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.
| 2012 Midyear Meeting - San Diego, CA | |||
| Committee Name | Panel Title | Material Title | Notes |
| Administrative Practice | Important Developments | Selected Recent Developments in Administrative Practice | paper by Bryon Christensen |
| Administrative Practice | Money Ball: Inside the IRS' Global High Wealth Industry Group. | Form 13744 – Examiner's Risk Analysis Worksheet | supplemental panel materials |
| Administrative Practice | Money Ball: Inside the IRS' Global High Wealth Industry Group. | Form 4564 – Information Document Request (IDR) – Attachment Mandatory Tax Shelter IDR | supplemental panel materials |
| Administrative Practice | Money Ball: Inside the IRS' Global High Wealth Industry Group. | Form 4764 – LB&I Examination Plan | supplemental panel materials |
| Administrative Practice | Money Ball: Inside the IRS' Global High Wealth Industry Group. | Supplemental panel slides | supplemental panel materials |
| Administrative Practice | Money Ball: Inside the IRS' Global High Wealth Industry Group. | MONEYBALL: Inside IRS’s GHW Group | slides submitted by Phil Pillar |
| Administrative Practice | The Adminstraive Procedure Act and Tax Administration: How Does it Apply? What is the Debate? What do Tax Professionals Need to Know? | Tax and the Administrative Procedure Act, 5 U.S.C. §§ 551-559, 701-706 | slides by Kevin R. Stults, Judge James Halpern, Kristin E. Hickman, Gilbert S. Rothenberg and Patrick J. Smith |
| Administrative Practice | The Techncial (or “Terrible?”) Advice Process: Using "TAM" as an Effective Issue Resolution Tool | Excerpts from Revenue Procedure 2012-1 | supplemental panel materials |
| Administrative Practice | The Techncial (or “Terrible?”) Advice Process: Using "TAM" as an Effective Issue Resolution Tool | The Terrible Exam Advice Process: Using the "TAM" as an Effective Issue Resolution Tool | slides by Daniel J. Wiles, Sara Coe, Gerald Kafka, Laurel Robinson, Beth Williams and Curt Wilson |
| Affiliated and Related Corporations | Application of Section 382 to Consolidated Groups | Application of Section 382 to Consolidated Groups | slides by Theresa Abell, Bryan P. Collins, Marc Countryman and Jeffrey Vogel |
| Banking & Savings Institutions | Distressed Debt Tax Issues from the Perspective of Banks | Distressed Debt Issues Affecting Banks | slides by David Garlock, Fran Mordi and Mark Price |
| Banking & Savings Institutions | Foreign Tax Credit Generators, Economic Substance and the Future | Foreign Tax Credit Generators, Economic Substance and the Future | slides submitted by Stow Lovejoy |
| Banking & Savings Institutions | Hot Topics in Taxation of Banking… | Hot Topics in Banking Taxation | slides by Clay Littlefield, Francisca N. Mordi, Louis J. Garday and Scott Brown |
| Bankruptcy and Workouts | Acquisition of Troubled Corporations | Acquisition of Troubled Corporations | slides by Dana Lasley, Suresh Advani and Don Leatherman |
| Bankruptcy and Workouts | New Developments 2011 | Bankruptcy and Workouts | paper by Kenneth C. Weil |
| Bankruptcy and Workouts | New Developments 2011 | Business Bankruptcy & Workouts – Annual Update | slides by Lee Zimet |
| Bankruptcy and Workouts | New Developments 2011 | Bankruptcy and Workouts Developments Report 2011 | slides by Kenneth C. Weil |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit D - DOJ Tax Division Settlement Reference Manual | supplemental presentation materials |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit E - Rules 330 – 334 | supplemental presentation materials |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit F - Complaint to Determine Dischargeability | supplemental presentation materials |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit G - 11 U.S.C. § 505(a) | supplemental presentation materials |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit I - Petition for Lien Action | supplemental presentation materials |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit K - CDP – Decisions – Frances D. Sheehy | supplemental presentation materials |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Survey of 2011 CDP Cases | paper by Frances D. Sheehy |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | A Panel Discussion: Bankruptcy Courts – Tax Litigation, A Comparison – Tax Court Litigation | slides by Wm. Robert Pope, Jr. |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit J - Motion to Dismiss 11 U.S.C. § 523 Action for Lack of Jurisdiction | supplemental presentation materials |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit B - K. Weil, Tax Liabilities and Bankruptcy | supplemental presentation materials |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit H - Complaint to Determine Liability | supplemental presentation materials |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit A-The IRS Collection Process And The Bankruptcy Alternative | supplemental presentation materials |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Survey of Dischargeability - Recent Cases - 2011 | paper by Frances D. Sheehy |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Survey of Dischargeability - Recent Cases - 2010 | paper by Frances D. Sheehy |
| Bankruptcy and Workouts | Tax Court or Bankruptcy Court - What, Where, How and Why. | Exhibit C - Automatic Stay | supplemental presentation materials |
