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.
Materials by Committee
Administrative Practice
Inside the Compliance Assurance Process (CAP) Program: Is it Right for Your Clients?
- Pre-Compliance Assurance Process (The Pre-CAP) MOU
- Form 14234: Pre-CAP and CAP Application Form
- CAP Permanency in a Nutshell
- Panel Presentation
- Compliance Assurance Process (The CAP) MOU
- Compliance Assurance Process (CAP) - Frequently Asked Questions (FAQs)
- Compliance Assurance Process (CAP) Internal Revenue Manual (IRM) Sections
I Knew my Taxes Were Complicated – But an Engineer and a Computer Specialist?
Important Developments
- Southgate Master Fund, L.L.C. v. United States of America
- WFC Holdings Corporation v. United States of America
- Pritired 1, LLC, Principal Life Insureance Company, Tax Matters Partner and Principal Life Insurance Company vs. United States of America
- Guidance for Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties
- Selected Recent Developments in Administrative Practice
Affiliated & Related Corporations
Current Developments in the Consolidated Returns Area
Banking & Savings Institutions
Trade or Business Issues Affecting Off-Shore Hedge Funds
The Economic Substance Doctrine: Where are We Now and What to Do About It?
Capital Recovery & Leasing
Electric Utility Capitalization Principles
The Continuing Saga of Non-Taxable Grants, Incentives, and Inducements
Current Developments Report and Update on Pending Guidance
Civil & Criminal Tax Penalties
Immigration Issues in Criminal Tax: What You Don't Know Can Hurt You
Reports of Subcommittees on Important Developments
- Recent Trends in IRS Enforcement Activity Regarding the Special Enforcement Program (“SEP”)
- Panel Paper
- International Tax Enforcement Continues to Rise
- Important Developments-Criminal
Get Ready for the Newest Specialized IRS Civil Agents: the SBSE Fraud/Bank Secrecy Act/Anti-Money Laundering Agent
- Exhibit D: Overview of BSA
- Exhibit C: In Re Grand Jury Investigation M.H.
- Exhibit B: Form 13726, Summary of Examination Findings and Recommendations
- Exhibit A: Anti-Money Laundering Program - Examination Procedures
FATCA Update
Update on the Committee's Participation in the Tax Section Task Force on Tax Reform
Immigration Issues in Criminal Tax: What You Don't Know Can Hurt You
- Panel Slides
- 2011 WL 3608726 (U.S.) (Appellate Brief) Supreme Court of the United States
- 2011 WL 3608726 (U.S.) (Appellate Brief) Supreme Court of the United States
Corporate Tax
Current Developments in Corporate Taxation
Court Procedure & Practice
Current Developments
Using Qualified Offers To Resolve Tax Cases
Requests for Admissions in Federal Tax Litigation
Common Evidentiary Issues in Tax Cases, Part II
Joint Defense Agreements, Part II
Remarks on Behalf of the Office of Chief Counsel, Internal Revenue Service
Employee Benefits
Employee Benefits Distributions Update
Employee Benefits EEOC, FMLA and Military Leave Update
Employee Benefits Legislative Update
- White House Deficit Reduction Plan Includes PBGC Premium Increases - Memo
- Legislative Update for July 2011 - Memo
- Joint Select Committee on Deficit Reduction Could Consider Benefits and Compensation Issues - Memo
Employee Benefits Mergers & Acquisitions Update
Employment Taxes
Employment Tax Consequences of an International Workforce – Moving Employees into and out of the US
Federal Update
When are Partners Employees for Employment Tax Purposes?
Energy and Environmental Taxes
Mining Hot Topics
Exempt Organizations
Exempt Organizations and Healthcare Reform under the Patient Protection and Affordable Care Act
- Panel Materials
- Section 501(r): Community Health Needs Assessment Requirement
- IRS Issues Interim Guidance Concerning Community Health Needs Assessment, Tax Planning for Accountable Care Organizations
- 2011-52
An Examination of Group Exemption Procedures
- Panel Slides
- Exempt Organizations: Group Exemptions – Creating a Higher Degree of Transparency, Accountability, and Responsibility
Fiduciary Income Tax
Crummey Issues
Grantor Trust Roundup
Recent Developments/Tax Reform Project Update
Financial Transactions
Schering-Plough and its Impact on Financial Transactions
New Swap Regulations and Other Current Developments
Foreign Activities of US Taxpayers
Principal Structures Are Not Just for Manufacturers – Planning for Service Providers Under Subpart F
Foreign Tax Credits
- Foreign Tax Credits: Focus on Section 901(m)
- Nature Abhors a Splitter: The FTC Splitter and Indirect FTC Rules
Individual & Family Taxation
Income Tax Consequences for Same Sex Couples and Domestic Partnerships
IRS Collection – Is the Pendulum in the Right Place?
