Thoughtful Insights. Useful Analysis.
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 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
Money Ball: Inside the IRS' Global High Wealth Industry Group.
- Form 13744 – Examiner's Risk Analysis Worksheet
- Form 4564 – Information Document Request (IDR) – Attachment Mandatory Tax Shelter IDR
- Form 4764 – LB&I Examination Plan
- Supplemental panel slides
- MONEYBALL: Inside IRS’s GHW Group
The Adminstraive Procedure Act and Tax Administration: How Does it Apply? What is the Debate? What do Tax Professionals Need to Know?
The Techncial (or “Terrible?”) Advice Process: Using "TAM" as an Effective Issue Resolution Tool
- Excerpts from Revenue Procedure 2012-1
- The Terrible Exam Advice Process: Using the "TAM" as an Effective Issue Resolution Tool
Affiliated and Related Corporations
Application of Section 382 to Consolidated Groups
Banking & Savings Institutions
Distressed Debt Tax Issues from the Perspective of Banks
Foreign Tax Credit Generators, Economic Substance and the Future
Hot Topics in Taxation of Banking…
Bankruptcy and Workouts
Acquisition of Troubled Corporations
New Developments 2011
- Bankruptcy and Workouts
- Business Bankruptcy & Workouts – Annual Update
- Bankruptcy and Workouts Developments Report 2011
Tax Court or Bankruptcy Court - What, Where, How and Why.
- Exhibit D - DOJ Tax Division Settlement Reference Manual
- Exhibit E - Rules 330 – 334
- Exhibit F - Complaint to Determine Dischargeability
- Exhibit G - 11 U.S.C. § 505(a)
- Exhibit I - Petition for Lien Action
- Exhibit K - CDP – Decisions – Frances D. Sheehy
- Survey of 2011 CDP Cases
- A Panel Discussion: Bankruptcy Courts – Tax Litigation, A Comparison – Tax Court Litigation
- Exhibit J - Motion to Dismiss 11 U.S.C. § 523 Action for Lack of Jurisdiction
- Exhibit B - K. Weil, Tax Liabilities and Bankruptcy
- Exhibit H - Complaint to Determine Liability
- Exhibit A-The IRS Collection Process And The Bankruptcy Alternative
- Survey of Dischargeability - Recent Cases - 2011
- Survey of Dischargeability - Recent Cases - 2010
- Exhibit C - Automatic Stay
Capital Recovery & Leasing
Current Developments
Current Issues and Topics in Depreciation Methods and Classifications
Deduction for Qualified Film and Television Production Expenditures
Civil and Criminal Tax Penalties
Integrity of Domestic and Offshore Accounts: The United States Perspective
Reports of Subcommittees on Important Developments
- Important Developments— Criminal
- Renewed Pursuit of Tax Avoidance and Evasion
- Subcommittee Report: Legislative & Administrative Developments
- Important Developments on Civil Penalties: October, 2011 through January, 2012
Sentencing – How to Make the Best of a Bad Situation
Should You Blow Your Whistle?
Closely Held Businesses
Estate Planning Gone Awry: What Happens When Things Don't Work Out the Way We Planned?
Impact of New Health Care Law on Closely Held Businesses
- Impact of the New Health Care Bills On Closely-Held Business
- Health Reform In A Nutshell: What Employers Need To Know
- Impact of the New Health Care Bills On Closely-Held Business
Reformation of Estate Documents: Why Your Documents Are Alive Even After You’re Dead
- Reformation of Estate Documents: Why Your Documents Are Alive Even After You’re Dead
- They Can Change My Will After I'm Gone? Really?
Sales of Personal Goodwill
- Current Developments In The Sale Of Personal Goodwill
- Sale Of A Business Or Practice & Sale Of Personal Goodwill
- Sales of Personal Goodwill: Presentation Handout
Update on Health Care Reform
Corporate Tax
North-South Transactions, Section 355 and Other Step Transaction Issues
Tax Opinions: What Does It Cost You and What Is It Worth to Your Client?
