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    TaxIQ

    2014 Midyear Meeting

    January 23-25, Phoenix, AZ

    Thoughtful Insights. Useful Analysis.

    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 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

    Appeals: New Initiatives

    LB&I's New IDR Enforcement Process

    Affiliated & Related Corporations

    Current Developments in Consolidated Returns

    Exploring the Intersection of the Federal Consolidated Return Rules and State Tax

    Banking & Savings Institutions

    Advising Banks and Savings Institutions in 2014

    Basel III and deferred tax assets: there's no such thing as a "mere timing difference"

    Final and Proposed Section 871(m) Regulations & FATCA Update

    Bankruptcy & Workouts

    Dealing with State Tax Authorities in Bankruptcy

    OPR: The IRS Collection Process and Bankruptcy Tax Issues

    Section 336(e) and Bankruptcy Restructuring

    Capital Recovery & Leasing

    Current Developments Report and Update on Pending Guidance

    Experimenting with the Definition of a Prototype: A look at the Proposed Section 174 Regulations

    Tangible Property Regulations Update – Transition Guidance Discussion, FAQs, and an Update on the Proposed Regulations

    True Lease Analysis – Lease vs. Sale/Financing

    Civil & Criminal Tax Penalties

    Oil and Water: Mixing the Ambiguous Economic Substance Doctrine with the Onerous Economic Substance Penalty

    Reports of Subcommittees on Important Developments

    Trends in Criminal Tax Enforcement

    US Department of Justice, Tax Division Update

    Closely Held Business

    Collection Issues Surrounding the BSA under Title 26 and Title 31

    Criminal Aspects of the Bank Secrecy Act

    Entity Selection and Corporate Governance for Closely-Held Businesses

    The Civil Aspects of the Bank Secrecy Act and its Impact on Closely Held Businesses

    The Taxation of the Purchase and Sale of Closely-Held Businesses and Professional Practices

    Corporate Tax

    C Corporation-to-REIT Conversions

    Corporate Tax Issues in Private Equity Transactions

    Court Procedure & Practice

    Ethical Issues Arising from Conflicts of Interest in Litigation

    Hot Topics in Captive Insurance and Risk Pooling Arrangements

    Important Developments: Recent Tax Litigation and Controversy Updates, including Supreme Court Decision in United States v. Woods

    Reaching Agreement - Settling Tax Cases in Litigation

    Step One of All Tax Litigation: Burden of Proof

    Diversity

    Post-Windsor Decision Health and Retirement Plans Guidance from Treasury and IRS

    Providing Pro Bono Legal Services. Our Ethical Obligation to the Profession

    Tax Implications of Immigration Cases

    Employee Benefits

    Administrative Practices Update

    Benefit Plans and Private Equity Funds: Problems at the Intersection

    Continued Aftermath of the Supreme Court’s DOMA Decision

    Defined Benefit Plans Update

    Defined Contribution Plans Update

    Distributions Update

    ESOP Update

    Executive Compensation, Fringe Benefits & Federal Securities Law Update

    Hot Topics

    Legislative Update

    Litigation Update

    Managing Pension Plan Liabilities: De-Risking and Shared Risk Strategies

    Mergers & Acquisitions Update

    Multinational Employee Benefits & Compensation Issues

    Multiple Employers, PEOs and Controlled Groups Update

    Pay Ratio Disclosures for the Proxy Season

    Welfare Plan and EEOC, FMLA and Leaves Issues Update

    Employment Taxes

    Employment Taxes On Tipped Employees: Navigating Tip Credits, Tip Reporting and Service Charges

    Federal Update

    Quality Stores—The Final Countdown

    Tax Controversy: How will the IRS's New IDR Enforcement Policies Impact Employment Tax Examinations?

    Energy & Environmental Taxes

    Hot Topics In the Energy Industry

    Estate & Gift Taxes

    Audit Proofing Family Limited Partnerships

    Captive Insurance Companies and the Closely Held Business

    Current Developments

    Self-Settled Asset Protection Trusts

    Estate & Gift Taxes and Fiduciary Income Tax

    Administering Unusual Assets with Purpose Trusts

    Exempt Organizations

    Earmarking -- Substance and Form

    Exempt Organizations and Employment Taxes

    Hot Topics in UBIT

    News from the IRS and Treasury

    Small Charities -- Problems and Solutions

    Fiduciary Income Tax

    Current Developments

    Income and Estate Tax Aspects of Joint Trusts in Community Property and Common Law Jurisdictions

    Residency and Domicile for State Income Tax and Transfer Tax Purposes

    Financial Transactions

    Bitcoin and Other Virtual Currencies: What are They, and How are they Taxed?