Insurance Companies
Developments Affecting Captives and Non-Traditional Risk Transfer Arrangements
- IRS Guidance: FET Applies on a Cascading Basis
- Update: FET Applies on a Cascading Basis
- Panel Slides
Discussion of the Impact of New IRS Audit, Appeals and Controversy Efforts on the IRS/Treasury Guidance Process
Developments Regarding the Definition of "Cash Surrender Value" under Section 7702
Investment Management
Issues for RICs Investing in Commodities
- Proposed CLN Rev. Proc.
- Panel Materials
- Memo - RE: ICI Letter To IRS On Suspension Of Rulings To Funds Seeking Commodities Exposure
- Memo Attachment - RE: Suspension of Rulings to RICs Seeking Commodities Exposure
- Follow-Up Letter to IRS on CLN Issue
FATCA and Investment Funds
- FATCA Update for U.S. Investment Funds (And Their Advisors)
- FATCA Update for U.S. Investment Funds (And Their Advisors)
Joint: Closely Held Businesses (TX) and Business Planning Group (TE)
State Income Tax of Trusts Holding Business Interests
- State Income Tax of Trusts Holding Business Interests - Outline
- Supplemental Materials – State Income Tax of Trusts Holding Business Interests
Uplifting Gifting - Using Additional Gift, Estate and Generation-Skipping Tax Exemption to Maximize Business Succession Planning
Non-Tax Issues in Business Succession Planning
- Non-Tax Succession Planning— For Dental Practices
- Conflicting Fiduciary Duties When Trusts and Estates Own Interests in Closely Held Businesses
- Non-Tax Considerations in Family Business Succession Planning
"GOTCHA" Transactions in the Formation, Structure and Conveyance of Business Interests
State Decoupling Issues in Business Succession Planning
Joint: Employee Benefits (TX & TE)
Ethics Issues in Employee Benefits
Healthcare Reform: A Regulatory and Legislative Update
- Treasury Department Proposes Rule Implementing Premium Tax Credits Under the Affordable Care Act
- Labor, Health and Human Services, and Treasury Departments Issue Proposed Regulations Implementing the “Summary of Benefits and Coverage” Requirement under the Affordable Care Act
- DOL, HHS, and IRS Issue Amendments to Rules Relating to Internal Claims and Appeals and External Review Processes under the Affordable Care Act
Hot Topics
- Health Care Reform Update: Proposed Regulations and other Guidance on Summary of Benefits and Coverage
- Health Care Reform Update: Recent Guidance on Claims and Appeals and External Review Procedures
Service Provider Fee Disclosures
- Discussion Questions Regarding 408(b)(2) and Form 5500 Schedule C
- 408(b)(2) Disclosures to Plan Sponsors/Fiduciaries: Timing Rules
- Panel Slides
Serving Two Masters: Complying with Code Section 409A v. Good Corporate Governance Practices
Discussion of ABA Tax Section Comments on Tax Reform and Simplification Regarding Employee Benefits and Executive Compensation
Employee Benefits Controlled Groups and Employee Status Update
Employee Benefits Defined Benefit Plans Update
- Single Employer Defined Benefit Plan Funding and Benefit Restriction Notice Requirements
- Recent PBGC Regulatory Developments (January 1, 2010, to September 30, 2011)
Employee Benefits Defined Contribution Plans Update
- Tatum v. R.J. Reynolds Tobacco Company
- US Labor Department's EBSA to re-propose rule on definition of a fiduciary
- Brown v. Continental Airlines, Inc.
Employee Benefits Executive Compensation, Fringe Benefits and Securities Law Update (TX & TE)
Employee Benefits Fiduciary and Litigation Update
Employee Benefits Administrative Practices Update
- 26 CFR 601.201: Rulings and determination letters
- Defined Contribution Listing of Required Modifications and Information Package (LRM)
- Cash or Deferred Arrangement (CODA)
- ABA 2011 Year-End Amendment List
Employee Benefits Welfare Benefits Design, Funding and Regulation Update
- State Insurance Exchanges: Eligibility and Enrollment Functions in the Non-Group Market
- Culturally and Linguistically Appropriate Provisions Slides
- Culturally and Linguistically Appropriate Provisions Materials
- Treasury Department Proposes Rule Implementing Premium Tax Credits Under the Affordable Care Act
- Labor, Health and Human Services, and Treasury Departments Issue Proposed Regulations Implementing the “Summary of Benefits and Coverage” Requirement under the Affordable Care Act"
- DOL, HHS, and IRS Issue Amendments to Rules Relating to Internal Claims and Appeals and External Review Processes under the Affordable Care Act
- Proposed Regulations Issued on the Summary of Benefits and Coverage and Uniform Glossary that Are Required to Be Provided by March 23, 2012
Joint: Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE)
Perpetual Dynasty Trusts: Tax Planning and Jurisdiction Selection
Foreign Reporting for Estate Planners
Current Developments
Where Do We Go From Here: A Comparison of Alternatives When You and the IRS Agree to Disagree
