May 25, 2017

2007 May Meeting


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 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. In addition, Tax Section books and government submissions can be viewed in the TaxIQ searchable database.

2007 May Meeting, Washington, DC

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Committee Name
Program Material Title
Speaker/Author Name
Document ID Number
Administrative Practice Ethical Issues in Connection with the Patenting of Tax Planning Strategies (Part I – Issues Affecting the Lawyer Who is Seeking or Hold a Patent) Lang, Michael B.
Administrative Practice Selected Recent Developments in Administrative Practice Hartford, Jamie
Johnson, Kevin
Affiliated and Related Corporations Section 1.1502-36 and Related Issues Leatherman, Professor Don
Peabody, Brian
Warnke, Gordon
Banking and Savings Institutions Foreign Banks in China: How Banks are Taxed Chen, Peter Guang
Bankruptcy and Workouts Federal Tax Issues Concerning Post-Petition Income of Individual Chapter 11 Debtors under BAPCPA Crapo, David N
Bankruptcy and Workouts Panel PowerPoint Griffith, Doreen
Kwasteniet, Ross M.
Maynes, Todd F.
Wallace, Mark S.
Business Cooperatives and Agriculture Congressional, Department of Treasury, and IRS Current Developments Thompson, Ty
Business Cooperatives and Agriculture Co-op Capital -- Time for a Co-op Investment Fund? Griffin, Mary
Business Cooperatives and Agriculture Uniform Limited Cooperative Association Act Frederick, Donald
Capital Recovery and Leasing BB&T Corporation v. United States Weisblat, David B.
Capital Recovery and Leasing Current Developments Report and Update on Capital Recovery Guidance Projects Breaks, Katherine
Capital Recovery and Leasing Update and Issues in the Leasing Area Johnson, Glenn
Civil and Criminal Tax Penalties Attorney-Client and Constitutional Privileges Williams, Bradley L.
Civil and Criminal Tax Penalties Important Developments - Criminal Ciraolo, Caroline D.
Civil and Criminal Tax Penalties International Enforcement Subcommittee Materials
Zagaris, Bruce
Civil and Criminal Tax Penalties Legislative & Administrative Developments Colvin, John
Civil and Criminal Tax Penalties Prosecution of Criminal Tax Cases Involving the Economic Substance Doctrine Feld, Lawrence
Muller, Charles
Closely Held Businesses Avoiding and Defending Against the Trust Fund Recovery Penalty Bell, Craig D.
Borison, Professor Jerome
Wilson, Gregory R.
Closely Held Businesses Selected Issues in Drafting Joint Venture Agreements, Including Allocation Provisions August, Jerald D.
White, III, Professor Thomas R.
Community Outreach Program Choosing the Proper Form of Legal Entity Markowitz, Jeff
Community Outreach Program Choosing the Proper Form of Legal Entity Problems Markowitz, Jeff
Community Outreach Program Depreciation of Real Property Markowitz, Jeff
Community Outreach Program Interest Deductions Schwidetzky, Walter D.
Community Outreach Program Like Kind Exchange Transactions by Robert A. Rombro Schwidetzky, Walter D.
Community Outreach Program Tax Planning for Sales of Real Property Sidle, Daryl J.
Community Outreach Program Time and Money: IRC 465 and 469 Jones, Darryll K.
Corporate Tax Distributions in Connection with Acquisitions Paul, Deborah L.
Thurston, Sally A
Corporate Tax Satisfying the Active Business Requirement in a Spin-Off Rievman, David M.
Court Procedure and Practice FIN 48: Impact on Litigation and Settlements Simmens, Todd
Court Procedure and Practice Hypothetical Rizek, Christopher S.
Ruchelman, Charles M.
Sapinski, Richard J.
Employee Benefits An Overview of the HIPAA Final Non-Discrimination and Wellness Program Regulations' paper Bianchi, Alden J.
Employee Benefits An Overview of the HIPAA Final Non-Discrimination and Wellness Program Regulations' presentation Bianchi, Alden J.
Employee Benefits Changes Made by Final Section 415 Regulations Lawson, Kurt P.
Employee Benefits CMS Guidance for Remote Use and Access to E-PHI Stember, Mark L.
Employee Benefits Congress Enhances Health Savings Accounts Stember, Mark L.
Employee Benefits HIPAA Privacy Rule Keeping Americans’ Health Information Accessible & Confidential Holtzman, David S.
Employee Benefits IRS Issues HSA and HRA Rollover Guidance Stember, Mark L.
Employee Benefits IRS Outlines Scope of HSA Permitted Insurance and Disregarded Coverage Stember, Mark L.
Employee Benefits Pension Protection Act of 2006 New Issues in Plan Design: Qualified Default Investment Funds and Automatic Enrollment Plans O'Hare, Bernard F.
Employment Taxes Employment Tax Fraud and Evasion Cronin, Edward F.
Employment Taxes Overview of Employment Tax Fraud Alter, Robert J.
Employment Taxes Section Program Worker Classification for Employment Tax Purposes Shulman, Harvey J.
Estate and Gift Taxes The Blount True-th About the F-Amlie Business: Tax and Nontax Considerations in Drafting Buy-Sell Agreements Aghdami, Farhad
Mancini, Mary Ann
Estate and Gift Taxes Current Developments in Estate Planning Delich-Gould, Stacey
Estate and Gift Taxes Estate Planning for the Terminally Ill Client: Even the Blackest Cloud Has a Silver Lining Harris, T. Randolph
Sloan, Barbara A.
Exempt Organizations Ethical Issues Arising Out of the Patenting of Tax Strategies Lang, Michael B.
Exempt Organizations Nonprofit Corporations: Looking at the Structure- Revisions and Review Moody, Lizabeth A.
Exempt Organizations Uniform Prudent Management of Institutional Funds Act Gary, Susan N.
Fiduciary Income Tax Panel Presentation Sega, A. Christopher
Fiduciary Income Tax Recent Developments in Fiduciary Income Tax Newlon, Jeanne L.
Stern, Lisa M.
Fiduciary Income Tax The Trustee's Duty to Provide Information to Beneficiaries: When Can the Settlor Say "Don''t Ask, Won''t Tell"? O'Brien, Anne
Fiduciary Income Tax UTC Section 105 and UTC Section 813 Sega, A. Christopher
Financial Transactions Convertibles with Hedges and Higher Strike Warrants: Further Tax Issues Marshall, Eileen
Financial Transactions Convertibles with Hedge and Higher Strike Warrants Overview Garlock, David
Foreign Activities of US Taxpayers Principal/Super-Entrepreneur Structures and the Contract Manufacturing Debate Angus, Barbara
Daub, Peter
Granwell, Alan
Foreign Lawyers Forum The New US Model Treaty Practical Implications and Other Countries’ Reactions Taylor, Willard B.
Foreign Lawyers Forum Transfers of Business Functions Abroad - A Legitimate Crystallization Event or an Illicit Exit Charge by Another Name? Durst, Michael C.
Jacob, Friedhelm
Somerville, James
Van Weeghel, Stef
Individual and Family Taxation Innocent Spouse Case Update Rice, David
Individual and Family Taxation Remodeling Home Ownership Tax Benefits Camp, Bryan T.
Carasso, Adam
Kahn, Jeffrey
Lazar, Stuart
Mann, Roberta F.
Investment Companies Excess Inclusion Income from REIT Taxable Mortgage Pools Gibian, Karen L.
Investment Companies Excess Inclusion Income (panel PowerPoint presentation) Gibian, Karen L.
Investment Companies Taxation of Exchange-Traded Funds, Exchange-Traded Notes, and Exchange-Traded Partnerships Flores, Deanna
Gelinas, A.J. Alex
Riley, Joseph A.
Joint Program: Closely Held Businesses & USAFTT Foreign Investment in US Closely Held Businesses - Fundamentals and Planning Appel, Alan I.
Bernstein, Jack
Rubinger, Jeffrey L.
Joint Program: Estate & Gift Taxes and Fiduciary Income Young Lawyers Subcommittee Panel Materials

