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2012 Joint Fall CLE Meeting

September 13-15, Boston, MA

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.

Materials by Committee

Administrative Practice

Important Developments

The IRS in 2012: The State of the Union

Through the Looking Glass (Part I): Opting Out of the OVDI Penalty Structure—What Happens Now?

Transferee Liability

Affiliated & Related Corporations

A Primer on Consolidated Return Basics: Membership and Group Continuance.

Banking & Savings Institutions

Current Developments in State and Local Taxation of Financial Institutions

Capital Recovery & Leasing

Current Developments Report and Update on Pending Guidance

Issues and Considerations InvolvingTenant Improvement Allowances

Tangible Property Regulations-Ongoing Implementation Issues

Civil & Criminal Tax Penalties

Flaws in the Façade: The Anti-Injunction Act After NFIB v. Sibelius and Cohen v. United States

Getting Paid and Staying Paid: How Alternate Charges in Tax Cases Can Put Your Fees and Client's Assets At Risk of Forfeiture.

Kovel and Tweel: How Much Vitality Do They Still Have in Sensitive Examination Matters?

Reports of Subcommittees on Important Developments

Corporate Tax

Interesting Private Letter Rulings and Other Current Developments

Section 367 – Part II

Court Procedure & Practice

Hot Topics in Trust Fund Litigation.

Important Developments

Litigating Section 7408 Actions

Through the Looking Glass (Part II): Litigating FBAR Penalties

Roundtable Discussion: Evidentiary Issues in Tax Litigation

Employee Benefits

Executive Compensation: Getting Ready for 2013

Employee Benefits Subcommittee on ESOPs


Employee Benefits ESOP Update

Employee Benefits Subcommittee on Litigation

Employee Benefits Litigation Update

Employee Benefits Subcommittee on Multiple Employers, PEOs and Controlled and Affiliated Service Groups

Employee Benefits Multiple Employers, PEOs and Controlled Groups Update

Employment Taxes

Accidental Expat/Employees

Northeast Tax Update

Section 530 – An In Depth Analysis

Exempt Organizations

Counseling and Representing Churches and Other Religious Organizations

Election Year Issues for Exempt Organizations

Financial Transactions

Federal Income Tax Withholding Update-FATCA & 871(m): Practical Applications, Observations and Implications for Global Capital Markets.

Foreign Activities of US Taxpayers

Outbound Intangible Transfers

Recent Developments in International Mergers & Acquisitions

Individual & Family Taxation

A Disabled Client and the Tax Code – Some Gems. What every Tax Practitioner and Controversy Attorney Should Know In Order to Properly Represent Their Clients

Insurance Companies

How Does One Clearly Reflect Income From an Arrangement that the IRS Believes Is Not Insurance?

If Diversification is the Goal, Why Are Sections 817(h) and 851(b) (3) So Different? Or Are They?

Investment Management

RICs and Commodity Market Exposure: Available Investment Options in the Current Climate

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

Chapter 14 Overview with Planning Implications

Defined Values Clauses--How Simple Can They Be After Wandry?

Issues in Dividing Up and Transferring Property Out of Professional Corporations and Partnerships

Structuring Buyouts for Retiring Professionals

Joint: Employee Benefits and Employee Benefit Plans and Other Compensation Arrangements Group (TE)

Ethical Concerns for the ERISA Attorney

Health Care Reform in the Wake of the Supreme Court Ruling

Open Multiple Employer Plans (MEPs): Benefits and Issues

Joint: Employee Benefits Subcommittee on Defined Benefit Plans (TX), Distributions (TX), and the Plan Transactions and Terminations Committee (TE)

Employee Benefits Distributions and Defined Benefit Plans Update

Joint: Employee Benefits Subcommittee on Executive Compensation, Fringe Benefits and Securities Law (TX) and Nonqualified Plans Subcommittee (TE)

Employee Benefits Executive Compensation, Fringe Benefits and Securities Law Update

