2015 Annual Meeting of the California Tax Bar and California Tax Policy Conference
2015 Conference Schedule for Thursday

Courses and speakers are subject to change. Plan ahead by pre-registering for the programs of your choice using the Course Selector. CTPC (State & Local Tax) and Annual Meeting-CTPC crossover courses are shown in blue and marked "CTPC".

Thursday, November 5

Time Event Course #
CTPC?

7 a.m. - 6 p.m.

Conference Registration & MCLE Sign-in

 

7:30 a.m. - 8:30 a.m.

Continental Breakfast

Continental Breakfast is complimentary, but your RSVP is required. Select item #34 in Section B of the Conference Registration Form.

Course #34

Taxation Section Committee Meetings

New in 2015 – Taxation Section Committee Breakfast Meetings! Tables will be reserved under each Committee’s name. If you are planning to attend a Committee meeting, select both the Continental Breakfast #34 AND the appropriate box in Section C of the Conference Registration Form.

Courses #42-50

8:30 a.m. - 10 a.m.

Estate and Gift Tax Current Developments

1.5 Hours MCLE & Legal Specialization

Estate & Gift Tax

The panel of government and private practitioners will discuss current case law, rulings, statutes and regulations. The panel will also discuss how to apply for rulings and pre-rulings and what is new at Counsel’s Office and Appeals.

Speaker(s):

  • Donna Herbert, Senior Counsel (SB/SE), Internal Revenue Service, Thousand Oaks
  • James F. Hogan, Managing Director of Washington D.C. Office, Andersen Tax, McLean, VA
  • Robin Klomparens, Partner, Wagner Kirkman Blaine Klomparens & Youmans, LLP, Mather

Course #2

Criminal Tax Workshop

1.5 Hours MCLE & Legal Specialization

Tax Procedure & Litigation, Young Tax Lawyers

This practical workshop is designed to provide essential strategies and techniques for handling a criminal tax case from inception through indictment and sentencing. A hypothetical will cover “egg shell” audits, referrals to Criminal Investigation, and the Criminal investigation phase. Topics will include surprise interviews, the Special Agent’s Report, and what to expect at a “SAC” Conference. The workshop also covers sentencing guidelines and how to compute the tax loss, successful strategies in plea bargaining, and sentencing and restitution issues. This program is a must for practitioners who represent clients with potential criminal tax exposure.

Speaker(s):

  • Wendy Abkin, Partner, Abkin Law, San Francisco
  • Sandra Brown, AUSA Division Chief, US Attorneys Office, Los Angeles
  • Steven Walker, Managing Shareholder, Law Offices of Steven Walker, San Jose
  • Federal Government Speaker Invited

Course #3

2014 and 2015 California Tax Legislation -- Policy Makers at Work

1.5 Hours MCLE & Legal Specialization

CTPC (State and Local Tax)

Legislative tax committee staff and other tax policy professionals will review what passed, what did not, and why. Panelists will also address pending and anticipated California legislative proposals and other states’ legislative policy differences.

Speaker(s):

  • Colin Grinnell, Consultant, California State Senate, Senate Committee on Governance and Finance, Sacramento
  • Gail Hall, Director, Legislative Services Bureau, California Franchise Tax Board, Sacramento
  • Oksana Jaffe, Chief Consultant, California State Assembly, Assembly Committee on Revenue and Taxation, Sacramento
  • Michele Pielsticker, Chief, Legislative and Research Division, California State Board of Equalization, Sacramento
  • Gina Rodriquez, Vice President, State Tax Policy, California Taxpayers Association, Sacramento

Course #4

CTPC

10:10 a.m. - 11:25 a.m.

 

Estate and Gift Tax Audit Issues

1.25 Hours MCLE & Legal Specialization

Estate & Gift Tax, Young Tax Lawyers

The panel will address the IRS’s most current focus in estate and gift tax audits. The discussion will include the latest areas of attack and how to plan around them, as well as how to defend them if the train has left the station.

