2013 May Meeting

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.

 

 

2013 May Meeting - Washington, DC

Panel TitleMaterials Title

Administrative Practice

Hey, Somebody Stole My Tax ID!Business identity theft is on the rise
Hey, Somebody Stole My Tax ID!Business Identity Theft Resource Guide
Hey, Somebody Stole My Tax ID!Despite warnings, most states slow to confront corporate ID theft
Hey, Somebody Stole My Tax ID!ID theft stings Captain D's franchisee
Hey, Somebody Stole My Tax ID!Slides: Hey, Somebody Stole My Tax ID!
Hey, Somebody Stole My Tax ID!Slides: The growing implications of employer identity theft
Hey, Somebody Stole My Tax ID!Tax refund scams can involve costly employer identity theft
Hey, Somebody Stole My Tax ID!USDOJ_ US Attorney's Office - Northern District of Texas
Hey, Somebody Stole My Tax ID!Will the Real John Doe Please Stand Up?: Tax Identity Theft Developments
Important DevelopmentsPaper: Selected Recent Developments in Administrative Practice
Managing International Tax Audits and Tax Risks in a Changing Global LandscapeSlides: Managing International Audits and Tax Risk in a Changing Global Environment

Affiliated & Related Corporations

Current Developments in Consolidated ReturnsSlides: Section 336(e) regulations
Member Tax Years and Related IssuesSlides: Member Tax Years and Related Issues

Banking & Savings Institutions

Highlights of the Final FATCA Regulations and Intergovernmental AgreementsSlides: The Far Reaching Impact of FATCA Across Borders and Across Industries
Is There a Mark to Market in your Near Future? A Discussion on the Recently Proposed Ways and Means Committee’s Tax Reform for Financial InstrumentsAlert: Ways and Means Committee Issues Draft Provisions to Reform Taxation of Financial Instruments
Is There a Mark to Market in your Near Future? A Discussion on the Recently Proposed Ways and Means Committee’s Tax Reform for Financial InstrumentsSlides: Is There a Mark to Market in your Near Future?
The Recent Tax Court’s Decision of the STARS TransactionSlides: The STARS Transaction Decision and other Recent Applications of the Economic Substance Doctrine

Bankruptcy & Workouts

A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of JusticeDiscussion Topics: A Conversation With Chief Counsel and The Tax Division
A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of JusticeEndnotes to PowerPoint
A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of JusticeReference Materials
A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of JusticeSlides: The Secured Federal Tax Debt in Bankruptcy
Judges' Perspective: What Tax Practitioners Need to Know about Chapter 11Tax-Related Requirements in Chapter 11 Bankruptcy: What Tax Lawyers Should Know About Chapter 11
The Mysteries of § 108Issues In Cancellation Of Debt Income Cases

Business Cooperatives & Agriculture

Cooperative Tax UpdateSlides: Cooperative Tax Update
Recovery Periods for Agricultural StructuresPanel Materials
The Battle for the Cash Method of Accounting – Part I: The Internal Revenue Service's New Position and the Taxpayer's ResponsePanel Materials

Capital Recovery & Leasing

Capitalization Issues Affecting BanksSlides: Capitalization Issues Affecting Banks
Current Developments Report and Update on Pending GuidanceCapital Recovery and Leasing Update - May 2013
Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263AIRS Memorandum (LB&I-04-0313-001), Accounting Method for Converting Capitalized Assets to Repair Expense Under Section 263(a)
Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263ANotice 2012-73
Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263APanel Materials: Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263A
Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263ARev. Proc. 2012-19
Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263ARev. Proc. 2012-20

