The end of the 1990s saw a popular game show, “Who Wants to Be a Millionaire?,” become a global phenomenon. Most of the readers of this column will remember that contestants were granted “lifelines” if they were stumped by a question, one of which was that they could “phone a friend” for help with an answer. Often the contestant would seek help in a call with a spouse, sibling, friend, or in one famous case, a parent, where the contestant simply said, “I’m calling to tell you I’m going to win the million dollars” and then got the answer right.
Readers of this column are mostly active members in the ABA Tax Section. Let us pause for a moment as we enter 2024 and think about all of the benefits we gain from this membership—best in class CLE; multiple opportunities to network, develop friendships, consult with experts, and learn from colleagues, mentors, and teachers; and for those of us in private practice, opportunities to grow our practices. We also participate in something larger—we proudly fund, and many members participate in, pro bono and public service fellowship programs; promote and implement initiatives to increase the diversity, equity, and inclusiveness of the tax bar; support sound, effective and equitable tax administration; and submit thoughtful and knowledgeable comments on IRS and Treasury proposed guidance, rules, and policy. Given the relatively low cost of ABA and Section membership, all of this comes at a real bargain.
So, I write in this Tax Times urging you to consider “phoning a friend” (or the 2020s equivalent - texting, social media, blogging, chatting over a coffee, etc.) to share how the Section enhances your professional life and the tax system. For those of you in management roles in professional firms, I encourage you to think about how the Section has benefitted your own practice and what benefits it might offer new professionals entering the field. Section members tend to work on the most interesting, important, and impactful matters in the panoply of international, federal, and state tax issues, and Section membership is a definite “value add” to that work. It is also a way for your junior colleagues to connect with peers and increase their job satisfaction. We should all “phone a friend” and get them to join and participate!
In this regard, let me note many great developments over the past few months and some of our upcoming events.
Midyear Meeting and “Live Well, Lawyer Well”
Our Midyear Meeting is fast upon us, January 18-20, as the Section returns to the Hyatt Embarcadero in beautiful San Francisco. Gorgeous vistas of the Bay, wonderful hilly walks, fabulous restaurants, and clanging cable car bells all beckon as we gather for our excellent committee meetings and other events.
The Program this year will contain something new – three separate events kicking off the Section’s new Live Well, Lawyer Well initiative, aimed at promoting personal well-being among our membership. On Thursday, January 18 at 4 PM, Les Book, Sonia Shaikh, and Melissa Wiley will lead an open discussion co-sponsored by the Women in Tax Forum (WITF) on managing stress and anxiety in juggling busy professional lives with our family and personal responsibilities. On Friday morning at 6:30 AM, Michael Desmond and Megan Brackney will lead a Run Well, Lawyer Well run through the streets of San Francisco. All skill levels are welcome. On Friday at 5:30 PM, the WITF will lead a one mile walk along the Bay for wonderful views and conversation, followed by a wellness discussion back at the conference hotel. Leadership and staff are very excited to debut this new program in San Francisco and we look forward to expanding our Live Well, Lawyer Well offerings down the road.
At Midyear we will also offer an outstanding Plenary Program at the Saturday luncheon, “The Structure of Revolutions in Taxation and the Law: Paradigm Shifts Caused by Artificial Intelligence.” Highly appropriate for a city that has brought us so much technological innovation, this will be a panel discussion led by Travis Thompson, Chair of the Tax Practice and Technology Committee. It will examine the current revolution taking place in the practice of tax and law, how artificial intelligence is changing the world, and what practitioners should know for the future.
The Generosity of Our Members
Tax Section members demonstrated their incredible generosity of heart and spirit as 2023 rolled toward an end. First, we participated in the ABA’s annual Giving Day in October, in support of our Tax Assistance Public Service (TAPS) endowment which funds Section public service fellowships and scholarships. I’m delighted to share that Section members and leadership contributed over $50,000, which exceeded our fundraising goal as well as all the other fundraising initiatives participating in Giving Day.
At year end, we also ran a campaign to strengthen our Justice Diversity Equity and Inclusion (JDEI) endowment. The JDEI endowment funds the Section’s Loretta Collins Argrett Fellowships and other diversity-related activity. This year we set a fundraising goal of $45,000, and I’m pleased to report that we exceeded that goal, with well over $50,000 in donations, through significant gifts and matches from our membership and leadership.
Our members are a caring bunch, but I am especially grateful to our committee leaders, Council members, and officers for their contributions. Those of us who hold leadership positions for the Section have the privilege to serve and with that privilege comes a responsibility to ensure that the Section’s good works can continue long after our positions transition to others. Please keep the Section in mind for your charitable giving as we move into 2024.
Other Section Activities
We had a busy fall in 2023. In October, we held our Virtual 2023 Fall Section Meeting. The week-long program featured outstanding panel sessions, networking gatherings, and a terrific plenary panel about service in the Treasury Department. The panel offered insight and analysis about the panelists’ combined decades of working at Treasury and dealing with the legislative and executive branches in formulating and implementing tax policy.
