On August 21, Chicago tax partner Nathaniel Carden and associate Matthew Hofheimer spoke at an International Fiscal Association USA Midwest Region Panel Discussion, held in Skadden's Chicago office. Mr. Carden welcomed the participants and provided introductions. Mr. Hofheimer joined a panel discussion on "U.S. Controversy Developments and Implications for Substantive Tax Planning." The panel covered recent trends arising in audits, litigation and published guidance and compared the courts' and the government's views of the underlying issues. The panel also discussed strategies for preparing for a potential government challenge while still in the transaction planning stage.