october 25–30, 2015

74 t h i n st i t u t e o nf e d e ra l taxat i o nA yeAr of insights And AnAlyses from AmericA’s top tAx Authorities

october 25–30, 2015grAnd hyAtt new yorkNew York, NY

november 15–20, 2015the fAirmont sAn frAncisco hotel SaN FraNciSco, ca

conference co-chairs

lewis r. steinberg, esq. Managing Director; Head of Structured Solutions, Americas Mergers & Acquisitions Group, Bank of America Merrill Lynch, New York, NY

Joseph m. pari, esq. National Principal-in-Charge Elect, KPMG LLP, Washington, DC

finAnce And lAw progrAms

2 | For more information, call (212) 992-3320. Register online at sps.nyu.edu/ift

74th institute on federAl tAxAtion OCTOBER 25–30, 2015 NEw YORk, NYNOvEmBER 15–20, 2015 SaN fRaNCiSCO, Ca

conference co-chAirs: lewis r. steinberg, esq., Managing Director; Head of Structured Solutions, Americas Mergers & Acquisitions Group, Bank of America Merrill Lynch, New York, NYJoseph m. pari, esq., National Principal-in-Charge Elect, KPMG LLP, Washington, DC

nyu school of professionAl studies dennis di lorenzo, bA, Harvey J. Stedman Dean

division of progrAms in businessscott stimpfel, mbA, edd, Associate Dean

depArtment of finAnce And lAw progrAms Julia n. miller, Jd, Directorkathleen costello, cmp, Assistant Director

leArning obJectivesThe Institute of Federal Taxation (IFT) is designed for the practitioner who must frequently anticipate and handle federal tax matters. Nationally recognized experts guide attendees through in-depth general sessions and panel discussions that cover the most advanced tax issues. They offer participants a clear understanding of the key issues affecting their clients or business and present planning ideas that can immediately be used in practice. Just as important, the Institute provides the perfect setting in which to meet practitioners from around the country. It’s an opportunity for you to share ideas, exchange views, learn what others are doing, and obtain credit for continuing education.

who should Attend?The Institute addresses all major areas of taxation and attracts attorneys, both general tax practitioners and specialists; accountants; corporate treasury and compliance executives; tax managers; and financial planners, seeking expert discussion of the latest technical, legislative, and planning developments.

http://www.sps.nyu.edu/ift

For more information, call (212) 992-3320. Register online at sps.nyu.edu/ift | 3

adviSorY Board

Jerald david August, esq., Kostelanetz & Fink, LLP, New York, NY

stephen m. breitstone, esq., Meltzer, Lippe, Goldstein & Breitstone, LLP, Mineola, NY & New York, NY

william g. cavanagh, esq., Chadbourne & Parke LLP, New York, NY

John J. clair, esq., Latham & Watkins LLP, Los Angeles, CA

terence floyd cuff, esq., Loeb & Loeb LLP, Los Angeles, CA

Julie A. divola, esq., Pillsbury Winthrop Shaw Pittman LLP, San Francisco, CA

elizabeth e. drigotas, esq., Deloitte Tax LLP, Washington, DC

Andrew J. dubroff, esq., Ernst & Young LLP, Washington, DC

phillip gall, esq., Ernst & Young LLP, New York, NY

John p. gimigliano, esq., KPMG LLP, Washington, DC

mary b. hevener, esq., Morgan, Lewis & Bockius LLP, Washington, DC

sidney kess, cpA, J.d., ll.m., Kostelanetz & Fink, LLP, New York, NY

stephen J. krass, esq., Krass, Snow & Schmutter, P.C., New York, NY

paul A. manuel, esq., PricewaterhouseCoopers LLP, New York, NY

pamela f. olson, esq., PricewaterhouseCoopers LLP, Washington, DC

Joseph m. pari, esq., KPMG LLP, Washington, DC

charles p. rettig, esq., Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, CA

stephen d. rose, esq., Munger, Tolles & Olson LLP, Los Angeles, CA

matthew A. rosen, esq., Skadden, Arps, Slate, Meagher & Flom LLP, New York, NY

blake d. rubin, esq., McDermott Will & Emery LLP, Washington, DC

sanford J. schlesinger, esq., Schlesinger Gannon & Lazetera LLP, New York, NY

Joseph p. scorese, esq., Harwood Lloyd, LLC, Hackensack, NJ

Abraham n.m. shashy, Jr., esq., King & Spalding LLP, Washington, DC

william b. sherman, esq., Holland & Knight LLP, Fort Lauderdale, FL

bryan c. skarlatos, esq., Kostelanetz & Fink, LLP, New York, NY

eric b. sloan, esq., Deloitte Tax LLP, New York, NY

matthew r. sontag, esq., cpA, AES Corporation, Arlington, VA

laurence J. stein, esq., Latham & Watkins LLP, Los Angeles, CA

lewis r. steinberg, esq., Bank of America Merrill Lynch, New York, NY

Andrea m. whiteway, esq., McDermott Will & Emery LLP, Washington, DC


sponsorsThe NYU School of Professional Studies thanks the following organizations for their contribution to the continued success of the Institute on Federal Taxation.

gold sponsors:

silver sponsors:

74th institute on federAl tAxAtion



topics At A glAncenyusps: keeping you current on federAl tAxAtion topicsThe NYU School of Professional Studies (NYUSPS) Institute on Federal Taxation brings together tax practitioners from around the country to ground themselves in new practices in federal taxation, exchange ideas, and stay on top of the latest tax trends and developments. Learn from America’s leading tax experts in the fields of finance, law, and government as they share their extensive knowledge on such topics as executive compensation and employee benefits, trusts and estates, ethics, partnerships and real estate, corporate taxes, and much more. Stay abreast of everything that’s going on in the industry by networking with hundreds of taxation professionals. As a premier educational institution, NYUSPS is committed to providing the highest standard of learning for our participants.

