7:30 a.m. - 8:00 a.m. Breakfast
8:00 a.m. - 10:00 a.m. CLE Program
Congress has passed the most significant tax legislation in at least a generation – the Tax Cuts and Jobs Act of 2017. This wide-ranging discussion will explain and analyze issues that include the overhaul of the U.S. international tax system; possible economic incentives and disincentives for numerous segments of our economy as well as U.S. trading partners; and technical issues raised by the Act. This program will also cover the impact of tax reform upon executive compensation, including the repeal of Section 162(m)'s performance-based compensation exception for public companies, the new excise tax for certain compensation paid by tax-exempt employers, and qualified equity grant plans for private companies under newly added Section 83(i).
Scott Levine advises on the tax aspects of corporate transactions, including international and domestic mergers and acquisitions, leveraged buyouts, spinoffs and other divestitures, restructurings, financings, and joint ventures. He also has negotiated private letter rulings with the Internal Revenue Service in the corporate, financial instruments, and energy credit tax areas and advised on the tax aspects of structuring cross-border acquisitions and financial instruments. Scott advised Procter & Gamble on the sale of its pet foods business to Mars; Essilor on its buyout of PPG's interest in Transitions; and Lam Research on its acquisition of Novellus Systems. In the renewable energy sector, he advised SunPower on its acquisition of PowerLight, and Solyndra on issues related to solar energy credits. Other representative clients include Abbott Labs, American Greetings, Bank of America, Celgene, Dow Corning, Monsanto, and T-Mobile.
Marcia Kelson focuses on complex benefit and compensation matters, including those arising in connection with corporate acquisitions, dispositions, mergers, pension de-risking, and employee stock ownership plans (ESOPs). With over 15 years of experience, she has counseled hundreds of plan sponsors, fiduciaries, and administrators on legal issues pertinent to employee benefit plans, as well as the entities that maintain them. This includes advising public, private, and nonprofit clients with respect to the structuring, drafting, and administration of qualified and nonqualified retirement plans, equity-based compensation, and similar plans and programs. In addition, Marcia regularly drafts and negotiates employment, severance, retention, and change-of-control agreements.
Ray Wiacek is one of the world's leading international tax lawyers. He represents multinational corporations on cross-border financings, international acquisitions and reorganizations, and transfer pricing. He is particularly skilled at global planning involving intellectual property. Ray also defends his advice, favorably resolving tax disputes ranging from the proper pricing of foreign autos to the effectiveness of an agreement to share R&D costs worldwide. He is currently challenging the IRS's anti-inversion regulations in court. Ray also negotiated and closed billions of dollars of cross-border financings for Bank of America against many of the leading banks in Europe. In addition, he led the worldwide team integrating Warner-Lambert and Pharmacia with Pfizer after Pfizer's overhaul of those companies. This included the disposition of nonstrategic assets, such as Schick and Wilkinson Sword to Energizer, and Chiclets and Dentyne to Cadbury. Ray also led the team that implemented a worldwide business and tax plan for Halliburton.
Fran Muracca represents clients in federal tax controversies at the administrative dispute resolution level before the IRS and in litigation before the U.S. Tax Court. He has successfully defended regional and national private business owners against challenges raised by the IRS involving unreasonable compensation; the valuation of nonmarketable privately held business interests for wealth transfer tax purposes; constructive dividends; and tax-motivated transactions. In addition, he has defended professional firms on challenges raised by the IRS involving "intermediary tax shelter" transactions. Fran's practice also centers on advising family offices and middle-market privately held business owners on a range of entity structure, transaction, and tax issues. He advises on the form of business entity and structure of business acquisitions and dispositions to minimize federal income tax consequences.
REGISTRATION & CLE CREDIT
Registration for this event is required. Visit the Jones Day event website to register. If you have any questions, please contact Molly Henry at email@example.com.
This program has been approved for 2.00 hours of general credit by the Pennsylvania CLE Board. This program has also been approved for 2.00 hours of general credit by the State Bar of California and 2.00 hours of areas of professional practice credit (including transitional credit) by the New York State CLE Board. Jones Day is a Pennsylvania CLE Board accredited provider, a State Bar of California MCLE approved provider, and an accredited provider in New York. Application for CLE credit in other states will be made as needed.