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.
Materials by Committee
Administrative Practice
Current Developments
Phone a Friend: When and How To Involve Others in the Government When Your Corporate Examination Languishes
- Slides: Navigating the IRS: Phone a Friend--When to Involve Others in the Government When…
- Slides: When and How to Involve Others in the Government When…
Update on IRS Audit Procedure
Affiliated & Related Corporations
Intercompany Debt Issues and Traps: A Discussion and Overview of the Rules Governing the Treatment of Intercompany Obligations, with a Transactional Focus
Tax Issues Arising from Tax Sharing Agreements
Current Developments in Banking / Capital Markets Taxation
Practical Considerations in Dealing with the Final Cost Basis Reporting Regulations for Debt, Options and Securities Futures Contracts
Repurchase Agreements and Dollar Rolls
Capital Recovery & Leasing
Current Developments Report and Update on Pending Guidance
Research and Development: A Discussion of Recent Developments and Overlying Issues
Tax Credit Hot Topics
Civil & Criminal Tax Penalties
Department of Labor - Civil and Criminal Enforcement
Navigating the Civil Employment Tax Audit and Related Issues
Advising the Fiduciaries of Trusts Holding Business Interests
Beyond IRC Section 6166; the Future of Graegin-style Loans
Succession Planning for Closely Held Businesses and Professional Practices
Transfer Planning with Carried Interests in Hedge and Private Equity Funds
Corporate Tax
Section 355 Transactions in the Cross-Border Context
Court Procedure & Practice
Important Developments
Insolvency and Tax: Advising Clients About Tax Matters in the Course of Bankruptcy
Litigating Cross-Border Transactions in US Courts
Employee Benefits, Subcommittee on Employee Benefits Legislation
Legislative Update
Employee Benefits, Subcommittee on ESOPs (TX) and Fiduciary Responsibility, Administration and Litigation (TE)
ESOP Update
Employee Benefits, Subcommittee on Litigation
Litigation Update
Employee Benefits, Subcommittee on Mergers & Acquisitions (TX) and Plan Transactions & Terminations Committee (TE)
Mergers & Acquisitions Update
Employee Benefits, Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices
Administrative Practices Update
Aftermath of the Supreme Court’s DOMA Decision
- Slides: Aftermath of Supreme Court's DOMA Decisions
- Paper: Employee Benefits Affecting Employees in Same Sex Marriages…
Attorneys Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and Beyond
- Slides: Legal Review of Employee Benefits Plan Services Agreements
- Slides: The Art of Understanding and Documenting Fees
- Chart: Attorney Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and Beyond
Hot Topics
- Paper: Notice to Employees…
- Paper: Wellness Programs Final Regulations
- Paper: Congress and DOL Consider Requiring Lifetime...
Independence Considerations in Employee Benefits – When Is a Service Provider Truly Independent?
Employment Taxes
Affordable Care Act and Its Impact on the Characterization of a Workforce
- Paper: Overview of Recent Judicial Opinions…Worker Classification
- Paper: Voluntary Classification Settlement Program
The Doom of DOMA, Keeping the Faith and Taking Credit
UI Integrity Act
Energy & Environmental Taxes
Begun Construction Test and the New PTC – How are Companies Planning to Meet the Test?
Estate Planning Without a Passport: Section 2801 and Other International Hot Topics
Much Ado About Something: Clash of the Agent, Attorney and Appraiser in Gift Tax Audits (in 4 Scenes)
Exempt Organizations
Cause Related Marketing & Commercial Co-Ventures
New Market Tax Credits
News from the IRS and Treasury
- Paper: Senate Finance Committee Staff Tax Reform Options for Discussion
- Slides: Current Developments Written Materials for “News from the IRS and Treasury”
Donor Advised Funds
Helping the IRS: 501(c)(4) Reform Proposals
Estate Planning for Real Estate Owners: Don’t Forget the Income Tax Side
- Paper: Estate Planning for Real Estate Owners: Don't Forget…
- Slides: Estate Planning for Investment Real Estate: Don't Forget…
Material Participation Under Passive Activity Limitations and Net Investment Income Tax
Financial Transactions
Financial Transaction Committee Reports on Camp
Futurization of Swaps - What the Clients are Dealing with Now
Tax Planning with REMICs: Everything Old is New Again
Foreign Activities of US Taxpayers
Issues and Challenges Arising Under the Foreign Tax Credit
Unresolved International Tax Issues in M&A Transactions
Individual & Family Taxation
"Helpful Tips on How to Bring a Case to Taxpayer Advocate Service and Recent Changes to IRS Collection Alternatives"
- Slides: Working With the Taxpayer Advocate Service
- Slides: Helpful Tips on How to Bring a Case to TAS and Recent Changes to IRS Collection Alternatives
How Implementation of the Affordable Care Act Impacts Individual Taxpayers
Reporting Foreign Source Income
Insurance Companies
Captive Insurance: Back in the spotlight
Insurance M&A: What are the biggest issues around Deferred Tax Assets?
Modern Family, Tax Policy and the Taxation of Insurance Products Post Windsor
- Outline: Income and Transfer Tax Issues After IRS Announcement on Same-Sex Marriage
- Chart: Status Recognition Chart for Same-Sex Couples
Investment Management
An Overview of Business Development Companies (“BDCs”) and Uses of These Vehicles in the Current Climate
Current Developments Regarding Tax Issues for Hedge Funds
Current Issues Confronting Regulated Investment Companies
Joint: Closely Held Businesses (TX) and Business Planning Group (TE)
Advising the Fiduciaries of Trusts Holding Business Interests
Joint: Court Procedure & Practice and Tax Litigation & Controversy Committee of the Income & Transfer Tax Planning Group Roundtable Discussion
Effective Use of Demonstrative Exhibits and Summary Exhibits in Tax Cases
Joint: Diversity and Employee Benefits International Issues
Leaving the US – It’s Very Different from Leaving Las Vegas. Tax Planning for US Persons Living and Working Abroad
Joint: Employee Benefits (TX) and Employee Benefit Plans & Other Compensation Arrangements Group (TE)
Aftermath of Litigation: What Plan Language and Administration Do You Need Now?
