Sections & Committees

Tax Section

TAX SECTION MEETING

Tuesday, January 15, 2019
8:45 AM - 4:00 PM
Total MCLE Credits: 5.00 (Professional Practice 5.00)
Rendezvous, 3rd Floor
#nysba19

Register for the 2019 Annual Meeting Here or Download The Registration Form Here.

8:45 a.m. –  9:00 a.m. Business Meeting and Election of Officers 
Trianon Ballroom, Third Floor
Concurrent Morning Sessions

9:15 a.m. – 10:30 a.m. Private Equity Transactions After the Tax Cuts and Jobs Act (TCJA) (1.5 Credits in Areas of Professional Practice)
This panel will discuss the impact of the TCJA and recent guidance on private equity transactions, with a focus on cross-border transactions.  Topics will include the change in the CFC rules and implications including GILTI and Section 956, pass-through transactions and blocker structures, and other implications of the interest deduction limitations of Section 163(j)

Panel Chair:
David R. Sicular, Esq.

Paul, Weiss, Rifkind, Wharton & Garrison LLP

Panelists:  
Erik H. Corwin, Esq.

KPMG LLP

David J. Sreter, Esq. 
Warburg Pincus LLC

Sara B. Zablotney, Esq. 

Kirkland & Ellis LLP

9:15 a.m. – 10:30 a.m. New York State’s Response to the TCJA  1.5 Credits in Areas of Professional Practice)
New York usually conforms to federal legislation, but not always. In response to TCJA, New York enacted some conforming and some decoupling legislative changes, and administrative interpretations were issued to provide additional guidance. New York and other states have banded together when their approaches have been challenged by Treasury and IRS pronouncements. This panel will discuss New York’s response to the federal changes. 
Panel Chair: 
Paul R. Comeau, Esq.

Hodgson Russ LLP

Leah S. Robinson, Esq.
Mayer Brown LLP 

Jack Trachtenberg, Esq.
Deloitte Tax LLP 

10:45 a.m. – 12:00 p.m. Mergers & Aquisitions in 2019 (1.5 Credits in Areas of Professional Practice)
Join us for a discussion of issues impacting M&A, including the new expensing rules under Section 168(k), the new slate of rules relevant when buying or selling a CFC, and guidance relating to spin-offs and private letter rulings.  
  
Panel Chair: 
David H. Schnabel, Esq.

Davis Polk & Wardwell LLP

Panelists: 
Pamela Lawrence Endreny, Esq.

Skadden, Arps, Slate, Meagher & Flom LLP

Lawrence M. Garrett, Esq.
Ernst & Young LLP 

Kara L. Mungovan, Esq.
Cravath, Swaine & Moore LLP

10:45 a.m. – 12:00 p.m. Rocks - Partnership Representatives - Hard Places (1.5 Credits in Ethics)
How can “Partnership Representatives” carry out their responsibilities and wade through the numerous conflicting interests and privacy concerns in light of all the obligations and elections they may have under the new partnership audit rules, the partnership agreement, their own contracts with the partnership, fiduciary obligations, and most importantly, the professional responsibility and ethical rules?   Would you want to be a PR?  Come and find out.

Panel Chair:
Diana L. Wollman, Esq.

Cleary Gottlieb Steen & Hamilton LLP

Panelists:
Bryan C. Skarlatos, Esq.

Kostelanetz & Fink, LLP

Diana S. Doyle, Esq.
Latham & Watkins LLP
(1.5 Credits in Ethics)
                    
12:30 p.m. – 2:00 p.m. Tax Section Luncheon (Extra Fee Applies)

2:15 p.m. - 4:00 p.m. International Tax Planning Under the TCJA: How It All Fits Together (2.0 Credits in Areas of Professional Practice)
Learn how the recently enacted international tax rules (including GILTI, FDII, BEAT and Sections 163(j), 245A and 965) interact with each other, some discontinuities between the new regimes and preexisting provisions, and how the new and preexisting rules together impact planning for common transactions.

Panel Chair: 
Philip R. Wagman, Esq.

Clifford Chance US LLP

Panelists:
Peter A. Furci, Esq.

Debevoise & Plimpton LLP

Michael L. Schler, Esq. 
Cravath, Swaine & Moore LLP

Dana L. Trier, Esq.
Davis Polk & Wardwell LLP


Tuesday, January 15, 2019
12:30 PM - 2:00 PM
Grand Ballroom & Foyer, 3rd Floor
#nysba19

Speaker:  HONORABLE CHARLES P. RETTIG
COMMISSIONER OF THE INTERNAL REVENUE SERVICE


Tickets:  $115 Each/Tables of 10 available for Purchase for $1150.
Individual Tickets may be purchased by mail or online.

