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 | |
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Administrative Practice | |
| Panel Title | Materials Title |
| Important Developments | Selected Recent Developments in Administrative Practice |
| Privilege Update: IRS Examinations, IDRs, the Summons Process and the Policy of Restraint | Slides: Examining Privilege Issues in the IRS Audit |
| The Procedural Side of FATCA: Witholding Operations, Refunds and Examinations | FATCA Administrative Issues |
| When You Whistle Where You Work: Hot Topics on Federal Tax Whistleblower Law | Slides: When You Whistle Where You Work |
| When You Whistle Where You Work: Hot Topics on Federal Tax Whistleblower Law | Additional Materials |
Affiliated & Related Corporations | |
| Panel Title | Materials Title |
| Current Developments in Consolidated Returns | Slides: Current Developments in Consolidated Returns |
| Net Operating Losses and Consolidated Groups | Slides: A Primer on Consolidated Return Basics: NOLs and Consolidated Groups |
Bankruptcy & Workouts | |
| Panel Title | Materials Title |
| Annual Update | Business Bankruptcy & Workouts - 2012/2013 Tax Update |
| Tax Problems of Liquidating Trusts | Bankruptcy Liquidating Trusts: Taxation and Tax Reporting |
| Tax Problems of Liquidating Trusts | Fixed and Contingent Claims in Bankruptcy – Liquidating Trusts and Partnerships |
| Tough Issues in Bankruptcy-tax and Annual Updates | Bankruptcy and Workouts |
| Tough Issues in Bankruptcy-tax and Annual Updates | Eliminating Tax Debt Through Bankruptcy |
| Tough Issues in Bankruptcy-tax and Annual Updates | IRS Collection Statute and Bankruptcy Discharge Time Requirements |
| Tough Issues in Bankruptcy-tax and Annual Updates | Outline: Tough Issues in Bankruptcy-tax and Annual Updates |
| Tough Issues in Bankruptcy-tax and Annual Updates | Survey of 2011 CDP Cases |
Banking & Savings Institutions | |
| Panel Title | Materials Title |
| How the Recent Revisions of Circular 230 Affect Tax Advisors to Financial Institutions | Slides: The Proposed circular 230 Regulations – a Move in the Right Direction? |
| Discussion of Recent Economic Substance and Debt/Equity Cases | Slides: Recent Substance over Form & Debt vs. Equity Cases |
Capital Recovery & Leasing | |
| Panel Title | Materials Title |
| Current Developments Report and Update on Pending Guidance | Current Developments |
| Electric Generation Property Repair and Capitalization Principles | Utility Industry - Industry Issue Resolution (IIR) Projects |
| Navigating the Depreciation of Airplanes | Slides: Navigating the Depreciation of Airplanes |
Civil & Criminal Tax Penalties | |
| Panel Title | Materials Title |
| Identity Theft: Issues for the Tax Practitioner and the Taxpayer | Slides: Tax Refund Fraud and Identity Theft |
| Limitations and Fraud | Allen briefs (from Tax Court) |
| Limitations and Fraud | Panel Outline |
| Limitations and Fraud | Stipulations in Allen |
| Reports of Subcommittees on Important Developments | Important Developments — Criminal |
| Reports of Subcommittees on Important Developments | Important Developments on Civil Penalties September, 2012 through December, 2012 Slides: IRS Investigations and Practices Subcommittee Report |
| Reports of Subcommittees on Important Developments | Subcommittee 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 | |
| Panel Title | Materials Title |
| “Anti-Non Recognition” and Other “Gotchas.” | Slides: Anti Non-Recognition and Other “Gotcha’s” |
| Current Developments In Subchapter C | Slides: Current Developments Panel |
| Where Does E&P Go? | Slides: Where Does E&P Go? |
Court Procedure & Practice | |
| Panel Title | Materials Title |
| Ethical Concerns in Preparing Witnesses | Outline: Ethical Concerns in Preparing Witnesses |
| Important Developments | Slides: Deborah Butler Presentation |
| Important Developments | Summary of Current Developments |
| Using Alternative Dispute Resolution (ADR) to Resolve Tax Cases | Slides: Using Alternative Dispute Resolution (ADR) to Resolve Tax Cases |
| Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties | SLIDES: Collection of the FBAR Penalty |
| Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties | Exhibit A McBride |
| Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties | Exhibit B Williams (4th cir) |
Diversity | |
| Panel Title | Materials Title |
| Safe Zones for LGBT Employees: Legal and Tax Implications | Shifting from Outsider to Insider: Promoting Inclusion of LGBTQ Gender Nonconformers in the Legal Profession |
| Safe Zones for LGBT Employees: Legal and Tax Implications | Slides: Gender Identity in the Workplace |
| Safe Zones for LGBT Employees: Legal and Tax Implications | Slides: Safe Zones for LGBT Employees |
| Safe Zones for LGBT Employees: Legal and Tax Implications | Slides: Safe Zones for LGBT Legal and Tax Implications |
| Safe Zones for LGBT Employees: Legal and Tax Implications | Safe Zone Training |
| Safe Zones for LGBT Employees: Legal and Tax Implications | Safe Zone Program Training Manual |
| Safe Zones for LGBT Employees: Legal and Tax Implications | USCODE-2010-title26-subtitleA-chap1-subchapB-partVI-sec162 |
Employee Benefits | |
| Panel Title | Materials Title |
| Circular 230 Redux and New Proposed Guidance – Ethical Consideration for the ERISA Attorney | Slides: Circular 230 - Affecting Employee Benefits |
| Employment Tax Issues in Executive Compensation | Impact of Section 409A on Executive Employment Arrangements |
| Employment Tax Issues in Executive Compensation | New Medicare 0.9 Percent and 3.8 Percent Taxes: Executive Compensation Year-End Tax Planning |
| EPCRS Correction and Prototype Plan Issues | Revenue Procedure 2013-12: Key Changes to the Employee Plans Compliance Resolution System |
| EPCRS Correction and Prototype Plan Issues | Rev. Proc. 2013-12 |
| EPCRS Correction and Prototype Plan Issues | Rev. Proc. 2008-50/2013-12 |
| EPCRS Correction and Prototype Plan Issues | Slides: Employee Plans Compliance Resolution System: Failures And Correction Methods |
| EPCRS Correction and Prototype Plan Issues | Slides: Employee Plans Compliance Resolution System: Revenue Procedure 2013-12 |
| EPCRS Correction and Prototype Plan Issues | Correction Methods For 401(k) Failures |
| Health Care Reform in 2013 and Beyond | Code §4980H(a) and (b) Pay or Play Penalties Flowchart |
| Health Care Reform in 2013 and Beyond | Overview 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 Beyond | Overview of HHS Proposed Regulations Implementing Reinsurance Fees Paid by Carriers and Group Health Plans Under the Affordable Care Act |
| Hot Topics | Redlined Comparison of EPCRS 2008-50 and EPCRS 2013-12 |
| Hot Topics | IRS Proposed Regulations on Employer Shared Responsibility |
| Hot Topics | IRS Issues Proposed Rule on ACA Play or Pay Requirements |
| Hot Topics | IRS Q&As on Affordable Care Act Tax Provisions |
| The Ins and Outs of Granting Equity to Employees of LLCs and Partnerships | Rev. Proc 2001-43 |
| The Ins and Outs of Granting Equity to Employees of LLCs and Partnerships | Internal Revenue Bulletin: 2005-24 |
| The Ins and Outs of Granting Equity to Employees of LLCs and Partnerships | Revenue Procedure 93-27 |
| The Ins and Outs of Granting Equity to Employees of LLCs and Partnerships | Slides: The Ins and Outs of Granting Equity to Employees of LLC and Partnerships |
Employee Benefits Subcommittees | |
| Employee Benefits Subcommittee on Defined Benefit Plans | |
| Panel Title | Materials Title |
| Defined Benefit Plans Update | A Window into PBGC’S Practice: Current Issues and Trends |
| Defined Benefit Plans Update | Recent PBGC Regulatory Developments |
| Employee Benefits Subcommittee on Defined Contribution Plans | |
| Panel Title | Materials Title |
| Defined Contribution Plans Update | American Taxpayer Relief Act of 2012 Excerpts |
| Defined Contribution Plans Update | EBSA News - Employee Benefit Plans in Wake of Hurricane Sandy |
| Defined Contribution Plans Update | IRS Announcement 2012-44 - Hurricane Sandy Relief |
| Defined Contribution Plans Update | IRS Chart of Significant Changes to EPCRS under Rev. Proc. 2013-12 |
| Defined Contribution Plans Update | IRS Revenue Procedure 2013-12 - EPCRS |
