2004 May 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.

2004 May Meeting, Washington, DC

Affiliated & Related Corporations

• Consolidated Return Issues for Buyers and Sellers in M&A Transactions

Capital Recovery & Leasing

• Summary of Significant Developments From January 13, 2004 Through April 23, 2004

Civil and Criminal Tax Penalties

• The Innocent and the Not-So Innocent: The Evolution of Section 6015
• Trends in IRS Enforcement: Strategies and Pitfalls in Resolving “Listed Transactions”

Closely Held Businesses

• Personal Goodwill in a Business/Practice Sale and Dissolution

Corporate Tax

• Recent Developments

Court Procedure and Practice

• Primer on Tax Summons Law (Including Hypothetical Summons Cases with Analysis)

Joint Session: Diversity, Teaching Taxation, and Young Lawyers Forum

• Race, Racism and Free Enterprise: Can Free Enterprise CureLow-Income Minority Communities?

Domestic Relations

• American Culture - Together, But Not For Internal Revenue Code Purposes (Just the Basics)

Estate & Gift Taxes

• Estate Planning for Non U.S. Citizen Spouses
• How to Request a Private Letter Ruling (in the Transfer Tax Context)
• Selected Developments in Income, Estate, Gift and Generation-Skipping Transfer Tax
• The Future of Federal Wealth Transfer Tax System: Reform or Repeal?
• When Bad Things Happen To Good People: Obtaining Section9100 Relief for Late Tax Elections

Exempt Organizations

• Ethics, Privilege and Circular 230 in the EO Practice

Fiduciary Income Tax

• Cottage Savings is a Loss to Trust Beneficiaries
• Final Minimum Distribution Rules (April 15, 2004)
• Practical Planning for Distributions from Retirement Accounts After The Final Minimum Distribution Regulations

Foreign Activities of U.S. Taxpayers

• Foreign Tax Credit Abuse — Tell it to me One More Time

Foreign Lawyers Forum

• Australian Thin Capitalisation Rules
• Canada – Thin Capitalization
• French Thin Capitalization Rules
• New and Improved Cross-Border Regimes for Attracting Investors in the EU (paper)
• New and Improved Cross-Border Regimes for Attracting Investors in the EU (PowerPoint)
• New Belgian Fund Structure Designed for Private Equity and Venture Capital in an International Environment (paper)
• New Belgian Fund Structure Designed for Private Equity and Venture Capital in an International Environment (PowerPoint)
• The New German 2004 Anti-Thin Capitalization Rules
• U.S. Earnings Stripping Rules

Individual Income Tax

• Be Careful What You Wish For: The Unintended Consequences of Income Tax Provisions
• The Individual AMT: Task Force Report

Partnerships & LLCs

• Big Brother is watching You! The Proposed Circular 230 Amendments and the New, New Office of Professional Responsibility
• Hot Topics

S Corporations

• Converting A Personal Service Corporation
• Recent Developments Relating to the Taxation of S Corporations

Sales Exchanges & Basis

• Current Developments (Other Than for Like-Kind Exchanges)
• Recently Released Depreciation Regulations Pertaining to Like-Kind Exchanges and Involuntary Conversions
• Theories of Relativity and Section 1031

Standards of Tax Practice

• As [Maine] New York Goes, So Goes…, And A Potpourri of Current Ethics Issues in MDP Developments
• Inter-Professional Practice Issues: A Debate and Discussion
• Multidisciplinary Practices: Where Are They? What Happened?

State and Local Taxes

• State Conformity to Federal Income Tax Provisions
• The False Claims Act: Can a Private Litigant Sue RemoteSellers for Failing to Collect Sales Tax?!?

Transfer Pricing

• Recent Developments in Transfer Pricing