2013 Midyear 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 Midyear Meeting - Orlando, FL

Panel TitleMaterials Title

Administrative Practice

Important DevelopmentsSelected Recent Developments in Administrative Practice
Privilege Update: IRS Examinations, IDRs, the Summons Process and the Policy of RestraintSlides: Examining Privilege Issues in the IRS Audit
The Procedural Side of FATCA: Witholding Operations, Refunds and ExaminationsFATCA Administrative Issues
When You Whistle Where You Work: Hot Topics on Federal Tax Whistleblower LawSlides: When You Whistle Where You Work
When You Whistle Where You Work: Hot Topics on Federal Tax Whistleblower LawAdditional Materials

Affiliated & Related Corporations

Current Developments in Consolidated ReturnsSlides: Current Developments in Consolidated Returns
Net Operating Losses and Consolidated GroupsSlides: A Primer on Consolidated Return Basics: NOLs and Consolidated Groups

Bankruptcy & Workouts

Annual UpdateBusiness Bankruptcy & Workouts - 2012/2013 Tax Update
Tax Problems of Liquidating TrustsBankruptcy Liquidating Trusts:  Taxation and Tax Reporting
Tax Problems of Liquidating TrustsFixed and Contingent Claims in Bankruptcy – Liquidating Trusts and Partnerships
Tough Issues in Bankruptcy-tax and Annual UpdatesBankruptcy and Workouts
Tough Issues in Bankruptcy-tax and Annual UpdatesEliminating Tax Debt Through Bankruptcy
Tough Issues in Bankruptcy-tax and Annual UpdatesIRS Collection Statute and Bankruptcy Discharge Time Requirements
Tough Issues in Bankruptcy-tax and Annual UpdatesOutline: Tough Issues in Bankruptcy-tax and Annual Updates
Tough Issues in Bankruptcy-tax and Annual UpdatesSurvey of 2011 CDP Cases

Banking & Savings Institutions

How the Recent Revisions of Circular 230 Affect Tax Advisors to Financial InstitutionsSlides: The Proposed circular 230 Regulations – a Move in the Right Direction?
Discussion of Recent Economic Substance and Debt/Equity CasesSlides: Recent Substance over Form & Debt vs. Equity Cases

Capital Recovery & Leasing

Current Developments Report and Update on Pending GuidanceCurrent Developments
Electric Generation Property Repair and Capitalization PrinciplesUtility Industry - Industry Issue Resolution (IIR) Projects
Navigating the Depreciation of AirplanesSlides: Navigating the Depreciation of Airplanes

Civil & Criminal Tax Penalties

Identity Theft: Issues for the Tax Practitioner and the TaxpayerSlides: Tax Refund Fraud and Identity Theft
Limitations and FraudAllen briefs (from Tax Court)
Limitations and FraudPanel Outline
Limitations and FraudStipulations in Allen
Reports of Subcommittees on Important DevelopmentsImportant Developments — Criminal
Reports of Subcommittees on Important DevelopmentsImportant Developments on Civil Penalties September, 2012 through December, 2012 Slides: IRS Investigations and Practices Subcommittee Report
Reports of Subcommittees on Important DevelopmentsSubcommittee Report: Legislative & Administrative Developments
So You Want to Be a Tax Controversy Associate?Outline - So You Want to Be a Tax Controversy Associate?

Corporate Tax

“Anti-Non Recognition” and Other “Gotchas.”Slides: Anti Non-Recognition  and Other “Gotcha’s”
Current Developments In Subchapter CSlides: Current Developments Panel
Where Does E&P Go?Slides: Where Does E&P Go?

Court Procedure & Practice

Ethical Concerns in Preparing WitnessesOutline: Ethical Concerns in Preparing Witnesses
Important DevelopmentsSlides: Deborah Butler Presentation
Important DevelopmentsSummary of Current Developments
Using Alternative Dispute Resolution (ADR) to Resolve Tax CasesSlides: Using Alternative Dispute Resolution (ADR) to Resolve Tax Cases
Through the Looking Glass (Part III): Collecting and Litigating FBAR PenaltiesSLIDES: Collection of the FBAR Penalty
Through the Looking Glass (Part III): Collecting and Litigating FBAR PenaltiesExhibit A McBride
Through the Looking Glass (Part III): Collecting and Litigating FBAR PenaltiesExhibit B Williams (4th cir)

