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
Important Developments
It’s a Privilege, or Is It?
Kicking it Upstairs — How to Elevate Issues Within the IRS
Banking & Savings Institutions
Current Developments
Taxation of Letters of Credit and Guarantee Fees in the Aftermath of Container Corp.
Capital Recovery & Leasing
Current Developments Report and Update on Pending Guidance
Issues and Considerations Involving Tenant Improvement Allowances
- Outline: Issues and Considerations Involving Tenant Improvement Allowances
- Outline: Examples - Issues and Considerations Involving Tenant Improvement Allowances
Tangible Property Regulations Update – Continuation from the May Meeting – Disposition Regulations, FAQs, and Related Discussions
Civil & Criminal Tax Penalties
Reports of Subcommittees on Important Developments
- Outline: Developments in International Tax Enforcement
- Outline: Important Developments - Criminal
- Outline: Developments on Civil Penalties
Statutes of Limitations in International Civil and Criminal Tax Matters – The Rules and the Many Exceptions
CLE Committee
Section Program: Harshing My Buzz - Federal Income Tax Rules Affecting "Legal" Marijuana Businesses
Closely Held Businesses (TX) and Business Planning Group (TE)
Basis Planning With Pass Through Entities
- Outline: Basis Planning with Passthrough Entities
- Outline: Venn Diagrams: The Intersection of Estate & Income Tax (Planning in the Atra-Math)
- Slides: Basis Planning with Pass Through Entities
Pre-Death and Post-Death Estate Planning for Closely Held Businesses
Succession Planning for Closely Held Businesses and Professional Practices — II
- Article: Planning for the Successful Transition of a Family Business to the Next Generation
- Outline: Succesion Planning for Dental and Dental Specialty Practices - II
- Slides: Succession Planning for Dental and Dental Specialty Practices - II
Tax Traps Involved in Related Party Transactions with Family or Closely Held Businesses
Corporate Tax
Current Developments
Tax Opinions 3.0? – Ethical Considerations and Best Practices Under the New Circular 230 Rules
Court Procedure & Practice
Beyond Deficiency, Liability and CDP Cases: The Other Jurisdictional Areas for the US Tax Court
Court Procedure and Practice Roundtable Discussion: Whistling Where Your Clients Work
Expert Witnesses: Experts in the Trenches: Risk, Fair Rewards, Economic Substance, and Shams
Important Developments
Diversity
Obtaining PLRs, CAMs and Section 9100 Relief
- Outline: Obtaining PLRs, CAMs and Section 9100 Relief
- Slides: Obtaining PLRS, CAMS and Section 9100 Relief
Employee Benefits
Administrative Practices Update
Affordable Care Act: Reporting 2015 Enrollment and Eligibility and the Looming Cadillac Tax
Defined Contribution Plans Update
- Outline: Department of Labor to Look Through the Brokerage Window
- Article: Clark v. Rameker: Effects on Tax-Qualified Retirement Plans
Department of Labor Employee Benefits Security Administration Regulatory Update
Employee Benefits in Tax Court - A Discussion with IRS Chief Counsel
- Outline: Perspective of Taxpayer Counsel
- Supplement: Selected Tax Court Decisions in the Last 12 Months Addressing Qualified Plan and IRA Issues
ERISA After 40 Years
ESOP Update
Executive Compensation, Fringe Benefits and Federal Securities Law Update
Exempt Organization and Governmental Plans Update
- Outline: Windsor and Subsequent IRS Guidance: Considerations for Governmental Plans
- Summary: Recent Developments in Church Plan Litigation
- Outline: Typical Requests in a 403(b) Audit
Fiduciary Responsibilities Update
Legislative Update
Multiple Employers, PEOs and Controlled Groups Update
Mergers & Acquisitions Update
- Outline: Overview of Selected Defined Benefit Plan Issues in Merger & Acquisition Transactions
- Slides: Joint and Several Benefit Plan Liability Issues in M&A Transactions
- Outline: PBGC's Early Warning Program
Multinational Employee Benefits & Compensation Issues
The Period Between Signing and Closing: What Benefits Counsel Needs to Know
- Outline: Sample Equity Award Provisions and Benefit Covenants
- Slides: The Period Between Signing and Closing: What Benefits Counsel Needs to Know
Welfare Plan and EEOC Issues Update
- Outline: Transitional Reinsurance Program Fees Submission of Annual Enrollment and Contributions
- Outline: The Affordable Care Act Intersects the Mental Health Mental Health Parity and Addiction Equity Act: Autism Spectrum Disorder and Applied Behavioral Analysis
- Outline: Information Reporting Requirements Under Code Sections 6055 & 6056
- Paper: Applying for a Health Plan Identifier (HPID) in the CMS Health Insurance Oversight (HIOS) Health Plan and Other Entity Enumeration System (HPOES)
Employment Taxes
Forms 1094-C and 1095-C. Understanding Employer’s Reporting Obligations under the Affordable Care Act (ACA)
Taxing the Mobile Workforce: International Employees
Third Party Payroll Providers
Energy & Environmental Taxes
Energy Tax Hot Topics
Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE)
Asset Protection Planning for LGBT Clients After the Windsor Case