Civil & Criminal Tax Penalties

Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing AdvocacyBOP - TRULINCS
Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing AdvocacyCriminal Defense Update- BOP Compassionate Release
Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing AdvocacyCumberland - (Camp) Admissions & Orientation Handbook
Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing AdvocacyMorris Correctional Manual
Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing AdvocacyPanel Materials
Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing AdvocacySecond Chance Act - 18 USC 3624
Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing AdvocacyThe Federal Bureau of Prisons’ Compassionate Release Program
Interview with Acting Deputy Assistant Attorney General, Department of JusticeMaterials: Interview with Acting Deputy Assistant Attorney General, Department of Justice
Interview with Chief of Criminal InvestigationMaterials: Interview with Chief of Criminal Investigation
Reports of Subcommittees on Important DevelopmentsImportant Developments — Criminal
Reports of Subcommittees on Important DevelopmentsImportant Developments on Civil Penalties
Reports of Subcommittees on Important DevelopmentsIRS Investigations and Practices Subcommittee Report
Reports of Subcommittees on Important DevelopmentsPaper: Report of Subcommittee on International Enforcement
Reports of Subcommittees on Important DevelopmentsSubcommittee Report: Legislative & Administrative Developments
The Handling and Mishandling of IRS WitnessesAdditional Materials
The Handling and Mishandling of IRS WitnessesSlides: The Handling and Mishandling of IRS Witnesses

Closely Held Businesses

The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations – Part IIABA Section of Taxation Comments Concerning Proposed Treasury Regulations under Section 1411
The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations – Part IISlides: The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations
What's New in Worker Classification?Article: Worker Classification Issues in Professional Practices
What's New in Worker Classification?Bio: Betty Williams
What's New in Worker Classification?Slides: What’s New in Worker Classification Background and Enforcement Trends in Worker Classification

Corporate Tax

Contingent Liabilities In Taxable and Tax-Free TransactionsSlides: Contingent Liabilities in Taxable Transactions and Distributions
Current Corporate Tax DevelopmentsSlides: ABA Corporate Tax Committee: Current Developments
Obsolete Rulings?Slides: “Obsolete” Corporate Rulings?

Court Procedure & Practice

Challenging IRS Action Under the Administrative Procedure ActSlides: The Administrative Procedure Act (“APA”) and IRS Guidance
Crossing Borders to Conduct Discovery in Tax Litigation– Tools, Strategies, and Evolving IssuesSlides: Cross-Border Discovery in International Tax Controversies
Effective Use of Depositions at TrialEffective Use of Depositions at Trial
Important DevelopmentsImportant Developments Summary

Diversity

Looking Beyond DOMA: Adapting the Code to the “Modern Family”Taxation of Same Sex Spouses After DOMA

Employee Benefits

Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates(1) EBSA Guidance Summary
Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates(2) EBSA Update
Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates(3) PBGC Update
Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates(4) PBGC Proposed Regs on Reportable Events
Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates(5) Technical Update
Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates(6) Examining PBGC Premium Issue Brief
Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates(7) DOL Field Assistance Bulletin 2013-01
Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation UpdatesA Window into PBGC’S Practice: Current Issues and Trends
Department of Treasury/IRS Hot Topics2013 ABA Section of Taxation Questions & Answers for 2013 May meeting
Department of Treasury/IRS Hot TopicsSummary of Selected Guidance Issued by IRS during the Past Year
Department of Treasury/IRS Questions and Answers2013 ABA Section of Taxation Questions & Answers for 2013 May meeting
Fiduciary Issues Encountered by Plan Administrators with Abandoned Plans and Plan Sponsors in BankruptcyMaterials: Record retention and compliance
Fiduciary Issues Encountered by Plan Administrators with Abandoned Plans and Plan Sponsors in BankruptcySlides: Fiduciary Liability Issues: Defined Benefit Plan Terminations
Fiduciary Issues Encountered by Plan Administrators with Abandoned Plans and Plan Sponsors in BankruptcySlides: Record Retention and Compliance
Fiduciary Issues Encountered by Plan Administrators with Abandoned Plans and Plan Sponsors in BankruptcySlides: Safe Harbor Rollover and Plan Administration Issues
The Ins and Outs of Benefit Provisions in M&A Credit AgreementsAdditional Materials
The Ins and Outs of Benefit Provisions in M&A Credit AgreementsSlides: What Benefit Provisions Should Be In M&A Credit Agreements?
The Ins and Outs of Benefit Provisions in M&A Credit AgreementsSun Capital Partners III LP v New England Teamsters and Trucking Industry Pension Fund
Welfare Plan Developments: HIPAA, HITECH and More ACASlides: HIPAA Enforcement & Audits
Welfare Plan Developments: HIPAA, HITECH and More ACASlides: New HIPAA/HITECH Act Regulations - What Plan Sponsors Need To Do To Comply