Joint: Exempt Organizations (TX) and Charitable Planning & Organizations (TE)
Uniform Act on Protection of Charitable Assets
Tax Issues Affecting Disaster Relief
Gift Tax on Transfers to Section 501(c)(4) Organizations
- Panel Materials List
- The Law Remains Unsettled on Gift Taxation of Section 501(c)(4) Contributions
- Federal Election-Related Activity by Tax-Exempt Organizations
- Revenue Ruling 82-216 (1982-2 C.B. 220)
- Guidance for SB/SE Estate and Gift Tax and TE/GE Exempt Organizations (July 7, 2011)
- Panel Slides
- Once and Future Gift Taxation of Transfers to Section 501(c)(4) Organizations: Current Law, Constitutional Issues and Policy Considerations
- Constitutional Issues Cloud the Gift Taxation of Section 501(c)(4) Contributions
- Comments of the Individual Members of the Exempt Organizations Committee''s Task Force on Section 501(c)(4) and Politics
Joint: FAUST, FLF, Transfer Pricing & USAFTT (TX)
Joint International Developments Panel
Joint: Young Lawyers Forum & Diversity (TX)
Financial Statements 101 - An Accounting Primer for Tax Attorneys
Low Income Taxpayers
Identity Acquisition and Theft
Update on Issues of Interest to Low Income Taxpayers
Benefits and Pitfalls of Advanced Pre-Refund Compliance Checks
- Panel Outline
- National Taxpayer Advocate Hearing on Improper Payments in the Administration of Refundable Tax Credits (May 2011)
- Tax Refunds: Enhanced Prerefund Compliance Checks Could Yield Significant Benefits (GAO)
- GAO Description
Partnerships & LLCs
Revenue Ruling 99-6, a Trap for the Unwary
Let's Make the World a Better Place –Partnerships and Social Responsibility
- Special Issues For Tax-Exempt Organizations as Investors in Pass-Through Entities
- Special Issues For Tax-Exempt Organizations as Owners of Passthrough Entities
- L3C Draft Letter Response
- L3C Draft Letter
- L3C Draft Appendix
Pro Bono
Update On Pro Bono Matters
Identity Theft vs. Fourth Amendment and Taxpayer Privacy Rights: The Case of Amalia's Translation and Tax Services in Greeley, CO
Real Estate
Hot Topics with Government Panelists
Real Estate Funds: To Block or Not to Block?
Selected Distressed Debt Issues
S Corporations
S Corporations and Cooperatives
Current Developments
Planning with Electing Small Business Trust
Sales, Exchanges & Basis
Tax Issues Affecting Ponzi Scheme Recoveries: The Long Journey for Victims of Bernie (and Others)
Check-the-Box Bramblett
Section 1031 Developments and Congress
Non-§1031 Current Developments
Section Program: Joint: Fiduciary Income Tax (TX) and Income & Transfer Tax Planning Group (TE)
The Lawyer's Guide to Shacking Up Wisely: Marriage, Domestic Partnerships, Civil Unions – The Developing Legal Landscape
Next Generation Disputes in the Family Business: Navigating the Remedial, Ethical and Tax Quagmires – A Case Study
Section Program: Low Income Taxpayers (TX)
Representing Your Client Before the Tax Court
Section Program: The Tax Estate Planning Considerations Group (TE)
Supercharge Your Estate Planning Techniques with Investment, Tax, Asset Protection and "Second-Look" Engineering
Ethical Issues in Federal Tax Practice - The Government Perspective
Standards of Tax Practice
Recent Amendments to Circular 230 and Their Potential Impact on Practitioner Disciplinary Proceedings
Ethical Issues Arising in Alternative Dispute Resolution
State & Local Taxes
Home is Where Your House Is, Or Is It? - Personal Income Tax Issues Related to Residency and Domicile
State Tax Credits & Incentives – State Tax Issues – Federal Tax Treatment
The MTC's Model SUT Notice & Reporting Act
- Report of the Hearing Officer Model Sales & Use Tax Notice and Reporting Statute (May 2011)
- Draft Model Sales & Use Tax Notice and Reporting Act (June 2011)
Daily Deal Coupons - Consumer Protection & Unclaimed Property Laws
Tax Accounting
Accounting Method Opportunities and Issues that Arise as part of E & P Planning
Unraveling the Maze of Deferred Expenses under Sections 248, 195, and 709
Tax Exempt Financing
Enforcement – Procedural and Ethical Issues and Approaches for Practitioners in Audits
Department of Treasury and IRS Update
Tax Simplification and Tax Reform for Tax-Exempt Bonds
The Role of the Tax-Exempt Bond Issuers in Conduit Financings; IRS Response to the 2010 ACT Report
Tax Policy and Simplification
Perspectives on Tax Reform: The Challenges of Enacting and Implementing Tax Simplification
- Perspectives on Tax Reform: The Challenges of Enacting and Implementing Tax Simplification Background Paper
- Comprehensive Tax Reform: Has its Time Come Around Again?
Tax Practice Management
Ethics in Estate Planning
- Estate Planning for Elderly Clients With Competency Issues
- Ethics in Estate Planning: Issues Raised when Attorneys are asked to Serve as Fiduciaries for Clients
Transfer Pricing
Transfer Pricing and Fair Value: And the Twain Shall Never Meet?