40pm    The Latest Twist on 401(k) Plans. This
          panel will discuss the reproposed 401(k)
          plan regulations (if issued) and the plan loan
          regulations (if issued). The panelists also will
          discuss planning opportunities and the
          impact of the guidance on plan design.
          Moderator: Greta E. Cowart, Haynes and
          Boone LLP, Dallas, TX. Panelists: W. Thomas
          Reeder, Associate Benefits Tax Counsel,
          Department of Treasury, Washington, DC;
          Richard J. Wickersham, Manager, EP
          Technical Guidance and Quality Assurance,
          IRS, Washington, DC; Leonard S. Hirsh,
          Ernst & Young LLP, New York, NY; Carol A.
          Weiser, Sutherland Asbill & Brennan LLP,
          Washington, DC.
3:20pm    Executive Compensation—Sarbanes-
          Oxley Revisited and Other
          Developments. This panel will discuss
          recent Sarbanes-Oxley developments and
          anticipated regulations regarding Incentive
          Stock Options (if issued). Moderator:
          Priscilla E. Ryan, Sidley, Austin, Brown &
          Wood, Chicago, IL. Panelists: Mark A.
          Borges, Office of Rulemaking, Division of
          Corporation Finance, Securities and
          Exchange Commission, Washington, DC;
          Alan Tawshunsky, Assistant Chief Counsel
          (Employee Benefits), TE/GE, IRS,
          Washington, DC; Max Schwartz, Sullivan &
          Cromwell, New York, NY.
                                                             45
JANUARY 24, 2003
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Friday


         4:05pm    Update on the Future of the
                   Determination Letter Program.
                   Speaker: Paul T. Shultz, Director, Employee
                   Plans Rulings and Agreements, IRS,
                   Washington, DC.
         4:20pm    Handling Plan Audits: IRS/DOL
                   Strategy and Tactics. A panel of IRS and
                   DOL representatives will address a wide
                   array of issues involving national audit
                   strategy and hands on practitioner issues in
                   plan audits. If anticipated guidance on
                   abusive nonqualified deferred compensation
                   issues is issued in advance of the meeting, it
                   will be addressed. Planning Chair and
                   Moderator: Seth H. Tievsky, Ernst & Young
                   LLP, Washington, DC. Alan Tawshunsky,
                   Assistant Chief Counsel (Employee Benefits),
                   TE/GE Chief Counsel, IRS, Washington, DC;
                   Steve Eischen, Regional Director, Pension
                   and Welfare Benefits Administration,
                   Department of Labor, Dallas, TX; Vicki
                   Hanson, Area Manager, Gulf Coast,
                   Employee Plans Division, IRS, Dallas TX;
                   Daniel Morgan, Venable, Washington, DC.
         5:30pm    Roundtable Discussion with
                   Representatives of the Department of
                   Treasury, Internal Revenue Service and
                   TE/GE Chief Counsel’s Office.

         2:30pm – 5:30pm                     Salon K, Level 3
         Financial Transactions
         Chair: Chip Harter, PricewaterhouseCoopers LLP,
         Washington DC
         2:30pm    Interesting Instruments—Contingent
                   Convertibles and Equity Linked
                   Securities. This panel will discuss policy
                   issues and recent developments with respect
                   to several types of innovative capital markets
                   transactions. One issue of discussion will be
                   how broadly Rev. Rul. 2002-31 should be
                   applied to allow the creation of “deductible
                   equity.” A second topic will be the tax
                   ownership issues arising under equity-linked
                   securities and the IRS’ positions in FSA
46
                                    JANUARY 24, 2003
                                Program Schedule         ✯




                                                         Friday
          200111011 and FSA 200131015, including
          recent developments with respect to
          STRYPEs and PRIDES. Moderator: Steve
          Surdell, Ernst & Young LLP, Chicago, IL.
          Panelists: Matthew Stevens, Special Counsel
          to the Chief Counsel, IRS, Washington, DC;
          Viva Hammer, Attorney Advisor, Office of Tax
          Policy, Department of Treasury, Washington,
          DC; David Shapiro, PricewaterhouseCoopers
          LLP, Washington, DC.
3:30pm    Foreign Currency Denominated Debt. A
          panel will discuss issues and recent
          developments with respect to the taxation
          of foreign currency denominated debt
          instruments. The treatment of contingent,
          dual currency, inflationary and
          hyperinflationary foreign currency
          denominated debt will be discussed. The
          subpart F implications of foreign currency
          denominated debt transactions will be
          discussed, including proposed regulations
          applicable to securities dealers. Moderator:
          David Garlock, Ernst & Young LLP,
          Washington, DC. Panelists: Peter Connors,
          Orrick, Herrington & Suttcliffe, New York,
          NY; Michael Feder, PricewaterhouseCoopers
          LLP, Washington, DC.
4:30pm    Current Developments. A panel will
          review recent administrative, regulatory,
          legislative and litigation developments
          relating to the taxation of financial
          transactions. The panel will include Matthew
          Stevens, Special Counsel to the Chief
          Counsel, IRS, Washington, DC and private
          practitioners positioned to address late-
          breaking issues.

2:30pm – 5:30pm                    Salon A, Level 3
Real Estate A
Chair: Michael J. Grace, Washington, DC
2:30pm    Welcome and Announcements by
          the Chair.



                                                         47
JANUARY 24, 2003
✯ Program Schedule
Friday


         2:35pm   New Markets Tax Credit. The
                  Department of Treasury is in the process of
                  making its first allocations of the New
                  Markets Tax Credit. The panel will analyze
                  the first round of allocations of the NMTC
                  and will explore the ownership structures
                  that successful applicants are using, with
                  particular emphasis on the use of partner-
                  ships as the investors in Community
                  Development Entities and the manner in
                  which a partnership is permitted to allocate
                  the NMTC among its partners. Moderator:
                  John H. Gadon, Lane Powell Spears
                  Lubersky LLP, Portland, OR. Panelists:
                  Eric Solomon, Deputy Assistant Secretary,
                  Regulatory Affairs, Department of Treasury,
                  Washington, DC; Steven P. Berman, Ballard
                  Spahr Andrews & Ingersoll LLP,
                  Philadelphia, PA.
         3:20pm   Passive Activity/At-Risk Update. The
                  panel will discuss the special passive activity
                  limitations applicable to real estate
                  professionals, recent litigation and rulings
                  involving passive activity and at-risk issues,
                  proposals to clarify the definition of
                  “qualified non-recourse financing” and
                  efforts to repeal the at-risk rules. Moderator:
                  Michael J. Grace, Washington, DC. Panelist:
                  Dan Carmody, Senior Counsel, Branch 1, IRS
                  Office of Associate Chief Counsel
                  (Passthroughs & Special Industries), IRS,
                  Washington, DC.
         3:45pm   Section 704(c) in the Real Estate World.
                  This panel will discuss various section 704(c)
                  related issues that confront partnerships that
                  own real estate, including issues relating to
                  property contributions, “book-ups” and
                  tiered partnerships. Moderator: Andrea
                  MacIntosh Whiteway, Arnold & Porter,
                  Washington, DC. Panelists: James E.
                  Wreggelsworth, Davis Wright Tremaine LLP,
                  Seattle, WA; Eric Sloan, Deloitte & Touche
                  LLP, New York, NY.


48
                                    JANUARY 24, 2003
                                 Program Schedule         ✯




                                                          Friday
4:25pm    Tax Planning for Home Builders. This panel
          will discuss various tax issues that confront
          home builders as well as available planning
          opportunities. Topics may include accounting
          methodologies, conversion of ordinary
          income into capital gain, capitalization vs.
          deductibility of expenditures and the
          presence of goodwill in sales of businesses.
          Moderator: Steven M. Friedman, Ernst &
          Young LLP, Washington, DC. Panelists:
          Christopher F. Allison, Jr., Locke Liddell &
          Sapp LLP, Dallas, TX; Gino Bianchini, Ernst &
          Young LLP, Washington, DC.
5:05pm    Tax Issues in Texas Real Estate
          Transactions—A Primer for Non-Texas
          Lawyers. A The panel will identify tax
          issues and planning opportunities that non-
          Texas practitioners should consider for
          transactions involving Texas investment and
          income-producing real property. Topics will
          include the impact of the Texas franchise tax
          on the choice of entity, basic property tax
          and transfer tax planning, and other aspects
          of Texas real property law. Moderator:
          Stanley L. Blend, Oppenheimer, Blend,
          Harrison & Tate, Inc., San Antonio, TX.
          Panelists: Barbara de Marigny,
          Oppenheimer, Blend, Harrison & Tate, Inc.,
          San Antonio, TX; Mitchell Tiras, Locke Lidell
          & Sapp LLP, Houston, TX.

2:30pm – 5:30pm                       Salon L, Level 3
State and Local Taxes
Chair: David R. Cassidy, Breazeale, Sachse & Wilson
LLP, Baton Rouge, LA
2:30pm    SALT Matters in a Bankruptcy/Workout
          Situation: Tread Lightly. This panel will
          address state and local tax issues in the
          bankruptcy and workout situation; knowing
          where the potholes are and how to avoid
          them is of paramount importance when
          addressing SALT issues in this situation.
          Moderator: Mark F. Sommer, Greenebaum
          Doll & McDonald PLLC, Louisville, KY.