Court Procedure and Practice
E-Litigation: Leveraging Technology Throughout Your Case
Important Developments
- Important Developments
- Tax Section Court Procedure Committee, Office of Chief Counsel Internal Revenue Service FY 2011
Litigating R&D Cases
Parallel Civil Tax Litigation and Criminal Investigations
Court Procedure Issues In CDP Judicial Review
Employee Benefits
DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and EFAST2 and Audit Reporting Issues
- 408(b)(2) Final Rule Regarding Service Provider Disclosures
- DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and EFAST2 and Audit Reporting Issues
- DOL Fact Sheet – 408(b)(2) Final Rule
- DOL – Changes in Final Rule – 408(b)(2)
- DOL News Release – 408(b)(2) Final Rule
- DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and Presentation: A Discussion of the DOL’s New Fee Disclosure Regulations
Hot Topics
- IRS Provides Guidance on W-2 Reporting re: Value of Health Care Coverage
- IRS Provides Guidance on Key Dates for Hybrid Plans
Plan Drafting and Administrative Issues After Amara
- Plan Drafting and Administrative Issues After Amara: Retirement Plan Issues
- CIGNA v. Amara: Litigation Perspectives
Practical Considerations in Providing Benefits and Equity Compensation to a Global Workforce
- Providing Equity Compensation to a Global Workforce
- Key Learnings from Global Employee Benefits Review
Proxy Disclosure 2012: Same as Last Year or New Year, New Challenges?
- Proxy Disclosure 2012: Same as Last Year or New Year, New Challenges?
- ISS Issues 2012 Policy Updates
- Practical Strategies for Preparing This Year’s CD&A and Compensation Tables
- 10 Tips for Enhancing Your 2012 Executive Compensation Disclosure
Worker Classification Issues Under Renewed Focus
Employee Benefits Defined Benefit Plans Update
- Recent PBGC Regulatory Developments: (January 1, 2010, to January 31, 2012)
- A Window into PBGC's Practice: Current Issues and Trends
Employee Benefits Distributions Update
Fiduciary Regulation Update
Employee Benefits International Update
Employee Benefits Administrative Practices Update
- EP Determinations Quality Assurance Bulletin
- Announcement 2011-82
- Announcement 2012-3
- Sample Plan Amendment for Section 436: Notice 2011-96
- 2011 Cumulative List of Changes in Plan Qualification Requirements
- Administrative Practices Update
- Qualified Plan Law Changes and Deadlines - Post GUST
Employee Benefits Fiduciary and Litigation Update
Employee Benefits Welfare Benefits Design, Funding and Regulation Update
- New Guidance Issued for Reporting the Cost of Health Coverage on Forms W-2
- IRS Updates Its Guidance on Form W-2 Reporting of Employer-Sponsored Health Coverage
- Revisiting the Medical Loss Ratio
- Comments RE: Essential Health Benefits Bulletin
- Impact of Federal Health Care Reform on Employers With Contingent Workers
- American Health Insurance Exchanges Under the PPACA - An Overview and Primer
- HHS Bulletin Outlining Essential Health Benefis Grants Significant Flexibility to States
Employment Taxes
California Employment Taxes and the Employment Development Department
- Employment Development Department Information Sheet
- Employment Development Department Information Sheet
Employment Tax Issues Relating to Health Care
Federal Update
Energy and Environmental Taxes
Hot Tax Topics for Utilities
New Excise Tax on Medical Devices
- Dear Treasury: Medical Device Industry Submits Comments on New Excise Tax
- New Excise Tax on Medical Devices
- New Excise Tax on Medical Devices
Estate & Gift Taxes
Current Developments
Estate and Income Tax Planning for the Passage of Family Homes
Mending Wayward Wealth Transfer Strategies (With the Help of a $5,000,000 Exclusion Amount)
Portability - Plethora of Problems, Pitfalls and Planning Possibilities
Exempt Organizations
Another Election Year: Recent Developments in Political Advocacy
Hybrid Entities: Do They Really Have a Place in the Charitable Investment World?
Practical Problems and Practical Solutions for Donor Advised Funds
The Future of the Charitable Deduction
- Coming Limitations on the Charitable Deduction
- Future of the Charitable Deduction: How. Not if. It will be Limited
VAT and the Tax-Exempt Sector: Unique U.S. Tax Issues
- VAT Exemptions: Principles and Practice
- VAT and the Tax-Exempt Sector: What are the Issues?
