TaxIQ

2008 Joint Fall CLE Meeting

September 11-13, San Francisco, CA

Thoughtful Insights. Useful Analysis.

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 PDF 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.

2008 Joint Fall CLE Meeting, San Francisco, CA

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Administrative Practice

Deference to Regulations

LMSB Update: The Industry Issue Focus Initiative - Managing & Resolving Tiered Issues

Selected Recent Developments in Administrative Practice

Affiliated & Related Corporations

Final Unified Loss Rules

Panel PowerPoint

Banking and Savings Institutions

Selected Mark-to-Market, Character and Interest Expense Limitation Considerations in a Wayward Economy

Panel PowerPoints

Capital Recovery & Leasing

Tax Incentives for Solar Energy

Civil and Criminal Tax Penalties

Reports of Subcommittees: Important Developments – Criminal Penalties

International Audits-Current Enforcement Concerns and Common Issues

Important Developments on Civil Penalties: May 2008 through August 2008

Panel PowerPoint

Corporate Tax

Panel PowerPoints

Court Procedure and Practice

Panel PowerPoint

Court Procedure and Practice

The Burden of Proof in the Circuit Courts of Appeal

Summary of Current Developments

Panel PowerPoint

Employee Benefits

Wrap Plans - Revisited, Revised and Resurrected

Section 409A: A Nightmare of Complexity

Section 409A and SERPs

Plan Audits & DOL Enforcement Activities

Overview of Final 403(B) Regulations – What You Need to Know and Do Before the End of 2008

Let’s Explore Rev Proc 2007-71

Equity-based Awards Under Section 409A

Employment Agreements - Section 409A Issue List

EBSA Update – Summer 2008

Drafting Plans and Agreements in Light of 409A: Strategies and Tactics

Panel PowerPoint

Employee Benefits: Section Program

Landmark Genetic Nondiscrimination Legislation

Impact on Welfare Benefit Plans of Proposed EBSA Regulation on Reasonable Contracts or Arrangements Under Section 408(b) (2)

Employer-Sponsored Health Plans Under Non-Privacy Health Plan Provisions of HIPAA

Metropolitan Life v. Glenn

Conflict of Interest in Claims Decisions – A Critical Analysis of MetLife v. Glenn

Employment Taxes

Important Developments

Exempt Organizations

Changing Standards for Exempt Organization Executive Benefits

Fiduciary Income Tax

Recent Developments in Fiduciary Income Tax

Panel PowerPoint

Partnership Interests Owned by Trusts and Estates: Understanding the Rules and Optimizing the Opportunities

Navigation Through Life Settlements

International Update

Financial Transactions

Panel PowerPoints

Foreign Activities of US Taxpayers

Tax Consequences of the Declining Economy: Managing Gains & Losses Under Sections 267, 987 and 988

Panel PowerPoint

Individual and Family Taxation

Federal & California Tax Issues for Non-Mainstream California Couples

Comparison of Senator Obama’s and Senator McCain’s Tax Plans

Individual and Family Taxation: Section Program

Rejecting Tax Exceptionalism in Judicial Deference and Administrative Procedure Act Compliance

General Outline

Current and Emerging Battlegrounds

Investment Management

Panel PowerPoints

Joint: Closely Held Businesses (TX) and Business Planning Group (RPTE)

The Trustee's Role in the Management of Business Entities

Conflicting Fiduciary Duties When Trusts and Estates Own Interests in Closely-Held Businesses

Joint: Closely Held Businesses (Tax), S Corporations (Tax) and Business Planning Group (RPTE)

Aircraft Ownership: Tax & Legal Considerations

Current Developments In Federal Taxation of S Corporations

S Corporation Tax Update

Appendix A Comparison of C Corporation ESOPs to S Corporation ESOPs

Panel Outline

Joint: Diversity (Tax) and (PRTE)

Estate Planning for the Baby Boomers: Will They Have Estates to Plan?

Case Study: Planning for Multiple Generations - The Family of Robert and Regina Retired

Panel Outline

Joint: Diversity Committee (Tax), Tax Practice Management (Tax) & Young Lawyers (Tax & RPTE)

Excerpts from the 2007 NALP Foundation Attorney Attrition Study

Career Planning Worksheet

Joint: Estate & Gift Taxes (Tax) and Income & Transfer Tax Planning Group (RPTE)

International Update

Emerging Issues Under the Twin UPIAS: Uniform Prudent Investor Act (1994): Restatement (Third) of Trusts and Uniform Principal and Income Act (1997)

When Things Don’t Go As Expected: 3 Case Studies

What Every Estate Planner Needs to Know About Hedge Funds

Entering the Crescent of Enlightenment: A Quick Tour of Community Property''s Utopian World

Current Developments in Estate Planning

Joint: Estate & Gift Taxes (Tax) and Income & Transfer Tax Planning Group (RPTE): Section Program

Who Trumps Whom: When Can Taxpayers Ignore IRS Guidance?

