2017 BTI - Bank & Capital Markets Tax Institute

8:00 am - 5:00 amRegistration
8:00 am - 9:00 amContinental Breakfast
8:30 am - 5:00 pmBank Tax Tutorial
David A. Thornton, Partner, Financial Institutions Tax Group, Crowe Horwath LLP
Trudie D. Kanter, CPA, Senior Manager, Crowe Horwath LLP
Patrick Egan, Senior Vice President, Corporate Tax, New York Community Bancorp
As most of the presentations at the conference will focus on specific technical issues, you will want to take advantage of our preparatory Bank Tax Tutorial. The Bank Tax Tutorial is designed for comptrollers, tax professionals and their outside advisors, and prepares you to follow the conference presentations with a greater understanding of the complexity of these issues. If you have not had a refresher course in some time, if you want a succinct and inclusive review, or if you just want to fill in gaps in your background, plan now to attend this special seven-hour tutorial. In this session, we will discuss the common schedule M adjustments specific to banking, the bad debt conformity election (including the recent IRS audit directive on bad debt conformity), and developments in the tax issues associated with loan foreclosures and holding foreclosed property.
8:30 am - 5:00 pm23rd Annual Community Bank Tax Workshop
John E. Cederberg, CPA, Principal, John E. Cederberg, CPA
Justin Horst, Chief Financial Officer, Pinnacle Bancorp, Inc.
Paul A. Sirek, CPA, MBT, Partner, Financial Institutions Services Group, Eide Bailly LLP
Randy J. Churchill, CPA, Director, Moss Adams LLP
The Community Bank Tax Workshop is the banking industry’s annual advanced tax conference focused specifically on tax planning and compliance by community banks, both C corporations and S corporations. The workshop is designed for the financial executives of community banks and bank holding companies, and their outside accountants and counsel. We will discuss a number of new “Schedule M-3” entries caused by changes in accounting methods that are not followed for tax purposes. Additionally, we will dive into the experience with LB&I directive to examiners regarding the examination of bad debts. We are seeing a recovery in community bank acquisition activity, but with a couple of “twists;” the acquirers are other community banks, not the large banks with experience as an acquirer, and many of the acquisitions are complicated by net operating loss carryforwards. It appears that we may not have enacted “tax reform,” but there is enough activity to have a lively discussion of how tax legislation is likely to affect the banking industry.
12:00 pm - 1:00 pmLunch
1:00 pm - 5:00 pmCapital Markets Workshop
Mark Price, Principal, Washington National Tax, KPMG LLP
Justin Weiss, Partner, Financial Institutions and Products, KPMG LLP
Matt Mosby, Senior Manager, Financial Institutions and Products, National Tax, KPMG LLP
Sam Chen, Senior Manager, Financial Institutions and Products, KPMG LLP
Banks continue to play a critical role in today’s capital markets, and changes to the regulatory and economic landscape have created new challenges and opportunities from a tax perspective. In recent years, the derivatives used and offered by banks of all sizes have evolved and become more complex; the tax rules have not evolved at the same pace. This workshop will review the tax considerations related to a bank’s derivative transactions and how they may change with tax reform, using the proposed Modernization of Derivatives Act as a baseline. This section will also address recent changes to the characterization of variation margin for certain cleared derivative contracts, and the uncertainty these changes have created in the contracts’ historical tax treatment.
The second section of this course will focus on tax issues and opportunities associated with financial institutions’ leasing businesses. Recent changes in financial accounting for leases have resulted in many institutions looking at their leasing portfolios anew, and now may be a good time to revisit the tax considerations surrounding these portfolios including lease characterization issues and how to account for lease payments. 
The third section of this course will focus on the securitization market. While securitizations have always played an important role in the financial services industry, the market’s recent evolution has created a host of complexities for tax departments.  This discussion will provide an overview of (i) the role banks play in the securitization market; (ii) common structures used to securitize assets; and, (iii) the tax considerations associated with sponsoring, servicing, and investing in securitizations.
3:15 pm - 3:45pmMid Afternoon Stretch
5:00 pm - 6:30 pmWelcome Cocktail Reception

7:00 am - 5:00 pmRegistration Open
7:00 am - 8:00 amNetworking Breakfast
8:00 am - 9:15 amMorning Keynote Address: The Economy in 2018
James Chessen, Executive Vice President & Chief Economist , American Bankers Association
Conducting business in this complex regulatory climate is a top concern for many institutions and companies. A year after the election and with several interest rates hikes by the Fed, this keynote will cover what’s next for the U.S. economy, including fiscal and monetary policy expectations.
