2013 Joint Fall CLE Meeting

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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.

 

 

2013 Joint Fall CLE Meeting - San Francisco, CA

Panel TitleMaterials Title

Administrative Practice

Current DevelopmentsOutline: Selected Recent Developments in Administrative Practice
Phone a Friend: When and How To Involve Others in the Government When Your Corporate Examination LanguishesSlides: Navigating the IRS: Phone a Friend--When to Involve Others in the Government When…
Phone a Friend: When and How To Involve Others in the Government When Your Corporate Examination LanguishesSlides: When and How to Involve Others in the Government When…
Update on IRS Audit ProcedureSlides: IRS Audit Trends & Developments

Affiliated & Related Corporations

Intercompany Debt Issues and Traps: A Discussion and Overview of the Rules Governing the Treatment of Intercompany Obligations, with a Transactional FocusSlides: The Intercompany Debt Regulations Treas. Reg. §1.1502-13(g)
Tax Issues Arising from Tax Sharing AgreementsSlides: Tax Sharing Agreements
Current Developments in Banking / Capital Markets TaxationSlides: Current Developments in Banking/Capital Markets Taxation
Practical Considerations in Dealing with the Final Cost Basis Reporting Regulations for Debt, Options and Securities Futures ContractsSlides: Cost Basis Reporting for Debt
Repurchase Agreements and Dollar RollsSlides: Repos, Dollar Rolls, and Purchase/Repos

Capital Recovery & Leasing

Current Developments Report and Update on Pending GuidancePaper: Current Developments
Research and Development: A Discussion of Recent Developments and Overlying IssuesSlides: Research Credit: A Discussion of Recent Developments
Tax Credit Hot TopicsSlides: PTC Begun Construction and Renewable Energy Issues
Tax Credit Hot TopicsSlides: Tax Credit Hot Topics

Civil & Criminal Tax Penalties

Department of Labor - Civil and Criminal EnforcementPaper: The U.S. Department of Labor, Employee Benefits Security Administration (EBSA), is responsible for the enforcement of Title I of ERISA.
Navigating the Civil Employment Tax Audit and Related IssuesPaper: Navigating the Civil Employment Tax Audit and Related Issues
Advising the Fiduciaries of Trusts Holding Business InterestsOutline: Potential Tax Liability for Trustees
Beyond IRC Section 6166; the Future of Graegin-style LoansPaper: Beyond IRS Section 6166: The Future of…
Succession Planning for Closely Held Businesses and Professional PracticesPaper: Planning for the Successful Transition of a Family Business…
Succession Planning for Closely Held Businesses and Professional PracticesPaper: Succession Planning for … Dental Specialty Practices
Transfer Planning with Carried Interests in Hedge and Private Equity FundsOutline: Transfer Tax Planning with Carried Interests in…
Transfer Planning with Carried Interests in Hedge and Private Equity FundsSlides: Transfer Tax Planning With…

Corporate Tax

Section 355 Transactions in the Cross-Border ContextSlides: Cross-Border Section 355 Transactions

Court Procedure & Practice

Important DevelopmentsPaper: Summary of Important Developments
Insolvency and Tax: Advising Clients About Tax Matters in the Course of BankruptcySlides: Insolvency and Tax: Advising Clients About Tax Matters in the Course of Bankruptcy
Litigating Cross-Border Transactions in US CourtsSlides: Transfer Pricing: Overview of Section 482 Rules

Employee Benefits, Subcommittee on Employee Benefits Legislation

Legislative UpdateOutline: Summary of the Secure Annuities for Employee (SAFE) Retirement Act

Employee Benefits, Subcommittee on ESOPs (TX) and Fiduciary Responsibility, Administration and Litigation (TE)

ESOP UpdatePaper: (no title)

Employee Benefits, Subcommittee on Litigation

Litigation UpdateOutline: Litigation Update

Employee Benefits, Subcommittee on Mergers & Acquisitions (TX) and Plan Transactions & Terminations Committee (TE)