                                                          49
JANUARY 24, 2003
✯ Program Schedule
Friday


                   Panelists: Christine Agnew, Weil Gotshal &
                   Manges LLP, New York, NY; Stanley R.
                   Kiminski, Duane Morris, Chicago, IL.
         3:30pm    Making Winning Feel Like Losing:
                   Remedies for Unconstitutional State
                   Taxes. This panel will discuss how courts
                   are interpreting the requirement in the
                   Supreme Court’s McKesson decision that a
                   state fashion a meaningful “backwards
                   looking remedy” for a state tax that has
                   been found to be unconstitutional.
                   Moderator: John A. Biek, McDermott, Will &
                   Emery, Chicago, IL. Panelists: Jack Van
                   Coevering, Administrator of Office of Legal
                   & Hearings, Michigan Department of
                   Treasury, Lansing, MI; Stewart M. Weintraub,
                   Schnader, Harrison, Segal, et al.,
                   Philadelphia, PA; Bruce P. Ely, Bradley Arant
                   Rose & White LLP, Birmingham, AL.
         4:30pm    The Streamline Sales Tax Project. This
                   panel will discuss the status of the project,
                   proposed changes, unresolved issues and its
                   prospects for ultimate success. Moderator:
                   Diann Smith, COST, Washington, DC.

         2:30pm – 5:30pm                  Salon M, Level 3
         Tax Accounting
         Chair: Kenneth E. Kempson, General Electric Company,
         Stamford CT
         2:30pm    Administrative Announcements by
                   the Chair.
         2:35pm    Recent Developments in the Area of
                   Tax Accounting. This program will cover
                   the important recent developments in the
                   tax accounting area since the October 2002
                   meeting in Los Angeles. Moderator: Beth
                   Benko, Ernst & Young LLP, Washington DC.
                   Panelists: Sharon Kay, Taxation Specialist,
                   Office of Tax Policy, Department of Treasury,
                   Washington, DC; David A. Schneider,
                   Special Counsel to Associate Chief Counsel,
                   (Income Tax & Accounting), IRS, Washington
                   DC; Professor Annette Nellen, San Jose
                   State University, San Jose, CA.
50
                                    JANUARY 24, 2003
                                Program Schedule          ✯




                                                          Friday
3:10pm   Proposed Regulations on Capitalization
         of Intangibles. Prior to the January
         meeting, the Treasury is expected to issue
         proposed regulations on the capitalization of
         intangibles. This panel will describe the
         positions taken and discuss issues raised in
         the proposed regulations. A Saturday Mini-
         program will address the proposed
         regulations in more depth. Moderator: Ellen
         McElroy, Ernst & Young LLP, Washington,
         DC. Panelists: Sharon Kay, Taxation
         Specialist, Office of Tax Policy, Department
         of Treasury, Washington, DC; Andrew Keyso,
         Jr., Attorney, Associate Chief Counsel
         (Income Tax Accounting) Branch 1, IRS,
         Washington DC; Jody J. Brewster, Skadden,
         Arps, Slate, Meagher & Flom LLP,
         Washington DC.
4:00pm   The Research Credit: Where Are We
         Now? This program will address the current
         standards for the research credit, including
         an overview of basic principles, the recent
         regulatory changes, and the confusing re-
         emergence of the “discovery” test in Tax
         and Accounting Software Corp. v. United
         States. Moderator: Rosemary Becchi,
         Citigroup, Inc., Washington DC. Panelists:
         Sharon Kay, Taxation Specialist, Office of Tax
         Policy, Department of Treasury, Washington,
         DC; James M. Eberle, KPMG LLP,
         Washington, DC; Daniel A. Rosen, Industry
         Counsel (Research Credit), Office of Chief
         Counsel, IRS, Washington, DC.
4:40pm   The “All Events” Test: New
         Developments in Old Law. Accrual basis
         taxpayers must meet the “all events” test to
         take items of income or expense into
         account. This panel will review the
         regulatory rules under sections 451 and 461,
         and will take an in-depth look at areas in
         which the law is developing, including
         contested liabilities, contested income,
         payroll taxes on deferred compensation,
         Medicaid rebates, and economic
         performance. Moderator: Jan Skelton,
                                                          51
JANUARY 24, 2003
✯ Program Schedule
Friday


                   Deloitte & Touche LLP, Washington, DC.
                   Panelists: Sharon Kay, Taxation Specialist,
                   Office of Tax Policy, Department of Treasury,
                   Washington, DC; David A. Schneider, Special
                   Counsel to Associate Chief Counsel, (Income
                   Tax & Accounting), IRS, Washington DC;
                   Carol Conjura, KPMG LLP, Washington, DC.

         2:30pm – 5:30pm                  Conf Rm 12, Level 3
         Tax Exempt Financing
         Chair: Carol L. Lew, Stradling Yocca Carlson & Rauth,
         Newport Beach, CA
         2:30pm    Administrative Matters and
                   Introduction to Today’s Meeting by
                   the Chair.
         2:40pm    Report on Status of IRS and
                   Department of the Treasury Projects
                   with Comments. Moderators: Bruce M.
                   Serchuk, Senior Technical Reviewer, Tax
                   Exempt Bond Branch, Office of Chief
                   Counsel, IRS, Washington, DC; Stephen J.
                   Watson, Associate Tax Legislative Counsel,
                   Tax Legislative Counsel, Department of
                   Treasury, Washington, DC.
         3:00pm    Student and Faculty Housing —
                   501(c)(3) Update. Moderator: Wayne B.
                   Henry, Kutak, Rock LLP, Omaha, NE.
                   Panelists: Bruce M. Serchuk, Senior
                   Technical Reviewer, Tax-Exempt Bond
                   Branch, Office of the Chief Counsel, IRS,
                   Washington, DC; Sunita Lough, Office of the
                   National Director, Tax-Exempt Bond
                   Program, Tax-Exempt and Governmental
                   Entities Division, IRS, Washington, DC.
         3:30pm    Update on Mixed Use Comment
                   Project. Moderator: John J. Cross III,
                   Hawkins Delafield & Wood, Washington,
                   DC. Panelists: Bruce M. Serchuk, Senior
                   Technical Reviewer, Tax Exempt Bond
                   Branch, Office of Chief Counsel, IRS,
                   Washington, DC; Stephen J. Watson,
                   Associate Tax Legislative Counsel, Tax
                   Legislative Counsel, Department of Treasury,
                   Washington, DC.
52
                                    JANUARY 24, 2003
                                 Program Schedule        ✯




                                                         Friday
4:00pm    Long-term Working Capital Financings
          — Current Issues. Moderator: David A.
          Caprera, Kutak Rock LLP, Denver, CO.
          Panelists: Bruce M. Serchuk, Senior
          Technical Reviewer, Tax Exempt Bond
          Branch, Office of Chief Counsel, IRS,
          Washington, DC; Stephen J. Watson,
          Associate Tax Legislative Counsel, Tax
          Legislative Counsel, Department of Treasury,
          Washington, DC.
4:30pm    Current Issues with Hedges, Including
          LIBOR Swaps. Moderator: John T. Lutz,
          Clifford Chance Rogers & Wells, LLP, New
          York, NY. Panelists: Bruce M. Serchuk,
          Senior Technical Reviewer, Tax Exempt Bond
          Branch, Office of Chief Counsel, IRS,
          Washington, DC; Stephen J. Watson,
          Associate Tax Legislative Counsel, Tax
          Legislative Counsel, Department of Treasury,
          Washington, DC.
5:00pm    "Essential Governmental Function" and
          Other Issues Relating to Tribal Debt.
          Panelists: Bruce M. Serchuk, Senior
          Technical Reviewer, Tax Exempt Bond
          Branch, Office of Chief Counsel, IRS,
          Washington, DC; Stephen J. Watson,
          Associate Tax Legislative Counsel, Tax
          Legislative Counsel, Department of Treasury,
          Washington, DC; Sunita Lough, Office of the
          National Director, Tax-Exempt Bond
          Program, Tax-Exempt and Governmental
          Entities Division, IRS, Washington, DC.

3:30pm – 5:00pm                       Salon F, Level 3
Transfer Pricing
Chair: Charles Triplett, Mayer, Brown, Rowe & Maw,
Washington, DC
3:30pm    Opening Remarks by the Chair.
3:35pm    Important Developments. Speaker:
          Steven Wrappe, Deloitte & Touche LLP,
          Washington, DC.
3:45pm    Proposed Regulations on Intercompany
          Services. A discussion of the long-awaited

                                                         53
JANUARY 24, 2003
✯ Program Schedule
Friday


                   section 1.482-2(b) proposed regulations.
                   Topics will include highlights of significant
                   policy issues vis-à-vis the existing regulations
                   and compatibility with the OECD Guidelines
                   on the treatment of intercompany services.
                   Panelists: Rocco Femia, Attorney-Advisor,
                   Department of Treasury, Washington, DC;
                   John Warner, Silverstein and Mullens, a
                   division of Buchanan Ingersoll, PC,
                   Washington, DC; Darrin Litsky, Pricewater-
                   houseCoopers LLP, Los Angeles, CA.
         4:15pm    Intangibles—Migration and Valuation
                   Post-DHL. A discussion of the current state
                   of the law regarding the valuation of
                   intangibles and prospects for change given
                   the recent Treasury Department study on
                   inversions and the migration of intangibles.
                   Panelists: Rocco Femia, Attorney-Advisor,
                   Department of Treasury, Washington, DC;
                   Michael Mundaca, Ernst & Young LLP,
                   Washington, DC; Henry Birnkrant, Alston &
                   Bird, Washington, DC.
         4:40pm    Update on Mexico and South America.
                   Topics will include the aggressive transfer
                   pricing audits by taxing authorities: “hot”
                   issues they are raising and specific industries
                   under scrutiny, including the Maquiladoras.
                   Panelists: Moisés Curiel, Mancera Ernst &
                   Young LLP, Mexico City, Mexico; Robert Stack,
                   Wilmer, Cutler & Pickering, Washington, DC.

