NEW YORK UNIVERSITY School of Continuing and Professional Studies division of programs in business SUMMER INSTITUTE IN TAXATION JULY 14–25, 2008 THE WESTIN NEW YORK Introduction to International Taxation* July 14–16, 2008 Advanced International Taxation July 17–18, 2008 Introduction to Trusts and Estates* July 14–16, 2008 Institute on Federal Wealth Taxation July 17–18, 2008 Introduction to State and Local Taxation* July 21–23, 2008 State and Local Taxation II July 24–25, 2008 Introduction to Partnerships* July 21–23, 2008 Introduction to Consolidated Returns* July 23–25, 2008 *These courses are available for transitional credit. Look inside for details. WWW.SCPS.NYU.EDU/SUMTAX Administration Robert Lapiner, Ph.D. Dean School of Continuing and Professional Studies Anthony Davidson, Ph.D. Divisional Dean and Clinical Professor Division of Programs in Business John Gamino, J.D., LL.M., CPA Academic Chair and Clinical Assistant Professor Department of Accounting, Taxation, and Legal Programs Kathleen Costello, CMP Assistant Director Department of Accounting, Taxation, and Legal Programs Sponsors New York University thanks the following organizations for their contribution to the enhancement and continued success of the Summer Institute in Taxation: New York University is an affirmative action/equal opportunity institution. summer institute in taxation July 14–25, 2008 WHY NYU? New York University has been a leader in continuing professional education for more than 70 years. We have a unique ability to blend the scholarly resources of the university with the practical know-how of the world-class professional community that surrounds us. Our longstanding tradition of excellence in continuing legal, accounting, and financial programs means that we attract the best and brightest to our faculty of speakers. As an educational institution, we are committed to providing the highest quality learning experience for our participants. WHO SHOULD ATTEND? Our intensive tax conferences are ideal for the new professional who wants a solid foundation in a specialized area of law or tax practice. Practicing attorneys and accountants attend to refresh their knowledge and learn about new developments in legislation and regulations. Attend the introductory conferences and acquire critical new skills and practical knowledge you can use immediately. Attend the intermediate/advanced conferences and receive a high-level update and in-depth analysis of the latest trends and developments. CONTINUING EDUCATION CREDIT In addition to meeting the educational requirements of many organizations and agencies, the introductory conferences are also available for New York transitional Continuing Legal Education (CLE) credit for newly admitted attorneys. These programs continue to be open to experienced attorneys and accountants seeking to refresh their practice skills or develop new ones. See the “General Information” section at the end of this brochure for more details. LEARNING OBJECTIVES/PROGRAM LEVELS/PREREQUISITES See individual conference agendas for learning objectives, program levels, and prerequisites. INSTRUCTIONAL METHOD Group Live. ADVANCED PREPARATION None. CONFERENCE LOCATION AND ACCOMMODATIONS All of the conferences will be held at The Westin New York at Times Square, a state-of-the-art conference facility in the heart of the theater district. We have arranged a group rate of $329. See the “General Information” section at the end of this brochure for more details. New York University reserves the right to change, with or without notice, any statement in this brochure concerning, but not limited to, rules, policies, tuition, fees, curriculum, courses, and programs. for more information, call (212) 992-3320 1 introduction to international taxation july 14–16, 2008 Chair: William B. Sherman, Esq., partner, Holland & Knight LLP, Fort Lauderdale, FL day 1 8.30–8.45 a.m. Introduction and Overview William B. Sherman, Esq., partner, Holland & Knight LLP, Fort Lauderdale, FL 8.45–10 a.m., 10.15 a.m.–12 noon U.S. Taxation of Foreign Persons 10–10.15 a.m. Refreshment Break 12 noon–1.15 p.m. Lunch Recess 1.15–2.15 p.m. Pre-Immigration Planning and Ethical Issues in Representing the Foreign Individual Source of income; U.S. trade or business; effectively connected income; FDAP income; withholding taxes; FIRPTA; branch profits tax; branch level interest tax; earnings stripping; anti-conduit financing. Hope P. Krebs, Esq., partner, Duane Morris LLP, Philadelphia, PA Kevin E. Packman, Esq., senior associate, Holland & Knight LLP, Miami, FL 2.15–3.15 p.m. State and Local Issues for Multinationals Intragroup transfers; unitary tax issues; treaty issues; financing and other planning opportunities. Alvan L. Bobrow, Esq., partner, Hodgson Russ LLP, New York, NY 3.15–3.30 p.m. Refreshment Break 3.30–4.30 p.m. Tax Treaty Primer—An Overview of Tax Treaty Planning Techniques Lawrence A. Pollack, Esq., partner, KPMG LLP, New York, NY day 2 8.30–10 a.m. Section 367 Michael J. Miller, Esq., partner, Roberts & Holland LLP, New York, NY 10–10.15 a.m. Refreshment Break 10.15 a.m.–12 noon Transfer Pricing General rules of Section 482; transfers of tangible and intangible property; services and loans; economic analysis; correlative relief; APAs; cost sharing agreements. Marc M. Levey, Esq., partner, Baker & McKenzie LLP, New York, NY 12 noon–1.15 p.m. Lunch Recess 1.15–3 p.m., 3.15–4.30 p.m. Direct and Indirect Foreign Tax Credit and Foreign Tax Credit Limitation Sections 901, 902, and 904. Richard E. Andersen, Esq., partner, Arnold & Porter LLP, New York, NY 3–3.15 p.m. Refreshment Break day 3 8.30–10.15 a.m., 10.30 a.m.–12 noon 10.15–10.30 a.m. 2 Subpart F Definition of CFC; subpart F income; exceptions and limitations on subpart F income; Section 956; distributions of previously taxed income. William B. Sherman, Esq., partner, Holland & Knight LLP, Fort Lauderdale, FL William L. Bricker, Jr., Esq., partner, Curtis, Mallet-Prevost, Colt & Mosle LLP, New York, NY Refreshment Break to register, visit www.scps.nyu.edu/sumtax 12 noon–1.15 p.m. Lunch Recess 1.15–2.15 p.m. Passive Foreign Investment Companies Hope P. Krebs, Esq., partner, Duane Morris LLP, Philadelphia, PA 2.15–3.15 p.m., 3.30–4.30 p.m. Case Studies for Outbound and Inbound Investment 3.15–3.30 p.m. Refreshment Break 4.30 p.m. Conference Concludes William B. Sherman, Esq., partner, Holland & Knight LLP, Fort Lauderdale, FL Michael J. Miller, Esq., partner, Roberts & Holland LLP, New York, NY Alan I. Appel, Esq., counsel, Bryan Cave LLP, New York, NY learning objectives On completing this program, you acquire a broad-based foundation in the federal income taxation of cross-border (both “inbound” and “outbound”) transactions and circumstances. In particular, you gain exposure to: • The relationship between income tax treaties