| Defined Contribution Plans Update | Proposed Amendment to Prohibited Transaction Exemption 2006-06 |
| Defined Contribution Plans Update | Outline: Defined Contribution Plans Update |
| Defined Contribution Plans Update | Proposed Amendments to Abandoned Plan Program - Fact Sheet |
| Defined Contribution Plans Update | Proposed Amendments to Abandoned Plan Regulations |
| Employee Benefits Subcommittee on Distributions | |
| Panel Title | Materials Title |
| Distributions Update | Outline: Distributions Update |
| Employee Benefits Subcommittee on Employee Benefit Legislation | |
| Panel Title | Materials Title |
| Legislative Update | Legislative Update for September 2012 |
| Legislative Update | Major Legislation Affecting Employee Benefit Plans - 1974-2012 |
| Employee Benefits Subcommittee on ESOPs | |
| Panel Title | Materials Title |
| ESOPs Update | Meeting Agenda with case summaries |
| Employee Benefits Subcommittees on Executive Compensation, Fringe Benefits and Federal Securities Law and Foreign and International Issues | |
| Panel Title | Materials Title |
| Executive Compensation, Fringe Benefits and Securities Law Update | US Taxation of Foreign Pension Plans |
| Employee Benefits Subcommittee on Fiduciary Responsibility/Plan Investments | |
| Panel Title | Materials Title |
| Employee Benefits Subcommittee on Foreign and International Issues | |
| Panel Title | Materials Title |
| Fiduciary Responsibilities Update | Fiduciary Responsibility Update |
| Employee Benefits Subcommittee on Foreign and International Issues | |
| International Update | 2012 Global Equity Incentives Survey |
| International Update | Slides: 2012 Global Equity Incentives Survey |
| International Update | Slides: Clawbacks and Compliance Topics in Global Equity Plans |
| Litigation Update | Employee Benefits Litigation Update |
| Multiple Employers, PEOs and Controlled Groups Update | An Introduction To The Controlled Group Rules |
| Multiple Employers, PEOs and Controlled Groups Update | A Multiple Employer Plans (MEPs) Primer |
| Multiple Employers, PEOs and Controlled Groups Update | DOL Has Spoken: What’s Next for Open MEPs? |
| Multiple Employers, PEOs and Controlled Groups Update | IRS Manual 7.11.7 |
| Multiple Employers, PEOs and Controlled Groups Update | LRM 86A MEPs |
| Multiple Employers, PEOs and Controlled Groups Update | Sun Capital Partners III |
| Multiple Employers, PEOs and Controlled Groups Update | GAO Report - Federal Agencies Should Collect Data and Coordinate Oversight of Multiple Employer Plans |
| Multiple Employers, PEOs and Controlled Groups Update | Selected Resources |
| Administrative Practices Update | Revenue Procedure 2013-12: Key Changes to the Employee Plans Compliance Resolution System |
| Administrative Practices Update | Form 8950 (draft) |
| Administrative Practices Update | Form 8951 (draft) |
| Administrative Practices Update | Form i8950 (draft) |
| Administrative Practices Update | Rev. Proc. 2013-12 |
| Administrative Practices Update | Slides: IRS Determination Letters: Current Status & Issues |
| Employee Benefits Subcommittee on Mergers and Acquisitions | |
| Panel Title | Materials Title |
| Mergers & Acquisitions Update | Slides: Mergers & Acquisitions Update |
| Employee Benefits Subcommittee on Multiple Employers, PEOs and Controlled and Affiliated Service Groups | |
| Panel Title | Materials Title |
| Multiple Employers, PEOs and Controlled Groups Update | PBGC v Asahi Tec Corporation |
| Multiple Employers, PEOs and Controlled Groups Update | Agenda for Subcommittee on MEPs PEOs CG & ASG |
| Multiple Employers, PEOs and Controlled Groups Update | Comparison of MEWAs and Open MEPS |
| Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices | |
| Panel Title | Materials Title |
| Administrative Practices Update | Slides: 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 | |
| Panel Title | Materials Title |
| Welfare Benefits Design, EEOC and FMLA Update | Health Care Reform Update: Proposed Regulations Regarding Essential Health Benefits, Actuarial Value, and Accreditation Standards |
| Welfare Benefits Design, EEOC and FMLA Update | Examining New Proposed Regulations on Employer Shared Responsibility Payments |