Mergers & Acquisitions UpdateSlides: Global Equity Compensation Tax Issues in M&A Transactions
Mergers & Acquisitions UpdateChart: Global Equity Matrix

Employee Benefits, Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices

Administrative Practices UpdateOutline: Key Changes to Determination Letter and EPCRS Procedures
Aftermath of the Supreme Court’s DOMA DecisionSlides: Aftermath of Supreme Court's DOMA Decisions
Aftermath of the Supreme Court’s DOMA DecisionPaper: Employee Benefits Affecting Employees in Same Sex Marriages…
Attorneys Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and BeyondSlides: Legal Review of Employee Benefits Plan Services Agreements
Attorneys Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and BeyondSlides: The Art of Understanding and Documenting Fees
Attorneys Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and BeyondChart: Attorney Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and Beyond
Hot TopicsPaper: Notice to Employees…
Hot TopicsPaper: Wellness Programs Final Regulations
Hot TopicsPaper: Congress and DOL Consider Requiring Lifetime...
Independence Considerations in Employee Benefits – When Is a Service Provider Truly Independent?Slides: Independence Considerations in Employee Benefits – When is a Service Provider Truly Independent?

Employment Taxes

Affordable Care Act and Its Impact on the Characterization of a WorkforcePaper: Overview of Recent Judicial Opinions…Worker Classification
Affordable Care Act and Its Impact on the Characterization of a WorkforcePaper: Voluntary Classification Settlement Program
The Doom of DOMA, Keeping the Faith and Taking CreditSlides: Defense of Marriage Act
UI Integrity ActSlides: Unemployment Insurance Issues

Energy & Environmental Taxes

Begun Construction Test and the New PTC – How are Companies Planning to Meet the Test?Slides: Renewable Energy Tax and Grant Updates
Estate Planning Without a Passport: Section 2801 and Other International Hot TopicsSlides: Estate Planning Without a Passport: Section 2801 and Other International Hot Topics
Much Ado About Something: Clash of the Agent, Attorney and Appraiser in Gift Tax Audits (in 4 Scenes)Outline: Much Ado About Something: Clash of the Agent, Attorney and Appraiser in Gift Tax Audits (In 4 Scenes)

Exempt Organizations

Cause Related Marketing & Commercial Co-VenturesPaper: Cause-Related Marketing & Commerical Co-Ventures
New Market Tax CreditsSlides: Use of New Markets Tax Credit by…
New Market Tax CreditsArticle: How Nonprofit Orgs Can Use…
News from the IRS and TreasuryPaper: Senate Finance Committee Staff Tax Reform Options for Discussion
News from the IRS and TreasurySlides: Current Developments Written Materials for “News from the IRS and Treasury”
Donor Advised FundsSlides: Donor Advised Funds
Helping the IRS: 501(c)(4) Reform ProposalsPaper: The Tie Goes To The Speaker, Not The Censor
Estate Planning for Real Estate Owners: Don’t Forget the Income Tax SidePaper: Estate Planning for Real Estate Owners: Don't Forget…
Estate Planning for Real Estate Owners: Don’t Forget the Income Tax SideSlides: Estate Planning for Investment Real Estate: Don't Forget…
Material Participation Under Passive Activity Limitations and Net Investment Income TaxOutline: Material Participation Under Passive Activity Limitations and Net Investment Income Tax

Financial Transactions

Financial Transaction Committee Reports on CampSlides: Financial Transactions Committee Reports on the Camp Proposals regarding Financial Products
Futurization of Swaps - What the Clients are Dealing with NowSlides: Futurization of Swaps
Tax Planning with REMICs: Everything Old is New AgainSlides: REMICs

Foreign Activities of US Taxpayers

Issues and Challenges Arising Under the Foreign Tax CreditSlides: Issues and Challenges Arising Under the Foreign Tax Credit
Unresolved International Tax Issues in M&A TransactionsSlides: Unresolved International Tax Issues in M&A Transactions