Speaker(s):

  • Robin Klomparens, Partner, Wagner Kirkman Blaine Klomparens & Youmans LLP, Mather
  • John Prokey, Partner, Ramsbacher Prokey & Leonard LLP, San Jose

Course #5

Advanced Tax Court Litigation Boot Camp, Part 1: Qualifying and Effectively Using an Expert at Trial

1.25 Hours MCLE & Legal Specialization

Tax Procedure & Litigation, Young Tax Lawyers

This panel will focus on the necessary procedure for qualifying and effectively using an expert witness in Tax Court. You will get an overview of Tax Court Rule 143(g), learn how to qualify your expert witness, perform effortless voir dire, and deliver a damaging cross examination. The panel will address using rebuttal reports, “hot-tubbing,” possible Daubert concerns, and provide a discussion regarding lay and industry experts.

Speaker(s):

  • Clifton Bonney, Special Trial Attorney, Office of Chief Counsel, IRS, San Francisco
  • William Colgin, Partner, Morgan, Lewis & Bockius, LLP, Palo Alto
  • Hon. Mark V. Holmes, Judge, United States Tax Court, Washington, D.C.
  • Audrey M. Morris, Deputy Area Counsel, Office of Chief Counsel, IRS, Dallas, Texas

Course #6

Blue Light Special, Finding the Market in California’s New Market-based Sourcing Rules

1.25 Hours MCLE & Legal Specialization

CTPC (State and Local Tax)

Join this panel for a lively discussion of the evolution and current status of California’s implementation of a single sales factor apportionment methodology with market-based sourcing rules for sales other than sales of tangible personal property. Specific areas of focus will include the current market-based sourcing regulation and the FTB’s efforts to provide greater clarification for how market-based sourcing is applied. The panel will also address best practices when there is no clear guidance for a particular type of receipt and touch on how other states have implemented their versions of market-based sourcing. Finally, the panel will consider the California tax policy implications of these developments.

Speaker(s):

  • Bart Baer, Principal, Deloitte Tax LLP, San Francisco
  • Matt Savatsky, Senior Manager, KPMG LLP, San Francisco
  • Melissa Williams, Tax Counsel IV, Multistate Tax Bureau, California Franchise Tax Board, Sacramento
  • Scott Wright, Partner, Sutherland Asbill & Brennan LLP, Atlanta, GA

Course #7

CTPC

11:35 a.m. - 1 p.m.

Luncheon and Federal Keynote

$49 per person

Conference Luncheon and Federal Keynote Address with Presentation of the V. Judson Klein Award and Joanne M. Garvey Award

The opening day luncheon showcases the prestigious V. Judson Klein Award to Doug Youmans, Partner, Wagner Kirkman Blaine Klomparens & Youmans LLP; and the distinguished Joanne M. Garvey Award to Martin A. Schainbaum, Managing Shareholder, Martin A. Schainbaum, APC. The luncheon program will feature a keynote address by Debra K. Moe (invited), Division Counsel (Small Business/Self-Employed Division), IRS Office of Chief Counsel, Washington, D.C. This luncheon is sponsored in part by Wagner Kirkman Blaine Klomparens & Youmans LLP. Purchase tickets in advance on the Conference Registration Form. Onsite ticket sales are limited.

Douglas Youmans  
Doug Youmans

Martin Schainbaum
Martin Schainbaum
Debra K. Moe
  Wagner Kirkman Blaine Klomparens & Youmans LLP Attorneys at Law  

Course #35

1:10 p.m. - 2:10 p.m.

Important Tax Administration and Procedural Rules for Estate Planners

1 Hour MCLE & Legal Specialization

Corporate & Pass-Through Entities, Estate & Gift Tax, Tax Exempt Organizations, Young Tax Lawyers

This panel will discuss the special tax rules that apply when dealing with post mortem administration, including: funding, transferee liability, fi duciary liability, estate tax liens, 6166, and other important rules.