         4:00pm – 6:30pm             Conf Rms 1 & 2, Level 3
         Young Lawyers Forum and Diversity
         Committee A
         Young Lawyers Forum Chair: Christine L. Agnew, Weil,
         Gotshal & Manges LLP, New York, NY
         Diversity Committee Co-Chairs: Wayne A. Hamilton,
         JM Family Enterprises, Inc. Deerfield Beach, FL; Jessica
         A. Hough, Skadden, Arps, Slate, Meagher, & Flom LLP,
         Washington, DC
         4:00pm    Opening Remarks by the Chair.
         4:15pm    Rethinking Pro Bono—It’s Not For Free.
                   Pro bono opportunities offer young lawyers
                   an opportunity to serve their communities,
54
                                    JANUARY 24, 2003
                                 Program Schedule          ✯




                                                           Friday
         but that doesn’t mean that young lawyers
         get nothing in return. In addition to giving
         back to their communities and helping
         others in need, many of these opportunities
         allow young lawyers to do things they are
         often not able to do in private, in-house or
         governmental practice: (1) take primary
         responsibility for a case; (2) develop client
         service and advocacy skills; and (3) get
         involved in exciting cases at a high level.
         The panel will discuss issues ranging from
         how to find pro bono opportunities in your
         community to how to balance your workload
         with your pro bono commitments.
         Moderator: Shannon Nash, Amgen Inc.,
         Thousand Oaks, CA. Panelists: Karen L.
         Hawkins, Taggart & Hawkins, Oakland, CA;
         Billy D. Hubbard, SPEC Territory Manager,
         IRS, Austin, TX; Peter A. Lowy, Shell Oil
         Company, Houston, TX; Nina E. Olson,
         National Taxpayer Advocate, IRS,
         Washington, DC.
5:30pm   Cocktail Reception. Young lawyers and
         Tax Section leaders share experiences and
         network with one another during this
         cocktail reception and representatives from
         various Tax Section committees will be there
         to showcase their committee projects and
         activities. In addition, the semi-finalists and
         winners from this year’s Tax Law Challenge
         will be announced at the reception.

5:00pm – 7:30pm               Conf Rm 15, Level 3
Corporate Offshore Inversions and International
Tax Reform Task Force (Executive Session)
Co-Chairs: Leonard Schneidman, Foley Hoag LLP,
Boston, MA; Stephen E. Shay, Ropes & Gray,
Boston, MA




                                                           55
JANUARY 24, 2003
✯ Program Schedule
Friday


         5:00pm – 6:00pm               Conf Rm 14, Level 3
         Foreign Activities of US Taxpayers Business
         Meeting

         5:00pm – 6:00pm                Conf Rm 17, Level 3
         Programs and Meetings
         Chair: Stanley L. Blend, Oppenheimer, Blend, Harrison
         & Tate, Inc., San Antonio, TX

         5:00pm – 5:30pm           Conf Rm 11, Level 3
         Young Lawyers of FAUST Subcommittee A
         Chair: Brent Gregoire, McDermott, Will & Emery,
         Washington, DC
         Inaugural meeting to introduce the subcommittee.

         5:30pm – 6:30pm            Conf Rm 16, Level 3
         Foreign Lawyers Forum Business Meeting

         5:30pm – 6:30pm                 Conf Rm 10, Level 3
         Professional Services
         Chair: Samuel L. Braunstein, Braunstein & Todisco, LLC,
         Fairfield, CT
         Report on Tax Section Plans and Goals for the
         Committee. Tax Section and Committee leadership will
         discuss the role of this Committee in implementing
         Section plans for programs, publications and meetings,
         and will explain how this Committee can help other Tax
         Section Committees succeed in reaching a larger
         audience of members and prospective members.
         Specific topics that will be discussed include: (1)
         teleconference programs “live from the meetings” –
         the pros and cons; program selection criteria; technical
         matters with such programs; and development of their
         potential for more effective membership participation;
         (2) “Last Wednesday” monthly teleconferences –
         update on scheduled programs, procedural matters
         and engaging assistance/cooperation of affected
         committees and Tax Section leadership; (3) mini-
         programs – procedures and program selection matters
         for mini-programs presented at Tax Section meetings;
         (4)Tax Section communications – ABA progress on
         email and other tools related to intra-section
         communications (or the lack thereof); (5)”freebies” – no
         charge teleconferences by select Tax Section
         committees; Tax Link Live series; (6) open discussion –
         brainstorming for other ways to enhance member
         benefits through Continuing Legal Education programs.
56
                                    JANUARY 24, 2003
                                  Program Schedule     ✯




                                                       Friday
5:30pm – 6:30pm               Conf Rm 13, Level 3
US Activities of Foreigners and Tax Treaties
Business Meeting


Cash Bars and Receptions
3:30pm – 4:00pm                     Salon E, Level 3
Exempt Organizations Cash Bar

5:00pm – 6:00pm                      Foyer, Level 3
Foreign Activities of US Taxpayers, Foreign
Lawyers Forum, Transfer Pricing and US Activities
of Foreigners and Tax Treaties Cash Bar

5:30pm – 6:30pm                      Foyer, Level 3
Agriculture Cash Bar

5:30pm – 6:30pm                      Foyer, Level 3
Financial Transactions Cash Bar

5:30pm – 6:30pm                      Foyer, Level 3
Tax Exempt Financing Cash Bar

5:30pm – 6:30pm       Conf Rms 3 & 4, Level 3
Young Lawyers Forum and Diversity Committee
Reception

6:30pm – 8:00pm                   Salon I, Level 3
Employee Benefits Reception (Ticketed Event)

6:30pm – 8:00pm                    Salon E, Level 3
Section Reception (Ticketed Event)




                                                       57
JANUARY 25, 2003
✯ Program Schedule
Saturday


           Saturday, January 25
           7:00am – 8:30am              Conf Rm 15, Level 3
           IRS Guidance Task Force
           Chair: Kenneth Gideon, Skadden, Arps, Slate, Meagher
           & Flom LLP, Washington, DC

           7:00am – 8:30am                 Conf Rm 16, Level 3
           Pro Bono
           Chair: Richard M. Lipton, Chicago, IL
           This will be an organizational meeting of the new
           Pro Bono Committee. Anyone who is interested in
           pro bono activities is encouraged to attend. A
           complimentary breakfast will be provided.

           7:00am – 8:30am                     Salon M, Level 3
           Tax Practice Management
           Chair: Aen W. Webster, Silverstein and Mullens,
           Washington, DC
           7:00am    Informal Discussion and Complimentary
                     Breakfast.
           7:20am    Opening Remarks, Report on
                     Committee Chairs and Vice Chairs
                     Breakfast.
           7:30am    Estate Planning Software
                     Demonstration. Given the plethora of tax
                     planning software on the market, it is
                     difficult to know which programs are the
                     best fit for your tax practice. Estate planning
                     attorney and frequent lecturer, T. Randolph
                     Harris will lead us through the capabilities
                     and kinks of several of the most popular
                     comprehensive estate planning software
                     programs, such as BNA Estate Tax Planner,
                     Brentmark EPLAN, ViewPlan and others.
                     Learn which programs have adapted most
                     quickly to the changes resulting from
                     EGTRRA. Committee Vice Chair Paul Van
                     Horn will demonstrate the uses of ZCalc, an
                     add-in to Microsoft Excel. Speakers: T.
                     Randolph Harris, McLaughlin & Stern LLP,
                     New York, NY; Paul E. Van Horn, McLaughlin
                     & Stern LLP, New York, NY.

58
                                    JANUARY 25, 2003
                                 Program Schedule        ✯




                                                         Saturday
7:15am – 8:30am              Conf Rm 12, Level 3
Court Procedure Officers and Subcommittee Chairs
Breakfast (Invitation Only)

7:15am – 8:15am                 Conf Rm 10, Level 3
EMPLOYEE BENEFITS: SPECIAL DEFINED
BENEFIT PLAN ISSUES UPDATE, presented by
the Subcommittee on Special Defined Benefit
Plan Issues
Chair: Pamela C. Scott, Towers Perrin, Valhalla, NY
Roundtable discussion, led by Pamela C. Scott, of the
new proposed regulations under section 411(b), as well
as future guidance under section 411(d)(6) and other
matters affecting qualified defined benefit pension
plans. Time will be reserved to identify issues to be
submitted to government agencies for the annual
JCEB visits in May.

7:15am – 8:30am                      Salon A, Level 3
Partnerships and Real Estate “Shop Talking”
Breakfast A (Ticketed Event)
Members of the Real Estate and Partnerships
Committees will gather for the traditional “open mike”
breakfast to share ideas and war stories and to seek
input on technical issues.

7:30am – 8:30am                    Conf Rm 8, Level 3
Sarbanes-Oxley Task Force (Executive Session)
Chair: Stuart J. Offer, Morrison & Foerster LLP,
San Francisco, CA

8:00am – 11:30am                    Salon J, Level 3
Corporate Tax
Chair: William M. Richardson, Hunton & Williams,
Richmond, VA
8:00am    Opening Remarks.
8:05am    Recent Developments. Moderator: Rose
          L. Williams, Ernst & Young LLP,
          Washington, DC. Panelist: Jeffrey H.
          Paravano, Senior Advisor to the Assistant
          Secretary for Tax Policy, Department of
          Treasury, Washington, DC; William D.
          Alexander, Associate Chief Counsel
          (Corporate), IRS, Washington, DC.


