2014 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.

 

 

2014 Midyear Meeting - Phoenix, AZ

Panel TitleMaterials Title

Administrative Practice

Appeals: New InitiativesSlides: IRS Appeals Update
Appeals: New InitiativesSlides: IRS Appeals Update - Hypotheticals
LB&I's New IDR Enforcement ProcessSlides: LB&I's New IDR Enforcement Process

Affiliated & Related Corporations

Current Developments in Consolidated ReturnsSlides: Current Developments in Consolidated Returns
Exploring the Intersection of the Federal Consolidated Return Rules and State TaxSlides: Exploring the Intersection of the Federal Consolidated Return Rules and State Tax

Banking & Savings Institutions

Advising Banks and Savings Institutions in 2014Slides: Advising the Banking & Savings Institution in 2014
Basel III and deferred tax assets: there's no such thing as a "mere timing difference"Slides: Basel III & DTAs: there is no such thing as a mere timing difference
Final and Proposed Section 871(m) Regulations & FATCA UpdateSlides: Dividend Equivalent Withholding §871(m) New Proposed Regulations
Final and Proposed Section 871(m) Regulations & FATCA UpdateSlides: Final FFI Agreement: Revenue Procedure 2014-10

Bankruptcy & Workouts

Dealing with State Tax Authorities in BankruptcySlides: Dealing with State Tax Authorities in Bankruptcy
OPR: The IRS Collection Process and Bankruptcy Tax IssuesSlides: The IRS Collection Process and Bankruptcy World
OPR: The IRS Collection Process and Bankruptcy Tax IssuesSupplement: Miscellaneous Links
OPR: The IRS Collection Process and Bankruptcy Tax IssuesOutline: Survey of Dischargeability - Recent Cases - 2013
OPR: The IRS Collection Process and Bankruptcy Tax IssuesOutline: Challenging the Underlying Liability in CDP
Section 336(e) and Bankruptcy RestructuringSlides: Section 336(e) and Bankruptcy Restructuring

Capital Recovery & Leasing

Current Developments Report and Update on Pending GuidancePaper: Current Developments
Experimenting with the Definition of a Prototype: A look at the Proposed Section 174 RegulationsOutline: Technical Outline Addressing IRC § 174 Proposed Regulations
Experimenting with the Definition of a Prototype: A look at the Proposed Section 174 RegulationsSlides: Update on Research and Development Incentives
Tangible Property Regulations Update – Transition Guidance Discussion, FAQs, and an Update on the Proposed RegulationsOutline: Tangible Property Regulation Guidance Panel Discussion
True Lease Analysis – Lease vs. Sale/FinancingSlides: True Lease Criteria: Standards Applied to End of Term Options

Civil & Criminal Tax Penalties

Oil and Water: Mixing the Ambiguous Economic Substance Doctrine with the Onerous Economic Substance PenaltySlides: Oil and Water: Mixing the Ambiguous Economic Substance Doctrine with the Onerous Economic Substance Penalty
Reports of Subcommittees on Important DevelopmentsOutline: Developments in International Tax Enforcement
Reports of Subcommittees on Important DevelopmentsOutline: Voluntary Disclosure and Compliance Update
Reports of Subcommittees on Important DevelopmentsSlides: IRS Investigations & Practices Subcommittee Report
Reports of Subcommittees on Important DevelopmentsOutline: Important Developments - Criminal
Reports of Subcommittees on Important DevelopmentsOutline: Legislative & Administrative Developments Subcommittee
Trends in Criminal Tax EnforcementPaper: The Tax Division's First Klein Conspiracy
Trends in Criminal Tax EnforcementOutline: Trends in Criminal Tax Enforcement
US Department of Justice, Tax Division UpdateOutline: U.S. Department of Justice, Tax Division Update: Current Enforcement Priorities in Civil and Criminal Tax Litigation Matters

