TaxIQ

2013 Joint Fall CLE Meeting

September 19-21, 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.

Materials by Committee

Administrative Practice

Current Developments

Phone a Friend: When and How To Involve Others in the Government When Your Corporate Examination Languishes

Update on IRS Audit Procedure

Affiliated & Related Corporations

Intercompany Debt Issues and Traps: A Discussion and Overview of the Rules Governing the Treatment of Intercompany Obligations, with a Transactional Focus

Tax Issues Arising from Tax Sharing Agreements

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

Repurchase Agreements and Dollar Rolls

Capital Recovery & Leasing

Current Developments Report and Update on Pending Guidance

Research and Development: A Discussion of Recent Developments and Overlying Issues

Tax Credit Hot Topics

Civil & Criminal Tax Penalties

Department of Labor - Civil and Criminal Enforcement

Navigating the Civil Employment Tax Audit and Related Issues

Advising the Fiduciaries of Trusts Holding Business Interests

Beyond IRC Section 6166; the Future of Graegin-style Loans

Succession Planning for Closely Held Businesses and Professional Practices

Transfer Planning with Carried Interests in Hedge and Private Equity Funds

Corporate Tax

Section 355 Transactions in the Cross-Border Context

Court Procedure & Practice

Important Developments

Insolvency and Tax: Advising Clients About Tax Matters in the Course of Bankruptcy

Litigating Cross-Border Transactions in US Courts

Employee Benefits, Subcommittee on Employee Benefits Legislation

Legislative Update

Employee Benefits, Subcommittee on ESOPs (TX) and Fiduciary Responsibility, Administration and Litigation (TE)

ESOP Update

Employee Benefits, Subcommittee on Litigation

Litigation Update

Employee Benefits, Subcommittee on Mergers & Acquisitions (TX) and Plan Transactions & Terminations Committee (TE)

Mergers & Acquisitions Update

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

Administrative Practices Update

Aftermath of the Supreme Court’s DOMA Decision

Attorneys Services With Respect to Plan Investment Advisor and Recordkeeper Agreements: Contract Review and Beyond

Hot Topics

Independence Considerations in Employee Benefits – When Is a Service Provider Truly Independent?

Employment Taxes

Affordable Care Act and Its Impact on the Characterization of a Workforce

The Doom of DOMA, Keeping the Faith and Taking Credit

UI Integrity Act

Energy & Environmental Taxes

Begun Construction Test and the New PTC – How are Companies Planning to Meet the Test?

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)

Exempt Organizations

Cause Related Marketing & Commercial Co-Ventures

New Market Tax Credits

News from the IRS and Treasury

Donor Advised Funds

Helping the IRS: 501(c)(4) Reform Proposals

Estate Planning for Real Estate Owners: Don’t Forget the Income Tax Side

Material Participation Under Passive Activity Limitations and Net Investment Income Tax

Financial Transactions

Financial Transaction Committee Reports on Camp

Futurization of Swaps - What the Clients are Dealing with Now

Tax Planning with REMICs: Everything Old is New Again

Foreign Activities of US Taxpayers

Issues and Challenges Arising Under the Foreign Tax Credit

Unresolved International Tax Issues in M&A Transactions

Individual & Family Taxation

"Helpful Tips on How to Bring a Case to Taxpayer Advocate Service and Recent Changes to IRS Collection Alternatives"

How Implementation of the Affordable Care Act Impacts Individual Taxpayers

Reporting Foreign Source Income

Insurance Companies

Captive Insurance: Back in the spotlight

Insurance M&A: What are the biggest issues around Deferred Tax Assets?

Modern Family, Tax Policy and the Taxation of Insurance Products Post Windsor

Investment Management

An Overview of Business Development Companies (“BDCs”) and Uses of These Vehicles in the Current Climate

Current Developments Regarding Tax Issues for Hedge Funds

Current Issues Confronting Regulated Investment Companies

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

Advising the Fiduciaries of Trusts Holding Business Interests

Joint: Court Procedure & Practice and Tax Litigation & Controversy Committee of the Income & Transfer Tax Planning Group Roundtable Discussion

Effective Use of Demonstrative Exhibits and Summary Exhibits in Tax Cases

Joint: Diversity and Employee Benefits International Issues

Leaving the US – It’s Very Different from Leaving Las Vegas. Tax Planning for US Persons Living and Working Abroad

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

Aftermath of Litigation: What Plan Language and Administration Do You Need Now?

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

Current Developments

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

Donor Advised Funds

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

Current Developments

Joint: Foreign Activities of US Taxpayers, Transfer Pricing and US Activities of Foreigners & Tax Treaties

Joint Current International Developments Panel

Partnerships & LLCs

Sailing in Circles: Forthcoming IRS Guidance on Partnership Transactions involving a Partner’s Stock

Sailing into Unchartered Waters: Subchapter K Tax Reform

Tightening the Lines: IRS to Restrict Partnership Debt Allocations

Pro Bono & Tax Clinics

Developments in Collection Due Process

Recent Developments Affecting Low Income Taxpayers

The Impact of US v. Windsor on the Civilian and Military Taxpayers

Update on Procedures from the Tax Court

Real Estate

Hot Topics

Setting up your Private REIT – A Practical Primer

State Tax Enforcement Areas – An Insider’s Perspective

Tax Credit Planning After Historic Boardwalk and Anticipated IRS Guidance

S Corporations

Charitable Gifts by S Corporations and Their Shareholders

Current Developments

Tax Effects of Converting Entities Under State Law Conversion and State Law Merger Statutes

Sales, Exchanges & Basis

Analyzing the Section 1031 “Disqualified Person” Rules: The Usual Suspects and Beyond

Current Developments in Sales, Exchanges and Basis

Tax Planning Workshop: “Drop & Swap” and “Mixing Bowl” Techniques

The Very Rare Find: A Section 1031 Collectible Exchange with Definite Answers

Section Program

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

Standards of Tax Practice

Ethical Issues Arising from Conflicts of Interest, Especially When Criminal Tax Charges are on the Horizon.

Ethical Issues in Federal Tax Practice - The Government Perspective

State & Local Taxes

Could The Due Process Clause Rain on the Nexus Everywhere Parade?

State and Local Tax Issues for International Commerce.

Transparency Under A Different Light: Discovery, Settlements and Confidentiality

What if the Marketplace Fairness Act Becomes Law?

Tax Accounting

Accounting Methods Issues Related to Short Year Returns

Current Developments

Tax Accounting Issues in International Tax Planning

Tax Exempt Financing

Legislative Department of Treasury and IRS Update

Tax Implications of Direct-Purchase (Private Placement) Bonds

Tax Round Table

Tax Policy & Simplification

Implementing the Affordable Care Act in 2014 and Beyond

What Can Tax Lawyers and Economists Learn from Each Other?

Tax Practice Management

Social Media and Your Practice: Avoiding Ethical Pitfalls

Social Media and Your Practice: Using It Effectively

Teaching Taxation

Would You Like a Calculator with that Diploma? Student loans and taxes

Transfer Pricing

Leading Transfer Pricing Cases in Current Litigation

The 3M Case and Blocked Income

US Activities of Foreigners & Tax Treaties

Applying the Permanent Establishment Rules in the Digital Age

Planning for “Inbound” US Investments Through Foreign Trusts

Young Lawyers Forum

Tax Planning for Natural Disasters