2009 Agenda

Earn up to 23 CPE Credits: Attend all BTI conference sessions and earn 15 CPE credits. Attenda a pre-conference workshop and earn 8 additional credits. Note: Registration is required in order to attend a pre-conference workshop. Please see details on the registration page. CONCURRENT PRE-CONFERENCE WORKSHOPS
Wednesday, November 18, 2009

8:30 - 5:00	15TH ANNUAL COMMUNITY BANK TAX WORKSHOP The Fifteenth Annual Community Bank Tax Workshop is a day long workshop focused specifically on the interests of those responsible for tax planning and compliance by smaller banks. The Workshop is targeted toward the financial executives of community banks and bank holding companies and their accountants and counsel. The faculty is reallocating the time for this year’s Workshop to emphasize the tax issues being encountered during the current recession; especially (a) the timing and character of losses on various investments in the bank’s portfolio, (b) the tax provisions in the American Recovery and Reinvestment Act., (c) tax compliance after your client bank is closed by the FDIC, (d) the tax attributes of acquiring a failed institution, and (e) tax and GAAP accounting for acquisitions of failed banks. We will, of course, continue the popular “current update” of developments since last year’s Workshop, discuss accounting methods and examination issues for both C corporation and S electing institutions., and keep some time for mergers and acquisitions.

	John Cederberg CPA	Steven Corrie Treasurer Security National Corporation		Kevin R. Sell CPA Heiskell MacGillivray & Associates, P.S.

	BANK TAX TUTORIAL 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 specialseven-hour tutorial.

	David A. Thornton Tax Executive Crowe Horwath LLP			James D. Slivanya Senior Tax Manager Crowe Chizek and Company, LLC

	BANK ACQUISITIONS WORKSHOP This workshop provides an in-depth look at developing tax and accounting strategies associated with the current wave of bank mergers and acquisitions and consolidations within the financial services industry. The workshop will be conducted at an intermediate to advanced level, and should be an invaluable experience for any advisor who is involved in any way with acquisition planning or reporting. Attend and concentrate on developing strategies and tax issues in bank acquisitions.

	Randy J. Churchill Senior Manager, Tax Moss Adams LLP		Mark Reis Partner Moss Adams LLP

MAIN CONFERENCE
Thursday, November 19, 2009

7:30 - 8:00	Registration Continental Breakfast/Exhibitors

8:00 - 8:15	OPENING REMARKS Glenn N. Eichen Head of Retail Tax TD Bank (Chairman)

8:15 - 8:45	*Keynote Address* James Chessen Chief Economist American Bankers Association

8:45 - 10:30	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 Head of Retail Tax TD Bank (Chairman)	Ron J. Copher Vice President, Senior Tax Counsel Glacier Bancorp, Inc. (Advisory Board Member)	Ellen Rotenberg Partner KPMG LLP (Advisory Board Member)
	Mark Price Principal, Washington National Tax KPMG LLP	Denise Schweiger Principal KPMG LLP

10:30 - 10:50	Coffee Break/Exhibitors

10:50 - 12:30	LOAN WORKOUTS/ASSET SECURITIZATION We know most of the rules on tax impacts of restructuring troubled debt assets and instruments. This session will take that knowledge and build a working model for using the tax implications of recovery of basis, hedging, character and mark to market accounting and tax rules and systems. We will discuss solutions to use and issues involving CDOs, CP Conduits, Auction Rate Securities, REMICs, specialized financial hedge products, and strategic transactions to address credit and interest rate risk in your businesses. The focus will be on the current day solutions that financial institutions in all three major segments of the industry are using to work through the resolution of some of the toughest asset portfolio issues of our time.

	Patrick Egan Director - Tax Planning New York Community Bancorp (Advisory Board Member)		Randy J. Churchill Senior Manager, Tax Moss Adams LLP (Advisory Board Member)
	Mark Reis Partner Moss Adams LLP

12:30 - 1:15	LUNCHEON

1:15 - 1:45	LUNCHEON ADDRESS Pamela F. Olson Partner Skadden, Arps, Slate, Meagher & Flom LLP

1:45 - 3:15	CONCURRENT SESSIONS A-1 RECENT DEVELOPMENTS IN STATE AND LOCAL TAXATION OF BANKS AND FINANCIAL INSTITUTIONS
	The panel will provide 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 developments, impact of federal bail-out legislation and other significant developments and issues affecting banks and financial institutions.

