2013 Meeting of the Virginia Tax Study Group

Next meeting, Friday, March 22, 2013

The next meeting of the Virginia Tax Study Group will take place at the University of Virginia School of Law on Friday, March 22, 2013, starting at 9:30 am and ending about 5:00 pm. It will be followed by a reception and dinner at the law school.

For those who wish hotel accommodations, we have reserved a set of rooms in The Residence Inn by Marriott, which is around the corner from the law school, for the nights of Thursday, March 21, and Friday, March 22. If you would like accommodations for one or more of those nights, please inform Teri Johnson (tlj3a@eservices.virginia.edu), who will then make the arrangements with the Inn. The cost of the room will be $134, plus tax.

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 Cecily Rock, Cathy Barrè, Holly Porter, Jon Traub, and possibly others, who will advise on 2013 tax law developments. The remaining sessions will all involve discussions of important tax policy and 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 the substantive 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.

Tentative schedule

9:30 – 10:45: DC Panel with Cecily Rock of the Joint Committee on Taxation; Cathy Barrè, Director, Legislative Affairs, Internal Revenue Service; Holly Porter, Finance Committee Staff; and Jon Traub, Managing Principal, Tax Policy Group, Deloitte & Touche, Washington, D.C.; and possibly other participants, will discuss what is likely to happen in the tax world in 2013.

10:45 – 11:00: break

11:00 – 12:15: Corporate Inversions. Willard Taylor (moderator)(Sullivan & Cromwell), Hal Hicks (Skadden, Arps), David Lenter (Joint Committee Staff), and Bret Wells (University of Houston Law Center) will discuss the tax treatment of corporate inversion transactions. The panel will begin with a history of inversions. The discussion will then turn to the strategic and economic forces driving companies to invert, the new regulations bearing on expatriated entities and their foreign parents, the merits of the present statutory and regulatory response to inversions in light of alternative approaches, and other related issues.

12:30 – 1:45: lunch. Jon Talisman, Capitol Tax Partners, Washington, D.C., will address the group during the lunch.

2:00 – 3:30: Aspirational Tax Reform. There has been much discussion about possible tax reform, but how realistic is it to think about effective legislative revision of the Tax Code? And what changes would both be realistic and improve the way the income tax works? Rod DeArment (Covington), Roberton Williams (Tax Policy Center), and Martin McMahon (Stephen C. O’Connell Professor of Law, University of Florida) will address these questions in light of their views about what tax reform should or could accomplish.

3:30 – 3:45: break

3:45 – 5:00: Impact of Significant Tax Legislation on Government Institutions Which Are Responsible for Administration and Enforcement. The implementation of major tax changes may have serious effects on the ability of those government agencies which will have to deal changes to an already complex tax system. Professor Ellen Aprill (John E. Anderson Professor of Tax Law, Loyola Law School, Los Angeles) (see The Impact of Agency Procedures and Judicial Review on Tax Reform, 65 NAT’L TAX J. 917 (2012)); Nina Olson (National Taxpayer Advocate); and Judge Mark Holmes (U.S. Tax Court) will discuss how tax legislation could affect the ability of these institutions to implement changes in the tax rules, or, conversely, how institutional limitations should be taken into account in formulating tax legislation.

5:15 – 8:00: Cocktails and dinner at the law school.