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2012 May Meeting

May 10-12, 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.

Materials by Committee

Administrative Practice

Important Developments

So You Think Your Statute is Closed? Mitigation Procedures and Equitable Remedies that may “Open” Closed Statutes

Tips and Traps in Transfer Pricing Examinations

Affiliated and Related Corporations

A Primer on Consolidated Return Basics: Part I – Consolidated Taxable Income and Investment Adjustments

A Primer on Consolidated Return Basics: Part II – Intercompany Transactions.

Banking & Savings Institutions

Highlights of the Newly-Proposed FATCA Due Diligence and Withholding Regulations

Section 871(m) and Withholding; What’s a Bank, as a Withholding Agent To Do

The Definition of “Bank” under the Internal Revenue Code

Bankruptcy and Workouts

Acquisition of Troubled Corporations

Bankruptcy, Collections and the Collection Due Process Appeal

Tax Hot Spots in Bankruptcy Proceedings

Business Cooperatives & Agriculture

Definition of a “Farming Business” under the Code

Capital Recovery & Leasing

Accelerated Credits in Lieu of Bonus Depreciation

Current Developments

Hot Topics in Leasing

Civil and Criminal Tax Penalties

Discovery, Documents and Privilege in Tax Litigation

International Tax Enforcement and Globalization: Can the Tax Police Keep Pace with the Criminals?

Reports of Subcommittees on Important Developments

Restitution and Civil Tax Issues in Sentencing

Corporate Tax

Current Developments and Corporate Tax Reform.

Section 382 Developments

Court Procedure and Practice

Roundtable Discussion: Electronic Trials

Fifty Years of Court Procedure and Practice

Important Developments

Motions in Limine in Tax Court Forums

Employee Benefits

Ethical Issues in Executive Compensation Plans

Lifetime Income Options for Retirement Plans

Pension Benefit Guaranty Corporation Update

Wellness Programs: HIPAA, the ADA , and GINA, Oh My!

Employee Benefits Defined Benefit Plans Update

Employee Benefits Distributions Update

Employee Benefits Executive Compensation, Fringe Benefits and Securities Law Update

Employee Benefits ESOP Update

Employee Benefits Welfare Benefits Design, Funding and Regulation Update

Employment Taxes

Federal Injunctions and Employment Taxes

How to Navigate the IRS Civil Employment Tax Penalties Maze

Just How Exactly Is the IRS Organized?

Energy and Environmental Taxes

Administrative Update on Renewable Energy

Legislative Update: Energy Tax Proposals and Policy

Estate & Gift Taxes

Art is Long, Life is Short: Estate Planning for the Artist and Art Collector

Choosing the Right Investment for Your Charitable Trust

Current Developments

Exempt Organizations

Ancillary Joint Ventures

Developments in IRS Enforcement

Family Foundations: Practical Problems and Practical Solutions

VAT and the Tax-Exempt Sector: Unique US Tax Issues

Fiduciary Income Tax

Early Termination of Charitable Remainder Trusts

Estate Planning Issues with Intra-Family Loans and Notes

IRA Minimum Distributions- What Really Happens After Death

Regulatory Roundup and Recent Developments

Foreign Activities of US Taxpayers


Transactions in the Cloud and Subpart F

Foreign Lawyers Forum

Beneficial Ownership

Taxation of Indirect Transfers of Shares: An Update in Light of the Vodafone Decision in India

Individual and Family Taxation

Section 469 – Passive Activity Loss and Credit Rules 25 Years Later - Trends and Recent Developments

The Nominee/Transferee/Alter-Ego Lien – What Can a Practitioner Do?

Insurance Companies

FATCA from an Insurance Company Perspective

Insurance Tax Litigation

Update on Insurance Tax Matters

Investment Management

US Private Equity Fund Outbound Transaction Structuring

Joint: Closely Held Businesses and Civil & Criminal Tax Penalties

Approaching Penalty Abatements: Strategies & Pitfalls

Joint: FAUST, FLF, Transfer Pricing & USAFTT

Joint Current International Developments Panel

Low Income Taxpayers

Tax Issues Impacting Military Personnel

Low Income Taxpayers Workshop

Timely Assessments

Partnerships and LLCs

Is there Alchemy when Debt Disappears in Partnership Contribution/Distribution Transactions?

Shazam! Debt Appears! Springing Debt and Rev. Rul. 99-5

The Trial of a Partnership Tax Case

Pro Bono

Pro Bono Matters: The Exploding Need for Pro Bono Services for Exempt Organizations

Real Estate

A New Bite: The 3.8% Tax on Net Investment Income

Hot Topics with Government Panelists

Recent REIT Developments

The Long-Awaited Proposed Repair Regulations under Section 263(a); What Do They Mean to You?

The UBTI Exception: Fractions Rule Compliance under Section 514(c)(9)

S Corporations

Current Developments

Hot Topics related to S Corporations

Worrying about Being At-Risk – Applying Section 465 to S Corporations

Sales, Exchanges and Basis

Current Developments in Sales, Exchanges and Basis, Including Sections 1031 & 1033

Is It Treated as a Sale? Lease, Financing? Constructive Sale? Option? Something Else? – Part II

Like-Kind Exchanges Involving Oil, Gas and Mineral Interests – Tax Gold

Section Program: Joint: Bankruptcy & Workouts and Low Income Taxpayers

Eliminating Tax Debt through Offer in Compromise or Bankruptcy

Section Program: Joint: Employment Taxes and Closely Held Businesses

Litigating Worker Classification Issues

Section Program: Real Estate

Income Tax Aspects of Debt Workouts

Standards of Tax Practice

Ethical Issues Arising When an Error in a Closed Year is Identified - Can You and Should You Correct it?

Losing the Forest Through the Trees: Has Routine “Legending” of E-mails and Other Communications Caused Practitioners to Lose Sight of the Underlying Ethical Rules?

State & Local Taxes

State Taxation of Foreign Income

Taxation of Nonprofit Healthcare Organizations – State and Federal Perspectives

The Evolving Marketing Concepts For Selling Goods and Services and Their Treatment For Sales Tax Purposes

Transparency Obligations of State and Local Government

Tax Accounting

Current Developments

Review of the Treatment of Rotable Spare Parts

Significant Issues Arising with the Application of Section 199

Tangible Property Regulations: Accounting Method Change Guidance

Tax Bridge to Practice

GENERAL SESSIONS: Corporate Tax: Know Your Spin-offs, Split-offs and Split-ups; A Tax Free Trifecta to Separate a Company’s Business

TRACK 2: Nuts & Bolts of Deficiency Cases: From Examination to the Tax Court

Tax Exempt Financing

Ethical Issues For Tax Attorneys Whose Practice Is In The Area Of Tax Exempt
And Other State And Local Government Finance

Tax Policy and Simplification

Perspectives on Tax Reform: Restoring the Middle Class

Tax Practice Management

Avoiding Malpractice

Transfer Pricing

How to Speed Up the APA Process

US Activities of Foreigners and Tax Treaties

Proposed Section 892 Regulations Facilitate Access to US Sovereign Exemption

US International Tax Planning in the Cloud

Young Lawyers Forum

IRS Guidance and the Section 1411 Tax on Net Investment Income