TaxIQ

2015 Joint Fall CLE Meeting

September 17-19, Chicago, IL

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.


Administrative Practice

Back to Basics: Who Has Capacity to Sign on Behalf of the Taxpayer Slides: Back to Basics: Who Can Sign on Behalf of Taxpayers
Important Developments Slides: Current Developments

Affiliated & Related Corporations

The Intersection of Subchapter K and Consolidated Returns Slides: The Intersection of Subchapter K and Consolidated Returns

Banking & Savings Institutions

Banking & Savings Tax Update Slides: Recent Developments Affecting The Banking Community
Dual Consolidated Loss Issues for Banking Entities Slides: Dual Consolidated Losses

Capital Recovery & Leasing

Current Developments Report and Update on Pending Guidance Outline: Current Developments

Civil & Criminal Tax Penalties

Aggressive IRS Audit Techniques – Tales from the Trenches Slides: Aggressive IRS Audit Techniques: Talkes from the Trenches
Reports of Subcommittees on Important Developments Outline: Civil and Criminal Tax Penalties Importane Developments - Criminal
Tax Preparer Fraud: Strategies for Defending the Tax Preparer or Promoter in Criminal and Civil Injunction Litigation Slides: Tax Preparer Fraud: Strategies for Defending the Tax Preparer or Promoter in Criminal and Civil Injunction Litigation

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

Old MacDonald Has a Farm... With Corporate Farming Statutes Here and Special Use Valuation There, What Kind of Planning Can He Do? Outline: Old MacDonald Has a Farm … With Corporate Farming Statutes Here and Special Use Valuation There, What Kind of Planning Can Old MacDonald Do?
Selling the Dreaded C-Corp While Minimizing the Double Taxation Outline: Selling the Dreaded C-Corp While Minimizing the Double Taxation
The Nuts & Bolts of Captive Insurance Companies Slides: The Nuts & Bolts of Captive Insurance Companies

Corporate Tax

Section 361(c) and Its Discontents Slides: Section 361(c) and Its Discontents

Court Procedure & Practice

Conflicts and Chaos: The Importance of Timely Recognizing and Managing Conflicts of Interest in Tax Litigation Handout: Discussion Hypotheticals
Conflicts and Chaos: The Importance of Timely Recognizing and Managing Conflicts of Interest in Tax Litigation Outline: Conflicts and Chaos: The Importance of Timely Recognizing and Managing Conflicts of Interest and Related Problems in Tax Litigation
Ethical Issues Arising in Discovery Slides: Ethical Issues Arising in Discovery
Important Developments Outline: Summary of Current Developments
Roundtable Discussion: Effective Writing in the Tax Court - "Prologue and Postscript: The Pretrial Memorandum and Post-Trial Brief, With Views from the Bench" Slides: Prologue and Postscript: The Pretrial Memorandum and Post-Trial Brief, With Views from the Bench

Diversity

Obergefell v. Hodges: Tax and Estate Planning Issues for Employers and Individuals Outline: Obergefell v. Hodges: Tax and Estate Planning Issues for Employers and Individuals
Obergefell v. Hodges: Tax and Estate Planning Issues for Employers and Individuals Outline: Employee Benefits Issues for Employers and Individuals after Obergefell v. Hodges
The Influence of Cultural Differences on Estate, Tax, and Employment Benefit Planning, Part II Slides: Elimination of Bias in the Legal Profession: The Influence of Cultural Differences on Estate, Tax, and Employment Benefit Planning, Part II

