2006 Joint Fall CLE 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.

2006 Fall Meeting, Denver, CO

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Banking and Savings Institutions

• Prop. Reg. § 1.1221-1(e), The New Bank One, Prop. Reg. § 1.1363-1(b)(2)

Business Planning Group (PT), Closely Held Business (TX)

• Introduction to Preferred Partnerships

Business Planning Group (PT), Litigation and Controversy Group (PT), Closely Held Business (TX)

• Transfer Tax Issues Affecting Changes in Entity

Civil and Criminal Tax Penalties

• Attorney-Client and Constitutional Privileges

Closely Held Businesses; Business Planning Group

• Estate Tax Planning for the Sale of Business Interests
• Estate Tax Planning for the Transfer of Business Interests
• Structuring Ownership of Privately-Owned Businesses: Tax and Estate Planning Implications

Closely Held Businesses; Business Planning Group; Litigation and Controversy Group

• Mediation Statutes/Rules/Procedure Chart
• Practical Problems in Succession Planning for Small, Family Owned Businesses

Commercial Real Estate Transactions Group RP

• Recent AIA Design-Build Changes from the Owner's Perspective

Employee Benefit Plans and Other Compensation Arrangements Group PT

• When an Employee or Family Member Becomes Disabled: Helping Patients, Families & Their Employers Cope

Employee Benefits

• Application of SOX’s Professional Responsibility Rules to Corporate Employee Benefits Practice
• Emerging Ethical Considerations for Fiduciary Lawyers
• Summary of Provisions of the Pension Protection Act of 2006 Affecting Defined Benefit Plan Funding and Hybrid Plans
• Timing of Plan Amendments

Employee Benefits Subcommittee: COBRA and Welfare Plan Design Issues; HIPAA; State Insurance Regulation of Welfare Plans; Cafeteria Plans and Flexible Benefits; Retiree Health, VEBAs and Other Funding Vehicles (Tax); Welfare Plan (RPPT)

• Massachusetts Health Care Reform — The Impact of Ch. 58 of the Acts of 2006 on Employers and Employees
• An Employer’s Guide to the 2006 Massachusetts Health Care Reform Act

Energy and Environmental Taxes

• Monetizing Production Tax Credits From Alternative and Renewable Energy Projects
• The Pool of Capital Doctrine
• The Pool of Capital Doctrine (powerpoint conversion)

Estate & Gift Taxes (TAX), Fiduciary Income Tax (TAX) and Probate and Trust Division (PT)

• Estate Planning Hot Topics Update

Estate and Gift Taxes

• Basic GRAT Funding and Administration Issues
• Current Developments in Estate Planning
• Estate Tax Legislation
• GRAT Planning - The Basics
• Structuring Transfers and Trusts to Qualify for Gift and GST Tax Exclusions for Educational and Medical Expenses Under §§ 2503(e); 2611(b); and 2642©
• The Care and Feeding of GRATs – Enhancing GRAT Performance Through Careful Structuring, Investing and Monitoring

Exempt Organizations

• Community Impact Oppotunities for Exempt Organizations

Fiduciary Income Tax

• Holding Private Company Interests in Trust
• Recent Developments in Fiduciary Income Tax
• Selected Income Tax Issues of Interest to Estate Planners
• Trusts and Beneficiaries of Qualified Plans and Individual Retirement Arrangements: New Developments

Foreign Activities of US Taxpayers

• Mission Impossible III: Understanding Current Cross-Border M&A Issues

Hospitality, Community Recreation and Common Interest Developments RP

• Ethical Issues for Transactional Lawyers
• Recent Events May Put the Brakes on Government Requests for Privilege Waivers in the Context of Corporate Criminal Investigations

Income and Transfer Tax Planning Group PT

• GRATS – Unresolved Issues, Potential Pitfalls and Random Observations
• Handling an IRS Estate or Gift Tax Audit and Beyond
• Summary of Selected Recent GST Tax Private Letter Rulings
• The New Era of the Hybrid Trust

Individual and Family Taxation

• CLE Panel Presentation Outline
• Family Tax Planning
• Tax Benefits Threatened

Leasing RP

• Business Interruption Insurance (Including Business Income)
• Destruction, Casualty and Major Forces
• Force Majeure Clauses in Leases
• Indemnification Provisions in Leases: What We Ask For and What Really Matters

Partnerships & LLCs

• Identifying Partners’ Interests in Partnership Profits and Capital
• The New Texas Margin Tax: (more than a marginal change to the Texas landscape)

Plenary Session

• Patenting Tax Planning Methods

Real Estate

• Defeasance Transactions
• Structuring Foreign Investments by U.S. REITS

Real Estate Financing Group RP

• The New ALTA/ACSM Survey Standards

Real Estate Taxation and Governmental Incentives RP

• A Basic Examination of Tax Increment Financing ("TIF") from the Perspective of Both Lawyers and Underwriters (outline and ppt presentation)

Residential, Multi-Family and Special Use RP

• Pricing the Equity of a Tax Credit Project: An Institutional Investor's Perspective

S Corporations

• Corporation’s Status as an S Corporation Due Diligence Checklist
• Oops, There Goes My S Election

Sales, Exchanges and Basis

• Real Estate - Preserving Capital Gains, Dealer Issues

Section Program: Closely Held Businesses Committee; Business Planning Group; Employee Benefit Plans and Other Compensation Arrangements Group

• Impact of § 409A Deferred Compensation Rules on Estate & Retirement Planning for Executives and Structuring the Sale or Business Succession of Closely Held Businesses
• The Application of Section 409A to Separation Pay Arrangements
• Transfer of Family Business Interests: Finding the Sweet Spot between General Income Tax, Chapter 14, and Code § 409A

Section Program: Employee Benefits

• The New Reality: The War on Deferred Compensation - How to Live with the New Section 409A Rules

Section Program: Foreclosures, Workouts and Bankruptcy (RP)

• Tenant Bankruptcies: Landlord’s Survival Kit Course Materials

Section Program: Generation Skipping Transfers Committee (PT)

• Extensions of Time to Make Timely GST Exemption Allocaitons and Reverse QTIP Elections

Section Program: Litigation and Controversy Group

• Damages for Breach of Fiduciary Duty
• Measuring Damages in Fiduciary Litigation -- A Review of Decisions and Trends

Section Program: Litigation and Controversy Group (PT)

• Family Limited Partnerships: A Practical Guide to Fighting Legal Pitfalls

Standards of Tax Practice

• Determing the Disciplinary Sanction: What Factors Are Considered In Ethics Enforcement

State and Local Taxes

• Income and Franchise Tax Developments

Tax Accounting

• Capitalization of Costs for Tangible Property Outline
• Domestic Manufacturing Deduction, Summary of Final Regulations

Teaching Taxation

• When a Gift is Not a Gift: Property Transfers to Family Caregivers

Wealth and Non-Tax Estate Planning Considerations (PT)

• The Power to Adjust and Total-Return Unitrust Statutes: State Developments and Tax Considerations
• Total Return Trusts – The Background