Audits and Appeals Seminar Meeting the Tax Controversy Needs of In-House Tax Professionals May 17-19, 2016 June 13-15, 2016

May 17-19, 2016

June 13-15, 2016

Hyatt Regency Hotel Aloft Boston Seaport Hotel Santa Clara, CA Boston, MA For over twenty-five years, Tax Executives Institute has met the tax controversy needs of the in-house professional community through its Audits & Appeals Seminar. Leading practitioners, litigators, regulators, policymakers, and jurists join TEI annually to discuss the nuts, bolts, and nuances of tax controversy with in-house tax professionals from around the world. As the tax controversy environment and challenges to effectively manage disputes has evolved, so have TEI’s programs. To supplement TEI’s core agenda (focusing on federal controversy), we have added full days of instruction devoted exclusively to foreign and state and local tax controversies. We are delighted to welcome our sponsors: • Baker & McKenzie to lead foreign controversy instruction in Santa Clara, and, • Sutherland Asbill & Brennan to lead the state and local tax controversy instruction in Boston. The 2016 TEI Audits & Appeals Seminars offer you the most comprehensive programs available. We have scheduled our seminars to allow you to register for and attend those aspects of the Audits & Appeals program that meet your specific needs. What do we mean by that? First, our program will take place in two locations, on two different dates:



Audits & Appeals (West) May 17-19, Santa Clara, California • May 17-18 – Insights and Skills for Federal Tax Controversy Success • May 19 – Managing International Tax Controversies in Challenging Jurisdictions, sponsored by Baker & McKenzie



Audits & Appeals (East) June 13-15, Boston, Massachusetts • June 13-14 – Insights and Skills for Federal Tax Controversy Success • June 15 – Managing State and Local Tax Controversies, sponsored by Sutherland Asbill & Brennan.

Second, at each location, you can register for all three days, the first two, or the final day, depending on your individual needs. I invite to you to review the following pages for program highlights. For more detailed information and instructions on how to register, please visit www.tei.org/events. I hope you take maximum advantage of the scope, depth, and diversity of this year’s Audits & Appeals Seminars.

Regards,



C.N. (Sandy) Macfarlane TEI International President

Audits and Appeals Seminar Meeting the Tax Controversy Needs of In-House Tax Professionals

MONDAY, JUNE 13 (DAY 1) | BOSTON, MA *All Educational sessions today will be held in the Mann Ballroom 1-2.

8:15-9:00 am Registration & Continental Breakfast.........Mann Ballroom Foyer

9:00-9:15 am Welcome & Overview

Colleen Brown Barrick Gold Company Chair, IRS Administrative Affairs Committee

2:00-3:00 pm Developing Your Audit Management Strategy in the New Environment Matthew D. Lerner Sidley & Austin LLP Pamela F. Olson PricewaterhouseCoopers LLP

9:15-10:45 am The New LB&I Division and Examination Process: Structure & Function



3:00-3:15 pm Break

David B. Blair Crowell & Moring LLP



3:15-4:15 pm Facts and Fact-Finding

Erin M. Collins Thomas D. Greenaway KPMG LLP

Sheri A. Dillon Morgan, Lewis & Bockius LLP



Mark S. Mesler Ernst & Young LLP

10:45-11:00 am Break



11:00 am-Noon Pre-Transaction Documentation

4:15- 5:15 pm Getting Ready for Appeals

Diane S. Ryan Skadden, Arps, Slate, Meagher & Flom LLP Sheldon M. Kay Sutherland Asbill & Brennan LLP

Matthew D. Lerner Sidley & Austin LLP



5:15-6:15 pm Reception....................................Mann Ballroom 3

Pamela F. Olson PricewaterhouseCoopers LLP

Noon-1:45 pm Luncheon....................................Mann Ballroom 3

Lunch Speaker:

Erik H. Corwin KPMG LLP Former Deputy Chief Counsel (Technical) Internal Revenue Service

Planning Committee C.N. (Sandy) Macfarlane Chevron Corporation TEI’s International President

Eli J. Dicker Executive Director Tax Executives Institute

Colleen Brown Barrick Gold Corporation Chair, TEI’s IRS Administrative Affairs Committee

W. Patrick Evans Chief Tax Counsel Tax Executives Institute

Pilar Mata Tax Counsel Tax Executives Institute

1:00 – 2:15 pm

Breakout Sessions

11:30 am – 1:00 pm

11:15 – 11:30 am

Breakout Sessions

9:45 – 11:15 am

9:30 – 9:45 am

Breakout Sessions

8:00 – 9:30 am

7:00 – 8:00 am



Robert C. Morris Norton Rose Fulbright LLP

Kathryn Keneally DLA Piper LLP



Brian W. Kittle Mayer Brown LLP

Joseph M. DePew Sutherland Asbill & Brennan LLP

Wayne Hamilton, Moderator Wal-Mart Stores, Inc. Maryanne L. Knott, Moderator Dunkin’ Brands, Inc.