| Welfare Benefits Design, EEOC and FMLA Update | IRS 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 | |
| Panel Title | Materials Title |
| Employment Tax Issues in Executive Compensation | Slides: Employment Tax Issues in Executive Compensation |
| Employment Tax Issues in Executive Compensation | Impact of Section 409A on Executive Employment Arrangements |
| Employment Tax Issues in Executive Compensation | Panel Outline |
| Employment Tax Issues in Executive Compensation | New Medicare 0.9 Percent and 3.8 Percent Taxes |
| Federal Update | Outline: Federal Update |
| On Hold: What to Tell Your Clients While Waiting for a Final Disposition inthe Quality Stores Case | United States v. Quality Stores, et al. |
| One if by Air; Two if by Sea | One 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 Sea | TAM 201014051 |
| The National Taxpayer Advocate | Summary : The Diminishing Role of the Revenue Officer Has Been Detrimental to the Overall Effectiveness of IRS Collection Operations |
| The National Taxpayer Advocate | Summary: Early Intervention, Offers in Compromise, and Proactive Outreach Can Help Victims of Failed Payroll Service Providers and Increase Employment Tax Compliance |
| The National Taxpayer Advocate | The Diminishing Role of the Revenue Officer Has Been Detrimental to the Overall Effectiveness of IRS Collection Operations |
| The National Taxpayer Advocate | Early Intervention, Offers in Compromise, and Proactive Outreach Can Help Victims of Failed Payroll Service Providers and Increase Employment Tax Compliance |
Energy & Environmental Taxes | |
| Panel Title | Materials Title |
| The Nuclear Reactor Tax Credit, Post-Fukushima | Slides: The Nuclear Reactor Tax Credit, Post-Fukushima |
| Renewable Energy Tax and Grant Updates | Slides: Renewable Energy Tax and Grant Updates |
Estate & Gift Taxes | |
| Panel Title | Materials Title |
| Current Developments | Current Developments in Estate Planning |
| Displaying Value: Special Issues in Valuing Art for Estate, Gift and Income Tax Reporting | Art Is Long, Life Is Short: Estate Planning For the Artist and the Art Collector |
| Home Sweet Home: Planning Issues for Residences | Home Sweet Home: Planning Issues for Residences |
Exempt Organizations | |
| Panel Title | Materials Title |
| Circular 230 Redux: What the Changes Mean for EO Practitioners | Slides: Circular 230 Overview: Proposed Revisions |
| Circular 230 Redux: What the Changes Mean for EO Practitioners | Circular 230 Comment Matrix |
| News from the IRS and Treasury | Outline of Current Regulatory and Other Developments |
| Non-Exempt Nonprofits – Not an Oxymoron | Materials Index |
| Non-Exempt Nonprofits – Not an Oxymoron | Taxability (Other than UBTI) of Exempt/Formerly Exempt/Benefit Corporations |
| Non-Exempt Nonprofits – Not an Oxymoron | Consequences of Revocation: Issues in Calculating “Taxable Income” When Jurisdiction over Entity Moves Out of TE/GE-Exempt Organization Division |
| Non-Exempt Nonprofits – Not an Oxymoron | Chart -- Legal Treatment Of Nonprofit Organizations |
| Non-Exempt Nonprofits – Not an Oxymoron | Scenarios for Discussion |
| Non-Exempt Nonprofits – Not an Oxymoron | Taxation of Revoked Tax-Exempt Organizations: The Synanon Case |
| Non-Exempt Nonprofits – Not an Oxymoron | Internal Revenue Manual – 4.75.31 Conversion of Returns Upon Revocation of Exemption |
| Non-Exempt Nonprofits – Not an Oxymoron | Gen. Couns. Mem. 39813 |
| Non-Exempt Nonprofits – Not an Oxymoron | Slides |
| Single Member LLCs and Exempt Organizations | Use of Single Member Limited Liability Companies by Tax-Exempt Organizations |
| Text It; Tweet It; Blog It; Delete It – Social Media and Exempt Organizations | Social Media Outline with attachments |
Fiduciary Income Tax | |
| Panel Title | Materials Title |
| Post-Mortem Income Tax Issues: A Fiduciary’s Handbook | Post-Mortem Income Tax Issues |
| Post-Mortem Income Tax Issues: A Fiduciary’s Handbook | Recent Updates: Overview of the 3.8% Surtax for Trust and Estates |
| Recent Developments | Recent Developments in Fiduciary Income Tax |