Diversity

Safe Zones for LGBT Employees: Legal and Tax ImplicationsShifting from Outsider to Insider: Promoting Inclusion of LGBTQ Gender Nonconformers in the Legal Profession
Safe Zones for LGBT Employees: Legal and Tax ImplicationsSlides: Gender Identity in the Workplace
Safe Zones for LGBT Employees: Legal and Tax ImplicationsSlides: Safe Zones for LGBT Employees
Safe Zones for LGBT Employees: Legal and Tax ImplicationsSlides: Safe Zones for LGBT Legal and Tax Implications
Safe Zones for LGBT Employees: Legal and Tax ImplicationsSafe Zone Training
Safe Zones for LGBT Employees: Legal and Tax ImplicationsSafe Zone Program Training Manual
Safe Zones for LGBT Employees: Legal and Tax ImplicationsUSCODE-2010-title26-subtitleA-chap1-subchapB-partVI-sec162

Employee Benefits

Circular 230 Redux and New Proposed Guidance – Ethical Consideration for the ERISA AttorneySlides: Circular 230 - Affecting Employee Benefits
Employment Tax Issues in Executive CompensationImpact of Section 409A on Executive Employment Arrangements
Employment Tax Issues in Executive CompensationNew Medicare 0.9 Percent and 3.8 Percent Taxes: Executive Compensation Year-End Tax Planning
EPCRS Correction and Prototype Plan IssuesRevenue Procedure 2013-12: Key Changes to the Employee Plans Compliance Resolution System
EPCRS Correction and Prototype Plan IssuesRev. Proc. 2013-12
EPCRS Correction and Prototype Plan IssuesRev. Proc. 2008-50/2013-12
EPCRS Correction and Prototype Plan IssuesSlides: Employee Plans Compliance Resolution System:  Failures And Correction Methods
EPCRS Correction and Prototype Plan IssuesSlides: Employee Plans Compliance Resolution System: Revenue Procedure 2013-12
EPCRS Correction and Prototype Plan IssuesCorrection Methods For 401(k) Failures
Health Care Reform in 2013 and BeyondCode §4980H(a) and (b) Pay or Play Penalties Flowchart
Health Care Reform in 2013 and BeyondOverview of HHS Proposed Regulations Implementing Reinsurance Fees Paid by Carriers and Group Health Plans Under the Affordable Care Act
Health Care Reform in 2013 and BeyondOverview of HHS Proposed Regulations Implementing Reinsurance Fees Paid by Carriers and Group Health Plans Under the Affordable Care Act
Hot TopicsRedlined Comparison of EPCRS 2008-50 and EPCRS 2013-12
Hot TopicsIRS Proposed Regulations on Employer Shared Responsibility
Hot TopicsIRS Issues Proposed Rule on ACA Play or Pay Requirements
Hot TopicsIRS Q&As on Affordable Care Act Tax Provisions
The Ins and Outs of Granting Equity to Employees of LLCs and PartnershipsRev. Proc 2001-43
The Ins and Outs of Granting Equity to Employees of LLCs and PartnershipsInternal Revenue Bulletin: 2005-24
The Ins and Outs of Granting Equity to Employees of LLCs and PartnershipsRevenue Procedure 93-27
The Ins and Outs of Granting Equity to Employees of LLCs and PartnershipsSlides: The Ins and Outs of Granting Equity to Employees of LLC and Partnerships