Employee Benefits Subcommittees

Subcommittee on Defined Benefit Plans
Defined Benefit Plans UpdateA Window into PBGC’S Practice: Current Issues and Trends
Defined Benefit Plans UpdateGAO: Timely Action Needed to Address Impending Multiemployer Plan Insolvencies
Defined Benefit Plans UpdateMultiemployer Pension Plans – Report to Congress Required by PPA (PBGC, Treasury, DoL)
Defined Benefit Plans UpdateRecent PBGC Regulatory Developments
Defined Benefit Plans UpdateSolutions not Bailouts – Report of the Retirement Security Review Commission of the NCCMP
Subcommittee on Defined Contribution Plans
Defined Contribution Plans UpdateAmerican Taxpayer Relief Act of 2012 Excerpts
Defined Contribution Plans UpdateDiscussion Summary
Defined Contribution Plans UpdateIRS Announcement 2007-59
Defined Contribution Plans UpdateJoint Committee on Taxation, General Explanation of Tax Legislation Enacted in the 112th Congress
Defined Contribution Plans UpdateSection 401(k) Compliance Check Final Report
Defined Contribution Plans UpdateTarget Date Retirement Funds - Tips for ERISA Plan Fiduciaries
Defined Contribution Plans UpdateTibble v. Edison International
Defined Contribution Plans UpdateTreasury Regulation Section 1.401(k)-3
Subcommittee on Distributions
Distributions UpdatePanel Outline
Subcommittee on Employee Benefit Legislation
Legislative UpdateArticle: Key Health, Retirement and Compensation Provisions in Obama Budget Proposal
Legislative UpdateSide-by-Side Comparison Key Provisions House, Senate and Administration Budget Proposals
Subcommittee on Employee Benefits Executive Compensation, Fringe Benefits and Federal Securities Law
Executive Compensation, Fringe Benefits and Federal Securities Law Update"IRS Proposes Regulations on $500,000 Deduction Limit for Health Insurer Executive Compensation"
Subcommittee on ESOPs
ESOP UpdateMaterials
Subcommittee on Exempt Organization and Governmental Plans
Exempt Organizations and Government Plans UpdateIRS Releases 403b Plan Approval Procedures
Exempt Organizations and Government Plans UpdateLitigation Challenges to the Church Plan Definition: a Critical Issue for Church-Related Hospitals and Nonprofits
Subcommittee on Fiduciary Responsibility/Plan Investments
Fiduciary Responsibilities UpdateFiduciary Responsibility Update
Subcommittee on Foreign and International Issues
International UpdateCynthia Marcotte Stamer Materials
International UpdateFATCA and Its Impact on Non-U.S. Retirement Plans
Subcommittee on Litigation
Litigation UpdatePanel Materials
Subcommittee on Mergers and Acquisitions
Mergers & Acquisitions UpdatePaper: Employee/Employee Benefits Covenants
Subcommittee on Multiple Employers, PEOs and Controlled and Affiliated Service Groups
Multiple Employers, PEOs and Controlled Groups UpdateEmployer Status and the PEO Relationship
Multiple Employers, PEOs and Controlled Groups UpdatePanel Slides
Multiple Employers, PEOs and Controlled Groups UpdatePaper: A Multiple Employer Plans (MEPs) Primer
Multiple Employers, PEOs and Controlled Groups UpdateThe Retirement Crisis and a Plan to Solve It
Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices
Administrative Practices UpdateOutline
Subcommittees on Welfare Plan Design, EEOC, FMLA and Leaves Issues and Cafeteria Plans and Reimbursement Accounts
Welfare Benefits Design, EEOC and FMLA Update"Final HHS Regulations Regarding Exchange and Issuer Standards Relating to Coverage of Essential Health Benefits, Actuarial Value, and Accreditation Standards"
Welfare Benefits Design, EEOC and FMLA UpdatePaper: On the Manifold Meanings of "Affordability" According to the Patient Protection and Affordable Care Act
Welfare Benefits Design, EEOC and FMLA UpdateWellness Programs: EEOC Developments and the Definition of “Tobacco Use” in New 45 CFR §147.102(a)(1)(iv)