and the Internal Revenue Code generally, including the standard subject-matter coverage of such treaties and when and how treaties override Code provisions • The basics of transfer pricing, including a comparison of U.S. transfer pricing rules to those of other countries and the mechanisms for addressing conflicts • The nature and application of withholding taxes and other “toll charges” on the movement of money and property across borders • U.S. compliance and reporting issues faced as a result of doing business globally, include Subpart F and foreign tax credit rules Program Level: Basic Prerequisite: None advanced international taxation july 17–18, 2008 Chair: William B. Sherman, Esq., partner, Holland & Knight LLP, Fort Lauderdale, FL day 1 8.30–8.45 a.m. Introduction and Overview William B. Sherman, Esq., partner, Holland & Knight LLP, Fort Lauderdale, FL 8.45–10 a.m. International Tax Issues in Private Equity Peter A. Glicklich, Esq., partner, Davies Ward Phillips & Vineberg LLP, New York, NY 10–11 a.m. Cross Border Real Estate Investing: Partnership and Other Traps, Opportunities, and Ethical Considerations Alan I. Appel, Esq., counsel, Bryan Cave LLP, New York, NY Michael Hirschfeld, Esq., partner, Dechert LLP, New York, NY 11–11.15 a.m. Refreshment Break 11.15 a.m.– 12.15 p.m. Foreign Tax Credit Planning Techniques and Recent Issues 12.15–1.30 p.m. Lunch Recess 1.30–2.30 p.m. Foreign Currency Transactions—Opportunities and Risks This session addresses how companies are contemplating restructuring to address the new rules. In addition, U.S. level planning, e.g., minimizing expense apportionment against foreign source income, is discussed. Donald V. Proper, Esq., partner, Ernst & Young LLP, New York, NY Andrea S. Kramer, partner, McDermott Will & Emery LLP, Chicago, IL for more information, call (212) 992-3320 3 2.30–3.15 p.m. Developments in the IRS Attack on “Foreign Tax Credit Arbitrage” Diana L. Wollman, Esq., partner, Sullivan & Cromwell LLP, New York, NY S. Eric Wang, Esq., associate, Sullivan & Cromwell LLP, London, UK 3.15–3.30 p.m. Refreshment Break 3.30–4.30 p.m. Tax Treaty Developments Richard E. Andersen, Esq., partner, Arnold & Porter LLP, New York, NY day 2 8.30–10 a.m. International Mergers and Acquisitions Planning Techniques William S. Dixon, Esq., managing director, mergers and acquisitions, Citigroup Global Markets, Inc., New York, NY Stephen E. Shay, Esq., partner, Ropes & Gray LLP, Boston, MA 10–10.15 a.m. Refreshment Break 10.15–11.15 a.m. Foreign Hybrid Entities—Overview and Update on U.S. Deferral Planning Techniques Lawrence A. Pollack, Esq., partner, KPMG LLP, New York, NY 11.15 a.m.– 12.15 p.m. UK and European Union Tax Update Jonathan Fox, head of international tax services, Northern Europe, Middle East, India, and Africa, Ernst & Young LLP, New York, NY 12.15–1.30 p.m. Lunch Recess 1.30–3 p.m. Use of Derivatives in International Tax Planning Jeffrey L. Rubinger, Esq., partner, Holland & Knight LLP, Fort Lauderdale, FL Mark H. Leeds, Esq., shareholder, Greenberg Traurig, LLP, New York, NY 3–4 p.m. Tax Planning for Intangibles/Focus on Marketing Intangibles and Cost Sharing Philip W. Carmichael, M.B.A., director of economics, Baker & McKenzie Consulting LLC, New York, NY Steven C. Wrappe, Esq., partner, Ernst & Young LLP, Washington, D.C. 4 p.m. Conference Concludes learning objectives On completing this program, you acquire sophisticated knowledge with respect to “hot button” issues and opportunities in international taxation such as: • Planning and pitfalls applicable to doing business globally, including the use of hybrid U.S. and foreign entities and investment structures • Foreign tax credit and other strategies for avoiding the double taxation of repatriated and non-repatriated foreign earnings • Foreign currency translation and transactions, including both investment and “trade or business” rules and applications • Foreign investment in U.S. real property and U.S. taxpayers’ investments in foreign real estate • Transfer pricing strategies involving intangible assets and services Program Level: Update Prerequisite: Knowledge of international taxation 4 to register, visit www.scps.nyu.edu/sumtax introduction to trusts and estates july 14–16, 2008 Chair: Joseph P. Scorese, Esq., partner, Harwood Lloyd LLC, Hackensack, NJ day 1 8.30–8.45 a.m. Introduction and Overview Joseph P. Scorese, Esq., partner, Harwood Lloyd LLC, Hackensack, NJ 8.45–9.45 a.m. Estate Taxes I: Understanding the Tax and the Gross Estate Tax rates and credits; definition of gross estate; powers of appointment; life insurance; joint interests; transfer with retained life estates. Mitchell A. Drossman, Esq., CPA, national director of wealth planning strategies, U.S. Trust, Bank of America Private Wealth Management, New York, NY 9.45–10.45 a.m. Estate Taxes II: Spousal Transfers and Credits Marital deduction rules in general; QTIP Trust; Qualified Domestic Trust; unified credit; credit for tax on prior transfers. Darren M. Wallace, Esq., counsel, Day Pitney LLP, Stamford, CT 10.45–11 a.m. Refreshment Break 11 a.m.–12 noon Estate Taxes III: Important Deductions Expenses of administration, indebtedness, and taxes; charitable transfers. Susan R. Schoenfeld, Esq., CPA, principal and associate fiduciary counsel, Bessemer Trust Company, N.A., New York, NY 12 noon–1 p.m. Lunch Recess 1–2.15 p.m. Estate Taxes IV: Valuation Issues That Drive the Wealth Tax Fair market value as applied to transfer taxes; asset valuations in general; closelyheld business valuation issues; family limited partnerships valuation discounts and abuses; Chapter 14 and the special valuation rules. John M. Olivieri, Esq., partner, White & Case LLP, New York, NY 2.15–2.30 p.m. Refreshment Break 2.30–4.30 p.m. Estate Taxes V: Filing the Return and Surviving the Audit Procedure and administration; returns, audit, and post-audit controversies; liability for tax; recovery rights; moot estate tax audit. Dean L. Surkin, Esq., principal, Rosen Seymour Shapss Martin & Co., New York, NY day 2 8.30–8.45 a.m. “Re-Group and Redux” Joseph P. Scorese, Esq., partner, Harwood Lloyd LLC, Hackensack, NJ 8.45–10.30 a.m. Lifetime Transfers and the Federal Gift Tax Completed gifts; deductions; annual exclusions; Crummey trusts; valuation rules; disclaimers; powers of appointment. Catherine G. Schmidt, Esq., partner, Patterson Belknap Webb & Tyler LLP, New York, NY 10.30–10.45 a.m. Refreshment Break 10.45 a.m.