Jim Gadwood, Jeff Tebbs, Samuel Lapin, and Caroline Reaves will speak at the ABA Section of Taxation 2022 Fall Tax Meeting on October 14, 2022, in Dallas.

Gadwood will present, as part of a panel, "Current Developments." This panel will review recent developments in the area of tax accounting and discuss recent IRS guidance and court decisions.

Tebbs will present "When Circles, Triangles and Rectangles Collide Within the Funds Space!" This panel will discuss tax classification concepts relating to entities and instruments commonly used by funds, tax issues that confront funds that have hybrid entities and/or instruments within their structures, and potential tax planning measures.

Lapin will moderate "Back to Basics: Collections Appeals," a panel discussion that will provide an overview of the CPD Appeals process.

Reaves will present, as part of a panel, "Tax Treaties: A Guide to Analyzing Permanent Establishments, Limitation on Benefits, and Withholding Taxes." This panel will provide a guide on how to analyze a U.S. tax treaty and will address some of the common withholding tax provisions, when and how business profits are taxed, and whether a person will qualify for treaty benefits under the limitation on benefits clause. The panel will also provide an overview of typical transactions in which treaty benefits may be applicable, how transactions are structured to provide for treaty benefits, and how treaty disputes are resolved.