| Capital Recovery & Leasing | Current Developments | Current Developments | paper by Jane Rohrs, Colleen O’Connor and Sam Weiler |
| Capital Recovery & Leasing | Current Issues and Topics in Depreciation Methods and Classifications | Current Issues and Topics in Depreciation Methods and Classifications | paper by Thomas C. Yeates III, Kathleen Reed, Scott Dinwiddie, Susan Grais and Alison Jones |
| Capital Recovery & Leasing | Deduction for Qualified Film and Television Production Expenditures | Deduction for Qualified Film and Television Production Expenditures: Final and Temporary Regulations under Section 181 | paper by Christopher J. Ohmes and Katharine Abdoo |
| Civil and Criminal Tax Penalties | Integrity of Domestic and Offshore Accounts: The United States Perspective | Integrity of Domestic and Offshore Accounts: The United States Perspective | slides by Ian M. Comisky, Rebecca A. Sparkman, Robert S. Fink, Miriam L. Fisher and Steven R. Toscher |
| Civil and Criminal Tax Penalties | Reports of Subcommittees on Important Developments | Important Developments— Criminal | paper by Michel Stein, Cory Stigile and Lacey Strachan |
| Civil and Criminal Tax Penalties | Reports of Subcommittees on Important Developments | Renewed Pursuit of Tax Avoidance and Evasion | slides prepared by Alan Granwell and Bruce Zagaris |
| Civil and Criminal Tax Penalties | Reports of Subcommittees on Important Developments | Subcommittee Report: Legislative & Administrative Developments | paper by John Colvin |
| Civil and Criminal Tax Penalties | Reports of Subcommittees on Important Developments | Important Developments on Civil Penalties: October, 2011 through January, 2012 | paper by Shane A. Lord |
| Civil and Criminal Tax Penalties | Sentencing – How to Make the Best of a Bad Situation | Sentencing – How to Make the Best of a Bad Situation | slides by Herbert J. Hoelter |
| Civil and Criminal Tax Penalties | Should You Blow Your Whistle? | Should You Blow Your Whistle? | panel materials by Erika A. Kelton, Steven A. Whitlock and Bryan C. Skarlatos |
| Closely Held Businesses | Estate Planning Gone Awry: What Happens When Things Don't Work Out the Way We Planned? | Estate Planning Gone Awry: What Happens When Things Don''t Work Out the Way We Planned? | paper by Eric L. Green, Alfred Casella and Shelby Wilson |
| Closely Held Businesses | Impact of New Health Care Law on Closely Held Businesses | Impact of the New Health Care Bills On Closely-Held Business | slides by paper by Thomas J. Nichols |
| Closely Held Businesses | Impact of New Health Care Law on Closely Held Businesses | Health Reform In A Nutshell: What Employers Need To Know | paper by Alson R. Martin |
| Closely Held Businesses | Impact of New Health Care Law on Closely Held Businesses | Impact of the New Health Care Bills On Closely-Held Business | paper by paper by Thomas J. Nichols |
| Closely Held Businesses | 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 | slides by John J. Pankauski |
| Closely Held Businesses | Reformation of Estate Documents: Why Your Documents Are Alive Even After You’re Dead | They Can Change My Will After I'm Gone? Really? | article by John J. Pankauski |
| Closely Held Businesses | Sales of Personal Goodwill | Current Developments In The Sale Of Personal Goodwill | article by William P. Prescott and Paul D. Rang |
| Closely Held Businesses | Sales of Personal Goodwill | Sale Of A Business Or Practice & Sale Of Personal Goodwill | paper by Alson R. Martin |
| Closely Held Businesses | Sales of Personal Goodwill | Sales of Personal Goodwill: Presentation Handout | by William P. Prescott |
| Closely Held Businesses | Update on Health Care Reform | Small Business Health Care Tax Credit and Reporting of Employer-Sponsored Health Care Coverage on Form W-2 | slides submitted by Robin M. Tuczak |
| Corporate Tax | North-South Transactions, Section 355 and Other Step Transaction Issues | North-South Transactions, Section 355 and Other Step Transaction Issues | slides by Joseph M. Pari, Michael Schler, Mark J. Silverman, Karen Gilbreath Sowell, and Thomas F. Wessel |
| Court Procedure and Practice | E-Litigation: Leveraging Technology Throughout Your Case | E-Litigation: Leveraging Technology Throughout Your Case | paper by Christopher Egan |
| Court Procedure and Practice | Important Developments | Important Developments | paper by Rachel L. Partain |
| Court Procedure and Practice | Important Developments | Tax Section Court Procedure Committee, Office of Chief Counsel Internal Revenue Service FY 2011 | slides submitted by Deborah Butler |
| Court Procedure and Practice | Litigating R&D Cases | Litigating R&D Cases: Insights, Strategies, and Traps for the Unwary | slides by Alex Sadler, Jeremy Fingeret, Roger Kave, Jeff Moeller and Mary Monahan |
| Court Procedure and Practice | Parallel Civil Tax Litigation and Criminal Investigations | Parallel Civil Tax Litigation and Criminal Investigations | slides submitted by Mark Allison |
| Court Procedure and Practice | Court Procedure Issues In CDP Judicial Review | The Tax Court's Review of the IRS's Determinations in CDP Cases | slides by Peter J. Panuthos, Susan T. Mosley, Juan F. Vasquez and Zhanna A. Ziering |
| 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 | supplemental panel materials |
| Employee Benefits | DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and EFAST2 and Audit Reporting Issues | DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and EFAST2 and Audit Reporting Issues | paper by Ronald J. Triche |