–12 noon An Introduction to State Death Taxes “De-coupled” state estate taxes; state inheritance taxes; planning considerations. Laura A. Kelly, Esq., partner, McCarter & English, LLP, Newark, NJ 12 noon–1 p.m. Lunch Recess 1–3 p.m. Income Taxation of Trusts, Estates and Beneficiaries Introduction to federal fiduciary income tax concepts; taxable income and rates; distributable net income (DNI); grantor trusts; income in respect of a decedent; basis of assets in the hands of beneficiaries; capital gains taxes; principal and income issues in fiduciary taxation. Sharon L. Klein, Esq., senior vice president, trust counsel and director of estate advisement, Fiduciary Trust Company International, New York, NY Craig S. Richards, CPA/PFS, CFP, senior vice president and director of tax services, Fiduciary Trust Company International, New York, NY for more information, call (212) 992-3320 5 3–3.15 p.m. Refreshment Break 3.15–4.30 p.m. Post Mortem Estate Planning Executor’s elections in general; fiscal year election and IRC §645 election; uses of alternate valuation; filing extensions and deferrals of payment of estate tax; income vs. estate tax deductions; strategic wealth planning for survivors; interaction between income and estate tax elections for the decedent and his/her estate. Michael M. Mariani, Esq., senior vice president, deputy general trust counsel and director of trust and estate services, Fiduciary Trust Company International, New York, NY day 3 8.30–8.45 a.m. “Re-Group and Redux” Joseph P. Scorese, Esq., partner, Harwood Lloyd LLC, Hackensack, NJ 8.45–10.15 a.m. Estate and Gift Tax Planning for Non-Resident Aliens Estate and gift tax; foreign trust taxation; planning for U.S. assets and for U.S. beneficiaries. Gideon Rothschild, Esq., partner, Moses & Singer LLP, New York, NY 10.15–10.30 a.m. Refreshment Break 10.30 a.m.–12 noon Multi-Generational Planning and the Generation-Skipping Transfer Tax Tax imposed, definition of generation-skipping transfer; allocation of GST exemption; inclusion ratio, generation assignment, effective planning techniques, utilizing exemptions and exclusions including use of dynasty trusts. Joseph P. Scorese, Esq., partner, Harwood Lloyd LLC, Hackensack, NJ 12 noon–1 p.m. Lunch Recess 1–2.30 p.m. Estate and Tax Planning for Qualified Plan and IRA Distributions Estate and income tax impact of beneficiary designations. Brad J. Richter, Esq., partner, Fried, Frank, Harris, Shriver & Jacobson LLP, New York, NY 2.30–2.45 p.m. Refreshment Break 2.45–4 p.m. Executive Compensation and Life Insurance Estate planning strategies for corporate executives. Robert K. Barbetti, Esq., managing director, advice lab, JP Morgan Private Bank, New York, NY 4–4.30 p.m. Wrap-Up 4.30 p.m. Conference Concludes learning objectives On completing this program, you acquire an understanding of the varieties of taxes and tax issues applicable to gratuitous transfers by individuals and trusts and estates: • The fundamentals of the estate tax, gift tax, and generation-skipping transfer tax are explored, including inclusions and exclusions, common valuation issues, and typical resolutions • Where and how the liability for the estate tax is handled both as a compliance matter and as a matter of the impact of the tax on estate assets and distributions • The ancillary impact of the estate tax rules including basis rules applicable to assets distributed from the estate to beneficiaries • The basics and differences in planning before and after death with emphasis on the relationship of the gift tax to the estate tax and planning opportunities involving spouses and family members Program Level: Basic Prerequisite: None 6 to register, visit www.scps.nyu.edu/sumtax institute on federal wealth taxation july 17–18, 2008 Chair: Jerald David August, Esq., partner, Fox Rothschild LLP, West Palm Beach, FL and Philadelphia, PA day 1 9–10.30 a.m. Update on Family Limited Partnerships and Litigation Strategies by the Internal Revenue Service This session explores the set of recent circuit courts decisions and those of the Tax Court that have addressed the meaning of the bona fide sale parenthetical to the “string provisions,” as well as the application of the Byrum principle to family limited partnerships. Jerald David August, Esq., partner, Fox Rothschild LLP, West Palm Beach, FL and Philadelphia, PA Guy B. Maxfield, Esq., senior counsel, Fox Rothschild LLP, West Palm Beach, FL 10.30–10.45 a.m. Refreshment Break 10.45 a.m.–12 noon Estate Planning for Privately Owned Business Including Generational Planning A discussion of estate planning techniques for owners of privately owned businesses operated as partnerships, limited liability companies, and S corporations, including outright gifts, preferred interest freezes, GRATs, installment sales, SCINS, private annuities, and the use of defective grantor trusts with one or more of these techniques to transfer ownership and control of the closely-held business to the next generation. C. Wells Hall, III, Esq., partner, Mayer Brown LLP, Charlotte, NC 12 noon–1.15 p.m. Lunch Recess 1.15–2.45 p.m. Selected Topics in Generation-Skipping Transfer Tax Planning: Special Rules on GST Exemption Allocation; Protecting Grandfathered Trusts, Dynasty Trust Planning, and Other Specific GST Trust Applications This presentation reviews the rules governing allocation of the GST exemption, including the timing of allocations and computation of inclusion ratios; rules governing automatic and deemed allocations; identification of situations where GST allocations were missed or improperly made, and understanding the special rules permitting late allocations of GST exemption, including Section 9100 relief. The speaker also discusses permissible transactions with GST “grandfathered” trusts, GST considerations in structuring dynasty trusts, allocation of GST exemption to ILITs and other “Crummey” trusts, and the interplay of the GST tax and charitable giving. Douglas L. Siegler, Esq., partner, Sutherland Asbill & Brennan LLP, Washington, D.C. 2.45–3 p.m. Refreshment Break 3–4.30 p.m. Recent Cases and Developments in Fiduciary Administration The challenges of fiduciary administration have become more complex and errors come with a higher price tag than ever before. This session focuses on several areas of particular difficulty: business interests held in a trust or estate; recent changes that affect administration of charitable entities and philanthropic planning; tax planning, and investment management, with a focus on recent litigation. The presentation also looks at changes in the industry as a result of changing demographics, evolving client expectations, and increased financial uncertainty. This review helps the professional advisor identify and respond to concerns of (1) individual clients concerned about wealth management and intra-generational planning; (2) fiduciaries, whether professional or family, seeking advice on effective administration; and (3) trust and estate beneficiaries. Jo Ann Engelhardt, Esq., managing director, Bessemer Trust, Palm Beach, FL for more information, call (212) 992-3320 7 day 2 9–10.15 a.m. Selected Post-Mortem Income Tax Planning Techniques for Partners and Shareholders Although estate planners generally do not want to get involved in income tax issues, there are many income tax traps in the administration of estates which they should be aware of to better serve their clients. This session covers which entities are taxed on the income from flow through entities for the year in which death occurs, S qualification issues respecting trusts, optional adjustment to basis issues, income tax issues on sales and redemptions of interests after death, income in respect of decedent issues, and gain recognition issues on satisfaction of bequests, among others. Robert R. Casey, Esq., partner, Jones, Walker, Waechter, Poitevnet, Carrère & Denègre, L.L.P., Baton Rouge, LA 10.15–10.30 a.m. Refreshment Break 10.30 a.m.