Employee Benefits Subcommittees

Employee Benefits Subcommittee on Defined Benefit Plans
Defined Benefit Plans UpdateA Window into PBGC’S Practice: Current Issues and Trends
Defined Benefit Plans UpdateRecent PBGC Regulatory Developments
Employee Benefits Subcommittee on Defined Contribution Plans
Defined Contribution Plans UpdateAmerican Taxpayer Relief Act of 2012 Excerpts
Defined Contribution Plans UpdateEBSA News - Employee Benefit Plans in Wake of Hurricane Sandy
Defined Contribution Plans UpdateIRS Announcement 2012-44 - Hurricane Sandy Relief
Defined Contribution Plans UpdateIRS Chart of Significant Changes to EPCRS under Rev. Proc. 2013-12
Defined Contribution Plans UpdateIRS Revenue Procedure 2013-12 - EPCRS
Defined Contribution Plans UpdateProposed Amendment to Prohibited Transaction Exemption 2006-06
Defined Contribution Plans UpdateOutline: Defined Contribution Plans Update
Defined Contribution Plans UpdateProposed Amendments to Abandoned Plan Program - Fact Sheet
Defined Contribution Plans UpdateProposed Amendments to Abandoned Plan Regulations
Employee Benefits Subcommittee on Distributions
Distributions UpdateOutline: Distributions Update
Employee Benefits Subcommittee on Employee Benefit Legislation
Legislative UpdateLegislative Update for September 2012
Legislative UpdateMajor Legislation Affecting Employee Benefit Plans - 1974-2012
Employee Benefits Subcommittee on ESOPs
ESOPs UpdateMeeting Agenda with case summaries
Employee Benefits Subcommittees on Executive Compensation, Fringe Benefits and Federal Securities Law and Foreign and International Issues
Executive Compensation, Fringe Benefits and Securities Law UpdateUS Taxation of Foreign Pension Plans
Employee Benefits Subcommittee on Fiduciary Responsibility/Plan Investments
Employee Benefits Subcommittee on Foreign and International Issues
Fiduciary Responsibilities UpdateFiduciary Responsibility Update
Employee Benefits Subcommittee on Foreign and International Issues
International Update2012 Global Equity Incentives Survey
International UpdateSlides: 2012 Global Equity Incentives Survey
International UpdateSlides: Clawbacks and Compliance Topics in Global Equity Plans
Litigation UpdateEmployee Benefits Litigation Update
Multiple Employers, PEOs and Controlled Groups UpdateAn Introduction To The Controlled Group Rules
Multiple Employers, PEOs and Controlled Groups UpdateA Multiple Employer Plans (MEPs) Primer
Multiple Employers, PEOs and Controlled Groups UpdateDOL Has Spoken: What’s Next for Open MEPs?
Multiple Employers, PEOs and Controlled Groups UpdateIRS Manual 7.11.7
Multiple Employers, PEOs and Controlled Groups UpdateLRM 86A MEPs
Multiple Employers, PEOs and Controlled Groups UpdateSun Capital Partners III
Multiple Employers, PEOs and Controlled Groups UpdateGAO Report - Federal Agencies Should Collect Data and Coordinate Oversight of Multiple Employer Plans
Multiple Employers, PEOs and Controlled Groups UpdateSelected Resources
Administrative Practices UpdateRevenue Procedure 2013-12: Key Changes to the Employee Plans Compliance Resolution System
Administrative Practices UpdateForm 8950 (draft)
Administrative Practices UpdateForm 8951 (draft)
Administrative Practices UpdateForm i8950 (draft)
Administrative Practices UpdateRev. Proc. 2013-12
Administrative Practices UpdateSlides: IRS Determination Letters: Current Status & Issues
Employee Benefits Subcommittee on Mergers and Acquisitions
Mergers & Acquisitions UpdateSlides: Mergers & Acquisitions Update
Employee Benefits Subcommittee on Multiple Employers, PEOs and Controlled and Affiliated Service Groups
Multiple Employers, PEOs and Controlled Groups UpdatePBGC v Asahi Tec Corporation
Multiple Employers, PEOs and Controlled Groups UpdateAgenda for Subcommittee on MEPs PEOs CG & ASG
Multiple Employers, PEOs and Controlled Groups UpdateComparison of MEWAs and Open MEPS
Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices
Administrative Practices UpdateSlides: Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices
Employee Benefits Subcommittee on Welfare Plan Design, EEOC, FMLA and Leaves Issues and Cafeteria Plans and Reimbursement Accounts
Welfare Benefits Design, EEOC and FMLA UpdateHealth Care Reform Update: Proposed Regulations Regarding Essential Health Benefits, Actuarial Value, and Accreditation Standards
Welfare Benefits Design, EEOC and FMLA UpdateExamining New Proposed Regulations on Employer Shared Responsibility Payments
Welfare Benefits Design, EEOC and FMLA UpdateIRS January 2, 2013 Proposed Regulations: IRC §4980H Guidance on Determining Status as an “Applicable Large Employer” and Resulting Exposure to the Employer Shared Responsibility “Assessable Payments”

