 |
Thoughtful Insights. Useful Analysis.
|
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.
Materials by Committee
Affiliated & Related Corporations |
|
| Current Developments in Consolidated Returns | Slides: Section 336(e) regulations |
| Member Tax Years and Related Issues | Slides: Member Tax Years and Related Issues |
Banking & Savings Institutions |
|
| Highlights of the Final FATCA Regulations and Intergovernmental Agreements | Slides: The Far Reaching Impact of FATCA Across Borders and Across Industries |
| Is There a Mark to Market in your Near Future? A Discussion on the Recently Proposed Ways and Means Committee’s Tax Reform for Financial Instruments | Alert: Ways and Means Committee Issues Draft Provisions to Reform Taxation of Financial Instruments |
| Is There a Mark to Market in your Near Future? A Discussion on the Recently Proposed Ways and Means Committee’s Tax Reform for Financial Instruments | Slides: Is There a Mark to Market in your Near Future? |
| The Recent Tax Court’s Decision of the STARS Transaction | Slides: The STARS Transaction Decision and other Recent Applications of the Economic Substance Doctrine |
Bankruptcy & Workouts |
|
| A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of Justice | Discussion Topics: A Conversation With Chief Counsel and The Tax Division |
| A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of Justice | Endnotes to PowerPoint |
| A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of Justice | Reference Materials |
| A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of Justice | Slides: The Secured Federal Tax Debt in Bankruptcy |
| Judges' Perspective: What Tax Practitioners Need to Know about Chapter 11 | Tax-Related Requirements in Chapter 11 Bankruptcy: What Tax Lawyers Should Know About Chapter 11 |
| The Mysteries of § 108 | Issues In Cancellation Of Debt Income Cases |
Business Cooperatives & Agriculture |
|
| Cooperative Tax Update | Slides: Cooperative Tax Update |
| Recovery Periods for Agricultural Structures | Panel Materials |
| The Battle for the Cash Method of Accounting – Part I: The Internal Revenue Service's New Position and the Taxpayer's Response | Panel Materials |
Capital Recovery & Leasing |
|
| Capitalization Issues Affecting Banks | Slides: Capitalization Issues Affecting Banks |
| Current Developments Report and Update on Pending Guidance | Capital Recovery and Leasing Update - May 2013 |
| Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263A | IRS Memorandum (LB&I-04-0313-001), Accounting Method for Converting Capitalized Assets to Repair Expense Under Section 263(a) |
| Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263A | Notice 2012-73 |
| Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263A | Panel Materials: Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263A |
| Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263A | Rev. Proc. 2012-19 |
| Issues with Early Adopting the Tangible Property Regulations and Complying with Section 263A | Rev. Proc. 2012-20 |
Civil & Criminal Tax Penalties |
|
| Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing Advocacy | BOP - TRULINCS |
| Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing Advocacy | Criminal Defense Update- BOP Compassionate Release |
| Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing Advocacy | Cumberland - (Camp) Admissions & Orientation Handbook |
| Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing Advocacy | Morris Correctional Manual |
| Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing Advocacy | Panel Materials |
| Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing Advocacy | Second Chance Act - 18 USC 3624 |
| Assisting Clients With the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing Advocacy | The Federal Bureau of Prisons’ Compassionate Release Program |
| Interview with Acting Deputy Assistant Attorney General, Department of Justice | Materials: Interview with Acting Deputy Assistant Attorney General, Department of Justice |
| Interview with Chief of Criminal Investigation | Materials: Interview with Chief of Criminal Investigation |
| Reports of Subcommittees on Important Developments | Important Developments — Criminal |
| Reports of Subcommittees on Important Developments | Important Developments on Civil Penalties |
| Reports of Subcommittees on Important Developments | IRS Investigations and Practices Subcommittee Report |
