TaxIQ

2017 Joint Fall CLE Meeting

September 14-16, Austin, TX

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 PDF 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

Dawn of a New Era – the New Partnership Audit Rules Will Soon Be Upon Us Slides: Dawn of a New Era – The New Partnership Audit Rules will Soon Be Upon Us
Important Developments in Administrative Practice Outline: Important Developments, Fall 2017
Important Developments in Administrative Practice Slides: Important Developments

Affiliated and Related Corporations

Current Developments in Affiliated & Related Corporations Slides: Current Developments for Consolidated Groups
Section 267: More than Granite Trust Slides: Section 267: More than Granite Trust

Banking & Savings Institutions

Beyond Bitcoin: Blockchain and the Tax System Slides: Beyond Bitcoin: Blockchain and the Tax System
Current Developments in Captive Insurance Companies Slides: The Captive Landscape
Energy Credits – Watt to Do? Slides: Energy Credits: Watt to Do?

Capital Recovery and Leasing

Current Developments Report and Update on Pending Guidance Outline: Current Developments Report and Update on Pending Guidance
Examination Experience with the Tangible Property Regulations Outline: Examination Items and Issues Pertaining to Tangible Property

Civil and Criminal Tax Penalties

Introduction to the New Chief of CI Outline: CCTP Updates—Important Developments: Criminal
Pressure from Foreign Governments and International Organizations on U.S. Tax Practitioners and Proposed Responses Paper: Pressure from Foreign Governments and International Organizations on U.S. Tax Practitioners and Proposed Responses: A Brave New World
Reports of Subcommittees on Important Developments Outline: Important Civil Developments: Third Quarter 2017
Reports of Subcommittees on Important Developments Outline: Subcommittee Report: Legislative and Administrative Developments
Reports of Subcommittees on Important Developments Slides: CLEIRS Investigations & Practices Subcommittee Report
Reports of Subcommittees on Important Developments Outline: Report on Offshore Enforcement Developments
State Prosecution of Tax Crimes Slides: State Prosecution of Tax Crimes

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

New Issues in Partnership Freezes Slides: Drop and Freeze: Current Issues and New Uses
Options for Cross-Purchase and Redemption Structures Outline: Options for Cross-Purchase and Redemption Structures
Partnership Audit Rules: Update and Practical Considerations for Closely Held Businesses Slides: New Centralized Partnership Audit Regime Overview and Practical Considerations
Recent Self-Employment Cases and Planning Implications Outline: Recent Self-Employment Cases and Planning Implications
Practical Uses of Sales of Business Interests to Intentionally Defective Grantor Trusts and Grantor Retained Annuity Trusts for Closely-Held Business Owners Slides: Sales of Business Interests to Intentionally Defective Grantor Trusts and Grantor Retained Annuity Trusts

Collection Workshop

How to Represent Taxpayers in Collection Matters From the Notice and Demand Through the Notice of Determination Outline: Nuts and Bolts of Tax Collection and CDP
How to Represent Taxpayers in Collection Matters From the Notice and Demand Through the Notice of Determination Paper: Assessments and Liabilities
How to Represent Taxpayers in Collection Matters From the Notice and Demand Through the Notice of Determination Paper: Tax Lien Basics
How to Represent Taxpayers in Collection Matters From the Notice and Demand Through the Notice of Determination Paper: Third Party Collection

Corporate Tax

Current Developments in Corporate Tax Slides: Corporate Tax Current Developments
Exploring the Boundaries of General Utilities Repeal Slides: Exploring the Boundaries of GU Repeal
Revenue Ruling Guidance We’d Like to See Slides: Revenue Ruling Guidance We’d Like to See