| Employee Benefits | DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and EFAST2 and Audit Reporting Issues | DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and EFAST2 and Audit Reporting Issues | supplemental panel materials |
| Employee Benefits | 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 | supplemental panel materials |
| Employee Benefits | DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and EFAST2 and Audit Reporting Issues | DOL – Changes in Final Rule – 408(b)(2) | supplemental panel materials |
| Employee Benefits | DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and EFAST2 and Audit Reporting Issues | DOL News Release – 408(b)(2) Final Rule | slides by Ronald J. Triche |
| Employee Benefits | DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and EFAST2 and Audit Reporting Issues | DOL Disclosure and Reporting Update: Participant and Plan-level Fee Disclosures and Presentation: A Discussion of the DOL’s New Fee Disclosure Regulations | article by Chad DeGroot |
| Employee Benefits | Hot Topics | IRS Provides Guidance on W-2 Reporting re: Value of Health Care Coverage | paper by Puneet Arora |
| Employee Benefits | Hot Topics | IRS Provides Guidance on Key Dates for Hybrid Plans | slides by Henry Talavera |
| Employee Benefits | Plan Drafting and Administrative Issues After Amara | Plan Drafting and Administrative Issues After Amara: Retirement Plan Issues | slides by J. Randal Wexler and Thomas G. Moukawsher |
| Employee Benefits | Plan Drafting and Administrative Issues After Amara | CIGNA v. Amara: Litigation Perspectives | slides by Mark C. Jones |
| Employee Benefits | Practical Considerations in Providing Benefits and Equity Compensation to a Global Workforce | Providing Equity Compensation to a Global Workforce | slides by Todd A. Solomon |
| Employee Benefits | Practical Considerations in Providing Benefits and Equity Compensation to a Global Workforce | Key Learnings from Global Employee Benefits Review | paper by Laura G. Thatcher |
| Employee Benefits | Proxy Disclosure 2012: Same as Last Year or New Year, New Challenges? | Proxy Disclosure 2012: Same as Last Year or New Year, New Challenges? | article |
| Employee Benefits | Proxy Disclosure 2012: Same as Last Year or New Year, New Challenges? | ISS Issues 2012 Policy Updates | memo by Amy Blackman |
| Employee Benefits | Proxy Disclosure 2012: Same as Last Year or New Year, New Challenges? | Practical Strategies for Preparing This Year’s CD&A and Compensation Tables | article |
| Employee Benefits | Proxy Disclosure 2012: Same as Last Year or New Year, New Challenges? | 10 Tips for Enhancing Your 2012 Executive Compensation Disclosure | paper submitted by Peter J. Hunt |
| Employee Benefits | Worker Classification Issues Under Renewed Focus | Controlled Groups and Employee Status Update | slides by Robert Miller, Peter Hunt, Daniel Morgan and Daniel Janich |
| Employee Benefits | Worker Classification Issues Under Renewed Focus | Worker Classification Issues Under Renewed Focus | paper by Harold J. Ashner |
| Employee Benefits Subcommittee on Defined Benefit Plans | Employee Benefits Defined Benefit Plans Update | Recent PBGC Regulatory Developments: (January 1, 2010, to January 31, 2012) | paper by James Eggeman |
| Employee Benefits Subcommittee on Defined Benefit Plans | Employee Benefits Defined Benefit Plans Update | A Window into PBGC's Practice: Current Issues and Trends | paper by Puneet Arora |
| Employee Benefits Subcommittee on Distributions | Employee Benefits Distributions Update | Supplemental Panel Materials | article by Stuart Sirkin |
| Employee Benefits Subcommittee on Distributions | Employee Benefits Distributions Update | PPA New Benefit Restrictions in Light of Recent Regulations | article by By Kathryn J. Kennedy |
| Employee Benefits Subcommittee on Fiduciary Responsibility/Plan Investments | Fiduciary Regulation Update | Fiduciary Responsibility Update | panel materials |
| Employee Benefits Subcommittee on Foreign and International Issues | Employee Benefits International Update | Clawbacks of Equity Compensation Outside the United States | slides by David W. Ellis |
| Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices | Employee Benefits Administrative Practices Update | EP Determinations Quality Assurance Bulletin | panel materials submitted by Lisa Tavares |
| Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices | Employee Benefits Administrative Practices Update | Announcement 2011-82 | panel materials submitted by Lisa Tavares |
| Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices | Employee Benefits Administrative Practices Update | Announcement 2012-3 | panel materials submitted by Lisa Tavares |
| Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices | Employee Benefits Administrative Practices Update | Sample Plan Amendment for Section 436: Notice 2011-96 | panel materials submitted by Lisa Tavares |
| Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices | Employee Benefits Administrative Practices Update | 2011 Cumulative List of Changes in Plan Qualification Requirements | panel materials submitted by Lisa Tavares |
| Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices | Employee Benefits Administrative Practices Update | Administrative Practices Update | paper submitted by Lisa Tavares |
| Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices | Employee Benefits Administrative Practices Update | Qualified Plan Law Changes and Deadlines - Post GUST | supplemental panel materials |
| Employee Benefits Subcommittee on Subcommittees on Fiduciary Responsibility/Plan Investments, Litigation, and ESOPs | Employee Benefits Fiduciary and Litigation Update | Panel Materials | panel materials |
| Employee Benefits Subcommittee on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans | Employee Benefits Welfare Benefits Design, Funding and Regulation Update | New Guidance Issued for Reporting the Cost of Health Coverage on Forms W-2 | paper by Mark L. Stember |
| Employee Benefits Subcommittee on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans | Employee Benefits Welfare Benefits Design, Funding and Regulation Update | IRS Updates Its Guidance on Form W-2 Reporting of Employer-Sponsored Health Coverage | article by Brian C. Gilmore |
| Employee Benefits Subcommittee on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans | Employee Benefits Welfare Benefits Design, Funding and Regulation Update | Revisiting the Medical Loss Ratio | paper by Linda R. Mendel |
| Employee Benefits Subcommittee on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans | Employee Benefits Welfare Benefits Design, Funding and Regulation Update | Comments RE: Essential Health Benefits Bulletin | panel materials submitted by Mark L. Stember |
| Employee Benefits Subcommittee on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans | Employee Benefits Welfare Benefits Design, Funding and Regulation Update | Impact of Federal Health Care Reform on Employers With Contingent Workers | article by Alden J. Bianchi |
| Employee Benefits Subcommittee on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans | Employee Benefits Welfare Benefits Design, Funding and Regulation Update | American Health Insurance Exchanges Under the PPACA - An Overview and Primer | article by Alden J. Bianchi |
| Employee Benefits Subcommittee on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans | Employee Benefits Welfare Benefits Design, Funding and Regulation Update | HHS Bulletin Outlining Essential Health Benefis Grants Significant Flexibility to States | article by Alden J. Bianchi and Gary E. Bacher |
| Employment Taxes | California Employment Taxes and the Employment Development Department | Employment Development Department Information Sheet | panel materials |
| Employment Taxes | California Employment Taxes and the Employment Development Department | Employment Development Department Information Sheet | panel materials |
| Employment Taxes | Employment Tax Issues Relating to Health Care | Affordable Care Act W-2 Aggregate Cost Reporting Compliance | slides by GJ Stillson MacDonnell |
| Employment Taxes | Federal Update | Federal Update Panel Presentation | slides submitted by Megan E. Marlin |
| Energy and Environmental Taxes | Hot Tax Topics for Utilities | Hot Tax Topics for Utilities | slides by Todd Reinstein, Benjamin Haas and Courtney Sandifer |
| Energy and Environmental Taxes | New Excise Tax on Medical Devices | Dear Treasury: Medical Device Industry Submits Comments on New Excise Tax | article by Taylor Cortright, Deborah Gordon and Ruth Hoffman |
| Energy and Environmental Taxes | New Excise Tax on Medical Devices | New Excise Tax on Medical Devices | article by Deborah Karet and Ruth Hoffman |
| Energy and Environmental Taxes | New Excise Tax on Medical Devices | New Excise Tax on Medical Devices | slides by Deborah Gordon, Stephanie Bland and Taylor Cortright |
| Estate & Gift Taxes | Current Developments | Current Developments in Estate Planning | paper by George D. Karibjanian & Hannah W. Mensch |
| Estate & Gift Taxes | Estate and Income Tax Planning for the Passage of Family Homes | Estate and Income Tax Planning for the Passage of Family Homes Using QPRTs, Split Interest Purchases, Family LLCs, Dynasty Trusts, and Other Strategies (Including a Discussion of Non-Tax Considerations) | paper by Nancy G. Henderson |
| Estate & Gift Taxes | Mending Wayward Wealth Transfer Strategies (With the Help of a $5,000,000 Exclusion Amount) | Mending Wealth Transfer Strategies (With Help from $5,120,000 Exemptions) | paper by Benjamin G. Carter |
| Estate & Gift Taxes | Portability - Plethora of Problems, Pitfalls and Planning Possibilities | Portability - Plethora of Problems, Pitfalls and Planning Possibilities | paper by Lester B. Law and George D. Karibjanian |
| Exempt Organizations | Another Election Year: Recent Developments in Political Advocacy | Selected FEC Regulations | paper by Beth Kingsley and Rosemary Fei |
| Exempt Organizations | Hybrid Entities: Do They Really Have a Place in the Charitable Investment World? | Hybrid Entities: Do They Really Have a Place in the Charitable Investment World? | paper by Will Fitzpatrick, Celia Roady and Robert A. Wexler |
| Exempt Organizations | Practical Problems and Practical Solutions for Donor Advised Funds | Practical Problems and Practical Solutions for Donor Advised Funds | paper by Edward Chaney, Jennifer Franklin, Kelly Shipp Simone and Emily Lam |
| Exempt Organizations | The Future of the Charitable Deduction | Coming Limitations on the Charitable Deduction | slides by Reynolds Cafferata |
| Exempt Organizations | The Future of the Charitable Deduction | Future of the Charitable Deduction: How. Not if. It will be Limited | paper by Reynolds Cafferata |
