2006 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.

2006 May Meeting, Washington, DC

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Banking and Savings Institutions

• Business Expansion for Banking Institutions After Gramm-Leach-Bliley
• Entity Classification of Bank Limited Liability Companies
• Pass-through Tax Treatment for National Banking Associations

Civil and Criminal Tax Penalties

• Important Civil Developments: February 2006 Through March 2006
• Legislative & Administrative Developments

Closely Held Businesses

• Choice of Business Entity
• Coordinating the Estate Plan with the Succession Plan
• Personal Goodwill by Owners of the Professional Practice - What's New?
• Planning with Qualified Retirement Plans
• The Impact of Choice of Entity on Fringe Benefit Plans

Employee Benefits

• Compensation Matters: 2006 Proxy Season Preview/2005 Review
• Materials for Presentation on Roth 401(k) Plans
• SEC Executive Compensation Disclosure Proposals
• SEC Proxy Disclosure Rules: Current vs. Proposed

Energy and Environmental Taxes

• Fundamentals of Oil and Gas Trading/Hedging Transactions

Estate and Gift Taxes

• Fahrenheit Philanthropy: Creative Gift Structures You Should Try Neither at Home Nor at the Office
• Living In The Lone Star State: Everything Your Clients Need To Know Before Moving To Texas
• Planning for the Closely Held Business Owner: The Charitable Options
• Recent cases affecting Family Limited Partnerships and LLCs and Other Valuation Issues
• The Sunshine State: Everything Your Clients Need to Know to Become Florida Residents

Exempt Organizations

• Nonprofit Governance: Recent Government Interest in Reform
• Update on Governance Best Practices for Exempt Organizations

Fiduciary Income Tax

• Recent Developments in Fiduciary Income Tax
• Special Needs Trusts: Federal Tax Aspects

Financial Transactions

• Old Debt-Equity Wine in New Bottles

Foreign Lawyers Forum

• Offshore Investments

Individual Income Tax

• It’s Not Easy Collecting Green: Tax Collection by Private Collection Agencies Outline of 26 U.S.C. § 6306
• The Fair Debt Collection Practices Act: Selected Provisions

Investment Companies

• The U.S. Federal Income Tax Consequences of Origination Activity by Foreign Investment Vehicles

Partnerships & LLCs

• The XYZs of Structuring Blockers in Private Equity Funds

Pro Bono

• Potholes to Avoid in Road-tripping with 501(c)(3) Organizations

Real Estate

• Estate Planning for Real Estate
• Hubert Enterprises, Inc. v. Commissioner: Does A Capital Account Deficit Restoration Obligation Increase A Partner’s At-Risk Amount or Share of Liabilities?

Standards of Tax Practice

• Conflicts of Interest Under the Model Rules and Circular 230: Potential, Actual, Imaginary

State and Local Taxes

• Tax Planning Dilemmas Facing State Tax Attorney’s in Today’s Environment

US Activities of Foreigners & Tax Treaties

• Accessing Income Tax Treaties Through Competent Authority - A Ray of Hope When All Else Fails
• Proposal to Expand the Definition of Domestic Corporations

US Activities of Foreigners & Tax Treaties Committee, Foreign Activities of US Taxpayers Committee, Foreign Lawyers Forum

• The Limited Liability Company: A reverse hybrid entity under Spanish Tax Law?
• Use of Hybrid Entities in Cross-Border Tax Planning: Italian Tax Points
• Use of Hybrid Entities in Cross-Border Tax Planning: Italian Tax Points

Value Added Tax and Other Consumption Taxes

• GIT and the WTO
• Input Tax, Refunds, and Fraud – The Connection for VAT Purposes
• Overview of the Growth and Investment Tax Proposal of the President’s Advisory Panel on Federal Tax Reform
• VAT Refunds: A Review of Country Experience