| Reports of Subcommittees on Important Developments | Paper: Report of Subcommittee on International Enforcement |
| Reports of Subcommittees on Important Developments | Subcommittee Report: Legislative & Administrative Developments |
| The Handling and Mishandling of IRS Witnesses | Additional Materials |
| The Handling and Mishandling of IRS Witnesses | Slides: The Handling and Mishandling of IRS Witnesses |
Closely Held Businesses |
|
| The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations – Part II | ABA Section of Taxation Comments Concerning Proposed Treasury Regulations under Section 1411 |
| The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations – Part II | Slides: The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations |
| What's New in Worker Classification? | Article: Worker Classification Issues in Professional Practices |
| What's New in Worker Classification? | Bio: Betty Williams |
| What's New in Worker Classification? | Slides: What’s New in Worker Classification Background and Enforcement Trends in Worker Classification |
Corporate Tax |
|
| Contingent Liabilities In Taxable and Tax-Free Transactions | Slides: Contingent Liabilities in Taxable Transactions and Distributions |
| Current Corporate Tax Developments | Slides: ABA Corporate Tax Committee: Current Developments |
| Obsolete Rulings? | Slides: “Obsolete” Corporate Rulings? |
Court Procedure & Practice |
|
| Challenging IRS Action Under the Administrative Procedure Act | Slides: The Administrative Procedure Act (“APA”) and IRS Guidance |
| Crossing Borders to Conduct Discovery in Tax Litigation– Tools, Strategies, and Evolving Issues | Slides: Cross-Border Discovery in International Tax Controversies |
| Effective Use of Depositions at Trial | Effective Use of Depositions at Trial |
| Important Developments | Important Developments Summary |
Diversity |
|
| Looking Beyond DOMA: Adapting the Code to the “Modern Family” | Taxation of Same Sex Spouses After DOMA |
Employee Benefits |
|
| Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates | (1) EBSA Guidance Summary |
| Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates | (2) EBSA Update |
| Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates | (3) PBGC Update |
| Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates | (4) PBGC Proposed Regs on Reportable Events |
| Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates | (5) Technical Update |
| Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates | (6) Examining PBGC Premium Issue Brief |
| Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates | (7) DOL Field Assistance Bulletin 2013-01 |
| Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates | A Window into PBGC’S Practice: Current Issues and Trends |
| Department of Treasury/IRS Hot Topics | 2013 ABA Section of Taxation Questions & Answers for 2013 May meeting |
| Department of Treasury/IRS Hot Topics | Summary of Selected Guidance Issued by IRS during the Past Year |
| Department of Treasury/IRS Questions and Answers | 2013 ABA Section of Taxation Questions & Answers for 2013 May meeting |
| Fiduciary Issues Encountered by Plan Administrators with Abandoned Plans and Plan Sponsors in Bankruptcy | Materials: Record retention and compliance |
| Fiduciary Issues Encountered by Plan Administrators with Abandoned Plans and Plan Sponsors in Bankruptcy | Slides: Fiduciary Liability Issues: Defined Benefit Plan Terminations |
| Fiduciary Issues Encountered by Plan Administrators with Abandoned Plans and Plan Sponsors in Bankruptcy | Slides: Record Retention and Compliance |
| Fiduciary Issues Encountered by Plan Administrators with Abandoned Plans and Plan Sponsors in Bankruptcy | Slides: Safe Harbor Rollover and Plan Administration Issues |
| The Ins and Outs of Benefit Provisions in M&A Credit Agreements | Additional Materials |
| The Ins and Outs of Benefit Provisions in M&A Credit Agreements | Slides: What Benefit Provisions Should Be In M&A Credit Agreements? |
| The Ins and Outs of Benefit Provisions in M&A Credit Agreements | Sun Capital Partners III LP v New England Teamsters and Trucking Industry Pension Fund |
| Welfare Plan Developments: HIPAA, HITECH and More ACA | Slides: HIPAA Enforcement & Audits |
| Welfare Plan Developments: HIPAA, HITECH and More ACA | Slides: New HIPAA/HITECH Act Regulations - What Plan Sponsors Need To Do To Comply |