Employment Taxes

Employment Taxes and VisasNonresident Alien Tax Compliance A Clearer View
Employment Taxes and VisasPaper: An Overview of U.S. Non-immigrant Visa Classifications
Jurisdiction and Venue in Employment Tax RefundsSlides: Employment Tax Refund Claims: Jurisdiction & Venue Issues

Energy & Environmental Taxes

Oil and Gas Tax UpdateSlides: International Oil and Gas Tax Issues
Renewable Energy Tax and Grant UpdatesSlides: Renewable Energy Tax and Grant Updates

Estate & Gift Taxes

Current DevelopmentsKaribjanian & Mensch - Current Developments in Transfer Tax
Preferred Equity Freezes: How They WorkSpecial Valuation Rules: Section 2701
Tax Apportionment: One Clause Does Not Fit AllPanel Outline

Exempt Organizations

Audits, Appeals, and Litigation: Trends and TacticsPanel Materials
Denials of Applications for Tax-Exempt StatusPanel Materials
News from Capitol HillExcerpts of the Joint Committee on Taxation Report to the House Committee on Ways and Means on Present Law and Suggestions for Reform Submitted to the Tax Reform Working Groups, specifically those portions having to do with tax exempt status and the charitable deduction
News from Capitol HillMaterials
News from Capitol HillOutline of Discussion Topics for Hill Update
News from the IRS and TreasuryOutline: News From The IRS and Treasury
Update on Colleges and UniversitiesUpdate on Colleges and Universities

Fiduciary Income Tax

Before Tying the Knot: Income Tax Provisions of a Prenuptial AgreementPaper: Before Tying The Knot: Income Tax Planning Of A Premarital Agreement
Regulatory Roundup and Recent DevelopmentsPaper: Recent Developments in Fiduciary Income Tax
Update on the 3.8% Tax on Net Investment IncomeSelected Sections of the Preamble & Proposed Regulation Text, and Selected Sections from the ABA Section of Taxation Comment Letter (dtd 4/5/13)
Update on the 3.8% Tax on Net Investment IncomeSlides: Update on the 3.8% Tax on Net Investment Income (§ 1411)
Using Estate Planning Vehicles for Income Tax PlanningUsing Estate Planning Vehicles for Income Tax Planning

Financial Transactions

Advanced Topics in Market DiscountPanel Materials
Economic Substance and Behavioral Economics in the Wake of Bank of New York MellonSlides: Economic Substance, the Frame Game, and Bank of New York Mellon v. Commissioner
Recent Developments and Current IssuesSlides: Recent Developments

Foreign Activities of US Taxpayers

Foreign Tax CreditsSlides: Foreign Tax Credits
Outbound Property Transfers Under Section 367(a)(5)Slides: Outbound Property Transfers Under Section 367(a)(5)

Individual & Family Taxation

Avoiding Taxpayer Penalties: First Time Abatement, and Reasonable Cause and Reliance on Professional AdvicePaper: Avoiding Taxpayer Penalties: Reasonable Cause and Reliance on Professional Advice
Avoiding Taxpayer Penalties: First Time Abatement, and Reasonable Cause and Reliance on Professional AdvicePaper: Update On The Accuracy Penalty: The Slippery Slope To Strict Liability
Avoiding Taxpayer Penalties: First Time Abatement, and Reasonable Cause and Reliance on Professional AdvicePenalty Abatement Procedures Should Be Applied Consistently to All Taxpayers and Should Encourage Voluntary Compliance
Avoiding Taxpayer Penalties: First Time Abatement, and Reasonable Cause and Reliance on Professional AdviceSlides: Taxpayer Penalties Strategies in Client Representation
How the IRS Assists Victims of Tax-Related Identity Theft and Return Preparer Misconduct or FraudPaper: Identity Theft
How the IRS Assists Victims of Tax-Related Identity Theft and Return Preparer Misconduct or FraudPaper: Return Preparer Fraud or Misconduct