Is That What Your Protest Looks Like?

Nathan E. Clukey Abraham N.M. (Hap) Shashy King & Spalding LLP

Wayne Hamilton, Moderator Wal-Mart Stores, Inc.

So You Think You Can Negotiate – Getting to Closure

George A. Hani Kevin L. Kenworthy Miller & Chevalier

Privilege & Work Product – Selected Issues

Kathleen Pakenham Cooley LLP

George Abney Alston & Bird LLP

Timothy F. Wigon, Moderator Haemonetics Corporation

LUNCH | SPEAKER: JUDGE RONALD L. BUCH, U.S. TAX COURT . . . MANN BALLROOM 3

Michael P. Dolan Kimberly T. Majure KPMG LLP

Colleen C. Brown, Moderator Barrick Gold Company

CbyC Reporting: The Latest Information Reporting Challenge

BREAK

Michael P. Dolan Kimberly T. Majure KPMG LLP

Colleen C. Brown, Moderator Barrick Gold Company

CbyC Reporting: The Latest Information Reporting Challenge



Kevin M. Johnson Pepper Hamilton LLP





Dwight N. Mersereau Crowell & Moring LLP



Kathleen King Alvarez & Marsal Taxand LLP

Nancy W. Chassman Roberts & Holland LLP



“Litigation” as a Dispite Resolution Strategy

Karen E. Miller, Moderator FusionStorm

Doug Rodolph, Moderator Wal-Mart Stores, Inc.

SHUFFLE TIME

Information Document Requests Framing the Issues, Preparing the Responses

Managing & Resolving R&D & 199 Issues

Document Retention: What Should I Keep?

Sushil Pokharel, Moderator Capital One Financial Corporation

Smoot Room

Mann Ballroom 2

Mann Ballroom 1

REGISTRATION AND CONTINENTAL BREAKFAST . . .MANN BALLROOM FOYER

TUESDAY, JUNE 14 (DAY 2)| BOSTON, MA

Meeting the Tax Controversy Needs of In-House Tax Professionals

Audits and Appeals Seminar

Breakout Sessions

4:00 – 5:30 pm

3:45 – 4:00 pm

Breakout Sessions

2:15 – 3:45 pm

Nathan E. Clukey Abraham N.M. (Hap) Shashy King & Spalding LLP



George A. Hani Kevin L. Kenworthy Miller & Chevalier

Sushil Pokharel, Moderator Capital One Financial Corporation

Information Document Requests Framing the Issues, Preparing the Responses

SHUFFLE TIME

Wayne Hamilton, Moderator Wal-Mart Stores, Inc.



Christopher S. Rizek Caplin & Drysdale Chartered

Linda Galler Maurice A. Deane School of Law Hofstra University

Michael J. Bernard, Moderator Microsoft Corporation

Ethical Dilemmas in Tax Controversy Matters

Kevin M. Johnson Pepper Hamilton LLP

Nancy W. Chassman Roberts & Holland LLP

Doug Rodolph, Moderator Wal-Mart Stores, Inc.

Document Retention: What Should I Keep?

So You Think You Can Negotiate – Getting to Closure



Mann Ballroom 2

Mann Ballroom 1

TUESDAY, JUNE 14 (DAY 2, Continued)| BOSTON, MA

Meeting the Tax Controversy Needs of In-House Tax Professionals

Audits and Appeals Seminar

Larry A. Campagna Philip Karter Chamberlain, Hrdlicka, White, Williams & Aughtry

Colleen C. Brown, Moderator Barrick Gold Company

Managing Interview Requests – The Good, Bad & Ugly

Larry A. Campagna Philip Karter Chamberlain, Hrdlicka, White, Williams & Aughtry

Colleen C. Brown, Moderator Barrick Gold Company

Managing Interview Requests – The Good, Bad & Ugly

Smoot Room

Audits and Appeals Seminar Meeting the Tax Controversy Needs of In-House Tax Professionals

WEDNESDAY, JUNE 15 (DAY 3) | BOSTON, MA *All Educational sessions today will be held in the Mann Ballroom 1-2.