                                                         59
JANUARY 25, 2003
✯ Program Schedule
Saturday


           8:40am    Selected Issues Involving Financially
                     Troubled Corporations. This panel will
                     focus on discharge of indebtedness income,
                     NOLs and other tax attributes, excess loss
                     accounts, and modifications and exchanges
                     of debt instruments. Moderator: Jasper L.
                     Cummings, Jr., Alston & Bird LLP, Raleigh,
                     NC. Panelists: William D. Alexander,
                     Associate Chief Counsel (Corporate), IRS,
                     Washington, DC; Milton B. Hyman, Irell &
                     Manella LLP, Los Angeles, CA; Carl M.
                     Jenks, Jones, Day, Reavis & Pogue,
                     Cleveland, OH; Joseph M. Pari, Dewey
                     Ballentine LLP, Washington, DC.
           10:10am Tax Opinion Practice—Reorganizations,
                   Spinoffs, and Other Transactions. This
                   panel will examine tax and other legal issues
                   faced by practitioners in preparing tax
                   opinions on reorganizations, spinoffs, and
                   certain other corporate transactions.
                   Moderator: Dana L. Trier, Davis Polk &
                   Wardwell, New York, NY. Panelists: Peter H.
                   Blessing, Shearman & Sterling, New York,
                   NY; Jasper L. Cummings, Jr., Alston & Bird
                   LLP, Raleigh, NC; Susan C. Philpott, Cooley
                   Goodward LLP, San Francisco, CA.

           8:30am – 11:30am                     Salon K, Level 3
           Civil and Criminal Tax Penalties
           Chair: Kathryn Keneally, Fulbright & Jaworski LLP,
           New York, NY
           8:30am    Opening Remarks. Reports of
                     Subcommittee Chairs: Attorney-Client and
                     Constitutional Privileges, Bradley Williams,
                     Ice Miller, Indianapolis, IN; Department of
                     Justice Procedures, Paul W. Raymond,
                     Newport Beach, CA; Important Develop-
                     ments—Civil, Charles Rettig, Hochman,
                     Salkin, Rettig, Toscher & Perez, PC, Beverly
                     Hills, CA; Important Developments—
                     Criminal, Josh O. Ungerman, Owens
                     Meadows et al., Dallas, TX; International Tax
                     Enforcement, Bruce Zagaris, Berliner
                     Corcoran et al., Washington, DC; IRS

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                                                            Saturday
          Investigations and Procedures, Terrence
          Grady, Schottenstein Zox & Dunn,
          Columbus, OH; Legislative and
          Administrative Developments, Michael D.
          Shepard, Blank Rome et al., Philadelphia,
          PA; Liaison to Standards of Tax Practice,
          Larry A. Campagna, Chamberlain Hrdlicka,
          Houston, TX; Monetary Violations and
          Forfeitures, Bryan C. Skarlatos, Kostelanetz
          & Fink, New York, NY; Sentencing
          Guidelines, Scott Fenstermaker, Slotnick,
          Shapiro & Crocker LLP, New York, NY.
9:30am    Sarbanes-Oxley for the Tax Practitioner.
          Part I of a two-hour panel discussion of how
          the Sarbanes-Oxley Act of 2002 impacts tax
          practice and tax controversy work. Part II will
          be presented at the meeting of the
          Committee on Standards of Tax Practice.
          The first hour’s panel will cover a general
          overview of the Sarbanes-Oxley Act; an
          analysis of the new criminal sanctions and
          penalty enhancements in the Act; new
          issues facing inside and outside counsel
          regarding tax and financial matters; and new
          regulations governing attorney conduct.
          Moderator: Larry A. Campagna;
          Chamberlain Hrdlicka, Houston, TX.
          Panelists: David F. Axelrod, Vorys, Sater,
          Seymour and Pease LLP, Columbus, OH;
          Mona L. Hymel, Associate Professor of Law,
          University of Arizona College of Law,
          Tucson, AZ; Mark S. Inzetta, Assistant
          General Counsel, Wendy’s International,
          Columbus, OH; Charles M. Meadows, Jr.,
          Meadows, Owens, Collier, Reed, Cousins &
          Blau, Dallas, TX; Quincy Ollison, Assistant
          US Attorney, Southern District of Texas,
          Houston, TX; Leslie S. Shapiro, Padgett
          Business Services, Washington, DC.
10:30am Document Retention and Destruction—
        the Lessons of Arthur Andersen.
        Overview of federal and state record
        retention requirements, discussion of record


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                     retention and destruction policies, civil and
                     criminal consequences of failure to keep or
                     destroying records, concluding with an
                     analysis of the lessons learned from the
                     Arthur Andersen trial. Moderator: Charles J.
                     Muller, III, Strasburger & Price LLP, San
                     Antonio, TX. Panelists: Rusty Hardin, Russell
                     Hardin, Jr. & Associates, PC, Houston, TX;
                     Gerald Goldstein, Goldstein, Goldstein &
                     Hilley, San Antonio, TX.

           8:30am – 11:30am                   Salon G, Level 3
           Employee Benefits
           Chair: Thomas R. Hoecker, Snell & Wilmer LLP,
           Phoenix, AZ
           8:30am    Opening Remarks by the Chair.
           8:40am    Ethics: The Emerging Role of Counsel in
                     Avoiding Executive Excess.           A panel
                     of experienced practitioners will examine
                     the potential exposure of attorneys who
                     assist employers in the design and
                     development of executive compensation
                     programs. The panel will address the impact
                     of Model Rule 1.13 (Organization as Client),
                     Sarbanes-Oxley and emerging common law
                     theories of liability. Moderator: Diane J.
                     Fuchs, Womble Carlyle Sandridge & Rice,
                     PLLC, Washington, DC. Panelists: Susan
                     Serota, Pillsbury Winthrop, New York, NY;
                     Joseph Cialone, Baker Botts, Houston, TX;
                     William Freivogel, Aon Risk Services, Inc.,
                     Chicago, IL.
           9:40am    Cash Balance Plans—Plan Design in
                     Light of the Proposed Regulations. The
                     panelists will explore the impact of
                     anticipated cash balance plan guidance on
                     plan design choices. Moderator: Taina E.
                     Edlund, Womble Carlyle Sandridge & Rice,
                     PLLC, Washington, DC. Panelists: Kyle N.
                     Brown, Watson Wyatt Worldwide,
                     Washington, DC; Michael Doran, Attorney-
                     Advisor, Benefits Tax Counsel, Department
                     of Treasury, Washington, DC; James E.
                     Holland, Manager, Actuarial Projects,
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                                                             Saturday
           Employee Plans, IRS, Washington, DC;
           Judith F. Mazo, The Segal Company,
           Washington, DC.
10:50am Managing Fiduciary Liability Through
        Plan Design. This panel will address the
        important question of who is responsible for
        investments in employer securities when the
        plan is silent. Other issues regarding the
        allocation of fiduciary responsibility also will
        be discussed. The focus will be on plan
        design. Moderator: James R. Raborn, Baker
        Botts LLP, Houston, TX. Panelists: Timothy
        D. Hauser, Associate Solicitor, Plan Benefits
        Security Division, Pension and Welfare
        Benefits Administration, Department of
        Labor, Washington, DC; Nell Hennessy, Aon
        Fiduciary Counselors, Inc., Washington, DC;
        Ronald S. Rizzo, Jones, Day, Reavis &
        Pogue, Chicago, IL.

8:30am – 11:30am                  Conf Rm 6, Level 3
Fiduciary Income Tax
Chair: Julia B. Fisher, JP Morgan Private Bank,
Philadelphia, PA
8:30am     Opening Remarks by the Chair.
8:35am     Recent Developments. Report on recent
           developments affecting the income taxation
           of trusts and estates. Speaker: Farhad
           Aghdami, Williams Mullen, Richmond, VA.
8:45am     Grantor Trust Update. This program will
           review recent developments relating to
           grantor trusts including the IRS’ position
           with respect to the transfer tax
           consequences associated with the grantor’s
           payment of the income tax liability
           attributable to the trust, recent attacks on
           transactions involving sales to grantor trusts,
           and other related issues. Moderator: A.
           Christopher Sega, Venable LLP, Washington,
           DC. Panelists: Melinda Merk, Ernst & Young
           LLP, Washington, DC; Jennifer Schooley
           Stringer, McGuireWoods LLP, Richmond, VA.


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           9:30am    Application of Cottage Savings to Trusts
                     —PLR 200231011. This program will
                     review PLR 200231011 and the application
                     of the Cottage Savings decision to the
                     conversion of an income interest to an
                     unitrust interest. The panel will review the
                     ruling and discuss its implications on the
                     proposed regulations under section 643.
                     Moderator: Farhad Aghdami, Williams
                     Mullen, Richmond, VA; Barbara A. Sloan,
                     McLaughlin & Stern LLP, New York, NY.
           10:00am Use of Hedge Funds in Offshore
                   Private Placement Life Insurance. This
                   program will review the use of hedge funds
                   in private placement variable life insurance
                   policies issued by non-US based insurance
                   carriers. Panelists: Leslie C. Giordani,
                   Giordani, Schurig, Beckett & Tackett LLP,
                   Austin, TX; John B. Lawson, Insurance
                   Distributors International (Bermuda), Ltd.,
                   Hamilton, Bermuda; Lawrence Brody, Bryan
                   Cave LLP, St. Louis, MO.

