Register online at http://www.law.villanova.edu/links/lawreview/

General registration incuding full program materials and Pennsylvania Continuing Legal Education Certificate ATTENDING THE PROGRAM *

For questions, call Megan Jacobs, Law Journals Coordinator, at 610-519-7053.

Legal Education Board for 5.5 substantive credits. Continuing Professional Education credit is also available.

Symposium-2011.*In addition, the program will be available by way of livestream at http://www.law.villanova.edu/VLR-Shachoy-

Villanova University School of Law John McDougal, Special Trial Attorney, IRS Office of Chief Counsel Bryan Skarlatos, Partner, Kostelanetz and Fink, and Adjunct Professor, New York University Graduate Tax Program Susan Morse, Associate Professor, University of California Hastings College of Law Leandra Lederman, William W. Oliver Professor of Tax Law, Indiana University Maurer School of Law

and formerly Director, Urban-Brookings Tax Policy Center Rosanne Altshuler, Professor and Chair, Rutgers University Economics Dept. School of Law and Graduate Tax Program

Ed Kleinbard, Professor of Law, University of Southern California and formerly Chief of Staff, Joint Committee on Taxation Mike Durst, Contributing Author, Tax Notes

and formerly Director, IRS APA Program Fritz Foley, Professor of Finance, Harvard Business School and Faculty Research Fellow, National Bureau of Economic Research

Kathryn J. Kennedy, Associate Dean for Advanced Studies & Research Professor, and Chair, Tax and Employee Benefits Practice Group, The John Marshall Law School Andrew C.W. Lund, Associate Professor of Law, Pace Law School

University of North Carolina Law School David I. Walker, Maurice Poch Faculty Research Scholar & Professor of Law, Boston University School of Law

is $125 ($30 if not receiving CLE credits). The program has been approved by the Pennsylvania Continuing

Gregg D. Polsky, Willie Person Mangum Professor of Law,

AGENDA

VILLANOVA UNIVERSITY LAW REVIEWNORMAN J. SHACHOY SYMPOSIUM

This symposium brings together leading academics, governmentofficials, practitioners, and journalists to discuss issues relating to the taxation of offshore activity - both individuals and MNC's, and the role of the tax laws regulating executive compensation.

Friday, September 23, 2011

8:15 - 8:25

accounts. The panel will discuss the civil and criminal penalties that face individuals seeking to hide assets offshore as well as the voluntary settlement initiatives that have been offered to individuals. Specific topics the panel will address include (1) use of John Doe summons and treaties to obtain information from offshore banks; (ii) what constitutes a valid voluntary disclosure; (iii) how to promote compliance among individuals who have taken money offshore; and (iv) the impact of FATCA and OECD rules in preventing the issue of offshore accounts to circumvent US taxation.

economic, and political issues and options surrounding the taxation of US MNC's

shifting by US MNC's; (ii) the range of policy options for addressing income shifting; (iii) the international competitive tax landscape; and (iv) the pros and cons of a territorial vs. a worldwide system of taxation.

tax laws in regulating executive compensation. In particular, the panel will discuss the use of the tax system to try to affect both the level and type of compensation paid to executives. Special emphasis will be placed on

offshore operations. Specific topics will include (i) the opportunity for income

discussing incentive pay and deferred compensation.

policy and technical issues facing individuals who have placed assets in offshore8:45 - 10:30 Tax issues surrounding individual offshore accounts - This panel will discuss

10:30 - 10:45 Break

Moderator Keith Fogg, Professor and Director of Federal Tax Clinic,

Villanova University School of Law. Welcoming Comments by Dean John Gotanda

8:25 - 8:45 Keynote speech by John DiCicco, Principal Deputy Assistant Attorney General (Tax), Department of Justice

Villanova University School of Law and Graduate Tax Program Introduction by Dick Harvey, Distinguished Professor of Practice,

1:30 - 3:30 Taxation of Executive Compensation - This panel will discuss the role of the

Moderator Dick Harvey, Distinguished Professor of Practice, Villanova University

10:45 - 12:30 Taxation of US MNC's offshore operations - This panel will discuss the tax policy,

Adjunct Professor, Villanova University School of Law Graduate Tax Program

3:30 - 3:40

Joseph E. Ronan, Jr., Senior Counsel, Morgan, Lewis & Bockius LLP, and

Villanova University School of Law and Graduate Tax ProgramModerator Joy Sabino Mullane, Associate Professor of Law,

12:30 - 1:30 Lunch with speech by Lee Sheppard, Contributing Editor, Tax Notes

Concluding Remarks by Leslie Book, Professor and Director of Graduate Tax Program, Villanova University School of Law