Employee Benefits

2015 Health Plan Advice: Ethics, Technical & Practical Challenges Outline: Updated IRS Guidance on ACA Reporting: Draft 2015 Forms and Instructions Released by IRS
Corporate Counsel Forum Slides: Nobody Wants to Be a Fiduciary: Mitigating Plan Sponsor’s Executives’ Fiduciary Liability
Defined Benefit Plan and Distributions Update Slides: PBGC Regulatory Update
Defined Benefit Plan and Distributions Update Slides: PBGC Updates
Defined Contribution Plans Update Outline: Field Assistance Bulletin 2015-02: Department of Labor Clarifies Annuity Selection Safe Harbor
Department of Treasury and Internal Revenue Service Hot Topics Outline: Summary of Selected Guidance Issued by the Department of the Treasury and the Internal Revenue Service during the Past 12 Months
Employer Wellness Programs and EEOC Proposed Rules Under the ADA Outline: Employer-Sponsored Wellness Programs: Who Sponsors Them? What Do They Offer? Do They “Work”? The Regulators’ Approaches to Employer-Sponsored Wellness Programs
ESOP Update Outline: Non-Corporate Forms of Entity Participation in ESOPs
ESOP Update Outline: Employee Benefits ESOP Update
Exempt Organization and Governmental Plans Update Chart: Available Catch-Up Contributions for 403(b) Plans
Exempt Organization and Governmental Plans Update Outline: Advisory Committee on Tax Exempt and Government Entities 403(b) Plan Recommendations
Keeping or Closing the Employer Stock Fund After Dudenhoeffer and Tatum – A Fiduciary Process Slides: Company Stock in 401(k) Plans The Role of the Independent Fiduciary
Litigation Update Outline: Cases from June, July and August 2015
Multinational Employee Benefits & Compensation Issues Slides: Impact Of New Accounting Rules on Executive Compensation
Multinational Employee Benefits & Compensation Issues Slides: International Considerations of Proposed Clawback Rules, Final Pay Ratio Rules
Multiple Employers, PEOs and Controlled & Affiliated Service Groups Update Outline: A Brief Comparison of Master Trusts and Open MEPs
Multiple Employers, PEOs and Controlled & Affiliated Service Groups Update Outline: Summary of Senate Finance Report on Plan Participation
Multiple Employers, PEOs and Controlled & Affiliated Service Groups Update Outline: Compilation of Affiliated Service Group &/or Management Service Organization Situations That Need Guidance
Over 20 Years of IRC Section 162(m) and 30 Years of IRC Section 280G – Has It Made a Difference in Executive Compensation? Slides: Over 20 Years of 162(m) and 30 years for 280G - Has it made a Difference in Executive Comp?
Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: Religiously Affiliated Nonprofits and Closely Held Employers with Religious Objections to Contraceptive Coverage May Use Accomodation to Comply with ACA
Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Slides: Group Health Plans: Factors Affecting Health Care Providers and the Costs They Generate for Employers and Participants

Employment Taxes

Employment Tax Primer for Small Businesses: I'm Ready to Hire My First Employee. What Should I Know About Taxes? Slides: Employment Tax Primer for Small Businesses: I’m Ready to Hire My First Employee. What Should I Know About Taxes?
Federal Employment Tax Update Slides: Federal Employment Tax Update
The Count Down Continues: Affordable Care Act (ACA) Slides: Count Down Continues: Affordable Care Act (ACA)

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

Current Developments Outline: Current Developments in Federal Transfer Taxes
Death, Divorce and Reproductive Technology: What Every Practitioner Needs to Know Now About Planning For the Future Outline: Resolving Disputes over the Disposition of Frozen Embryos In the Context of Divorce
Death, Divorce and Reproductive Technology: What Every Practitioner Needs to Know Now About Planning For the Future Outline: Death, Divorce and Reproductive Technology: What Every Practitioner Needs to Know Now About Planning for the Future
Section 2801 Uncovered: Taxation of Gifts and Bequests from Covered Expatriates Outline: Section 2801 Uncovered: Taxation of Gifts and Bequests from Covered Expatriates
The Middle Way: The Uniform Trust Decanting Act Outline: The Middle Way: The Uniform Trust Decanting Act
Understanding Valuation Discounts Slides: Understanding Valuation Discounts
Understanding Valuation Discounts Outline: Understanding Valuation Discounts

Exempt Organizations

Best Practices: Prizes, Sweepstakes, Contests and Awards Slides: Best Practices: Prizes, Sweepstakes, Contests and Awards
Coloring Outside the Lines: The Art of Gifting Art Outline: Coloring Outside the Lines: The Art of Gifting Art
Not So Fast: Exempt Organization Changes and Your State Attorney General Slides: Not So Fast: Exempt Organization Changes and Your State Attorney General
Section 501(c)(6) Trade Associations: Tax Issues, Governance, Controversies Slides: Section 501(c)(6) Trade Associations: Tax Issues, Governance, Controversies

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

Current Developments Outline: Recent Developments in Fiduciary Income Tax
Implementation and Administration of Self-Cancelling Installment Notes Outline: Implementation and Administration of Self-Cancelling Installment Notes
Income Tax Deductions for Charitable Bequests of IRD Article: Treacherous Waters: Using IRD for Charitable Bequests
Section 2704(b) Proposed Regulations and Valuation Discounts on Transfers of Closely Held Entities Slides: Possible Section 2704(b) Proposed Regulations and Valuation Discounts on Transfers of Closely Held Entities