–12 noon Estate Planning for Owners of Real Estate The panel considers the management and ownership of a real estate entrepreneur’s assets in ways best attuned to minimizing estate and gift taxes. The discussion includes forms of ownership, business succession concerns, gifting and/or sales techniques that are particularly well-suited for real estate holdings and methods of providing for the payment of estate and gift taxes in the most cost efficient ways. Stefan F. Tucker, Esq., partner, Venable LLP, Washington, D.C. Mary Ann Mancini, Esq., partner, Bryan Cave LLP, Washington, D.C. 12 noon–1.15 p.m. Lunch Recess 1.15–2.15 p.m. Should the Existing Estate Tax be Replaced by an Accession Tax? The accessions tax is a tax on the cumulative lifetime gratuitous receipts of a person. The accessions tax is politically less vulnerable than an estate tax and offers vast simplification advantages over the existing system, which is beyond any possibility of serious reform. Joseph M. Dodge, Esq., professor of law, Florida State University College of Law, Tallahassee, FL 2.15–3.15 p.m. Planning in Contemplation of Estate Tax Reform This session discusses a brief history of the evolution of the estate tax and an examination of the specific provisions of estate tax reform bills which narrowly failed over the last three years. Particular emphasis is given to the operation of, and planning options related to, the proposed new “portability” of the estate tax exemption to a surviving spouse. Louis Nostro, Esq., partner, Shutts & Bowen LLP, Miami, FL 3.15–3.30 p.m. Refreshment Break institute on federal wealth taxation board of directors Farhad Aghdami, Esq., partner, Williams Mullen, Richmond, VA Jerald David August, Esq., partner, Fox Rothschild LLP, West Palm Beach, FL and Philadelphia, PA Victoria B. Bjorklund, Esq., partner, Simpson Thacher & Bartlett LLP, New York, NY Jonathan G. Blattmachr, Esq., partner, Milbank, Tweed, Hadley & McCloy LLP, New York, NY Robert R. Casey, Esq., partner, Jones, Walker, Waechter, Poitevnet, Carrère & Denègre, L.L.P., Baton Rouge, LA 8 Jo Ann Engelhardt, Esq., managing director, Bessemer Trust, Palm Beach, FL Guy B. Maxfield, Esq., senior counsel, Fox Rothschild LLP, West Palm Beach, FL C. Wells Hall, III, Esq., partner, Carlyn S. McCaffrey, Esq., Mayer Brown LLP, Charlotte, NC partner, Weil, Gotshal & Manges LLP, New York, NY T. Randolph Harris, Esq., partner, McLaughlin & Stern, LLP, New York, NY Douglas L. Siegler, Esq., partner, Sutherland Asbill & Brennan LLP, Washington, D.C. Edward F. Koren, Esq., partner, Holland & Knight LLP, Tampa, FL Barbara A. Sloan, Esq., partner, Robert C. Lawrence, III, Esq., McLaughlin & Stern, LLP, partner, Cadwalader, Wickersham New York, NY & Taft LLP, New York, NY John R. MacDonald, CPA, partner, compensation & benefits, Smart and Associates LLP, Portland, OR John B. Stine, II, Esq., partner-in-charge, tax services, Smart and Associates LLP, Devon, PA To register, visit www.scps.nyu.edu/sumtax 3.30–5 p.m. Panel Discussion: Ethical Standards of Tax Practice for Estate Planners and Tax Advisors; Circular 230, Revisions to the Tax Return Preparer Rules and Conflicts of Interests The panel discusses the impact of the revised Tax Return Preparer rules and guidelines on estate planners and tax advisors in general. The current rules pose ethical issues for practitioners in advising clients. The guidelines further effect the standards of practice before the IRS under Circular 230. Jerald David August, Esq., partner, Fox Rothschild LLP, West Palm Beach, FL and Philadelphia, PA Guy B. Maxfield, Esq., senior counsel, Fox Rothschild LLP, West Palm Beach, FL Stefan F. Tucker, Esq., partner, Venable LLP, Washington, D.C. 5 p.m. Conference Concludes learning objectives On completing this program, you move beyond the basics of the taxation of trusts and estates to more sophisticated planning opportunities and pitfalls, such as: • The use of family limited partnerships and the issues of principal focus from the perspective of the Internal Revenue Service • Succession planning with respect to family-owned businesses • Post-mortem planning opportunities and obstacles • The generation-skipping tax and planning opportunities applicable to multi-generation giving • Issues of fiduciary obligation and administration, including ethical and practice issues unique to professionals representing individuals in their planning for, or dealing with, trusts and estates Program Level: Update Prerequisite: Knowledge of the taxation of trusts and estates Tax Conference Preview 67TH INSTITUTE ON FEDERAL TAXATION October 19–24, 2008, The Grand Hyatt, New York, NY November 9–14, 2008, The Hotel del Coronado, San Diego, CA Co-Chairs: Lewis R. Steinberg, Esq., global head of the Strategic Solutions Group; managing director, investment banking, UBS Securities LLC, New York, NY Pamela F. Olson, Esq., partner, Skadden, Arps, Slate, Meagher & Flom LLP, Washington, D.C. For hundreds of tax practitioners, the NYU Institute on Federal Taxation is the event of the year. The Institute is designed for the practitioner who must frequently anticipate and handle federal tax matters. It provides high-level updates, practical advice you can implement, and in-depth analysis of the latest trends and developments from leading experts. Participants return to work with a wealth of materials, plus the tools and strategies needed to help save their clients’ tax dollars and provide them with better service. A six-day program encompasses all major areas of tax, including current developments; tax controversies; corporate tax; partnerships, LLCs, and real estate; trusts and estates; executive compensation and employee benefits; closely-held businesses; international tax; ethical transactions; and hot tax topics. The Institute attracts attorneys, both general tax practitioners and specialists; accountants; corporate treasury and compliance executives; tax managers; and financial planners seeking expert discussion of the latest technical, legislative, and planning developments. Just as important, the Institute provides the perfect setting to meet practitioners from around the country. It’s an opportunity for you to share ideas, exchange views, learn what others are doing, and obtain credit for continuing education. www.scps.nyu.edu/ift for more information, call (212) 992-3320 9 introduction to state and local taxation july 21–23, 2008 Chair: Arthur R. Rosen, Esq., partner, McDermott Will & Emery LLP, New York, NY day 1 8.30–10 a.m., 10.15 a.m.