new york sAn frAncisco

current developments OcTOber 25 NOvember 15 John p. gimigliano, esq., Principal-in-Charge of Federal Tax Legislative and Regulatory Services, KPMG LLP, Washington, DC

tAx controversies OcTOber 25 NOvember 15charles p. rettig, esq., Principal, Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, CA

executive compensAtion And employee benefits OcTOber 25 NOvember 15 elizabeth e. drigotas, esq., Principal, Deloitte Tax LLP, Washington, DC

internAtionAl tAx OcTOber 26 NOvember 16 william b. sherman, esq., Partner, Holland & Knight LLP, Fort Lauderdale, FL

hot tAx topics OcTOber 26 NOvember 16 william g. cavanagh, esq., Partner, Chadbourne & Parke LLP, New York, NY

corporAte tAx OcTOber 27 NOvember 17 lewis r. steinberg, esq., Managing Director; Head of Structured Solutions, Americas Mergers & Acquisitions Group, Bank of America Merrill Lynch, New York, NY

stephen d. rose, esq., Partner, Munger, Tolles & Olson LLP, Los Angeles, CA

evening session: fundAmentAls of pArtnership And reAl estAte tAxAtion OcTOber 27 NOvember 17 blake d. rubin, esq., Partner, McDermott Will & Emery LLP, Washington, DC

pArtnerships, llcs, And reAl estAte OcTOber 28 NOvember 18 blake d. rubin, esq., Partner, McDermott Will & Emery LLP, Washington, DC

evening session: moving the reAl estAte empire to the next generAtion OcTOber 28 NOvember 18 stephen m. breitstone, esq., Partner, Meltzer, Lippe, Goldstein & Breitstone, LLP, Mineola, NY and New York, NY

closely–held businesses OcTOber 29 NOvember 19Jerald david August, esq., Partner, Kostelanetz & Fink, LLP, New York, NY

evening session: ethics OcTOber 29 NOvember 19 bryan c. skarlatos, esq., Partner, Kostelanetz & Fink, LLP, New York, NY

trusts And estAtes OcTOber 30 NOvember 20 sanford J. schlesinger, esq., Founding Partner, Schlesinger Gannon & Lazetera LLP, New York, NY

The NYU School of Professional Studies reserves the right to change, with or without notice, any statement in this brochure concerning, but not limited to rules, policies, tuition, fees, curriculum, courses, speakers, and programs.

ImPOrTANT NOTe: The city that a speaker is presenting in is indicated by NY for New York and by SF for San Francisco. When NY or SF does not appear, that speaker is presenting in both cities. NOTe: Start and end times, lunch recesses, and refreshment breaks vary from day to day, so please consult each day’s schedule for specifics.


october 25–30, 2015GrANd HYATT NeW YOrk

NeW YOrk, NY

november 15–20, 2015FAIrmONT SAN FrANcIScO HOTeL

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dAy 1: sundAy, oct. 25/nov. 15

10.30 a.m.continentAl breAkfAstFull-Week and Single-day registration and distribution of materials

10.45 a.m.welcoming remArks

current developments

chair: John p. gimigliano, esq., Principal-in-Charge of Federal Tax Legislative and Regulatory Services, KPMG LLP, Washington, DC

11 a.m.legislAtive updAteA review of legislation enacted, considered, and pending in the current congressional session.John p. gimigliano, esq., Principal-in-Charge of Federal Tax Legislative and Regulatory Services, KPMG LLP, Washington, DC

12.15 p.m.the treAsury AgendAA review of recently issued and pending Treasury guidance.thomas c. west, Jr., esq., Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the Treasury, Washington, DC

1.05 p.m.refreshment breAk

tAx controversies

chair: charles p. rettig, esq., Principal, Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, CA

1.15 p.m.from the experts: irs representAtion tools, techniQues And defensive strAtegies–civil & criminAl tAx updAteTips from the tax trenches from leading tax controversy practitioners in an open discussion regarding pending IrS enforcement priorities and initiatives, including the ongoing IrS Offshore voluntary disclosure Program/Streamlined Procedures re: FbArs and the Swiss bank Program, effectively responding to IrS information document requests in the new enforcement environment, hot topics and enforcement priorities within the IrS Small business and Self-employed Operating division and the IrS Large business & International division; IrS Appeals resolution strategies; criminal tax enforcement update (foreign and domestic voluntary disclosures), current developments in the United States Tax court and litigation alternatives; protecting privileged communications; penalty abatement considerations; and recent cases of significance.moderator: charles p. rettig, esq., Principal, Hochman, Salkin, Rettig, Toscher & Perez, P.C.,

Beverly Hills, CAny & sf: larry A. campagna, esq., Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry,

Houston, TXny: scott d. michel, esq., Member, Caplin & Drysdale, Chartered, Washington, DCsf: martin A. schainbaum, esq., Principal, Martin A. Schainbaum, P.L.C., San Francisco, CA





executive compensAtion & employee benefits

chair: elizabeth e. drigotas, esq., Principal, Deloitte Tax LLP, Washington, DC

4 p.m.updAte on section 409AIt’s been over 10 years since Section 409A was enacted, bringing with it significant changes in the rules applicable to nonqualified deferred compensation. The IrS and the Treasury have issued guidance and adopted correction programs, and practitioners and employers have gained experience working with the rules. As a result, many issues have been clarified, but there are points of uncertainty and errors still happen in practice. This session covers the current state of practice under Section 409A and solutions to common errors. It also covers developments related to the income inclusion regulations.Andrew c. liazos, esq., Partner, McDermott Will & Emery LLP, Boston, MA

5 p.m.compensAtion tAx in m&AFrom spin-offs to mergers of equals, from private equity acquisitions to cross-border transactions, in today’s world of shareholder activism and litigation, corporate boards should be fully apprised of the compensation tax implications of some of the most basic decisions to be made in a corporate transaction. This session reviews the various compensation tax rules that apply in each such transaction, with an emphasis on the different considerations that arise in public vs. private m&A.Andrea k. wahlquist, esq., Partner, Wachtell, Lipton, Rosen & Katz, New York, NY

6 p.m.deductions: timing And plAnningThis session covers the deduction timing rules applicable to different types of compensation, including current compensation, qualified and nonqualified deferred compensation, equity compensation, and fringe benefits. The discussion covers differences between current and deferred compensation, timing of bonus deductions, and situations in which the rules are unclear or potentially conflicted. It also addresses when changes in deduction timing implicate the change in accounting method rules.elizabeth e. drigotas, esq., Principal, Deloitte Tax LLP, Washington, DC

7 p.m.recess



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dAy 2: mondAy, oct. 26/nov. 16