Financial Transactions

Financial Products and Partnership Interests Slides: Financial Products and Partnership Interests

Foreign Activities of US Taxpayers

Incorporations and Liquidations of Foreign Entities Slides: Selected Issues Relating to Inbound Liquidations Outbound Contributions and Foreign-to-Foreign Transactions
Issues Arising Under Section 956 – Part I Slides: Issues Arising Under Section 956

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

Joint Current International Developments Panel Slides: Joint Current International Developments Panel

Individual & Family Taxation

Household Employee Tax Compliance Outline: The Requirements of Tax Reporting For Household Employees
Household Employee Tax Compliance Slides: Household Employee Tax Compliance: Worker Classification Issues
Penalty Panel Part II Slides: IRS “Additions To Tax”
Taxpayer Filing Status - Options and Recent Law Outline: Taxpayer Filing Status
Taxpayer Filing Status - Options and Recent Law Outline: Breaking Up Is Hard To Do: Protecting Divorcing Spouses from the IRS (and Each Other)
Taxpayer Filing Status - Options and Recent Law Outline: List of Unavailable Refundable Tax Credits With The Filing Status of Married Filing Separately
Taxpayer Filing Status - Options and Recent Law Outline: Filing Status Issues for nonresident taxpayers and resident alien taxpayers
Taxpayer Filing Status - Options and Recent Law Outline: Filing Status Outline

Insurance Companies

Litigation / Administrative Update Slides: Insurance Companies and Products: Litigation and Administrative Update
Reinsurance Update Slides: Reinsurance Update
Retaliatory Taxes and Other State Premium Tax Issues Slides: SALT for Insurance

Investment Management

Current Issues for Private Investment Funds and their Managers Slides: Selected Tax Issues Impacting Private Investment Funds and Their Managers
Current Issues for Regulated Investment Companies Slides: Current Issues for Regulated Investment Companies
Current Issues for Regulated Investment Companies Slides: Current Issues for Regulated Investment Companies
Current Issues for Regulated Investment Companies Slides: Current Issues for Regulated Investment Companies
Thinking About Converting to an RIC? Important Considerations Slides: Thinking about Converting to a RIC? Important Considerations

Joint Section Programs

Estate Tax Return Preparation and Audit Mitigation Strategies Slides: Estate Tax Return Preparation and Audit Mitigation Strategies
Obergefell: Remaining Estate Planning and Tax Issues and a Look Into the Future Outline: Same-Sex Marriage and the Road to Nationwide Recognition
Tax, Immigration, and Employment Issues for Household Employees Outline: The Requirements of Tax Reporting For Household Employees
Tax, Immigration, and Employment Issues for Household Employees Slides: Household Employee Tax Compliance: Worker Classification Issues

Partnerships & LLCs

Issues Arising Under Section 956 – Part II Slides: Issues Arising Under Section 956
Management Fee Waivers Slides: Waiving Goodbye: Proposed Regulations under Section 707(a)(2)(A)
Partnership Debt vs. Debt-Like Equity Slides: What is the difference? Partnership Debt v. Debt-Like Equity?
Staying Dry Under The Umbrella: Avoiding PTP Issues In Umbrella Partnership Structures Slides: PTP Issues in UPREIT, UP-C and UP-PTP Structures

Pro Bono & Tax Clinics

Basics of IRS Collection Alternatives Outline: Basic and Trending Issues in Tax Collection
Designing a Pro Bono Project for Your Firm Slides: Designing a Pro Bono Project for Your Firm: Military VITA Adopt-A-Base Program
Recent Developments Affecting Low-Income Taxpayers Outline: Recent Developments Affecting Low-Income Taxpayers

Real Estate

Dealer vs. Investor - Caselaw Update Slides: Dealer v. Investor Revisited
Dealer vs. Investor - Caselaw Update Outline: Wading Into the Investor/Dealer Quagmire -- Coffee Break’s Over, Back on Your Heads
Federal Tax Impact of Using State Tax Credits Outline: Federal Income Tax Aspects of State Tax Credits
Hot Topics Slides: Real Estate Committee Hot Topics
Motivating the Real Estate Deal and Fund Team – Part Deux Slides: Motivating the Real Estate Deal and Fund Team – Part Deux

