TaxIQ

2014 Joint Fall CLE Meeting

September 18-20, Denver, CO

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

Important Developments Slides: Important Developments in Administrative Practice
It’s a Privilege, or Is It? Slides: It's a Privilege, or Is It?
Kicking it Upstairs — How to Elevate Issues Within the IRS Slides: Kicking it Upstairs - How to Elevate Issues Within the IRS

Banking & Savings Institutions

Current Developments Slides: CPDI - Treatment of Consent Fee
Current Developments Slides: T.D. 9691, New Reg. §1.1092(d)-1(d)/€
Taxation of Letters of Credit and Guarantee Fees in the Aftermath of Container Corp. Slides: Taxation of Consent, Guarantee, Letters of Credit and Similar Fees

Capital Recovery & Leasing

Current Developments Report and Update on Pending Guidance Outline: Current Developments
Issues and Considerations Involving Tenant Improvement Allowances Outline: Issues and Considerations Involving Tenant Improvement Allowances
Issues and Considerations Involving Tenant Improvement Allowances Outline: Examples - Issues and Considerations Involving Tenant Improvement Allowances
Tangible Property Regulations Update – Continuation from the May Meeting – Disposition Regulations, FAQs, and Related Discussions Outline: Final tangible property regulations on dispositions of MACRS property and on general asset accounts

Civil & Criminal Tax Penalties

Reports of Subcommittees on Important Developments Outline: Developments in International Tax Enforcement
Reports of Subcommittees on Important Developments Outline: Important Developments - Criminal
Reports of Subcommittees on Important Developments Outline: Developments on Civil Penalties
Statutes of Limitations in International Civil and Criminal Tax Matters – The Rules and the Many Exceptions Outline: Statutes of Limitations in International Civil and Criminal Tax Matters The Rules and the Many Exceptions

CLE Committee

Section Program: Harshing My Buzz - Federal Income Tax Rules Affecting "Legal" Marijuana Businesses Slides: Federal Income Taxation of Marijuana Businesses

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

Basis Planning With Pass Through Entities Outline: Basis Planning with Passthrough Entities
Basis Planning With Pass Through Entities Outline: Venn Diagrams: The Intersection of Estate & Income Tax (Planning in the Atra-Math)
Basis Planning With Pass Through Entities Slides: Basis Planning with Pass Through Entities
Pre-Death and Post-Death Estate Planning for Closely Held Businesses Article: Pre-Death and Post-Death Estate Planning for Closely Held Businesses
Succession Planning for Closely Held Businesses and Professional Practices — II Article: Planning for the Successful Transition of a Family Business to the Next Generation
Succession Planning for Closely Held Businesses and Professional Practices — II Outline: Succesion Planning for Dental and Dental Specialty Practices - II
Succession Planning for Closely Held Businesses and Professional Practices — II Slides: Succession Planning for Dental and Dental Specialty Practices - II
Tax Traps Involved in Related Party Transactions with Family or Closely Held Businesses Outline: Transfer Tax Traps Involved in Related Party Transactions with Family or Closely Held Businesses

Corporate Tax

Current Developments Slides: Current Developments
Tax Opinions 3.0? – Ethical Considerations and Best Practices Under the New Circular 230 Rules Slides: Tax Opinions 3.0?: Ethical Considerations and Best Practices Under the New Circular 230 Rules

Court Procedure & Practice

Beyond Deficiency, Liability and CDP Cases: The Other Jurisdictional Areas for the US Tax Court Slides: The Esoteric Areas of the U.S. Tax Court's Jurisdiction
Court Procedure and Practice Roundtable Discussion: Whistling Where Your Clients Work Slides: Whistling Where Your Client Works
Expert Witnesses: Experts in the Trenches: Risk, Fair Rewards, Economic Substance, and Shams Slides: Experts in the Trenches: Risk, Fair Rewards, Economic Substance, and Shams
Important Developments Outline: Important Developments Report for the Court Procedure and Practice Committee

Diversity

Obtaining PLRs, CAMs and Section 9100 Relief Outline: Obtaining PLRs, CAMs and Section 9100 Relief
Obtaining PLRs, CAMs and Section 9100 Relief Slides: Obtaining PLRS, CAMS and Section 9100 Relief