8 a.m.continentAl breAkfAstSingle-day registration and distribution of materials

8.25 a.m.introductory remArks

internAtionAl tAx

chair: william b. sherman, esq., Partner, Holland & Knight LLP, Fort Lauderdale, FL

8.30 a.m.internAtionAl Aspects of mergers And AcQuisitions for compAnieslArge And smAllWith increasing globalization, companies large and small are engaging in cross-border mergers and acquisitions as a means to grow and expand their businesses. This session focuses on how the U.S. tax rules apply to these transactions for companies of varying sizes, public and private, both in the context of foreign acquirors of U.S. businesses and U.S. acquirors of foreign businesses. Particular attention is paid to the developments affecting the U.S. anti-inversion rulesny & sf: sam k. kaywood, esq., Partner, Alston & Bird LLP, Atlanta, GAny: william s. dixon, esq., Managing Director, Mergers and Acquisitions,

Citigroup Global Markets Inc., New York, NYsf: lewis r. steinberg, esq., Managing Director; Head of Structured Solutions,

Americas Mergers & Acquisitions Group, Bank of America Merrill Lynch, New York, NY

10 a.m.refreshment breAk

10.10 a.m.the u.s. tAx conseQuences of A foreign person hAving Anemployee or Agent in the u.s.This session discusses the fundamentals of U.S. taxation applicable to a foreign person having an employee or an agent in the U.S., including the concepts of engagement in a U.S. trade or business; effectively connected income; and permanent establishments.william b. sherman, esq., Partner, Holland & Knight LLP, Fort Lauderdale, FLleonard schneidman, esq., Managing Director, Andersen Tax LLC, Boston, MAAlan i. Appel, esq., Professor of Law, New York Law School, New York, NY

12 p.m.lunch recess

1.15 p.m.the current stAte of u.s. internAtionAl tAx compliAnceU.S. taxpayers and practitioners are facing an increasing bevy of tax reporting and disclosure obligations relating to international investments and activities. This session addresses these compliance burdens and the penalties for failing to properly adhere to the requirements. In addition, the various programs for offshore voluntary disclosure are reviewed.kevin e. packman, esq., Partner, Holland & Knight LLP, Miami, FLhenry p. Alden ii, mst, cpA, pfs, Partner, Everest Ito Group, LLP, Annapolis, MD




hot tAx topics

chair: william g. cavanagh, esq., Partner, Chadbourne & Parke LLP, New York, NY

2.45 p.m.hot tAx topicsA fast-paced survey of important but lesser-publicized hot federal and state tax planning and tax litigation issues including: mergers and acquisition issues; state corporate income and sales tax nexus; income, deduction and capitalization issues; tax-exempt organizations; foreign tax issues; and tax controversy strategy tips.william g. cavanagh, esq., Partner, Chadbourne & Parke LLP, New York, NY

5 p.m.recess

networking reception

5 p.m.It’s never been more valuable or vital to connect with colleagues at the Institute’s annual reception. Please be our guest for cocktails and hors d’oeuvres, and take the opportunity to meet and greet our distinguished speakers, sponsors, and advisory board members. Also, enjoy this time to meet and network with fellow tax professionals from around the country.



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dAy 3: tuesdAy, oct. 27/nov. 17



corporAte tAx

co-chairs: lewis r. steinberg, esq., Managing Director; Head of Structured Solutions, Americas Mergers & Acquisitions Group, Bank of America Merrill Lynch, New York, NY stephen d. rose, esq., Partner, Munger, Tolles & Olson LLP, Los Angeles, CA

8.30 a.m.mergers And AcQuisitions involving s corporAtionscontrary to popular belief, S corporations still exist, often as decades-old, closely-held family enterprises that will someday be sold. And when an S corp is sold, the deal can present complex and sometimes unexpected tax issues. This session explores the anatomy of an S corp acquisition, including structuring techniques, diligence approaches, indemnity considerations, and post-closing audit issues.lauren Angelilli, esq., Partner, Cravath, Swaine & Moore LLP, New York, NYsamuel t. greenberg, esq., Associate, Munger, Tolles & Olson LLP, Los Angeles, CA




10 a.m.refreshment breAk

10.15 a.m.hot corporAte deAlsThis program discusses several interesting and high profile recent public deals. The presentation focuses on the structural and commercial features of each transaction and analyzes its tax treatment, with a particular emphasis on novel tax issues.ny: deborah l. paul, esq., Partner, Wachtell, Lipton, Rosen & Katz, New York, NYsf: rachel d. kleinberg, esq., Partner, Davis Polk & Wardwell LLP, Menlo Park, CA

11.45 a.m.lunch recess

1 p.m.choice of business entity revisited – opportunities And chAllengesThis presentation considers the various advantages and disadvantages of LLcs taxed as partnerships, disregarded entities, S corporations, and c corporations in a variety of real-world situations, and describes factors that should be considered in entity formations and acquisitions. While in many cases the optimal business entity will be an LLc, there are important situations where an S corporation or c corporation may be advantageous.david m. rievman, esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP, New York, NY


3 p.m.hot corporAte tAx topicsThis panel discusses recent legislative, regulatory, and judicial developments in corporate tax. The speakers focus on topics that present planning opportunities, as well as those that may be traps for the unwary.ny & sf: eric solomon, esq., National Tax Co-Director, Ernst & Young LLP, Washington, DCny: Joseph m. pari, esq., National Principal-in-Charge Elect, KPMG LLP, Washington, DC

gregory n. kidder, esq., Partner, Steptoe & Johnson LLP, Washington, DCsf: Alexander m. lee, esq., Partner, Paul Hastings LLP, Los Angeles, CA

laurence J. stein, esq., Partner, Latham & Watkins LLP, Los Angeles, CA

5 p.m.recess

5.15-6.55 p.m.

evening session:fundAmentAls of pArtnership And reAl estAte tAxAtionThis session provides useful background that is helpful for attendees who do not have extensive experience in the taxation of partnerships and real estate.blake d. rubin, esq., Partner, McDermott Will & Emery LLP, Washington, DC



