The Philadelphia Tax Conference, 10/30

Hosted by the Villanova University Graduate Tax Program

Friday, October 30
8:00 a.m.-4:00 p.m.

Laurence E. Hirsch ’71 Classroom (Room 101)
John F. Scarpa Hall 

Join the Graduate Tax Program for this year’s Philadelphia Tax Conference, bringing together leading tax professionals, industry experts and practitioners for a day of in-depth analysis and valuable networking. Panels will explore key developments in corporate tax, partnership tax, international tax and the economic substance doctrine.

This event is pending approval for 5 CLE and 5 CPE credits. Please note that registration is required.

For more information about the conference, contact Stephen Olsen, professor of practice and faculty director of the Graduate Tax Program. 

Conference Co-Chairs:

• John Apadula, Vice President of Tax Research & Planning, Comcast Corporation
• Debra Martino, Senior Operating Partner, Graham Partners

Agenda

Subject to change

8:00–8:25 a.m.: Registration and Continental Breakfast

8:25–8:30 a.m.: Opening Remarks from

• Conference Co-Chair: Debra Martino, Senior Operating Partner, Graham Partners

8:30–9:30 a.m.: Session 1 – Partnership Update: Hot Topics and Transactional Trends

• This panel will address recent judicial, legislative and regulatory developments and market trends affecting partnership taxation, including:
  • The continuing SECA Saga 
  • State of partnership tax guidance and enforcement
  • BBA audit trends and practical observations
  • Developments in fund structuring and sponsor economics
  • Emerging transactional trends practitioners are seeing
• Panelists:
  • Eytan de Gunzburg, Associate Attorney, Gibson Dunn
  • Deborah L. Paul, Partner, Sidley Austin
  • Eric B. Sloan, Partner, Gibson Dunn

9:30–9:45 a.m.: Networking Break

9:45–10:45 a.m.: Session 2 – Corporate Tax Update

• This session will cover recent corporate tax developments, including:  
  • Upcoming Treasury/IRS Guidance
  • PLR Practice
  • Section 368(a)(1)(F) Reorgs
  • Zero Basis
  • Corp AMT
  • Stock Buyback Excise Tax
  • Section 1202/QSBS
• Panelists:
  • Gregory Fairbanks, Partner, Grant Thornton
  • Robert Liquerman, Associate Chief Counsel (Corporate), Internal Revenue Service (invited)
  • Eric Solomon, Partner, Ivins, Phillips & Barker
  • Christina Tacoronti, Principal, EY

10:45–11:00 a.m.: Networking Break

11:00 a.m.–12:00 p.m.: Session 3 – International Tax Update

• The session will include an update on IRS priorities and guidance. The panel expects to cover:    
  • Open OBBBA issues under Section 174 (amortization of R&D expenses) and Stewardship
  • A review of proposed regulations under Sections 898 (tax years of foreign corporations) and Section 951(a)(1) (determining a US shareholder’s pro rata share of income inclusion under Subpart F)
  • A consideration of recent holdings in Varian Med. Systems, Inc. v. Comm’r, and Siemens Med. Sol. USA Inc. v. Comm’r.  

• Panelists:
  • Joan Arnold, Professor of Practice, Graduate Tax Program
  • Layla Asali, Member & Firm Vice Chair, Miller & Chevalier
  • John Bates, Principal, Deloitte
  • Tracy Villecco, Associate Chief Counsel (International), Internal Revenue Services (invited)

12:00–1:30 p.m.: Legislative Update Lunch – Impact of Upcoming Election on Legislative Agenda

• John Gimigliano, Principal-in-charge, Federal Legislative and Regulatory Services (FLRS) Group, Washington National Tax Practice, KPMG LLP

1:45–2:45 p.m.: Session 4 – Common Traps for the Unwary Under Subchapter K

• Real-world mistakes, technical landmines and unexpected tax consequences. Topics include:
  • Accidental partnership continuations
  • Partnership mergers and divisions gone wrong
  • Forgotten section 754 elections
  • Attribution rule traps
  • Anti-churning surprises
  • Leveraged distribution issues
  • Section 83(b) election pitfalls
  • K-1 versus W-2 classification issues

• Panelists:
  • Sarah Brodie, Principal, EY and Adjunct Professor of Law, Georgetown Law
  • Matthew J. Donnelly, Partner, Kirkland & Ellis
  • Eric B. Sloan, Partner, Gibson Dunn

2:45–3:00 p.m.: Networking Break

3:00–4:00 p.m.: Session 5 – Economic Substance: The Long, Strange Trip Continues

• This panel will address recent developments in the economic substance doctrine and offer insights about what to expect in the year ahead.
• Panelists:
  • Nathaniel S. Pollock, Partner & Lead, Tax Controversy Practice, SouthBank Legal
  • Eric B. Sloan, Partner, Gibson Dunn
  • Eric Solomon, Partner, Ivins, Phillips & Barker