Court Procedure and Practice

Answering for a Professional’s Misconduct – How a Professional’s Actions Can Become the Taxpayer’s Responsibility Outline: Answering for a Professional’s Misconduct – How a Professional’s Actions Can Become the Taxpayer’s Responsibility
Answering for a Professional’s Misconduct – How a Professional’s Actions Can Become the Taxpayer’s Responsibility Outline: Fraudulent Conduct by Other than the Taxpayer as a Basis for Extending the Time to Assert Tax Deficiencies Against the Taxpayer
Can’t Get There from Here: Passport Restrictions for Seriously Delinquent Tax Debtors Slides: Can’t Get There from Here: Passport Restrictions for Seriously Delinquent Tax Debtors
Current Developments in Court Procedure and Practice Outline: Summary of Recent Opinions
Questions About Questions: How to Interview a Witness Slides: Questions About Questions: How to Interview a Witness
Revenue Agent as Witness Outline: Government Employees as Witnesses

Diversity

ITIN, FICA, CSED, CDP... Am I Speaking Your Language? Increasing Participation Among English as a Second Language Communities in Federal and Local Tax Systems Slides: Tax Issues and English as a Second Language
ITIN, FICA, CSED, CDP... Am I Speaking Your Language? Increasing Participation Among English as a Second Language Communities in Federal and Local Tax Systems Slides: Protecting Your Clients against Notorious Notarios: How Fraud can lead to IRS Debt or Deportation

Employee Benefits

Defined Benefit Plans and Distributions Update Outline: Recent PBGC Legislative/Regulatory Developments
Defined Benefit Plans and Distributions Update Slides: QNEC and QMAC Proposed Regulations
Defined Contribution Plans Update Outline: Pre-Approved Document Program Modified to Accommodate More Plan Designs
ESOP Update Outline: Petersen v. Commissioner
Executive Compensation, Fringe Benefits and Federal Securities Law Update Slides: A Primer on CEO Pay Ratio
Exempt Organization and Governmental Plans Update Slides: State Sponsored/Facilitated Plans: The Secure Choice Pension Model
Fiduciary Responsibility & Plan Investments Update Outline: Fiduciary Responsibility and Plan Investment Regulatory Developments
Missing Participant Issues and Proposed Expansion of PBGC Missing Participant Program Outline: PBGC Issues Proposed Regulations on Missing Participant Program
Missing Participant Issues and Proposed Expansion of PBGC Missing Participant Program Slides: Missing Participants Program
Multinational Employee Benefits & Compensation Issues Update Slides: Walter Energy and Cross-Border Pension Claims
Multiple Employers, PEOs and Controlled Groups Update Slides: Certified Professional Employer Organization Update: Considerations and Process
Proxy Drafting in Uncertain Times Slides: Proxy Drafting in Uncertain Times
Repeal, Replace and Deregulate: The First Six Months Slides: Repeal, Replace and Deregulate: The First Six Months
Welfare Plans and EEOC, FMLA and Leaves Issues Update Outline: Employer-Sponsored Group Health Benefit Plans: Strategies to Reduce Costs and Increase Value
Welfare Plans and EEOC, FMLA and Leaves Issues Update Outline: Legislative Efforts to Repeal or Modify the Cadillac Tax

Employment Taxes

Hot Topics in Employment Taxes Slides: Federal Employment Tax Update
How to Fix It? Practical Considerations in Employment Tax Corrections Slides: How to Fix It? Practical Considerations in Employment Tax Corrections
Mobile Workforce Slides: Mobile Workforce

Energy & Environmental Taxes

Updates Impacting the Energy Industry Slides: Updates Impacting the Energy Industry

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

Family Limited Partnerships – Update Outline: The Non-Events of Current Events: Limited Partnership Litigation and Other Updates
Family Limited Partnerships – Update Slides: The Non-Events of Current Events: Limited Partnership Litigation and Other Updates
Moving to Tax Paradise: Three Options for the Mobile Taxpayer Outline: Moving to Tax Paradise: Three options for the mobile taxpayer
Moving to Tax Paradise: Three Options for the Mobile Taxpayer Slides: Moving to Puerto Rico: A Tax Hybrid

