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Thoughtful Insights. Useful Analysis.
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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 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 |
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| Current Developments | Outline: Selected Recent Developments in Administrative Practice |
| Phone a Friend: When and How To Involve Others in the Government When Your Corporate Examination Languishes | Slides: Navigating the IRS: Phone a Friend--When to Involve Others in the Government When… |
| Phone a Friend: When and How To Involve Others in the Government When Your Corporate Examination Languishes | Slides: When and How to Involve Others in the Government When… |
| Update on IRS Audit Procedure | Slides: IRS Audit Trends & Developments |
Affiliated & Related Corporations |
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| Intercompany Debt Issues and Traps: A Discussion and Overview of the Rules Governing the Treatment of Intercompany Obligations, with a Transactional Focus | Slides: The Intercompany Debt Regulations Treas. Reg. §1.1502-13(g) |
| Tax Issues Arising from Tax Sharing Agreements | Slides: Tax Sharing Agreements |
| Current Developments in Banking / Capital Markets Taxation | Slides: Current Developments in Banking/Capital Markets Taxation |
| Practical Considerations in Dealing with the Final Cost Basis Reporting Regulations for Debt, Options and Securities Futures Contracts | Slides: Cost Basis Reporting for Debt |
| Repurchase Agreements and Dollar Rolls | Slides: Repos, Dollar Rolls, and Purchase/Repos |
Capital Recovery & Leasing |
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| Current Developments Report and Update on Pending Guidance | Paper: Current Developments |
| Research and Development: A Discussion of Recent Developments and Overlying Issues | Slides: Research Credit: A Discussion of Recent Developments |
| Tax Credit Hot Topics | Slides: PTC Begun Construction and Renewable Energy Issues |
| Tax Credit Hot Topics | Slides: Tax Credit Hot Topics |
Civil & Criminal Tax Penalties |
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| Department of Labor - Civil and Criminal Enforcement | Paper: The U.S. Department of Labor, Employee Benefits Security Administration (EBSA), is responsible for the enforcement of Title I of ERISA. |
| Navigating the Civil Employment Tax Audit and Related Issues | Paper: Navigating the Civil Employment Tax Audit and Related Issues |
| Advising the Fiduciaries of Trusts Holding Business Interests | Outline: Potential Tax Liability for Trustees |
| Beyond IRC Section 6166; the Future of Graegin-style Loans | Paper: Beyond IRS Section 6166: The Future of… |
| Succession Planning for Closely Held Businesses and Professional Practices | Paper: Planning for the Successful Transition of a Family Business… |
| Transfer Planning with Carried Interests in Hedge and Private Equity Funds | Outline: Transfer Tax Planning with Carried Interests in… |
| Transfer Planning with Carried Interests in Hedge and Private Equity Funds | Slides: Transfer Tax Planning With… |
Corporate Tax |
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| Section 355 Transactions in the Cross-Border Context | Slides: Cross-Border Section 355 Transactions |
Court Procedure & Practice |
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| Important Developments | Paper: Summary of Important Developments |
| Insolvency and Tax: Advising Clients About Tax Matters in the Course of Bankruptcy | Slides: Insolvency and Tax: Advising Clients About Tax Matters in the Course of Bankruptcy |
| Litigating Cross-Border Transactions in US Courts | Slides: Transfer Pricing: Overview of Section 482 Rules |
Employee Benefits, Subcommittee on Employee Benefits Legislation |
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| Legislative Update | Outline: Summary of the Secure Annuities for Employee (SAFE) Retirement Act |
Employee Benefits, Subcommittee on ESOPs (TX) and Fiduciary Responsibility, Administration and Litigation (TE) |
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| ESOP Update | Paper: (no title) |
Employee Benefits, Subcommittee on Litigation |
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| Litigation Update | Outline: Litigation Update |
Employee Benefits, Subcommittee on Mergers & Acquisitions (TX) and Plan Transactions & Terminations Committee (TE) |
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| Mergers & Acquisitions Update | Slides: Global Equity Compensation Tax Issues in M&A Transactions |
| Mergers & Acquisitions Update | Chart: Global Equity Matrix |
Employee Benefits, Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices |
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| Administrative Practices Update | Outline: Key Changes to Determination Letter and EPCRS Procedures |
| Aftermath of the Supreme Court’s DOMA Decision | Slides: Aftermath of Supreme Court's DOMA Decisions |
| Aftermath of the Supreme Court’s DOMA Decision | Paper: Employee Benefits Affecting Employees in Same Sex Marriages… |