Closely Held Business

Collection Issues Surrounding the BSA under Title 26 and Title 31Outline: Collection Aspects of International Cases
Criminal Aspects of the Bank Secrecy ActSlides: Criminal Aspects of the Bank Secrecy Act
Entity Selection and Corporate Governance for Closely-Held BusinessesOutline: Choice of Entity - A Fresh Look
The Civil Aspects of the Bank Secrecy Act and its Impact on Closely Held BusinessesSupplement: Electronic Code of Federal Regulations
The Civil Aspects of the Bank Secrecy Act and its Impact on Closely Held BusinessesPaper: The Gathering Storm: IRS Enforcement of the Bank Secrecy Act
The Civil Aspects of the Bank Secrecy Act and its Impact on Closely Held BusinessesSupplement: Guidance for the Insurance Industry on Filing Form 8300
The Taxation of the Purchase and Sale of Closely-Held Businesses and Professional PracticesOutline: Sale Of A Business Or Practice & Sale Of Personal Goodwill

Corporate Tax

C Corporation-to-REIT ConversionsSlides: Conversions from C corporations to REITs (and other restructuring)
Corporate Tax Issues in Private Equity TransactionsSlides: Corporate Tax Issues In Private Equity

Court Procedure & Practice

Ethical Issues Arising from Conflicts of Interest in LitigationSlides: Ethical Issues Arising from Conflicts of Interest in Litigation
Hot Topics in Captive Insurance and Risk Pooling ArrangementsSlides: Hot Topics in Captive Insurance and Risk Pooling Arrangements
Important Developments: Recent Tax Litigation and Controversy Updates, including Supreme Court Decision in United States v. WoodsOutline: Important Developments: Recent Tax Litigation and Controversy Updates, including Supreme Court Decision in United States v. Woods
Reaching Agreement - Settling Tax Cases in LitigationOutline: Materials for Reaching Agreement - Settling Tax Cases in Litigation
Step One of All Tax Litigation: Burden of ProofOutline: Step One of All Tax Litigation: Burden of Proof

Diversity

Post-Windsor Decision Health and Retirement Plans Guidance from Treasury and IRSSupplement: Same-Sex Marriage Laws in the United States
Providing Pro Bono Legal Services. Our Ethical Obligation to the ProfessionSlides: Providing Pro Bono Legal Services: Our Ethical Obligation to the Profession
Tax Implications of Immigration CasesSlides: Tax Implications of Immigration Cases
Tax Implications of Immigration CasesOutline: Tax Implications of Immigration Cases

Employee Benefits

Administrative Practices UpdateOutline: Voluntary Correction Program – Interim Amendment Failures
Administrative Practices UpdateSlides: Employee Benefits Administrative Practices Update
Administrative Practices UpdateSupplement: Discussion of Changes Made by Revenue Procedure 2014-6
Benefit Plans and Private Equity Funds: Problems at the IntersectionSlides: Employee Benefit Plans and Private Equity: Sun Capital Partners vs Teamsters Pension Fund
Continued Aftermath of the Supreme Court’s DOMA DecisionSlides: Continued Aftermath of the Supreme Court's DOMA Decision
Defined Benefit Plans UpdateSlides: Global DB Audit Issues
Defined Benefit Plans UpdateOutline: Recent PBGC Legislative/Regulatory Developments
Defined Benefit Plans UpdateSlides: PBGC Update
Defined Benefit Plans UpdateSlides: PPA Sunset
Defined Benefit Plans UpdateSlides: Defined Benefit Plans Update
Defined Contribution Plans UpdateOutline: IRS Issues In-Plan Rollover Guidance (Notice 2013-74)
Distributions UpdateAgenda: Uncashed Checks
Distributions UpdateSlides: Stale-Dated / Uncashed Checks "The Billion Dollar Question"
ESOP UpdatePaper: Subcommittee on ESOP Update
Executive Compensation, Fringe Benefits & Federal Securities Law UpdateSlides: Change in Control Report
Executive Compensation, Fringe Benefits & Federal Securities Law UpdateSlides: Private Equity Phantom Carried Interest Plan Design and 409A Compliance
Hot TopicsOutline: Summary of Selected Guidance Issued by the Dept. of the Treasury and the IRS during the Past Year
Legislative UpdateSupplement: Legislative Update: October 2013
Litigation UpdateOutline: Employee Benefits Litigation Update
Managing Pension Plan Liabilities: De-Risking and Shared Risk StrategiesSlides: Pension De-Risking: Recent Developments
Managing Pension Plan Liabilities: De-Risking and Shared Risk StrategiesSlides: Shared Risk Plans and the New Brunswick Experience
Mergers & Acquisitions UpdateSlides: 280G Discussion
Multinational Employee Benefits & Compensation IssuesSlides: Puerto Rico Qualified Retirement Plans Overview & Recent Developments
Multiple Employers, PEOs and Controlled Groups UpdateSlides: Subcommittee on Multiple Employers, PEOs and Controlled Groups Update
Multiple Employers, PEOs and Controlled Groups UpdateOutline: Proposals for Offering Voluntary Operational Guidelines For MEPs
Pay Ratio Disclosures for the Proxy SeasonSlides: Dodd-Frank Update - CEO Pay Ratio Disclosure and Other Compensation-Related Developments
Welfare Plan and EEOC, FMLA and Leaves Issues UpdateOutline: Employee Benefits Welfare Plan and EEOC Issues Update
Welfare Plan and EEOC, FMLA and Leaves Issues UpdateOutline: Square Pegs and Round Holes
Welfare Plan and EEOC, FMLA and Leaves Issues UpdateOutline: Selected Issues in FAQs Part XVIII and Notice 2013-54