           8:30am – 11:30am                   Salon L, Level 3
           Foreign Lawyers Forum
           Chair: Ewout van Asbeck, NautaDutilh, Amsterdam,
           The Netherlands
           8:30am    Chairman Thomas Has His Cake and
                     Eats It, Too: What Government Giveth
                     to Domestic Tax Payers and Taketh
                     Away from Foreign Taxpayers. It has
                     been observed that legislation recently
                     proposed by House Ways and Means
                     Committee Chairman Thomas tightens
                     earnings stripping rules for foreign taxpayers
                     while simultaneously loosening the rules that
                     historically have made it unattractive for US
                     companies to earnings-strip out of foreign
                     jurisdictions. The panel will examine these
                     provisions, as well as other important recent
                     developments that appear to favor domestic
                     taxpayers, such as the Schneider case, which
                     invalidated French CFC rules as applied to the
                     earnings of a Swiss subsidiary. Moderator:

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                                                           Saturday
          Philip West, Steptoe & Johnson LLP,
          Washington, DC. Panelists: Janice Lucchesi,
          Akzo-Nobel, Chicago, IL; Michel Collet,
          Bureau Francis Lefebvre, New York, NY;
          Professor Karen Brown, George Washington
          University, Washington, DC; Jack Bernstein,
          Aird & Berlis LLP, Toronto, Canada.
9:30am    International M&A and Other Rulings:
          Necessary Certainty or Private Law?
          This panel will examine ruling practices in
          selected countries in the context of
          important recent developments. Expected
          areas of focus include the growing
          controversy over the standards for issuance
          of M&A rulings under section 367, recent
          reforms to Dutch ruling practice and the
          certainty attainable in other historically tax
          efficient jurisdictions. Moderator: Bernard T.
          Bress, PricewaterhouseCoopers LLP,
          Washington, DC. Panelists: Gary Wilcox,
          Deputy Chief Counsel – Technical, IRS,
          Washington, DC; Veronique Sway, Loyens &
          Loeff, New York, NY.
10:30am There is One US Export that Many
        Taxpayers Would Like to See Curbed:
        Anti-Arbitrage Tax Rules. This panel will
        examine recent developments in selected
        countries’ anti-arbitrage rules, noting that
        many had their genesis in the US. For
        example, the panel will address Germany’s
        recent attempt to impose dual consolidated
        loss rules and Dutch rules relating to hybrid
        instruments and rulings on hybrid entity
        structures. Recent US developments on this
        topic will be considered, including anti-
        arbitrage rules contained in tax treaties and
        how different standards apply to certain
        inbound and outbound structures.
        Moderator: Friedhelm Jacob, Hengeler
        Mueller, Frankfurt, Germany. Panelists: Edgar
        Brood, NautaDutilh, Rotterdam, The
        Netherlands; Michael Farber, Davis Polk &
        Wardwell, New York, NY.


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           8:30am – 10:30am                      Salon D, Level 3
           Low Income Taxpayers
           Chair: Professor Leslie Book, Villanova University School
           of Law, Villanova, PA
           8:30am     Opening Remarks by Chair and
                      Discussion of Committee Business.
           8:35am     Report on the National Taxpayer
                      Advocate’s Annual Report to Congress.
                      Speaker: Nina Olson, National Taxpayer
                      Advocate, IRS, Washington, DC.
           9:15am     Update on the Earned Income Credit.
                      The EIC has become one of the nation’s
                      most important federal transfer programs in
                      terms of its effects on reducing poverty and
                      providing work incentives. While partici-
                      pation rates are generally high, there are
                      continued challenges facing the IRS in
                      administering this program. This panel
                      will examine some of these challenges,
                      including taxpayer compliance problems. It
                      will also consider recent governmental
                      efforts to improve its administration of the
                      EIC. Moderator: Susan Morgenstern, Legal
                      Aid Society of Cleveland, Cleveland, OH.
                      Panelists: Jack Holstein, Project Manager,
                      W&I, IRS, Atlanta, GA; Susan Boehmer,
                      Project Manager, W&I, IRS, Atlanta, GA;
                      Mary Gillum, Legal Aid Society of Middle
                      Tennessee, Oak Ridge, TN.

           8:30am – 11:30am               Conf Rm 11, Level 3
           Sales, Exchanges & Basis
           Chair: Laurence E. Crouch, Shearman & Sterling,
           Menlo Park, CA
           8:30am     Opening Remarks by the Chair.
           8:45am     Current Developments. Panelists:
                      Laurence E. Crouch, Shearman & Sterling,
                      Menlo Park, CA; David Shechtman,
                      Montgomery, McCracken, Walker and
                      Rhoads LLP, Philadelphia PA.
           9:10am     Is Tax Structuring Still Possible? The IRS’
                      attempts to expand the scope of the
                      business purpose and economic substance
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                                                             Saturday
           doctrines to attack tax product transactions
           has created uncertainty to taxpayers and
           practitioners concerning the extent to which
           they can structure a transaction to achieve
           tax savings. The panel will focus on the
           limits of the business purpose and economic
           substance doctrines. Moderator: Virginia
           Stevenson, Sidley, Austin Brown & Wood
           LLP, Washington DC Panelists: Cary D. Pugh,
           Special Counsel to the Chief Counsel, IRS,
           Washington, DC; Mark H. Leeds, Managing
           Director, Deutsche Bank AG, New York, NY;
           Anthony J. Tuths, Sidley Austin Brown &
           Wood, New York, NY.
10:00am STRYPES, PEPS, DECS—Income
        Recognition and Other Issues. The panel
        will revisit constructive sale principles in light
        of the IRS’ attempt to apply pre-section 1259
        principles to variable forward contracts.
        Moderator: Paul L. B. McKenney, Raymond &
        Prokop, PC, Southfield, MI. Panelists: Michael
        B. Shulman, Shearman & Sterling,
        Washington DC; Michael S. Novey, Office of
        Tax Legislative Council, Office Of Tax Policy,
        Department of Treasury, Washington, DC.
10:50am State Tax Issues that Impact Section
        1031 Exchanges. The panel will discuss
        state tax issues that arise in section 1031
        exchanges, including identifying states that
        do not follow section 1031, addressing state
        transfer tax issues that arise in parking
        transactions, planning to avoid state sales
        tax in personal property exchanges, and
        avoiding state income tax in out-of-state
        parking transactions. Moderator: Bradley T.
        Borden, Oppenheimer, Blend, Harrison &
        Tate, Inc., San Antonio, TX. Panelists: Max A.
        Hansen, Reverse Exchange Services, Dillon,
        MT; J. Patrick Dowdall, Atlantic Exchange
        Company, LLC, Boston, MA.

8:30am – 11:30am                  Conf Rm 7, Level 3
Value Added Tax and Other Consumption Taxes
Chair: William H. Morris, General Electric Company,
Fairfield, CT
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           8:30am     Opening Remarks and Committee
                      Business by the Chair.
           9:00am     Ten Easy Ways to Lose 20 Percent of
                      Your Gross Revenues: Indirect Taxes. A
                      series of case studies demonstrating why
                      exporters and multinationals ignore VAT at
                      their peril. Speaker: Chris Needham, GE
                      Capital, Leeds, England.
           10:30am Review of Current Developments and
                   Regional Spotlight. Moderator: Jeffrey
                   Catanzaro, Smithtown, NY.

           8:30am – 11:30am       Conf Rms 17 & 18, Level 3
           VITA Training (Volunteer Income Taxpayer
           Assistance) (Complimentary Breakfast)
           The Section of Taxation strongly encourages all of its
           members to participate in the Volunteer Income Tax
           Assistance (VITA) program that provides free tax return
           preparation for low-income individuals. A team of IRS
           VITA trainers will lead the training session. You are
           urged to take this 3-hour training course and then,
           upon returning home, assist low income taxpayers
           meet their tax return filing obligations.

           9:00am – 11:00am             Conf Rm 12, Level 3
           Closely-Held Businesses Business Meeting

           9:00am – 12:00pm
           Companions Tour (Ticketed Event )
           Outlying Missions Tour (See page 7 for a
           description.)
           Buses will depart from the front entrance of the
           Marriott Rivercenter promptly at 9:00am.
           In the event of inclement weather, please check with
           the Section Registration Desk regarding the status of
           the tour.

           9:00am – 11:00am                Conf Rm 8, Level 3
           Judicial Deference Task Force (Executive Session)
           Chair: Irving Salem, Latham & Watkins, New York, NY

           9:00am – 10:30am                   Salon C, Level 3
           State and Local Taxes Practitioner’s Roundtable




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                                                           Saturday
9:30am – 11:30am                 Conf Rm 15, Level 3
Code Simplification Task Force (Executive Session)
Co-Chairs: David Glickman, Baker & McKenzie, Dallas,
TX; Terrill A. Hyde, Wilmer, Culter & Pickering,
Washington, DC

9:30am – 11:00am                   Conf Rm 12, Level 3
Special Projects
Chair: Frederic L. Ballard, Jr., Ballard Spahr Andrews &
Ingersoll LLP, Washington, DC
9:30am     Sarbanes-Oxley Update.