| Turbocharging the Estate Plan | Turbocharging the Estate Plan |
| What Estate Planners Need to Know about Marital Law | A Prenuptial Agreement Primer for the Estate Planning Attorney |
| What Estate Planners Need to Know about Marital Law | Slides: A Prenuptial Agreement Primer for the Estate Planning Attorney |
Financial Transactions | |
| Panel Title | Materials Title |
| Fear and Loathing in Section 1092 | Slides: 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 Issues | Slides: Current Developments and Shop Talk |
| Taxing Derivatives: Do Look-through Rules Work? | Slides: Taxing Derivatives: Do Deemed Ownership Rules Work? |
| Outbound Stock and Asset Transfers | Slides: Foreign Activities of U.S. Taxpayers "Outbound Stock and Asset Transfers" |
Foreign Activities of US Taxpayers | |
| Panel Title | Materials Title |
| Technical Aspects of International Tax Reform Proposals | Slides: Technical Aspects of International Reform Proposals |
Foreign Lawyers Forum | |
| Panel Title | Materials Title |
| FATCA and the Intergovernmental Agreements – The View From the Other Side | FATCA and Intergovernmental Agreements – The View from the Other Side |
Indian Tribal Tax | |
| Panel Title | Materials Title |
| Exploring The Unique Environment of The Tribal-IRS Relationship | Slides: The Tribal-IRS Relationship |
| Exploring The Unique Environment of The Tribal-IRS Relationship | CRS Reviews Indian Tribal Governmental Tax Status Act |
| Exploring The Unique Environment of The Tribal-IRS Relationship | Internal Revenue Manual - 22.41.1 Indian Tribal Governments Outreach |
| Exploring The Unique Environment of The Tribal-IRS Relationship | Internal Revenue Manual - 4.86.1 Indian Tribal Governments Administration |
| Exploring The Unique Environment of The Tribal-IRS Relationship | Overview of Federal Tax Provisions Relating to Native American Tribes and Their Members |
| Exploring The Unique Environment of The Tribal-IRS Relationship | Rev Rul 67-284 |
| Exploring The Unique Environment of The Tribal-IRS Relationship | Rev Rul 94-16 |
| Exploring The Unique Environment of The Tribal-IRS Relationship | Rev Rul 94-81 |
| IRS Enforcement in Indian Country | Streitz Indian Taxation Presentation |
| IRS Enforcement in Indian Country | Attachment A. IRS Protocols for Tribal Contacts |
| IRS Enforcement in Indian Country | Attachment B. Prior Treasury Department Consultation Policy |
| IRS Enforcement in Indian Country | Attachment C. Current Treasury Department Consultation Process |
| IRS Enforcement in Indian Country | Attachment D. Draft Treasury Department Tribal Consultation Progress Report |
| IRS Enforcement in Indian Country | Attachment E. IRS Notice 2012-75 |
| IRS Enforcement in Indian Country | Attachment F. NCAI Requests for Consultation on Trust Per Capita Payments Issue |
| IRS Enforcement in Indian Country | Attachment G. IRS Notice 12-60 |
| IRS Enforcement in Indian Country | Attachment H. NCAI Follow Up Letter on Trust Per Capita Payments Issue |
| IRS Enforcement in Indian Country | Attachment I. Miccosukee Decisions |
Insurance Companies | |
| Panel Title | Materials Title |
| 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 Annuities | Slides: Hedging of Guaranteed Benefits on Variable Annuities |
| Waiting to Exhale: Current Developments From the IRS and Treasury, Including the Treatment of Extracontractual Obligations | Slides: Current Developments: Waiting To Exhale |
Investment Management | |
| Panel Title | Materials Title |
| Current Developments Regarding Tax Issues for Regulated Investment Companies | 1 - Slides: RIC Modernization Act 2010 Defining the “Reasonable Cause and Not Willful Neglect” Standard |
| Current Developments Regarding Tax Issues for Regulated Investment Companies | 2 - RIC Modernization Act 2010 Reasonable Cause Exception Authorities |
| Current Developments Regarding Tax Issues for Regulated Investment Companies | 3 - Slides: Lack of Integration of Sub M and Excise Tax |
| Current Developments Regarding Tax Issues for Regulated Investment Companies | 4 - Lack of Integration of Sub M and Excise Tax Authorities |