Employee Benefits

Administrative Practices Update Slides: DOL Update
Affordable Care Act: Reporting 2015 Enrollment and Eligibility and the Looming Cadillac Tax Slides: Reporting Common Employment Situations on Form 1095-C
Defined Contribution Plans Update Outline: Department of Labor to Look Through the Brokerage Window
Defined Contribution Plans Update Article: Clark v. Rameker: Effects on Tax-Qualified Retirement Plans
Department of Labor Employee Benefits Security Administration Regulatory Update Slides: Security Administration Regulatory Update
Employee Benefits in Tax Court - A Discussion with IRS Chief Counsel Outline: Perspective of Taxpayer Counsel
Employee Benefits in Tax Court - A Discussion with IRS Chief Counsel Supplement: Selected Tax Court Decisions in the Last 12 Months Addressing Qualified Plan and IRA Issues
ERISA After 40 Years Slides: ERISA After 40 Years
ESOP Update Outline: Employee Stock Ownership Plan Current Issues
ESOP Update Chart: ESOP Litigation Status
Executive Compensation, Fringe Benefits and Federal Securities Law Update Slides: Witholding, Reporting, and Deposit Timing Issues Related to Equity Compensation
Exempt Organization and Governmental Plans Update Outline: Windsor and Subsequent IRS Guidance: Considerations for Governmental Plans
Exempt Organization and Governmental Plans Update Summary: Recent Developments in Church Plan Litigation
Exempt Organization and Governmental Plans Update Outline: Typical Requests in a 403(b) Audit
Fiduciary Responsibilities Update Outline: Employee Benefits Fiduciary Responsibilities Update
Legislative Update Outline: Legislative Update
Multiple Employers, PEOs and Controlled Groups Update Outline: Considerations in Addressing Problems Created Under the IRS One Bad Apple Rule for Multpile Employer Plans
Mergers & Acquisitions Update Outline: Overview of Selected Defined Benefit Plan Issues in Merger & Acquisition Transactions
Mergers & Acquisitions Update Slides: Joint and Several Benefit Plan Liability Issues in M&A Transactions
Mergers & Acquisitions Update Outline: PBGC's Early Warning Program
Multinational Employee Benefits & Compensation Issues Slides: FATCA: Practical Considerations for Nonfinancial Companies
Multinational Employee Benefits & Compensation Issues Slides: Section 402(b)
The Period Between Signing and Closing: What Benefits Counsel Needs to Know Outline: Sample Equity Award Provisions and Benefit Covenants
The Period Between Signing and Closing: What Benefits Counsel Needs to Know Slides: The Period Between Signing and Closing: What Benefits Counsel Needs to Know
Welfare Plan and EEOC Issues Update Outline: Transitional Reinsurance Program Fees Submission of Annual Enrollment and Contributions
Welfare Plan and EEOC Issues Update Outline: The Affordable Care Act Intersects the Mental Health Mental Health Parity and Addiction Equity Act: Autism Spectrum Disorder and Applied Behavioral Analysis
Welfare Plan and EEOC Issues Update Outline: Information Reporting Requirements Under Code Sections 6055 & 6056
Welfare Plan and EEOC Issues Update Paper: Applying for a Health Plan Identifier (HPID) in the CMS Health Insurance Oversight (HIOS) Health Plan and Other Entity Enumeration System (HPOES)

Employment Taxes

Forms 1094-C and 1095-C. Understanding Employer’s Reporting Obligations under the Affordable Care Act (ACA) Slides: Employer's Reporting Obligations Under the Affordable Care Act
Taxing the Mobile Workforce: International Employees Slides: Employment Taxes: Impact on International Employers
Third Party Payroll Providers Slides: Third Party Payroll Providers

Energy & Environmental Taxes

Energy Tax Hot Topics Slides: Renewable Energy Tax and Grant Updates

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

Asset Protection Planning for LGBT Clients After the Windsor Case Outline: Same-Sex Marriage in 2014: The Aftermath of Windsor, Perry and IRS Action, Plus the 21st Century Battle Between The States
Asset Protection Planning for LGBT Clients After the Windsor Case Slides: Asset Protection Planning for LGBT Clients After Windsor
Asset Protection Planning for LGBT Clients After the Windsor Case Outline: Ethical Issues in Asset Protection Planning
Creative Inter Vivos QTIP Planning Article: Creative Inter Vivos QTIP Planning
Creative Inter Vivos QTIP Planning Slides: Creative Inter Vivos QTIP Planning
Current Developments Article: Current Developments in Federal Transfer Taxes
Estate Planning Challenges for Pass-Through Entities Article: Estate Planning Challenges for Pass Through Entities
Ethics 101 for Estate Planners Outline: Ethics 101 for the Estate Planner