Joint: Exempt Organizations (TX) and Charitable Planning & Organization Group (RPTE)

Uniform Prudent Management of Institutional Funds Act

UMIFA and UPMIFA: The Law of Endowments

The Uniform Unincorporated Nonprofit Association Act – A Vast Improvement and A First Attempt at International Collaboration

Supporting Organizations That Change Their Status

Supporting Organizations and Other Entities (After the Pension Protection Act)

Is Mission Investing Prudent?

FSP No. FAS 117-1, Endowments of Not-for-Profit Organizations

Low Income Taxpayer Clinic Workshop

Barriers that Representatives Face in EIC Audits

EITC Audit Barriers and the Impact of Representation on EITC Audit Outcomes

Identify Theft Can Steal The Show - IRS Efforts to Protect Taxpayer Privacy

Discussion Points for EITC Audits

Low Income Taxpayers

Collections Financial Standards Changes

Military Tax Update

Partnerships & LLCs

Topic Outline

Economic Effect Rules and PIP

Panel PowerPoints

Appendix I - Legal Effectiveness of Backdating for State Law Purposes: Formation Issues

Pro Bono

Panel Outline and Materials

Real Estate

New Proposed Regulations Under Section 460 Provide Relief for Condo Developers

Free Money – Or Is It? The Taxation of Nonpartner Capital Contributions

Panel PowerPoints

Important Developments

Recourse or Nonrecourse

Sales, Exchanges & Basis

Section 1031 Exchanges Involving Real Property: Why Should State Law Matter?

Sales and Exchanges: Current Developments

Economic Substance Doctrine - Not Just For Shelters Anymore

Tax Treatment of Business Recoveries

Section Program: Employee Benefits

Landmark Genetic Nondiscrimination Legislation

Impact on Welfare Benefit Plans of Proposed EBSA Regulation on Reasonable Contracts or Arrangements Under Section 408(b) (2)

Employer-Sponsored Health Plans Under Non-Privacy Health Plan Provisions of HIPAA

Conflict of Interest in Claims Decisions – A Critical Analysis of MetLife v. Glenn

Metropolitan Life v. Glenn

Section Program: Estate and Gift Tax Committee, Income and Transfer Tax Planning Group (RPTE)

Who Trumps Whom: When Can Taxpayers Ignore IRS Guidance?

Section Program: Fiduciary Responsibility, Administration and Litigation Committee – Employee Benefit Plans and Other Compensation Arrangements Group (RPTE)

Reporting & Disclosure of Fees for 401(k) and Other Plans – Coping with the New Regime

Emerging Standards: ERISA Service Contracting & Fee Disclosure

Section Program: Individual and Family Taxation

Rejecting Tax Exceptionalism in Judicial Deference and Administrative Procedure Act Compliance

General Outline

Current and Emerging Battlegrounds

Section Program: Insurance and Financial Planning Committee - Non-Tax Estate Planning Considerations Group (RPTE)

Panel PowerPoint

Section Program: Plan Transactions and Terminations Committee – Employee Benefit Plans and Other Compensation Arrangements Group (RPTE)

Panel PowerPoint

PBGC Outline

Section Program: Tax Litigation and Controversy Committee – Income & Transfer Tax Planning Group (RPTE) Estate and Gift Taxes and Fiduciary Income Tax Committees (Tax)

McCord to Holman: Five Years of Value Judgments

Section Program: Teaching Taxation, Tax Practice Management, Task Force on Patenting Tax Strategies (Tax) and Real Property, Trust and Estate Law (RPTE)

Patented Tax Strategies – Ethical Concerns for the Tax Lawyer and Estate Planner

Introduction to Tax Strategy Patents

Section Program: USAFTT, FAUST, Transfer Pricing (TX) and Income & Transfer Tax Planning Group (RPTE)

Panel PowerPoint

Standards of Tax Practice

Panel Outline

State and Local Taxes

The Economic Substance Doctrine in State and Local Taxation

Panel Paper

Debt Workouts and IRC §382: Could You Be Squeezed Between State and Federal Tax Laws?

Tax Accounting

Panel Paper

Transfer Pricing

Panel PowerPoints

US Activities of Foreigners and Tax Treaties

Tax Planning for International Entertainers and Athletes

Artists and Entertainers- A Subset unto Their Own

Panel PowerPoint