2001 Annual Meeting

Section Meeting Materials Archive

Thousands of pages of cutting-edge committee program materials presented at Section of Taxation Meetings from May 1999 to the present are available to all Tax Section members in TaxIQ. These PDF documents contain analysis of the latest federal tax policy, initiatives, regulations, legislative forecasts, and planning ideas developed by the country's leading tax attorneys and government officials.

2001 Annual Meeting, Chicago, IL

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Administrative Practice

• Selected Recent Developments in Administrative Practice
• Some Observations on Establishing Independence: The Prohibition of Ex Parte Communications By Appeals Officers

Agriculture

• Farm Leasing Alternatives Including Income Tax, Social Security and Estate Tax Ramifications and Government Farm Programs
• McNamara: Eighth Circuit Sends IRS Back to Bird Island in Search of Nexus!

Capital Recovery & Leasing

• ETI Leasing Structures: The Past is Prologue

Closely Held Businesses

• Limited Liability Companies: Applications for Real Estate, Business and Estate Planning
• Panel Discussion on Valuation: Discounting of Minority Interests In Corporations, Partnerships, and Limited Liability Entities
• Recent Developments Affecting Real Estate and Pass-Through Entities
• Section 2704(b) and Valuation of Family Partnership Interests: Kerr v. Commissioner
• Tax Court Decision Threatens Personal Service Corporations—Impacts Choice of Entity Decision
• Tax Issues in Bankruptcy for Small Business Owners

Corporate Tax

• Impact of Sales and Use Taxes on Corporate Transactions
• Real Estate Transfer Taxes and Business Acquisitions
• State and Local Tax Aspects of Section 368(h)(10) Transactions
• State and Local Income and Franchise Tax Aspects of Corporate Acquisitions

Court Procedure & Practice

• Summary of Current Developments

Employee Benefits

• Experimental Treatment Exclusions: Recent Course Cases 1995–Present
• Implications of EGTRRA for Retirement Plans of Tax-Exempt Organizations
• Outline of the Impact of the Economic Growth and Tax Relief Reconciliation Act of 2001 On Section 401(K) Plans and Issues That May Need Clarification
• Paying Enhanced Pension Benefits to Involuntarily Terminated Employees
• Phased Retirement: Transforming the End of Work
• Recent COBRA and HIPAA Cases
• Selected Issues Under Section 83
• Severance Pay Basics
• Supplemental Unemployment Benefits As Severance Pay: What's Old is New Again
• Tax Qualification: Practical Uses and Limitations of the 401(b) Remedial Amendment Period

Employment Taxes

• Important Developments for the Period May 8, 2001 Through July 29, 2001

Estate & Gift Taxes

• The Code Sec. 705 Proposed Regulations - Fact or Fiction?
• Community Property Laws and Selected Planning Issues
• Current Tax Tips and Traps in Charitable Planned Giving
• Interrelated Computations and the Estate and Gift Tax
• Preliminary Consideration of Gift, Estate and Generation-Skipping Transfer Tax Planning Issues After Enactment of the Economic Growth and Tax Relief Reconciliation Act of 2001
• Selected Developments in Income, Estate, Gift, & Generation-Skipping Transfer Tax: April 16–July 13, 2001

Exempt Organizations

• Accountability of Religious Institutions: Reference Materials
• I Want To Use A Life Line: Flunking the Public Support Test—Options and Alternatives
• Public Support: The Basics
• Tax-Exempt Organizations: Requirements to Disclose to the IRS

Fiduciary Income Tax

• Drafting Concerns With Potential ESBTs
• Fiduciary Income Tax Recent Developments
• Notice 2001-10

Foreign Activities of U.S. Taxpayers

• Summary Outline of Proposed Circular 230 Regulations
• Summary Outline of Temporary and Proposed Corporate Tax Shelter Regulations
• Transparencies—A Canadian Perspective
• Use of Nova Scotia Unlimited Liability Companies (NSULCs) by Americans

Joint Session: F.A.U.S.T.; F.L.F.; U.S.A.F.T.T.

• Current Developments Panel: Withholding Issues
• New U.K.-U.S. Treaty Announced
• Proposed Reverse Hybrid Regulations

Insurance Companies

• A Chronological History of the Treatment of Insurance Companies Electing Under I.R.C. Section 338

Low Income Taxpayers

• The Attorney-Client Privilege and Work Product Doctrine: Concerns of Tax Practitioners
• Section 7525: The Tax Practitioner Privilege

PLENARY SESSION

• Transfer Taxes After the 2001 Act

PRESIDENTIAL SHOWCASE

• Allocating the Cost of Dividing Business Interests in Divorce Settlements
• Executive Compensation in Divorce
• Income Tax Pitfalls and Planning Techniques in Divorce Cases2
• Planning for Property Transfers: Business Divisions and Compensatory Property Transfers

Real Estate

• Letter to the Internal Revenue Service Regarding Rev. Proc. 2000-46 I.R.B. 438
• Liquidation of UPREIT Checklist
• REIT Mergers & Acquisitions: Tax Consequences

S Corporations

• Executive Compensation Plans for S Corporations
• Recent Developments Relating to the Taxation of S Corporations: May 12 through July 31, 2001

Sales, Exchanges & Basis

• Current Developments
• Everything You Wanted To Know About Like-Kind Exchanges
• The Future of Section 1031
• Panel on the Future of Section 1031: The Staff of the Joint Committee Proposal to Replace Section 1031 with a Rollover Rule
• Section 1031 Current Developments
• Section 1031 Exchanges: Part 1: Nuts & Bolts Presentation
• Steps in Successful Reverse Parking Exchange
• "Together" But not as the Tax Law Envisions—Overview to Tax Considerations of Property Transactions Between Unmarried Individuals

Standards of Tax Practice

• Estate Planning and Conflict of Interest

State & Local Taxes

• Establishing Arm's Length Royalty Rates For Intellectual Property Transferred To Intangible Asset Holding Companiess
• Streamlined Sales Tax Project

Teaching Taxation

• Equity and the Article I Court: Is the Tax Court’s Exercise of Equitable Powers Constitutional?

U.S. Activities of Foreigners & Tax Treaties

• Sourcing Income From Space and Ocean and Certain Communication Activities Under the Proposed Regulations
• Tax Ownership and Ethical Minuets