	Stewart J. Beyerle Executive Director FSI SALT Ernst & Young LLP	Steven W. Corrie Treasurer Security National Corporation (Advisory Board Member)
	Jeffrey B. Gotlinger National Director FSI SALT Ernst & Young LLP	Michael R. Johnson Partner - State & Local Tax Services Ernst & Young LLP

	A-2 IRS POLICIES AND PROCEDURES This panel will discuss developments concerning tax penalties, the IRS whistleblower program, tax accrual workpaper privilege issues, and IRS compliance initiatives. Our panel of tax professionals will discus the impact of these issues and related matters on taxpayers and tax practitioners in the areas of tax compliance, tax planning and tax controversy.

	Walter B. Doggett, III Corporate Tax Director The Wilmington Trust Company (Advisory Board Member)		Pete Wilson Managing Director RSM McGladrey, Inc.

	A-3 FINANCIAL PRODUCTS: "SECTION 475 ISSUES AND CURRENT FINANCIAL PRODUCTS DEVELOPMENTS" This panel will discuss selected issues arising under the mark-to-market rules of section 475. In addition to valuation theory (and book conformity), there are a number of practical and technical issues that confront tax departments and the IRS. Topics to be discussed include: (1) identification statements (best practices, practical considerations, and traps for the unwary), (2) scope of the tax mark-to-market book (practical considerations -- interaction with FAS 159, migration of position in or out, per-se held-for-investment positions), (3) overlapping section 475(f) "trader" elections (practical considerations), and (4) method change and consistency considerations when mark-to-market books are merged together or as valuation models are refined. This panel will also discuss late-breaking financial products issues relevant to the industry, including recently enacted and proposed legislation.

	Glenn N. Eichen Head of Retail Tax TD Bank (Conference Chairman)		Rebecca Lee Director PricewaterhouseCoopers LLP
	Jeff Maddrey Partner PricewaterhouseCoopers LLP		TBD Internal Revenue Service


3:15 - 4:00	COFFEE BREAK/EXHIBITORS

4:00 - 5:30	CONCURRENT SESSIONS B-1 STATE AND LOCAL TAXATION OF BANKS AND FINANCIAL INSTITUTIONS—LEGISLATIVE OUTLOOK
	This session will provide a review of recent developments in corporate income/franchise taxes, sales and use and other indirect taxes, and other compliance related issues. The panelists will highlight the various state legislative changes, state developments related to Federal programs impacting banks and financial institutions, and other significant developments and issues affecting banks and financial institutions.

	Edward J. Kane Executive Vice President, Director of Corporate Tax Huntington Bancshares Incorporated (Advisory Board Member)		Michael Desrochers Partner, SALT Income & Incentives KPMG LLP
	Fred James Partner, SALT Income & Incentives KPMG LLP

	B-2 TROUBLED ASSETS RELIEF PROGRAM (TARP) This session will provide an overview of tax issues resulting from the government's Financial Stability Plan and its various components. Planned topics include: ·Loan modifications ·Executive compensation ·Asset-backed securities ·Capital transactions

	James W. Ahern Senior Treasury Tax Advisor GMAC Financial Services (Advisory Board Member)		Kenneth W. Busey Partner and National Direction PricewaterhouseCoopers LLP
	Bruce Kamins Deputy Tax Director, Global Consumer Group Citigroup Corporate Tax Department

	B-3 S CORPORATION S corporation banks make up approximately 1/3 of all banks in the United States. Their pass-through structure poses some unique challenges and opportunities that will be explored in this session. We will also cover the impact of new and any proposed legislation, review relevant IRS audit issues and how to prepare for an examination, discuss issues related to S corporation banks participating in the Capital Purchase Program, and examine merger and acquisition issues and planning strategies.

	John P. Kinsella Senior Vice President and Director of Tax US Bancorp (Advisory Board Member)	Brett E. LaBelle Executive, Financial Institutions Group Crowe Horwath LLP	Kevin F. Powers Tax Executive Crowe Horwath LLP

	B-4 INFORMATION REPORTING AND WITHHOLDING Economic developments that have created debt restructurings and debt forgiveness bring about information reporting issues we have not had to focus on in the recent past. These issues, coupled with the recent elevation of IRC Section 1441 – foreign withholding and information reporting – to Tier I status and mandated legislative changes that will soon be upon us, make the information reporting landscape more challenging than ever. Join us for an informative session regarding the challenges faced by the financial services industry in complying with the information reporting and withholding tax rules. Our session will cover: ·Information reporting requirements related to debt forgiveness ·Background information - a review of the reporting, documentation and withholding tax rules for both foreign and domestic payees ·Discussion of new information reporting and withholding tax rules imposed upon credit card companies, banks and other payment settlement entities, and brokers ·Leading practices for compliance, including policies, procedures and technology ·Steps for identifying and remediating current compliance issues, along with suggestions for quantifying and addressing your potential withholding tax exposure