We were delighted that over 600 representatives from the IRS attended the virtual meeting, from D.C. as well as local offices throughout the country. One of the highlights of the virtual format is that it facilitates broad participation of government officials and provides committee leaders the unique opportunity to engage issue area experts from the government throughout the country in panel presentations. It also introduces a wide range of attendees both in and out of the government who would not be able to travel to an in-person Section meeting to participate in our programming. We look forward to partnering with the IRS in a similarly meaningful way in subsequent meetings.
In November, the Section offered a new form of programming on a hot topic with a full-day Boot Camp of panels and speakers on the globally significant developments arising from the movement toward the OECD’s Pillar Two approach to international taxation. With enormous appreciation to our former Council Director Scott Levine (who is now serving as Acting Deputy Assistant Secretary (International Tax Affairs)) and his former firm Jones Day, the Section hosted a hybrid event attended by 50 people in person at Jones Day’s office in Washington D.C., and 400 participants online from twenty-two countries (a Section record for our virtual programming). The Boot Camp was a great success and portends well for future Section programming of similar creative content and format.
In December, Section leadership met with IRS Commissioner Danny Werfel and many other IRS officials for our annual Courtesy Call. We were warmly welcomed into the same conference room at the IRS where President John F. Kennedy once spoke to IRS officials, the only President ever to appear at 1111 Constitution. Section representatives raised over a dozen agenda items seeking guidance and administrative action to improve the tax system. The meeting was productive, and we are grateful to our IRS hosts for having us. The Section deeply values our partnership with the IRS in the joint effort of ensuring that the Service is properly funded and able to effectively administer and enforce the tax laws.
Through the hard work of our Government Submissions Committee, we continue to submit thoughtful comments on proposed IRS guidance. In the past three months we have made major submissions regarding i) basis reporting by brokers and determination of amount realized and basis for digital asset transactions; ii) the treatment of certain non-fungible tokens as collectibles within the meaning of section 408(m); iii) the treatment of section 357(c)(3)(A) liabilities in section 351 exchanges between members of a consolidated group; iv) information collection requirements for reports of foreign financial accounts and FinCEN Form 114; v) ways to improve dispute resolution programs; and vi) the taxation of digital assets. Our COGS teams are working on more than a dozen other comment projects that we expect to submit in the coming months.
Diversity in the Profession Committee
Under the leadership of Chair-Elect Alice Abreu as Chair of our Diversity in the Profession Committee (DIPC), we have greatly expanded the Section’s infrastructure to work on important issues related to diversity, equity, and inclusion (DEI). DIPC has grown to over 25 members with four subcommittees working under the DIPC Vice Chairs Eman Cuyler and Kathy Packenham: (1) DEI Programming and Publications, (2) DEI Research and Policy, (3) Fellowships and Scholarships, and (4) Liaisons and Ambassadors. The members of DIPC are working on issues important to the Section such as our leadership nomination process and outreach efforts to grow and enhance the diversity of the tax law profession. There will be more news to report from DIPC in the coming months.
The Section Conference calendar rolls onward.
- March 11-15, 2024: With the Institute for Professionals in Taxation, the Section is co-sponsoring a series of advanced meetings on state income tax, sales and use tax, and property tax issues. Join our talented SALT members in New Orleans for this great meeting! Register here.
- April 10-12, 2024: Please join us in Munich, Germany for the 24th Annual U.S. and Europe Tax Practice Trends conference, co-sponsored with the International Bar Association (IBA). The conference will be at the lovely Bayerischer Hof Hotel in central Munich and offers a wonderful opportunity to learn from and network with tax lawyers from all over the world. Register here.
- May 2-4, 2024: The Section’s Main Event – the May Tax Meeting – will be held at the Marriott Marquis in Washington, DC. If you know, you know; and if you don’t know, go and find out how amazing this meeting is. It’s the place to be if you’re a tax professional!
- June 12-14, 2024: The 16th Annual U.S. and Latin American Tax Practice Trends meeting returns to the Mandarin Oriental in dynamic Miami, Florida. Co-sponsored with the International Fiscal Association and the IBA, the conference draws tax professionals from the far corners of the Western Hemisphere and is a tremendous opportunity to learn and network.
- January 25, 2024 and January 30, 2024: The Tax Section presents two webinars later this month:
Welcome to Betsi Roach, New Section Director
It is a great pleasure to announce that Betsi Roach has joined our staff as the new Section Director! Betsi started her position just after Thanksgiving and is getting up to speed on the Section’s many activities and initiatives. She comes to the Tax Section having served previously as the Director of the ABA’s Intellectual Property Law Section and in several senior positions in the legal marketing and legal operations fields. We are excited to welcome Betsi and look forward to working with her in the coming months.
Returning to the theme of the introduction, this column should underscore to everyone how much the Section has going on and the many ways in which the Section can enrich our professional development and work. I encourage each of you to think of and reach out to at least one person in the tax field who you would like to see at our meetings and who you think might benefit from membership and participation. In other words, “phone a friend.” We have a great thing going here, and as is oft’ said, “the more the merrier!”
Warmest wishes to everyone for a happy and healthy 2024. See you in San Francisco!