TaxIQ

2018 Fall Tax Meeting

October 4-6, Atlanta, GA

Thoughtful Insights. Useful Analysis.
Section 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

Important Developments in Administrative Practice Slides: Important Developments in Administrative Practice
Should You Advise Your Client to Agree to Extend the Statute of Limitations? Outline: Extending the Tax Assessment Period: Should You Advise Your Client to Agree to Extend the Statute of Limitations?
Should You Advise Your Client to Agree to Extend the Statute of Limitations? Slides: Should You Advise Your Client to Agree to Extend the Statute of Limitations?
The New Partnership Audit Rules, Round I – The Partnership Audit: How You and the IRS Figure It Out Slides: The Partnership Audit Rules

Affiliated and Related Corporations

Current Developments in Affiliated & Related Corporations Slides: Current Developments - Consolidated Aspects of the 2017 Tax Act
When Consolidated Groups and Insurance Collide Outline: When Consolidated Groups and Insurance Collide

Banking and Savings Institutions

US Tax Rules Pertaining to Hybrid Instruments Slides: US Hybrid Rules

Capital Recovery and Leasing

Current Developments and Update on Pending Guidance Outline: Current Developments

Civil and Criminal Tax Penalties

It’s All About the Penalties Outline: It’s All About the Penalties
OVDP – End of an Era Slides: Offshore Voluntary Disclosure Program The End of An Era
OVDP – End of an Era Slides: OVDP – End of an Era
Reports of Subcommittees on Important Developments Outline: Subcommittee Report: Legislative and Administrative Developments
Reports of Subcommittees on Important Developments Outline: Important Civil Developments
Skills Workshop: Preparing Your Client (the Taxpayer) for the Government Interview Outline: IRS Agent Interviewing the Taxpayer
Skills Workshop: Preparing Your Client (the Taxpayer) for the Government Interview Slides: Skills Workshop: Preparing Your Client (the Taxpayer) for the Government Interview

Closely Held Businesses and Business Planning Group

Beyond Powell – Examining the Important Provisions of Operating Agreements and Shareholder Agreements Outline: Family Limited Partnerships “Soup to Nuts”
Beyond Powell – Examining the Important Provisions of Operating Agreements and Shareholder Agreements Outline: Considerations for Shareholder Agreements Memo

Collection Workshop

How to Represent Taxpayers in Collection Matters from the Final Notice Through Trial and Resolving Collection Issues Facing Estates, Donors, and Donees Outline: NYC Taxpayer Advocate Panel materials

Corporate Tax

Special Issues Under the 2017 Tax Act Slides: Special Issues Under the 2017 Tax Act

Court Procedure and Practice

A Primer on the Use of Experts in Tax Court Slides: A Primer on the Use of Experts in Tax Court
Current Developments in Court Procedure and Practice Outline: Current Developments: Selected Recent Holdings
Litigating Whistleblower Cases in the Tax Court Outline: Whistleblower Panel Outline
Litigating Whistleblower Cases in the Tax Court Slides: Litigating Whistleblower Cases in the Tax Court
The New Partnership Audit Rules, Round 2 – After the Partnership Audit, How You and the IRS Fight it Out Slides: The New Partnership Audit Rules, Round 2: After the partnership audit, how you and the IRS fight it out

Diversity

Preparing Fiduciary Income Tax Returns and Representing Clients on Audit Outline: The 1041 Fiduciary Tax Return: General Questions and Answers
The “Nanny Tax”: Taxation of Household Employees Slides: The "Nanny Tax": Taxation of Household Employees

Employee Benefits

Corporate Counsel Forum Slides: The Form You Never Want to File –or Do You -- IRS Form 8928
Defined Benefit Plans Update Outline: Recent PBGC Legislative/Regulatory Developments
Employment and Benefits Developments for Non-Traditional Employment Relationships Slides: Multiple Employer Plans for Contingent Workers
Employment and Benefits Developments for Non-Traditional Employment Relationships Slides: Association Health Plans Reinvented
Employment and Benefits Developments for Non-Traditional Employment Relationships Slides: Worker Classification in the Gig Economy
ESOP Update Outline: TBM Consulting Group, Inc. v. Lubbock National Bank Case Summary
ESOP Update Outline: Brown v. Wilmington Trust Case Summary
Executive Compensation, Fringe Benefits and Federal Securities Law Update Slides: IRS Guidance in Notice 2018-68 on the 2017 Tax Act Amendments to §162(m)
Exempt Organization and Governmental Plans Update Outline: University 403(b) Litigation Update
Impact of #MeToo on Executive Compensation - Clawbacks and More Outline: #MeToo: Sexual Harassment and Executive Compensation
Impact of #MeToo on Executive Compensation - Clawbacks and More Slides: #MeToo, Employment Agreements, and the Clawback of Executive Compensation
Legislation & Litigation Update Chart: Industry, Regulatory, and Congressional Proposals Affecting Retirement Security (Reintroduced in 115th Congress)
Multiple Employers, PEOs and Controlled Groups Update Slides: 199A Update re: W-2 Wages and PEOs
Multiple Employers, PEOs and Controlled Groups Update Slides: Code Section 414 Controlled Group Principles & Native American Tribal Governments
Proxy Season: Looking Back, Looking Forward Slides: Proxy Season: Looking Back, Looking Forward
The Affordable Care Act: What Now? What Next? Slides: The Affordable Care Act: What Now? What Next?
Welfare Plans and EEOC, FMLA and Leaves Issues Update Slides: Prohibited Transactions - Health and Welfare Plans Sponsored by Hospital Systems
Welfare Plans and EEOC, FMLA and Leaves Issues Update Slides: Prescription Drugs Programs Update