Individual & Family Taxation

"Helpful Tips on How to Bring a Case to Taxpayer Advocate Service and Recent Changes to IRS Collection Alternatives"Slides: Working With the Taxpayer Advocate Service
"Helpful Tips on How to Bring a Case to Taxpayer Advocate Service and Recent Changes to IRS Collection Alternatives"Slides: Helpful Tips on How to Bring a Case to TAS and Recent Changes to IRS Collection Alternatives
How Implementation of the Affordable Care Act Impacts Individual TaxpayersSlides: How Implementation of the Affordable Care Act Impacts Individual Taxpayers
Reporting Foreign Source IncomeOutline: Reporting Foreign Source Income
Reporting Foreign Source IncomeSlides: Reporting Foreign Source Income

Insurance Companies

Captive Insurance: Back in the spotlightSlides: Captive Insurance Back in the Spotlight
Insurance M&A: What are the biggest issues around Deferred Tax Assets?Slides: Insurance M&A - What Are the Biggest Issues…
Modern Family, Tax Policy and the Taxation of Insurance Products Post WindsorOutline: Income and Transfer Tax Issues After IRS Announcement on Same-Sex Marriage
Modern Family, Tax Policy and the Taxation of Insurance Products Post WindsorChart: Status Recognition Chart for Same-Sex Couples

Investment Management

An Overview of Business Development Companies (“BDCs”) and Uses of These Vehicles in the Current ClimateSlides: Overview of Organization and Structuring of BDCs
Current Developments Regarding Tax Issues for Hedge FundsSlides: Net Investment Income Tax & Other Hedge Fund Issues
Current Issues Confronting Regulated Investment CompaniesSlides: RIC UPDATE

Joint: Closely Held Businesses (TX) and Business Planning Group (TE)

Advising the Fiduciaries of Trusts Holding Business InterestsOutline: Trusts as S Corporation Shareholders

Joint: Court Procedure & Practice and Tax Litigation & Controversy Committee of the Income & Transfer Tax Planning Group Roundtable Discussion

Effective Use of Demonstrative Exhibits and Summary Exhibits in Tax CasesSlides: Effective Use of Demonstrative and Summary Exhibits in Tax Cases

Joint: Diversity and Employee Benefits International Issues

Leaving the US – It’s Very Different from Leaving Las Vegas. Tax Planning for US Persons Living and Working AbroadChecklist: International Executives Checklist

Joint: Employee Benefits (TX) and Employee Benefit Plans & Other Compensation Arrangements Group (TE)

Aftermath of Litigation: What Plan Language and Administration Do You Need Now?Slides: Aftermath of Litigation: What Plan Language

Joint: Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE)

Current DevelopmentsPaper: Current Developments in Federal Transfer Taxes

Joint: Exempt Organizations (TX) and Charitable Planning & Exempt Organizations Group (TE)

Donor Advised FundsOutline: Donor Advised Funds

Joint: Fiduciary Income Tax (TX) and Income & Transfer Tax Planning Group (TE)

Current DevelopmentsPaper: Recent Developments in Fiduciary Income Tax

Joint: Foreign Activities of US Taxpayers, Transfer Pricing and US Activities of Foreigners & Tax Treaties

Joint Current International Developments PanelSlides: International Tax Update

Partnerships & LLCs

Sailing in Circles: Forthcoming IRS Guidance on Partnership Transactions involving a Partner’s StockSlides: Partnership Transactions Involving a Partner’s Stock
Sailing into Unchartered Waters: Subchapter K Tax ReformPaper: Testimony Before the Subcommittee on Select Revenue Measures
Sailing into Unchartered Waters: Subchapter K Tax ReformSlides: Chairman Camp Discussion Draft
Sailing into Unchartered Waters: Subchapter K Tax ReformSupplement: Technical Explanation of the Ways and Means Committee Discussion Draft Provisions to Reform the Taxation of Small Business and Passthrough Entities
Sailing into Unchartered Waters: Subchapter K Tax ReformArticle: Comments on the Taxation Of Passthrough Entities
Tightening the Lines: IRS to Restrict Partnership Debt AllocationsSlides: Tightening the Lines: IRS to Restrict Partnership Debt Allocations