–12 p.m., 1–2.15 p.m., 2.30–4.30 p.m. Federal Constraints on State and Local Taxation Historical foundations; jurisdictional issues; operational vs. nonoperational income; P.L. 86-272. Arthur R. Rosen, Esq., partner, McDermott Will & Emery LLP, New York, NY David A. Fruchtman, Esq., of counsel, Horwood Marcus & Berk Chartered, Chicago, IL 10–10.15 a.m. Refreshment Break 12 noon–1 p.m. Lunch Recess 2.15–2.30 p.m. Refreshment Break day 2 8.30–10 a.m., 10.15 a.m.–12 p.m., 1–2.15 p.m., 2.30–4.30 p.m. Corporate Income and Franchise Taxation 10–10.15 a.m. Refreshment Break 12 noon–1 p.m. Lunch Recess 2.15–2.30 p.m. Refreshment Break Unitary business; UDITPA; combined reporting; allocation and apportionment; corporate acquisitions and reorganizations; S corporations; unique state taxing schemes. Arthur R. Rosen, Esq., partner, McDermott Will & Emery LLP, New York, NY William M. Backstrom, Jr., Esq., partner, Jones Walker L.L.P., New Orleans, LA Charles J. Moll, III, Esq., partner, Winston & Strawn LLP, San Francisco, CA day 3 8.30–10 a.m., 10.15 a.m.–12 p.m., 1–2.15 p.m., 2.30–4.30 p.m. Sales and Use Taxation 10–10.15 a.m. Refreshment Break 12 noon–1 p.m. Lunch Recess 2.15–2.30 p.m. Refreshment Break 4.30 p.m. Conference Concludes Underlying principles; destination issues; services; audits; bulk sales; special transactions. Albert H. Cornell, Jr., CPA, director, PricewaterhouseCoopers LLP, Charlotte, NC Todd Lard, Esq., general counsel, Council On State Taxation, Washington, D.C. Jill D. Nielsen, CPA, director, PricewaterhouseCoopers LLP, Chicago, IL learning objectives On completing this program, you acquire a broad-based foundation in state and local taxation, as well as a basis for comparing and contrasting the various states’ systems of taxation with each other and the Internal Revenue Code: • Constitutional limitations on the ability of states to tax kinds of income and categories of taxpayers generally • The essentials of multistate income taxation including allocation and apportionment of income with respect to taxpayers with residence or operations in more than one state • The essentials and principles of non-income based taxes with emphasis on sales and use taxes Program Level: Basic Prerequisite: None 10 to register, visit www.scps.nyu.edu/sumtax state and local taxation ii july 24–25, 2008 Chair: Arthur R. Rosen, Esq., partner, McDermott Will & Emery LLP, New York, NY day 1 8.30–10 a.m., 10.15 a.m.–12 noon Mergers, Acquisitions, and Dispositions This session focuses on minimizing risks and deriving tax benefits from acquisition and restructuring transactions. The panel explores the state income and sales and use tax aspects of mergers, acquisitions, and other restructuring models. Peter L. Faber, Esq., partner, McDermott Will & Emery LLP, New York, NY Susan K. Haffield, CPA, partner, PricewaterhouseCoopers LLP, Minneapolis, MN Beth Ann Kendzierski, CPA, director, tax, Apria Healthcare, Inc., Lake Forest, CA 10–10.15 a.m. Refreshment Break 12 noon–1 p.m. Lunch Recess 1–3 p.m. In-Depth Review of Significant Apportionment Factor Issues An intensive study and discussion of payroll, property, and receipts factors, examining issues such as throwback and throwout (e.g., Joyce, Finnegan, Brown), assigning receipts from performing services and from holding intangibles, assigning receipts from dock sales and drop shipments, utilizing gross receipts or net gains. Joseph X. Donovan, Esq., counsel, Sullivan & Worcester LLP, Boston, MA Philip M. Zinn, SALT–national practice leader, PricewaterhouseCoopers LLP, Chicago, IL Margaret C. Wilson, Esq., assistant general counsel, state and local tax, Verizon, Basking Ridge, NJ 3–3.15 p.m. Refreshment Break 3.15–4 p.m. The Use (and Misuse) of Discretionary Authority State taxing agencies often are given grants of discretionary authority in connection with various statutes. A taxpayer may request the use of discretionary authority to shield it from otherwise inequitable tax consequences, such as to grant an application for special apportionment or waiver of a penalty. Conversely, a taxing agency may use its discretionary authority as a sword (e.g., to redetermine or reallocate income in a manner that leads to an increased tax liability). This session explores the boundaries of discretionary authority and examines various instances in which a state taxing agency has used, or misused, such authority. Mary T. Benton, Esq., partner, Alston & Bird LLP, Atlanta, GA Ronald I. Heller, Esq., director, Torkildson, Katz, Moore & Hetherington AAL, ALC, Honolulu, HI day 2 8.30–9.45 a.m. The View of the State Tax World From the Revenue Department Perspective State tax officials offer their views on the attitude and practices of their staffs, on how they interface with corporate tax managers and tax practitioners, and on how tax managers and tax practitioners can better deal with those in state revenue departments. Moderator: Kimberley M. Reeder, Esq., principal, KPMG LLP, Mountain View, CA Kurt Kawafuchi, Esq., CPA, director of taxation, State of Hawaii Department of Taxation, Honolulu, HI Joe Huddleston, Esq., executive director, Multistate Tax Commission, Washington, D.C. Selvi Stanislaus, Esq., executive officer, State of California Franchise Tax Board, Rancho Cordova, CA 9.45–10 a.m. Refreshment Break for more information, call (212) 992-3320 11 10–11 a.m. Challenges to Statutory Add-Back Provisions This session provides a historical overview of state add-back statutes, a discussion of the numbers and structures of existing add-back provisions, and the types of federal and state constitutional and other challenges that taxpayers can and have used against their imposition, including an in-depth discussion of the recent challenge to Alabama’s add-back statute at the circuit court level in VFJ Ventures, Inc. v. Commissioner of the Department of Revenue et al., Docket No. CV-03-3172 (Alabama Circuit Court, January 24, 2007). Christopher R. Grissom, Esq., partner, Bradley Arant Rose & White LLP, Birmingham, AL David J. Shipley, Esq., special counsel, McCarter & English, LLP, Philadelphia, PA 11 a.m.