| Exempt Organizations | VAT and the Tax-Exempt Sector: Unique U.S. Tax Issues | VAT Exemptions: Principles and Practice | article by By Walter Hellerstein and Harley Duncan |
| Exempt Organizations | VAT and the Tax-Exempt Sector: Unique U.S. Tax Issues | VAT and the Tax-Exempt Sector: What are the Issues? | slides submitted by Harley Duncan |
| Exempt Organizations | VAT and the Tax-Exempt Sector: Unique U.S. Tax Issues | VAT and the Tax-Exempt Sector: Unique U.S. Issues | article by By Harley Duncan and Walter Hellerstein |
| Fiduciary Income Tax | Anatomy of a Form 1041, Fiduciary Income Tax Return | Anatomy of a Form 1041, Fiduciary Income Tax Return | paper by W. Aaron Hawthorne and Joshua Husbands |
| Fiduciary Income Tax | Ethical Issues for Trust and Estate Practitioners | Final Circular 230 Regulations Create Registered Tax Return Preparer Category | supplemental panel materials |
| Fiduciary Income Tax | Ethical Issues for Trust and Estate Practitioners | Notice 2011-6 | supplemental panel materials |
| Fiduciary Income Tax | Ethical Issues for Trust and Estate Practitioners | Treasury Department Circular No. 230 | supplemental panel materials |
| Fiduciary Income Tax | Ethical Issues for Trust and Estate Practitioners | Ethical Issues for Trust and Estate Practitioners: An Overview of Circular 230 with Recent Updates | paper by Louis A. Mezzullo and David A. Berek |
| Fiduciary Income Tax | Making Retirement Benefits Payable to Trusts | The IRA Beneficiary Designation Form: How to complete it properly | paper By Salvatore J. LaMendola |
| Fiduciary Income Tax | Making Retirement Benefits Payable to Trusts | 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 | paper by Edwin P. Morrow III |
| Fiduciary Income Tax | Recent Developments | Recent Developments in Fiduciary Income Tax | paper by Rachel D. Burke |
| Financial Transactions | Contingent Swaps and the New Regime | Contingent Swaps and the New Regime | slides by David C. Garlock and Rebecca E. Lee |
| Financial Transactions | Section 871(m): New Guidance on Cross-Border Equity Swaps | Section 871(m): New Guidance on Cross-Border Equity Swaps | slides by Rachel Kleinberg, Rebecca Lee, D. Peter Merkel and Karl Walli |
| Financial Transactions | Short Derivatives: Getting Topsy Turvy | Short Derivatives: Selected Issues | slides by Eileen Marshall, Michael Novey and Robert Scarborough |
| Foreign Activities of US Taxpayers | Foreign Tax Credits | Foreign Activities of US Taxpayers: Foreign Tax Credits | slides by Ginny Chung, Anne Devereaux, Mark Hoose, Natan Leyva and Martin Collins |
| Foreign Lawyers Forum | Renewed Pursuit of Tax Avoidance and Evasion | Renewed Pursuit of Tax Avoidance and Evasion | slides prepared by Alan Granwell and Bruce Zagaris |
| Foreign Lawyers Forum | Special Taxes on Financial Institutions and Transactions | Special Taxes on Financial Institutions and Transactions The Netherlands | slides by Lodewijk Berger |
| Foreign Lawyers Forum | Special Taxes on Financial Institutions and Transactions | Special Taxes on Financial Institutions and Transactions | slides by Steve Rosenthal |
| Foreign Lawyers Forum | Special Taxes on Financial Institutions and Transactions | Bank Levies in the UK, France and Germany: A Comparison of the New Levies on Banks | panel presentation |
| Foreign Lawyers Forum | Special Taxes on Financial Institutions and Transactions | Special Taxes on Financial Institutions and Transactions | slides by Michel Collet |
| 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 | paper by Wendy S. Pearson |
| Indian Tribal Tax Committee | Federal Taxation of Tribes and Their Members – Fundamental Issues and Hot Topics | Federal Taxation of Tribes and their Members: Fundamental Issues and Hot Topics | paper by Kathleen M. Nilles |
| Indian Tribal Tax Committee | What Tax Lawyers Need to Know About Federal Indian Law | Introduction To Federal Indian Law | paper prepared by C. Joseph Lennihan |
| Individual and Family Taxation | Am I Really An Independent Contractor? | Present Law and Background Relating to Worker Classification For Federal Tax Purposes | prepared by the Staff of the Joint Committee on Taxation |
| Individual and Family Taxation | Am I Really An Independent Contractor? | Form 8952, Instructions and FAQs on Voluntary Compliance Settlement Program | supplemental panel materials |
| Individual and Family Taxation | Am I Really An Independent Contractor? | Incorporating Independent Contractors is no Panacea for Misclassification | by William Hays Weissman |
| Individual and Family Taxation | Am I Really An Independent Contractor? | Section 530: Its History And Application In Light of the Federal Definition of the Employer-Employee Relationship For Federal Tax Purposes, NATRPM | by William Hays Weissman |
| Individual and Family Taxation | Highlights from the National Taxpayer Advocate 2011 Annual Report to Congress | National Taxpayer Advocate 2011 Annual Report to Congress | paper by Nina Olson |
| Insurance Companies | DOMA vs. the States, with Tax Rules in the Middle | DOMA vs. the States: With Tax Rules in the Middle | slides by Alison R. Peak and Patricia A. Cain |
| Insurance Companies | DOMA vs. the States, with Tax Rules in the Middle | Panel Materials: IRS Letter | supplemental panel materials |