Employee Benefits Subcommittees |
|
| Subcommittee on Defined Benefit Plans | |
| Defined Benefit Plans Update | A Window into PBGC’S Practice: Current Issues and Trends |
| Defined Benefit Plans Update | GAO: Timely Action Needed to Address Impending Multiemployer Plan Insolvencies |
| Defined Benefit Plans Update | Multiemployer Pension Plans – Report to Congress Required by PPA (PBGC, Treasury, DoL) |
| Defined Benefit Plans Update | Recent PBGC Regulatory Developments |
| Defined Benefit Plans Update | Solutions not Bailouts – Report of the Retirement Security Review Commission of the NCCMP |
| Subcommittee on Defined Contribution Plans | |
| Defined Contribution Plans Update | American Taxpayer Relief Act of 2012 Excerpts |
| Defined Contribution Plans Update | Discussion Summary |
| Defined Contribution Plans Update | IRS Announcement 2007-59 |
| Defined Contribution Plans Update | Joint Committee on Taxation, General Explanation of Tax Legislation Enacted in the 112th Congress |
| Defined Contribution Plans Update | Section 401(k) Compliance Check Final Report |
| Defined Contribution Plans Update | Target Date Retirement Funds - Tips for ERISA Plan Fiduciaries |
| Defined Contribution Plans Update | Tibble v. Edison International |
| Defined Contribution Plans Update | Treasury Regulation Section 1.401(k)-3 |
| Subcommittee on Distributions | |
| Distributions Update | Panel Outline |
| Subcommittee on Employee Benefit Legislation | |
| Legislative Update | Article: Key Health, Retirement and Compensation Provisions in Obama Budget Proposal |
| Legislative Update | Side-by-Side Comparison Key Provisions House, Senate and Administration Budget Proposals |
| Subcommittee on Employee Benefits Executive Compensation, Fringe Benefits and Federal Securities Law | |
| Executive Compensation, Fringe Benefits and Federal Securities Law Update | "IRS Proposes Regulations on $500,000 Deduction Limit for Health Insurer Executive Compensation" |
| Subcommittee on ESOPs | |
| ESOP Update | Materials |
| Subcommittee on Exempt Organization and Governmental Plans | |
| Exempt Organizations and Government Plans Update | IRS Releases 403b Plan Approval Procedures |
| Exempt Organizations and Government Plans Update | Litigation Challenges to the Church Plan Definition: a Critical Issue for Church-Related Hospitals and Nonprofits |
| Subcommittee on Fiduciary Responsibility/Plan Investments | |
| Fiduciary Responsibilities Update | Fiduciary Responsibility Update |
| Subcommittee on Foreign and International Issues | |
| International Update | Cynthia Marcotte Stamer Materials |
| International Update | FATCA and Its Impact on Non-U.S. Retirement Plans |
| Subcommittee on Litigation | |
| Litigation Update | Panel Materials |
| Subcommittee on Mergers and Acquisitions | |
| Mergers & Acquisitions Update | Paper: Employee/Employee Benefits Covenants |
| Subcommittee on Multiple Employers, PEOs and Controlled and Affiliated Service Groups | |
| Multiple Employers, PEOs and Controlled Groups Update | Employer Status and the PEO Relationship |
| Multiple Employers, PEOs and Controlled Groups Update | Panel Slides |
| Multiple Employers, PEOs and Controlled Groups Update | Paper: A Multiple Employer Plans (MEPs) Primer |
| Multiple Employers, PEOs and Controlled Groups Update | The Retirement Crisis and a Plan to Solve It |
| Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices | |
| Administrative Practices Update | Outline |
| Subcommittees on Welfare Plan Design, EEOC, FMLA and Leaves Issues and Cafeteria Plans and Reimbursement Accounts | |
| Welfare Benefits Design, EEOC and FMLA Update | "Final HHS Regulations Regarding Exchange and Issuer Standards Relating to Coverage of Essential Health Benefits, Actuarial Value, and Accreditation Standards" |
| Welfare Benefits Design, EEOC and FMLA Update | Paper: On the Manifold Meanings of "Affordability" According to the Patient Protection and Affordable Care Act |
| Welfare Benefits Design, EEOC and FMLA Update | Wellness Programs: EEOC Developments and the Definition of “Tobacco Use” in New 45 CFR §147.102(a)(1)(iv) |
Employment Taxes |
|
| Employment Taxes and Visas | Nonresident Alien Tax Compliance A Clearer View |
| Employment Taxes and Visas | Paper: An Overview of U.S. Non-immigrant Visa Classifications |