Employment Taxes

Employment Tax Issues in Executive CompensationSlides: Employment Tax Issues in Executive Compensation
Employment Tax Issues in Executive CompensationImpact of Section 409A on Executive Employment Arrangements
Employment Tax Issues in Executive CompensationPanel Outline
Employment Tax Issues in Executive CompensationNew Medicare 0.9 Percent and 3.8 Percent Taxes
Federal UpdateOutline: Federal Update
On Hold: What to Tell Your Clients While Waiting for a Final Disposition inthe Quality Stores CaseUnited States v. Quality Stores, et al.
One if by Air; Two if by SeaOne if by Air; Two if by Sea: U.S. Employment Tax Reporting and Withholding Obligations in Connection with Nonresident Aliens Performing Services in U.S. Airports, Seaports, or in U.S. Territorial Waters, as Crew Members of an Airplane, Cruise Ship, Fishing or Cargo Vessel, or on the Outer Continental Shelf
One if by Air; Two if by SeaTAM 201014051
The National Taxpayer AdvocateSummary : The Diminishing Role of the Revenue Officer Has Been Detrimental to the Overall Effectiveness of IRS Collection Operations
The National Taxpayer AdvocateSummary: Early Intervention, Offers in Compromise, and Proactive Outreach Can Help Victims of Failed Payroll Service Providers and Increase Employment Tax Compliance
The National Taxpayer AdvocateThe Diminishing Role of the Revenue Officer Has Been Detrimental to the Overall Effectiveness of IRS Collection Operations
The National Taxpayer AdvocateEarly Intervention, Offers in Compromise, and Proactive Outreach Can Help Victims of Failed Payroll Service Providers and Increase Employment Tax Compliance

Energy & Environmental Taxes

The Nuclear Reactor Tax Credit, Post-FukushimaSlides: The Nuclear Reactor Tax Credit, Post-Fukushima
Renewable Energy Tax and Grant UpdatesSlides: Renewable Energy Tax  and Grant Updates

Estate & Gift Taxes

Current DevelopmentsCurrent Developments in Estate Planning
Displaying Value: Special Issues in Valuing Art for Estate, Gift and Income Tax ReportingArt Is Long, Life Is Short: Estate Planning For the Artist and the Art Collector
Home Sweet Home: Planning Issues for ResidencesHome Sweet Home: Planning Issues for Residences

Exempt Organizations

Circular 230 Redux: What the Changes Mean for EO PractitionersSlides: Circular 230 Overview:  Proposed Revisions
Circular 230 Redux: What the Changes Mean for EO PractitionersCircular 230 Comment Matrix
News from the IRS and TreasuryOutline of Current Regulatory and Other Developments
Non-Exempt Nonprofits – Not an OxymoronMaterials Index
Non-Exempt Nonprofits – Not an OxymoronTaxability (Other than UBTI) of Exempt/Formerly Exempt/Benefit Corporations
Non-Exempt Nonprofits – Not an OxymoronConsequences of Revocation:  Issues in Calculating “Taxable Income” When Jurisdiction over Entity Moves Out of TE/GE-Exempt Organization Division
Non-Exempt Nonprofits – Not an OxymoronChart -- Legal Treatment Of Nonprofit Organizations
Non-Exempt Nonprofits – Not an OxymoronScenarios for Discussion
Non-Exempt Nonprofits – Not an OxymoronTaxation of Revoked Tax-Exempt Organizations: The Synanon Case
Non-Exempt Nonprofits – Not an OxymoronInternal Revenue Manual – 4.75.31 Conversion of Returns Upon Revocation of Exemption
Non-Exempt Nonprofits – Not an OxymoronGen. Couns. Mem. 39813
Non-Exempt Nonprofits – Not an OxymoronSlides
Single Member LLCs and Exempt OrganizationsUse of Single Member Limited Liability Companies by Tax-Exempt Organizations
Text It; Tweet It; Blog It; Delete It – Social Media and Exempt OrganizationsSocial Media Outline with attachments

Fiduciary Income Tax

Post-Mortem Income Tax Issues: A Fiduciary’s HandbookPost-Mortem Income Tax Issues
Post-Mortem Income Tax Issues: A Fiduciary’s HandbookRecent Updates: Overview of the 3.8% Surtax for Trust and Estates
Recent DevelopmentsRecent Developments in Fiduciary Income Tax
Turbocharging the Estate PlanTurbocharging the Estate Plan
What Estate Planners Need to Know about Marital LawA Prenuptial Agreement Primer for the Estate Planning Attorney
What Estate Planners Need to Know about Marital LawSlides: A Prenuptial Agreement Primer for the Estate Planning Attorney 