Employment Taxes

Employment Taxes On Tipped Employees: Navigating Tip Credits, Tip Reporting and Service ChargesSlides: ABA - Tips
Employment Taxes On Tipped Employees: Navigating Tip Credits, Tip Reporting and Service ChargesSlides: Employment Taxes on Tipped Employees: Navigating Tip Credits, Tip Reporting and Service Charges
Federal UpdateOutline: ABA Federal Tax Update
Quality Stores—The Final CountdownSlides: ABA Quality Stores
Tax Controversy: How will the IRS's New IDR Enforcement Policies Impact Employment Tax Examinations?Slides: Tax Controversy: New IDR Enforcement Process

Energy & Environmental Taxes

Hot Topics In the Energy IndustrySlides: Renewable Energy Tax and Grant Updates

Estate & Gift Taxes

Audit Proofing Family Limited PartnershipsOutline: Avoiding the Tax-Man's Dance: Audit Minimizing Partnerships and LLCs
Audit Proofing Family Limited PartnershipsSlides: Avoiding the Tax-Man's Dance: Audit Minimizing Partnerships and LLCs
Captive Insurance Companies and the Closely Held BusinessSlides: Use of Captive Insurance Companies in Estate Planning
Current DevelopmentsPaper: Current Developments in Federal Transfer Taxes
Self-Settled Asset Protection TrustsOutline: Planning and Defending Domestic Asset-Protection Trusts

Estate & Gift Taxes and Fiduciary Income Tax

Administering Unusual Assets with Purpose TrustsOutline: Administering Unusual Assets

Exempt Organizations

Earmarking -- Substance and FormOutline: Earmarking: Substance and Form
Exempt Organizations and Employment TaxesSlides: Exempt Organizations and Employment Taxes
Hot Topics in UBITSlides: Hot Topics in UBIT
News from the IRS and TreasurySlides: Current Developments
Small Charities -- Problems and SolutionsSupplement: Small Nonprofit Consultation Checklist
Small Charities -- Problems and SolutionsLetter: Reinstatement Procedures for Automatically Revoked Exempt Organizations
Small Charities -- Problems and SolutionsArticle: Nonprofit Board Duties: Program Oversight
Small Charities -- Problems and SolutionsSupplement: New Retroactive Reinstatement Process(es)/Opportunities Under Revenue Procedure 2014-11

Fiduciary Income Tax

Current DevelopmentsOutline: Recent Developments in Fiduciary Income Tax
Income and Estate Tax Aspects of Joint Trusts in Community Property and Common Law JurisdictionsSlides: Income and Wealth Transfer Tax Aspects of Joint Trusts in Community Property and Common Law Jurisdictions
Residency and Domicile for State Income Tax and Transfer Tax PurposesPaper: The Role of "Residence" and "Domicile" in State Income and Transfer Tax Planning
Residency and Domicile for State Income Tax and Transfer Tax PurposesAppendix: The Role of "Residence" and "Domicile" in State Income and Transfer Tax Planning - Appendix