- VAT and the Tax-Exempt Sector: Unique U.S. Issues
Fiduciary Income Tax
Anatomy of a Form 1041, Fiduciary Income Tax Return
Ethical Issues for Trust and Estate Practitioners
- Final Circular 230 Regulations Create Registered Tax Return Preparer Category
- Notice 2011-6
- Treasury Department Circular No. 230
- Ethical Issues for Trust and Estate Practitioners: An Overview of Circular 230 with Recent Updates
Making Retirement Benefits Payable to Trusts
- The IRA Beneficiary Designation Form: How to complete it properly
- Checklist of Issues to Consider when a Trust is Beneficiary of Qualified Retirement Benefits, including SEP/SIMPLE IRAs, traditional IRAs, 401(k)s, 403(b)s, 457 or other defined benefit/contribution plans including Roth variants
Recent Developments
Financial Transactions
Contingent Swaps and the New Regime
Section 871(m): New Guidance on Cross-Border Equity Swaps
Short Derivatives: Getting Topsy Turvy
Foreign Activities of US Taxpayers
Foreign Tax Credits
Foreign Lawyers Forum
Renewed Pursuit of Tax Avoidance and Evasion
Special Taxes on Financial Institutions and Transactions
- Special Taxes on Financial Institutions and Transactions The Netherlands
- Special Taxes on Financial Institutions and Transactions
- Bank Levies in the UK, France and Germany: A Comparison of the New Levies on Banks
- Special Taxes on Financial Institutions and Transactions
Indian Tribal Tax Committee
Federal Taxation of Tribes and Their Members – Fundamental Issues and Hot Topics
- The General Welfare Doctrine: Emerging Issues for Tribal Governments and Tribal Members
- Federal Taxation of Tribes and their Members: Fundamental Issues and Hot Topics
What Tax Lawyers Need to Know About Federal Indian Law
Individual and Family Taxation
Am I Really An Independent Contractor?
- Present Law and Background Relating to Worker Classification For Federal Tax Purposes
- Form 8952, Instructions and FAQs on Voluntary Compliance Settlement Program
- Incorporating Independent Contractors is no Panacea for Misclassification
- Section 530: Its History And Application In Light of the Federal Definition of the Employer-Employee Relationship For Federal Tax Purposes, NATRPM
Highlights from the National Taxpayer Advocate 2011 Annual Report to Congress
Insurance Companies
DOMA vs. the States, with Tax Rules in the Middle
- DOMA vs. the States: With Tax Rules in the Middle
- Panel Materials: IRS Letter
- Status Recognition Chart for Same Sex Couples
Health Care Reform – Tax and Fee Implementation Issues Affecting the Insurance Industry and the Scope of “Health Insurance.”
Transfer Pricing and Insurance
Update on Recent Tax Developments and Projects on the IRS Priority Guidance Plan
Investment Management
RICs and PFICs – A Couple That Still Can’t Get Along
Joint: Employee Benefits Subcommittee on Employee Benefits Executive Compensation, Fringe Benefits and Securities Law and the Subcommittee on Mergers & Acquisitions
Employee Benefits Executive Compensation, Fringe Benefits and Securities Law Update
Joint: FAUST, FLF, Transfer Pricing & USAFTT
Joint International Developments Panel
Low Income Taxpayers
Dealing with Tax Issues Following a Disaster
Innocent Spouse - We Won But Where Are We Now?
Introductory remarks and administrative issues
National Taxpayer Advocate’s Annual Report to Congress
Partnerships and LLCs
Applying Section 118 to Partnerships—Isn't It About Time?
- Applying Section 118 to Partnerships—Isn't It About Time?
- Applying Section 118 to Partnerships—Isn't It About Time?
- Contributions to Capital
Hola, Ni Hao, Shalom—Say Hello To Your Foreign Partner
Hot Topics
The Do's and Don’t's of Structuring Leveraged Partnerships
- Partnership Disguised Sales of Property: G-I Holdings Misses the Mark
- The Do's and Don’t's of Structuring Leveraged Partnerships
- Tax Court Goes Overboard in Canal
Pro Bono
Pro Bono Matters: WHY? Ethical and Economic Reflections on ABA Model Rule 6.1 “Voluntary Pro Bono Publico Service.”
- Pro Bono Matters (Not a Contradiction In Terms): A Primer
- Pro Bono Is Every Lawyer’s Professional Responsibility
Real Estate
Installment Sales: Interesting and Unresolved Issues.
Minimizing Gain/Maximizing Loss: May I Cherry Pick Property?
Real Estate Funds: A Potpourri of Issues that Vex the Practical Practitioner
What is Real Property and Why Do I Care?