Exempt Organizations

Exemption from Property Tax vs. Income Tax: Analyzing the Intersection Outline: Exemption from Property Tax vs. Income Tax: Analyzing the Intersection
Intermediaries: The EO "Swiss Army Knife" Outline: Intermediaries: The EO "Swiss Army Knife"
Lessening the Burdens of Government in the 21st Century Slides: Lessening the Burdens of Government in the 21st Century
News from the IRS and Treasury Slides: News from the IRS and Treasury With Legislative and Judicial Updates
Not-for-Profit Financial Reporting: What Tax Lawyers Need to Know about the New FASB Guidance Slides: Not‐for‐Profit Financial Reporting: What Tax and Legal Advisors Need to Know About the New FASB Guidance

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

Abbreviated Subchapter J Boot Camp – Income Taxation of Ordinary Trusts Slides: Abbreviated Subchapter J Boot-Camp: Income Taxation of Ordinary Trusts
Current Developments and Section 682 Support Trusts Slides: Support Trusts in Lieu of Alimony
Current Developments and Section 682 Support Trusts Slides: Recent Developments in Fiduciary Income Tax
Estate Planning and S-Corporation Stock: What Were Those Rules Again? Outline: Estate Planning and S Corporation Stock: What Were Those Rules Again?

Financial Transactions

Mark-to-Market Taxation: Examining the Prospects for MODA or Similar Legislation Slides: Mark-to-Market Taxation of Derivatives: Examining the Prospects for MODA or Similar Legislation

Individual & Family Taxation

Military VITA Training Opportunities Through the Adopt-A Base Program Slides: Military VITA Training Opportunities Through the Adopt-A Base Program
Private Cause of Action for Improper Issuance of Information Returns Outline: Section 7434: A Roadmap and Summary of Key Issues
Private Cause of Action for Improper Issuance of Information Returns Slides: Section 7434: Private Cause of Action for False Information Returns
Tax Issues Facing the Amish Community Slides: Tax Issues of the Amish

Insurance Companies

Correcting Failed Life Products Slides: Closing Agreements for Life Insurance Products
Current Health Care Tax Issues Slides: Current Health Care Tax Issues
Update on OECD Initiatives Affecting Insurance Companies Slides: BEPS CbCReporting and MLI Developments

Investment Management

Current Issues for Funds Making Energy-Related Investments Slides: Current Issues for Private Equity Funds Making Energy Related Investments
Grecian Magnesite: Exiting Private Funds with ECI Investments Slides: Grecian Magnesite: Exiting Private Funds with ECI Investments
RIC Liquidations Slides: Liquidations of Regulated Investment Companies

Partnerships & LLCs

Advantages of the Partnership Form Slides: Advantages of Partnership Form
Stacked Partnerships: Straightforward Tiers or Potential Tears? Slides: “Stacked Partnerships: Straightforward Tiers or Potential Tears?”
Your Allocations and Capital Accounts are Screwed Up! - What's a Partner(ship)/Tax Advisor/Return Preparer To Do? - Part 1 Outline: Your Allocations and Capital Accounts are Screwed Up! - What's a Partner(ship)/Tax Advisor/Return Preparer To Do?
Your Allocations and Capital Accounts are Screwed Up! - What's a Partner(ship)/Tax Advisor/Return Preparer To Do? - Part 1 Slides: Your Allocations and Capital Accounts are Screwed Up! - What's a Partner(ship)/Tax Advisor/Return Preparer To Do?

Pro Bono & Tax Clinics

Private Debt Collection Slides: When Private Debt Collection Agencies Break Bad: Taxpayer Remedies for Tax Collection Violations under the FDCPA
Recent Developments in Pro Bono & Tax Clinics Outline: Recent Developments in Federal Income Taxation Affecting Low-Income Taxpayers
Recent Developments in Pro Bono & Tax Clinics Slides: Recent Developments in Federal Income Taxation Affecting Low-Income Taxpayers

S Corporations

Important Developments in S Corporations Outline: Important Developments in the Federal Income Taxation of S Corporations
Section 409A Issue Spotting Slides: Compensation Issues Under Internal Revenue Code Sections 409A and 3121(v)(2) for S Corporations
Using LLCs as S Corporations Outline: Operating an S Corporation Through a State Law Limited Liability Company