Financial Transactions

Fear and Loathing in Section 1092Slides: Fear and Loathing (and Loving) in Section 1092: The use of identified mixed straddles and other techniques to accelerate unrealized gains
Recent Developments and Current IssuesSlides: Current Developments and Shop Talk
Taxing Derivatives: Do Look-through Rules Work?Slides: Taxing Derivatives: Do Deemed Ownership Rules Work?
Outbound Stock and Asset TransfersSlides: Foreign Activities of U.S. Taxpayers "Outbound Stock and Asset Transfers"

Foreign Activities of US Taxpayers

Technical Aspects of International Tax Reform ProposalsSlides: Technical Aspects of International Reform Proposals

Foreign Lawyers Forum

FATCA and the Intergovernmental Agreements – The View From the Other SideFATCA and Intergovernmental Agreements – The View from the Other Side

Indian Tribal Tax

Exploring The Unique Environment of The Tribal-IRS RelationshipSlides: The Tribal-IRS Relationship
Exploring The Unique Environment of The Tribal-IRS RelationshipCRS Reviews Indian Tribal Governmental Tax Status Act
Exploring The Unique Environment of The Tribal-IRS RelationshipInternal Revenue Manual - 22.41.1 Indian Tribal Governments Outreach
Exploring The Unique Environment of The Tribal-IRS RelationshipInternal Revenue Manual - 4.86.1 Indian Tribal Governments Administration
Exploring The Unique Environment of The Tribal-IRS RelationshipOverview of Federal Tax Provisions Relating to Native American Tribes and Their Members
Exploring The Unique Environment of The Tribal-IRS RelationshipRev Rul 67-284
Exploring The Unique Environment of The Tribal-IRS RelationshipRev Rul 94-16
Exploring The Unique Environment of The Tribal-IRS RelationshipRev Rul 94-81
IRS Enforcement in Indian CountryStreitz Indian Taxation Presentation
IRS Enforcement in Indian CountryAttachment A. IRS Protocols for Tribal Contacts
IRS Enforcement in Indian CountryAttachment B. Prior Treasury Department Consultation Policy
IRS Enforcement in Indian CountryAttachment C. Current Treasury Department Consultation Process
IRS Enforcement in Indian CountryAttachment D. Draft Treasury Department Tribal Consultation Progress Report
IRS Enforcement in Indian CountryAttachment E. IRS Notice 2012-75
IRS Enforcement in Indian CountryAttachment F. NCAI Requests for Consultation on Trust Per Capita Payments Issue
IRS Enforcement in Indian CountryAttachment G. IRS Notice 12-60
IRS Enforcement in Indian CountryAttachment H. NCAI Follow Up Letter on Trust Per Capita Payments Issue
IRS Enforcement in Indian CountryAttachment I. Miccosukee Decisions

Insurance Companies

Reports From the Frontier Between Insurance and Employee Benefits (Or, Don’t Shoot the Messenger!)Summary of Lifetime Income Guidance Released by Treasury and IRS
Unique Financial Products Issues that Affect Issuers of Variable AnnuitiesSlides: Hedging of Guaranteed Benefits on Variable Annuities
Waiting to Exhale: Current Developments From the IRS and Treasury, Including the Treatment of Extracontractual ObligationsSlides: Current Developments: Waiting To Exhale

Investment Management

Current Developments Regarding Tax Issues for Regulated Investment Companies1 - Slides: RIC Modernization Act 2010 Defining the “Reasonable Cause and Not Willful Neglect” Standard
Current Developments Regarding Tax Issues for Regulated Investment Companies2 - RIC Modernization Act 2010 Reasonable Cause Exception Authorities
Current Developments Regarding Tax Issues for Regulated Investment Companies3 - Slides: Lack of Integration of Sub M and Excise Tax
Current Developments Regarding Tax Issues for Regulated Investment Companies4 - Lack of Integration of Sub M and Excise Tax Authorities
Current Developments Regarding Tax Issues for Regulated Investment Companies5 - Slides: RICs and Declarations of Spillback Dividends: Special Issues
Current Developments Regarding Tax Issues for Regulated Investment Companies6 - RICs and Declarations of Spillback Dividends: Special Issues Authorities
Current Developments Regarding Tax Issues for Regulated Investment Companies7 - Slides: ICI Updates on U.S. and International Tax Issues
Current Developments Regarding Tax Issues for Regulated Investment Companies8 - ICI Updates on U.S. and International Tax Issues Authorities
Structuring and Operational Issues for Venture Capital FundsSlides: Structuring and Operational Issues for Venture Capital Funds
Structuring and Planning Issues for MLP InvestmentsRecent Relevant IRS Private Letter Rulings for Master Limited Partnerships
Structuring and Planning Issues for MLP InvestmentsSlides: Structuring and Planning Issues for MLP Investments