Joint: Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE)
Current Developments
Joint: Exempt Organizations (TX) and Charitable Planning & Exempt Organizations Group (TE)
Donor Advised Funds
Joint: Fiduciary Income Tax (TX) and Income & Transfer Tax Planning Group (TE)
Current Developments
Joint: Foreign Activities of US Taxpayers, Transfer Pricing and US Activities of Foreigners & Tax Treaties
Joint Current International Developments Panel
Partnerships & LLCs
Sailing in Circles: Forthcoming IRS Guidance on Partnership Transactions involving a Partner’s Stock
Sailing into Unchartered Waters: Subchapter K Tax Reform
- Paper: Testimony Before the Subcommittee on Select Revenue Measures
- Slides: Chairman Camp Discussion Draft
- Supplement: Technical Explanation of the Ways and Means Committee Discussion Draft Provisions to Reform the Taxation of Small Business and Passthrough Entities
Tightening the Lines: IRS to Restrict Partnership Debt Allocations
Pro Bono & Tax Clinics
Developments in Collection Due Process
Recent Developments Affecting Low Income Taxpayers
The Impact of US v. Windsor on the Civilian and Military Taxpayers
- Outline: Which Marriages Should be Recognized by the IRS
- Outline: Specific Tax Issues Raised by the Fall of DOMA
- Chart: Status Recognition Chart for Same-Sex Couples
Update on Procedures from the Tax Court
Real Estate
Hot Topics
Setting up your Private REIT – A Practical Primer
State Tax Enforcement Areas – An Insider’s Perspective
- "Outline: State Tax Enforcement Areas An Insider's Perspective "
- "Slides: State Tax Enforcement Areas An Insider's Perspective"
Tax Credit Planning After Historic Boardwalk and Anticipated IRS Guidance
- Paper: Credit Where Credit Is Due? Who Is a Partner after Historic Boardwalk?
- Slides: Historic Boardwalk
S Corporations
Charitable Gifts by S Corporations and Their Shareholders
Current Developments
Tax Effects of Converting Entities Under State Law Conversion and State Law Merger Statutes
- Outline: Tax Effects of Converting Entities Under State Law Conversion and State Law Merger Statutes
Sales, Exchanges & Basis
Analyzing the Section 1031 “Disqualified Person” Rules: The Usual Suspects and Beyond
Current Developments in Sales, Exchanges and Basis
Tax Planning Workshop: “Drop & Swap” and “Mixing Bowl” Techniques
The Very Rare Find: A Section 1031 Collectible Exchange with Definite Answers
- Paper: Section 1031 and Approximate and Midstream Business Transactions
- Slides: Tax-Deferred Exchanges of Art…
Section Program
Estate & Gift Taxes (TX) and the Income & Transfer Tax Planning Group (TE)
Standards of Tax Practice
Ethical Issues Arising from Conflicts of Interest, Especially When Criminal Tax Charges are on the Horizon.
Ethical Issues in Federal Tax Practice - The Government Perspective
State & Local Taxes
Could The Due Process Clause Rain on the Nexus Everywhere Parade?
State and Local Tax Issues for International Commerce.
- Slides: State Tax Issues for International Commerce
- Outline: State Income Taxation of Foreign Corporations
- Outline: State Tax Implications of International Transactions Relevant Federal Tax Concepts and Special Situations
Transparency Under A Different Light: Discovery, Settlements and Confidentiality
What if the Marketplace Fairness Act Becomes Law?
Tax Accounting
Accounting Methods Issues Related to Short Year Returns
- Handout: Accounting Method Issues Related to Short Year Returns Guidance Excerpts
- Outline: Accounting Method Issues Relating to Short Year Returns Scenarios
Current Developments
Tax Accounting Issues in International Tax Planning
Tax Exempt Financing
Legislative Department of Treasury and IRS Update
Tax Implications of Direct-Purchase (Private Placement) Bonds
Tax Round Table
Tax Policy & Simplification
Implementing the Affordable Care Act in 2014 and Beyond
- Slides: The Not-So-Mandatory Individual Mandate
- Slides: Premium Tax Credits under the ACA
- "Paper: Perverse Incentives Arising from the Tax Provisions of Healthcare Reform:"
What Can Tax Lawyers and Economists Learn from Each Other?
- Slides: Economists are from Mars, Lawyers are from Venus
- Paper: Economists are from Mars, Lawyers are from Venus
- Article: Perverse Incentives Arising from the Tax Provisions of Healthcare Reform
Tax Practice Management
Social Media and Your Practice: Avoiding Ethical Pitfalls
Social Media and Your Practice: Using It Effectively
Teaching Taxation
Would You Like a Calculator with that Diploma? Student loans and taxes
- Slides: LRAPs and Section 108(f)
- Outline: Discharge of Student Loans in Bankruptcy
- Outline: Student Loans, Taxes, and the American Dream in Retrograde
- Chart: Payment Scenarios
Transfer Pricing
Leading Transfer Pricing Cases in Current Litigation
The 3M Case and Blocked Income
US Activities of Foreigners & Tax Treaties
Applying the Permanent Establishment Rules in the Digital Age
Planning for “Inbound” US Investments Through Foreign Trusts
Young Lawyers Forum
Tax Planning for Natural Disasters