Insurance Companies

Affordable Care Act ImplementationACA section 9010 health insurance provider fee -- summary of recent proposed regulations.
Affordable Care Act ImplementationIRC section 162(m)(6) $500,000 compensation deduction limitation -- summary of recent proposed regulations
Affordable Care Act ImplementationIRC sections 4375 and 4376 (PCORI fee) and ACA section 1341 Transitional Reinsurance Program Fee -- Summary of provisions
Dialogue On Tax Reform and Its Effects On InsurersSlides: Dealing with Uncertainty
Tax Controversy: What Lessons May Be Learned From Recent Cases?Overview of Representative Cases
Tax Controversy: What Lessons May Be Learned From Recent Cases?Slides: Tax Controversy: Lessons Learned From Recent Cases

Investment Management

Current Issues Being Addressed by the Investment Company InstituteSlides: ICI Update
Current Issues Being Addressed by the Investment Company InstituteSupplemental Materials
Taxing Private Equity Funds as Corporate ‘Developers’Article: Taxing Private Equity Funds as Corporate ‘Developers’
Taxing Private Equity Funds as Corporate ‘Developers’Slides: Taxing Private Equity Funds as Corporate Developers
Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and MauritiusArticle: Regulated Investment Companies and Commodity-Linked Instruments: The Current State of Play
Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and MauritiusArticle: Two Recent Private Letter Rulings Provide a Rationale for Determining When Certain Derivative Contracts Will Be Considered Securities Under Code Sec. 851(b)(2) and Will Produce Qualifying Income for a Regulated Investment Company
Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and MauritiusDoing Business in India
Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and MauritiusGlobalizing India Inc.
Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and MauritiusKey Considerations: Joint Ventures In India
Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and MauritiusOffshore Derivative Instruments: An Investigation Into Tax Related Aspects
Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and MauritiusPrivate Equity in Real Estate
Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and MauritiusSection 851 of the Code

JOINT: Estate & Gift Taxes, Fiduciary Income Tax and Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittees Luncheon

Estate & Gift Taxes, Fiduciary Income Tax and Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittees LuncheonAscertainable Standards Outline

JOINT: Foreign Activities of US Taxpayers, US Activities of Foreigners and Tax Treaties, Foreign Lawyers Forum, and Transfer Pricing

Joint Current International Developments PanelSlides: Joint Current International Developments Panel USAFTT, FAUST, Transfer Pricing and FLF

Partnerships & LLCs

Aggregate versus Entity: The Original Sin of Subchapter KSlides: Aggregate v. Entity The Original Sin of Subchapter K
Allocation of Basis Adjustments Under Section 743(b) to Contingent LiabilitiesArticle: Can (or Must) Basis Adjustments Under Code Sec. 743(b) Be Allocated to Contingent Liabilities?
Allocation of Basis Adjustments Under Section 743(b) to Contingent LiabilitiesArticle: Should Purchasers Anticipate that Partnership Interests with Identical Legal and Economic Characteristics Might Produce Different Tax Results when Purchased from Different Sellers?
Allocation of Basis Adjustments Under Section 743(b) to Contingent LiabilitiesReport on the Allocation of Basis Adjustments Under Section 743(b) to Contingent Liabilities
Allocation of Basis Adjustments Under Section 743(b) to Contingent LiabilitiesSlides: Allocation of Basis Adjustments Under Section 743(b) to Contingent Liabilities
Hot TopicsSlides: Hot Topics