| Insurance Companies | DOMA vs. the States, with Tax Rules in the Middle | Status Recognition Chart for Same Sex Couples | supplemental panel materials prepared by Patricia A. Cain |
| Insurance Companies | Health Care Reform – Tax and Fee Implementation Issues Affecting the Insurance Industry and the Scope of “Health Insurance.” | Health Care Reform – Tax and Fee Implementation Issues Affecting the Insurance Industry and the Scope of “Health Insurance.” | slides by Craig Springfield and Allison Ullman |
| Insurance Companies | Transfer Pricing and Insurance | Transfer Pricing in the Insurance Industry | slides by Frank Douglass, Julia Sceats and Mark S. Smith |
| Insurance Companies | Update on Recent Tax Developments and Projects on the IRS Priority Guidance Plan | Supplemental Panel Materials | submitted by Jean Baxley |
| Insurance Companies | Update on Recent Tax Developments and Projects on the IRS Priority Guidance Plan | Update on Recent Insurance Tax Developments | slides by Jean Baxley and Lori Robbins |
| Investment Management | RICs and PFICs – A Couple That Still Can’t Get Along | PFICs, RICs and 1296 | slides by Paul Murphy |
| Investment Management | RICs and PFICs – A Couple That Still Can’t Get Along | Passive Foreign Investment Companies--still a challenge after all these years | slides by Deanna Flores |
| 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 | Section 409A Issues in Mergers and Acquisitions | slides by Jeremy L. Goldstein |
| Joint: FAUST, FLF, Transfer Pricing & USAFTT | Joint International Developments Panel | Joint Current International Developments Panel FAUST, USAFFT, FLF, and Transfer Pricing | slides by John Merrick, Mark Plowgian, Janine Burman, Len Schneidman, Lewis Greenwald, Michal McGowan and John Woodruff |
| Low Income Taxpayers | Dealing with Tax Issues Following a Disaster | FEMA Debt Collection | paper by Mark Moreau |
| Low Income Taxpayers | Innocent Spouse - We Won But Where Are We Now? | Innocent Spouse - We Won But Where Are We Now? | paper by Prof. Carlton M. Smith |
| Low Income Taxpayers | Introductory remarks and administrative issues | Dealing with Tax Issues Following a Disaster | paper submitted by Keith Fogg |
| Low Income Taxpayers | National Taxpayer Advocate’s Annual Report to Congress | Report from the National Taxpayer Advocate on her 2011 Annual Report to Congress | paper by Nina Olson |
| Partnerships and LLCs | Applying Section 118 to Partnerships—Isn't It About Time? | Applying Section 118 to Partnerships—Isn't It About Time? | slides by Todd D. Golub,Patricia Ann Metzer and Eliot L. Kaplan |
| Partnerships and LLCs | Applying Section 118 to Partnerships—Isn't It About Time? | Applying Section 118 to Partnerships—Isn't It About Time? | paper by Eliot L. Kaplan |
| Partnerships and LLCs | Applying Section 118 to Partnerships—Isn't It About Time? | Contributions to Capital | slides by Patricia Ann Metzer |
| Partnerships and LLCs | Hola, Ni Hao, Shalom—Say Hello To Your Foreign Partner | Hola, Ni Hao, Shalom—Say Hello To Your Foreign Partner | slides by Alan I. Appel, Joseph M. Calianno, Noel P. Brock and Julie M. Marion |
| Partnerships and LLCs | Hot Topics | Partnership Hot Topics | slides by Jeanne Sullivan |
| Partnerships and LLCs | The Do's and Don’t's of Structuring Leveraged Partnerships | Partnership Disguised Sales of Property: G-I Holdings Misses the Mark | paper by Blake D. Rubin, Andrea MacintoshWhiteway and Jon G. Finkelstein |
| Partnerships and LLCs | The Do's and Don’t's of Structuring Leveraged Partnerships | The Do's and Don’t's of Structuring Leveraged Partnerships | slides by Andrea MacintoshWhiteway, Patricia W. McDonald and Dawn M. Duncan |
| Partnerships and LLCs | The Do's and Don’t's of Structuring Leveraged Partnerships | Tax Court Goes Overboard in Canal | paper by Blake D. Rubin, Andrea MacintoshWhiteway and Jon G. Finkelstein |
| 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 | article by Bruce Kayle |
| Pro Bono | Pro Bono Matters: WHY? Ethical and Economic Reflections on ABA Model Rule 6.1 “Voluntary Pro Bono Publico Service.” | Pro Bono Is Every Lawyer’s Professional Responsibility | paper submitted by Francine J. Lipman |
| Real Estate | Installment Sales: Interesting and Unresolved Issues. | Installment Sales: Interesting and Unresolved Issues | slides by Jill E. Darrow and Adam Handle |
| Real Estate | Minimizing Gain/Maximizing Loss: May I Cherry Pick Property? | Bifurcating or Fragmenting a Sale or Exchange – The Art of Cherry Picking | slides submitted by Mike Frankel, Terry Cuff and Lou Weller |
| Real Estate | Real Estate Funds: A Potpourri of Issues that Vex the Practical Practitioner | Real Estate Funds: A Potpourri of Issues that Vex the Practical Practitioner | paper by Darryl Steinhause, Thomas S. Wisialowskiand Pardis Zomorodi |
| Real Estate | What is Real Property and Why Do I Care? | Real Property – Why do we care and what does it mean? | slides by David Miller, Gino Bianchini and Jim Lokey |
| S Corporations | Current Developments | Important Developments in the Federal Income Taxation of S Corporations | paper by Dana Lasley and William Klein |
| S Corporations | Medicare Taxes and S Corporations | Medicare Taxes and S Corporations (and Other Pass-Through Entities) | slides submitted by C. Wells Hall III |
| S Corporations | Medicare Taxes and S Corporations | Medicare Taxes and S Corporations (and Other Pass-Through Entities) | paper submitted by C. Wells Hall III |