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dAy 4: wednesdAy, oct. 28/nov. 18



pArtnerships, llcs, And reAl estAte

chair: blake d. rubin, esq., Partner, McDermott Will & Emery LLP, Washington, DC

8.30 a.m.hot topics in pArtnership And reAl estAte tAxAtion:the government perspectiveAn overview of recent and pending developments in partnership and real estate taxation from the government perspective. An opportunity to hear, first-hand, the views of two key government officials about what’s important, why it’s important, and what the government is doing about it.craig gerson, esq., Attorney-Advisor, U.S. Department of the Treasury, Washington, DCcurtis g. wilson, esq., Associate Chief Counsel (Passthroughs & Special Industries),Internal Revenue Service, Washington, DCblake d. rubin, esq., Partner, McDermott Will & Emery LLP, Washington, DC

9.15 a.m.recent developmentsThe Top-10 recent developments affecting partnership and real estate transactions. An up-to-the minute discussion from one of the nation’s leading practitioners.blake d. rubin, esq., Partner, McDermott Will & Emery LLP, Washington, DC

10.15 a.m.refreshment breAk

10.30 a.m.structuring foreign investment in u.s. reAl estAteSubstantial foreign capital is flowing into U.S. commercial real estate, with continuing year-over-year increases expected. Understanding the FIrPTA rules; structuring foreign investment in U.S. real estate through partnerships, corporations, and reITs; minimizing taxes and maximizing flexibility on exit.Alan i. Appel, esq., Professor of Law, New York Law School, New York, NYAmeek Ashok ponda, esq., Partner, Sullivan & Worcester LLP, Boston, MA

11.30 a.m.mAximiZing cApitAl gAins in reAl estAte trAnsActionsA recovering economy and rising real estate prices require renewed focus on capital gains issues, with an emphasis on practical planning. rates, holding periods, and netting rules, including the 25% rate for straight line real estate depreciation recapture; converting high rate gain into low rate gain and low rate losses into high rate losses; developing without dealing; land development and condo conversions.bradley t. borden, esq., cpA, Professor of Law, Brooklyn Law School, New York, NYJames m. lowy, esq., Consultant, EY LLP, Mill Valley, CA




12.30 p.m.lunch recess

1.45 p.m.beyond like-kind exchAnges: creAtive AlternAtives to tAxAble sAlesAs the market improves and transaction volume increases, so does the focus on creative deal structures. For owners seeking to dispose of real estate, structuring the disposition in the most tax-efficient manner is of paramount importance. For acquirors of real estate, bringing a tax-advantaged deal structure to the table can be the secret weapon that clinches the deal in a competitive market. An up-to-the minute discussion including the use of leveraged partnerships and other creative deal structuresAndrea m. whiteway, esq., Partner, McDermott Will & Emery LLP, Washington, DCJon g. finkelstein, esq., Partner, McDermott Will & Emery LLP, Washington, DC

3 p.m.tefrA pArtnership Audit procedures primereven practitioners who do not focus primarily on tax controversy or litigation need to have a basic understanding of the TeFrA unified partnership audit rules. Partnership, nonpartnership, and affected items; consistency requirement; role of the tax matters partner; statute of limitations issues; and practical tips for handling partnership tax audits.miriam l. fisher, esq., Partner, Latham & Watkins LLP, Washington, DC




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4 p.m.hot like-kind exchAnge issuesrelated party exchanges; build-to-suits, reverse exchanges and parking arrangements within and outside the safe harbor; exchanges involving partnerships and trusts; exchanges of property into and out of foreclosure; recent developments on what constitutes “like-kind”; and other current issues including legislative outlook.ny: robert d. schachat, esq., Principal, EY LLP, Washington, DCsf: Adam m. handler, esq., Principal, PricewaterhouseCoopers LLP, Los Angeles, CA

5 p.m.recess

5.15-6.55 p.m.

evening session:moving the reAl estAte empire to the next generAtion – bAlAncing income tAxes And trAnsfer tAxesmoving the private real estate empire to the next generation poses many challenges. Planning must take into consideration proposals of the Obama Administration; significantly elevated income tax rates and reduced transfer tax rates. Increasing exemptions complicate the process of striking a balance between transfer tax planning and obtaining the maximum step-up in income tax basis. This program takes a fresh look at the planning opportunities and challenges, and explores planning techniques that are responsive to the changing environment.ny & sf: stephen m. breitstone, esq., Partner, Meltzer, Lippe, Goldstein & Breitstone, LLP,

Mineola, NY and New York, NYny: david c. Jacobson, esq., Counsel, Meltzer, Lippe, Goldstein & Breitstone, LLP,

Mineola, NY




dAy 5: thursdAy, oct. 29/nov. 19



closely-held businesses

chair: Jerald david August, esq., Partner, Kostelanetz & Fink, LLP, New York, NY

8.30 a.m.pArtnership issues relAted to mArriAge And divorcemr. cuff discusses tax aspects of (i) partnerships and limited liability companies between married and unmarried spouses, (ii) transfers of partnerships between spouses during marriage, (iii) partnerships on divorce, (iv) transfers of partnership interests on divorce, and (v) partnership interests after divorce.terence f. cuff, esq., Of Counsel, Loeb & Loeb LLP, Los Angeles, CA


10 a.m.the complete AnAtomy of A Q sub election – not Just the nuts And boltsdiscussion focuses on the taxation of Qualified Subchapter S Subsidiaries, including a review of the history, qualification requirements, the election, termination, planning opportunities, and traps that exist for the unwary.larry J. brant, esq., Shareholder, Garvey Schubert Barer, Portland, OR

11 a.m.trAnsfers of property to And distributions And redemptions of stock in closely-held corporAtionsStructuring taxable and nontaxable transfers of property to closely-held c and S corporations, shareholder and corporation basis, holding period in transferred property, tax treatment of distributions from c corporations, including qualified dividend treatment, actual versus constructive distributions, general distribution rules for S corporations with and without earnings and profits, treatment on redemptions of stock qualifying for dividend versus capital gains treatment, adjustments to basis, special elections for closing of the books, bypassing AAA, effect on single class of stock requirement, qualified stock dispositions under Section 336(e).c. wells hall, iii, esq., Partner, Nelson Mullins Riley & Scarborough LLP, Charlotte, NC