	Adrian Fenton Senior Vice President, Director of Tax PNC Financial Services Group, Inc. (Advisory Board Member)		Faye J. Tannenbaum Partner Deloitte Tax LLP
	Glenn Geffner Tax Partner Deloitte Tax LLP		Cheryl McClintock Tax Senior Manager Deloitte Tax LLP

5:30 - 6:45	NETWORKING RECEPTION

Friday, November 20, 2009

7:30 - 8:00 Continental Breakfast/Exhibitors

8:00 - 10:00
IRS DEVELOPMENTS
This 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. The session will also include a discussion of IRS releases affecting examination issues.

Dean M. Fischbeck
Senior Vice President
Bank of America
(Advisory Board Member)
Vincent J. Guiliano
Senior Counsel
Area Counsel, I.R.S.

Jeffrey Kammerman
Commercial Banking Technical Advisor
Internal Revenue Service

Larry Leubbers
Partner
Deloitte Tax LLP Neal Yaros
Partner
Deloitte Tax LLP

10:00 - 10:15 Coffee Break/Exhibitors

10:15 - 12:15 GAAP ACCOUNTING/FAS 109/IFRS
Has the current environment had an impact on your GAAP reporting? Are you exploring the differences between GAAP and IFRS for your institution? Are you responding to more inquiry around your accounting for income tax? If so, this session will cover some of the GAAP standards financial institutions are wrestling with and the similarities and differences between GAAP and IFRS. We will also cover some of the most recent FAS 109 disclosures and the impact on FAS 109 reporting as a result of the current market conditions.

Richard Garrison
Jeffries & Co.
(Advisory Board Member)

Clark Wulf
EVP & Corporate Tax Director
KeyCorp
(Advisory Board Member)

Christopher R. Arndt
Managing Director, International Tax Services
RSM McGladrey, Inc.

John Keyser
Partner and National Audit & Accounting Financial Institutions Industry Leader
McGladrey & Pullen



Marco Marcellan
Director, International Assurance Services Group
RSM McGladrey, Inc.

12:15 - 1:15 LUNCHEON

1:15 - 3:00 CONCURRENT SESSIONS
C-1 PURCHASE ACCOUNTING
After many years of deliberation and negotiation between the Financial Accounting Standards Board and the International Accounting Standards Board, new global accounting standards dealing with the accounting for business combinations, measurement of fair market value and accounting for minority interests were promulgated and became effective for US calendar year companies on January 1, 2009. The good news for those that never had to deal with the income tax accounting for business combinations is that just about all the rules have changed and the bad news for everybody is that all the rules have changed! This session with describe all of the changes to the income tax accounting for business combinations as well as the indirect changes caused by other changes in the rules as well as some practical advice on how to anticipate and be ready for some of the challenges that will arise under the new accounting standards, why business combinations may create significant volatility in corporate effective tax rates and the myth of the "one year window" to get it right! The presentation also will highlight other potential income tax accounting challenges associated with business combinations that have nothing to due with the new changes in the accounting standards.

John P. Kinsella
Senior Vice President and Director of Tax
US Bancorp
(Advisory Board Member)
P. Michael Baldasaro
Partner
Ernst & Young LLP

C-2 MERGERS & ACQUISITIONS
The session will review federal income tax developments and planning and accounting issues arising in mergers and acquisitions. Consideration will be given to the form of the transaction and the resulting consequences. Topics to be discussed include an analysis and review of common acquisition structures, new reorganization regulations, boot allocation in corporate reorganizations, handling target stock options, paying out deferred compensation, enhancing 280G limitations; resolving due diligence issues with S Corp elections and developments; closing down the target’s ESOP; recording the proper deferred taxes; and required disclosures with final returns

Richard E. Schumacher, Jr.
Senior Vice President, Tax
Alliance Data Systems Corp.
(Advisory Board Member)

Kevin R. Sell
CPA
Heiskell MacGillivray & Associates, P.S.

C-3 COMPENSATION
A comprehensive review of nettlesome day to day compensation tax issues including Employee benefits: what's taxable and what's not; how to assess the tax impact of proposed changes to extant deferred compensation plans; managing share based compensation planning in a down market; BOLI: What happens if you don't hold it till the death benefit is paid out; and Section 162(m) disclosure guidance.