9:15 am - 10:30 amGeneral Banking Update
John P. Kinsella, Vice President, Tax Policy, American Bankers Association
Clark Wulf, Executive Vice President, Corporate Tax Director, KeyCorp
Elizabeth L’Hommedieu, Principal, Financial Institutions and Products, KPMG LLP
Anthony Welburn, Partner, KPMG LLP
This session will provide attendees with an overview of federal income tax and accounting developments of significant interest to banks and practitioners. Topics to be discussed include an analysis and review of recent and proposed tax legislation, including tax reform proposals, a summary of recent IRS pronouncements and cases, recent accounting and regulatory guidance, and a review of current IRS examination issues.
10:30 am - 11:00 amMid-Morning Break
11:00 am - 12:15 pmIRS Developments
James Ahern, Tax Director-Capital Markets, Synchrony Financial
Denise Schwieger, Principal, Pricewaterhouse Coopers LLP
Ellen Rotenberg, Partner, Tax, PricewaterhouseCoopers LLP
Paul DeNard, Managing Director, PricewaterhouseCoopers LLP
Led by representatives from industry and public accounting, as well as former IRS executives, this panel will discuss the taxpayer and government positions on current issues being raised by the IRS for examination. The panel will feature a lively discussion of IRS positions affecting current examination issues as well as strategic initiatives and structural changes within the IRS that will impact taxpayers.
12:15 pm - 1:45 pmAward Presentation followed by Luncheon Keynote: Legislative & Tax Reform Update
Pamela Olson, Deputy Tax Leader, PricewaterhouseCoopers LLP
Join us to hear the latest in tax and Social Security reform, legislative matters and the structuring of transactions. This session will dive into tax competition, the importance of a consensus on taxing jurisdiction in the international trading regime, multilateral cooperation and the BEPS project, challenges in determining value added on a geographic basis, and why the focus on profit shifting is misdirected.
1:45 pm - 3:15 pmCommunity Banking Update
David A. Thornton, Partner, Financial Institutions Tax Group, Crowe Horwath LLP
Colleen Delger, CPA, Vice President, Tax Manager, Banner Bank
James Goeller, Partner, Crowe Horwath LLP
Lance Davis, Partner, BKD LLP
This session will provide an overview of federal income tax issues and recent developments of significant interest to small and mid-sized banks. Topics to be discussed include an update on recent IRS pronouncements and initiatives impacting community banks, an overview of proposed federal tax legislation and suggested tax planning strategies to capitalize on a potential reduction in the federal corporate income tax rate. All topics will be presented from a community banking perspective by practitioners who serve this market extensively.
FSI - Recent Tax Developments
Jack Burns, Executive Director, EY
Moderator: Keith Anzel, Managing Director and Chief Tax Officer, Citigroup Global Markets Inc.
This session will discuss recent tax developments to the financial services industry and international arena.
Comp & Fringe Benefits Update
Ron Copher, CFO, Glacier Bancorp, Inc.
Bill O'Malley, Senior Director, RSM
Steve Levin, Senior Director, RSM
The session will address a variety of compensation-related topics including, for example, approaches to providing equity compensation and tax considerations, impact of IRC section 409A on equity and deferred compensation and issues we have seen in practice, IRC section 280G and 162(m) considerations, tax reporting/withholding matters and fringe benefits.
3:15 pm - 3:45 pmMid-Afternoon Stretch
3:45 pm - 5:15 pmS Corp Update
Jeremy Uhl, Vice President of Finance, Security National Bank
Francis Godfrey, Partner, BKD LLP
Aaron Wiegert, Partner, BKD LLP
The pass-through structure of a Sub S bank poses many unique challenges and opportunities. In this session, we will explore the advantages and disadvantages of being a Sub S bank. What impact will tax reform have on Sub S bank shareholders? Will it still make sense to be a Sub S bank? We will examine the impact of new legislation, discuss select merger and acquisition concepts, present tax planning strategies, and review other currently relevant tax issues.
Planning for Efficiency and Effectiveness in the Stress Testing Process
David Henderson, Partner, DHG LLP
Heather Wallace, Partner, DHG LLP
Clark Wulf, Executive Vice President, Corporate Tax Director, KeyCorp
Jared Forman, Principal, DHG LLP
Challenges persist as banks strive to meet supervisory expectations for sound risk and capital management practices, and the tax department frequently lands in the center of the storm. Hear tactical methodologies and leading practices to better plan for your bank’s capital management and stress testing process. Presenters will discuss what you should be doing now regarding documentation, processes, controls and model validation to meet and thrive in today’s dynamic environment.