| Jurisdiction and Venue in Employment Tax Refunds | Slides: Employment Tax Refund Claims: Jurisdiction & Venue Issues |
Energy & Environmental Taxes |
|
| Oil and Gas Tax Update | Slides: International Oil and Gas Tax Issues |
| Renewable Energy Tax and Grant Updates | Slides: Renewable Energy Tax and Grant Updates |
Estate & Gift Taxes |
|
| Current Developments | Karibjanian & Mensch - Current Developments in Transfer Tax |
| Preferred Equity Freezes: How They Work | Special Valuation Rules: Section 2701 |
| Tax Apportionment: One Clause Does Not Fit All | Panel Outline |
Exempt Organizations |
|
| Audits, Appeals, and Litigation: Trends and Tactics | Panel Materials |
| Denials of Applications for Tax-Exempt Status | Panel Materials |
| News from Capitol Hill | Excerpts of the Joint Committee on Taxation Report to the House Committee on Ways and Means on Present Law and Suggestions for Reform Submitted to the Tax Reform Working Groups, specifically those portions having to do with tax exempt status and the charitable deduction |
| News from Capitol Hill | Materials |
| News from Capitol Hill | Outline of Discussion Topics for Hill Update |
| News from the IRS and Treasury | Outline: News From The IRS and Treasury |
| Update on Colleges and Universities | Update on Colleges and Universities |
Fiduciary Income Tax |
|
| Before Tying the Knot: Income Tax Provisions of a Prenuptial Agreement | Paper: Before Tying The Knot: Income Tax Planning Of A Premarital Agreement |
| Regulatory Roundup and Recent Developments | Paper: Recent Developments in Fiduciary Income Tax |
| Update on the 3.8% Tax on Net Investment Income | Selected Sections of the Preamble & Proposed Regulation Text, and Selected Sections from the ABA Section of Taxation Comment Letter (dtd 4/5/13) |
| Update on the 3.8% Tax on Net Investment Income | Slides: Update on the 3.8% Tax on Net Investment Income (§ 1411) |
| Using Estate Planning Vehicles for Income Tax Planning | Using Estate Planning Vehicles for Income Tax Planning |
Financial Transactions |
|
| Advanced Topics in Market Discount | Panel Materials |
| Economic Substance and Behavioral Economics in the Wake of Bank of New York Mellon | Slides: Economic Substance, the Frame Game, and Bank of New York Mellon v. Commissioner |
| Recent Developments and Current Issues | Slides: Recent Developments |
Foreign Activities of US Taxpayers |
|
| Foreign Tax Credits | Slides: Foreign Tax Credits |
| Outbound Property Transfers Under Section 367(a)(5) | Slides: Outbound Property Transfers Under Section 367(a)(5) |
Individual & Family Taxation |
|
| Avoiding Taxpayer Penalties: First Time Abatement, and Reasonable Cause and Reliance on Professional Advice | Paper: Avoiding Taxpayer Penalties: Reasonable Cause and Reliance on Professional Advice |
| Avoiding Taxpayer Penalties: First Time Abatement, and Reasonable Cause and Reliance on Professional Advice | Paper: Update On The Accuracy Penalty: The Slippery Slope To Strict Liability |
| Avoiding Taxpayer Penalties: First Time Abatement, and Reasonable Cause and Reliance on Professional Advice | Penalty Abatement Procedures Should Be Applied Consistently to All Taxpayers and Should Encourage Voluntary Compliance |
| Avoiding Taxpayer Penalties: First Time Abatement, and Reasonable Cause and Reliance on Professional Advice | Slides: Taxpayer Penalties Strategies in Client Representation |
| How the IRS Assists Victims of Tax-Related Identity Theft and Return Preparer Misconduct or Fraud | Paper: Identity Theft |
| How the IRS Assists Victims of Tax-Related Identity Theft and Return Preparer Misconduct or Fraud | Paper: Return Preparer Fraud or Misconduct |
Insurance Companies |
|
| Affordable Care Act Implementation | ACA section 9010 health insurance provider fee -- summary of recent proposed regulations. |
| Affordable Care Act Implementation | IRC section 162(m)(6) $500,000 compensation deduction limitation -- summary of recent proposed regulations |
| Affordable Care Act Implementation | IRC sections 4375 and 4376 (PCORI fee) and ACA section 1341 Transitional Reinsurance Program Fee -- Summary of provisions |
| Dialogue On Tax Reform and Its Effects On Insurers | Slides: Dealing with Uncertainty |
| Tax Controversy: What Lessons May Be Learned From Recent Cases? | Overview of Representative Cases |
| Tax Controversy: What Lessons May Be Learned From Recent Cases? | Slides: Tax Controversy: Lessons Learned From Recent Cases |
