For interested readers, we have a number of speaking engagements approaching in the next couple of months.
- Tomorrow (March 23), I will be speaking with Ed Froelich (Morrison & Foerster) and Kristin Hickman (University of Minnesota) on a Strafford webinar about the impact of the Supreme Court’s decision in Mayo Foundation. We will be discussing not only the reasoning behind the decision and its implications for non-regulatory guidance but also specific considerations for taxpayers to deal with heightened deference to Treasury’s interpretations of the Internal Revenue Code.
- On April 11th, Phil Karter and I will be speaking at the Chicago Tax Club about how taxpayers are dealing with the codification of the economic substance doctrine. Specifically, we will explore the intersection of economic substance and transfer pricing disputes and why even taxpayers who don’t participate in traditional “tax shelters” need to assess their exposure to the possible application of the doctrine in their audits.
- On April 12th, I will be speaking in Chicago at the second installment of BNA-CITE’s newest program, Resolving IRS Tax Controversies. The program, which runs from April 11th to the 12th, will cover the entire spectrum of federal tax controversies, from pre-audit considerations to forum selection for litigation.
If any readers will be attending any of these programs, please let us know.