–12 noon Business or Non-Business Income: The Cessation of Business Exception This session focuses on a controversial topic: In those states that adopt the UDITPA definition of “business income,” assuming that this definition provides a functional test as well as a transactional test, does that functional test include an inquiry into the nature of the disposition of the asset (the “disposition inquiry,” sometimes referred to as the “cessation of business exception”)? Janette M. Lohman, Esq., CPA, partner, Thompson Coburn LLP, St. Louis, MO Jane W. May, Esq., partner, McDermott Will & Emery LLP, Chicago, IL David A. Hughes, Esq., partner, Horwood Marcus & Berk Chartered, Chicago, IL 12 noon–1 p.m. Lunch Recess 1–2 p.m. Confidentiality Under FIN 48 and Related Issues They can’t always get what they want! And if you try sometimes, you just might find, you keep what you need! A discussion of “privilege,” work product, and other protections for use in ethically shielding corporate documents from the prying eyes of federal and state tax auditors. William Townsend, Esq., shareholder, Fowler White Boggs Banker, Tallahassee, FL Leah Samit, Esq., attorney, McDermott Will & Emery LLP, New York, NY 2–2.45 p.m. Federal Legislative Activity Directly Affecting State Taxation The number of bills that Congress is being asked to enact that directly affect state and local taxation increases every year. Why is this? Should Congress be more active in this area? Should any of the specific bills (which affect income/franchise taxes, sales taxes, withholding taxes, communications taxes, etc.) be enacted? Will any of them be enacted? Arthur R. Rosen, Esq., partner, McDermott Will & Emery LLP, New York, NY Jeffrey S. Reed, Esq., attorney, McDermott Will & Emery LLP, New York, NY 2.45–3 p.m. Refreshment Break 3–4 p.m. The Move Away From Income-Based Taxes There is an emerging trend among states to replace the traditional net income tax base for businesses with gross receipts-type taxes, e.g., the Ohio Commercial Activity Tax (“CAT”). This presentation focuses on the impact this trend could have on businesses, their tax planning, and financial policy decisions. Joey Gigliotti, senior director, taxes, Marsh & McLennan & Companies, Inc., Hoboken, NJ Michael J. Guerriero, Esq., partner, Day Pitney LLP, Morristown, NJ 4 p.m. Conference Concludes learning objectives On completing this program, you reach and are exposed to the full range of cutting-edge issues in state and local taxation including: • Corporate and business franchise taxes including both traditional income approaches and more recent moves toward gross receipts and other “alternative” tax bases • Sophisticated planning and enforcement issues in multistate allocation and apportionment • Federal oversight and legislative initiatives directed at defining and enforcing the boundaries between federal and state taxing authority as well as the rights and limitations applicable to states as among themselves • Planning for and around the state and local tax impact with respect to material business transactions Program Level: Intermediate Prerequisite: Basic knowledge of state and local taxation 12 to register, visit www.scps.nyu.edu/sumtax introduction to partnerships july 21–23, 2008 Chair: James A. Gouwar, Esq., partner, McKee Nelson LLP, New York, NY day 1 8.30–10 a.m., 10.15 a.m.–12 noon Introduction and Choice of Entity 10–10.15 a.m. Refreshment Break 12 noon–1 p.m. Lunch Recess 1–3 p.m. Partnership Formation Introduction; choice of entity and uses of partnerships; classification; types of entities that can be treated as partnerships for tax purposes: general partnership, limited partnership, LLC, LLP, trust, contract, foreign entities, e.g., GmbH, limitada. Philip Wagman, Esq., partner, Clifford Chance US LLP, New York, NY Formation of a partnership; nonrecognition, beginning book and tax capital account and beginning basis; taxable year; methods of accounting. Christopher Roman, Esq., partner, Clifford Chance US LLP, New York, NY 3–3.15 p.m. Refreshment Break 3.15–4.30 p.m. Partnership Operations Effect of partnership operations on tax and book capital accounts and basis; special allocations. Glenn E. Mincey, Esq., senior manager, Deloitte Tax LLP, New York, NY Matthew S. Belcher, Esq., senior manager, Deloitte Tax LLP, New York, NY day 2 8.30–10 a.m. Nonrecourse Allocations Allocations of nonrecourse debt and nonrecourse deductions. Holly Belanger J.D., CPA, partner, KPMG LLP, Washington, D.C. Sarah I. Staudenraus, CPA, senior manager, KPMG LLP, Washington, D.C. 10–10.15 a.m. Refreshment Break 10.15 a.m.–12 noon Partnership Distributions Current and liquidating distributions; disproportionate distributions. Holly Belanger J.D., CPA, partner, KPMG LLP, Washington, D.C. Sarah I. Staudenraus, CPA, senior manager, KPMG LLP, Washington, D.C. 12 noon–1 p.m. Lunch Recess 1–2.45 p.m. Transfers of Partnership Interests Sales and purchases of partnership interests. James A. Gouwar, Esq., partner, McKee Nelson LLP, New York, NY 2.45–3 p.m. Refreshment Break 3–4.30 p.m. Retirement and Death of a Partner Consequences under subchapter K, including effect on timing and character of income. James A. Gouwar, Esq., partner, McKee Nelson LLP, New York, NY day 3 8.30–10 a.m., 10.15 a.m.–12 noon Partner-Partnership Transactions 10–10.15 a.m. Refreshment Break 12 noon–1 p.m. Lunch Recess Disguised sales and other partner-partnership transactions. Jeff A. Erickson, Esq., principal, Ernst & Young LLP, Washington, D.C. Rebekah Myers, Esq., manager, Ernst & Young LLP, Salt Lake City, UT for more information, call (212) 992-3320 13 Hot Topics 1–2.30 p.m. An overview of recent developments in the law and in the uses of partnerships. James A. Gouwar, Esq., partner, McKee Nelson LLP, New York, NY Michael A. Meisler, Esq., CPA, partner, Ernst & Young LLP, New York, NY 2.30–2.45 p.m. Refreshment Break 2.45–3.30 p.m. The Troubled Partnership Workouts, foreclosure, deed in lieu, abandonment of partnership interest. Michael A. Meisler, Esq., CPA, partner, Ernst & Young LLP, New York, NY Summing Up 3.30–4.30 p.m. Work through a partnership tax return and a sample partnership agreement with emphasis on the tax-sensitive provisions, such as capital account maintenance, book-ups, choice of allocation methods under Section 704(c), allocation and distribution provisions, and liquidation provisions. Michael A. Meisler, Esq., CPA, partner, Ernst & Young LLP, New York, NY Conference Concludes 4.30 p.m. learning objectives On completing this program, you acquire a solid foundation from which to address the intricacies of Subchapter K of the Internal Revenue Code: • The nature of partnerships and the various legal entities taxed as partnerships • The relationships between a partnership and its partners as well as between and among partners themselves • Approaches to formation including contributions of property and services in exchange for partnership interests, the classification of those interests • partnership operations and reporting with particular emphasis on the basics of distributions to partners and allocation of income and deductions • Winding down and winding up partnerships, including the withdrawal of individual partners and the transfer of partnership interests Program Level: Basic Prerequisite: None introduction to consolidated returns july 23–25, 2008 Chair: Stephen A. Sacks, CPA, J.D., LL.M., executive director, Ernst & Young LLP, New York, NY Although this is an introductory conference, certain topics may be complex and the instructors will review the basic tax law prior to discussing the consolidated return effects. Nevertheless, some knowledge of corporate taxation is assumed. day 1 8.30–10 a.m., 10.15 a.m.