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.
Administrative Practice
Back to Basics: Who Has Capacity to Sign on Behalf of the Taxpayer
Important Developments
Affiliated & Related Corporations
The Intersection of Subchapter K and Consolidated Returns
Banking & Savings Institutions
Banking & Savings Tax Update
Dual Consolidated Loss Issues for Banking Entities
Capital Recovery & Leasing
Current Developments Report and Update on Pending Guidance
Civil & Criminal Tax Penalties
Aggressive IRS Audit Techniques – Tales from the Trenches
Reports of Subcommittees on Important Developments
Tax Preparer Fraud: Strategies for Defending the Tax Preparer or Promoter in Criminal and Civil Injunction Litigation
Closely Held Businesses (TX) and Business Planning Group (TE)
Old MacDonald Has a Farm... With Corporate Farming Statutes Here and Special Use Valuation There, What Kind of Planning Can He Do?
Selling the Dreaded C-Corp While Minimizing the Double Taxation
The Nuts & Bolts of Captive Insurance Companies
Corporate Tax
Section 361(c) and Its Discontents
Court Procedure & Practice
Conflicts and Chaos: The Importance of Timely Recognizing and Managing Conflicts of Interest in Tax Litigation
- Handout: Discussion Hypotheticals
- Outline: Conflicts and Chaos: The Importance of Timely Recognizing and Managing Conflicts of Interest and Related Problems in Tax Litigation
Ethical Issues Arising in Discovery
Important Developments
Roundtable Discussion: Effective Writing in the Tax Court - "Prologue and Postscript: The Pretrial Memorandum and Post-Trial Brief, With Views from the Bench"
Diversity
Obergefell v. Hodges: Tax and Estate Planning Issues for Employers and Individuals
- Outline: Obergefell v. Hodges: Tax and Estate Planning Issues for Employers and Individuals
- Outline: Employee Benefits Issues for Employers and Individuals after Obergefell v. Hodges
The Influence of Cultural Differences on Estate, Tax, and Employment Benefit Planning, Part II
Employee Benefits
2015 Health Plan Advice: Ethics, Technical & Practical Challenges
Corporate Counsel Forum
Defined Benefit Plan and Distributions Update
Defined Contribution Plans Update
Department of Treasury and Internal Revenue Service Hot Topics
Employer Wellness Programs and EEOC Proposed Rules Under the ADA
ESOP Update
- Outline: Non-Corporate Forms of Entity Participation in ESOPs
- Outline: Employee Benefits ESOP Update
Exempt Organization and Governmental Plans Update
- Chart: Available Catch-Up Contributions for 403(b) Plans
- Outline: Advisory Committee on Tax Exempt and Government Entities 403(b) Plan Recommendations
Keeping or Closing the Employer Stock Fund After Dudenhoeffer and Tatum – A Fiduciary Process
Litigation Update
Multinational Employee Benefits & Compensation Issues
- Slides: Impact Of New Accounting Rules on Executive Compensation
- Slides: International Considerations of Proposed Clawback Rules, Final Pay Ratio Rules
Multiple Employers, PEOs and Controlled & Affiliated Service Groups Update
- Outline: A Brief Comparison of Master Trusts and Open MEPs
- Outline: Summary of Senate Finance Report on Plan Participation
- Outline: Compilation of Affiliated Service Group &/or Management Service Organization Situations That Need Guidance
Over 20 Years of IRC Section 162(m) and 30 Years of IRC Section 280G – Has It Made a Difference in Executive Compensation?
Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update
- Outline: Religiously Affiliated Nonprofits and Closely Held Employers with Religious Objections to Contraceptive Coverage May Use Accomodation to Comply with ACA
- Slides: Group Health Plans: Factors Affecting Health Care Providers and the Costs They Generate for Employers and Participants
Employment Taxes
Employment Tax Primer for Small Businesses: I'm Ready to Hire My First Employee. What Should I Know About Taxes?