| S Corporations | Medicare Taxes and S Corporations | Impact of the New Health Care Bills On Closely-Held Business | paper by paper by Thomas J. Nichols |
| S Corporations | Medicare Taxes and S Corporations | Impact of the New Health Care Bills On Closely-Held Business | slides by paper by Thomas J. Nichols |
| S Corporations | QSubs: The Basics and Beyond | QSubs: The Basics and Beyond | paper by John B. Truskowski, Don S. Kovacic and Tim Glasgow |
| S Corporations | QSubs: The Basics and Beyond | QSub and Disregarded Entity Taxation - Multistate and California | paper by Don S. Kovacic |
| Sales, Exchanges and Basis | Build-to-Suit or Full-of-Boot: Analyzing Exchanges Involving Leasehold Improvements Constructed by a QI or EAT | Build-to-Suit or Full-of-Boot: Analyzing Exchanges Involving Leasehold Improvements Constructed by a QI, EAT or Other Accommodator | paper by David Shechtman and Bradley T. Borden |
| Sales, Exchanges and Basis | Current Developments in Sales, Exchanges and Basis Other Than Sections 1031 & 1033 | Current Developments in Sales, Exchanges and Basis Other Than Sections 1031 & 1033 | paper by Erik M. Jensen |
| Sales, Exchanges and Basis | Current Developments in Section 1031 and Section 1033 Transactions | Simultaneous U.S. and Canadian Non-recognition Rollovers | slides by Alan S. Lederman, Kelly E. Alton and James A. Hutchinson |
| Sales, Exchanges and Basis | Involuntary Conversions and Qualification of Replacement Property | Rethinking Section 1033: A “Continuity of Investment” Approach | slides by Mark E. Wilensky & Kelly E. Alton |
| Sales, Exchanges and Basis | Involuntary Conversions and Qualification of Replacement Property | Rethinking Section 1033:A "Continuity of Investment" Approach to Replacement Of Involuntarily Converted Trade or Business or Rental Property | paper by Mark E. Wilensky |
| Sales, Exchanges and Basis | Is It Treated as a Sale? Lease, Financing? Constructive Sale? Option? Something Else? – Part I | Is It Treated as a Sale? Lease? Financing? Constructive Sale? Option? | slides by Mark Leeds |
| Section Program: Joint: Real Estate and Partnerships and LLCs | Drafting Real Estate Partnership and LLC Agreements – Part 2 | Drafting Real Estate Partnership and LLC Agreements – Part 2 | panel presentation submitted by Steven R. Schneider |
| Section Program: Joint: Tax Accounting and Capital Recovery and Leasing | Repair Regs Re-Do: Review of the New Guidance Regarding Tangible Property | Repair Regs Re-Do: Mini Program to Review the New Guidance Regarding Tangible Property | panel presentation submitted by Ellen McElroy |
| 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 | The Far-Reaching Impact of FATCA Across Borders and Across Industries | slides by Rochelle L. Hodes, Joan C. Arnold, Susan Seabrook, Danielle Nishida, Rebecca E. Lee, John J. Sweeney and Yoram Keinan |
| Section Program: Teaching Taxation | Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation | Recent Developments in Federal Income Taxation | paper by Martin J. McMahon, Jr., Ira B. Shepard and Daniel L. Simmons |
| Section Program: Teaching Taxation | Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation | Federal Estate, Gift and Generation Skipping Tax Update | paper by Professor Elaine Hightower Gagliardi and Professor James M. Delaney |
| Standards of Tax Practice | Circular 230’s Range of Disciplinary Sanctions: How Bad Can it Get & How is it Determined? | Panel Materials | handouts submitted by Jeremiah Coder |
| Standards of Tax Practice | Ethical Issues in Federal Tax Practice - The Government Perspective | Ethical Issues in Federal Tax Practice | paper submitted by Deborah A. Butler |
| Standards of Tax Practice | Pro Bono Representations: Ethical Issues Specific to the Pro Bono Context | Standards of Tax Practice Committee/Pro Bono Committee Presentation | paper by Diane L. Kroupa, Monica E. Koch and Frank Agostino |
| Standards of Tax Practice | Pro Bono Representations: Ethical Issues Specific to the Pro Bono Context | Pro Bono Representation: Ethical Issues Specific to the Pro Bono Context | slides by Diane L. Kroupa, Monica E. Koch and Frank Agostino |
| State & Local Taxes | Apportionment: Sales Factors Based on Benefit Received | Sales Factors Based on the Benefit Received | slides by Giles Sutton and Robert L. Mahon |
| State & Local Taxes | Apportionment: Sales Factors Based on Benefit Received | Sales Factors Based on the Benefit Received | draft paper by Giles Sutton |
| State & Local Taxes | 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 | paper submitted by Bruce P. Ely, James E. Long, Jr. and J. Leigh Griffith |
| State & Local Taxes | Current Developments: Series LLCs | Current Developments: Series LLCs | slides by Leigh Griffith, Bruce Ely & Jimmy Long |
| State & Local Taxes | Digital Downloads and On-Line Services - Taxing Issues in the Virtual Realm | Digital Downloads and On-Line Services - Taxing Issues in the Virtual Realm | slides by Arthur R. Rosen |
| State & Local Taxes | Remote Sales & Nexus Issues | Panel Slides | slides by Edward J. Bernert, George Isaacson, Bruce Johnson and Kurt A. Lamp |
| 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 | paper by Carol Conjura, John Moriarty, Barbara Young, Alexa Claybon and Annette Ahlers |