| Current Developments Regarding Tax Issues for Regulated Investment Companies | 5 - Slides: RICs and Declarations of Spillback Dividends: Special Issues |
| Current Developments Regarding Tax Issues for Regulated Investment Companies | 6 - RICs and Declarations of Spillback Dividends: Special Issues Authorities |
| Current Developments Regarding Tax Issues for Regulated Investment Companies | 7 - Slides: ICI Updates on U.S. and International Tax Issues |
| Current Developments Regarding Tax Issues for Regulated Investment Companies | 8 - ICI Updates on U.S. and International Tax Issues Authorities |
| Structuring and Operational Issues for Venture Capital Funds | Slides: Structuring and Operational Issues for Venture Capital Funds |
| Structuring and Planning Issues for MLP Investments | Recent Relevant IRS Private Letter Rulings for Master Limited Partnerships |
| Structuring and Planning Issues for MLP Investments | Slides: Structuring and Planning Issues for MLP Investments |
JOINT: Closely Held Businesses and Bankruptcy & Workouts | |
| Panel Title | Materials Title |
| The Exit Strategy from Retirement Accounts for the Financially Challenged: The IRS Collection Process and Bankruptcy Protection | Protection 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 Protection | USA v. Cooper |
| IRS Collection & Bankruptcy Alternatives | IRS Collection & Bankruptcy Alternatives |
| Tales from the Crypt: Dealing with a Decedent’s Tax Fraud | Materials - Tales from the Crypt: Dealing with a Decedent's Tax Fraud |
JOINT: Closely Held Businesses Committee and Civil & Criminal Tax Penalties | |
| Panel Title | Materials Title |
| The ABCs of Summons Enforcement, Including Recent Developments in the Area of 5th Amendment Issues for Closely Held Businesses | Outline: 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 Businesses | Slides: Use, Enforcement, and Defense of IRS Summons |
| Update on LB&I Global High Wealth Group Examinations | Slides: 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 | |
| Panel Title | Materials Title |
| Joint Current International Developments Panel | DRAFT SLIDES: Joint Current International Developments Panel |
JOINT: Individual & Family Taxation and Pro Bono & Tax Clinics | |
| Panel Title | Materials Title |
| Hot Practice Tips for Representing an Individual Taxpayer Before and During an IRS Examination | Slides: Hot Practice Tips for Representing an Individual Taxpayer Before and During an IRS Examination |
| Proposed Changes to the Guidelines for Innocent Spouse Relief | Comments on Proposed Changes to the Guidelines for Innocent Spouse Relief in Revenue Procedure 2003-61 |
| Proposed Changes to the Guidelines for Innocent Spouse Relief | Outline: Proposed Changes to the Guidelines for Innocent Spouse Relief |
| Vanishing Time Limits for Equitable Relief | Vanishing Time Limits for Equitable Relief |
| Vanishing Time Limits for Equitable Relief | Hypotheticals |
| Vanishing Time Limits for Equitable Relief | Additional Materials |
JOINT: Individual & Family Taxation, Standards of Tax Practice and Tax Practice Management | |
| Panel Title | Materials Title |
| Practical and Ethical Strategies in Representing Couples | Panel Materials |
| Practical and Ethical Strategies in Representing Couples | Additional Materials |
JOINT: Teaching Taxation and Tax Policy & Simplification | |
| Panel Title | Materials Title |
| Panel Discussion of We’re Not Broke | Slides: What Tax Professionals should understand about Transfer Pricing |
| Panel Discussion of We’re Not Broke | The “Price of Offshore” Revisited |
| Panel Discussion of We’re Not Broke | Towards Unitary Taxation of Transnational Corporations |
| Panel Discussion of We’re Not Broke | Utopian Visions toward a Grand Unified Global Income Tax |
| The Prospects for Tax Reform in President Obama’s Second Term | Tax Reform Today |
| The Prospects for Tax Reform in President Obama’s Second Term | Slides: Tax Reform - Nellen |
| The Prospects for Tax Reform in President Obama’s Second Term | Slides: Tax Reform: Will It Happen? |
| The Prospects for Tax Reform in President Obama’s Second Term | Slides: Tax Reform |