10:30am – 11:00am               Salon C, Level 3
State and Local Taxes Subcommittee: State and
Local Tax Lawyer

11:45am – 12:40pm           Salon E, Level 3
SECTION LUNCHEON (Ticketed Event)
     Award Presentation
     2002 Law Student Tax Challenge
     Announcement
     2003 - 2004 John S. Nolan Tax Law Fellows
     Remarks
     Speaker: Pamela F. Olson, Assistant Secretary (Tax
     Policy), Department of Treasury, Washington, DC
     Topic: Current and Upcoming Projects from the
     Office of Tax Policy


12:40pm – 1:45pm                     Salon E, Level 3
PLENARY SESSION
Herbert N. Beller, Section Chair, Presiding
Welcome to San Antonio
Stanley L. Blend, Host Committee Chair
Chair’s Report to the Section
Herbert N. Beller, Section Chair
Adoption of Consent Calendar
Report of Nominating Committee
Richard M. Lipton, Nominating Committee Chair




                                                           69
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           PANEL:
           International Tax Reform—Where Do We Go
           From Here? A
           Territoriality. Competitiveness. Deferral. Capital Export
           Neutrality. Capital Import Neutrality. Confused? This
           panel will explain those terms (and many others) that
           will pepper the emerging debate over the possible
           reform of the international tax provisions of the Code.
           This debate, long carried on in the deep recesses of
           academia and think tanks has now spilled over to the
           front pages of the New York Times and the Wall
           Street Journal. Sparked by the “corporate inversion”
           phenomena and potentially funded by the revenue
           effects of the imminent repeal of the “extra-territorial
           income” regime (compliments of the WTO), the
           prospects for significant reform in the international tax
           area are more real than they have been in decades.
           This panel, consisting of tax lawyers, economists and
           Capital Hill staffers, will analyze some of the alternative
           models for such reform in clear and concise fashion.
           This panel is an extremely useful primer for those tax
           lawyers who, while they might not practice in the
           international area, nevertheless want to understand the
           issues and stakes in the upcoming reform effort.
           Moderator: Leonard Schneidman, Foley Hoag LLP,
                      Boston, MA
           Panelists:   John L. Buckley, Democratic Chief Tax
                        Counsel, House Ways & Means
                        Committee, Washington, DC
                        Robert Culbertson, King & Spaulding,
                        Washington DC
                        James R. Hines, Jr., University of Michigan
                        Business School, Ann Arbor, MI
                        Edward McClellan, Republican Tax
                        Counsel, Senate Finance Committee,
                        Washington, DC
                        Stephen E. Shay, Ropes & Gray,
                        Boston, MA


           12:40pm – 1:45pm               Conf Rm 5, Level 3
           Resolutions
           Chair: Jere D.McGaffey, Foley & Lardner,
           Milwaulkee, WI


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                                                           Saturday
2:00pm – 5:00pm                Conf Rm 12, Level 3
Standards of Tax Practice
Chair: Donald P. Lan, Kroney Mincey, Inc., Dallas, TX
2:00pm    Opening Remarks by the Chair.
2:05pm    The Final (So Far) Circular 230
          Regulations. This panel will discuss the
          final Circular 230 regulations issued in the
          summer of 2002. Moderator: Michael B.
          Lang, Chapman University School of Law,
          Orange, CA. Panelists: Charlie Pulaski, Snell
          & Wilmer LLP, Phoenix, AZ; Richard S.
          Goldstein, IRS, Special Counsel to the
          Assistant Chief Counsel (Administrative
          Provisions and Judicial Practice),
          Washington, DC.
2:55pm    Ethical Considerations in Offers in
          Compromise. This panel will discuss ethical
          issues in preparing and filing offers in
          compromise, including the scope due
          diligence under Circular 230 and Rule 1.3 of
          the Model Rules of Professional Conduct.
          Moderator: Leslie S. Shapiro, Padgett
          Business Services Foundation, Washington,
          DC. Panelist: Donald P. Lan, Kroney Mincey,
          Inc., Dallas, TX.
3:40pm    Sarbanes-Oxley for the Tax
          Practitioner: Part Two. The concluding
          hour of a two-hour panel discussion of how
          the Sarbanes-Oxley Act of 2002 impacts tax
          practice. Part I will have been presented at
          the Committee on Civil and Criminal
          Penalties. The panel will discuss new rules
          relating to auditor independence; new
          whistleblower rules and regulations
          governing corporate and counsel
          responsibility; new relationships between
          outside counsel and public company boards
          of directors; new certification rules; and new
          rules governing loans and compensation to
          employees of public companies. Moderator:
          Larry A. Campagna, Chamberlain, Hrdlicka,
          White Williams, and Martin, Houston, TX.
          Panelists: David F. Axelrod, Vorys, Sater,

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Saturday


                     Seymour and Pease LLP, Columbus, OH;
                     Mona L. Hymel, Associate Professor of Law,
                     University of Arizona College of Law, Tucson,
                     AZ; Mark Inzetta, Assistant General Counsel,
                     Wendy’s International, Columbus, OH;
                     Charles M. Meadows, Jr., Meadows, Owens,
                     Collier, Reed, Cousins & Blau; Dallas, TX;
                     Quincy Ollison, Assistant US Attorney,
                     Southern District of Texas, Houston, TX;
                     Leslie S. Shapiro, Padgett Business Services,
                     Washington, DC.
           4:40pm    Annual Report on Important
                     Developments. Speaker: Stephen T. Black,
                     Syracuse University College of Law,
                     Syracuse, NY.

           2:00pm – 5:00pm            Conf Rms 17 & 18, Level 3
           VITA Training (Volunteer Income Taxpayer
           Assistance)
           The Section of Taxation strongly encourages all of its
           members to participate in the Volunteer Income Tax
           Assistance (VITA) program that provides free tax return
           preparation for low-income individuals. A team of IRS
           VITA trainers will lead the training session. You are
           urged to take this 3-hour training course and then,
           upon returning home, assist low income taxpayers
           meet their tax return filing obligations.




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                                                           Saturday
SECTION PROGRAMS
Saturday, January 25
2:00pm – 5:00pm                         Salon L, Level 3
Current Developments in Individual, Corporate,
Partnership and Estate & Gift Taxation
A review of the most significant judicial and admin-
istrative developments during the preceding year. The
panel will discuss income taxation developments as
well as estate and gift taxation developments.
Panelists: Professor Wendy C. Gerzog, University of
              Baltimore School of Law, Baltimore, MD
              Professor Martin J. McMahon, University of
              Florida, Fredric G. Levin College of Law,
              Gainesville, FL
              Professor Ira B. Shepard, University of
              Houston Law Center, Houston, TX
Sponsored by: Teaching Taxation Committee

2:00pm – 5:00pm                       Salon M, Level 3
Enhanced IRS Enforcement and the “Sensitive
Issue” Audit: Practical and Ethical Considerations
A
Practical and ethical considerations confronting a
representative involved in a sensitive issue “eggshell”
IRS audit. A distinguished panel will lead an open dis-
cussion on the potential impact of inappropriately
amending returns, voluntary disclosure practice
pitfalls, engagement of the Kovel accountant,
when/whether counsel should “surface” during the
audit, and other practical considerations that
frequently arise, together with a detailed overview of
enhanced IRS enforcement efforts and tools. (Ethics
credit requested for this program)
Moderator: Charles P. Rettig, Hochman, Salkin, Rettig,
              Toscher & Perez, PC, Beverly Hills, CA
Panelists: Scott Michel, Caplin & Drysdale,
              Chartered, Washington, DC
              Martin A. Schainbaum, Martin A.
              Schainbaum Professional Law Corporation,
              San Francisco, CA
              Bryan Skarlatos, Kostelanetz and Fink LLP,
              New York, NY
Sponsored by: Civil and Criminal Tax Penalties Committee
                                                           73
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           2:00pm – 4:00pm                      Salon B, Level 3
           In Light of Recent Circumstances – An Updated
           Look at What Benefits Lawyers Need to Know
           about Securities Laws
           The panel will engage in a lively discussion of the
           expanding influence of federal securities laws on
           employee benefits, including not only the basics,
           but also practical problems and hot issues brought
           on by the Sarbanes-Oxley Act and other “recent
           circumstances.”
           Moderator: Pamela Baker, Sonnenschein Nath &
                      Rosenthal, Chicago, IL
           Panelists:   Susan J. Daley, Altheimer & Gray,
                        Chicago, IL
                        George Ince, Davis Polk & Wardwell,
                        New York, NY
                        W. Alan Kailer, Jenkens & Gilchrist,
                        Dallas, TX
           Sponsored by: Employee Benefits Committee

           2:00pm – 4:00pm                         Salon C, Level 3
           Tax Planning for International Joint Ventures
           This program will explore the tax consequences in the
           US and in selected foreign countries that arise from
           international joint ventures. Topics covered include the
           US tax consequences of operations, transfers of
           property to the venture, withholding obligations of
           effectively connected income, sales of partnership
           interests, application of treaties to partnership revenue
           and comparisons to tax treatment under foreign law.
           Panelists:   Alan I. Appel , Bryan Cave LLP,
                        New York, NY
                        Peter Blessing, Shearman & Sterling,
                        New York, NY
                        Stanley C. Ruchelman, The Ruchelman Law
                        Firm, New York, NY
                        Mark van Casteren, Loyens & Loeff,
                        New York, NY
           Sponsored by: US Activities of Foreigners & Tax
           Treaties Committee




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                                                          Saturday
2:00pm – 4:00pm                        Salon K, Level 3
Capitalization of Intangibles
The program will focus on the proposed regulations
that will just recently have been issued by the
Department of Treasury and the IRS. The panel will
describe the rules and safe harbors contained in the
proposed regulations and discuss them from tax policy,
administrative and legal perspectives.
Moderator: Glenn Carrington, Deloitte & Touche LLP,
           Washington, DC
Panelists:   Jodi Cohen, Special Assistant to Assistant
             Secretary (Tax Policy), Department of
             Treasury, Washington, DC
             Kenneth Kempson, General Electric
             Company, Stamford, CT
             Pamela F. Olson, Assistant Secretary (Tax
             Policy), Department of Treasury,
             Washington, DC
             B. John Williams, Chief Counsel, IRS,
             Washington, DC
Sponsored by: Tax Accounting Committee




                                                          75
✯ Alpha Schedule
     ALPHA SCHEDULE
     The      symbol indicates that the program is
     being audio-taped by Teach’em. A A indicates
     that the program would appeal to young lawyers
     and a indicates that ethics has been requested
     for this program. All meetings will be held in the
     Marriott Rivercenter Hotel.
     Committee                     Day/Time                        Location

