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 in Administrative Practice
Should You Advise Your Client to Agree to Extend the Statute of Limitations?
- Outline: Extending the Tax Assessment Period: Should You Advise Your Client to Agree to Extend the Statute of Limitations?
- Slides: Should You Advise Your Client to Agree to Extend the Statute of Limitations?
The New Partnership Audit Rules, Round I – The Partnership Audit: How You and the IRS Figure It Out
Affiliated and Related Corporations
Current Developments in Affiliated & Related Corporations
When Consolidated Groups and Insurance Collide
Banking and Savings Institutions
US Tax Rules Pertaining to Hybrid Instruments
Capital Recovery and Leasing
Current Developments and Update on Pending Guidance
Civil and Criminal Tax Penalties
It’s All About the Penalties
OVDP – End of an Era
Reports of Subcommittees on Important Developments
- Outline: Subcommittee Report: Legislative and Administrative Developments
- Outline: Important Civil Developments
Skills Workshop: Preparing Your Client (the Taxpayer) for the Government Interview
- Outline: IRS Agent Interviewing the Taxpayer
- Slides: Skills Workshop: Preparing Your Client (the Taxpayer) for the Government Interview
Closely Held Businesses and Business Planning Group
Beyond Powell – Examining the Important Provisions of Operating Agreements and Shareholder Agreements
Beyond Powell – Examining the Important Provisions of Operating Agreements and Shareholder Agreements
Collection Workshop
How to Represent Taxpayers in Collection Matters from the Final Notice Through Trial and Resolving Collection Issues Facing Estates, Donors, and Donees
Corporate Tax
Special Issues Under the 2017 Tax Act
Court Procedure and Practice
A Primer on the Use of Experts in Tax Court
Current Developments in Court Procedure and Practice
Litigating Whistleblower Cases in the Tax Court
Litigating Whistleblower Cases in the Tax Court
The New Partnership Audit Rules, Round 2 – After the Partnership Audit, How You and the IRS Fight it Out
Diversity
Preparing Fiduciary Income Tax Returns and Representing Clients on Audit
The “Nanny Tax”: Taxation of Household Employees
Employee Benefits
Corporate Counsel Forum
Defined Benefit Plans Update
Employment and Benefits Developments for Non-Traditional Employment Relationships
- Slides: Multiple Employer Plans for Contingent Workers
- Slides: Association Health Plans Reinvented
- Slides: Worker Classification in the Gig Economy
ESOP Update
- Outline: TBM Consulting Group, Inc. v. Lubbock National Bank Case Summary
- Outline: Brown v. Wilmington Trust Case Summary
Executive Compensation, Fringe Benefits and Federal Securities Law Update
Exempt Organization and Governmental Plans Update
Impact of #MeToo on Executive Compensation - Clawbacks and More
- Outline: #MeToo: Sexual Harassment and Executive Compensation
- Slides: #MeToo, Employment Agreements, and the Clawback of Executive Compensation
Legislation & Litigation Update
Multiple Employers, PEOs and Controlled Groups Update
- Slides: 199A Update re: W-2 Wages and PEOs
- Slides: Code Section 414 Controlled Group Principles & Native American Tribal Governments
Proxy Season: Looking Back, Looking Forward
The Affordable Care Act: What Now? What Next?
Welfare Plans and EEOC, FMLA and Leaves Issues Update
- Slides: Prohibited Transactions - Health and Welfare Plans Sponsored by Hospital Systems
- Slides: Prescription Drugs Programs Update
Employment Taxes
Correcting Payroll Tax Reporting Errors and Grossing Up Payments for Tax Consequences
Tax Consequences of Employment Settlements and Judgements
The Competing Tensions Driving Independent Contractor Status for Service Providers
Estate & Gift Taxes and Income & Transfer Tax Planning Group
Can the IRS Have Their Cahill and Eat Yours Too?
Can the IRS Have Their Cahill and Eat Yours Too?
