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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.
Administrative Practice |
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| Good News, Your Audit is Over. Or is it? The Process and Impact of a Joint Committee Review | Slides: Tax Refund Claims: A Window Into the Joint Committee on Taxation’s Review Process |
| Important Developments | Outline: Important Developments |
| International Information Return Penalties from Assessment to Abatement and All That is Inbetween | Slides: International Information Return Penalties from Assessment to Abatement and All That is In Between |
Affiliated and Related Corporations |
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| Application of the Proposed Section 385 Regulations to Consolidated Groups | Slides: Consolidated Groups & the Proposed Section 385 Regulations |
| Do We Really Understand the Consolidated E&P Rules? | Slides: Do We Really Understand the Consolidated E&P Rules? |
Capital Recovery and Leasing |
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| Basis Recovery for Assets Subject to the Foreign Sales Corporation Regime or Extraterritorial Income Exclusions | Outline: Basis Recovery for Assets Subject to the Foreign Sales Corporation Regime or Extraterritorial Income Exclusions |
| Current Developments Report and Update on Pending Guidance | Outline: Current Developmets |
Civil and Criminal Tax Penalties |
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| Civil and Criminal Enforcement Tools for Use Against Overseas Taxpayers and Taxpayers with Overseas Assets | Outline: Foreign Tax Authorities Ability to Obtain Information Via American Legal Procedures & IRS/DOJ Ability to Obtain Information Via Foreign Legal Procedures |
| Civil and Criminal Enforcement Tools for Use Against Overseas Taxpayers and Taxpayers with Overseas Assets | Slides: Civil and Criminal Enforcement Tools Used Against Offshore Assets |
| It’s a Small World After All: Evidence in Offshore Noncompliance Cases (Part II) | Slides: It’s a Small World After All: Evidence in Offshore Noncompliance Cases (Part II) |
| Valuation Misstatement Penalties | Slides: Valuation Misstatement Penalties |
Closely Held Businesses (TX) and Business Planning Group (TE) |
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| A Primer on Key Tax Elections to Plan for When Estate Planning with Closely Held Business Interests | Slides: Critical Tax Elections: Business Succession Planning |
| State Taxation of Trusts Holding Business Interests | Slides: State Taxation of Trusts Holding Business Interests |
Corporate Tax |
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| Debt and Equity as of October 1, 2016 | Slides: Section 385 Regulations |
| Recent Section 355 Developments | Slides: Recent Section 355 Developments |
Court Procedure and Practice |
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| It’s a Small World After All: Evidence in Offshore Noncompliance Cases (Part I) | Slides: It’s a Small World After All: Evidence in Offshore Noncompliance Cases (Part I) |
| Large Case Litigation in the Tax Court – Discovery and Depositions | Outline: Large Case Litigation in the U.S. Tax Court - Discovery and Depositions |
| "PATH" Through Privileges | Slides: “PATH” Through Privileges |
Employment Taxes |
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| Employment Taxes and Criminal Prosecutions | Slides: Employment Taxes and Criminal Prosecutions |
| Federal Employment Tax Update | Slides: Federal Employment Tax Update |
| New Certified Professional Employer Organizations | Slides: New Certified Professional Employer Organizations |
| Worker Classification and the Tax Court | Slides: Worker Classification and the Tax Court |
Estate & Gift Taxes (TX) and Income & Transfer Tax Planning Group (TE) |
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| New Hampshire Trusts: Why the Granite State Rocks at Trust Administration | Chart: How New Hampshire Trust Laws Compare – Delaware & Massachusetts |
| New Hampshire Trusts: Why the Granite State Rocks at Trust Administration | Slides: Why the Granite State Rocks at Trust Administration |
| They’re Finally Here! Unpacking the Proposed Regulations under Section 2704(b) | Outline: They’re Finally Here! Unpacking the Proposed Regulations under Section 2704(b) |
Exempt Organizations |
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| Corporate Integration and Exempt Organizations | Outline: Corporate Tax Reform and Tax-Exempt Entities |