    Section 871(m) Update

    Foreign Activities of US Taxpayers

    Currency Issues of Controlled Foreign Corporations, including Treasury Centers

    Investments in United States Property under Section 956 Developments and Unresolved Issues

    Joint Current Developments: FAUST, FLF, Transfer Pricing and USAFTT

    Foreign Lawyers Forum

    Current International IP tax issues– BEPS, patent boxes and more

    Redomiciliations, cross-border acquisitions and holding company regime

    Indian Tribal Tax

    Federal Indian Law and Policy, The Nuts & Bolts

    State and Tribal Taxing Jurisdictions, A Complicated Relationship

    Individual & Family Taxation

    Presentation of Annual Report to Congress

    Return Preparer Review after Loving and Under the PAC IRS Review Process

    Insurance Companies

    Information Reporting on Life Insurance Products

    International Developments Affecting Insurers

    Recent Developments Affecting Insurers and their Policyholders

    Investment Management

    Selected Tax Issues Regarding Operational Aspects of Private Investment Funds

    The Intersection of Private REITs and Partnerships and Other Issues Related to the Formation and Operation of Private REITs

    The Structure Games (Pooled Investment Entity Edition)

    Partnerships & LLCs

    Considering Retirement in Arizona? Payments to Retiring Partners under Section 736

    Hot Topics in Partnership Taxation

    Is Private Equity Engaged in the Conduct of a Trade or Business?

    Prickliest Provisions in a Partnership Agreement: Allocations

    Pro Bono & Tax Clinics

    Eliminating Errors and Penalties in Tax Return Preparation

    National Taxpayer Advocate’s Annual Report to Congress

    The Qualified Offer Rule & Attorney Fees: Where Do We Stand?

    Real Estate

    Compensation or Capital Gain? An Earn-Out Primer

    Controlling REIT Spin-Offs

    So What if We’re Related?

    When Do Options Transfer Tax Ownership?

    S Corporations

    Current Developments

    Section 179 and Controlled Groups: Are S Corporations In or Out?

    Tax Rules Applicable to S Corporation ESOPs

    Sales, Exchanges & Basis

    Current Developments in Sales, Exchanges & Basis

    North Central and its Implications for Related Party Exchanges

    Sales, Exchanges, and Basis in the World of Section 1411

    Stress Testing “Cash Out” Section 1031 Techniques

    To Wed or Not to Wed? The Tax Consequences of Windsor for Intervivos Property Transactions

    Standards of Tax Practice

    Ensuring Compliance With Circular 230 and Other Practice Rules: What’s a Manager to Do and What Happens if They Don’t?

    Ethical Issues in Federal Tax Practice—The Government Perspective

    Teaching Ethics—Incorporating Ethical Issues from Basic Tax to LLM Courses

    Teaching Ethics—Just Whose Responsibility Is It?

    State & Local Taxes

    Are Modern Trading Posts Off the Reservation: Do New Federal Regulations Create Tax Havens for non-Native American Businesses Conducted on Tribal Lands?

    Private Enforcement of State Tax Laws: False Claims Acts and The Transaction Tax Overpayment Model Act

    State Taxation of Pass-Through Entities and Their Owners

    The Rush to Extend the Sales Tax to Services: Is It Over or Just Beginning?

    Tax Accounting

    Current Developments

    Guidance Project Addressing the Treatment of Advance Payments

    Tangible Property Regulations: Practical Implications

    Tax Exempt Financing

    Legislative, Treasury and Internal Revenue Service Update

    Proposed Arbitrage Regulations

    Tax Policy & Simplification

    The Role of the Internal Revenue Service in the Administration of Social Welfare Policy

    Teaching Taxation

    Section Program: Current Developments

    Transfer Pricing

    New IRS Revenue Procedures for the Competent Authority and APA processes

    Update on Transfer Pricing Issues in Developing Countries

    US Activities of Foreigners & Tax Treaties

    FATCA for Those on This Side of the Ocean/Border

    Inbound Financings: Issues and Planning Strategies