Speaker(s):

  • Nancy Henderson, Partner, Henderson, Caverly, Pum & Charney, LLP, San Diego
  • Mike Sorrow, Partner, McDermott WIll & Emery, Chicago, IL

Course #8

Transfer Pricing Hot Topics

1 Hour MCLE & Legal Specialization

International Tax, CTPC (State and Local Tax), Tax Procedure & Litigation

This program will discuss new developments in the realm of transfer pricing and explore the relationship between transfer pricing and an entity’s tax and fi nancial reporting. In addition, an esteemed panelist from the Multistate Tax Commission (“MTC”) will discuss its Arm’s-length Adjustment Service (“ALAS”) initiative to support state revenue authorities in their independent reviews of transfer pricing arrangements.

Speaker(s):

  • David L. Forst, Partner, Fenwick & West, LLP, San Francisco
  • Gregory S. Matson, Deputy Executive Director, Multistate Tax Commission, Washington, D.C. (CTPC)

Course #9

Partial
CTPC

Going Nuts Over the Complexities of Sales Tax Classifications

1 Hour MCLE & Legal Specialization

CTPC (State and Local Tax)

Ever wonder why your bill at the deli is different for the same sandwich when you eat in the restaurant versus when you take it to go? Our panel of sales tax gurus will answer this question and many more as they take on the complexities of the sales and use tax laws. Discussion topics will include the need (or lack thereof) for such complexity, the pros and cons of reforming the system, and recent developments in the area of sales and use tax.

Speaker(s):

  • Fred O. Marcus, Principal, Horwood Marcus & Berk Chartered, Chicago, Il
  • Lawrence Mendel, Tax Counsel IV, Tax and Fee Programs Division, California State Board of Equalization, Sacramento
  • Rob Putzier, Director, Grant Thornton LLP, Irvine
  • Mark N. Stefan, Partner, Ernst & Young LLP, San Jose

Course #10

CTPC

2:20 p.m. - 3:20 p.m.

What Every Domestic Estate Planning Attorney Should

1 Hour MCLE & Legal Specialization

Estate & Gift Tax, International Tax, Young Tax Lawyers

Know About International Estate Planning As the world becomes increasingly global, estate planners must have a basic understanding of international issues that may arise. This presentation will give an overview of the top international estate planning issues that a domestic estate planner is likely to encounter. Learn what to do when a U.S. person has a foreign bank account or foreign real property, names a foreign trustee, leaves property to a foreign beneficiary, receives a gift from a non-resident alien, or marries a non-citizen spouse.

Speaker(s):

  • Michelle Graham, Partner, Withers Bergman LLP, Rancho Santa Fe
  • Wayne Johnson, Managing Principal, Wayne R. Johnson& Associates, PLC, Los Angeles
  • Patrick Martin, International Tax Partner, Procopio, Cory, Hergreaves, Savitch, LLP, San Diego

Course #11

Partnership Liability Allocations

1 Hour MCLE & Legal Specialization

Corporate & Pass-Through Entities, Tax Procedure& Litigation

Discover how new proposed regulations on partnership liability allocations could dramatically tighten the rules in this critical area such as what will trigger gains for many taxpayers with negative capital accounts. The program includes a review of planning techniques under current law and potential effects of the proposed changes.

Speaker(s):

  • Terry Cuff, Partner, Loeb & Loeb, LLP, Los Angeles
  • Phil Jelsma, Partner, Crosbie Gliner Schiffman Southard& Swanson LLP, San Diego

Course #12

Is it a Plane, an Automobile or a Computer? Exploration of California’s Property Tax Software Exemption

1 Hour MCLE & Legal Specialization

CTPC (State and Local Tax)

Computers and software are embedded into nearly every modern electrically operated machine. However, because software is generally exempt from property taxation, assessors have begun to question the continued application of California’s software exemption. Our panel will discuss practical problems associated with complying with the current law, and whether the Cardinal Health decision remains relevant in a world filled with computers.

Speaker(s):

  • Michael Boykin, Principal, Grant Thornton LLP, Charlotte, NC
  • Richard Moon, Tax Counsel IV, Tax and Fee Programs Division, California State Board of Equalization, Sacramento
  • Brian Toman, Partner, Reed Smith LLP, San Francisco
  • Troy M. Van Dongen, Partner, Winston & Strawn LLP, San Francisco

Course #13

CTPC

3:30 p.m. - 6 p.m.