Employment Taxes

Correcting Payroll Tax Reporting Errors and Grossing Up Payments for Tax Consequences Slides: Correcting Payroll Tax Reporting Errors
Tax Consequences of Employment Settlements and Judgements Slides: Taxation of Sexual Harassment Cases
The Competing Tensions Driving Independent Contractor Status for Service Providers Slides: The Competing Tensions Driving Independent Contractor Status for Service Providers

Estate & Gift Taxes and Income & Transfer Tax Planning Group

Can the IRS Have Their Cahill and Eat Yours Too? Outline: Family Limited Partnerships “Soup to Nuts”
Can the IRS Have Their Cahill and Eat Yours Too? Slides: Can the IRS Have Their Cahill and Eat Yours Too?
Current Developments in Estate & Gift Taxes and Income & Transfer Tax Planning Outline: Current Developments in Federal Transfer Taxes
Wealth Transfer Planning with Carried Interests in Funds Outline: Wealth Transfer Planning with Carried Interests in Funds

Estate & Gift Taxes, Fiduciary Income Tax and Income & Transfer Tax Planning Group

2018 Update of Privileges and Fiduciaries Outline: Background and Recent Cases on the Fiduciary Exception to the Attorney-Client Privilege
Creating the Ultimate Digital Asset Estate Planning Checklist Outline: Creating the Ultimate Digital Estate Planning Checklist
Creating the Ultimate Digital Asset Estate Planning Checklist Slides: Revised Uniform Fiduciary Access to Digital Access Act

Exempt Organizations

Charitable Giving Under the 2017 Tax Act: Keeping and Creating Charitable Contribution Deductions Outline: Charitable Giving Provisions of the TCJA: Charitable Contributions and State Initiatives in High SALT States
Charitable Giving Under the 2017 Tax Act: Keeping and Creating Charitable Contribution Deductions Slides: Charitable Giving Under the 2017 Tax Act: Keeping and Creating Charitable Contribution Deductions
Crowdfunding Charity: Navigating the Legal Landscape Outline: Crowdfunding Charity: Navigating the Legal Landscape
News from the IRS and Treasury Slides: News from the IRS and Treasury with Legislative and Judicial Updates
Shared Employment, Reporting of Compensation and Its Implications for Exempt Organizations Employment Slides: Shared employment, reporting of compensation and its implications for exempt organizations
Shared Employment, Reporting of Compensation and Its Implications for Exempt Organizations Employment Outline: Shared Employment, Reporting of Compensation and Its Implications for Exempt Organizations
Unrelated Business Taxable Income: Current Developments in Enforcement Activity Slides: Unrelated Business Taxable Income Current Developments in Enforcement Activity

Fiduciary Income Tax

Current Developments in Fiduciary Income Tax and Income & Transfer Tax Planning Outline: Recent Developments in Fiduciary Income Tax
Trusts and the Transition Tax: Everything You Didn’t Want to Know Slides: Trusts and the Transition Tax: Everything You Didn’t Want to Know

Financial Transactions

Treatment of Certain Debt Related Fees Slides: Treatment of Certain Debt Related Fees

Individual & Family Taxation

How Can I Live On That? Slides: How Can I Live On That?
What Is the APA's Role in Tax Administration? Slides: What is the Administrative Law's Role in Tax Administration?

Insurance Companies

Insurance Tax “Real Time” Topics Slides: Insurance Tax “Real Time” Topics
International Tax Reform and Insurance Companies Slides: Global Intangible Low-taxed Income (GILTI)
International Tax Reform and Insurance Companies Slides: New PFIC Qualifying Insurance Company Rule under Section 1297(f)
International Tax Reform and Insurance Companies Slides: International Tax Reform and Insurance Companies: Base erosion and anti-abuse tax (BEAT)
Traps for the Unwary: Life Insurance Valuation and Transfer Issues Slides: Traps for the Unwary: Life Insurance Valuation and Transfer Issues

Investment Management

Cryptocurrency Funds Slides: Vital Currency: Issues for Investment Funds
Post-Tax Reform Planning for Cross-Border Investments by Private Funds Slides: Post-Tax Reform Planning for Cross-Border Investments by Private Funds
State Tax Issues for Investment Funds Slides: State Tax Issues for Investment Funds

Partnerships & LLCs

Code Section 163(j) Slides: Section 163(j) and Partnerships
Code Section 199A Slides: Code Section 199A: The Proposed Regulations
Hot Topics in Partnerships & LLCs Slides: Partnership Hot Topics
International Hot Topics Slides: International Hot Topics