12.15 p.m.lunch recess

1.30 p.m.tAx provisions in AcQuisition Agreements: tips, trAps, & usuAl suspectsThis presentation discusses tax issues raised in the provisions of acquisition agreements, including the working capital adjustment, purchase price allocation, representations, pre- and post-closing covenants (e.g., tax audits & litigation), and indemnification provisions. emphasis is placed on the typical issues that arise in negotiating the acquisition agreement and their practical resolution. robert w. phillpott, esq., Partner, Norton Rose Fulbright US LLP, Houston, TX stephen A. kuntz, esq., Partner, Norton Rose Fulbright US LLP, Houston, TX



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2.45 p.m.tAx reporting for cross-border trAnsActions—forms, penAlties, stAtute of limitAtions, possible defensesA discussion of the international tax reporting requirements relevant to U.S. persons engaged in cross-border transactions. Foreign information returns to be discussed include Forms 926, 5471, 5472, 8858, 8865, 8621, 8938, and FinceN Form 114 (FbAr). The discussion focuses upon proper execution of the Forms, potential penalties for noncompliance, statute of limitations issues, and possible defenses to penalty imposition.mark c. peltz, esq., Principal, WeiserMazars LLP, New York, NY Jennifer l. sklar-romano, esq., Tax Director, WeiserMazars LLP, New York, NY

3.45 p.m.tAx plAnning for s corporAtions: mergers And AcQuisitions involving s corporAtionsThe discussion focuses on sales of assets, stock sales, and stock sales involving qualified stock purchase acquisitions, including the application of Section 336(e), allocation of consideration, taxable income or loss in year of acquisition, tax treatment of holdbacks, escrows and contingent purchase price and tax-free reorganizations involving S corporations.Jerald david August, esq., Partner, Kostelanetz & Fink, LLP, New York, NY stephen r. looney, esq., Shareholder, Dean, Mead, Egerton, Bloodworth, Capouano& Bozarth, P.A., Orlando, FL

5 p.m.recess

5.15-6.55 p.m.

evening session:ethicAl issues for tAx prActitioners: good tAx plAnning, Aggressive tAx Advice or criminAl tAx evAsionTax practitioners are governed by a host of rules and regulations, from circular 230, to Irc 6694, to the Statements on Standards for Tax Services, to the criminal provisions of the Internal revenue code. The real question is how these standards apply in everyday practice. How sure do you have to be before you can tell a client it is okay to take a deduction or report income as capital gain? do you have to audit a client’s records, or can you just rely on what the client tells you? What do you do when a client tells you she has not been reporting income or foreign assets? This panel of expert practitioners addresses these and other thorny ethical issues that arise in everyday tax practice through the use of real-world hypothetical examples.chair: bryan c. skarlatos, esq., Partner, Kostelanetz & Fink, LLP, New York, NYny: karen l. hawkins, esq., Former Director, Internal Revenue Service Office of Professional

Responsibility, Washington, DC christopher s. rizek, esq., Member, Caplin & Drysdale, Chartered, Washington, DC

sf: michael J. desmond, esq., The Law Offices of Michael J. Desmond, APC, Santa Barbara, CA gersham goldstein, esq., Stoel Rives LLP, Portland, OR




dAy 6: fridAy, oct. 30/nov. 20



trusts & estAtes

chair: sanford J. schlesinger, esq., Founding Partner, Schlesinger Gannon & Lazetera LLP, New York, NY

8.30 a.m.recent developments in estAte plAnning And federAl trAnsfer tAxAtionThe speaker discusses three years’ experience with the transfer tax provisions of the American Taxpayer relief Act of 2012. The speaker also reviews the Obama Administration’s current transfer tax and related income tax proposals, and how they would affect estate planning decisions if enacted. The session also includes a discussion of recent state transfer tax developments, and recent IrS developments regarding various aspects of estates and trusts.sanford J. schlesinger, esq., Founding Partner, Schlesinger Gannon & Lazetera LLP, New York, NY

9.30 a.m.evAluAtion of the different forms of life insurAnce policies, their complexities And how they Are vAluedThis session reviews the different types of life insurance policies and the premium structure for each of them. The speaker also discusses the circumstances in which the use of each type of policy may be preferable, and estate planning techniques involving the use of life insurance. The session also includes a discussion as to how each type of policy is valued for tax purposes.donald o. Jansen, esq., Senior Tax Counsel, The University of Texas System, Austin, TX


10.45 a.m.trAnsfer tAx vs. income tAx bAsis issuesNow that the 40% estate tax rate and the highest income tax rates (after state income tax rates are considered) are about the same, the current concern is whether appreciated assets should be included in the decedent’s estate to obtain a “stepped-up” basis at death for income tax purposes. This presentation first compares the income tax savings to the estate tax cost by including different kinds of appreciated assets in the decedent’s estate, what assets are better suited for estate tax inclusion, and what assets should be shifted to the next generation without estate tax inclusion. The presenter then evaluates the techniques for ensuring estate tax inclusion or exclusion, including what can be done near death and well in advance to provide the needed flexibility to obtain the favorable “stepped-up” basis at death.Jerome m. hesch, esq., Adjunct Professor of Law, University of Miami School of Law, Miami, FL

12 p.m.lunch recess



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1.15 p.m.grAntor trusts – A burden or A benefitA detailed review of the income tax grantor trust rules, how and in what circumstances these rules operate, and how these rules may affect estate tax includability. The session also includes a discussion of using the grantor trust rules as a “sword,” rather than as a “shield,” to achieve transfer tax savings, and other estate planning techniques involving the use of grantor trusts. marco svagna, cpA, Partner, Berdon LLP, New York, NY


2.30 p.m.portAbility – love it or leAve itThe speaker discusses all aspects of portability, including the rules regarding its election and use, whether or not portability replaces traditional credit shelter trust planning, and how portability factors into the preparation of prenuptial agreements.stephanie e. heilborn, esq., Partner, Norton Rose Fulbright US LLP, New York, NY

3.30 p.m.

the Arthur d. sederbAum memoriAl lecturefAmily limited pArtnerships And sophisticAted plAnning techniQues in the current environmentThe panelists analyze the significant new cases regarding family limited partnerships and provide guidance for creating, implementing, and preserving the successful FLP. They also review strategies for handling audits and appeals of FLP issues, and other valuation issues, including formula clauses, built-in capital gains, and tax affecting S corporations. The panelists also discuss other sophisticated planning techniques that may be useful as an alternative to or in addition to FLPs.ny & sf: sanford J. schlesinger, esq., Founding Partner, Schlesinger Gannon & Lazetera LLP,