To purchase Tables for the Luncheon, download the Luncheon Table Reservation form

Welcome!

The Tax Section of the New York State Bar Association is pleased to welcome Section members and visitors. Among the resources available at this site is a comprehensive listing of links relevant to the Section, and the Section's Tax Reports. View the 2013 Annual Report of the Section dated January 28, 2014 here

Karen Gilbreath Sowell is the 2018 Chair of the (2,063) member Tax Section.  Karen is a Principal at Ernst & Young LLP and is co-leader of the firm’s National Tax M&A practice.  She was the Deputy Assistant Secretary for Tax Policy at the U.S. Department of Treasury from 2007 – 2009 and an Associate Legislative Counsel and Attorney Advisor from 1997-2001.

We encourage you to get more involved with the section founded in 1949. The Executive Committee of the Tax Section is comprised of 4 Officers, at least 40 Co-Chairs of more than 20 separate tax committees, 9 At-Large Members, and 25 former Section Chairs. The Executive Committee oversees the activities of the tax committees. Any member of the Tax Section is eligible to join the tax committees. Please contact Tiffany Bardwell if you are interested or complete and mail in the Tax Section Membership and Committee Application Brochure.

The Tax Section engages in many activities, including testifying before Congress, holding semi-annual meetings and sponsoring Ad hoc conferences. Our primary function, however, is to comment on proposed legislation and proposed regulatory guidance at the federal, state and local levels. We usually do this in the form of written reports.

Although the Tax Section first began to prepare these reports shortly after its formation, it did not begin to number them until 1972. Since then, we have submitted over 1280 reports. To obtain a report pre-2000 please contact Tiffany Bardwell. Reports issued in 2000 to date are available on this website.

Most of our reports comment on proposed guidance or legislation related to corporate and partnership tax, international tax, the taxation of financial instruments, debt and equity securities, employee benefits, IRS regulation of tax lawyers, and state and local tax matters.

To maintain our high standards in the years ahead, we need you to become more involved in the Tax Section, to go beyond reading a few of our reports or attending a few of our conferences. Take the next step by joining one of our tax committees and seize the opportunity to participate in one of these working groups.

The Tax Section hosts events to provide tax lawyers who tend to be underrepresented at the senior levels of our profession the opportunity to meet with members of the Tax Section in a relaxed atmosphere to discuss career opportunities, what life as a tax partner at a law firm is really like or just to mingle. These events "Women in the Law" and "Under 10", for attorneys who graduated from law school less than 10 years ago, also include panel presentations not only on interesting tax issues, but on topics like alternative career paths for tax lawyers or how to attain greater stature within the tax bar and best practices with clients. The section won the Section Diversity Leader Award in the 2012 NYSBA Diversity Challenge and was a  Section Diversity Champion in 2013 for these efforts. Photos of the Diversity Award and the EC Committee at work are here

Mission Statement


Section Bylaws

Tax Section Reports

Executive Committee Roster


Master Index of NYSBA Tax Section Reports

Already a member of the NYSBA Tax Section? Join a Committee!

Bankruptcy and Losses
Compliance, Practice and Procedure
Consolidated Returns
Corporations
Cross Border Capital Markets
Diversity

Employee Benefits
Estates and Trusts
Financial Instruments
"Inbound" U.S. Activities of Foreign Taxpayers
Individuals
Investment Funds
New York City Taxes
New York State Taxes

"Outbound" Foreign Activities of U.S. Taxpayers
Partnerships
Pass-Through Entities
Real Property
Reorganizations 
Securitizations and Structured Finance
Tax Exempt Entities

Other Committees:
Contact Tiffany Bardwell at tbardwell@nysba.org or 518.487.5675 for more information if you are interested in joining the following Committees:

Cross-Border M & A
Complexity and Administrability

Spin Offs
Treaties and Intergovernmental Agreements

TAX Section Under Ten Club

The section sponsors a “tax club” for members of the Tax Section with less than ten years of legal experience. We call it “Under 10.” The purpose of Under 10 is to bring together lawyers from various law firms, allow them to get to know each other better and offer an environment for learning more about current tax issues. In addition, we hope that attendees will become involved in the Tax Section and in reports prepared by the Section. We anticipate that Under 10 will meet quarterly on specific topics. If you are interested in joining the Under 10 club please contact Tiffany Bardwell at tbardwell@nysba.org or 518.487.5675.

 The Section has formalized its “Under 10” tax club for members of the Tax Section who graduated from law school less than 10 years ago. With organizational and financial support of the Tax Section, the club operates independently from the Tax Section through its own officers and meets four times per year.  The goal of the club is to serve as a source of professional development and networking for mid-level and senior associates.

See Under 10 bylaws here.