     Administrative Practice       Fri   8:30a-11:30a       Salon C, Level 3
      Cash Bar/Dinner              Th    6:30p-10:00p    Conf Rm 17, Level 3
       (Invitation Only)
      Joint Luncheon               Fri 12:30p-1:30p           Salon A, Level 3
       (Ticketed)
     Affiliated & Related          Fri   8:30a-11:30a     Conf Rm 12,Level 3
     Corporations
      Joint Luncheon (Ticketed)    Fri 12:00p-1:30p          Salon G, Level 3
     Agriculture                   Fri 2:30p-5:30p        Conf Rm 9, Level 3
      Luncheon (Ticketed)          Fri 12:30p-1:30p       Conf Rm 16,Level 3
     Appointments to the           Fri 11:30a-12:30p     Conf Rm 13, Level 3
     Tax Court (Executive Session)
     Banking and Savings           Fri   8:30a-11:30a      Conf Rm 5, Level 3
     Institutions
       Joint Luncheon              Fri 12:30p-2:00p        Conf Rm 5, Level 3
       (Ticketed)
     Bankruptcy Task Force         Fri   2:30p-5:30p     Conf Rm 18, Level 3
     Business Activities Nexus     Fri 11:00a-12:00p     Conf Rm 18, Level 3
     Task Force
     Capital Recovery &            Fri   7:00a-9:00a          Salon B, Level 3
     Leasing
     Civil and Criminal            Sat 8:30a-11:30a           Salon K, Level 3
     Tax Penalties
       Luncheon (Ticketed)         Fri 12:30p-1:30p          Salon M, Level 3
     Closely Held                  Fri   8:30a-11:30a      Conf Rm 7, Level 3
     Businesses    A
       Afternoon Program       A   Fri 2:15p-5:30p        Conf Rm 7, Level 3
       Business Meeting            Sat 9:00a-11:00a      Conf Rm 12, Level 3
     Committees                    Fri   9:00a-11:00a    Conf Rm 15, Level 3
     (Executive Session)
     Code Simplification          Sat 9:30a-11:30a               Conf Rm 15,
     Task Force (Executive Session)                                   Level 3
     Committee Chairs,             Fri   7:00a-8:15a          Salon I, Level 3
     Vice Chairs, Officers &
     Council Breakfast
     Companions Breakfast          Fri   8:00a-9:00a         JW’s Restaurant,
     (Complimentary)                                                  Level 2
     Companions Tours (Ticketed Events):
     Heart of San Antonio Art  Fri 9:00a-3:00p          Buses will depart from
     Tile Tour and Luncheon                              the front entrance of
     Outlying Missions         Sat 9:00a-12:00p           Marriott Rivercenter
76
Committee                      Day/Time
                                                    Alpha Schedule
                                                               Location
                                                                              ✯
Corporate Offshore           Fri     5:00p-7:30p             Conf Rm 15,
Inversions and Inter-                                             Level 3
national Tax Reform
Task Force (Executive Session)
Corporate Tax                  Sat 8:00a-11:30a           Salon J, Level 3
 Joint Luncheon (Ticketed)     Fri 12:00p-1:30p          Salon G, Level 3
Court Procedure &              Fri   2:00p-5:00p          Salon D, Level 3
Practice
  Joint Luncheon (Ticketed)    Fri 12:30p-1:30p           Salon A, Level 3
  Officers & Subcommittee
   Chairs Breakfast            Sat 7:15a-8:30a        Conf Rm 12, Level 3
   (Invitation Only)
Distinguished Service          NOT MEETING
Award
Diversity  A                   Fri   4:00p-5:30p    Conf Rms 1&2, Level 3
 Reception                     Fri   5:30p-6:30p    Conf Rms 3&4, Level 3
Domestic Relations             Fri   8:30a-11:30a         Salon L, Level 3
Employee Benefits              Fri 2:30p-6:30p          Salon G, Level 3
                               Sat 8:30a-11:30a         Salon G, Level 3
  Leadership Meeting/          Fri 11:00a-1:00p       Conf Rm 4, Level 3
  Luncheon (Invitation Only)
  New Members Outreach Fri           8:00a-8:45a     Conf Rm 16, Level 3
  Initiative A
Reception (Ticketed)         Fri     6:30p-8:00p           Salon I, Level 3


Employee Benefits Subcommittees and Task Force Update Programs:
COBRA and Welfare Plan       Fri     9:30a-12:00p      Conf Rm 1, Level 3
Design Issues; Welfare Plan
Legislation; State Insurance
Regulation of Welfare Plans;
and CafeteriaPlans and
Flexible Benefits
Corporate Counsel Forum        Fri 10:00a-11:00a      Conf Rm 16, Level 3
Distributions; QDROs,          Fri   9:30a-11:00a      Conf Rm 3, Level 3
QMSCOs, Other Domestic
Relations Benefits Issues;
and Estate & Gift Tax Issues
EEOC Issues                    NOT MEETING
Electronic Plan                Fri 11:00a-12:00p      Conf Rm 11, Level 3
Administration
Employee and Independent NOT MEETING
Contractor Status & Controlled
Groups, Affiliated Service
Groups & Leased Employees
EPCRS & Other              Fri       8:00a-10:00a     Conf Rm 10, Level 3
Administrative Practices
and Master, Prototype,
and Volume Submitter Plans
ESOPs                          Fri 11:00a-12:00p       Conf Rm 8, Level 3
Executive Compensation         Fri   8:00a-10:00a     Conf Rm 11, Level 3
and Federal Securities
Laws Issues
                                                                              77
✯ Alpha Schedule
     Committee                    Day/Time                       Location
     Fiduciary Responsibility;      Fri 12:30p-2:15p      Conf Rm 2, Level 3
     Litigation; Prohibited
     Transactions; and ESOPs
     Foreign & International Issues Fri 10:00a-11:00a    Conf Rm 14, Level 3
     Fringe Benefits                NOT MEETING
     Government Plans; §457         Fri   1:15p-2:15p    Conf Rm 11, Level 3
     Issues; and §403(b) &
     EO Issues
     IRAs                           Fri   1:15p-2:15p    Conf Rm 10, Level 3
     Mergers & Acquisitions         Fri 10:30a-12:00p     Conf Rm 2, Level 3
     Nondiscrimination &            Fri   1:15p-2:15p    Conf Rm 14, Level 3
     §415 Issues
     Qualified Cash or Deferred     Fri 12:30p-2:15p      Conf Rm 1, Level 3
     Arrangements
     Retiree Health, VEBAs &        Fri   9:00a-10:00a   Conf Rm 17, Level 3
     Other Funding Vehicles
     Special Defined Benefit        Sat 7:15a-8:15a      Conf Rm 10, Level 3
     Plan Issues


     Employment Taxes               Fri   1:30p-5:30p     Conf Rm 8, Level 3
      Practitioner’s Workshop       Fri   4:30p-5:30p     Conf Rm 8, Level 3
      (Not Taped)
     Energy & Environmental         NOT MEETING
     Taxes
     Estate & Gift Taxes            Fri 8:30a-11:30a        Salon A, Level 3
       Joint Luncheon (Ticketed)    Fri 12:30p-1:30p         Salon L, Level 3
       Young Lawyer                 Fri 1:30p-2:30p      Conf Rm 15, Level 3
        Subcommittee A
     Exempt Organizations           Fri 8:45a-4:00p          Salon E, Level 3
      Luncheon (Ticketed)           Fri 12:30p-1:30p         Salon E, Level 3


     Exempt Organizations Subcommittees:
     Health Care Organizations;     Fri   7:30a-8:30a     Conf Rm 1, Level 3
     State and Local Regulation;
     and Tax Exempt Financing
     Political & Lobbying           Fri   7:30a-8:30a     Conf Rm 2, Level 3
     Activities and Organizations
     Private Foundations;           Fri   7:30a-8:30a     Conf Rm 3, Level 3
     Unrelated Business Income
     Tax; and International
     Philanthropy
     Religious Organizations        Fri   7:30a-8:30a     Conf Rm 4, Level 3


     Fiduciary Income Tax           Sat 8:30a-11:30a      Conf Rm 6, Level 3
       Joint Luncheon (Ticketed)    Fri 12:30p-1:30p        Salon L, Level 3
     Financial Transactions         Fri 2:30p-5:30p         Salon K, Level 3
       Joint Luncheon (Ticketed)    Fri 12:30p-2:00p      Conf Rm 5, Level 3