7:30-8:00 am Registration & Continental Breakfast.........Mann Ballroom Foyer

8:00-8:15 am Welcome & Introduction

Eli J. Dicker Executive Director Tax Executives Institute, Inc. 8:15-9:15 am Understanding the State Tax Controversy Lifecycle



1:15-2:15 pm Settlement Strategies: Getting to Yes!

Jonathan A. Feldman Leah M. Robinson Sutherland Asbill & Brennan LLP

2:15-2:30 pm Break

2:30-3:30 pm Coordinating Federal, State and Multistate Tax Audits and Controversies

Marc A. Simonetti Sutherland Asbill & Brennan LLP

Andrew D. Appleby Maria M. Todorova Sutherland Asbill & Brennan LLP

Pilar Mata Tax Executives Institute, Inc.

3:30-4:30 pm Industry Perspective of Managing Audits and Litigation

9:15-10:15 am Best Practices for Preparing and Managing State Tax Audits

Jeffrey A. Friedman, Moderator Sutherland Asbill & Brennan LLP

Madison J. Barnett Michele Borens Sutherland Asbill & Brennan LLP

Stephanie Anderson State Tax Counsel Amazon.com



10:15-10:30 am Break



10:30-11:45 am Best Practices for Protests and Litigation

Jen Galbreath Director, State and Local Tax Audits Comcast Corporation

Timothy A. Gustafson Carley A. Roberts Sutherland Asbill & Brennan LLP

Nick Kory Director and Senior Tax Counsel IBM Corporation

11:45 am-1:15 pm Lunch and State Tax Court Judge Panel................................Mann Ballroom 3

Jaimie Lee Indirect Tax Senior Manager Uber USA LLC

Pilar Mata, Moderator Tax Executives Institute, Inc. Thomas Hammond Chairman and Chief Administrative Hearing Officer Massachusetts Appellate Tax Board Roberta Moseley Nero President & Commissioner New York State Tax Tribunal Bill Thompson Chief Tax Tribunal Judge Alabama Tax Tribunal



GENERAL INFORMATION REGISTRATION

Detach and return completed registration form, along with remittance in U.S. funds to TEI, P.O. Box 9407, Uniondale, NY 11555-9407. Check or credit card information must accompany registration form. Photocopy form for additional registrants. 8 WEB: Go to www.tei.org. / MAIL: Send registration form with check or credit card information. 4 FAX: 202.638.5607. Credit card registrations only. VISA, MasterCard, American Express, Diners Club, and Discover accepted. Registration is limited to members of TEI and other in-house tax professionals. (Individuals engaged in private law, accounting, or other consulting practice are ineligible to attend). Registration forms without payment will not be processed by TEI. Please note: Membership in Tax Executives Institute is on an individual basis. There are no “company” or “corporate” memberships. Only members of the Institute — or individuals whose membership applications are pending at TEI — are entitled to the member rate. All others are required to pay at the nonmember rate. For membership information, visit the “Membership” section of www.tei.org. Enrollment is limited and registrations will be accepted on a first-come, first-served basis. Should maximum enrollment be reached prior to the seminar and TEI cannot accept your registration, you will be notified immediately. You will receive a confirmation by email; no other confirmation will be sent. Educational materials will be distributed electronically prior to the meeting. Seminar registrants should either down load materials to their laptop/tablet or print the handouts they will need onsite. All cancellations must be made in writing by 4:00 pm ET on May 23, 2016, and will be subject to an administrative service charge of $75 (U.S.); for cancellations after May 23, 2016 (the date handout materials

Questions? Call TEI at 202.638.5601 or visit the website at www.tei.org. Click on “Events & Education.”

become available) and before May 30, the charge will be $200 (U.S.). No refunds will be made for cancellations received after May 30 and for no-shows. To cancel please send an email [email protected]. In the event of cancellation or oversubscription of the conference, TEI’s liability is limited to the return of the registration fee. Financial Aid for Illinois Licensed Attorneys. Scholarships to defray tuition expense for this program are available for in-house tax professionals (both TEI members and nonmembers) who are temporarily unemployed and who are Illinois licensed attorneys with a demonstrated financial hardship. Scholarships will be reviewed and provided upon application on a case-by-case basis. Attorneys who qualify will receive at least a 50% reduction in the conference fee (which does not include any reduction or reimbursement for meals, lodging, or travel costs associated with the conference). To request information on whether you might qualify, please contact us at [email protected].