Pro Bono & Tax Clinics

Tax and Consumer Transactions1. Dealing with Errors in the 1099C
Tax and Consumer Transactions2. Example Evidentiary Objections
Tax and Consumer Transactions2013 NCLC/CFA Tax-Time Products Report
Tax and Consumer Transactions3. Forgiven but not Forgotten
Tax and Consumer TransactionsNCLC-NCTC amicus in Loving v IRS
Tax and DisabilityOutline: Taxpayers with Disabilities
Tax and DisabilityTaxpayers with a Disability
Tax and Family LawSlides: Tax and Family Law
Tax and ImmigrationSlides: Emerging Issues: Tax Implications of Immigration Reform
Tax and ImmigrationSlides: New ITIN Rules: The IRS Response To TIGTA Reports
Changes in AppealsOutline: Appeals Judicial Approach and Culture
Update from Tax CourtUnited States Tax Court Update

Real Estate

FATCA Compliance and Real Estate TransactionsSlides: FATCA and Real Estate
Issues Unique to Single Family REITsSlides: Federal Tax Issues Unique to Single Family Rental REITs
Net Investment Income Tax and Its Specific Impact on Real EstateOutline: Net Investment Income Tax
Net Investment Income Tax and Its Specific Impact on Real EstateSlides: Net Investment Income Tax and Its Specific Impact on Real Estate
Three Decades Later, Same IssuesSlides: The Terms They Are A-Changin

S Corporations

Application of Non-Subchapter S Provisions to S CorporationsOutline: Application of Non-Subchapter S Provisions to S Corporations
Current DevelopmentsMaterials: Important Developments in the Federal Income Taxation of S Corporations
The Proposed Regulations Regarding Section 1411’s Tax on Net Investment Income – Part IABA Section of Taxation Comments Concerning Proposed Treasury Regulations under Section 1411
The Proposed Regulations Regarding Section 1411’s Tax on Net Investment Income – Part ISlides: The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations

Sales, Exchanges & Basis

Current Developments in Sales, Exchanges and BasisPaper: Current Non-Section 1031 Developments
Current Developments in Sales, Exchanges and BasisPaper: IRC § 1031/§ 1033 Current Developments
Front Page News: Tax Reform and Section 1031Materials: Front Page News: Tax Reform and Section 1031
Hot Topics in Section 1031: Art Exchanges & Constructive Receipt IssuesMaterials: Actual and Constructive Receipt Issues in a Deferred Exchange
Separating Building from Land for Tax PurposesSeparating Building from Land for Tax Purposes
Slogging Through Section 1(h): A Guide for the PerplexedPaper: Slogging Through Section 1(H): A Guide For The Perplexed

SECTION PROGRAM

Criminal Employment TaxSlides: Criminal Enforcement of Employment Taxes
NAIC Annual Statements for LawyersSlides: NAIC Annual Statements for Lawyers
State and Local Tax Concerns for Closely-Held BusinessesSlides: State and Local Tax Concerns for Closely-Held Businesses

Standards of Tax Practice

Ethical Issues in Federal Tax Practice – The Government PerspectiveAppendix of Materials Referenced
Ethical Issues in Federal Tax Practice – The Government PerspectiveSlides: Ethical Issues in Federal Tax Practice - The Government Perspective
Ethical Violations and Injunctive Actions Against PractitionersOutline: Ethical Violations and Injunctive Actions Against Practitioners
Ethics in the Electronic AgeSlides: Ethical Issues in E-Discovery

State & Local Taxes

Because I Said So: Forced Combination, Alternative Apportionment and Taxpayer Transparency Concerns"Because I Said So… The Increased Use of Alternative Apportionment Methods and the Need for Transparency "
Current Developments: Series LLCs and Task Force ReportABA Section of Taxation Comments on Proposed Series LLCs Regulations
Current Developments: Series LLCs and Task Force ReportSummary of Series LLC Task Force Report
Deciding How to Decide – Rules of Statutory Construction, Presumptions and Burdens of ProofOutline
Sales of Other Than Tangible Personal Property: The Pros and Cons of Market-Based SourcingSlides: Sales of Other Than Tangible Personal Property: The Pros and Cons of Market-Based Sourcing
Sales/Use Tax Issues in Emerging PaymentsSlides: Sales and Use Tax Issues in Emerging Payments