| Tax Accounting | Considering the Proper Tax Accounting Treatment of Advance Payments in a Corporate Transaction | Taxable Asset Acquisitions and the Treatment of Advance Payments: Issues and Answers | slides by Carol Conjura, John Moriarty, Barbara Young, Alexa Claybon and Annette Ahlers |
| Tax Accounting | Inventory: Recent Guidance, Anticipated Guidance | Panel Materials | supplemental material submitted by Scott Vance |
| Tax Accounting | Inventory: Recent Guidance, Anticipated Guidance | Inventory: Recent Guidance, Anticipated Guidance | paper submitted by Scott Vance |
| Tax Accounting | Issues Arising in Tax Controversies Involving Tax Accounting Issues | Issues Arising in Tax Controversies Involving Tax Accounting Issues | slides by Rita Cavanagh, Mark Mesler and Stephen F. Gertzman |
| Tax Accounting | Recent Developments in Tax Accounting | Tax Accounting Current Developments February 2012 | Submitted by James Liechty, Scott MacKay, Natalie Tucker, Tracy Watkins and Sam Weiler |
| Tax Exempt Financing | Legislative, Department of Treasury and IRS Update | Legislative, Treasury and Internal Revenue Service Updates | paper by John Swendseid, James Polfer, Perry Israel and Stefano Taverna |
| Tax Exempt Financing | Tax Implications of On-Behalf-Of Financings | Tax Implications of On-Behalf-Of Financings | paper submitted by Nancy M. Lashnits |
| Tax Exempt Financing | VCAP and Other Compliance and Program Management Initiatives | IRM 4.81.6 | supplemental panel materials |
| Tax Exempt Financing | VCAP and Other Compliance and Program Management Initiatives | CPM Update – 2011 Highlights | paper by Todd Mitchell |
| Tax Exempt Financing | VCAP and Other Compliance and Program Management Initiatives | IRM 7.2.3 | supplemental panel materials |
| Tax Policy and Simplification | Perspectives on Tax Reform: Charitable Contributions and the Nonprofit Sector | Perspectives on Tax Reform: Charitable Contributions and the Nonprofit Sector | slides by Professor Jon Forman |
| Tax Policy and Simplification | Perspectives on Tax Reform: Charitable Contributions and the Nonprofit Sector | Principles and Rationales Behind the Charitable Deduction & Alternatives | slides by Roger Colinvaux, Brian Galle and Eugene Steuerle |
| Tax Policy and Simplification | Perspectives on Tax Reform: Taxation of Capital Gains and Dividend Income | Mitt Romney's Teachable Moment on Capital Gains | article by Len Burman |
| Tax Policy and Simplification | Perspectives on Tax Reform: Taxation of Capital Gains and Dividend Income | 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,” | Testimony before the Senate Committee on Finance, September 14, 2011, submitted by Len Burman |
| Tax Policy and Simplification | Perspectives on Tax Reform: Taxation of Capital Gains and Dividend Income | Beyond the ‘Buffett Rule’: Making The Income Tax More Progressive | article by Samuel C. Thompson Jr. |
| Teaching Taxation | Tax and the First Amendment | Campaign Disclosure and Tax-Exempt Entities: A Quick Repair to the Regulatory Plumbing | paper by Donald B. Tobin |
| Teaching Taxation | Tax and the First Amendment | Campaign Disclosure and Tax-Exempt Entities: A Quick Repair to the Regulatory Plumbing | paper by Donald B. Tobin |
| Teaching Taxation | Tax and the First Amendment | Once and Future Gift Taxation of Transfers to Section 501(c)(4) Organizations: Current Law, Constitutional Issues, and Policy Considerations | paper by Ellen P. Aprill |
| Teaching Taxation | Tax and the First Amendment | The Parsonage Exemption Violates the Establishment Clause and Should Be Declared Unconstitutional | paper by Erwin Chemerinsky |
| Transfer Pricing | Comparability and Economic Adjustments | Comparability and Economic Adjustments | slides by E. Miller Williams, Michael Aarstol, John Wills and Jeffrey Bethard |
| Transfer Pricing | Comparability and Economic Adjustments | APA Training Adjusting Comparables’ Results (Including Asset Intensity Adjustments) | panel materials by Russell Kwiat and RobertWeissler |
| Transfer Pricing | Transfer Pricing for Financial Institutions and Products | Financial Services Transfer Pricing Panel Presentation | slides submitted by Lucia Fedina |
| US Activities of Foreigners and Tax Treaties | The Corporate Mixed Marriage | The Corporate Mixed Marriage | lides by David Shapiro, Stuart Chessman, Friedhelm Jacob and Diana Wollman |
| US Activities of Foreigners and Tax Treaties | The New Proposed Foreign Account Tax Compliance Act (“FATCA”) Regulations | New Proposed FATCA Regulations | slides by Michael Hirschfeld and Fred Murray |
| Young Lawyers Forum | Making a Difference as a Tax Lawyer | Client Contract Letter - 3 | supplemental panel materials submitted by Catherine Engell |
| Young Lawyers Forum | Making a Difference as a Tax Lawyer | Making a Difference as a Tax Lawyer | slides prepared by Rachel Ney |
| Young Lawyers Forum | Making a Difference as a Tax Lawyer | Engagement Letter | supplemental panel materials submitted by Catherine Engell |
| Young Lawyers Forum | Making a Difference as a Tax Lawyer | Client Contract Letter - 1 | supplemental panel materials submitted by Catherine Engell |
| Young Lawyers Forum | Making a Difference as a Tax Lawyer | Client Contract Letter - 4 | supplemental panel materials submitted by Catherine Engell |
| Corporate Tax | Tax Opinions: What Does It Cost You and What Is It Worth to Your Client? | Tax Opinions: What Does It Cost You and What Is It Worth to Your Client? | slides by Jack Cummings, Julie Divola and Daniel White |