HOTEL RESERVATIONS

A block of rooms is being held at The Aloft Boston Seaport Hotel. Registrants are responsible for making their own reservations. Please telephone the hotel at (877) 462-5638, and identify yourself as a member of the Tax Executives Institute group. The room rate is $249 single/double, plus tax. TEI’s block of rooms will be released for sale to the public on May 22, 2016. Requests for accommodations after that date, or if the block sells out prior to May 22, cannot be ensured. Aloft Boston Seaport Hotel 401 D Street Boston, MA 02210 Questions? Call TEI at 202.638.5601 or visit the website at www.tei.org. Click on “Events & Education.”

CPE Credit Information Tax Executives Institute is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417. Website: www.nasba.org. For more information regarding administrative policies such as complaint or refund, please contact TEI directly at 202.638.5601. Date: June 13-15, 2016 Delivery Method: Group Live Program Level: Basic Field of Study: Taxes Learning Objectives: Designed to provide the tools and techniques to enable tax professionals to effectively manage federal and international tax controversies. Prerequisite: No prerequisites Advanced Preparation: No advance preparation required

Day 1-2 Credits CPE Credit: 16.5 credits based on a 50-minute hour CLE Credit: 14 credits based on a 60-minute hour Ethics Credit: 1.0 credits based on a 60-minute hour Day 3 Credits CPE Credit: 8.0 credits based on a 50-minute hour CLE Credit: 6.5 credits based on a 60-minute hour Tax Executives Institute and TEI Education Fund accord to participants of any race, color, creed, sex, or national ethnic origin all the rights, privileges, programs, and activities generally accorded or made available to participants at its program, courses, and other activities.

Boston, Massachusetts

Audits and Appeals Seminar Meeting the Tax Controversy Needs of In-House Tax Professionals

REGISTRATION FORM | June 13-15, 2016

BOSTON

Make checks payable to Tax Executives Institute. Fee covers course materials and other items specified in course announcement. Applications will be accepted on a first-come, first-served basis, and must be mailed to Tax Executives Institute, P.O. Box 9407, Uniondale, NY 11555-9407. Applicants are encouraged to register via www.tei.org. Do not mail applications to TEI’s street address. Credit card registrations may be faxed—see below. Questions? Call 202.638.5601. Name Nickname for Badge Your Title Company Mailing Address City

State/Province Fax

Telephone Email

♿■

Zip/Zone

Please check here if you require special accessibility or assistance at this function. We will contact you.

NOTE: Registrants may sign up for the core two-day program, the special one-day foreign audits program, or all three days.

Seminar

Boston

3-Day Registration - Federal and State Controversy (June 13-15)

q$

950 TEI Members

q $1,150

2-Day Registration - Federal Controversy only (June 13-14)

q$

700 TEI Members

q$

1-Day Registration - State Controversy only (June 15)

q$

400 Member/Non-Member

Charge to:

■ VISA

■ MasterCard



Card Number

■ American Express

Non-Members

800 Non-Members

■ Discover



■ Diners Club

Exp. Date

Signature Cardholder Name (print) If faxing your registration using a credit card, please do so between 9:00 a.m. and 4:00 p.m. ET to ensure confidentiality. Fax number for registrations and cancellations is 202.638.5607. All cancellations must be made in writing by 4:00 pm ET on May 23, 2016, and will be subject to an administrative service charge of $75 (U.S.); for cancellations after May 23, 2016 (the date handout materials become available) and before May 30, the charge will be $200 (U.S.). No refunds will be made for cancellations received after May 30 and for no-shows. To cancel please send an email [email protected]. In the event of cancellation or oversubscription of the conference, TEI’s liability is limited to the return of the registration fee. TEI’s Federal Taxpayer ID Number is 52-0239291. Note: There will be a $50 charge for substitutions (plus any fee differential). In accordance with section 274(n) of the Internal Revenue Code, registrants are notified that the portion of the seminar registration fee attributable to food and beverage is $315 (U.S.) for the 2-day program and is $400 (U.S.) for the 3-day program. AAS16-Bos