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2010 May Meeting

May 6-8, Washington, DC

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.

2010 May Meeting, Washington, DC

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Administrative Practice

Panel Slides

Panel Materials

Outline of Relevant Provisions

Affiliated & Related Corporations

Panel Slides

Banking and Savings Institutions

Panel Presentation

Panel Materials

Bankruptcy & Workouts

The Worker, Homeownership, and Business Assistance Act of 2009 5-Year NOL Carryback Provision

Limitations on Corproate Tax Attributes: An Analysis of Sections 382 and Related Provisions

Panel Slides

Capital Recovery & Leasing

Panel Materials

Civil & Criminal Tax Penalties

Important Developments - Criminal

Important Developments on Civil Penalties January 2010 through April 2010

Creative Sentencing Advocacy in Criminal Tax Cases after Kimbrough and Gall

Panel Outline

Panel Slides

Report of Foreign Bank and Financial Account (FBAR) Regulation Update

International Tax Enforcement and Reporting: The Big Powers Use the Financial Crisis to Achieve Game Chnage and Interplay with U.S.Legislative Initiatives

Legislative and Administrative Developments: Civil

Closely Held Businesses

Choice of Entity - A Fresh Look: Tax & Non-Tax Considerations

Panel Materials

Buy-Sell Agreements & IRC Section 409A: Restrictions on Separation Pay

Corporate Tax

Panel Slides

Court Procedure & Practice

Summary of Current Developments

Panel Materials

Employee Benefits

Prototype Plan Trust Agreement Issues

Health Care Reform: Employer Group Health Plan Considerations

Typical Compliance Problems in Prototype Plans

Dealing with PBGC: Reporting Changes, Early Warning Program, and Downsizing Liability

Employee Benefits Guidance Released January 2010-April 2010

Patient Protection and Affordable Care Act Chart

Defined Contribution Plans Disclosure Obligations to Participants

Panel Slides

Defined Benefit Plans Disclosure Obligations to Participants

Health Care Reform

Employee Benefits Subcommittee on Defined Benefit Plans

Recent PBGC Regulatory Developments

Employee Benefits Subcommittee on Defined Contribution Plans

Reproposed Participant Investment Advice Prohibited Transactions Regulations

Employee Benefits Subcommittee on Distributions

The Roth IRA: Leverage in a New Garb

Employee Benefits Subcommittee on ESOPs

Panel Materials

Employee Benefits Subcommittees on ESOPs, Fiduciary Responsibility/Plan Investments and Litigation

Panel Materials

Employee Benefits Subcommittee on Foreign and International Issues

TE/GE Employee Plans: International Overview

Employee Benefits Subcommittee on Mergers and Acquisitions

Dealing with PBGC: Reporting Changes, Early Warning Program, and Downsizing Liability

Mergers and Acquisitions: Executive Compensation Issues

Employee Benefits Subcommittee on Self Correction, Determination Letters and Other Administrative Practices

IRS - Employee Plans Examinations Hot Issues

Employment Taxes

Important Developments

Energy & Environmental Taxes

Panel Slides

May 2009-May 2010 Administrative Update

Estate & Gift Taxes

Planning with Graegin Loans

Current Developments in Estate Planning

Estate Tax Legislative Update

Exempt Organizations

The Plight of Newspapers: Can Tax-Exempt Organizations Help?

Charitable Grantmaking Affiliates

Summary of Issues for Affiliated Organizations

Glossary for “Affiliated” Organizations

Board of Directors of Not-for-Profit Corporations Confronting Insolvency

Charities in Financial Distress: The Trust Fund Recovery Penalty

Charities in Financial Distress: Endowments and Other Restricted-Gift Issues

Panel Presentation

Fiduciary Income Tax

Section 675(4)(C) – Planning and Problems with the Nonfiduciary Power to Substitute Assets

Death of a Partner in Family Limited Partnerships: Capital Shifts and Income Tax Traps

Grantor Trust Status under Sections 675(1) and 675(4)(A) and (B)