| The PATH to Partnership | Slides: The Bipartisan Budget Act of 2015: Impact of Partnership Audit Rules on Tax-Exempt Organizations |
| Using Non-501(c)(3) Vehicles to Accomplish Philanthropic Objectives | Outline: Further Legal Information for Presentation on Using Non-c3 Vehicles to Accomplish Philanthropic Objectives |
| Using Non-501(c)(3) Vehicles to Accomplish Philanthropic Objectives | Slides: Using Non-c3 Vehicles to Accomplish Philanthropic Objectives |
Fiduciary Income Tax (TX) and Income & Transfer Tax Planning Group (TE) |
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| Current Developments | Outline: Recent Developments in Fiduciary Income Tax |
| Painting By Numbers: The Art of Planning With Art | Slides: Painting By Numbers: The Art of Planning With Art (Part 1) |
| Painting By Numbers: The Art of Planning With Art | Slides: Painting By Numbers: The Art of Planning With Art (Part 3) |
| Painting By Numbers: The Art of Planning With Art | Slides: Art Tax Update: Recent New York Sales and Use Tax Developments in Art Transactions (Part 2) |
| The New Basis Consistency Rules: The Top Issues Facing Practitioners | Slides: The New Basis Consistency Rules: The Top “Um-teen” Issues Facing Practitioners |
| The “Shark Fin” CLAT - A Valuable Estate Planning Tool, or Should You Stay Out of the Water? | Slides: The Shark-Fin CLAT –Go For a Swim, or Stay Out of the Water? |
Financial Transactions |
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| Section 385, the Financial Industry and the Proposed (Final?) Regulations | Slides: Section 385, the Financial Industry and the Proposed (Final?) Regulations |
| Section 871(m) Update and the New QI - QDD Notice | Slides: Section 871(m) Update and the New QI -QDD Notice |
| Speaking Truth to Power: The Finance Committee Reports on the Modernization of Derivatives Act | Slides: Speaking Truth to Power: The Financial Transactions Committee Reports on the Modernization of Derivatives Act |
Foreign Activities of US Taxpayers |
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| Managing Cash in an Ever Changing World | Slides: Managing Cash in an Ever Changing World |
Individual & Family Taxation |
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| Ethical Considerations in Individual and Family Representation | Slides: Ethical Considerations in Individual & Family Representation |
| Higher Education Savings and Planning: Tax & Non-Tax Considerations | Slides: Higher Education Savings and Planning: Tax & Non-Tax Considerations |
Insurance Companies |
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| Section 385 Regulations | Slides: Taking Stock in Related-Party Debt: Insurers Confront New Issues Under Proposed Debt-Equity Regulations |
| The Secret Life of Captives | Slides: The Secret Life of Captives |
Investment Management |
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| Current Legislative and Regulatory Initiatives Impacting Regulated Investment Companies | Slides: EU Reclaims Netting Mechanics: Applying Notice 2016-10 |
| Current Legislative and Regulatory Initiatives Impacting Regulated Investment Companies | Slides: Money Market Reform Tax Guidance and Issues |
| Current Legislative and Regulatory Initiatives Impacting Regulated Investment Companies | Slides: (Really) Recent IRS Guidance on CFCs and Securities |
| Managing the Special Tax Issues Presented by Sovereign Wealth Fund Investors in US-Domiciled Funds | Slides: Tax Issues Presented by Sovereign Wealth Fund Investors in US Domiciled Investment Funds |
| Partnership Audit Reform and Private Funds | Slides: Partnership Audit Reform and Private Funds |
Partnerships & LLCs |
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| Hot Topics in Partnerships & LLCs | Slides: Hot Topics |
| Qualifying Income of PTP’s: What’s In (And What’s Out) | Slides: Qualifying Income of PTPs: What’s In (and What’s Out) |
| Recent Sea Changes Affecting Subchapter K: Sections 385 and Section 721(c) | Slides: Recent Sea Changes Affecting Subchapter K: Sections 385 and Section 721(c) |
| Section 743 Basis Adjustments | Slides: Section 743(b) Basis Adjustments |
Pro Bono & Tax Clinics |
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| Adopt-A-Base | Slides: Military Adopt-A-Base Program FY 2017 |
| Military Tax Issues | Outline: Military Tax Panel |
| Military Tax Issues | Outline: State Tax Preparation and Tax Aspects of the SCRA |
| Poverty and Tax in America | Slides: A Differing Take on EITC Compliance: Taxpayer Rights |