New York, NY Jerome m. hesch, esq., Adjunct Professor of Law, University of Miami School of Law, Miami, FL

ny: John w. porter, esq., Partner, Baker Botts L.L.P., Houston, TXsf: keri d. brown, esq., Senior Associate, Baker Botts L.L.P., Houston, TX

4.35 p.m.recess




generAl informAtion

full-week conference fees And discountsThe full-week conference fee includes tuition, continental breakfast, networking reception on monday evening, refreshment breaks, and one set of course materials on a USb flash drive. A full-week individual registration is $2,120 for all six days. If you register before October 2, you will qualify for the 15% early-bird, full-week registration discount ($1,802). If two or more individuals register from the same firm at the same time, each person qualifies for the 20% full-week team discount ($1,696 each). If you are a full-time government official or a full-time university professor, you receive a 15% discount off a full-week registration ($1,802). If you are a solo practitioner, work for a firm with fewer than five professionals, or work for a nonprofit organization, you receive a 15% discount off a full-week registration ($1,802). Note: Promotion and discount codes, as well as team discounts, must be applied at the time of registration. Discounts cannot be applied retroactively to existing registrations, or combined with any other offers.

You may register online, by mail, or on-site at the conference. We do not accept faxed registrations or wire transfers as a form of payment. Full and partial waivers of the conference fee, based upon financial need are available as well. To request an application, please call (212) 992-3320 or e-mail your request to [email protected]. Invited speakers are pre-registered. To register online for the 20% full-week team discount, please call (212) 992-3320 or e-mail [email protected] for a special discount code. To qualify, the team must be from the same firm and must register together. each team member must register. Team discounts must be applied at the time of registration. discounts cannot be applied retroactively to existing registrations, or combined with any other offers.

After october 2, to register online for the 15% full-week full-time government official, full-time university professor, solo practitioner, nonprofit, or small firm discount, please call (212) 992-3320 or e-mail [email protected] for a special discount code.

To register by mail, complete the registration form and return it with a check or money order made payable to New York University. All registrations sent by mail must be received by 12 p.m. on Tuesday, October 20, 2015 (eastern Standard Time) for New York and by 12 p.m. on Tuesday, November 10, 2015 (eastern Standard Time) for california.

To register on-site, you may pay with a check, a money order, or a credit card. To pay by credit card, all walk-ins will be required to self-register at available kiosks. For faster service, conference attendees should plan to register in advance online at sps.nyu.edu/ift To register on-site, visit the NYU registration desk at the Institute beginning at 10.30 a.m. on Sunday or 8 a.m. monday-Friday.

single-dAy registrAtion feeThe single-day conference fee of $595 includes tuition for one day of sessions, an evening session (if applicable) for the selected day, continental breakfast, refreshment breaks, and one set of course materials on a USb flash drive for the day of attendance.

multi-dAy registrAtion feesThe 2-day, 3-day, 4-day, and 5-day conference fees include tuition for sessions on the days selected, evening sessions (if applicable) for the selected days, continental breakfast, refreshment breaks, and one set of course materials on a USb flash drive for the days of attendance. the 2-day fee is $1,075; 3-day is $1,395; 4-day is $1,650; and 5-day is $1,775.

hAlf-dAy registrAtion feeThe half-day conference fee of $350 includes tuition for a half-day of sessions, refreshment breaks, and one set of course materials on a USb flash drive for the half-day of attendance.

evening session registrAtion feeThe evening session conference fee of $125 includes tuition for one evening session on Tuesday, Wednesday, or Thursday evening and a set of the written materials for the evening session. evening session registration is included in the purchase of a daytime registration, as described above.

corporAte group discountsWe recognize that your organization may not be able to afford the time and the expense of sending all of its employees to the 74th IFT for the entire week. To accommodate those organizations that wish to send large groups to attend a sampling of sessions, we offer a special corporate Group rate for five or more attendees. Please take advantage of this option. remember, shared registrations are not permitted (i.e. you may not register a firm or a single member of a firm and pass along a single badge). Only registered attendees are eligible to receive continuing education credits. We want all of our attendees to benefit from a simple and efficient registration process. For more details, please call kathleen costello at (212) 992-3320 or e-mail [email protected].



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mailto:[email protected]






press bAdgesIf your publication plans to cover the NYU 74th Institute on Federal Taxation, please e-mail coverage strategy and press credentials to [email protected].

electronic confirmAtionAn automated e-mail confirmation will be sent to the e-mail address provided to NYUSPS at the time of registration. Please use an individual e-mail address for each registrant. If a confirmation is not received within two days of online registration submission (allow one–two weeks for registrations sent by mail), please e-mail [email protected] to request a duplicate copy. Note: confirmations may display the start and the end dates of the eNTIre Institute; please check the conference agenda for individual dates and times.

cAncellAtion And substitution policyA written request for cancellation must be e-mailed to [email protected] to the attention of: conference Administration. If your request is received by october 9 for New York or by october 30 for San diego, you will receive a 100% tuition refund less a $250 cancellation fee. due to financial obligations incurred by NYUSPS, there are no refunds available during the two weeks prior to the conference. We are not able to arrange cancellation exceptions or to accept on-site cancellations. If you are unable to attend the Institute but would like to send someone in your place, please send written notification by e-mail to [email protected] no later than October 22 for New York or November 12 for San Francisco.

new york conference locAtion And hotel AccommodAtionsThe Grand Hyatt New York hotel is conveniently located in midtown manhattan on Park Avenue at Grand central Station. It is a short walk to nearby broadway theaters, Fifth Avenue shopping, Times Square, and major museums. To provide a quality Institute at the best possible cost NYU has negotiated special room rates and has committed to a block of rooms at the Grand Hyatt New York. We ask you to support NYU by reserving your sleeping accommodations within the room block. Your support allows us to keep our registration fees reasonable. Single or double occupancy rooms are available at the Grand Hyatt at the NYU group rate of $399. The Grand Hyatt has a limited number of rooms with two double beds. If you require a double room, please make your reservation as soon as possible. To make your reservation, call (888) 421-1442 and identify yourself as attending the NYU tax conference. New York city is one of the most popular destinations for fall travel. We urge you to make your hotel and travel plans early to avoid disappointment. Hotel rooms can sell out prior to the cut-off date. These rooms will be held as a block, unless exhausted, until October 2, at which time they will be released to the general public.

