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Tax Executives Institute: Philadelphia Chapter Meeting

Malvern, PA

Thomas Cryan,* Steven Dixon,* Maria O'Toole Jones, James Gadwood, and Lisandra Ortiz will present to Tax Executives Institute's (TEI's) Philadelphia Chapter on October 30, 2019.

Jones and Gadwood will present "Important Developments in Administrative Practice." This presentation will address recent important developments in Treasury and IRS guidance and court decisions relating to administrative practice before the IRS. The presentation will address developments on areas such as:

  • The IRS examination process
  • Conferences with the IRS Independent Office of Appeals
  • Statutes of limitations
  • Penalty defenses
  • Privilege issues

Cryan will present, as part of a panel, "Employment Tax and Executive Compensation." This panel explores recent hot issues in the field of employment taxes and executive compensation, including:

  • The new section 162(m)
  • Supplemental income tax withholding rules
  • FICA taxes and deferred compensation
  • Section 409A
  • Deductions for moving, marking and meals
  • M&A compensation reporting
  • Clawbacks

Dixon and Ortiz will present "Just BEAT It," a presentation focused on the base erosion and anti-abuse tax (BEAT), the new minimum tax imposed by Section 59A. The presentation will address:

  • The current state of the guidance
  • Complexities raised by application of the BEAT rules
  • Planning strategies and opportunities to minimize exposure
  • What to expect going forward

*Former Miller & Chevalier attorney