- Outline: Same-Sex Marriage in 2014: The Aftermath of Windsor, Perry and IRS Action, Plus the 21st Century Battle Between The States
- Slides: Asset Protection Planning for LGBT Clients After Windsor
Asset Protection Planning for LGBT Clients After the Windsor Case
Creative Inter Vivos QTIP Planning
Current Developments
Estate Planning Challenges for Pass-Through Entities
Ethics 101 for Estate Planners
Exempt Organizations
Ethical and Practical Problems for the Attorney on the Nonprofit Board
International Activity and Negotiating the Alphabet Soup
Private Foundation Reporting Pitfalls
- Slides: Private Foundation Reporting Pitfalls
- Outline: Reporting Obligations of Private Foundations Beyond Form 990-PF
Section Program: Hybrid Corporate Models - The Benefit Corporation and its Siblings
Fiduciary Income Tax (TX) and Income & Transfer Tax Planning Group (TE)
Current Developments
Foreign Trust Traps: In-Bound Planning with Foreign Trusts
Frank Aragona Trust v. Commissioner and Material Participation of Estates and Trusts for Passive Activities
Unbundling the IRS' Final Regulations on the Deductibility of Costs Incurred by Trusts and Estates
Financial Transactions
Advanced Topics under the Wash Sale Rules
Foreign Activities of US Taxpayers
Foreign Tax Credits Developments
Issues Surrounding Passive Foreign Investment Companies
Joint International Committee: FAUST, FLF, USAFTT, and TP
Joint Current International Developments Panel
Individual & Family Taxation
Pardon the Mess: Jurisdictional Issues in a Post-DOMA World
- Slides: Pardon the Mess: Jurisdictional Issues in a Post-DOMA World
- Chart: Same Sex Marriage Information
Update on Craft and Litigation of Tenancy by Entirety Property
- Outline: Assigning Values to Property Interests When One Spouse Owes Taxes but Both Own the Property
Insurance Companies
Merger and Acquisition Issues as Applicable to Insurance Companies
Recent Developments Involving Insurance Products and Qualified Retirement Arrangements
Update on IRS Guidance Affecting Insurance Companies and Products
Investment Management
Current Issues for Insurance Dedicated Mutual Funds
Mutual Fund Investments in Derivatives: Current Issues
Why Not a Partnership?: Thinking Outside the Box
- Slides: Why Not a Partnership? Thinking Outside the Box
- Outline: Why Not a Partnership? Thinking Outside the Square and Inside the Triangle
Partnerships & LLCs
Hot Topics
Partnership Continuations
Service Firms (LLCs and LLPs) and/or Their Members in Bankruptcy: Tax and Non-Tax Aspects – Part 1
What’s Wrong With the Nonrecourse Debt Rules?
- Slides: What’s Wrong With the Nonrecourse Debt Rules?
- Outline: Exculpatory Liabilities and Other Unresolved Issues
Pro Bono & Tax Clinics
Adopt-a-Base Issues
Real Estate
Current Issues with Real Estate Funds
Homebuilders, Land Developers and Use of the Completed Contract Method of Accounting
Revised Definition of “Real Estate” for REITs
S Corporations
Current Developments
S Corporations and Life Insurance
Sales, Exchanges & Basis
“Over? It’s Not Over Until We Say It’s Over”: Strategies for Extending the 180-day Exchange Deadlines
Current Developments in Sales, Exchanges & Basis
Silver Linings: Finding Opportunity in Involuntary Conversions under Section 1033
Standards of Tax Practice
Back to Basics on The Ethics of Federal Tax Practice: Best Practices 101
Ethical Issues in Federal Tax Practice – The Government Perspective
What’s Going on with Circular 230? — Final Regulations on Written Tax Advice, Litigation Developments from Loving to Ridgely, and The Question of What Next
State & Local Taxes
Sorting Through the Weeds: Marijuana and State and Local Taxes
- Slides: Sorting Through the Weeds: Marijuana and State and Local Taxes
- Slides: The State of Marijuana in Colorado
State Taxation of Nonprofit Organizations: When Nonprofit Doesn’t Mean "Tax-Exempt."
Tax Accounting
Current Developments
Inventory Accounting Challenges
Selected Topics and Recent Developments Concerning the Research and Development Credit.
Tax Accounting Method Implications of Recent Changes to Financial Accounting Revenue Recognition Standard
Tax Policy & Simplification
Prospects for Direct (or Indirect) Taxation of Wealth
- Outline: Prospects for Direct (or Indirect) Taxation of Wealth - Background Paper and Bibliography
- Paper: Piketty's Inequality Conclusions Inaccurate, Recommendations Impossible Background Paper
Tax Practice Management
Going Out on Your Own and Changing Firms - Practical and Ethical Considerations
- Outline: Ethical Issues in Changing Firms
- Outline: Discussion Outline - Key Considerations When Moving Laterally Between Law Firms
- Supplement: Checklist for Starting Your Firm
Teaching Taxation
Bitcoins and Virtual Currency: Tax and Regulatory Implications of the Growing World of Digital Currency
Transfer Pricing
Advance Pricing Agreement and Competent Authority Update
The Evolving Role of the IRS's Transfer Pricing Practice and the Use of the TP Road Map in IRS Audits
US Activities of Foreigners & Tax Treaties
Accidental Inversions
Flipping the Switch on Foreign Corporation’s Form of Doing Business in the US