Exempt Organizations

Ethical and Practical Problems for the Attorney on the Nonprofit Board Outline: Ethical and Practical Problems for the Attorney on the Nonprofit Board
International Activity and Negotiating the Alphabet Soup Slides: International Activity: Negotiating the Alphabet Soup
Private Foundation Reporting Pitfalls Slides: Private Foundation Reporting Pitfalls
Private Foundation Reporting Pitfalls Outline: Reporting Obligations of Private Foundations Beyond Form 990-PF
Section Program: Hybrid Corporate Models - The Benefit Corporation and its Siblings Outline: For-Profit Social Enterprise Models Understanding the Legal Landscape

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

Current Developments Outline: Recent Developments in Fiduciary Income Tax
Current Developments Slides: Recent Developments in FATCA
Foreign Trust Traps: In-Bound Planning with Foreign Trusts Slides: Foreign Trust Traps: In-Bound Planning With Foreign Trusts (Case Studies)
Frank Aragona Trust v. Commissioner and Material Participation of Estates and Trusts for Passive Activities Slides: Frank Aragona Trust v. Commissioner and the Material Participation of Estates and Trusts for Passive Activities
Unbundling the IRS' Final Regulations on the Deductibility of Costs Incurred by Trusts and Estates Outline: Unbundling the IRS' Final Regulations on the Deductibility of Costs Incurred By Trusts & Estates

Financial Transactions

Advanced Topics under the Wash Sale Rules Slides: Problems in the Wash Sale Rules: Where Does the Loss Go?

Foreign Activities of US Taxpayers

Foreign Tax Credits Developments Slides: Foreign Tax Credit Developments
Issues Surrounding Passive Foreign Investment Companies Slides: Issues Surrounding Passive Foreign Investment Companies

Joint International Committee: FAUST, FLF, USAFTT, and TP

Joint Current International Developments Panel Slides: Joint Current International Developments Panel USAFTT, FAUST, Transfer Pricing and FLF

Individual & Family Taxation

Pardon the Mess: Jurisdictional Issues in a Post-DOMA World Slides: Pardon the Mess: Jurisdictional Issues in a Post-DOMA World
Pardon the Mess: Jurisdictional Issues in a Post-DOMA World Chart: Same Sex Marriage Information
Update on Craft and Litigation of Tenancy by Entirety Property Outline: Assigning Values to Property Interests When One Spouse Owes Taxes but Both Own the Property

Insurance Companies

Merger and Acquisition Issues as Applicable to Insurance Companies Slides: What to Know Before You Go: Hot Topics in Insurance M&A
Recent Developments Involving Insurance Products and Qualified Retirement Arrangements Slides: Recent Developments Involving Insurance Products And Qualified Retirement Arrangements
Update on IRS Guidance Affecting Insurance Companies and Products Slides: Update on IRS Guidance Affecting Insurance Companies and Products

Investment Management

Current Issues for Insurance Dedicated Mutual Funds Slides: Current Issues for Insurance Dedicated Mutual Funds
Mutual Fund Investments in Derivatives: Current Issues Slides: Fund Investments in Derivatives: Current Issues
Why Not a Partnership?: Thinking Outside the Box Slides: Why Not a Partnership? Thinking Outside the Box
Why Not a Partnership?: Thinking Outside the Box Outline: Why Not a Partnership? Thinking Outside the Square and Inside the Triangle

Partnerships & LLCs

Hot Topics Slides: Hot Topics in Partnership Taxation
Partnership Continuations Slides: Parternship Continuations
Service Firms (LLCs and LLPs) and/or Their Members in Bankruptcy: Tax and Non-Tax Aspects – Part 1 Outline: Service Firms (LLCs and LLPs) and/or Their Members in Bankruptcy: Tax and Non-Tax Aspects – Part 1
What’s Wrong With the Nonrecourse Debt Rules? Slides: What’s Wrong With the Nonrecourse Debt Rules?
What’s Wrong With the Nonrecourse Debt Rules? Outline: Exculpatory Liabilities and Other Unresolved Issues

Pro Bono & Tax Clinics

Adopt-a-Base Issues Slides: Adopt-A-Base Program

Real Estate

Current Issues with Real Estate Funds Slides: Current Issues with Real Estate Funds
Homebuilders, Land Developers and Use of the Completed Contract Method of Accounting Slides: Homebuilders, Land Developers and Use of the Completed Contract Method of Accounting
Revised Definition of “Real Estate” for REITs Slides: Proposed Treas. Reg. Section 1.856-10: The Final Chapter (?)