Captive Insurance Update
Brett Scribner, Senior Vice President, Director of Tax, U.S. Bancorp
Lynn McGuire, Partner, Crowe Horwath LLP
This session will cover the basic structure of captive insurance companies, their federal income tax treatment and recent legislation and IRS initiatives aimed at the captive insurance industry. Topics will include an overview of the PATH Act enhancement to the small captive insurance company premium exemption and the status of the IRS information gathering and reporting requirement set forth in IRS Notice 2016-66.
5:15 pm - 6:15 pmNetworking Cocktail Reception

7:00 am - 12:00 pmRegistration Open
7:00 am - 8:00 amContinental Breakfast
7:30 am - 8:45 amMorning Keynote Address: The Banking Industry--Past, Present and Future
Thomas Brown, Founder & CEO, Second Curve Capital
Constant technological and regulation changes has resulted in a very challenging decade for the banking industry. This session will highlight what will separate the winners from the losers in the future of banking.
8:45 am - 10:00 amTax Reform Implications
Ron Copher, CFO, Glacier Bancorp, Inc.
Bill Reilly, Partner, Grant Thornton LLP
Dan Gross, Senior Manager, Grant Thornton LLP
John Gimigliano, Principal-in-Charge, Federal Legislative and Regulatory Services, KPMG LLP
Matt Mosby, Senior Manager, Financial Institutions and Products, National Tax, KPMG LLP
The 2016 elections generated a renewed focus on comprehensive tax reform, but, as 2017 has already demonstrated, achieving this goal is very challenging. This panel will discuss the latest federal tax legislative developments, focusing on the key proposals for the banking industry. The panel will also discuss how these proposals could affect the industry and what banks should be doing now.
10:00 am - 10:05 amPrize Drawing
10:05 am - 10:30 amMid-Morning Break
10:30 am - 12:00 pmTax Accounting Update
Randy J. Churchill, CPA, Director, Moss Adams LLP
Brett Scribner, Senior Vice President, Director of Tax, U.S. Bancorp
Kristine Hoeflin, Partner, Moss Adams LLP
Sarah Nold, Director, PricewaterhouseCoopers LLP
Christine Turgeon, Partner, PricewaterhouseCoopers LLP
In this session, our panelists will update you on the latest developments in Accounting for Income Taxes, including discussions of the upcoming revenue recognition and leasing standards, and tax accounting for international operations. There will be valuable insights for community banks as well as large multinational financial institutions.
Bank M&A Tax Considerations: Opportunities & Hazards Ahead
James Ahern, Tax Director-Capital Markets, Synchrony Financial
Nathan Clark, Partner, DHG LLP
Joshua Elliott, Partner, DHG LLP
Nikki Yarborough, Tax Partner, DHG LLP
As consolidation and M&A activity continue at a rapid pace, bankers are looking ahead to build a competitive edge and a strong business. In this session, panelists will discuss accounting methods in M&A situations, transaction cost studies/280G issues, and tax accounting highlights. Hear observations, items commonly missed, and strategies to overcome challenges that your bank can act on now.
IRS Practice & Procedure Update
Susanne Muller, Executive Director, UBS AG – Group Tax
Dean M. Fischbeck, Senior Vice President, Bank of America
John Keenan, Director, Deloitte
This panel will discuss the taxpayer and government positions on current issues being raised by the IRS for examination. The panel will feature a lively discussion of IRS positions affecting current examination issues as well as strategic initiatives and structural changes within the IRS that will impact taxpayers.
12:00 pm - 1:00 pmNetworking Lunch
1:00 pm - 2:30 pmSALT Update
Walter Doggett III, Vice President of Tax, E*Trade Financial Corporation
Ann Kamasky, Partner, Deloitte
Matthew DiDonato, Partner, Grant Thornton LLP
The State and Local Tax session will be an interactive panel discussion covering the latest developments in state and local taxation of financial institutions. Topics will include a review of the “State of the States,” an update on significant new and pending legislation, thoughts on the recent trend toward market-based sourcing, recent judicial and administrative rulings, and other state/local developments and trends that are impacting the industry and your state effective tax rate.
Tax Process Automation
Adrian Fenton, U.S. Tax Services Director, Asset Servicing, Bank of New York Mellon
Christopher Dobson, Partner/Principal , EY
Technology continues to change at a rapid pace – the iPhone is only 10yrs old! Tax is not immune and a new wave of technologies can provide significant automation and risk management benefits for tax processes from planning, to controversy, accounting, compliance and regulatory reporting. Please join us in this session as we discuss the new wave of intelligent automation (including robotics process automation) and the potential benefits within your tax department.