TaxIQ

2013 Joint Fall CLE Meeting

September 19-21, San Francisco, CA

Thoughtful Insights. Useful Analysis.
TaxIQ 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 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 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

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

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

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

Section 355 Transactions in the Cross-Border Context Slides: Cross-Border Section 355 Transactions

Court Procedure & Practice

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

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)

ESOP Update Paper: (no title)

Employee Benefits, Subcommittee on Litigation

Litigation Update Outline: Litigation Update

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

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

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

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

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)

Exempt Organizations

Cause Related Marketing & Commercial Co-Ventures Paper: Cause-Related Marketing & Commerical Co-Ventures
New Market Tax Credits Slides: Use of New Markets Tax Credit by…
New Market Tax Credits Article: How Nonprofit Orgs Can Use…
News from the IRS and Treasury Paper: Senate Finance Committee Staff Tax Reform Options for Discussion
News from the IRS and Treasury Slides: Current Developments Written Materials for “News from the IRS and Treasury”
Donor Advised Funds Slides: Donor Advised Funds
Helping the IRS: 501(c)(4) Reform Proposals Paper: The Tie Goes To The Speaker, Not The Censor
Estate Planning for Real Estate Owners: Don’t Forget the Income Tax Side Paper: Estate Planning for Real Estate Owners: Don't Forget…
Estate Planning for Real Estate Owners: Don’t Forget the Income Tax Side Slides: Estate Planning for Investment Real Estate: Don't Forget…
Material Participation Under Passive Activity Limitations and Net Investment Income Tax Outline: Material Participation Under Passive Activity Limitations and Net Investment Income Tax

Financial Transactions

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

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

"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

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

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)

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

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

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)

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)

Current Developments Paper: Current Developments in Federal Transfer Taxes

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

Donor Advised Funds Outline: Donor Advised Funds

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

Current Developments Paper: Recent Developments in Fiduciary Income Tax

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

Joint Current International Developments Panel Slides: International Tax Update

Partnerships & LLCs

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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