Financial Transactions

Bitcoin and Other Virtual Currencies: What are They, and How are they Taxed?Slides: Bitcoin and Other Virtual Currencies
Section 871(m) UpdateSlides: Section 871(m): Final and Proposed Regulations

Foreign Activities of US Taxpayers

Currency Issues of Controlled Foreign Corporations, including Treasury CentersSlides: Currency Issues of Controlled Foreign Corporations, including Treasury Centers
Investments in United States Property under Section 956 Developments and Unresolved IssuesSlides: Investments in US Property under Section 956 - Developments and Unresolved Issues
Joint Current Developments: FAUST, FLF, Transfer Pricing and USAFTTSlides: Joint Current Developments

Foreign Lawyers Forum

Current International IP tax issues– BEPS, patent boxes and moreOutline: UK Corporate Intangibles Tax Rules
Redomiciliations, cross-border acquisitions and holding company regimeSlides: FLF E--Redomiciliations, Cross-Border Acquisitions and Holding Company Regime

Indian Tribal Tax

 
Federal Indian Law and Policy, The Nuts & BoltsSlides: Federal Indian Law for Tax Nerds
State and Tribal Taxing Jurisdictions, A Complicated RelationshipOutline: Indian Law and Taxation
State and Tribal Taxing Jurisdictions, A Complicated RelationshipSlides: Taxation in Indian Country: Federal Policy and Tax Law

Individual & Family Taxation

Presentation of Annual Report to CongressReport: 2013 Annual Report to Congress, Executive Summary
Return Preparer Review after Loving and Under the PAC IRS Review ProcessSlides: Return Preparer Oversight after Loving and under the PAC Review Process

Insurance Companies

Information Reporting on Life Insurance ProductsSlides: Information Reporting on Life Insurance Products
International Developments Affecting InsurersSlides: International Insurance Subcommittee
Recent Developments Affecting Insurers and their PolicyholdersOutline: Overview of Developments Affecting Insurance Companies and Policyholders

Investment Management

Selected Tax Issues Regarding Operational Aspects of Private Investment FundsSlides: Selected Tax Issues Regarding Operational Aspects of Private Investment Funds
The Intersection of Private REITs and Partnerships and Other Issues Related to the Formation and Operation of Private REITsSlides: The Private REIT: Selected Tax Issues
The Structure Games (Pooled Investment Entity Edition)Slides: The Structure Games - Pooled Investment Entity Edition
The Structure Games (Pooled Investment Entity Edition)Slides: The Structure Games - Pooled Investment Entity Edition: The Legal Landscape

Partnerships & LLCs

Considering Retirement in Arizona? Payments to Retiring Partners under Section 736Slides: Payments Made to Retiring Partners -- Sections 736 and 1411
Hot Topics in Partnership TaxationSlides: Hot Topics in Partnership Taxation
Is Private Equity Engaged in the Conduct of a Trade or Business?Slides: Is Private Equity Engaged in the Conduct of a Trade or Business?
Prickliest Provisions in a Partnership Agreement: AllocationsSlides: Prickliest Provisions in a Partnership Agreement: Allocations

Pro Bono & Tax Clinics

Eliminating Errors and Penalties in Tax Return PreparationSlides: Eliminating Errors and Penalties in Tax Return Preparation
National Taxpayer Advocate’s Annual Report to CongressReport: 2013 Annual Report to Congress, Executive Summary
The Qualified Offer Rule & Attorney Fees: Where Do We Stand?Slides: Qualified Offer Rule

Real Estate

Compensation or Capital Gain? An Earn-Out PrimerSlides: Compensation or Capital Gain?
Controlling REIT Spin-OffsSlides: REIT Spin-offs
So What if We’re Related?Slides: So What if We're Related?
When Do Options Transfer Tax Ownership?Slides: When Do Options Transfer Tax Ownership

S Corporations

Current DevelopmentsOutline: Current Developments in the Federal Income Taxation of S Corporations
Section 179 and Controlled Groups: Are S Corporations In or Out?Slides: Section 179 and Controlled Groups: Are S Corporations In or Out
Tax Rules Applicable to S Corporation ESOPsOutline: Tax Rules Applicable to S Corporation ESOPs
Tax Rules Applicable to S Corporation ESOPsSlides: Tax Rules Applicable to S Corporation ESOPs