Joint: Employee Benefits Subcommittee on Mergers and Acquisitions (TX) and Plan Transactions and Terminations Committee (TE)


Employee Benefits Mergers & Acquisitions Update

Joint: Employee Benefits Subcommittee on Welfare Plan Design, EEOC, FMLA and Leaves Issues (TX) and Cafeteria Plans and Reimbursement Accounts (TX) and Subcommittee on Welfare Plans (TE)

Employee Benefits Welfare Benefits Design, EEOC and FMLA Update

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

Current Developments


Planning in the Face of Uncertainty Including Last Minute, 4th Quarter Strategies

S Corporations: What an Estate Planner Should Know

Joint: Exempt Organizations (TX) and Charitable Planning Group (TE)

Ethical Issues for EO and Charitable Gift Planning Lawyers

Private Foundations:  Practical Considerations in Addressing Excise Tax Consequences

Joint: FAUST, FLF, Transfer Pricing & USAFTT

Joint Current International Developments Panel

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

Just When You Thought It Couldn't Get More Difficult: Advanced Income Taxation of Trusts And Estates.

Recent Developments

Trustee Selection: Finding the Best Fit

Unraveling Family Limited Partnerships.

Joint: Tax Practice Management and Estate & Gift Taxes (TX)

Paralegals: Everything You Need to Know about Using Them in Your Practice

Partnerships & LLCs

Geminate: Can a Partner also be an Employee?

Hot Topics

What? This Old Stuff? Section 197 Planning for Partnerships

Pro Bono & Tax Clinics

Decisions and Rulings Impacting Low Income Taxpayers

Representative Capacity

Real Estate

Deal With It: Managing Dealer v. Investor Status

Going from Bad to Worse – The Mechanics and Tax Consequences of Clawback Arrangements

UBTI or Not UBTI – Tax-Exempt Investor Issues

We're Not Quite Out of the Woods Yet: Current and Continuing Debt Workout Issues

S Corporations

Current Developments

Proposed Back-to-Back Loan Regulations

Section 469 – Passive Activity Rules and S Corporations

The Section 1411 "Medicare Tax" and S Corporations

Sales, Exchanges & Basis

Current Non-Section 1031 Developments.

Everything You Wanted to Know About Like-Kind Exchanges—Open Mic!

Is It Treated as a Sale? Something Else? – Part III: Issues Surrounding Tax Ownership of US Residential Mortgage Debt.

Professor Jensen Speaks His Mind on the Supreme Court's Decision in National Federation.

The 2013 Tax Increases Are Coming – Carpe Diem!

Section Program: Closely Held Businesses (TX)

Contesting, Correcting and Changing Your Estate Documents: Why Your Documents Are Alive Even After You're Dead!

Section Program: Joint: Estate & Gift Taxes (TX) and the Non Tax Estate Planning Considerations Group (TE)

Asset Protection

Standards of Tax Practice

Addressing Concerns About the Ethical Judgments of a Supervising Attorney

Ethical Issues in Federal Tax Practice – The Government Perspective

State & Local Taxes

Cutting Edge Issues Regarding Manufacturing Exemptions From Sales And Use Taxes

Selling Your Business: Where's Our Share? State Taxes on the Sale of an Interstate Business or Subsidiary.

Tax Accounting

Changing Methods to Comply with the Tangible Property Regulations

Current Developments

Tax Accounting Issues in the Real Estate Industry

Tax Exempt Financing

2012 Report of the ACT Committee: Tax-Exempt Bonds: A Survey of IRS Form for Information Reporting.

Transfer Pricing

Practical Considerations for Dealing with the Pricing of Guarantee Arrangements

US Activities of Foreigners and Tax Treaties

FATCA in "No-Man's Land": How Do You Handle Withholding and Reporting for Funds, Trusts and Other Entities that Defy Classification?

Tax Issues for Investment Funds with Foreign Investors.

Young Lawyers Forum

To OVDI or Not OVDI: The Implications of Voluntarily Disclosing.