Day, Eileen
Sontag, Matthew R. Tobey, Judith

Low Income Taxpayers A Practical Primer on Appeals Leyden, Diana
Low Income Taxpayers CDP Proceedings in Appeals Atkinson, Elizabeth J.
Low Income Taxpayers Filing the Tax Court Case Atkinson, Elizabeth J.
Low Income Taxpayers Innocent Spouse Relief Section 6015(f) Atkinson, Elizabeth J.
Partnerships & LLCs Hot Topics Kugler, Paul F.
Partnerships & LLCs Section 751(b) – ABA Reform Proposals Abrams, Howard
Partnerships & LLCs Series LLCs: What We Know (and Don't Know) Donn, Allan G.
Ely, Bruce P.
Schippel, Bahar A.
Partnerships & LLCs Series LLCs: What We Know (and Don't Know) Powerpoint slides Donn, Allan G.
Ely, Bruce P.
Schippel, Bahar A.
Pro Bono Business Best Practices for Incorporating Pro Bono Work Into Your Law Practice Hawkins, Karen
Leyden, Diana
Salman, Samira
Turner, Suzanne
Real Estate The "Ought and Is" of TIC Syndications: Rev. Proc. 2002-22 Five Years Later Steinhause, Darryl
S Corporations Administrative Complexities Associated with F Reorganizations Involving S Corporations Harper, John S.
S Corporations Current Developments In Federal Taxation of S Corporations Howell-Smith, Laura
S Corporations Limited Liability Companies Classified as S Corporations D'Amico, Christopher R
Klein, Steven
Levitt, Ronald
Looney, Stephen R.
S Corporations S Corporation Charitable Contribution Analysis Nichols, Thomas J.
S Corporations Sec. 1367. Adjustments to Basis of Stock of Shareholders, Etc. Nichols, Thomas J.
Sales, Exchanges & Basis Balancing Taxpayer Protections with Treasury Regulation § 1.1031(k)-1(g) Safe Harbor Provisions Miller, Carlene
Sales, Exchanges & Basis Current Developments in Like-Kind Exchanges Shechtman, David
Sales, Exchanges & Basis Economic Substance Doctrine - Not Just For Shelters Anymore Borden, Brad
McKenney, Paul L.B.
Sales, Exchanges & Basis Revisiting the "(g)(6)" Constructive Receipt Rules for Deferred Exchanges Shechtman, David
Sales, Exchanges & Basis Sales and Exchanges: Current Developments Jensen, Erik M.
Sales, Exchanges & Basis Sample Provision Exchange Agreement Shechtman, David
State and Local Taxes Apportionment of Intangibles and Services: Is Cost of Performance Still The Way to Go? Joseph, Carl
Reeder, Kimberley M.
Wilson, Margaret C.
State and Local Taxes State Unclaimed Property Update Biek, John A.
State and Local Taxes: Mini-Program The Ongoing Controversy About State and Local Nexus Issues- Is There a Resolution In Sight? Rosen, Art
Smith, Scott D.
Teaching Taxation Murphy v. IRS Panel PowerPoint

Germain, Gregory

Teaching Taxation Murphy’s Law: Bad Cases Can Make Good Teachers Abreu, Professor Alice
Transfer Pricing Recent Trends in Transfer Pricing Audits and Penalties Fanaroff, Carolyn D.
Johnson, Jeffrey
VAT & Other Consumption Taxes A Federal VAT in a State Consumption Tax World Perry, Victoria J.