JOINT: Closely Held Businesses and Bankruptcy & Workouts

The Exit Strategy from Retirement Accounts for the Financially Challenged: The IRS Collection Process and Bankruptcy ProtectionProtection from Creditors and the IRS: Misconceptions, Foot Faults and Some Suggestions
The Exit Strategy from Retirement Accounts for the Financially Challenged: The IRS Collection Process and Bankruptcy ProtectionUSA v. Cooper
IRS Collection & Bankruptcy AlternativesIRS Collection & Bankruptcy Alternatives
Tales from the Crypt: Dealing with a Decedent’s Tax FraudMaterials - Tales from the Crypt: Dealing with a Decedent's Tax Fraud

JOINT: Closely Held Businesses Committee and Civil & Criminal Tax Penalties

The ABCs of Summons Enforcement, Including Recent Developments in the Area of 5th Amendment Issues for Closely Held BusinessesOutline: Use, Enforcement, and Defense of IRS Summons
The ABCs of Summons Enforcement, Including Recent Developments in the Area of 5th Amendment Issues for Closely Held BusinessesSlides: Use, Enforcement, and Defense of IRS Summons
Update on LB&I Global High Wealth Group ExaminationsSlides: Update On Global High Wealth Industry Group Examinations

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

Joint Current International Developments PanelDRAFT SLIDES: Joint Current International Developments Panel

JOINT: Individual & Family Taxation and Pro Bono & Tax Clinics

Hot Practice Tips for Representing an Individual Taxpayer Before and During an IRS ExaminationSlides: Hot Practice Tips for Representing an Individual Taxpayer Before and During an IRS Examination
Proposed Changes to the Guidelines for Innocent Spouse ReliefComments on Proposed Changes to the Guidelines for Innocent Spouse Relief in Revenue Procedure 2003-61
Proposed Changes to the Guidelines for Innocent Spouse ReliefOutline: Proposed Changes to the Guidelines for Innocent Spouse Relief
Vanishing Time Limits for Equitable ReliefVanishing Time Limits for Equitable Relief
Vanishing Time Limits for Equitable ReliefHypotheticals
Vanishing Time Limits for Equitable ReliefAdditional Materials

JOINT: Individual & Family Taxation, Standards of Tax Practice and Tax Practice Management

Practical and Ethical Strategies in Representing CouplesPanel Materials
Practical and Ethical Strategies in Representing CouplesAdditional Materials

JOINT: Teaching Taxation and Tax Policy & Simplification

Panel Discussion of We’re Not BrokeSlides: What Tax Professionals should understand about Transfer Pricing
Panel Discussion of We’re Not BrokeThe “Price of Offshore” Revisited
Panel Discussion of We’re Not BrokeTowards Unitary Taxation of Transnational Corporations
Panel Discussion of We’re Not BrokeUtopian Visions toward a Grand Unified Global Income Tax
The Prospects for Tax Reform in President Obama’s Second TermTax Reform Today
The Prospects for Tax Reform in President Obama’s Second TermSlides: Tax Reform - Nellen
The Prospects for Tax Reform in President Obama’s Second TermSlides: Tax Reform: Will It Happen?
The Prospects for Tax Reform in President Obama’s Second TermSlides: Tax Reform
The Prospects for Tax Reform in President Obama’s Second TermSlides: Prospects for Tax Reform  in Pres. Obama’s 2nd Term
The Prospects for Tax Reform in President Obama’s Second TermThe Time for Tax Reform is Now
The Prospects for Tax Reform in President Obama’s Second TermThe Complexity of the Tax Code