The Nature and Effectiveness of Domestic Asset Protection Trusts

1.5 Hours MCLE & Legal Specialization

CTPC (State and Local Tax), Estate & Gift Tax, Income & Other Taxes

This panel, including a Chief Judge of the U.S. Bankruptcy Court, will examine and explore the viability of domestic asset protection trusts, including NINGS and DINGS. The panel will also analyze differences in various jurisdictions in the U.S., including California.

Speaker(s):

  • Peter W. Bowie, Of Counsel, Ballard Spahr, LLP, San Diego (former Chief Judge, U.S. Bankruptcy Court, S. Dist. CA)
  • George D. Karibjanian, Senior Counsel, Proskauer Rose, LLP, Boca Raton, FL
  • Sonia Woodruff, Tax Counsel III, General Tax Bureau, California Franchise Tax Board, Sacramento (CTPC)

Course #14

Partial
CTPC

Advanced Tax Court Litigation Boot Camp, Part 2: Perfect your Advocacy Skills and Develop Advanced Trial Techniques

1.5 Hours MCLE & Legal Specialization

Tax Procedure & Litigation, Young Tax Lawyers

Learn practical tips to successfully advocate for your client in Tax Court. This advanced “Boot Camp” is designed as a litigation refresher for new and seasoned litigators. Walk away with 10 solid techniques that will allow you to win objections, protect the record, impeach during cross examination, understand hearsay, and lay foundation for exhibits. Become comfortable with the most common federal rules of evidence and receive tips from the Tax Court Judge on properly representing your client before and after trial.

Speaker(s):

  • Hon. L. Paige Marvel, Judge, United States Tax Court, Washington, D.C.
  • Jordan S. Musen, Associate Area Counsel, Office Of Chief Counsel, IRS, Thousand Oaks
  • Dennis L. Perez, Partner, Hochman, Salkin, Rettig, Toscher& Perez, P.C., Los Angeles
  • Edward Robbins, Partner, Hochman, Salkin, Rettig, Toscher & Perez, P.C., Los Angeles
  • Kaelyn J. Romey, Senior Counsel, Office of Chief Counsel, IRS, San Francisco

Course #15

Exploring the Facts and Circumstances of “Nonbusiness” Income

1.5 Hours MCLE & Legal Specialization

Corporate & Pass-Through Entities, CTPC (State and Local Tax)

This panel of seasoned state tax professionals will navigate relevant California administrative and judicial case law, as well as U.S. Supreme Court and other state case law, and share their policy views concerning the future state of “nonbusiness” income. Topics to be covered by the panelists include the impact of intercompany relationships; to what extent “old and cold” business assets can become nonbusiness; making distinctions between an intent or attempt to integrate the assets and actual integration, including a discussion of FTB Legal Ruling 2012-1; and whether or when intercompany debt expense may risk disallowance of nonbusiness income treatment.

Speaker(s):

  • Jeff Friedman, Partner, Sutherland Asbill & Brennan LLP, Washington, D.C.
  • Carl A. Joseph, Principal, Ernst & Young LLP, Roseville
  • David Pope, Associate, Baker & McKenzie LLP, New York, NY
  • Ted Tourian, Tax Counsel III, Multistate Tax Bureau, California Franchise Tax Board, Sacramento

Course #16

CTPC

6 p.m. - 8:30 p.m.

Annual Conference Dinner

$95 per person

Annual Conference Dinner & Entertainment by Renowned Comedian and Political Satirist, Will Durst

Purchase tickets in advance. Onsite tickets sales are limited. This dinner is sponsored in part by Pillsbury Winthrop Shaw Pittman LLP and Reed Smith LLP. (CTPC Sponsors)

Pillsbury Winthrop Shaw Pittman LLP    Reed Smith

 

Course #36

Partial
CTPC
 

8:30 p.m. - 10:30 p.m.

Thursday Late Night “Vegas Style” Event

Complimentary

Join us at the annual Vegas-style casino night sponsored in part by Sutherland Asbill & Brennan LLP. This event is complimentary; however, your RSVP is requested. Sign up on the Conference Registration Form. (CTPC Sponsor)

Sutherland

Course #37

Partial
CTPC