S Corporations

Current Developments Outline: Current Developments in the Federal Income Taxation of S Corporations
S Corporations and Life Insurance Outline: Life Insurance and S Corporation Buy-Sell Arrangements

Sales, Exchanges & Basis

“Over? It’s Not Over Until We Say It’s Over”: Strategies for Extending the 180-day Exchange Deadlines Slides: Over? It’s Not Over Until We Say It’s Over: Strategies for Extending the 180-Day Exchange Deadlines
Current Developments in Sales, Exchanges & Basis Outline: Current Non-Section 1031 Developments
Silver Linings: Finding Opportunity in Involuntary Conversions under Section 1033 Outline: Silver Linings: Finding Opportunity in Involuntary Conversion under Section 1033

Standards of Tax Practice

Back to Basics on The Ethics of Federal Tax Practice: Best Practices 101 Slides: Back to Basics on The Ethics of Federal Tax Practice: Best Practices 101
Ethical Issues in Federal Tax Practice – The Government Perspective Slides: Ethical Issues in Federal Tax Practice – The Government Perspective
What’s Going on with Circular 230? — Final Regulations on Written Tax Advice, Litigation Developments from Loving to Ridgely, and The Question of What Next Outline: What's Going On With Circular 230?

State & Local Taxes

Sorting Through the Weeds: Marijuana and State and Local Taxes Slides: Sorting Through the Weeds: Marijuana and State and Local Taxes
Sorting Through the Weeds: Marijuana and State and Local Taxes Slides: The State of Marijuana in Colorado
State Taxation of Nonprofit Organizations: When Nonprofit Doesn’t Mean "Tax-Exempt." Slides: State Taxation of Nonprofit Organizations: When Nonprofit Doesn't Mean "Tax-Exempt"

Tax Accounting

Current Developments Outline: Current Developments
Inventory Accounting Challenges Outline: Inventory Accounting Challenges
Selected Topics and Recent Developments Concerning the Research and Development Credit. Slides: Selected Topics and Recent Developments Concerning the Research Credit
Tax Accounting Method Implications of Recent Changes to Financial Accounting Revenue Recognition Standard Slides: Accounting Method Implications of New Financial Accounting Revenue Recognition Standard

Tax Policy & Simplification

Prospects for Direct (or Indirect) Taxation of Wealth Outline: Prospects for Direct (or Indirect) Taxation of Wealth - Background Paper and Bibliography
Prospects for Direct (or Indirect) Taxation of Wealth Paper: Piketty's Inequality Conclusions Inaccurate, Recommendations Impossible Background Paper

Tax Practice Management

Going Out on Your Own and Changing Firms - Practical and Ethical Considerations Outline: Ethical Issues in Changing Firms
Going Out on Your Own and Changing Firms - Practical and Ethical Considerations Outline: Discussion Outline - Key Considerations When Moving Laterally Between Law Firms
Going Out on Your Own and Changing Firms - Practical and Ethical Considerations Supplement: Checklist for Starting Your Firm

Teaching Taxation

Bitcoins and Virtual Currency: Tax and Regulatory Implications of the Growing World of Digital Currency Slides: Taxation of Virtual Income

Transfer Pricing

Advance Pricing Agreement and Competent Authority Update Slides: APMA and the REV PROCS
The Evolving Role of the IRS's Transfer Pricing Practice and the Use of the TP Road Map in IRS Audits Slides: U.S. Transfer Pricing Administration and Enforcement Update

US Activities of Foreigners & Tax Treaties

Accidental Inversions Slides: The Accidental Inversion
Flipping the Switch on Foreign Corporation’s Form of Doing Business in the US Slides: Flipping the Switch on Foreign Corporation’s Form of Doing Business in the U.S.