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.
2010 Joint Fall CLE Meeting, Toronto, ON
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Administrative Practice
Back-to-Basics: IRS Appeals
Future of International Enforcement in the Burgeoning Global Economy
Important Developments
IRS' Global High Wealth Industry - What to Expect and When
Affiliated & Related Corporations
Consolidated Tax Attributes - A Discussion about OFLs and DCLs
Current Developments in Consolidated Returns
Banking & Savings Institutions
Past, Present and Future of Equity Swaps
REMIC Update and Other Emerging Issues
The Effect of Increased Reporting on US Borrowing Activities, Foreign Investors and the Shadow Banking System
Capital Recovery & Leasing
Current Developments Report and Update on Pending Guidance
Civil & Criminal Tax Penalties
Civil Tax Penalty Abatements - Fact or Fiction?
- Panel Presentation
- Collateral Effects of Criminal Tax Conviction on Subsequent Civil Tax Penalty Proceedings
Reports of Subcommittees on Important Developments
- Civil and Criminal Tax Penalties: Important Developments - Criminal
- Important Developments on Civil Penalties: May 2010 through August 2010
Sensitive Issue Examination - Is Tweel Still Relevant?
The Quiet Revolution - FATCA and Bank Secrecy
Corporate Tax
Current Developments
US-Canadian Cross-Border Transactions
Court Procedure & Practice
Litigating The Application Of Anti-Tax Avoidance Statutes – Learning From The Canada Experience
Recent Developments
US and Canada Approaches To Litigating Cross-Border Transactions
Roundtable: What Works and What Doesn’t? Resolving Tax Disputes in the US and Canada
Employee Benefits
Executive Compensation - A Review of Selected Issues
- Roth Conversions: Fundamentals and Recharacterization
- Assessing the Impact of the Health Care Reform Insurance Non-discrimination Rules on Executive Employment Agreements
- Executive Compensation: Selected Topics
Form 5500 Update: EFAST2 Electronic Filing System, Expanded Schedule C Reporting and Other Important Changes
Hot Employee Benefits Topics
- Announcement 2010-20 and Amendment to PTE 84-14 (QPAMs)
- Employee Benefits Guidance Released May 7 – September 22, 2010
- Termination Of Abandoned Plans: An Overview Of The Department Of Labor Rules Including Recent Developments
Implementing Health Care Reform
- The Next Chapter in Healthcare Reform: Patient Protection & Preventive Care Regulations
- To Grandfather or Not to Grandfather - What Does It Really Mean?
Employee Benefits Subcommittee on Defined Benefit Plans
Employee Benefits Defined Benefit Plans Update
Employee Benefits Subcommittee on Foreign and International Issues
Employee Benefits International Update
- Foreign and International Issues Subcommittee Meeting
- Hot Topics in Canada-U.S. cross-border employee benefits
Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices
Employee Benefits Administrative Practices Update
Employee Benefits Subcommittees on Executive Compensation and Fringe Benefits and Federal Securities Laws Issues
Employee Benefits Executive Compensation, Fringe Benefits and Securities Law Update
Employee Benefits Subcommittees on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans
Employee Benefits Welfare Benefits Design, Funding and Regulation Update
Employment Taxes
Advanced Employment Tax Audit Techniques
Canadian and Cross Border Employment Tax Issues
Payments of US Source Income to Non-US Persons
Exempt Organizations
Citizens United: Implications of Corporate Political Free Speech for the EO Sector
Colleges and Universities – Current Audit Activity and What We Have Learned from the IRS Interim Report
Expenditure Responsibility: Ten Puzzling Practical Problems
The Effect of Health Care Reform on Hospitals
Fiduciary Income Tax
Recent Developments
Rethinking Roth IRA Conversions in 2010
Financial Transactions
Anschutz and Calloway: Finding the Owner of Publicly Traded Stock
- A Divided Tax Court Treats a Stock “Loan” as a Sale
- Tax Ownership Update: Three Recent Cases, but Has Anything Really Changed?
Swaps and Stock Loans: The Latest on Dividend-Equivalent Payments
Foreign Activities of US Taxpayers
Doing Business in Canada: What US Multinationals Need to Know
Economic Substance Codification – Issues for US Multinational Taxpayers
Individual & Family Taxation
Tax Consequences of Disasters
Insurance Companies
Canadian Taxation of Insurance Companies and Current Cross-Border Insurance Issues
Update on Recent Tax Guidance Affecting Insurance Companies and Products
- American Financial vs. United States: New Developments
- Recent Developments of Interest to Property-Casualty Insurance Companies
Investment Management
Implications of Proposed Carried Interest Legislation
Partnership Allocations
Joint: Business Planning Group (TE) and Closely Held Businesses (TX)
Co- Ownership in Professional Practices- A Taxing Problem
Practical and Tax Issues in Shutting Down a Closely Held Business with Tax and Non-Tax Debts
Primer on Tax Aspects and Mechanics of Entity Conversions
- Primer on Tax Aspects and Mechanics of Corporate Conversions
- A Summary of the Income Tax Treatment of LLCS in Conversion Transactions Under Delaware and Georgia Law
- Primer on Tax Aspects and Mechanics of Entity Conversions
- Tax Consequences of Conversions Involving LLCs
Joint: Business Planning Group (TE), Closely Held Businesses (TX) and S Corporations (TX)
Choice of Entity in Light of New and Proposed Legislation
- Choice of Entity in Light Of New and Proposed Legislation
- Choice of Entity in Light Of New and Proposed Legislation
- Choice of Entity in Light of New and Proposed Legislation
Important Developments
- Panel Presentation
- Important Developments Relating to Closely Held Businesses and Their Owners
- Current Developments
International Tax Aspects of Cross Border Business of Closely Held Businesses in Canada
Joint: Estate & Gift Taxes (TX) and Income & Generation Skipping Transfers Committee of the Income and Transfer Tax Planning Group (TE)
Tax Apportionment Clauses: Friend or Foe
Joint: Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE)
Current Developments
Expatriation Under Section 877A's Mark-To-Market System, and What Notice 2009-85 Did and Did Not Tell Us
Tax Issues in International Philanthropy
Joint: Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittee
How to Develop an Estate Planning Practice
Joint: FAUST, Transfer Pricing & USAFTT (TX)
Joint International Developments Panel
Joint: Young Lawyers Forum & Diversity (TX)
Are You (Too) Confident About Your Tax Opinions?