Partnerships & LLCs Clinics

Dipping our Toes in Foreign WatersSlides: Dipping Our Toes in Foreign Waters: Outbound International Partnership Issues
Dipping our Toes in Foreign WatersThe Schizophrenic Partnership: IRS Issues Notice 2010-41 Addressing Partnership Blocker to Subpart F Inclusions
Dipping our Toes in Foreign WatersNotice 2009-7: IRS Designates “Partnership Blocker” to Subpart F Inclusions as a New Transaction of Interest
Is Your Partner Under the Boardwalk?Slides: Is Your Partner Under the Boardwalk?
Fun with a "D": Management Fee Waivers and Clawback Issues for Private Equity and Hedge FundsSlides: Fun with a “D”: Management Fee Waivers and Clawback Issues for Private Equity and Hedge Funds

Pro Bono & Tax Clinics

Issues Involving Cancellation of Debt IncomeSlides: Issues involving Cancellation of Debt Income
Presentation of Annual Report to CongressOutline: Report from the National Taxpayer Advocate on her 2012 Annual Report to Congress
Tax Issues in Immigration LawSlides: New ITIN rules THE IRS response to TIGTA reports
Tax Issues in Immigration LawSlides: Taxing Immigrants:  A Primer
Tax Issues in Immigration LawCase Studies on Immigration and Tax
Tax Issues in Immigration LawCommunity Interpreter Internship Syllabus
Tax Issues in Immigration LawAdditional Handouts
Tax Issues in Immigration LawSlides: Strategies for Delivering Tax Services to Rural Migrants

Real Estate

Hot TopicsSlides: Hot Topics
New Guidance Regarding Impact of State Law on Classification of Section 1031 Exchange PropertyIRS Muddies the Like-Kind Waters in Guidance Considering State Law Classification
New Guidance Regarding Impact of State Law on Classification of Section 1031 Exchange PropertySlides: State Law Characterization and Section 1031
Noncore REITs and Other Hot REIT IssuesSlides: Developing Trends in REIT Conversions and Related Issues
Update on the 3.8% Tax on Net Investment Income and its Impact on Real EstateSection 1411 Proposed Regulations
at to Expect in the Post-Election EnvironmentSlides: Tax Legislative Outlook

S Corporations

Recent Developments in State and Local Taxation of S CorporationsSlides: Recent Developments in State and Local Taxation of S Corporations
S Corporation Compensation Reclassification RisksMaterials: S Corporation Compensation Reclassification Risks
S Corporation Compensation Reclassification RisksSlides: S Corporation Compensation Reclassification Risks
Subchapter S Valuation: To Tax Effect, or Not to Tax Effect, Is Not Really the QuestionPaper: Sub S Valuation: To Tax Effect, Or Not To Tax Effect, Is Not Really The Question
Subchapter S Valuation: To Tax Effect, or Not to Tax Effect, Is Not Really the QuestionSlides: Sub S Valuation: To Tax Effect, Or Not To Tax Effect, Is Not Really The Question
The Proposed Section 1411 “Medicare Tax” Regulations and S CorporationsSlides: The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations

Sales, Exchanges & Basis

Current Developments in Sales, Exchanges and Basis, Including Sections 1031 & 1033Current Non-Section 1031 Developments
Current Developments in Sales, Exchanges and Basis, Including Sections 1031 & 1033IRC § 1031/1033 Current Developments
Everything You Need to Know About the Tax Issues in National Federation of Independent Business v. SebeliusCourse Materials
Ponzi Scheme Update: Tax Treatment of Clawbacks and Other ItemsBefore It's Too Late, Reconsidering the IRS Relief for Madoff Losses
Ponzi Scheme Update: Tax Treatment of Clawbacks and Other ItemsSlides: Ponzi Scheme Update:  Tax Treatment of Clawbacks and Other Items
Tax Issues Involving Flawed SecuritizationsSlides: Tax Disqualification Issues Facing REMICs

Section Program

Current Developments in Individual, Corporate, Partnership and Estate & Gift TaxationFederal Estate, Gift and Generation-Skipping Transfer Tax Update
Current Developments in Individual, Corporate, Partnership and Estate & Gift TaxationRecent Developments in Federal Income Taxation
Healthcare Reform Update2013 Medicare Taxes For Investors, Business Entities & Their Owners, Trusts & Estates - Outline 1
Healthcare Reform UpdateProposed IRS Regulations On PPACA Shared Responsibility (Employer Mandate) Provisions
Healthcare Reform Update4980H proposed regulation
Healthcare Reform UpdateAdd'l Medicare Tax Proposed Reg
Healthcare Reform UpdateNet Investment Income Proposed Regs
Healthcare Reform UpdateNet Investment Income Tax FAQ
Healthcare Reform UpdatePCORTF fee reg
Healthcare Reform UpdateQuestions and Answers for the Additional Medicare Tax
Healthcare Reform UpdateQuestions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act