| Attorneys Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and Beyond | Slides: Legal Review of Employee Benefits Plan Services Agreements |
| Attorneys Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and Beyond | Slides: The Art of Understanding and Documenting Fees |
| Attorneys Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and Beyond | Chart: Attorney Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and Beyond |
| Hot Topics | Paper: Notice to Employees… |
| Hot Topics | Paper: Wellness Programs Final Regulations |
| Hot Topics | Paper: Congress and DOL Consider Requiring Lifetime... |
| Independence Considerations in Employee Benefits – When Is a Service Provider Truly Independent? | Slides: Independence Considerations in Employee Benefits – When is a Service Provider Truly Independent? |
Employment Taxes |
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| Affordable Care Act and Its Impact on the Characterization of a Workforce | Paper: Overview of Recent Judicial Opinions…Worker Classification |
| Affordable Care Act and Its Impact on the Characterization of a Workforce | Paper: Voluntary Classification Settlement Program |
| The Doom of DOMA, Keeping the Faith and Taking Credit | Slides: Defense of Marriage Act |
| UI Integrity Act | Slides: Unemployment Insurance Issues |
Energy & Environmental Taxes |
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| Begun Construction Test and the New PTC – How are Companies Planning to Meet the Test? | Slides: Renewable Energy Tax and Grant Updates |
| Estate Planning Without a Passport: Section 2801 and Other International Hot Topics | Slides: Estate Planning Without a Passport: Section 2801 and Other International Hot Topics |
| Much Ado About Something: Clash of the Agent, Attorney and Appraiser in Gift Tax Audits (in 4 Scenes) | Outline: Much Ado About Something: Clash of the Agent, Attorney and Appraiser in Gift Tax Audits (In 4 Scenes) |
Financial Transactions |
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| Financial Transaction Committee Reports on Camp | Slides: Financial Transactions Committee Reports on the Camp Proposals regarding Financial Products |
| Futurization of Swaps - What the Clients are Dealing with Now | Slides: Futurization of Swaps |
| Tax Planning with REMICs: Everything Old is New Again | Slides: REMICs |
Foreign Activities of US Taxpayers |
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| Issues and Challenges Arising Under the Foreign Tax Credit | Slides: Issues and Challenges Arising Under the Foreign Tax Credit |
| Unresolved International Tax Issues in M&A Transactions | Slides: Unresolved International Tax Issues in M&A Transactions |
Individual & Family Taxation |
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| "Helpful Tips on How to Bring a Case to Taxpayer Advocate Service and Recent Changes to IRS Collection Alternatives" | Slides: Working With the Taxpayer Advocate Service |
| "Helpful Tips on How to Bring a Case to Taxpayer Advocate Service and Recent Changes to IRS Collection Alternatives" | Slides: Helpful Tips on How to Bring a Case to TAS and Recent Changes to IRS Collection Alternatives |
| How Implementation of the Affordable Care Act Impacts Individual Taxpayers | Slides: How Implementation of the Affordable Care Act Impacts Individual Taxpayers |
| Reporting Foreign Source Income | Outline: Reporting Foreign Source Income |
| Reporting Foreign Source Income | Slides: Reporting Foreign Source Income |
Insurance Companies |
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| Captive Insurance: Back in the spotlight | Slides: Captive Insurance Back in the Spotlight |
| Insurance M&A: What are the biggest issues around Deferred Tax Assets? | Slides: Insurance M&A - What Are the Biggest Issues… |
| Modern Family, Tax Policy and the Taxation of Insurance Products Post Windsor | Outline: Income and Transfer Tax Issues After IRS Announcement on Same-Sex Marriage |
| Modern Family, Tax Policy and the Taxation of Insurance Products Post Windsor | Chart: Status Recognition Chart for Same-Sex Couples |
Investment Management |
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| An Overview of Business Development Companies (“BDCs”) and Uses of These Vehicles in the Current Climate | Slides: Overview of Organization and Structuring of BDCs |
| Current Developments Regarding Tax Issues for Hedge Funds | Slides: Net Investment Income Tax & Other Hedge Fund Issues |
| Current Issues Confronting Regulated Investment Companies | Slides: RIC UPDATE |
Joint: Closely Held Businesses (TX) and Business Planning Group (TE) |
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| Advising the Fiduciaries of Trusts Holding Business Interests | Outline: Trusts as S Corporation Shareholders |
Joint: Court Procedure & Practice and Tax Litigation & Controversy Committee of the Income & Transfer Tax Planning Group Roundtable Discussion |
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| Effective Use of Demonstrative Exhibits and Summary Exhibits in Tax Cases | Slides: Effective Use of Demonstrative and Summary Exhibits in Tax Cases |
Joint: Diversity and Employee Benefits International Issues |
