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2010 Joint Fall CLE Meeting

September 23-25, Toronto, ON

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.

2010 Joint Fall CLE Meeting, Toronto, ON

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Administrative Practice

Back-to-Basics: IRS Appeals

Future of International Enforcement in the Burgeoning Global Economy

Important Developments

IRS' Global High Wealth Industry - What to Expect and When

Affiliated & Related Corporations

Consolidated Tax Attributes - A Discussion about OFLs and DCLs

Current Developments in Consolidated Returns

Banking & Savings Institutions

Past, Present and Future of Equity Swaps

REMIC Update and Other Emerging Issues

The Effect of Increased Reporting on US Borrowing Activities, Foreign Investors and the Shadow Banking System

Capital Recovery & Leasing

Current Developments Report and Update on Pending Guidance

Civil & Criminal Tax Penalties

Civil Tax Penalty Abatements - Fact or Fiction?

Reports of Subcommittees on Important Developments

Sensitive Issue Examination - Is Tweel Still Relevant?

The Quiet Revolution - FATCA and Bank Secrecy

Corporate Tax

Current Developments

US-Canadian Cross-Border Transactions

Court Procedure & Practice

Litigating The Application Of Anti-Tax Avoidance Statutes – Learning From The Canada Experience

Recent Developments

US and Canada Approaches To Litigating Cross-Border Transactions

Roundtable: What Works and What Doesn’t? Resolving Tax Disputes in the US and Canada

Employee Benefits

Executive Compensation - A Review of Selected Issues

Form 5500 Update: EFAST2 Electronic Filing System, Expanded Schedule C Reporting and Other Important Changes

Hot Employee Benefits Topics

Implementing Health Care Reform

Employee Benefits Subcommittee on Defined Benefit Plans

Employee Benefits Defined Benefit Plans Update

Employee Benefits Subcommittee on Foreign and International Issues

Employee Benefits International Update

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

Employee Benefits Administrative Practices Update

Employee Benefits Subcommittees on Executive Compensation and Fringe Benefits and Federal Securities Laws Issues

Employee Benefits Executive Compensation, Fringe Benefits and Securities Law Update

Employee Benefits Subcommittees on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans

Employee Benefits Welfare Benefits Design, Funding and Regulation Update

Employment Taxes

Advanced Employment Tax Audit Techniques

Canadian and Cross Border Employment Tax Issues

Payments of US Source Income to Non-US Persons

Exempt Organizations

Citizens United: Implications of Corporate Political Free Speech for the EO Sector

Colleges and Universities – Current Audit Activity and What We Have Learned from the IRS Interim Report

Expenditure Responsibility: Ten Puzzling Practical Problems

The Effect of Health Care Reform on Hospitals

Fiduciary Income Tax

Recent Developments

Rethinking Roth IRA Conversions in 2010

Financial Transactions

Anschutz and Calloway: Finding the Owner of Publicly Traded Stock

Swaps and Stock Loans: The Latest on Dividend-Equivalent Payments

Foreign Activities of US Taxpayers

Doing Business in Canada: What US Multinationals Need to Know

Economic Substance Codification – Issues for US Multinational Taxpayers

Individual & Family Taxation

Tax Consequences of Disasters

Insurance Companies

Canadian Taxation of Insurance Companies and Current Cross-Border Insurance Issues

Update on Recent Tax Guidance Affecting Insurance Companies and Products

Investment Management

Implications of Proposed Carried Interest Legislation

Partnership Allocations

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

Co- Ownership in Professional Practices- A Taxing Problem

Practical and Tax Issues in Shutting Down a Closely Held Business with Tax and Non-Tax Debts

Primer on Tax Aspects and Mechanics of Entity Conversions

Joint: Business Planning Group (TE), Closely Held Businesses (TX) and S Corporations (TX)

Choice of Entity in Light of New and Proposed Legislation

Important Developments

International Tax Aspects of Cross Border Business of Closely Held Businesses in Canada

Joint: Estate & Gift Taxes (TX) and Income & Generation Skipping Transfers Committee of the Income and Transfer Tax Planning Group (TE)

Tax Apportionment Clauses: Friend or Foe

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

Current Developments

Expatriation Under Section 877A's Mark-To-Market System, and What Notice 2009-85 Did and Did Not Tell Us

Tax Issues in International Philanthropy

Joint: Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittee

How to Develop an Estate Planning Practice

Joint: FAUST, Transfer Pricing & USAFTT (TX)

Joint International Developments Panel

Joint: Young Lawyers Forum & Diversity (TX)

Are You (Too) Confident About Your Tax Opinions? 

LLCs And LLPs Subcommittee of Partnerships & LLCs

LLC's and Partnerships: Recent Canadian Tax Developments - What Works and What Does Not

Low Income Taxpayers

History of Low Income Tax Clinics

How to Start a Low Income Tax Clinic

Partnerships & LLCs

Don't Get Carried Away by Carried Interests

Economic Substance in Partnership Transactions--Is it the Chicken Little of Legitimate Tax Planning?

Hot Topics in Partnerships

Real Estate

Debt Modifications -- New Developments in a Still Recovering Economy

Real Estate Roll-Up Transactions -- How Much Has Changed?

The Grass Is Greener -- Inbound and Outbound Investments in US and Canadian Real Estate

Sales, Exchanges & Basis

Codification/Clarification of Economic Substance - The Rubber Meets the Road in Common Transactions

Current Non-Section 1031 Developments

Like-Kind Exchange Current Developments

The 2011 Tax Increases Are Comne - Carpe Diem

Section Program: Joint: Estate & Gift Taxes (TX and TE)

Donee Selection and Practical Consideration Under Petter Formula Allocation Clauses

Section Program: Joint: Low Income Taxpayers, Administrative Practice, Court Procedure and Practice, Individual & Family Taxation and Pro Bono

Innocent Spouse: Administrative and Litigation Issues on Innocent Spouse Cases

Section Program: Tax Exempt Financing and Exempt Organizations

Structuring Innovative Management Contracts for Bond Financed Projects

Standards of Tax Practice

Ethical Issues in Federal Administrative Tax Practice

Ethics and the Codification of Economic Substance

State & Local Taxes

Current and Thorny Unclaimed Property Issues

Executive Committee Reports on Current SALT Issues Part 2: Are We There Yet?: Getting to 50 State Tax Tribunals -- An Update on the Model Tax Tribunal Act

Luncheon: New Breed of Amazon "Taxes" - - Colorado's Clever Twist

Purchasing Digital Products – A Comparison of Canadian and US Taxes

Recent State Challenges to Related Party Transactions and the Success or Lack Thereof: Business Purpose, Sham and Economic Substance Assertions Abound

Tax Accounting

Accounting Method Issues Arising with respect to Losses and Bad Debts

Distinguishing Non-Deductible Fines and Penalties from Deductible Business Expenses

Recent Developments in Tax Accounting Methods

Tax Exempt Financing

Legal Issues Related to the Paid Preparer Requirements for Forms 8038

The Issue Price Conundrum

Tax Practice Management

Beyond the Basics: Understanding Financial Statements for Tax Lawyers

Teaching Taxation

Employing Stock: US and Foreign Taxation of Employee Stock Options

Transfer Pricing

US - Canada Hot Transfer Pricing Issues

US Activities of Foreigners & Tax Treaties

Codification of Economic Substance -- Can we Predict the Future by Looking at the Past? 

Pitfalls and Benefits of Foreign Corporation using LLCs in the US