Standards of Tax Practice

An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax ControversiesPanel Materials - An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies
An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax ControversiesSlides - An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies
Ethical Issues in Federal Tax Practice – The Government PerspectiveSlides: Ethical Issues in Federal Tax Practice – The Government Perspective
The Proposed (or Final) Amendments to Circular 230Comments on Proposed Reg- 138367-06 Relating to Practice Before the Internal Revenue Service
The Proposed (or Final) Amendments to Circular 230The Proposed Amendments to Circular 230: How They Would Affect OPR’s Practice Standards Oversight Activity, What Additional Guidance and Requirements They Would Establish and How Practitioners Should Respond
The Proposed (or Final) Amendments to Circular 230IRS Office of Professional Responsibility Disbars Return Preparer Accused of Filing False Returns
The Proposed (or Final) Amendments to Circular 230Motion for Decision by Default Denied as Moot; Motion for Summary Adjudication Granted In Part; Order Imposing Sanction of  Disbarment
The Proposed (or Final) Amendments to Circular 230IRS Statement on Court Ruling Related to Return Preparers
The Proposed (or Final) Amendments to Circular 230Loving
The Proposed (or Final) Amendments to Circular 230Loving Stay Motion

State & Local Taxes

Current Trends in Economic Nexus for State Income TaxesSlides: Current Trends in Economic Nexus for State Income Taxes
Is the Multistate Tax Compact Apportionment Election Still Available?State Multistate Tax Compact Enactments - Articles III.1 and IV
Is the Multistate Tax Compact Apportionment Election Still Available?Is the Multistate Tax Compact Apportionment Election Still Available?
Is the Multistate Tax Compact Apportionment Election Still Available?Model Multistate Tax Compact
State and Local Taxation of the Mobile WorkforceAppendix
State and Local Taxation of the Mobile WorkforceSlides: The Stalled Mobile Workforce Project
State Tax Administration in Theory and in Practice: Evaluating Transparency in State Tax AdministrationMeasuring Transparency In State Tax Administration
State Tax Administration in Theory and in Practice: Evaluating Transparency in State Tax AdministrationTransparency in State Taxation — Part I: Discretionary Authority
State Tax Administration in Theory and in Practice: Evaluating Transparency in State Tax AdministrationTransparency in State Taxation, Part 2: Legislative Process and Letter Rulings

Tax Accounting

Current DevelopmentsCurrent Developments Materials
Hot Topics in HealthcareSlides: Hot Topics in Healthcare
Tangible Property Regulations UpdateSlides: Tangible Property Regulations Update

Tax Exempt Financing

New Rules for Tax-Exempt Financing Tax Lawyers Under Circular 230; Rules of Ethics Applicable to Opinions Given by Tax-Exempt Financing Tax LawyersCircular 230 and Ethics Discussion Outline
New Rules for Tax-Exempt Financing Tax Lawyers Under Circular 230; Rules of Ethics Applicable to Opinions Given by Tax-Exempt Financing Tax LawyersExcerpts from Circular 230
New Rules for Tax-Exempt Financing Tax Lawyers Under Circular 230; Rules of Ethics Applicable to Opinions Given by Tax-Exempt Financing Tax LawyersProposed Circular 230 Operative Sections
New Rules for Tax-Exempt Financing Tax Lawyers Under Circular 230; Rules of Ethics Applicable to Opinions Given by Tax-Exempt Financing Tax LawyersABA Comments to Circular 230 Proposal
Treasury and Internal Revenue Service UpdateTreasury and IRS Updates Panel
Will the Historical Approach of Exempting Interest on Municipal Bonds be Radically Changed by the New Congress?Outline For Remarks on Current Proposals Affecting Tax Exempt Bonds

Transfer Pricing

Planning for Intangible Property Migration in an Uncertain EnvironmentSlides: Planning for Intangible Property Migration in an Uncertain Environment

US Activities of Foreigners & Tax Treaties

Inbound Mergers and Acquisitions: Recent Trends and ConsiderationsSlides: Inbound Mergers & Acquisitions: Recent Trends & Considerations 
Understanding Tax Issues for Foreign Persons Investing in US Real EstateSlides: Foreign Persons Investing in U.S. Real Estate

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