–12 p.m., 1–2.15 p.m., 2.30–4.30 p.m. Reasons for filing consolidated returns and the impact of filing them; definition of affiliated group; reverse acquisitions; determination of taxable years; due dates; accounting methods; the tax treatment of intercompany transactions. Stephen A. Sacks, CPA, J.D., LL.M., executive director, Ernst & Young LLP, New York, NY William F. Huber, CPA, M.B.A., retired partner, PricewaterhouseCoopers LLP 10–10.15 a.m. Refreshment Break 12 noon–1 p.m. Lunch Recess 2.15–2.30 p.m. Refreshment Break 14 to register, visit www.scps.nyu.edu/sumtax day 2 8.30–10 a.m., 10.15 a.m.–12 p.m., 1–2.15 p.m., 2.30–4.30 p.m. Special limitations on certain deductions and losses; Separate Return Limitation Year (“SRLY”) rules and built-in loss rules; regulations addressing Section 382 in a consolidated context; “Overlap Rule”; at risk and passive activity rules; dual consolidated losses; NOL and capital loss carrybacks and carryforwards; loss absorption rules; effect of debt cancellation income on NOLs; other special rules relating to the computation of consolidated taxable income; consolidated tax liability including AMT, before credits; consolidated tax credits; allocation of consolidated tax liability. Richard W. Stern, J.D., M.L.T., executive director, Ernst & Young LLP, New York, NY Kurt J. Roderich, CPA, M.S.T., partner, Ernst & Young LLP, London, UK 10–10.15 a.m. Refreshment Break 12 noon–1 p.m. Lunch Recess 2.15–2.30 p.m. Refreshment Break day 3 8.30–10 a.m., 10.15 a.m.–12 p.m., 1–2.15 p.m., 2.30–4.30 p.m. Stock basis; excess loss accounts; determination of gain or loss on disposition of subsidiary stock; loss disallowance; earnings and profits; application of Section 108 to a consolidated group; rules regarding intragroup distributions, including special rules relating to stock of members and debt obligations of members. James W. Banks, CPA, partner, PricewaterhouseCoopers LLP, Los Angeles, CA Jeffrey L. Vogel, J.D., LL.M., principal, KPMG LLP, Washington, D.C. 10–10.15 a.m. Refreshment Break 12 noon–1 p.m. Lunch Recess 2.15–2.30 p.m. Refreshment Break 4.30 p.m. Conference Concludes learning objectives On completing this program, you learn the fundamentals of the special rules governing the federal income taxation of consolidated groups: • The eligibility requirements to file a consolidated federal income tax return, including the definitional provisions and the parameters for determining when an affiliated group is eligible to file a consolidated return and which corporations are eligible for inclusion • The basics of calculating consolidated taxable income with emphasis on net operating losses and other tax attributes, the treatment of carryover and carryback items to separate return years and the limits placed on such attributes • The effects of consolidation within the group and as among group members including basis, deferral of gains and losses, earnings and profits, and distributions Program Level: Basic Prerequisite: Basic knowledge of corporate taxation Tax Conference Preview 27TH INSTITUTE ON STATE AND LOCAL TAXATION December 15–16, 2008, The Grand Hyatt, New York, NY Co-Chairs: Paul H. Frankel, Esq., partner, Morrison & Foerster LLP, New York, NY Richard W. Genetelli, CPA, president, The Genetelli Consulting Group, New York, NY The Institute is designed for the practitioner who must frequently anticipate and handle state and local tax matters. It provides high-level updates, practical advice you can implement, and in-depth analysis of the latest developments and current issues in all areas of state and local taxation. Attendees learn practical solutions and valuable insights from leading authorities throughout the industry. Just as important, the Institute provides the perfect setting to meet practitioners from around the country. It’s an opportunity to share ideas, exchange views, learn what others are doing, and obtain credit for continuing education. www.scps.nyu.edu/salt general information Conference Fee: See the registration form for individual conference fees. Each conference fee includes sessions, continental breakfast, refreshment breaks, and written materials for each participant. To request an application for Financial Hardship, please call (212) 992-3320, fax your request to (212) 992-3650, or e-mail your request to scps.atl@nyu.edu. Electronic Registration Confirmation: Confirmation of registrations submitted online, by mail or fax is via e-mail. Please use an individual e-mail address for each registrant. Confirmations will display the start and end dates of the entire Institute, please check the conference agenda for individual conference dates and times. If a confirmation is not received within one week of online registration submission (allow 2-3 weeks for registrations sent by mail/fax), please contact your firm’s IT firewall administrator or e-mail scps.atl@nyu.edu to request a duplicate copy. Conference Location and Hotel Accommodations: All of the conferences in the Summer Institute in Taxation are held at The Westin New York at Times Square, 270 West 43rd Street on the corner of Eighth Avenue. Hotel accommodations also are available at The Westin New York, which is easily accessible to Times Square, Broadway theaters, Radio City Music Hall, Carnegie Hall, Rockefeller Center, Central Park, and Fifth Avenue shopping. Single or double occupancy rooms are available at the NYU group rate of $329 by calling (888) 627-7149 or (212) 201-2700 and referring to the NYU tax conference. Book your reservation in advance. Hotel rooms can sell out prior to cutoff date. These rooms will be held as a block, unless exhausted, until June 18th, at which time they will be released to the general public. Conference Check-In and Continental Breakfast: Conference check-in and continental breakfast begins each day at 8 a.m. Cancellation and Substitution Policy: Written notice is required for all cancellations. Cancellations and requests for refunds must be received on or before June 27, 2008. You may fax requests to (212) 992-3650. There is a $150 cancellation fee. Due to financial obligations incurred by NYU, there are no refunds available for cancellations after June 27. If you would like to send a