Section Meeting

2018 Fall Tax Meeting

Hyatt Regency Atlanta, Atlanta, GA, October 4-6


Materials for the 2018 Fall Tax Meeting are available for download in PDF format.

At the close of the meeting, attendees who registered for the 2018 Fall Tax Meeting may access the materials by logging in with the ABA username and password used to register for the meeting.

To retrieve a forgotten ID or password, please follow the prompts at You may also contact the ABA Member Service Center at or 1-800-285-2221.

Materials by Committee

Administrative Practice

Important Developments in Administrative Practice

Should You Advise Your Client to Agree to Extend the Statute of Limitations?

The New Partnership Audit Rules, Round I – The Partnership Audit: How You and the IRS Figure It Out

Affiliated and Related Corporations

Current Developments in Affiliated & Related Corporations

When Consolidated Groups and Insurance Collide

Banking and Savings Institutions

Banks and the International Provisions of the 2017 Tax Act

Cryptoasset Taxation: Where Are We Now? A Comparative Discussion Across Jurisdictions

US Tax Rules Pertaining to Hybrid Instruments

Capital Recovery and Leasing

A Discussion on Bonus Depreciation - Unpacking the Guidance

Current Developments and Update on Pending Guidance

Civil and Criminal Tax Penalties

It’s All About the Penalties

OVDP – End of an Era

Reports of Subcommittees on Important Developments

Skills Workshop: Preparing Your Client (the Taxpayer) for the Government Interview

Closely Held Businesses and Business Planning Group

199A; Update and Analysis

Beyond Powell – Examining the Important Provisions of Operating Agreements and Shareholder Agreements

Partnership Audit Rules; Update and Practical Considerations

Section 1202: Tax Planning in Light of the 2017 Tax Act

Collection Workshop

How to Represent Taxpayers in Collection Matters from the Final Notice Through Trial and Resolving Collection Issues Facing Estates, Donors, and Donees
Co-Sponsored by: Pro Bono & Tax Clinics and Tax Collection, Bankruptcy & Workouts

Corporate Tax

Current Developments in Corporate Tax

Special Issues Under the 2017 Tax Act

Court Procedure and Practice

A Primer on the Use of Experts in Tax Court
Roundtable Discussion

Current Developments in Court Procedure and Practice

Litigating Whistleblower Cases in the Tax Court

Post-Mayo Jurisprudence: Challenging Regulations after Mayo

The New Partnership Audit Rules, Round 2 – After the Partnership Audit, How You and the IRS Fight it Out


Diversity in the Workplace: Recruiting and Retaining Diverse Professionals

Preparing Fiduciary Income Tax Returns and Representing Clients on Audit

The 21st Century Family: Drafting Wills and Trusts in a Time of Changing Concepts of Family, Gender, and Race

The “Nanny Tax”: Taxation of Household Employees

Employee Benefits

Administrative Practices
Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices

Corporate Counsel Forum
Employee Benefits Corporate Counsel Forum

Defined Benefit Plans Update
Subcommittee on Defined Benefit Plans

Defined Contribution Plans Update
Subcommittee on Defined Contribution Plans

Department of the Treasury/Internal Revenue Service Hot Topics

Distributions Update
Tax Section Subcommittees on Distributions and the RPTE Section Subcommittee on IRA Accounts & Plan Distributions

Employment and Benefits Developments for Non-Traditional Employment Relationships

ESOP Update
Subcommittee on ESOPs

Executive Compensation, Fringe Benefits and Federal Securities Law Update
Subcommittee on Employee Benefits Executive Compensation, Fringe Benefits, and Federal Securities Law

Exempt Organization and Governmental Plans Update
Subcommittee on Exempt Organization and Governmental Plans

Fiduciary Responsibility & Plan Investments Update
Subcommittee on Fiduciary Responsibility & Plan Investments Update

Impact of #MeToo on Executive Compensation - Clawbacks and More

Legislation & Litigation Update
Subcommittee on Employee Benefits Legislation & Litigation

Mergers & Acquisitions Update
Subcommittee on Mergers & Acquisitions

Moving Expenses, Meals, Commuting, Entertainment, Leave, De Minimis Fringes, 162(m) and 83(i), Oh My! Your Just-in-Time 2017 Tax Act Guidance Primer

Multiple Employers, PEOs and Controlled Groups Update
Subcommittee on Multiple Employers, Professional Employer Organizations (PEOs) and Controlled and Affiliated Service Groups

Proxy Season: Looking Back, Looking Forward

The Affordable Care Act: What Now? What Next?

Welfare Plans and EEOC, FMLA and Leaves Issues Update
Subcommittee on Welfare Plan and EEOC, FMLA and Leaves Issues

Employment Taxes

Correcting Payroll Tax Reporting Errors and Grossing Up Payments for Tax Consequences

IRS Employment Tax Update

  • Materials are forthcoming and will be posted when available.

Tax Consequences of Employment Settlements and Judgements

The Competing Tensions Driving Independent Contractor Status for Service Providers

Energy and Environmental Taxes

Energy Industry Tax Updates Roundtable

Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE) (JT)

Can the IRS Have Their Cahill and Eat Yours Too?