Sales, Exchanges and Basis

Capital Gains for Songwriters and Other Creators - at the Austin City Limits and Beyond Slides: Capital Gains for Songwriters and Other Creators - at the Austin City Limits and Beyond
Current Developments and Legislative Prospects Relating to Sales, Exchanges & Basis Outline: Current Non-Section 1031 Developments
Current Developments and Legislative Prospects Relating to Sales, Exchanges & Basis Outline: Current Developments in Like-Kind Exchanges
Taxation of Payments for Participating in Infrastructure Projects Slides: Infrastructure Tax Update
What If? Contingent Payment Issues in Real Estate Transactions Slides: What If? Contingent Payment Issues in Real Estate Transactions

Section Programs

Hurricane Harvey – Tax Issues for Disaster Survivors Slides: Tax Issues for Disaster Survivors

Standards of Tax Practice

A Comprehensive Look at Malpractice, Insurance, and Related Issues Slides: Malpractice and Insurance-Related Issues
A Primer on the IRS Disciplinary Process Slides: A Primer on the Disciplinary Process
Ethical Issues in Federal Tax Practice – The Government Perspective Slides: Ethical Issues in Federal Tax Practice: The Government Perspective

State & Local Taxes

False Claims Acts and State Taxes Slides: False Claims Acts and State Taxes
View From the Texas Comptroller’s Office Slides: View From the Texas Comptroller’s Office

Tax Accounting

Comparison of Revenue Recognition Methods Between ASC 606 and Section 451 Slides: Comparison of Revenue Recognition Methods Between ASC 606 and Section 451
Current Developments in Tax Accounting Outline: Current Developments
How New Partnership Audit Rules Will Impact Accounting Methods Procedures Outline: How New Partnership Audit Rules Will Impact Accounting Methods Procedures
Tax Accounting Period Issues Slides: Accounting Periods

Tax Bridge on the Road

Employee Benefits: How Taxing Can They Be? Slides: Employee Benefits: How Taxing Can They Be?
International Tax Developments: Cross-Border Tax Issues When Operating in Mexico Slides: US-Mexico Cross Border Tax Issues
Private Equity: Key US Tax Considerations Slides: Private Equity: Key US Tax Considerations

Tax Policy and Simplification

Recent Practice Changes at IRS Appeals Outline: Appeals Team Cases Conferencing Initiative: Frequently Asked Questions about Compliance Attendance at Conferences
Recent Practice Changes at IRS Appeals Slides: Recent Changesto IRS Appeals Procedures
Tax Aspects of Healthcare Reform Outline: The Dormant Commerce Clause and Creative State Responses to Federal Health Reform

Tax Practice Management

The Ethical Duty of Technology Competence Outline: The Ethical Duty of Technology Competence
The Ethical Duty of Technology Competence Slides: Ethical Duty of Technology Competence

Teaching Taxation

Best Practices in Drafting and Interpreting IRS Guidance Slides: Best Practices in Drafting and Interpreting IRS Guidance

Transfer Pricing

Base Erosion and Profit Shifting (BEPS): Transfer Pricing Update Slides: Base Erosion and Profit Shifting (BEPS): Transfer Pricing Update
Mexican Transfer Pricing and Dispute Resolution Issues Slides: Mexican Transfer Pricing and Dispute Resolution Issues
Transfer Pricing Methods in Tax Court: Economic Considerations and Implications Slides: Transfer Pricing Methods in Tax Court: Economic Implications and Considerations

US Activities of Foreigners & Tax Treaties

Hiding the Ball Slides: “Hiding the Ball” – The U.S. as the World’s Favorite Tax Haven: “Gatekeepers” in the New World of Tax Transparency

Young Lawyers Forum

Tax Issues in the Life Cycle of Technology Slides: Tax Issues in the Life Cycle of Technology: Development, Transfers, and Disputes