Tax Section Meeting

Tuesday, January 15, 2019
8:45 AM - 4:00 PM
Total MCLE Credits: 5.00 (Professional Practice 3.50, Ethics 1.50)
Rendezvous Ballroom- 3rd Floor


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) - Trianon Ballroom, Third Floor (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

Erik H. Corwin, Esq.


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 Rendezvous Ballroom, Third Floor (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 & Acquisitions in 2019 Trianon Ballroom, Third Floor (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

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 - Rendezvous Ballroom, Third Floor (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

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 Grand Ballroom, Third Floor (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

Peter A. Furci, Esq.

Debevoise & Plimpton LLP

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

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