| The Prospects for Tax Reform in President Obama’s Second Term | Slides: Prospects for Tax Reform in Pres. Obama’s 2nd Term |
| The Prospects for Tax Reform in President Obama’s Second Term | The Time for Tax Reform is Now |
| The Prospects for Tax Reform in President Obama’s Second Term | The Complexity of the Tax Code |
Partnerships & LLCs Clinics | |
| Panel Title | Materials Title |
| Dipping our Toes in Foreign Waters | Slides: Dipping Our Toes in Foreign Waters: Outbound International Partnership Issues |
| Dipping our Toes in Foreign Waters | The Schizophrenic Partnership: IRS Issues Notice 2010-41 Addressing Partnership Blocker to Subpart F Inclusions |
| Dipping our Toes in Foreign Waters | Notice 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 Funds | Slides: Fun with a “D”: Management Fee Waivers and Clawback Issues for Private Equity and Hedge Funds |
Pro Bono & Tax Clinics | |
| Panel Title | Materials Title |
| Issues Involving Cancellation of Debt Income | Slides: Issues involving Cancellation of Debt Income |
| Presentation of Annual Report to Congress | Outline: Report from the National Taxpayer Advocate on her 2012 Annual Report to Congress |
| Tax Issues in Immigration Law | Slides: New ITIN rules THE IRS response to TIGTA reports |
| Tax Issues in Immigration Law | Slides: Taxing Immigrants: A Primer |
| Tax Issues in Immigration Law | Case Studies on Immigration and Tax |
| Tax Issues in Immigration Law | Community Interpreter Internship Syllabus |
| Tax Issues in Immigration Law | Additional Handouts |
| Tax Issues in Immigration Law | Slides: Strategies for Delivering Tax Services to Rural Migrants |
Real Estate | |
| Panel Title | Materials Title |
| Hot Topics | Slides: Hot Topics |
| New Guidance Regarding Impact of State Law on Classification of Section 1031 Exchange Property | IRS Muddies the Like-Kind Waters in Guidance Considering State Law Classification |
| New Guidance Regarding Impact of State Law on Classification of Section 1031 Exchange Property | Slides: State Law Characterization and Section 1031 |
| Noncore REITs and Other Hot REIT Issues | Slides: Developing Trends in REIT Conversions and Related Issues |
| Update on the 3.8% Tax on Net Investment Income and its Impact on Real Estate | Section 1411 Proposed Regulations |
| at to Expect in the Post-Election Environment | Slides: Tax Legislative Outlook |
S Corporations | |
| Panel Title | Materials Title |
| Recent Developments in State and Local Taxation of S Corporations | Slides: Recent Developments in State and Local Taxation of S Corporations |
| S Corporation Compensation Reclassification Risks | Materials: S Corporation Compensation Reclassification Risks |
| S Corporation Compensation Reclassification Risks | Slides: S Corporation Compensation Reclassification Risks |
| Subchapter S Valuation: To Tax Effect, or Not to Tax Effect, Is Not Really the Question | Paper: 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 Question | Slides: 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 Corporations | Slides: The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations |
Sales, Exchanges & Basis | |
| Panel Title | Materials Title |
| Current Developments in Sales, Exchanges and Basis, Including Sections 1031 & 1033 | Current Non-Section 1031 Developments |
| Current Developments in Sales, Exchanges and Basis, Including Sections 1031 & 1033 | IRC § 1031/1033 Current Developments |
| Everything You Need to Know About the Tax Issues in National Federation of Independent Business v. Sebelius | Course Materials |
| Ponzi Scheme Update: Tax Treatment of Clawbacks and Other Items | Before It's Too Late, Reconsidering the IRS Relief for Madoff Losses |
| Ponzi Scheme Update: Tax Treatment of Clawbacks and Other Items | Slides: Ponzi Scheme Update: Tax Treatment of Clawbacks and Other Items |
| Tax Issues Involving Flawed Securitizations | Slides: Tax Disqualification Issues Facing REMICs |
Section Program | |
| Panel Title | Materials Title |
| Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation | Federal Estate, Gift and Generation-Skipping Transfer Tax Update |
| Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation | Recent Developments in Federal Income Taxation |
