TaxIQ

2016 Joint Fall CLE Meeting

September 29-October 1, Boston, MA

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

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

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

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

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)

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

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

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

Diversity

Tax and Planning Considerations for Special Needs Trusts Slides: ABLE Program §529A Legislation
Tax and Planning Considerations for Special Needs Trusts Outline: Taxation of Special Needs Trusts
Tax and Planning Considerations for Special Needs Trusts Outline: Special Needs Trust Administration Issues
Tax and Planning Considerations for Special Needs Trusts Outline: ABLE: Achieving a Better Life Experience: A Primer for Estate & Trust Attorneys
Tax and Planning Considerations for Special Needs Trusts Slides: Taxation of Special Needs Trusts
Tax and Planning Considerations for Special Needs Trusts Slides: ABLE Act: Aka “The Stephen Beck, Jr. Achieving a Better Life Experience”: A New Option for People with Disabilities
Tax and Social Policy: Delivering Social Benefits Through the Tax Code Outline: How Housing Tax Policy Affects Inequality of Income and Opportunity
Tax and Social Policy: Delivering Social Benefits Through the Tax Code Slides: How Housing Tax Policy Affects Inequality of Income and Opportunity
Tax and Social Policy: Delivering Social Benefits Through the Tax Code Slides: Tax & Social Policy: Delivering Social Benefits Through the Tax Code

Employee Benefits (TX), Employee Benefits Group (TE) and Welfare Plans Committee (TE)

401(k) Plans on Autopilot Outline: 401(k) Plans on Autopilot: Automatic Enrollment 401(K) Plan
Defined Benefit Plan and Distributions Update Outline: Recent PBGC Legislative/Regulatory Developments
Defined Benefit Plan and Distributions Update Slides: Hybrid Pension Plans: Amendment Countdown
Executive Compensation, Fringe Benefits and Federal Securities Law Update Slides: Transactions Update: Purchase Price or Compensation
Exempt Organization and Governmental Plans Update Outline: State Automatic IRAs
Litigation Update Outline: Case Summaries
Litigation Update Outline: New Developments in Retirement Plan Fee Cases
Maintaining Retirement Plan Documents after Revenue Procedure 2016-37 Slides: Maintaining Retirement Plan Documents after Revenue Procedure 2016-37
Multinational Employee Benefits & Compensation Issues Slides: Proposed Regulations to Expatriate Health Coverage Clarification Act of 2014
Multiple Employers, PEOs and Controlled & Affiliated Service Groups Update Outline: Savings Arrangements Established by States for Non-Governmental Employees - DOL Final and Proposed Rules
Plan Participant Disclosures Slides: Participant Plan Disclosures
The Proposed 457(f) and 409A Regulations - What You Need to Know Outline: Deferred Compensation Plans of Governmental and Tax Exempt Employers – Outline of Section 457 Requirements and Impact of Proposed Regulations
The Proposed 457(f) and 409A Regulations - What You Need to Know Slides: The Proposed Section 457(f) and 409A Regulations -What You Need to Know
Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Slides: Expatriate Health Plan Proposed Regulations
Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: DOL Subregulatory Guidance on Compliance with MHPAEA

Employment Taxes

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)

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

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)

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

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

Managing Cash in an Ever Changing World Slides: Managing Cash in an Ever Changing World

Individual & Family Taxation

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

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

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

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

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

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

Important Developments Outline: Current Developments in the Federal Income Taxation of S Corporations

Sales, Exchanges & Basis

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

Nationwide Marriage Equality Revisited: Emerging Issues Slides: Nationwide Marriage Equality Revisited: Emerging Issues

Standards of Tax Practice

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

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

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

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

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

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

When Is Something a “Tax”? Slides: When Is Something a “Tax”?

Transfer Pricing

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

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