Investment Management |
|
| Current Issues Being Addressed by the Investment Company Institute | Slides: ICI Update |
| Current Issues Being Addressed by the Investment Company Institute | Supplemental Materials |
| Taxing Private Equity Funds as Corporate ‘Developers’ | Article: Taxing Private Equity Funds as Corporate ‘Developers’ |
| Taxing Private Equity Funds as Corporate ‘Developers’ | Slides: Taxing Private Equity Funds as Corporate Developers |
| Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and Mauritius | Article: Regulated Investment Companies and Commodity-Linked Instruments: The Current State of Play |
| Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and Mauritius | Article: Two Recent Private Letter Rulings Provide a Rationale for Determining When Certain Derivative Contracts Will Be Considered Securities Under Code Sec. 851(b)(2) and Will Produce Qualifying Income for a Regulated Investment Company |
| Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and Mauritius | Doing Business in India |
| Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and Mauritius | Globalizing India Inc. |
| Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and Mauritius | Key Considerations: Joint Ventures In India |
| Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and Mauritius | Offshore Derivative Instruments: An Investigation Into Tax Related Aspects |
| Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and Mauritius | Private Equity in Real Estate |
| Updates Regarding Tax Issues Involving Regulated Investment Companies from the IRS Office of Chief Counsel and Regarding Investment Activities in India and Mauritius | Section 851 of the Code |
JOINT: Estate & Gift Taxes, Fiduciary Income Tax and Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittees Luncheon |
|
| Estate & Gift Taxes, Fiduciary Income Tax and Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittees Luncheon | Ascertainable Standards Outline |
JOINT: Foreign Activities of US Taxpayers, US Activities of Foreigners and Tax Treaties, Foreign Lawyers Forum, and Transfer Pricing |
|
| Joint Current International Developments Panel | Slides: Joint Current International Developments Panel USAFTT, FAUST, Transfer Pricing and FLF |
Partnerships & LLCs |
|
| Aggregate versus Entity: The Original Sin of Subchapter K | Slides: Aggregate v. Entity The Original Sin of Subchapter K |
| Allocation of Basis Adjustments Under Section 743(b) to Contingent Liabilities | Article: Can (or Must) Basis Adjustments Under Code Sec. 743(b) Be Allocated to Contingent Liabilities? |
| Allocation of Basis Adjustments Under Section 743(b) to Contingent Liabilities | Article: Should Purchasers Anticipate that Partnership Interests with Identical Legal and Economic Characteristics Might Produce Different Tax Results when Purchased from Different Sellers? |
| Allocation of Basis Adjustments Under Section 743(b) to Contingent Liabilities | Report on the Allocation of Basis Adjustments Under Section 743(b) to Contingent Liabilities |
| Allocation of Basis Adjustments Under Section 743(b) to Contingent Liabilities | Slides: Allocation of Basis Adjustments Under Section 743(b) to Contingent Liabilities |
| Hot Topics | Slides: Hot Topics |
Pro Bono & Tax Clinics |
|
| Tax and Consumer Transactions | 1. Dealing with Errors in the 1099C |
| Tax and Consumer Transactions | 2. Example Evidentiary Objections |
| Tax and Consumer Transactions | 2013 NCLC/CFA Tax-Time Products Report |
| Tax and Consumer Transactions | 3. Forgiven but not Forgotten |
| Tax and Consumer Transactions | NCLC-NCTC amicus in Loving v IRS |
| Tax and Disability | Outline: Taxpayers with Disabilities |
| Tax and Disability | Taxpayers with a Disability |
| Tax and Family Law | Slides: Tax and Family Law |
| Tax and Immigration | Slides: Emerging Issues: Tax Implications of Immigration Reform |
| Tax and Immigration | Slides: New ITIN Rules: The IRS Response To TIGTA Reports |
| Changes in Appeals | Outline: Appeals Judicial Approach and Culture |
| Update from Tax Court | United States Tax Court Update |
Real Estate |
|
| FATCA Compliance and Real Estate Transactions | Slides: FATCA and Real Estate |
| Issues Unique to Single Family REITs | Slides: Federal Tax Issues Unique to Single Family Rental REITs |
| Net Investment Income Tax and Its Specific Impact on Real Estate | Outline: Net Investment Income Tax |