substitute, please fax a written request to (212) 992-3650 no later than July 9. Special Needs: Participants having special needs (i.e., physical) may e-mail scps.atl@nyu.edu or call NYU at (212) 992-3320 to indicate their particular requirements. Introduction to International Taxation 22.0 based on a 50-minute hour (including 1.0 ethics credit) 18.5 based on a 60-minute hour (including 1.0 ethics credit) Advanced International Taxation 14.0 based on a 50-minute hour (including 1.0 ethics credit) 12.0 based on a 60-minute hour (including 1.0 ethics credit) Continuing Education Credit: The School of Continuing and Professional Studies at New York University is a recognized leader in professional continuing education. New York University’s Department of Accounting, Taxation, and Legal Programs has been certified by the New York State Continuing Legal Education Board as an Accredited Provider of continuing legal education in the State of New York. These conferences meet the educational requirements of many organizations and agencies with mandatory CLE/CPE/ CFP filing requirements. The introductory conferences are also available for New York transitional Continuing Legal Education (CLE) credits for newly admitted attorneys. We urge you to contact our office at (212) 992-3320 at least 30 days prior to the conference start date to ensure the availability of credit for a specific MCLE state. NASBA: New York University’s School of Continuing and Professional Studies Department of Accounting, Taxation, and Legal Programs 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. Web site: www.nasba.org. Attention Certified Financial Planners: Each CFP licensee must complete 30 hours of continuing education each reporting period. The reporting period is a two-year period ending with the last day of the licensee’s renewal month. New York University has filed the Introduction to Trusts and Estates and the Institute on Federal Wealth Taxation with the Certified Financial Planner Board of Standards. For more information regarding acceptance of these conferences for continuing education credit, please call (212) 992-3320. Estimated Continuing Education Credit: Except where indicated, CLE credits are in the categories of Professional Practice/Practice Management. CLE boards define a credit hour as either 60 minutes or 50 minutes. Recommended CPE credits are in the following NASBA field of study: Taxes. In accordance with the standards of the National Registry of CPE Sponsors, CPE credits are based on a 50-minute hour. Please note that not all state boards accept half credits. A certificate of attendance is given to each registrant and validated upon completion. Introduction to Trusts and Estates 22.5 based on a 50-minute hour 18.5 based on a 60-minute hour Institute on Federal Wealth Taxation 14.0 based on a 50-minute hour (including 1.5 ethics credits) 12.0 based on a 60-minute hour (including 1.5 ethics credits) Introduction to State and Local Taxation I 23.0 based on a 50-minute hour 19.5 based on a 60-minute hour State and Local Taxation II 14.0 based on a 50-minute hour 12.0 based on a 60-minute hour Introduction to Partnerships 23.0 based on a 50-minute hour 19.5 based on a 60-minute hour Introduction to Consolidated Returns 23.0 based on a 50-minute hour 19.5 based on a 60-minute hour registration form Your e-mail address is your registration ID; confirmations are sent by e-mail. By Internet: Register online with your credit card at www.scps.nyu.edu/sumtax. By Mail: To register by mail, simply fill out the registration form below and return it with a credit card authorization or check payable to New York University, to: New York University, Summer Institute in Taxation, 25 West 4th Street, Room 203, New York, NY 10012. By Fax: You may fax your credit card registration to us 24 hours a day at (212) 995-4677. For further information regarding administrative policies such as complaints and refunds or if you need help registering, please call our conference administrators at (212) 992-3320. You may photocopy this form. Please submit a separate form and e-mail address for each registrant and print clearly. Registrations will not be processed unless accompanied by a check or credit card information. All Conferences: Use registration no. SCPS09. Please register me for: ¨ Intro. to State and Local Taxation for $865. ¨ Intro. to Partnerships for $865. ¨ State and Local Taxation II for $725. ¨ Intro. to Consolidated Returns for $865. ¨ Intro. to International Taxation for $865. ¨ Intro. to Trusts and Estates for $865. ¨ Advanced International Taxation for $725. ¨ Institute on Federal Wealth Taxation for $725. Name qqqqqqqqqqqqqqqqqqqqqqqqqqqqqw Firm qqqqqqqqqqqqqqqqqqqqqqqqqqqqqw Address City qqqqqqqqqqqqqqqqqqqqqqqqqqqqw qqqqqqqqqqqqqw Business Phone E-mail State qqw Zip Code qqqqqw-qqqqw qqqw-qqqw-qqqqw qqqqqqqqqqqqqqqqqqqqqqqqqqqqqw I am a: ¨ CPA ¨ Attorney ¨ CFP ¨ Other I require: ¨ CLE ¨ CFP ¨ CPE Credit State(s) in which CLE credit is being sought ¨ I have enclosed a check or money order payable to New York University. ¨ I authorize you to charge my credit card ¨ Discover ¨ Visa ® (Signature) ¨ American Express ® ¨ MasterCard® ® Number Expiration Date can’t attend a conference? If you are unable to attend a conference but would like to receive a copy of the written materials, please use the coupon below and mail to: New York University, Summer Institute in Taxation Book Orders, 11 West 42nd St., Suite 401B, New York, NY 10036; call (212) 992-3320; or fax (212) 992-3650 to reserve your copy. Reserve your copy by June 27, 2008. We cannot guarantee a selection after June 27. Prices for each book are listed below. There is no additional charge for shipping and handling in the continental U.S. Please add an additional $20 for shipping orders outside the continental U.S. Please make checks payable to New York University. Please send me: ¨ Introduction to State and Local Taxation for $195. ¨ State and Local Taxation II for $195. ¨ Introduction to International Taxation for $195. ¨ Advanced International Taxation for $195. ¨ ¨ ¨ ¨ Introduction to Partnerships for $195 Introduction to Consolidated Returns for $195. Introduction to Trusts and Estates for $195. Institute on Federal Wealth and Taxation for $195. Name: Address: State: City: Phone: ( ) Zip Code: E-Mail: ¨ Payment is enclosed or ¨ I authorize you to charge my credit card ¨ Discover® ¨ Visa® Number (Signature) ¨ American Express® ¨ MasterCard® Expiration Date www.scps.nyu.edu/sumtax at The Westin New York at Times Square July 2008 Summer Institute in Taxation School of Continuing and Professional Studies Summer Institute in Taxation 11 West 42nd Street, Suite 401B New York, NY 10036 A private university in the public service NEW YORK UNIVERSITY Nonprofit Org. U.S. Postage PAID New York University