sAn frAncisco conference locAtion And hotel AccommodAtionsThe Fairmont Hotel is located at 950 mason Street in the Nob Hill section of San Francisco. central to the Financial district, Union Square, and Fisherman’s Wharf, The Fairmont San Francisco is located at the only spot in San Francisco where each of the city’s cable car lines meet. To provide a quality Institute at the best possible cost NYUSPS has negotiated special room rates and has committed to a block of rooms at the Fairmont Hotel. We ask you to support NYUSPS by reserving your sleeping accommodations within the room block. Your support allows us to keep our registration fees reasonable. Single or double occupancy rooms are available at the Fairmont Hotel at the group rate of $269. The Fairmont has a limited number of rooms with two double beds. If you require a double room, please make your reservation as soon as possible. To make your reservation, call (800) 441-1414 and identify yourself as attending the NYU tax conference. We urge you to make your hotel and travel plans early to avoid disappointment. Hotel rooms can sell out prior to the cut-off date. These rooms will be held as a block, unless exhausted, until October 19, at which time they will be released to the general public.

speciAl needsAny participant who has special needs, (physical, etc.) is encouraged to e-mail [email protected] or to call the NYU School of Professional Studies department of Finance and Law Programs at (212) 992-3320 at least two weeks prior to the conference start date to indicate their particular requirement.

conference check-in And course mAteriAls pick-upThe NYU Institute on Federal Taxation registration desk will open, and materials will be available, beginning at 10.30 a.m. on Sunday. The Institute registration desk will open at 8 a.m. monday through Friday. Proper photo identification is required for badge retrieval. One set of conference materials on a USb flash drive per paid registrant is provided at time of badging. badges must be displayed in all public spaces throughout the conference.









conference mAteriAlscourse materials are provided for each day of the Institute for which you are registered. Included in the conference fee, registrants will receive a USb flash drive at the time of check-in containing the materials for the day(s) of attendance. In addition, registrants will receive an e-mail from NYU approximately 2-3 days before the Institute containing a link and special password in order to access and to download and/or print the course materials for the day(s) of attendance. bound hardcopies of the course materials will be available only upon advance request at an additional fee of $250. If you wish to have a printed set of materials available at the NYU registration desk for the day(s) of your attendance, please indicate this when registering and submit the additional fee of $250. Printers will not be available at the conference. Please note that materials not provided to NYU in advance may be available in hard copy on-site and/or may be e-mailed to registrants after the Institute upon request. However, last minute materials will not be on the USb flash drive. If you are unable to attend the Institute but would like to receive a copy of the course materials (on a USb flash drive), please send your request to: NYU 74th Institute on Federal Taxation course materials Order, 11 West 42nd Street, Suite 400, New York, NY 10036, call (212) 992-3320 or e-mail [email protected] to reserve your copy. See the Institute registration Form for further details on how to order course materials.

matthew bender & co., Inc., a member of the LexisNexis Group®, also publishes comprehensive articles written by speakers, based upon their presentation at the NYU Institute.

For additional information regarding NYU Institute publications, please call (937) 610-5157 or e-mail [email protected].

sponsorship And exhibit opportunitiesFor information on becoming an Institute Sponsor or exhibiting at the conference, please contact kathleen costello at (212) 992-3320 or by e-mail at [email protected].

continuing educAtion creditThe NYU School of Professional Studies is a recognized leader in professional continuing education. The NYU School of Professional Studies department of Finance and Law Programs has been certified by the New York State continuing Legal education board as an Accredited Provider of continuing legal education in the State of New York. This conference meets the educational requirements of many organizations and agencies with mandatory cLe/cPe/ce filing requirements. We urge you to contact our office at (212) 992-3320 or at [email protected] at least 30 days prior to the conference start date to ensure the availability of credit for a specific mcLe state, as we cannot guarantee that credit will be applied for in all cases.

nAsbAThe NYU School of Professional Studies department of Finance and Law Programs is registered with the National Association of State boards of Accountancy (NASbA), as a sponsor of continuing professional education on the National registry of cPe Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for cPe credit. complaints regarding registered sponsors may

be addressed to the National registry of cPe Sponsors through its website: www.learningmarket.org. delivery method: Group-Live. Program Level: Overview. NASbA Fields of Study: Taxes; regulatory ethics. Prerequisite: No prerequisite. Advanced Preparation: No advanced preparation required.

New York and Texas require sponsors to individually register with their states as continuing professional education sponsors; the NYU School of Professional Studies is a registered sponsor in the State of New York (Sponsor Id# 000493) and in the State of Texas (Sponsor Id#000439).

irs continuing professionAl educAtion creditsThe NYU School of Professional Studies has been approved as an IrS ce Provider. Provider #P9cA0. enrolled Agents

and Tax Preparers should always look for IrS approved providers when fulfilling their continuing education requirements. visit www.irs.gov/taxpros/ce for more information.

estimAted continuing educAtion creditsexcept where indicated, cLe credits are in the categories of professional practice/practice management. cLe boards define a credit hour as either 60 minutes or 50 minutes. recommended cPe credits are in the following NYS subject area: Taxation. NASbA Fields of Study: Taxes; regulatory ethics. In accordance with the Standards of the National registry of cPe Sponsors, cPe credits are based upon a 50-minute hour. Please note that not all state boards accept half-credits.



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http://www.learningmarket.org

http://www.irs.gov/taxpros/ce


full-week credit hours:46.0 60-minute hrs. including 1.5 ethics credits55.0 50-minute hrs. including 2.0 ethics credits (This includes all evening session workshops.)

The following is a daily breakdown of the credit hours for those attending single days:

SuNdaY moNdaY TueSdaY wedNeSdaY ThurSdaY FridaY

7.5

60-min. hrs.

6.75

60-min. hrs.

*8.25

60-min. hrs.

*8.25

60-min. hrs.

**8.25

60-min. hrs.

6.25

60-min. hrs.

9.0

50-min. hrs.

8.0

50-min. hrs.

*10.0

50-min. hrs.

*10.0

50-min. hrs.

**10.0

50-min. hrs.

7.5

50-min. hrs.