Current Developments in Estate & Gift Taxes and Income & Transfer Tax Planning

Installment Sales to Spousal Grantor Trusts

Wealth Transfer Planning with Carried Interests in Funds

Estate & Gift Taxes and Fiduciary Income Tax (TX) and Income & Transfer Tax Planning Group (TE) (JT)

2018 Update of Privileges and Fiduciaries

Creating the Ultimate Digital Asset Estate Planning Checklist
Young Lawyers Subcommittee

Exempt Organizations

Charitable Giving Under the 2017 Tax Act: Keeping and Creating Charitable Contribution Deductions
Co-Sponsored by: RPTE Charitable Group

Crowdfunding Charity: Navigating the Legal Landscape
Co-Sponsored by: RPTE Charitable Group

News from the IRS and Treasury

Shared Employment, Reporting of Compensation and Its Implications for Exempt Organizations Employment

Unrelated Business Taxable Income: Current Developments in Enforcement Activity

Fiduciary Income Tax (TX) and Income & Transfer Tax Planning Group (TE) (JT)

Can You Keep a Secret? Working with Silent Trusts

Current Developments in Fiduciary Income Tax and Income & Transfer Tax Planning

The Tax Overhaul for Tax Exempts: What You Need to Know Now

Trusts and the Transition Tax: Everything You Didn’t Want to Know

Financial Transactions

Banks and the BEAT

Section 163(j) Update

Treatment of Certain Debt Related Fees

Foreign Activities of U.S. Taxpayers

BEAT – Not for the Faint of Heart

Repatriation of Foreign Earnings (Real or Imagined, Voluntary or Otherwise)

Individual and Family Taxation

How Can I Live On That?

SALT Deduction Limit Workarounds Panel

What Is the APA's Role in Tax Administration?

Insurance Companies

Insurance Tax “Real Time” Topics

International Tax Reform and Insurance Companies

Traps for the Unwary: Life Insurance Valuation and Transfer Issues

Investment Management

Cryptocurrency Funds

Post-Tax Reform Planning for Cross-Border Investments by Private Funds

State Tax Issues for Investment Funds

LLCs and LLPs Subcommittee of Partnerships & LLCs

A Discussion Concerning the States’ Reactions to the New Partnership Audit Rules (NO CLE)

  • There will not be materials for this panel.

The Conservation Easement Battle Rages On (NO CLE)

Partnerships and LLCs

Code Section 163(j)

Code Section 199A

Hot Topics in Partnerships & LLCs

International Hot Topics

Pro Bono and Tax Clinics

Canceled Debt Reporting Under IRC Section 6050P

Jurisdictional Ramifications of a CDP Request

Tax Consequences of Student Loan Debt Cancellation

Real Estate

Overview of Qualified Opportunity Zones

Special Issues Applicable to Timber

Structuring Foreign Investment in US Real Property After Tax Reform

What is a Real Estate Trade or Business?

S Corporations


Important Developments in the Federal Income Taxation of S Corporations

Section 199A Proposed Regulations

Sales, Exchanges and Basis

Current Developments Relating to Sales, Exchanges & Basis

Deferring and Reducing Income Taxes on Non-Opportunity Zone Property, and Eliminating Income Taxes on Opportunity Zone Property, Through Qualified Opportunity Funds

Handling Associated Personal Property in Real Estate Contracts

The Interaction of Section 267, 1031 and 1033 with the Qualified Business Income Limitation

Standards of Tax Practice

Ethical Issues in Federal Tax Practice – The Government Perspective

Ethical Issues Regarding the Partnership Representative
Co-sponsored by: Administrative Practice

Ethical Pitfalls in Representing Spouses

State and Local Taxes

Impact of Wayfair on Services and International Taxes

Improving the Sales Tax Systems: COST Report on the Best and Worst of Sales Tax Administration (NO CLE)

SALT Deduction “Workaround” Responses to the 2017 Tax Act

What Is a Remote Seller to Do in This Post-Quill World?

Tax Accounting

Accounting Method Changes for Controlled Foreign Corporations

Current Developments in Tax Accounting


Revenue Recognition and Section 451

Tax Bridge on the Road

Cross-Species Mergers: Key US Federal Income Tax Considerations
Sponsored by: Young Lawyers Forum and Diversity; Co-sponsored by: Corporate Tax

Is There Another Side to the Story? - C Corporation Versus Passthrough Form
Sponsored by: Young Lawyers Forum and Diversity

Planning for Litigation in the Captive Insurance Area
Sponsored by: Young Lawyers Forum and Diversity; Co-sponsored by: Court Procedure & Practice

State and Local Tax: Wayfair and the Way Forward
Sponsored by: Young Lawyers Forum and Diversity; Co-sponsored by: State & Local Taxes

Tax Policy and Simplification

Transparency Tide or Transparency Tsunami? The New Wave of Global Reporting Rules and IRS Tools to Unearth Foreign Financial Accounts: FATCA, FBAR, & CRS developments in the wake of OVDP and Swiss Bank Program

Tax Practice Management

The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement

Teaching Taxation

Global Trends in Transparency and Disclosure
Co-Sponsored by: Foreign Lawyers Forum

Transfer Pricing

Impact of BEPS and US Tax Reform on Transfer Pricing Controversies: Preparing for the Storm

The Great BEAT Debate

U.S. Activities of Foreigners and Tax Treaties

Advanced FIRPTA: Traps to Keep You Up at Night

Inbound Financing After Tax Reform - What Now?

Young Lawyers Forum

New Law, New Regulations, New Practitioners: Legal and Ethical Obligations When Advising Taxpayers in an Uncertain Legal Environment