| Poverty and Tax in America | Slides: Complicated Families – Complicated Taxes |
| Recent Developments | Outline: Recent Developments: ITINs, Education Credit Proposed Regulations, and Form 8867 |
Real Estate |
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| Current Events Affecting Real Estate Transactions | Slides: Current Events Affecting Real Estate Transactions |
| PATH Act - Section 897 | Slides: The PATH Act: FIRPTA Provisions |
S Corporations |
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| Important Developments | Outline: Current Developments in the Federal Income Taxation of S Corporations |
Sales, Exchanges & Basis |
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| Current Developments | Outline: Current Non-Section 1031 Developments |
| Current Developments | Outline: Current Developments in Like-Kind Exchanges |
| “I Was Ripped Off. Do I Get a Deduction?” | Slides: I Was Ripped Off. Do I Get a Deduction? |
Joint Section Programs |
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| Nationwide Marriage Equality Revisited: Emerging Issues | Slides: Nationwide Marriage Equality Revisited: Emerging Issues |
Standards of Tax Practice |
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| Ethical Considerations in IRS Settlement Negotiations | Slides: Ethical Considerations in IRS Settlement Negotiations |
| Ethical Issues in Federal Tax Practice - The Government Perspective | Slides: Office of Professional Responsibility Update |
| Ethical Obligations in Representing Deceased, Incompetent and Unavailable Clients | Slides: Ethical Obligations in Representing Deceased, Incompetent and Unavailable Clients |
State & Local Taxes |
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| No Winners Here: Tax Administration in an Anti-tax Environment | Slides: No Winners Here: Tax Administration in an Anti-tax Environment |
| Potential State Tax Implications of Proposed IRC 385 Debt/Equity Regulations | Slides: Potential State Tax Implications of Proposed IRC §385 Debt/Equity Regulations |
| Remote Use Tax Collection in a Post-Quill World | Slides: Remote Use Tax Collection in a Post-Quill World |
Tax Accounting |
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| Inventory Accounting Update | Outline: Inventory Accounting Update |
| Issues Involving Advance Payments | Outline: Issues Involving Advance Payments |
| Issues Involving Advance Payments | Slides: Issues Involving Advance Payments |
Tax Bridge on the Road |
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| Basics & Hot Topics: RICs and REITs | Slides: Basics & Hot Topics: RICs and REITs |
| Nuts & Bolts: Same-Sex Estate Planning after Obergfell v. Hodges | Outline: Same-Sex Marriage and Estate Planning: Nope, It’s Not Over Yet! |
| The Intersection of Sports and Tax Law | Slides: Intersection of Sports and Taxes |
Tax Policy & Simplification |
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| Integration of Corporate and Shareholder Income Taxes | Outline: Integration of Corporate and Shareholder Income Taxes |
| Integration of Corporate and Shareholder Income Taxes | Slides: Corporate Taxation: Understanding the Potential of Integration |
| Tax Incentives for Technological Innovation | Outline: Innovation Tax Incentives |
Tax Practice Management and Young Lawyers Forum |
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| Legal Incubators: What Are They and How Can They Impact My Practice? | Outline: Legal Incubators: What Are They and How Can They Impact My Practice? |
Teaching Taxation and State & Local Taxes |
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| When Is Something a “Tax”? | Slides: When Is Something a “Tax”? |
Transfer Pricing |
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| Current Transfer Pricing Issues in the Biotechnology and Technology Industries | Slides: Biotech and Tech Transfer Pricing Panel |
| OECD Country-by-Country Data Submissions: A Potential for Misapplication of Big Data? | Slides: OECD Country-by-Country Data Submissions: A Potential for Misapplication of Big Data |
| The Work of Competent Authority Today: Perspectives from Canada and the US | Slides: The Work of Competent Authority Today: Issues and Challenges |
US Activities of Foreigners & Tax Treaties |
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| Brave New World - Implications of the Proposed 385 Regulations on Inbound Transactions | Slides: Brave New World – Implications of the Proposed 385 Regulations on Inbound Transactions |