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| Leaving the US – It’s Very Different from Leaving Las Vegas. Tax Planning for US Persons Living and Working Abroad | Checklist: International Executives Checklist |
Joint: Employee Benefits (TX) and Employee Benefit Plans & Other Compensation Arrangements Group (TE) |
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| Aftermath of Litigation: What Plan Language and Administration Do You Need Now? | Slides: Aftermath of Litigation: What Plan Language |
Joint: Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE) |
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| Current Developments | Paper: Current Developments in Federal Transfer Taxes |
Joint: Exempt Organizations (TX) and Charitable Planning & Exempt Organizations Group (TE) |
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| Donor Advised Funds | Outline: Donor Advised Funds |
Joint: Fiduciary Income Tax (TX) and Income & Transfer Tax Planning Group (TE) |
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| Current Developments | Paper: Recent Developments in Fiduciary Income Tax |
Joint: Foreign Activities of US Taxpayers, Transfer Pricing and US Activities of Foreigners & Tax Treaties |
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| Joint Current International Developments Panel | Slides: International Tax Update |
Partnerships & LLCs |
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| Sailing in Circles: Forthcoming IRS Guidance on Partnership Transactions involving a Partner’s Stock | Slides: Partnership Transactions Involving a Partner’s Stock |
| Sailing into Unchartered Waters: Subchapter K Tax Reform | Paper: Testimony Before the Subcommittee on Select Revenue Measures |
| Sailing into Unchartered Waters: Subchapter K Tax Reform | Slides: Chairman Camp Discussion Draft |
| Sailing into Unchartered Waters: Subchapter K Tax Reform | Supplement: Technical Explanation of the Ways and Means Committee Discussion Draft Provisions to Reform the Taxation of Small Business and Passthrough Entities |
| Tightening the Lines: IRS to Restrict Partnership Debt Allocations | Slides: Tightening the Lines: IRS to Restrict Partnership Debt Allocations |
Pro Bono & Tax Clinics |
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| Developments in Collection Due Process | Outline: Pro Bono and Tax Clinics: Developments in Collection Due Process |
| Recent Developments Affecting Low Income Taxpayers | Outline: Recent Developments Affecting Low Income Taxpayers |
| The Impact of US v. Windsor on the Civilian and Military Taxpayers | Outline: Which Marriages Should be Recognized by the IRS |
| The Impact of US v. Windsor on the Civilian and Military Taxpayers | Outline: Specific Tax Issues Raised by the Fall of DOMA |
| The Impact of US v. Windsor on the Civilian and Military Taxpayers | Chart: Status Recognition Chart for Same-Sex Couples |
| Update on Procedures from the Tax Court | "Outline: Discussion of ways to enhance Court procedures for the benefit of self-represented taxpayers" |
Real Estate |
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| Hot Topics | Slides: Hot Topics |
| Setting up your Private REIT – A Practical Primer | Slides: Setting up your Private REIT – A Practical Primer |
| State Tax Enforcement Areas – An Insider’s Perspective | "Outline: State Tax Enforcement Areas An Insider's Perspective " |
| State Tax Enforcement Areas – An Insider’s Perspective | "Slides: State Tax Enforcement Areas An Insider's Perspective" |
| Tax Credit Planning After Historic Boardwalk and Anticipated IRS Guidance | Paper: Credit Where Credit Is Due? Who Is a Partner after Historic Boardwalk? |
| Tax Credit Planning After Historic Boardwalk and Anticipated IRS Guidance | Slides: Historic Boardwalk |
S Corporations |
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| Charitable Gifts by S Corporations and Their Shareholders | Paper: Planning for Maximum Tax Benefits from Charitable Gifts… |
| Current Developments | Outline: Current Developments in the Federal Income Taxation of S Corporations |
| Tax Effects of Converting Entities Under State Law Conversion and State Law Merger Statutes | Outline: Tax Effects of Converting Entities Under State Law Conversion and State Law Merger Statutes |
Sales, Exchanges & Basis |
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| Analyzing the Section 1031 “Disqualified Person” Rules: The Usual Suspects and Beyond | "Slides: Analyzing the Section 1031 “Disqualified Person” Rules" |
| Current Developments in Sales, Exchanges and Basis | Outline: Current Non-Section 1031 Developments |
| Current Developments in Sales, Exchanges and Basis | Paper: IRC 1031/1033 Current Developments |
| Tax Planning Workshop: “Drop & Swap” and “Mixing Bowl” Techniques | Report: 2001 Joint Report on IRC Section 1031 Open Issues Involving Partnerships |
| The Very Rare Find: A Section 1031 Collectible Exchange with Definite Answers | Paper: Section 1031 and Approximate and Midstream Business Transactions |
| The Very Rare Find: A Section 1031 Collectible Exchange with Definite Answers | Slides: Tax-Deferred Exchanges of Art… |
Section Program |