S Corporations

Important Developments Outline: Current Developments in the Federal Income Taxation of S Corporations
Primer on S Corporation Shareholders Outline: Primer on S Corporation Shareholders
S Corporation Valuations Issues Slides: Understanding & Valuing S-Corporations
Trusts Decanting with S Corporation Shareholders Slides: Trust Decanting of S Corporation Shareholders

Sales, Exchanges & Basis

A Primer on Section 1031 Transactions Outline: Real Estate Exchanges Under I.R.C. Section 1031
Current Developments Outline: Current Developments
Current Developments Outline: Current Non-Section 1031 Developments
Negotiating and Drafting Tax Provisions in Rental Real Estate Purchase Agreements Slides: Negotiating and Drafting Tax Provisions in Real Estate Purchase Agreements
The "Partnership Installment Note" Transaction Slides: The Partnership Installment Note (PINs) Transaction

Standards of Tax Practice

Ethical Issues in Federal Tax Practice - The Government and Local Perspective Slides: Ethical Issues in Federal Tax Practice – The Government and Local Perspective
Ethics Two-Minute Drill Outline: Ethics Two-Minute Drill
Ethics Two-Minute Drill Slides: Ethics Two-Minute Drill
Procedures to Ensure Compliance Slides: Oversight Responsibilities in Tax Practice under Circular 230 §10.36

State and Local Taxes

Revising the Uniform Unclaimed Property Act Slides: Revising the Uniform Unclaimed Property Act
State Resident Tax Credits After the Supreme Court’s Wynne Decision Slides: State Resident Tax Credits After the Supreme Court’s Wynne Decision

Tax Accounting

Current Developments Outline: Current Developments
Tax Accounting Method Issues for Financial Institutions and Financial Products Outline: Tax Accounting Method Issues for Financial Institutions and Financial Products of Non-financial Institutions
Transaction Costs in Business Acquisitions: Recent Developments and Hot Topics Slides: Transaction Costs in Business Acquisitions: Recent Developments and Hot Topics
Update on Prevalent Tangible Property Regulations Issues and Anticipated Guidance Outline: Summary of Select Discussion Topics - Tangible Property and Disposition Regulations

Tax Bridge on the Road

Ethical Issues for Newer Attorneys Outline: Tax Bridge on the Road: Ethical Issues for Young Tax Lawyers
Ethical Issues for Newer Attorneys Slides: Ethical Issues for Newer Attorneys
Social Media: Ethics in the Internet Age Slides: Social Media: Ethics in the Internet Age
State Income, Double Taxation, and Tax Discrimination in the Post-Wynne World Outline: State Income, Double Taxation, and Tax Discrimination in the Post-Wynne World
State Income, Double Taxation, and Tax Discrimination in the Post-Wynne World Slides: State Income, Double Taxation, and Tax Discrimination in the Post-Wynne World
State Income, Double Taxation, and Tax Discrimination in the Post-Wynne World Slides: MD Comptroller of Treasury v. Wynne: The Impact upon Philadelphia and Pennsylvania Taxpayers

Tax Policy & Simplification

Estate Tax on Farms: Repeal, Retain, or Reform? Outline: Estate Tax on Farms: Repeal, Retain, or Reform?
Estate Tax on Farms: Repeal, Retain, or Reform? Slides: The State of the Estate Tax: Will and Should the Death Tax Die?
Estate Tax on Farms: Repeal, Retain, or Reform? Outline: Reforming the Estate Tax
The Design of Tax Incentives: Lessons from Energy and Environmental Incentives Slides: The Design of Tax Incentives: Theory and Practice
The Design of Tax Incentives: Lessons from Energy and Environmental Incentives Article: Picking Winners an Losers: History, Political Economy, and the Effects of "Imbeddedness" for Tax Subsidies to the Energy Industry

Teaching Taxation

The Status of the Tax Court post-Kuretski: Significant Shift, Minor Adjustment, or Nothing New? Outline: The Status of the Tax Court post-Kuretski: Significant Shift, Minor Adjustment, or Nothing New?
The Status of the Tax Court post-Kuretski: Significant Shift, Minor Adjustment, or Nothing New? Outline: The Un-Precedented Tax Court

Transfer Pricing

Preparing for Country by Country Reporting Slides: BEPS, Country-by-Country reporting and the new approach to compliance

US Activities of Foreigners & Tax Treaties

The New US Model Treaty and Treasury Explanation: What is Proposed and What is Needed Slides: Proposed Changes to US Model Treaty and Suggestions for New Technical Explanation