8:00 - 8:15 am   Welcome and Opening Remarks     

Glenn N. Eichen, Vice President,Senior Tax Counsel, Citigroup, Inc., Bank Tax Board Chaiman

8:45 - 10:30 am   General Banking Update

This session will provide attendees with an overview of federal income tax and controversy developments of  significant interest to banks and practitioners. Topics to be discussed include an analysis and review of recent and proposed tax legislation, a summary of recent IRS pronouncements and a review of current IRS examination
issues.

Glenn N. Eichen, Vice President,Senior Tax Counsel, Citigroup, Inc., Bank Tax Board Chaiman

Dean M. Fischbeck, Senior Vice President, Bank of America

Laura Newinski, Partner, KPMG, LLP (Advisory Board Member)

Mark H. Price, Principal, Washington National Tax  KPMG LLP

Denise J. Schwieger,   Senior Manager, KPMG LLP

11:00 am - 12:30 pm CONCURENT SESSIONS
 
A-1: Recent Developments in State and Local Taxation of Banks and Financial Institutions—Part I
(Continued In B-1)

A review of recent developments in corporate income/franchise taxes, sales and use and other indirect taxes, and state tax shelter reporting requirements. This year’s session will highlight the myriad of state legislative changes, including economic nexus, public and captive REIT provisions, and other significant developments and issues affecting banks and financial institutions.

Stewart Beyerle, Executive Director, State and Local Tax Ernst & Young LLP     

Jeffrey Gotlinger, National Director - FSI SALT, Ernst & Young LLP

Edward J. Kane, Executive Vice President, Director of Corporate Tax , Huntington Bancshares Inc., (Advisory Board Member)  

Timothy Mahon, Senior Manager, Financial Services, Ernst & Young LLP

A-3: Purchase Accounting

A comprehensive review of the tax-related planning and accounting issues arising in acquisition transactions after the form of the combination (tax-free reorganization, stock acquisition or asset purchase) is selected: handling target stock options, paying out deferred compensation, enhancing 280G limitations; closing down the target’s ESOP; recording the proper deferred taxes; required disclosures with final returns and other vexing tax matters.

Ron J. Copher,  CFO and Director of Taxation, Glacier Bancorp, Inc.  (Advisory Board Member)   

Andrew E. Finkle, Tax Partner, Grant Thornton LLP

1:45 - 3:15 pm    CONCURENT SESSIONS
 
B-1: Recent Developments in State and Local Taxation of Banks and Financial Institutions—Part II
(Continuation of A-1) *Please see A-1 Session description.

Stewart Beyerle, Executive Director, State and Local Tax Ernst & Young LLP     

Jeffrey Gotlinger, National Director - FSI SALT, Ernst & Young LLP

Edward J. Kane, Executive Vice President, Director of Corporate Tax , Huntington Bancshares Inc., (Advisory Board Member)  

Timothy Mahon, Senior Manager, Financial Services, Ernst & Young LLP

B-3: S Corporation
It has now been more than 10 years since banks were allowed to elect S-corporation status. This session will provide a brief overview of the general and bank specific eligibility requirements and operational issues. Additional topics to be discussed will include new and proposed legislation, built-in-gains tax, bad debt recapture, TEFRA, and deferred tax recapture. We will also cover merger and acquisition issues and planning strategies.

Chad Brandmeyer, Tax Manager, RSM McGladrey, Inc.

Ronald W. Blasi,  Professor, College of Law, Georgia State University

Steven W. Corrie, Treasurer, Security National Corporation (Advisory Board Member) 

Richard D. Wehrheim,  Managing Director,  RSM McGladrey, Inc.

C-2: Information Reporting and Withholding: Why You Need To Care

• IRS Audit Activity is On the Rise, and New IRM Guidelines Tell Agents How to Conduct Those Audits
• Substantial Exposure Exists Around Payments to NRAs
• The Credit Crisis has Information Reporting Consequences
• Legislative Proposals Look to Close the Tax Gap with Increased Burdens On Financial Institutions, and
• NOLs Cannot Offset Withholding Tax Liabilities or Information Reporting Penalties

John P. Kinsella, Senior Vice President  and Director of Tax US Bancorp  (Advisory Board Member) 

Deborah J. Pflieger, Executive Director, Tax Withholding and Information, Reporting Services,  Ernst & Young LLP

Anthony Inzerillo, Senior Manager, Ernst & Young LLP

5:15 - 5:30 pm  Question and Answer Session

8:00 - 10:00 am  IRS Developments
Our panel will discuss the taxpayer and government positions on current issues being raised by the IRS on examination. The panel will include representatives from industry, public accounting and the IRS. Our session will also include a discussion of IRS releases affecting examination issues.

Glenn N. Eichen (Chairman), Vice President, Senior Tax Counsel,  Citigroup, Inc. 

Jeffrey M. Barth, Tax Partner, Deloitte Tax LLP

Jody Botsford (Invited), Technical Advisor, Internal Revenue Service

Jeffery Kammerman (Invited), Commercial Banking Technical Advisor, Internal Revenue Service

Scott Michaels, Jr., Partner, Deloitte Tax LLP

10:15 am - 12:00 pm  GAAP Accounting /Tax Risk Management /Advanced 109/IFRS
This session will provide attendees with a technical update of accounting and auditing professional standards that are widely applicable to financial institutions, including discussion of evolving and pending issues with both regulatory agencies and accounting standard setting boards.

• FAS 109 and FIN 48 - Best practices going forward
• EITF 06-04 - Understanding the accounting for split dollar arrangements
• FAS 123R - Comparing Restricted stock awards with Options
• Fair Value Accounting - FAS 157 &159 adoption issues
• Merger & Acquisition update
• Interim reporting issues - APB 28 and FIN 18
•  Evolving issues with regulators, including loan loss allowance methodologies

Richard S. Millerick, Vice President, Corporate Tax and General Tax Counsel, Freddie Mac (Advisory Board Member) 

Randy J. Churchill, Senior Manager, Tax, Moss Adams LLP (Advisory Board Member) 

Kevin R. Sell, Partner, Moss Adams LLP

Michael R. Thronson, Partner, Moss Adams LLP

D-2: Troubled Debt
What constitutes a “significant modification” under IRC Section 1001? Does an alteration of legal rights, change in yield, or change in timing or amount of payment qualify? When is gain recognized? When must a debtor recognize income and how and when is this reported? These are a few of the issues to be discussed in this session.

John P. Kinsella, Senior Vice President and Director of Tax, US Bancorp (Advisory Board Member)

Charles Sparano, Director,  RSM McGladrey, Inc.