Section 675(2) and Section 675(3) Grantor Trust Status Based on Borrowing Power

Recent Developments in Fiduciary Income Tax

Financial Transactions

Panel Slides

Panel Paper

Foreign Activities of US Taxpayers

Panel Slides

Foreign Lawyers Forum

Panel Slides

Individual & Family Income Tax

Environmental Tax Credits for Homeowners

Look Homeward Angel: Tax Aspects of Loan Modifications and Short Sales

Special Rules under § 121

Current Home Office Issues

Encouraging the Fair Treatment of Emotional Distress Damage Awards

Tax Issues and Service Animals

Insurance Companies

Important Recent Published Guidance, Legislation, and Cases in Litigation

Important Developments under Sections 72 and 7702 – January 2010 through May 2010

Investment Management

Foreign Account Compliance (FATCA and FBAR)

Panel Slides (Deferred Compensation for Hedge Fund Advisors)

Panel Slides (New Cost Basis Reporting Rules)

Joint: Estate & Gift Taxes and Fiduciary Income Taxes Young Lawyers Subcommittee

Learning to Let Go: A Primer on Qualified Disclaimers

Joint: FAUST, FLF, Transfer Pricing and USAFTT: Current Developments

International Tax Committees Current Developments Panel Slides

Joint: Tax Practice Management & Young Lawyers Forum

Panel Materials

Low Income Taxpayers

Challenging Treasury Regulations

Low Income Taxpayer Workshop

Refund and Refund Litigation

Refund Claims for Low Income Taxpayers: The Most Common Contexts

Partnerships & LLCs

Panel Materials

Panel Presentation

Panel Slides

Pro Bono

Panel Materials

Real Estate

Current Legislative Developments and other Real Estate Hot Topics

Panel Presentation

Panel Slides

S Corporations

Retroactivity Issues For S Corporations Seeking Inadvertent Termination Relief

Selected Income Tax Considerations Concerning Choice of Entity for Conducting Business Operations Outside the United States

Important Developments in the Federal Income Taxation of S Corporations

Sales, Exchanges & Basis

Current Developments in Like-Kind Exchanges

Obtaining a New 30 Year Lease as Replacement Property in a Section 1031 Exchange

Panel Presentation

Section 1031: Replacement Asset is a Leasehold Interest

Panel Materials

Section Program: Be Prepared: A [Scout's] Guide to the Coming Regulation of Federal Tax Return Preparers

Panel Slides

Section Program: Financially Distressed S Corporations

Debt Workouts of S Corporations

Financially Distressed S Corporation Fact Pattern

Panel Slides

Section Program: Legal Ethics Due Diligence Standard in Circular 230: What Do They Mean for Tax Opinions and Certificate Practice

Panel Slides

Section Program: Making Your 401k Last a Lifetime

Panel Presentation

Current Lifetime Income Solutions for Defined Contribution Plans

Section Program: Offshore Voluntary Compliance Update - Criminal to Civil and Done

Panel Slides

Standards of Tax Practice

Recent Developments and Decisions from the IRS's Office of Professional Responsibility

Attorney-Client Privilege in the Family Office

Panel Slides

State & Local Taxes

Panel Outlines

Panel Slides

Announcement 2010-9: Disclosure of Uncertain Tax Positions

Task Force on Patenting Tax Strategies

Why Business Method Patents?

Tax Accounting

Panel Slides

Panel Materials

Panel Slides

Current Developments

Tax Bridge to Practice


Panel Slides

Income Shifting for Tax Purposes in Divorce Settlements: Alimony and Its Incidents

Click Through Nexus Bills

Tax Exempt Financing

EMMA Trade Data

Panel Materials

Panel Agenda & Questions

Bond Enforcement and VCAP

Panel Outline

Panel Slides

Tax Policy & Simplification

Panel Presentation

Subnational VATs: What Can We Learn from the California BNRT Proposal?

VAT Fraud (No State VATs, Please, Until We Solve the Fraud)

State VAT: A Brazilian Experience

Transfer Pricing

Panel Slides

Veritas Software and Xilinx: Implications Within and Outside Cost Sharing

US Activities of Foreigners & Tax Treaties

The FATCA Provisions of the HIRE Act

Panel Slides