Sales, Exchanges & Basis

Current Developments in Sales, Exchanges & BasisOutline: Current Non-Section 1031 Developments
Current Developments in Sales, Exchanges & BasisOutline: IRC § 1031/§ 1033 Current Developments
North Central and its Implications for Related Party ExchangesSlides: North Central and Related Party Like-Kind Exchanges
Sales, Exchanges, and Basis in the World of Section 1411Supplement: Sales, Exchanges, and Basis in the World of Section 1411
Stress Testing “Cash Out” Section 1031 TechniquesOutline: Cash Out Strategies in Section 1031 Exchanges
To Wed or Not to Wed? The Tax Consequences of Windsor for Intervivos Property TransactionsPaper: To Wed or Not to Wed

Standards of Tax Practice

Ensuring Compliance With Circular 230 and Other Practice Rules: What’s a Manager to Do and What Happens if They Don’t?Slides: Ensuring Compliance With Circular 230: Responsibilities of Firm Management
Ethical Issues in Federal Tax Practice—The Government PerspectiveSlides: Ethical Issues in Federal Tax Practice - The Government Perspective
Teaching Ethics—Incorporating Ethical Issues from Basic Tax to LLM CoursesOutline: Comments on Incorporating Ethics at All Levels of tax Education
Teaching Ethics—Just Whose Responsibility Is It?Slides: Teaching Ethics: Just Whose Responsibility Is It, Anyway?

State & Local Taxes

Are Modern Trading Posts Off the Reservation: Do New Federal Regulations Create Tax Havens for non-Native American Businesses Conducted on Tribal Lands?Slides: The Impact of the New BIA "Pre-emption Regulations" on State and Local Tax
Are Modern Trading Posts Off the Reservation: Do New Federal Regulations Create Tax Havens for non-Native American Businesses Conducted on Tribal Lands?Slides: HEARTH ACT and DOI Leasing Regulations on Tribal Lands
Private Enforcement of State Tax Laws: False Claims Acts and The Transaction Tax Overpayment Model ActSlides: Private Enforcement of State Tax Laws
Private Enforcement of State Tax Laws: False Claims Acts and The Transaction Tax Overpayment Model ActPaper: The Model Transactional Tax Overpayment Act
State Taxation of Pass-Through Entities and Their OwnersPaper: State Taxation of Partnership Entities and their Corporate Owners
State Taxation of Pass-Through Entities and Their OwnersSlides: State Taxation of Pass-Through Entities and their Owners
The Rush to Extend the Sales Tax to Services: Is It Over or Just Beginning?Slides: The Rush To Extend the Sales Tax to Services:
Is it Over or Just Beginning?

Tax Accounting

Current DevelopmentsOutline: Current Developments
Guidance Project Addressing the Treatment of Advance PaymentsSlides: Advance Payments
Tangible Property Regulations: Practical ImplicationsOutline: Tangible Property Regulations: Practical Implications.

Tax Exempt Financing

Legislative, Treasury and Internal Revenue Service UpdateOutline: Legislative, Treasury and Internal Revenue Service Updates
Proposed Arbitrage RegulationsPaper: Section Comments to Proposed Arbitrage Regulations

Tax Policy & Simplification

The Role of the Internal Revenue Service in the Administration of Social Welfare PolicyOutline: The Role of the Internal Revenue Service in the Administration of Social Welfare Policy
The Role of the Internal Revenue Service in the Administration of Social Welfare PolicySlides: IRS Administration of Social Welfare Policy

Teaching Taxation

Section Program: Current DevelopmentsPaper: Federal Estate, Gift and Generation-Skipping Transfer Tax Update
Section Program: Current DevelopmentsPaper: Recent Developments in Federal Income Taxation

Transfer Pricing

New IRS Revenue Procedures for the Competent Authority and APA processesOutline: Notice 2013-78 and Notice 2013-79
Update on Transfer Pricing Issues in Developing CountriesSlides: Update on Transfer Pricing Issues in Developing Countries

US Activities of Foreigners & Tax Treaties

FATCA for Those on This Side of the Ocean/BorderSlides: FATCA for Those on This Side of the Ocean/Border
Inbound Financings: Issues and Planning StrategiesSlides: Inbound Financings: Issues and Planning Strategies

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