Federal Employment Tax Update
The Count Down Continues: Affordable Care Act (ACA)
Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE)
Current Developments
Death, Divorce and Reproductive Technology: What Every Practitioner Needs to Know Now About Planning For the Future
- Outline: Resolving Disputes over the Disposition of Frozen Embryos In the Context of Divorce
- Outline: Death, Divorce and Reproductive Technology: What Every Practitioner Needs to Know Now About Planning for the Future
Section 2801 Uncovered: Taxation of Gifts and Bequests from Covered Expatriates
The Middle Way: The Uniform Trust Decanting Act
Understanding Valuation Discounts
Exempt Organizations
Best Practices: Prizes, Sweepstakes, Contests and Awards
Coloring Outside the Lines: The Art of Gifting Art
Not So Fast: Exempt Organization Changes and Your State Attorney General
Section 501(c)(6) Trade Associations: Tax Issues, Governance, Controversies
Fiduciary Income Tax (TX) and Income & Transfer Tax Planning Group (TE)
Current Developments
Implementation and Administration of Self-Cancelling Installment Notes
Income Tax Deductions for Charitable Bequests of IRD
Section 2704(b) Proposed Regulations and Valuation Discounts on Transfers of Closely Held Entities
Financial Transactions
Financial Products and Partnership Interests
Foreign Activities of US Taxpayers
Incorporations and Liquidations of Foreign Entities
Issues Arising Under Section 956 – Part I
Joint International Committees: FAUST, FLF, USAFTT, and TP
Joint Current International Developments Panel
Individual & Family Taxation
Household Employee Tax Compliance
- Outline: The Requirements of Tax Reporting For Household Employees
- Slides: Household Employee Tax Compliance: Worker Classification Issues
Penalty Panel Part II
Taxpayer Filing Status - Options and Recent Law
- Outline: Taxpayer Filing Status
- Outline: Breaking Up Is Hard To Do: Protecting Divorcing Spouses from the IRS (and Each Other)
- Outline: List of Unavailable Refundable Tax Credits With The Filing Status of Married Filing Separately
- Outline: Filing Status Issues for nonresident taxpayers and resident alien taxpayers
- Outline: Filing Status Outline
Insurance Companies
Litigation / Administrative Update
Reinsurance Update
Retaliatory Taxes and Other State Premium Tax Issues
Investment Management
Current Issues for Private Investment Funds and their Managers
Current Issues for Regulated Investment Companies
- Slides: Current Issues for Regulated Investment Companies
- Slides: Current Issues for Regulated Investment Companies
- Slides: Current Issues for Regulated Investment Companies
Thinking About Converting to an RIC? Important Considerations
Joint Section Programs
Estate Tax Return Preparation and Audit Mitigation Strategies
Obergefell: Remaining Estate Planning and Tax Issues and a Look Into the Future
Tax, Immigration, and Employment Issues for Household Employees
- Outline: The Requirements of Tax Reporting For Household Employees
- Slides: Household Employee Tax Compliance: Worker Classification Issues
Partnerships & LLCs
Issues Arising Under Section 956 – Part II
Management Fee Waivers
Partnership Debt vs. Debt-Like Equity
Staying Dry Under The Umbrella: Avoiding PTP Issues In Umbrella Partnership Structures
Pro Bono & Tax Clinics
Basics of IRS Collection Alternatives
Designing a Pro Bono Project for Your Firm
Recent Developments Affecting Low-Income Taxpayers
Real Estate
Dealer vs. Investor - Caselaw Update
- Slides: Dealer v. Investor Revisited
- Outline: Wading Into the Investor/Dealer Quagmire -- Coffee Break’s Over, Back on Your Heads
Federal Tax Impact of Using State Tax Credits
Hot Topics
Motivating the Real Estate Deal and Fund Team – Part Deux
S Corporations
Important Developments
Primer on S Corporation Shareholders
S Corporation Valuations Issues
Trusts Decanting with S Corporation Shareholders
Sales, Exchanges & Basis
A Primer on Section 1031 Transactions
Current Developments
Negotiating and Drafting Tax Provisions in Rental Real Estate Purchase Agreements
The "Partnership Installment Note" Transaction
Standards of Tax Practice
Ethical Issues in Federal Tax Practice - The Government and Local Perspective
Ethics Two-Minute Drill
Procedures to Ensure Compliance
State and Local Taxes
Revising the Uniform Unclaimed Property Act
State Resident Tax Credits After the Supreme Court’s Wynne Decision
Tax Accounting
Current Developments
Tax Accounting Method Issues for Financial Institutions and Financial Products
Transaction Costs in Business Acquisitions: Recent Developments and Hot Topics
Update on Prevalent Tangible Property Regulations Issues and Anticipated Guidance
Tax Bridge on the Road
Ethical Issues for Newer Attorneys
- Outline: Tax Bridge on the Road: Ethical Issues for Young Tax Lawyers
- Slides: Ethical Issues for Newer Attorneys
Social Media: Ethics in the Internet Age
State Income, Double Taxation, and Tax Discrimination in the Post-Wynne World
- Outline: State Income, Double Taxation, and Tax Discrimination in the Post-Wynne World
- Slides: State Income, Double Taxation, and Tax Discrimination in the Post-Wynne World
- Slides: MD Comptroller of Treasury v. Wynne: The Impact upon Philadelphia and Pennsylvania Taxpayers
Tax Policy & Simplification
Estate Tax on Farms: Repeal, Retain, or Reform?
- Outline: Estate Tax on Farms: Repeal, Retain, or Reform?
- Slides: The State of the Estate Tax: Will and Should the Death Tax Die?
- Outline: Reforming the Estate Tax
The Design of Tax Incentives: Lessons from Energy and Environmental Incentives
- Slides: The Design of Tax Incentives: Theory and Practice
- Article: Picking Winners an Losers: History, Political Economy, and the Effects of "Imbeddedness" for Tax Subsidies to the Energy Industry
Teaching Taxation
The Status of the Tax Court post-Kuretski: Significant Shift, Minor Adjustment, or Nothing New?
- Outline: The Status of the Tax Court post-Kuretski: Significant Shift, Minor Adjustment, or Nothing New?
- Outline: The Un-Precedented Tax Court
Transfer Pricing
Preparing for Country by Country Reporting
US Activities of Foreigners & Tax Treaties
The New US Model Treaty and Treasury Explanation: What is Proposed and What is Needed