Pro Bono & Tax Clinics

Developments in Collection Due ProcessOutline: Pro Bono and Tax Clinics: Developments in Collection Due Process
Recent Developments Affecting Low Income TaxpayersOutline: Recent Developments Affecting Low Income Taxpayers
The Impact of US v. Windsor on the Civilian and Military TaxpayersOutline: Which Marriages Should be Recognized by the IRS
The Impact of US v. Windsor on the Civilian and Military TaxpayersOutline: Specific Tax Issues Raised by the Fall of DOMA
The Impact of US v. Windsor on the Civilian and Military TaxpayersChart: Status Recognition Chart for Same-Sex Couples
Update on Procedures from the Tax Court"Outline: Discussion of ways to enhance Court procedures for the benefit of self-represented taxpayers"

Real Estate

Hot TopicsSlides: Hot Topics
Setting up your Private REIT – A Practical PrimerSlides: Setting up your Private REIT – A Practical Primer
State Tax Enforcement Areas – An Insider’s Perspective"Outline: State Tax Enforcement Areas An Insider's Perspective "
State Tax Enforcement Areas – An Insider’s Perspective"Slides: State Tax Enforcement Areas An Insider's Perspective"
Tax Credit Planning After Historic Boardwalk and Anticipated IRS GuidancePaper: Credit Where Credit Is Due? Who Is a Partner after Historic Boardwalk?
Tax Credit Planning After Historic Boardwalk and Anticipated IRS GuidanceSlides: Historic Boardwalk

S Corporations

Charitable Gifts by S Corporations and Their ShareholdersPaper: Planning for Maximum Tax Benefits from Charitable Gifts…
Current DevelopmentsOutline: Current Developments in the Federal Income Taxation of S Corporations
Tax Effects of Converting Entities Under State Law Conversion and State Law Merger StatutesOutline: Tax Effects of Converting Entities Under State Law Conversion and State Law Merger Statutes

Sales, Exchanges & Basis

Analyzing the Section 1031 “Disqualified Person” Rules: The Usual Suspects and Beyond"Slides: Analyzing the Section 1031 “Disqualified Person” Rules"
Current Developments in Sales, Exchanges and BasisOutline: Current Non-Section 1031 Developments
Current Developments in Sales, Exchanges and BasisPaper: IRC 1031/1033 Current Developments
Tax Planning Workshop: “Drop & Swap” and “Mixing Bowl” TechniquesReport: 2001 Joint Report on IRC Section 1031 Open Issues Involving Partnerships
The Very Rare Find: A Section 1031 Collectible Exchange with Definite AnswersPaper: Section 1031 and Approximate and Midstream Business Transactions
The Very Rare Find: A Section 1031 Collectible Exchange with Definite AnswersSlides: Tax-Deferred Exchanges of Art…

Section Program

Estate & Gift Taxes (TX) and the Income & Transfer Tax Planning Group (TE)Slides: “Well, That Certainly Resolved Everything…” Same-Sex Planning in a Post-Windsor and Perry World

Standards of Tax Practice

Ethical Issues Arising from Conflicts of Interest, Especially When Criminal Tax Charges are on the Horizon.Slides: Ethical Issues Arising from Conflicts of Interest
Ethical Issues in Federal Tax Practice - The Government PerspectiveSlides: Ethical Issues in Federal Tax Practice - The Government Perspective