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| Estate & Gift Taxes (TX) and the Income & Transfer Tax Planning Group (TE) | Slides: “Well, That Certainly Resolved Everything…” Same-Sex Planning in a Post-Windsor and Perry World |
Standards of Tax Practice |
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| Ethical Issues Arising from Conflicts of Interest, Especially When Criminal Tax Charges are on the Horizon. | Slides: Ethical Issues Arising from Conflicts of Interest |
| Ethical Issues in Federal Tax Practice - The Government Perspective | Slides: Ethical Issues in Federal Tax Practice - The Government Perspective |
State & Local Taxes |
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| Could The Due Process Clause Rain on the Nexus Everywhere Parade? | Slides: Could the Due Process Clause Rain on… |
| State and Local Tax Issues for International Commerce. | Slides: State Tax Issues for International Commerce |
| State and Local Tax Issues for International Commerce. | Outline: State Income Taxation of Foreign Corporations |
| State and Local Tax Issues for International Commerce. | Outline: State Tax Implications of International Transactions Relevant Federal Tax Concepts and Special Situations |
| Transparency Under A Different Light: Discovery, Settlements and Confidentiality | Slides: Transparency Under a Different Light: Discovery, Settlements and Confidentiality |
| What if the Marketplace Fairness Act Becomes Law? | Slides: What If The Marketplace Fairness Act Becomes Law? |
Tax Accounting |
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| Accounting Methods Issues Related to Short Year Returns | Handout: Accounting Method Issues Related to Short Year Returns Guidance Excerpts |
| Accounting Methods Issues Related to Short Year Returns | Outline: Accounting Method Issues Relating to Short Year Returns Scenarios |
| Current Developments | Outline: Current Developments |
| Tax Accounting Issues in International Tax Planning | Outline: Accounting method issues impacting International Operations |
Tax Exempt Financing |
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| Legislative Department of Treasury and IRS Update | Outline: Legislative, Treasury, and Internal Revenue Service Updates |
| Tax Implications of Direct-Purchase (Private Placement) Bonds | Outline: Direct Placement Bond Issues Tax Considerations |
| Tax Round Table | Outline: Capitalization of Expenditures |
Tax Policy & Simplification |
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| Implementing the Affordable Care Act in 2014 and Beyond | Slides: The Not-So-Mandatory Individual Mandate |
| Implementing the Affordable Care Act in 2014 and Beyond | Slides: Premium Tax Credits under the ACA |
| Implementing the Affordable Care Act in 2014 and Beyond | "Paper: Perverse Incentives Arising from the Tax Provisions of Healthcare Reform:" |
| What Can Tax Lawyers and Economists Learn from Each Other? | Slides: Economists are from Mars, Lawyers are from Venus |
| What Can Tax Lawyers and Economists Learn from Each Other? | Paper: Economists are from Mars, Lawyers are from Venus |
| What Can Tax Lawyers and Economists Learn from Each Other? | Article: Perverse Incentives Arising from the Tax Provisions of Healthcare Reform |
Tax Practice Management |
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| Social Media and Your Practice: Avoiding Ethical Pitfalls | Outline: Social Media and Your Practice - Avoiding Ethical Pitfalls |
| Social Media and Your Practice: Using It Effectively | Supplement: Social Media Platforms |
| Social Media and Your Practice: Using It Effectively | Slides: Social Media and Your Practice: Using It Effectively |
Teaching Taxation |
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| Would You Like a Calculator with that Diploma? Student loans and taxes | Slides: LRAPs and Section 108(f) |
| Would You Like a Calculator with that Diploma? Student loans and taxes | Outline: Discharge of Student Loans in Bankruptcy |
| Would You Like a Calculator with that Diploma? Student loans and taxes | Outline: Student Loans, Taxes, and the American Dream in Retrograde |
| Would You Like a Calculator with that Diploma? Student loans and taxes | Chart: Payment Scenarios |
Transfer Pricing |
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| Leading Transfer Pricing Cases in Current Litigation | Slides: Current Transfer Pricing Cases: Reading the Tea Leaves |
| The 3M Case and Blocked Income | Slides: The 3M Case and Blocked Income |
US Activities of Foreigners & Tax Treaties |
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| Applying the Permanent Establishment Rules in the Digital Age | Slides: Permanent Establishment in the Digital Age |
| Planning for “Inbound” US Investments Through Foreign Trusts | Slides: Inbound Investments by Foreign Trusts and Individuals |
Young Lawyers Forum |
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| Tax Planning for Natural Disasters | State Tax Implications of Natural Disasters |
| Tax Planning for Natural Disasters | Slides: Tax Implications of Natural Disasters |
| Tax Planning for Natural Disasters | Outline: Tax Implications of Natural Disasters, Part IV: Best Practices |
| Tax Planning for Natural Disasters | Slides: Tax Implications of Natural Disasters |