78
Committee                       Day/Time
                                                      Alpha Schedule
                                                               Location
                                                                               ✯
Foreign Activities of US        Fri    8:30a-10:30a        Salon F, Level 3
Taxpayers
  Joint Luncheon (Ticketed)     Fri 12:30p-1:30p           Salon F, Level 3
  Joint Program                 Fri 10:30a-12:00p          Salon F, Level 3
  Business Meeting              Fri 5:00p-6:00p        Conf Rm 14, Level 3
  Dinner (Invitation Only)      Th 7:00p-10:00p              Charles Court
  Young Lawyer
  Subcommittee A                Fri    5:00p-5:30p     Conf Rm 11, Level 3
Foreign Lawyers Forum           Sat    8:30a-11:30a        Salon L, Level 3
 Joint Luncheon (Ticketed)      Fri   12:30p-1:30p         Salon F, Level 3
 Joint Program                  Fri   10:30a-12:00p        Salon F, Level 3
 Business Meeting               Fri    5:30p-6:30p     Conf Rm 16, Level 3
 Dinner (Invitation Only)       Th     7:00p-10:00p          Charles Court
Formation of Tax                Fri    2:00p-5:00p         Salon B, Level 3
Policy  A
Government Relations            NOT MEETING
Government Submissions          NOT MEETING
Individual Income Tax           NOT MEETING
Insurance Companies             NOT MEETING
IRS Guidance Task Force         Sat 7:00a-8:30a        Conf Rm 15, Level 3
Judicial Deference Task         Sat 9:00a-11:00a        Conf Rm 8, Level 3
Force (Executive Session)
Low Income Taxpayers            Sat 8:30a-10:30a           Salon D, Level 3
Membership & Marketing          Fri 11:30a-12:30p      Conf Rm 15, Level 3
Nominating                      Fri    2:00p-5:00p     Conf Rm 13, Level 3
(Executive Session)
Officers and Council        Th         8:30a-5:00p         Salon D, Level 3
Meeting (Executive Session)
Partnerships     A              Fri    8:30a-11:30a       Salon D, Level 3
 Joint Dinner                   Th     6:30p-9:30p                  Rio Rio
 Joint Breakfast (Ticketed) A   Sat    7:15a-8:30a        Salon A, Level 3
 Joint Luncheon (Ticketed)      Fri   12:30p-1:30p         Salon I, Level 3
 Task Force on Simpli-          Th     4:00p-6:00p      Conf Rm 5, Level 3
 fication of Subchapter K
 (Executive Session)
PLENARY SESSION          A      Sat 12:40p-1:45p           Salon E, Level 3
Panel: International Tax
Reform–Where Do We Go
From Here?
Pro Bono                        Sat 7:00a-8:30a        Conf Rm 16, Level 3
Professional Services           Fri    5:30p-6:30p     Conf Rm 10, Level 3
Programs & Meetings             Fri    5:00p-6:00p     Conf Rm 17, Level 3
Real Estate    A                Fri    2:30p-5:30p         Salon A, Level 3
 Joint Dinner                   Th     6:30p-9:30p                   Rio Rio
 Joint Breakfast (Ticketed)A    Sat    7:15a-8:30a         Salon A, Level 3
 Joint Luncheon (Ticketed)      Fri   12:30p-1:30p          Salon I, Level 3
Regulated Investment            Fri 10:00a-12:30p       Conf Rm 9, Level 3
Companies
 Joint Luncheon (Ticketed)      Fri 12:30p-2:00p        Conf Rm 5, Level 3


                                                                               79
✯ Alpha Schedule
     Committee                     Day/Time                        Location
     Resolutions                    Sat 12:40p-1:45p        Conf Rm 5, Level 3
     S Corporations                 Fri 1:00p-5:30p            Salon J, Level 3
       Luncheon (Ticketed)          Fri 12:00p-1:00p           Salon J, Level 3
     Sales, Exchanges and           Sat 8:30a-11:30a       Conf Rm 11, Level 3
     Basis
     Sarbanes-Oxley Task            Sat 7:30a-8:30a         Conf Rm 8, Level 3
     Force (Executive Session)
     Section Luncheon               Sat 11:45a-12:40p          Salon E, Level 3
     (Ticketed)
     Section Reception              Fri   6:30p-8:00p          Salon E, Level 3
     (Ticketed)
     Special Projects               Sat 9:30a-11:00a       Conf Rm 12, Level 3
     Standards of Tax               Sat 2:00p-5:00p        Conf Rm 12, Level 3
     Practice
     State and Local Taxes          Fri   2:30p-5:30p          Salon L, Level 3
       Cash Bar/Dinner              Th    6:30p-10:00p La Mansion del Rio Hotel
        (Invitation Only)
       Current State Tax            Fri   1:00p-1:30p          Salon K, Level 3
       Decisions
       Luncheon (Ticketed)          Fri 12:30p-1:00p           Salon K, Level 3
       Practitioners’ Roundtable    Sat 9:00a-10:30a           Salon C, Level 3
       State & Local Tax Lawyer     Sat 10:30a-11:00a          Salon C, Level 3
     Tax Accounting                 Fri   2:30p-5:30p          Salon M, Level 3
     Tax Exempt Financing           Fri 2:30p-5:30p        Conf Rm 12, Level 3
       Joint Luncheon (Ticketed)    Fri 12:30p-2:00p        Conf Rm 5, Level 3
     Tax Practice                   Sat 7:00a-8:30a            Salon M, Level 3
     Management
     Tax Shelters Task Force        Fri 10:30a-12:30p     Conf Rm 17, Level 3
     Teaching Taxation              Fri   7:00a-9:00a          Salon M, Level 3
     Transfer Pricing               Fri 3:30p-5:00p             Salon F, Level 3
       Joint Luncheon (Ticketed)    Fri 12:30p-1:30p            Salon F, Level 3
       Joint Program                Fri 10:30a-12:00p           Salon F, Level 3
       Dinner (Invitation Only)     Th 7:00p-10:00p              Charles Court
     US Activities of Foreigners    Fri   1:30p-3:30p           Salon F, Level 3
     & Tax Treaties
      Joint Luncheon (Ticketed)     Fri 12:30p-1:30p           Salon F, Level 3
      Joint Program                 Fri 10:30a-12:00p          Salon F, Level 3
      Business Meeting              Fri 5:30p-6:30p        Conf Rm 13, Level 3
      Dinner (Invitation Only)      Th 7:00p-10:00p              Charles Court
     VAT & Other Consumption Sat 8:30a-11:30a               Conf Rm 7, Level 3
     Taxes
     VITA Training                  Sat 8:30a-11:30a        Conf Rms 17&18,
                                    (Complimentary Breakfast)        Level 3
                                    Sat 2:00p-5:00p         Conf Rms 17&18,
                                                                     Level 3




80
Committee                 Day/Time
                                               Alpha Schedule
                                                         Location
                                                                        ✯
Young Lawyers Forum      AFri   4:00p-5:30p    Conf Rms 1&2, Level 3
  Reception               Fri   5:30p-6:30p    Conf Rms 3&4, Level 3
  2002 Law Student Tax
  Challenge A
  Semi-Final Competition  Fri   9:00a-12:00p      Conf Rm 6, Level 3
   (Not Open to Public)
  Final Competition       Fri   2:30p-4:00p       Conf Rm 6, Level 3
   (Open to Public)


SECTION PROGRAMS:
Capitalization of         Sat 2:00p-4:00p            Salon K, Level 3
Intangibles
Current Developments in   Sat 2:00p-5:00p            Salon L, Level 3
Individual,Corporate,
Partnership and Estate
& Gift Taxation
Enhanced IRS Enforce-     Sat 2:00p-5:00p           Salon M, Level 3
ment and the "Sensitive
Issue" Audit: Practical
and Ethical
Considerations     A
In Light of Recent       Sat 2:00p-4:00p             Salon B, Level 3
Circumstances - An
Updated Look at What
Benefits Lawyers Need
to Know about Securities
Laws
Tax Planning for          Sat 2:00p-4:00p            Salon C, Level 3
International Joint
Ventures




                                                                        81
✯ Affiliated Organizations
      AMERICAN COLLEGE OF TAX COUNSEL
      2003 ANNUAL MEETING OF FELLOWS
      Friday, January 24, 2003
      7:30am – 9:30am          Conf Rm 14, Level 3
      ACTC Board of Regents Meeting


      Saturday, January 25, 2003
      5:30pm – 7:00pm                     Salon D, Level 3
      Annual Business Meeting of Fellows
      Recognition of the Theodore Tannenwald, Jr.
      Foundation for Excellence in Tax Scholarship winner.

      2003 Griswold Lecture
      by Professor Joel B. Slemrod

      7:15pm
      Reception and Dinner
      Biga on the Banks
      203 St. Mary’s Street (International Center)


      Sunday, January 26, 2003
      7:30am – 8:30am                       Salon D, Level 3
      Continental Breakfast

      8:30am – 9:30am                  Salon D, Level 3
      Panel Discussion with Pamela F. Olson, Assistant
      Secretary (Tax Policy), Department of Treasury,
      Washington, DC




82
Sa
an Antonio Marriott Rivercenter Floor Plans   ✯




                                              84
FUTURE MEETINGS
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


Co-Sponsored Meetings
2003
US-European Tax Strategies for Multinationals
(Co-sponsored with IBA)
March 14, 2003, Paris, France
ABA 202-662-8670
Sales/Use Tax and Property Tax Seminars
(Co-sponsored with IPT)
March 31 – April 3, 2003, New Orleans, LA
ABA 202-662-8676
Low Income Tax Clinic Conference
(Co-sponsored with American University)
May 8, 2003 Washington, DC
ABA 202-662-8670
ERISA Basics
(Co-sponsored with JCEB)
June 4-6, 2003, Chicago, IL
JCEB 202-662-8641
Employee Benefits in Mergers & Acquisitions
(Co-sponsored with JCEB)
New York, NY
JCEB 202-662-8641
Check www.abanet.org/jceb for updates to the program.


Section of Taxation Meetings
2003                                  2004   (continued)
May Meeting                           Fall Meeting
May 8-10                              September 30-October 2
Grand Hyatt, Washington, DC           Sheraton, Boston, MA

Fall Meeting                          2005
September 11-13                       Midyear Meeting
(Co-sponsored with the Section Real
                                      January 20-22
Property, Probate and Trust Law)
                                      Manchester Grand Hyatt,
Sheraton Chicago, Chicago, IL         San Diego, CA
2004                                  May Meeting
Midyear Meeting                       May 19-21
January 29-31                         Grand Hyatt, Washington, DC
Gaylord Palms Hotel,
Kissimee, FL                          Fall Meeting
                                      September 15-17
May Meeting                           Park Hyatt & Hyatt Regency,
May 6-8                               San Francisco, CA
Grand Hyatt, Washington, DC
 SECTION OF TAXATION
 AMERICAN BAR ASSOCIATION
 740 15th Street, NW
 Washington, DC 20005
 (202) 662-8670




 Visit the Tax Section’s Website at
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 • News about upcoming Section Meetings
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