State & Local Taxes

Could The Due Process Clause Rain on the Nexus Everywhere Parade?Slides: Could the Due Process Clause Rain on…
State and Local Tax Issues for International Commerce.Slides: State Tax Issues for International Commerce
State and Local Tax Issues for International Commerce.Outline: State Income Taxation of Foreign Corporations
State and Local Tax Issues for International Commerce.Outline: State Tax Implications of International Transactions Relevant Federal Tax Concepts and Special Situations
Transparency Under A Different Light: Discovery, Settlements and ConfidentialitySlides: Transparency Under a Different Light: Discovery, Settlements and Confidentiality
What if the Marketplace Fairness Act Becomes Law?Slides: What If The Marketplace Fairness Act Becomes Law?

Tax Accounting

Accounting Methods Issues Related to Short Year ReturnsHandout: Accounting Method Issues Related to Short Year Returns Guidance Excerpts
Accounting Methods Issues Related to Short Year ReturnsOutline: Accounting Method Issues Relating to Short Year Returns Scenarios
Current DevelopmentsOutline: Current Developments
Tax Accounting Issues in International Tax PlanningOutline: Accounting method issues impacting International Operations

Tax Exempt Financing

Legislative Department of Treasury and IRS UpdateOutline: Legislative, Treasury, and Internal Revenue Service Updates
Tax Implications of Direct-Purchase (Private Placement) BondsOutline: Direct Placement Bond Issues Tax Considerations
Tax Round TableOutline: Capitalization of Expenditures

Tax Policy & Simplification

Implementing the Affordable Care Act in 2014 and BeyondSlides: The Not-So-Mandatory Individual Mandate
Implementing the Affordable Care Act in 2014 and BeyondSlides: Premium Tax Credits under the ACA
Implementing the Affordable Care Act in 2014 and Beyond"Paper: Perverse Incentives Arising from the Tax Provisions of Healthcare Reform:"
What Can Tax Lawyers and Economists Learn from Each Other?Slides: Economists are from Mars, Lawyers are from Venus
What Can Tax Lawyers and Economists Learn from Each Other?Paper: Economists are from Mars, Lawyers are from Venus
What Can Tax Lawyers and Economists Learn from Each Other?Article: Perverse Incentives Arising from the Tax Provisions of Healthcare Reform

Tax Practice Management

Social Media and Your Practice: Avoiding Ethical PitfallsOutline: Social Media and Your Practice - Avoiding Ethical Pitfalls
Social Media and Your Practice: Using It EffectivelySupplement: Social Media Platforms
Social Media and Your Practice: Using It EffectivelySlides: Social Media and Your Practice: Using It Effectively

Teaching Taxation

Would You Like a Calculator with that Diploma? Student loans and taxesSlides: LRAPs and Section 108(f)
Would You Like a Calculator with that Diploma? Student loans and taxesOutline: Discharge of Student Loans in Bankruptcy
Would You Like a Calculator with that Diploma? Student loans and taxesOutline: Student Loans, Taxes, and the American Dream in Retrograde
Would You Like a Calculator with that Diploma? Student loans and taxesChart: Payment Scenarios

Transfer Pricing

Leading Transfer Pricing Cases in Current LitigationSlides: Current Transfer Pricing Cases: Reading the Tea Leaves
The 3M Case and Blocked IncomeSlides: The 3M Case and Blocked Income

US Activities of Foreigners & Tax Treaties

Applying the Permanent Establishment Rules in the Digital AgeSlides: Permanent Establishment in the Digital Age
Planning for “Inbound” US Investments Through Foreign TrustsSlides: Inbound Investments by Foreign Trusts and Individuals

Young Lawyers Forum

Tax Planning for Natural DisastersState Tax Implications of Natural Disasters
Tax Planning for Natural DisastersSlides: Tax Implications of Natural Disasters
Tax Planning for Natural DisastersOutline: Tax Implications of Natural Disasters, Part IV: Best Practices
Tax Planning for Natural DisastersSlides: Tax Implications of Natural Disasters

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