TaxIQ

2011 May Meeting

May 5-7, 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.

2011 May Meeting - Washington, DC

Administrative Practice

Back-to-Basics: Oops! Curing Missed Regulatory Elections Through 9100 Relief and Related Procedures

Important Developments

International Tax Audits

Update on IRS Penalty Policy and Practice

Affiliated and Related Corporations

Current Developments in Consolidated Returns

Banking and Savings Institutions

Forward Contracts and Issue Price Determinations: Eliminating the Uncertainties?

Recent Developments in Foreign Bank and Financial Account Reporting (FBARs)

Recent Developments in Foreign Bank and Financial Account Reporting (FBARs)

Recent Developments in Foreign Bank and Financial Account Reporting (FBARs)

Tax Issues Surrounding Banking Industry Consolidation

Bankruptcy & Workouts

IRS Expense Standards

Section 597 and FDIC-Assisted Transactions

Business Cooperatives and Agriculture

Grants of Conservation Easements on Death: Issues and Practical Considerations

Capital Recovery & Leasing

Continued Efforts to Define Non-Taxable Contributions to Capital Under Section 118

Civil & Criminal Tax Penalties

Hardball: A Hard Look at Pending Offshore Voluntary Disclosure Initiatives

The Move Towards “No Fault”: The Accuracy Penalty Reconsidered

Corporate Tax

Intercompany Transactions – Basics and Traps for the Unwary, Including Intercompany Transactions in Member Stock

Recent Developments in Corporate Taxation

Court Procedure & Practice

Common Evidentiary Issues In Tax Cases

Joint Defense Agreements

Remarks on Behalf of the Department of Justice Division of Taxation.

Remarks on Behalf of the Office of Chief Counsel, IRS

Remarks on Behalf of the Tax Court

Employee Benefits

Employee Benefits Security Administration (EBSA) Update

Internal Revenue Service and US Department of Treasury Update

IRS and Treasury Questions and Answers

Looking Into the Crystal Ball:  Tax Reform Legislative Proposals

Pension Benefit Guaranty Corporation Update

Pension Plan Update

Employee Benefits Subcommittee on Defined Benefit Plans

Employee Benefits Defined Benefit Plans Update

Employee Benefits Defined Benefit Plans Update

Employee Benefits Subcommittee on ESOPs

Employee Benefits ESOP Update

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

Employee Benefits Litigation Update

Employee Benefits Subcommittee on Foreign and International Issues

Employee Benefits International Update

Employee Benefits Subcommittee on Mergers and Acquisitions

Employee Benefits Mergers & Acquisitions Update

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

Employee Benefits Administrative Practices Update

Employee Benefits Subcommittee on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans

Employee Benefits Welfare Benefits Design, Funding and Regulation Update

Employee Benefits Subcommittees on Executive Compensation and Fringe Benefits and Federal Securities Laws Issues

Employee Benefits Executive Compensation, Fringe Benefits and Securities Law Update

Employee Benefits Subcommittees on Executive Compensation and Fringe Benefits and Federal Securities Laws Issues

Employee Benefits Executive Compensation, Fringe Benefits and Securities Law Update

Employment Taxes

Advanced Employment Tax Audit Techniques, Part III of III.

Employment Taxes

Federal Update

Employment Taxes

Update from the National Tax Advocate

Energy & Environmental Taxes

Administrative Update: Discussion of Various IRS Guidance

Estate & Gift Taxes

Current Developments

Split Dollar Arrangements Revisited

The Fisher-Price Aftermath: Toying around with Gifts of FLP and LLC Interests

Exempt Organizations

Practical Problems and Practical Solutions for Private Foundations

The Best Defense is a Strong Offense: Using D & O Insurance to Protect Directors and Officers

Fiduciary Income Tax

A Potpourri of Charitable Planning Tricks and Traps

Section 677

Financial Transactions

Current Developments

The Latest in Structured Products

Upfront Payments, Inducement Payments, Bargain Purchases and Off-Market Sales

Foreign Activities of U.S. Taxpayers

Territoriality for the United States?

The New Foreign Tax Credit Guidance

Foreign Lawyers Forum

Exploring the Terrain of Territorial Exemption Systems

Planning in the Territorial Exemption Systems in the G8

Individual and Family Taxation

Divorce Taxation - An Overview of the Basics of Divorce Taxation for Married Couples and Same-Sex Couples

Tax Simplification: Individuals and Families

Insurance Companies

Legislative and Regulatory Outlook for Insurers and their Products.

Investment Management

State and Local Tax Issues Applicable to Private Equity Funds

What Keeps Hedge Fund Tax Directors Up At Night

Joint: Closely Held Businesses and S Corporations

Impact of Health Care Reform On Closely-Held Business

Joint: Estate & Gift Taxes and Fiduciary Income Taxes

Impact of Health Care Reform On Closely-Held Business

IRS Perspectives On Health Care Reform

Joint: FAUST, FLF, Transfer Pricing and USAFTT

Joint International Developments Panel

Joint: Young Lawyers Forum & Diversity

Preparers Beware!

The Defense of Marriage Act (DOMA) and the Internal Revenue Code

Low Income Taxpayers

What’s Next?

Partnerships & LLCs

Hot Topics

Pro Bono

Role of The National Taxpayer Advocate

Update On Projects

Real Estate

Putting Real Estate to Good Use

REIT Recent Developments

S Corporations

Due Diligence Involving S Corporations

Important Developments

Sales Exchanges & Basis

Back to Basics: Depreciation Recapture

Gold, Precious Metals, and Section 1031

Non-§1031 Current Developments

The Green Economy: Can It Blossom Under Section 1031

Standards of Tax Practice

Dealing with Conflicts of Interest in Common Practice Situations

Ethical Implications of DOJ Decision Not to Enforce the “Defense of Marriage Act.”

Ethical Issues in Federal Tax Practice – The Government Perspective

Resolved: That the Standards for Tax Return Positions of Circular 230 Section 10.34 Should Conform in All Respects to the Standards Prescribed by IRC Section 6694

State & Local Taxes

Cloud Computing and Other Innovative Technologies - SALT Issues Arising Out From Use of These New and Innovative Technologies

Can You Keep a Secret? Discovery and Confidentiality in State Tax Controversies

Sales Tax and Government Contracting

Tax Accounting

Benefits and Burdens of Ownership for Federal Income Tax Purposes Considering the Implications with Respect to Sections 199, 263A, and Other Sections

Recent Developments in Tax Accounting Methods

Tax Accounting for Vendor Allowances

Tax Exempt Financing

IRS Enforcement, Compliance and Tax Administration Update

IRS, Department of Treasury and Legislative Update

Long-Term and Short-Term Working Capital Bonds

Report on Management Contract Guidelines Project

Tax Section Proposals for Reform and Simplification

Tax Policy and Simplification

Tax Reform and Deficit Reduction: Proposals, Implementation, and Policy Considerations, Part I – Administrative and Legislative Perspectives

Tax Reform and Deficit Reduction: Proposals, Implementation, and Policy Considerations, Part II – Policy Commentary

Tax Practice Management

Ethical Warning Signs – Avoiding and Dealing with Difficult Clients

Teaching Taxation

Tax Reform Redux: Lessons Learned

Transfer Pricing

Avoiding Double Taxation When Competent Authority Relief is Unnecessary, Unavailable or Unsuccessful.

Transfer Pricing and International Tax and the new IRS LB&I Organization

US Activities of Foreigners and Tax Treaties (USAFTT)

Coming attractions: International tax reform and other future developments.

Tax Planning for “Inbound” Licensing of Intellectual Property