Current Developments in Estate & Gift Taxes and Income & Transfer Tax Planning
Wealth Transfer Planning with Carried Interests in Funds
Estate & Gift Taxes, Fiduciary Income Tax and Income & Transfer Tax Planning Group
2018 Update of Privileges and Fiduciaries
Creating the Ultimate Digital Asset Estate Planning Checklist
- Outline: Creating the Ultimate Digital Estate Planning Checklist
- Slides: Revised Uniform Fiduciary Access to Digital Access Act
Exempt Organizations
Charitable Giving Under the 2017 Tax Act: Keeping and Creating Charitable Contribution Deductions
- Outline: Charitable Giving Provisions of the TCJA: Charitable Contributions and State Initiatives in High SALT States
- Slides: Charitable Giving Under the 2017 Tax Act: Keeping and Creating Charitable Contribution Deductions
Crowdfunding Charity: Navigating the Legal Landscape
News from the IRS and Treasury
Shared Employment, Reporting of Compensation and Its Implications for Exempt Organizations Employment
- Slides: Shared employment, reporting of compensation and its implications for exempt organizations
- Outline: Shared Employment, Reporting of Compensation and Its Implications for Exempt Organizations
Unrelated Business Taxable Income: Current Developments in Enforcement Activity
Fiduciary Income Tax
Current Developments in Fiduciary Income Tax and Income & Transfer Tax Planning
Trusts and the Transition Tax: Everything You Didn’t Want to Know
Financial Transactions
Treatment of Certain Debt Related Fees
Individual & Family Taxation
How Can I Live On That?
What Is the APA's Role in Tax Administration?
Insurance Companies
Insurance Tax “Real Time” Topics
International Tax Reform and Insurance Companies
- Slides: Global Intangible Low-taxed Income (GILTI)
- Slides: New PFIC Qualifying Insurance Company Rule under Section 1297(f)
- Slides: International Tax Reform and Insurance Companies: Base erosion and anti-abuse tax (BEAT)
Traps for the Unwary: Life Insurance Valuation and Transfer Issues
Investment Management
Cryptocurrency Funds
Post-Tax Reform Planning for Cross-Border Investments by Private Funds
State Tax Issues for Investment Funds
Partnerships & LLCs
Code Section 163(j)
Code Section 199A
Hot Topics in Partnerships & LLCs
International Hot Topics
Pro Bono & Tax Clinics
Canceled Debt Reporting Under IRC Section 6050P
Jurisdictional Ramifications of a CDP Request
Tax Consequences of Student Loan Debt Cancellation
- Outline: Information for People who Received Form 1099-C from Aequitas
- Slides: Tax Consequences of Student Loan Debt Cancellation
Real Estate
Overview of Qualified Opportunity Zones
Special Issues Applicable to Timber
Structuring Foreign Investment in US Real Property After Tax Reform
What is a Real Estate Trade or Business?
- Outline: Revisiting "Trade or Business" in the Real Estate Context in Light of Tax Reform
- Slides: Real Estate Trade or Business –When Does it Matter under Tax Reform?
S Corporations
Cooperatives
Important Developments in the Federal Income Taxation of S Corporations
Sales, Exchanges and Basis
Current Developments Relating to Sales, Exchanges & Basis
Deferring and Reducing Income Taxes on Non-Opportunity Zone Property, and Eliminating Income Taxes on Opportunity Zone Property, Through Qualified Opportunity Funds
- Slides: Qualified Opportunity Funds
- Slides: Should Real Estate Gain be Rolled Over Through a QOF Rather Than 1031
The Interaction of Section 267, 1031 and 1033 with the Qualified Business Income Limitation
Standards of Tax Practice
Ethical Issues Regarding the Partnership Representative
Ethical Pitfalls in Representing Spouses
State & Local Taxes
Impact of Wayfair on Services and International Taxes
What Is a Remote Seller to Do in This Post-Quill World?
Tax Accounting
Accounting Method Changes for Controlled Foreign Corporations
Current Developments in Tax Accounting
Inventory
Revenue Recognition and Section 451
Tax Bridge on the Road
Cross-Species Mergers: Key US Federal Income Tax Considerations
Planning for Litigation in the Captive Insurance Area
State and Local Tax: Wayfair and the Way Forward
Tax Policy and Simplification
Transparency Tide or Transparency Tsunami? The New Wave of Global Reporting Rules and IRS Tools to Unearth Foreign Financial Accounts: FATCA, FBAR, & CRS developments in the wake of OVDP and Swiss Bank Program
Tax Practice Management
The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement
- Paper: The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement
- Slides: The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement
Transfer Pricing
Impact of BEPS and US Tax Reform on Transfer Pricing Controversies: Preparing for the Storm
The Great BEAT Debate
US Activities of Foreigners & Tax Treaties
Advanced FIRPTA: Traps to Keep You Up at Night
Inbound Financing After Tax Reform - What Now?
Young Lawyers Forum
New Law, New Regulations, New Practitioners: Legal and Ethical Obligations When Advising Taxpayers in an Uncertain Legal Environment