Laura M. Gingrich, CPA
Vice President, Director of Financial Reporting and Tax
Washington Trust Bank
(Advisory Board Member)
Glenn R. James
Partner
Grant Thornton LLP

J. Henry Oehmann III CCP, CBP, CEBS, SPHR
Director-National Executive Compensation Services
Grant Thornton, LLP

3:00 -   3:20 QUESTION AND ANSWER SESSION
(Held within individual sessions)

3:20 Adjournment

Friday, November 20, 2009

7:30 - 8:00	Continental Breakfast/Exhibitors

8:00 - 10:00	IRS DEVELOPMENTS This 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. The session will also include a discussion of IRS releases affecting examination issues.

	Dean M. Fischbeck Senior Vice President Bank of America (Advisory Board Member)	Vincent J. Guiliano Senior Counsel Area Counsel, I.R.S.	Jeffrey Kammerman Commercial Banking Technical Advisor Internal Revenue Service
	Larry Leubbers Partner Deloitte Tax LLP	Neal Yaros Partner Deloitte Tax LLP

10:00 - 10:15	Coffee Break/Exhibitors

10:15 - 12:15	GAAP ACCOUNTING/FAS 109/IFRS Has the current environment had an impact on your GAAP reporting? Are you exploring the differences between GAAP and IFRS for your institution? Are you responding to more inquiry around your accounting for income tax? If so, this session will cover some of the GAAP standards financial institutions are wrestling with and the similarities and differences between GAAP and IFRS. We will also cover some of the most recent FAS 109 disclosures and the impact on FAS 109 reporting as a result of the current market conditions.

	Richard Garrison Jeffries & Co. (Advisory Board Member)		Clark Wulf EVP & Corporate Tax Director KeyCorp (Advisory Board Member)

	Christopher R. Arndt Managing Director, International Tax Services RSM McGladrey, Inc.	John Keyser Partner and National Audit & Accounting Financial Institutions Industry Leader McGladrey & Pullen	Marco Marcellan Director, International Assurance Services Group RSM McGladrey, Inc.

12:15 - 1:15	LUNCHEON


1:15 - 3:00	CONCURRENT SESSIONS C-1 PURCHASE ACCOUNTING After many years of deliberation and negotiation between the Financial Accounting Standards Board and the International Accounting Standards Board, new global accounting standards dealing with the accounting for business combinations, measurement of fair market value and accounting for minority interests were promulgated and became effective for US calendar year companies on January 1, 2009. The good news for those that never had to deal with the income tax accounting for business combinations is that just about all the rules have changed and the bad news for everybody is that all the rules have changed! This session with describe all of the changes to the income tax accounting for business combinations as well as the indirect changes caused by other changes in the rules as well as some practical advice on how to anticipate and be ready for some of the challenges that will arise under the new accounting standards, why business combinations may create significant volatility in corporate effective tax rates and the myth of the "one year window" to get it right! The presentation also will highlight other potential income tax accounting challenges associated with business combinations that have nothing to due with the new changes in the accounting standards.

	John P. Kinsella Senior Vice President and Director of Tax US Bancorp (Advisory Board Member)		P. Michael Baldasaro Partner Ernst & Young LLP


	C-2 MERGERS & ACQUISITIONS The session will review federal income tax developments and planning and accounting issues arising in mergers and acquisitions. Consideration will be given to the form of the transaction and the resulting consequences. Topics to be discussed include an analysis and review of common acquisition structures, new reorganization regulations, boot allocation in corporate reorganizations, handling target stock options, paying out deferred compensation, enhancing 280G limitations; resolving due diligence issues with S Corp elections and developments; closing down the target’s ESOP; recording the proper deferred taxes; and required disclosures with final returns

	Richard E. Schumacher, Jr. Senior Vice President, Tax Alliance Data Systems Corp. (Advisory Board Member)		Kevin R. Sell CPA Heiskell MacGillivray & Associates, P.S.

	C-3 COMPENSATION A comprehensive review of nettlesome day to day compensation tax issues including Employee benefits: what's taxable and what's not; how to assess the tax impact of proposed changes to extant deferred compensation plans; managing share based compensation planning in a down market; BOLI: What happens if you don't hold it till the death benefit is paid out; and Section 162(m) disclosure guidance.

	Laura M. Gingrich, CPA Vice President, Director of Financial Reporting and Tax Washington Trust Bank (Advisory Board Member)		Glenn R. James Partner Grant Thornton LLP
	J. Henry Oehmann III CCP, CBP, CEBS, SPHR Director-National Executive Compensation Services Grant Thornton, LLP

3:00 - 3:20	QUESTION AND ANSWER SESSION (Held within individual sessions)

3:20	Adjournment