| Healthcare Reform Update | 2013 Medicare Taxes For Investors, Business Entities & Their Owners, Trusts & Estates - Outline 1 |
| Healthcare Reform Update | Proposed IRS Regulations On PPACA Shared Responsibility (Employer Mandate) Provisions |
| Healthcare Reform Update | 4980H proposed regulation |
| Healthcare Reform Update | Add'l Medicare Tax Proposed Reg |
| Healthcare Reform Update | Net Investment Income Proposed Regs |
| Healthcare Reform Update | Net Investment Income Tax FAQ |
| Healthcare Reform Update | PCORTF fee reg |
| Healthcare Reform Update | Questions and Answers for the Additional Medicare Tax |
| Healthcare Reform Update | Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act |
Standards of Tax Practice | |
| Panel Title | Materials Title |
| An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies | Panel Materials - An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies |
| An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies | Slides - An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies |
| Ethical Issues in Federal Tax Practice – The Government Perspective | Slides: Ethical Issues in Federal Tax Practice – The Government Perspective |
| The Proposed (or Final) Amendments to Circular 230 | Comments on Proposed Reg- 138367-06 Relating to Practice Before the Internal Revenue Service |
| The Proposed (or Final) Amendments to Circular 230 | The 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 230 | IRS Office of Professional Responsibility Disbars Return Preparer Accused of Filing False Returns |
| The Proposed (or Final) Amendments to Circular 230 | Motion 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 230 | IRS Statement on Court Ruling Related to Return Preparers |
| The Proposed (or Final) Amendments to Circular 230 | Loving |
| The Proposed (or Final) Amendments to Circular 230 | Loving Stay Motion |
State & Local Taxes | |
| Panel Title | Materials Title |
| Current Trends in Economic Nexus for State Income Taxes | Slides: 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 Workforce | Appendix |
| State and Local Taxation of the Mobile Workforce | Slides: The Stalled Mobile Workforce Project |
| State Tax Administration in Theory and in Practice: Evaluating Transparency in State Tax Administration | Measuring Transparency In State Tax Administration |
| State Tax Administration in Theory and in Practice: Evaluating Transparency in State Tax Administration | Transparency in State Taxation — Part I: Discretionary Authority |
| State Tax Administration in Theory and in Practice: Evaluating Transparency in State Tax Administration | Transparency in State Taxation, Part 2: Legislative Process and Letter Rulings |
Tax Accounting | |
| Panel Title | Materials Title |
| Current Developments | Current Developments Materials |
| Hot Topics in Healthcare | Slides: Hot Topics in Healthcare |
| Tangible Property Regulations Update | Slides: Tangible Property Regulations Update |
Tax Exempt Financing | |
| Panel Title | Materials Title |
| New Rules for Tax-Exempt Financing Tax Lawyers Under Circular 230; Rules of Ethics Applicable to Opinions Given by Tax-Exempt Financing Tax Lawyers | Circular 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 Lawyers | Excerpts 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 Lawyers | Proposed 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 Lawyers | ABA Comments to Circular 230 Proposal |
| Treasury and Internal Revenue Service Update | Treasury 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 | |
| Panel Title | Materials Title |
| Planning for Intangible Property Migration in an Uncertain Environment | Slides: Planning for Intangible Property Migration in an Uncertain Environment |
US Activities of Foreigners & Tax Treaties | |
| Panel Title | Materials Title |
| Inbound Mergers and Acquisitions: Recent Trends and Considerations | Slides: Inbound Mergers & Acquisitions: Recent Trends & Considerations |
| Understanding Tax Issues for Foreign Persons Investing in US Real Estate | Slides: Foreign Persons Investing in U.S. Real Estate |
