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2018 Fall Tax Meeting

October 4-6, Atlanta, GA

Thoughtful Insights. Useful Analysis.

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

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

Affiliated and Related Corporations

Current Developments in Affiliated & Related Corporations

When Consolidated Groups and Insurance Collide

Banking and Savings Institutions

US Tax Rules Pertaining to Hybrid Instruments

Capital Recovery and Leasing

Current Developments and Update on Pending Guidance

Civil and Criminal Tax Penalties

It’s All About the Penalties

OVDP – End of an Era

Reports of Subcommittees on Important Developments

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

Beyond Powell – Examining the Important Provisions of Operating Agreements and Shareholder Agreements

Collection Workshop

How to Represent Taxpayers in Collection Matters from the Final Notice Through Trial and Resolving Collection Issues Facing Estates, Donors, and Donees

Corporate Tax

Special Issues Under the 2017 Tax Act

Court Procedure and Practice

A Primer on the Use of Experts in Tax Court

Current Developments in Court Procedure and Practice

Litigating Whistleblower Cases in the Tax Court

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


Preparing Fiduciary Income Tax Returns and Representing Clients on Audit

The “Nanny Tax”: Taxation of Household Employees

Employee Benefits

Corporate Counsel Forum

Defined Benefit Plans Update

Employment and Benefits Developments for Non-Traditional Employment Relationships

ESOP Update

Executive Compensation, Fringe Benefits and Federal Securities Law Update

Exempt Organization and Governmental Plans Update

Impact of #MeToo on Executive Compensation - Clawbacks and More

Legislation & Litigation Update

Multiple Employers, PEOs and Controlled Groups Update

Proxy Season: Looking Back, Looking Forward

The Affordable Care Act: What Now? What Next?

Welfare Plans and EEOC, FMLA and Leaves Issues Update

Employment Taxes

Correcting Payroll Tax Reporting Errors and Grossing Up Payments for Tax Consequences

Tax Consequences of Employment Settlements and Judgements

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?

Can the IRS Have Their Cahill and Eat Yours Too?

Current Developments in Estate & Gift Taxes and Income & Transfer Tax Planning

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

Creating the Ultimate Digital Asset Estate Planning Checklist

Exempt Organizations

Charitable Giving Under the 2017 Tax Act: Keeping and Creating Charitable Contribution Deductions

Crowdfunding Charity: Navigating the Legal Landscape

News from the IRS and Treasury

Shared Employment, Reporting of Compensation and Its Implications for Exempt Organizations Employment

Unrelated Business Taxable Income: Current Developments in Enforcement Activity

Fiduciary Income Tax

Current Developments in Fiduciary Income Tax and Income & Transfer Tax Planning

Trusts and the Transition Tax: Everything You Didn’t Want to Know

Financial Transactions

Treatment of Certain Debt Related Fees

Individual & Family Taxation

How Can I Live On That?

What Is the APA's Role in Tax Administration?

Insurance Companies

Insurance Tax “Real Time” Topics

International Tax Reform and Insurance Companies

Traps for the Unwary: Life Insurance Valuation and Transfer Issues

Investment Management

Cryptocurrency Funds

Post-Tax Reform Planning for Cross-Border Investments by Private Funds

State Tax Issues for Investment Funds

Partnerships & LLCs

Code Section 163(j)

Code Section 199A

Hot Topics in Partnerships & LLCs

International Hot Topics

Pro Bono & Tax Clinics

Canceled Debt Reporting Under IRC Section 6050P

Jurisdictional Ramifications of a CDP Request

Tax Consequences of Student Loan Debt Cancellation

Real Estate

Overview of Qualified Opportunity Zones

Special Issues Applicable to Timber

Structuring Foreign Investment in US Real Property After Tax Reform

What is a Real Estate Trade or Business?

S Corporations


Important Developments in the Federal Income Taxation of S Corporations

Sales, Exchanges and Basis

Current Developments Relating to Sales, Exchanges & Basis

Deferring and Reducing Income Taxes on Non-Opportunity Zone Property, and Eliminating Income Taxes on Opportunity Zone Property, Through Qualified Opportunity Funds

The Interaction of Section 267, 1031 and 1033 with the Qualified Business Income Limitation

Standards of Tax Practice

Ethical Issues Regarding the Partnership Representative

Ethical Pitfalls in Representing Spouses

State & Local Taxes

Impact of Wayfair on Services and International Taxes

What Is a Remote Seller to Do in This Post-Quill World?

Tax Accounting

Accounting Method Changes for Controlled Foreign Corporations

Current Developments in Tax Accounting


Revenue Recognition and Section 451

Tax Bridge on the Road

Cross-Species Mergers: Key US Federal Income Tax Considerations

Planning for Litigation in the Captive Insurance Area

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

Tax Practice Management

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

The Great BEAT Debate

US Activities of Foreigners & Tax Treaties

Advanced FIRPTA: Traps to Keep You Up at Night

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