Tax Accounting

Current DevelopmentsPanel Materials
Tax Accounting for Litigation ExpensesOutline: The Tax Accounting Treatment of Legal Fees, including Legal Defense and Related Costs
Tax Accounting Issues for Foreign Pension Plans (section 404A)Panel Slides
Tax Accounting Issues in Oil and GasPanel Outline

Tax Bridge to Practice

Nuts & Bolts Series: Nuts and Bolts of the Affordable Care Act – Employee Benefits and Tax Aspect.Slides: Nuts and Bolts of the Affordable Care Act: Employee Benefits and Tax Aspects
Nuts & Bolts Series: The Nuts & Bolts of Deficiency Cases – From Examination to the Tax CourtJudge Vasquez- Notice and Order
Nuts & Bolts Series: The Nuts & Bolts of Deficiency Cases – From Examination to the Tax CourtThe Examination and Administrative Appeals Process
Nuts & Bolts Series: The Nuts & Bolts of Deficiency Cases – From Examination to the Tax CourtThe Nuts And Bolts Of Deficiency Cases: From Examination To The Tax Court
Nuts & Bolts Series: The Nuts & Bolts of the Taxation of S CorporationsSlides: Introduction to Taxation of S Corporations

Tax Exempt Financing

Recent Developments in IRS Enforcement and the Voluntary Closing Agreement Program for Tax-Exempt BondsOutline of Issues Pertaining to Panel on Recent Developments in Internal Revenue Service Enforcement and the Voluntary Closing Agreement Program for Tax-Exempt Bonds
The Latest News on Legislation, Regulations and Other Guidance for Tax-Exempt BondsPanel Outline and Materials
What a Section 103 Tax Lawyer Should Know About the SEC.Panel Outline and Materials

Tax Policy & Simplification

Government Perspectives on Tax ReformPanel Materials
What are the Constitutional Parameters of Tax Reform and Simplification?Erik M. Jensen, Post-NFIB: Does the Taxing Clause Give Congress Unlimited Power?, 136 Tax Notes 1309 (2012).
What are the Constitutional Parameters of Tax Reform and Simplification?Jasper L. Cummings, 222 Years of the Supreme Court, The Constitution, and Federal Tax, 135 Tax Notes 1511 (2011).
What are the Constitutional Parameters of Tax Reform and Simplification?Joseph J. Thorndike, Why Repealing the 16th Amendment Probably Wouldn't Matter, 136 Tax Notes 1369 (2012).
What are the Constitutional Parameters of Tax Reform and Simplification?Slides: Constitutional Parameters of Tax Reform
What are the Constitutional Parameters of Tax Reform and Simplification?Stephen Mazza & Tracy Kaye, Constitutional and Administrative Law: Restricting the Legislative Power to Tax in the United States, 54 Am. J. Comp. L. 641 (2006)

Tax Practice Management

Working with CPAs and CFPs: Necessary or Helpful, Advantages and ConcernsAdditional Links
Working with CPAs and CFPs: Necessary or Helpful, Advantages and ConcernsOutline: United States v. Kovel

Teaching Taxation

The Future of Corporate Tax Reform: A DebateArticle: CORPORATE SHAMS
The Future of Corporate Tax Reform: A DebateArticle: Meaningless Comparisons: Corporate Tax Reform Discourse In the United States
The Future of Corporate Tax Reform: A DebateThe Future of Corporate Tax Reform: A Debate

Transfer Pricing

APMA: Past, Present and FutureSlides: APMA: Past, Present and Future
Transfer Pricing Elements of OECD BEPS ReportSlides: Base Erosion and Profit Shifting

US Activities of Foreigners and Tax Treaties

Coping with FATCA if You’re Not a Foreign Financial InstitutionSlides: Coping with FATCA if You’re Not a Foreign Financial Institution
Howdy, Partner! US Tax Law Treatment of Foreign PartnersSlides: Howdy Partner! U.S. Tax Law Treatment of Foreign Partners

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