LLCs And LLPs Subcommittee of Partnerships & LLCs
LLC's and Partnerships: Recent Canadian Tax Developments - What Works and What Does Not
Low Income Taxpayers
History of Low Income Tax Clinics
How to Start a Low Income Tax Clinic
Partnerships & LLCs
Don't Get Carried Away by Carried Interests
Economic Substance in Partnership Transactions--Is it the Chicken Little of Legitimate Tax Planning?
Hot Topics in Partnerships
Real Estate
Debt Modifications -- New Developments in a Still Recovering Economy
Real Estate Roll-Up Transactions -- How Much Has Changed?
The Grass Is Greener -- Inbound and Outbound Investments in US and Canadian Real Estate
- Canadian Acquisition of U.S. Real Estate
- Investment in US Real Property by Canadian Institutional Investors -- US Tax Structuring Considerations
- US Tax Structuring Considerations -- Inbound Investment in US Real Estate by Canadian Institutional Investors
- US Residents Investing in Canadian Real Estate
Sales, Exchanges & Basis
Codification/Clarification of Economic Substance - The Rubber Meets the Road in Common Transactions
Current Non-Section 1031 Developments
Like-Kind Exchange Current Developments
The 2011 Tax Increases Are Comne - Carpe Diem
Section Program: Joint: Estate & Gift Taxes (TX and TE)
Donee Selection and Practical Consideration Under Petter Formula Allocation Clauses
- Using Tax-Exempt Entities as Donees of the “Excess Value” Under a Formula Allocation Clause
- Donee Selection and Practical Considerations Under Petter Formula Allocation Clauses
Section Program: Joint: Low Income Taxpayers, Administrative Practice, Court Procedure and Practice, Individual & Family Taxation and Pro Bono
Innocent Spouse: Administrative and Litigation Issues on Innocent Spouse Cases
- Innocent Spouse Flow Chart
- Update of Innocent Spouse Cases 2008-2010
- Legislative Solution to Issues Raised in Innocent Spouse Cases
Section Program: Tax Exempt Financing and Exempt Organizations
Structuring Innovative Management Contracts for Bond Financed Projects
Standards of Tax Practice
Ethical Issues in Federal Administrative Tax Practice
Ethics and the Codification of Economic Substance
State & Local Taxes
Current and Thorny Unclaimed Property Issues
- Current and Thorny Unclaimed Property Issues
- The Canadian Law on Unclaimed Intangible Personal Property
Executive Committee Reports on Current SALT Issues Part 2: Are We There Yet?: Getting to 50 State Tax Tribunals -- An Update on the Model Tax Tribunal Act
- Memo Re: Model Act developments since May, 2010, Meeting
- Are We There Yet? Getting To Fifty State Tax Tribunals - An Update On The Model Tax Tribunal Act-Louisiana
Luncheon: New Breed of Amazon "Taxes" - - Colorado's Clever Twist
Purchasing Digital Products – A Comparison of Canadian and US Taxes
Recent State Challenges to Related Party Transactions and the Success or Lack Thereof: Business Purpose, Sham and Economic Substance Assertions Abound
Tax Accounting
Accounting Method Issues Arising with respect to Losses and Bad Debts
Distinguishing Non-Deductible Fines and Penalties from Deductible Business Expenses
Recent Developments in Tax Accounting Methods
Tax Exempt Financing
Legal Issues Related to the Paid Preparer Requirements for Forms 8038
The Issue Price Conundrum
Tax Practice Management
Beyond the Basics: Understanding Financial Statements for Tax Lawyers
Teaching Taxation
Employing Stock: US and Foreign Taxation of Employee Stock Options
- Cross-Border Stock Options
- Compensating International Executives with U.S. Stock Options
- Summary of Key Points: Stock Options and Stock Grants
- Employing Stock: U.S. and Foreign Taxation of Employee Stock Options
- Employee Stock Options: A Microcosm of Tax Policy Choices
Transfer Pricing
US - Canada Hot Transfer Pricing Issues
US Activities of Foreigners & Tax Treaties
Codification of Economic Substance -- Can we Predict the Future by Looking at the Past?
Pitfalls and Benefits of Foreign Corporation using LLCs in the US