* This includes 1.5 60-minute hours or 2.0 50-minute hours of credit for an evening session. ** This includes 1.5 60-minute hours or 2.0 50-minute hours of ethics credit for an ethics evening session.

A certificate of attendance is given to each registrant and validated upon completion of attendance. For questions concerning credit hours or approvals, please call (212) 992-3320 or e-mail [email protected].

registrAtion instructionsonline• vISIT sps.nyu.edu/ift

• Highly recommended for fastest response

• Automated e-mail confirmation will be sent to the e-mail address provided to NYU at the time of registration

• Please use an individual e-mail address for each registrant

• major credit cards accepted: American express®, discover®, mastercard®, or visa®

other registrAtion optionsmAil: To register by mail, complete the registration form and return it with a check or money order payable to New York University, to: NYUSPS budget Office, New York University, 7 east 12th Street, 12th Floor, New York, NY 10003, Attention: 74th Institute on Federal Taxation. All registrations sent by mail must be received by 12 p.m. on Tuesday, October 20, 2015 (eastern Standard Time) for New York and by 12 p.m. on Tuesday, November 10, 2015 (eastern Standard Time) for california.

on-site: To register on-site, you may pay with a check, a money order, or a credit card. To pay by credit card, all walk-ins will be required to self-register at available kiosks. For faster service, conference attendees should plan to register in advance online at sps.nyu.edu/ift To register on-site, visit the NYU registration desk at the Institute beginning at 10.30 a.m. on Sunday or 8 a.m. monday–Friday.

Note: each person attending the IFT must register individually by using a separate form, or in a separate online registration session. Sharing registrations is NOT permitted. Only registered attendees are eligible to receive continuing education credits. Please call (212) 992-3320 or e-mail [email protected] for information on customizing a group discount to fit your needs. To register online for the 20% Full-Week Team discount, please call (212) 992-3320 or e-mail [email protected] for a special discount code. To qualify: Team must be from the same firm and must register together. each team member must register. Team discounts must be applied at time of registration. discounts cannot be applied retroactively to existing registrations, or combined with any other offers. After October 2, to register online for the 15% Full-Week full-time government official, full-time university professor, solo practitioner, nonprofit or small firm discount, please call (212) 992-3320 or e-mail [email protected] for a special discount code. We do not accept faxed registrations or wire transfers as a form of payment.

Note: confirmations may display the start and end dates of the eNTIre Institute; please check the conference agenda for individual dates and times.

For further information regarding administrative policies, such as complaints and refunds, or if you need help registering, please call our conference administrators at (212) 992-3320 or e-mail [email protected].











P1314-XXXX

registrAtion form new york: October 25-30, 2015 | sAn frAncisco: November 15-20, 2015online: sps.nyu.edu/ift

mail to: NYU School of Professional Studies budget Office, New York University 7 east 12th Street, 12th Floor, New York, NY 10003 Attention: Institute on Federal Taxation

choose either: 1. full-week registrAtion

check one for registration and payment:

Individual Full-Week registration – $2,120 NY Oct. 25-30 SF Nov. 15-20

15% early-bird Full-Week discount registration – $1,802to qualify: your registration must be received by october 2.

NY Oct. 25-30 SF Nov. 15-20

20% Team Full-Week discount registration – $1,696 eachto qualify: team must be from the same firm and register together. each teammember must register. team discounts must be applied at the time of registration. discounts cannot be applied retroactively to existing registrations, or combined with any other offers.

NY Oct. 25-30 SF Nov. 15-20

15% Full-Time Government Official/Full-Time University Professor Full-Week discount registration – $1,802 eachto qualify: please provide proof of employment with registration. cannot be combined with the 15% early-bird, or with any other offers .

NY Oct. 25-30 SF Nov. 15-20

15% Small Firm/Solo Practitioner/NonprofitFull-Week discount registration – $1,802 eachto qualify: please enclose company letterhead with registration. cannot be combined with the 15% early-bird, or with any other offers.

NY Oct. 25-30 SF Nov. 15-20

or: 2. single-dAy registrAtionstep 1: check the day(s) for which you wish to register:NY Sun. Oct. 25 mon. Oct. 26 Tues. Oct. 27 Wed. Oct. 28 Thurs. Oct. 29 Fri. Oct. 30

SF Sun. Nov. 15 mon. Nov. 16 Tues. Nov. 17 Wed. Nov. 18 Thurs. Nov. 19 Fri. Nov. 20

step 2: check one for payment: 1 day—$595 2 days—$1,075 3 days—$1,395 4 days—$1,650 5 days—$1,775

1/2 day—$350 Tuesday, Wednesday, and/or Thursday evening Session—$125 each**Evening session registration is included in the purchase of daytime registration or can be purchased separately.

printed course mAteriAls—extra option for an Additional feeWe are going green; to help defray costs, printed materials are available for an additional $250. check here if you want a bound copy of the materials for the day(s) of your attendance and include the $250 fee.

printed materials for $250Included in the conference fee, registrants will be provided access to download and/or print the course materials prior to the Institute and will also receive a USB flash drive at the time of check-in containing the materials for the day(s) of attendance.I am a/n cPA ATTOrNeY eA rTrP OTHerI require cLe credit cPe credit ce credit

FOr cLe ONLY: For which state(s) is cLe credit being requested? _________________________________________

Print or type clearly. This information will appear on the attendee list and on your badge. (Emails will not be publicized.)

Name:

Firm:

Address:

city: State: Zip code:

e-mail*: business Phone:

(*E-mail is required—registration confirmations are sent via e-mail.)

cAn’t Attend?If you are unable to attend the Institute but would like to receive a copy of the course materials (on a USb flash drive), please send your request to: NYU School of Professional Studies, 74th Institute on Federal Taxation course materials Order, 11 West 42nd Street, Suite 400, New York, NY 10036, call (212) 992-3320, or e-mail [email protected] to reserve your copy. reserve your copy by November 2, 2015. We cannot guarantee a selection after November 2. The price for one set of materials on a USb flash drive is $500. There is no additional charge for shipping and handling in the continental U.S. Please add an additional $20 for shipping orders outside the continental U.S. Please make checks or money order payable to New York University. materials are mailed in early december 2015.Please send me: 74th Institute on Federal Taxation course materials

Name:

Firm:

Address:

city: State: Zip code:

e-mail:



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Documents