S Corporations
Current Developments
Medicare Taxes and S Corporations
- Medicare Taxes and S Corporations (and Other Pass-Through Entities)
- Medicare Taxes and S Corporations (and Other Pass-Through Entities)
- Impact of the New Health Care Bills On Closely-Held Business
- Impact of the New Health Care Bills On Closely-Held Business
QSubs: The Basics and Beyond
Sales, Exchanges and Basis
Build-to-Suit or Full-of-Boot: Analyzing Exchanges Involving Leasehold Improvements Constructed by a QI or EAT
Current Developments in Sales, Exchanges and Basis Other Than Sections 1031 & 1033
Current Developments in Section 1031 and Section 1033 Transactions
Involuntary Conversions and Qualification of Replacement Property
- Rethinking Section 1033: A “Continuity of Investment” Approach
- Rethinking Section 1033:A "Continuity of Investment" Approach to Replacement Of Involuntarily Converted Trade or Business or Rental Property
Is It Treated as a Sale? Lease, Financing? Constructive Sale? Option? Something Else? – Part I
Section Program: Joint: Real Estate and Partnerships and LLCs
Drafting Real Estate Partnership and LLC Agreements – Part 2
Section Program: Joint: Tax Accounting and Capital Recovery and Leasing
Repair Regs Re-Do: Review of the New Guidance Regarding Tangible Property
Section Program: Joint: US Activities of Foreigners and Tax Treaties, Banking and Savings Institutions, and Tax Shelters
The Far-Reaching Impact of FATCA Across Borders and Across Industries
Section Program: Teaching Taxation
Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation
- Recent Developments in Federal Income Taxation
- Federal Estate, Gift and Generation Skipping Tax Update
Standards of Tax Practice
Circular 230’s Range of Disciplinary Sanctions: How Bad Can it Get & How is it Determined?
Ethical Issues in Federal Tax Practice - The Government Perspective
Pro Bono Representations: Ethical Issues Specific to the Pro Bono Context
- Standards of Tax Practice Committee/Pro Bono Committee Presentation
- Pro Bono Representation: Ethical Issues Specific to the Pro Bono Context
State & Local Taxes
Apportionment: Sales Factors Based on Benefit Received
Current Developments: Series LLCs
- Survey of State Departments of Revenue/Finance Regarding Their Intent to Conform with the Classification of Series LLCs as Discussed in Treasury Department/IRS-Proposed Regulations
- Current Developments: Series LLCs
Digital Downloads and On-Line Services - Taxing Issues in the Virtual Realm
Remote Sales & Nexus Issues
Tax Accounting
Considering the Proper Tax Accounting Treatment of Advance Payments in a Corporate Transaction
- The Tax Accounting Treatment of Advance Payments/Deferred Revenue in Taxable Asset Acquisitions
- Taxable Asset Acquisitions and the Treatment of Advance Payments: Issues and Answers
Inventory: Recent Guidance, Anticipated Guidance
Issues Arising in Tax Controversies Involving Tax Accounting Issues
Recent Developments in Tax Accounting
Tax Exempt Financing
Legislative, Department of Treasury and IRS Update
Tax Implications of On-Behalf-Of Financings
VCAP and Other Compliance and Program Management Initiatives
Tax Policy and Simplification
Perspectives on Tax Reform: Charitable Contributions and the Nonprofit Sector
- Perspectives on Tax Reform: Charitable Contributions and the Nonprofit Sector
- Principles and Rationales Behind the Charitable Deduction & Alternatives
Perspectives on Tax Reform: Taxation of Capital Gains and Dividend Income
- Mitt Romney's Teachable Moment on Capital Gains
- Tax Reform and the Taxation of Capital Gains and Dividends, Excerpted from “Tax Reform Options: Marginal Rates on High-Income Taxpayers, Capital Gains, and Dividends,”
- Beyond the ‘Buffett Rule’: Making The Income Tax More Progressive
Teaching Taxation
Tax and the First Amendment
- Campaign Disclosure and Tax-Exempt Entities: A Quick Repair to the Regulatory Plumbing
- Campaign Disclosure and Tax-Exempt Entities: A Quick Repair to the Regulatory Plumbing
- Once and Future Gift Taxation of Transfers to Section 501(c)(4) Organizations: Current Law, Constitutional Issues, and Policy Considerations
- The Parsonage Exemption Violates the Establishment Clause and Should Be Declared Unconstitutional
Transfer Pricing
Comparability and Economic Adjustments
- Comparability and Economic Adjustments
- APA Training Adjusting Comparables’ Results (Including Asset Intensity Adjustments)
Transfer Pricing for Financial Institutions and Products
US Activities of Foreigners and Tax Treaties
The Corporate Mixed Marriage
The New Proposed Foreign Account Tax Compliance Act (“FATCA”) Regulations
Young Lawyers Forum
Making a Difference as a Tax Lawyer