Pro Bono & Tax Clinics

Canceled Debt Reporting Under IRC Section 6050P Slides: Canceled Debt Reporting Under IRC Section 6050P
Jurisdictional Ramifications of a CDP Request Outline: The Jurisdictional Ramifications of Where You Send a CDP Request
Tax Consequences of Student Loan Debt Cancellation Outline: Information for People who Received Form 1099-C from Aequitas
Tax Consequences of Student Loan Debt Cancellation Slides: Tax Consequences of Student Loan Debt Cancellation

Real Estate

Overview of Qualified Opportunity Zones Slides: Overview of Qualified Opportunity Zones
Special Issues Applicable to Timber Slides: Special Issues Applicable to Timber
Structuring Foreign Investment in US Real Property After Tax Reform Slides: Structuring Foreign Investment in U.S. Real Property After Tax Reform
What is a Real Estate Trade or Business? Outline: Revisiting "Trade or Business" in the Real Estate Context in Light of Tax Reform
What is a Real Estate Trade or Business? Slides: Real Estate Trade or Business –When Does it Matter under Tax Reform?

S Corporations

Cooperatives Outline: Use of a Subchapter T Cooperative as an Alternative to or with and S Corporation - the "Elective Pass-through Entity" Option
Important Developments in the Federal Income Taxation of S Corporations Outline: Important Developments in the Federal Income Taxation of S Corporations

Sales, Exchanges and Basis

Current Developments Relating to Sales, Exchanges & Basis Outline: Current Non-Section 1031 Developments
Current Developments Relating to Sales, Exchanges & Basis Outline: Current Developments in Like-Kind Exchanges
Deferring and Reducing Income Taxes on Non-Opportunity Zone Property, and Eliminating Income Taxes on Opportunity Zone Property, Through Qualified Opportunity Funds Slides: Qualified Opportunity Funds
Deferring and Reducing Income Taxes on Non-Opportunity Zone Property, and Eliminating Income Taxes on Opportunity Zone Property, Through Qualified Opportunity Funds Slides: Should Real Estate Gain be Rolled Over Through a QOF Rather Than 1031
The Interaction of Section 267, 1031 and 1033 with the Qualified Business Income Limitation Slides: The Interaction of Sections 267, 1031, and 1033 with the Qualified Business Income Limitation

Standards of Tax Practice

Ethical Issues Regarding the Partnership Representative Slides: Ethical Issues Regarding the Partnership Representative
Ethical Pitfalls in Representing Spouses Outline: Joint Representation Engagement Samples
Ethical Pitfalls in Representing Spouses Slides: Ethical Pitfalls In Representing Spouses

State & Local Taxes

Impact of Wayfair on Services and International Taxes Slides: Impact of Wayfair on Services & International Taxes
What Is a Remote Seller to Do in This Post-Quill World? Slides: Remote Sellers in a Post-Quill World?

Tax Accounting

Accounting Method Changes for Controlled Foreign Corporations Slides: Accounting Method Changes for Controlled Foreign Corporations
Current Developments in Tax Accounting Outline: Current Developments in Tax Accounting
Inventory Slides: Inventory Panel
Revenue Recognition and Section 451 Slides: Panel on Revenue Recognition and Section 451

Tax Bridge on the Road

Cross-Species Mergers: Key US Federal Income Tax Considerations Slides: Cross-Species Mergers: Key US Federal Income Tax Considerations
Planning for Litigation in the Captive Insurance Area Slides: Planning for Litigation in the Captive Insurance Area
State and Local Tax: Wayfair and the Way Forward Slides: State and Local Tax: Wayfair and the Way Forward

Tax Policy and Simplification

Transparency Tide or Transparency Tsunami? The New Wave of Global Reporting Rules and IRS Tools to Unearth Foreign Financial Accounts: FATCA, FBAR, & CRS developments in the wake of OVDP and Swiss Bank Program Slides: Transparency Tide or Transparency Tsunami? The New Wave of Global Reporting Rules and IRS Tools to Unearth Foreign Financial Accounts: FATCA, FBAR, & CRS developments in the wake of OVDP and Swiss Bank Program

Tax Practice Management

The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement Paper: The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement
The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement Slides: The IRS’s Modern Use of Artificial Intelligence and Big Data in Tax Enforcement

Transfer Pricing

Impact of BEPS and US Tax Reform on Transfer Pricing Controversies: Preparing for the Storm Slides: Impact of BEPS and U.S. Tax Reform on Transfer Pricing Controversies: Preparing for the Storm
The Great BEAT Debate Slides: The Great BEAT Debate

US Activities of Foreigners & Tax Treaties

Advanced FIRPTA: Traps to Keep You Up at Night Slides: Advanced FIRPTA: Traps to Keep You Up at Night
Inbound Financing After Tax Reform - What Now? Slides: Inbound Financing After Tax Reform – What Now?

Young Lawyers Forum

New Law, New Regulations, New Practitioners: Legal and Ethical Obligations When Advising Taxpayers in an Uncertain Legal Environment Slides: New Law, New Regulations, New Practitioners: Legal and Ethical Obligations When Advising Taxpayers in an Uncertain Legal Environment