2011 Meeting of the Virginia Tax Study Group

Virginia Tax Study Group Meeting: Friday, March 25, 2011

Location: University of Virginia School of Law, Rm. WB 128
Time: 09:30 – 17:00, followed by cocktails and dinner

2011 Meeting Information
Meeting starts at 9:30 am and ends about 5:00 pm.  It will be followed by cocktails and dinner at the law school.

For those who wish hotel accommodations, we have reserved ten rooms in the Residence Inn, which is on Millmont Street, a short walk from the law school, for the nights of Thursday, March 24, and Friday, March 25, at $139 a night.  The hold on these rooms will be released on March 2.

As you will see from the tentative schedule set forth below, the opening session for the program will be our usual “DC Panel” led by Mort Caplin, Rod DeArment, Cecily Rock, and possibly others, who will advise on 2011 tax law developments.  The remaining sessions will all involve discussions of important tax administration issues.  We have a highly distinguished group of experts who will present and comment on these issues.

As we have in past years, we will make available written materials dealing with each of these topics.  We will send you an email with the Website location containing the papers and password information for access, and will send a PDF of the materials upon request.  As usual, we have reserved a significant amount of time for audience involvement and hope that all of you will actively participate in the program throughout the day.

2011 Meeting Schedule
– 9:30 – 10:45:   DC Panel with Mort Caplin of Caplin & Drysdale, Rod DeArment of Covington & Burling, Cecily Rock of the Joint Committee on Taxation, and possibly other participants, will discuss what will happen in the tax world in 2011.
– 10:45 – 11:00:  break
– 11:00 – 12:15:  The Internal Revenue Service has announced that it will require certain taxpayers to disclose uncertain tax positions taken on their tax returns.  This panel will discuss issues raised by the implementation of this position.  The discussion will be led by Fred Murray of Grant, Thornton and William Wilkins, Chief Counsel of the Internal Revenue Service, and Pamela Olson, Tax Partner, Skadden, Arps, will provide comment.
– 12:30 – 1:45:  lunch.  Len Burman, Daniel Patrick Moynihan Professor of Public Affairs at Syracuse University, will address the group during the lunch.
– 2:00 – 3:30: Enactment of the economic substance doctrine has produced concern about the IRS’s position with respect to a variety of tax sensitive transactions.  To present this topic, David Hariton, Tax Partner, Sullivan & Cromwell, will discuss his article, The Frame Game: How Defining the “Transaction” Decides the Case, 63 Tax Lawyer 1 (Fall 2009).  Karen Burke, Warren Distinguished Professor of Law, University of San Diego School of Law, and William Alexander, Associate Chief Counsel (Corporate), Internal Revenue Service will provide comment.
– 3:30 – 3:45:  break
– 3:45 – 5:00:  On July 22, 2010, the House Ways & Means Committee held a hearing on transfer pricing, in preparation for which the Joint Committee staff published an informative report.  This panel will focus on the important topic of transfer pricing.  Reuven Avi-Yonah, Irwin I. Cohn Professor of Law, University of Michigan Law School, will discuss his paper, “Formulary Apportionment: Myths and Prospects.”  Tom Barthold, Chief of Staff, Joint Committee on Taxation, will discuss the Joint Committee Report, and Michael Durst, Special Counsel, Steptoe & Johnson, and Steve Shay, Deputy Assistant Secretary (International Tax Affairs), Treasury Department, will provide comment.
– 5:15 – 8:00:  Cocktails and dinner at the law school.