| Net Investment Income Tax and Its Specific Impact on Real Estate | Slides: Net Investment Income Tax and Its Specific Impact on Real Estate |
| Three Decades Later, Same Issues | Slides: The Terms They Are A-Changin |
S Corporations |
|
| Application of Non-Subchapter S Provisions to S Corporations | Outline: Application of Non-Subchapter S Provisions to S Corporations |
| Current Developments | Materials: Important Developments in the Federal Income Taxation of S Corporations |
| The Proposed Regulations Regarding Section 1411’s Tax on Net Investment Income – Part I | ABA Section of Taxation Comments Concerning Proposed Treasury Regulations under Section 1411 |
| The Proposed Regulations Regarding Section 1411’s Tax on Net Investment Income – Part I | Slides: The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations |
Sales, Exchanges & Basis |
|
| Current Developments in Sales, Exchanges and Basis | Paper: Current Non-Section 1031 Developments |
| Current Developments in Sales, Exchanges and Basis | Paper: IRC § 1031/§ 1033 Current Developments |
| Front Page News: Tax Reform and Section 1031 | Materials: Front Page News: Tax Reform and Section 1031 |
| Hot Topics in Section 1031: Art Exchanges & Constructive Receipt Issues | Materials: Actual and Constructive Receipt Issues in a Deferred Exchange |
| Separating Building from Land for Tax Purposes | Separating Building from Land for Tax Purposes |
| Slogging Through Section 1(h): A Guide for the Perplexed | Paper: Slogging Through Section 1(H): A Guide For The Perplexed |
SECTION PROGRAM |
|
| Criminal Employment Tax | Slides: Criminal Enforcement of Employment Taxes |
| NAIC Annual Statements for Lawyers | Slides: NAIC Annual Statements for Lawyers |
| State and Local Tax Concerns for Closely-Held Businesses | Slides: State and Local Tax Concerns for Closely-Held Businesses |
Standards of Tax Practice |
|
| Ethical Issues in Federal Tax Practice – The Government Perspective | Appendix of Materials Referenced |
| Ethical Issues in Federal Tax Practice – The Government Perspective | Slides: Ethical Issues in Federal Tax Practice - The Government Perspective |
| Ethical Violations and Injunctive Actions Against Practitioners | Outline: Ethical Violations and Injunctive Actions Against Practitioners |
| Ethics in the Electronic Age | Slides: Ethical Issues in E-Discovery |
State & Local Taxes |
|
| Because I Said So: Forced Combination, Alternative Apportionment and Taxpayer Transparency Concerns | "Because I Said So… The Increased Use of Alternative Apportionment Methods and the Need for Transparency " |
| Current Developments: Series LLCs and Task Force Report | ABA Section of Taxation Comments on Proposed Series LLCs Regulations |
| Current Developments: Series LLCs and Task Force Report | Summary of Series LLC Task Force Report |
| Deciding How to Decide – Rules of Statutory Construction, Presumptions and Burdens of Proof | Outline |
| Sales of Other Than Tangible Personal Property: The Pros and Cons of Market-Based Sourcing | Slides: Sales of Other Than Tangible Personal Property: The Pros and Cons of Market-Based Sourcing |
| Sales/Use Tax Issues in Emerging Payments | Slides: Sales and Use Tax Issues in Emerging Payments |
Tax Accounting |
|
| Current Developments | Panel Materials |
| Tax Accounting for Litigation Expenses | Outline: The Tax Accounting Treatment of Legal Fees, including Legal Defense and Related Costs |
| Tax Accounting Issues for Foreign Pension Plans (section 404A) | Panel Slides |
| Tax Accounting Issues in Oil and Gas | Panel Outline |
Tax Bridge to Practice |
|
| Nuts & Bolts Series: Nuts and Bolts of the Affordable Care Act – Employee Benefits and Tax Aspect. | Slides: Nuts and Bolts of the Affordable Care Act: Employee Benefits and Tax Aspects |
| Nuts & Bolts Series: The Nuts & Bolts of Deficiency Cases – From Examination to the Tax Court | Judge Vasquez- Notice and Order |
| Nuts & Bolts Series: The Nuts & Bolts of Deficiency Cases – From Examination to the Tax Court | The Examination and Administrative Appeals Process |
| Nuts & Bolts Series: The Nuts & Bolts of Deficiency Cases – From Examination to the Tax Court | The Nuts And Bolts Of Deficiency Cases: From Examination To The Tax Court |
| Nuts & Bolts Series: The Nuts & Bolts of the Taxation of S Corporations | Slides: Introduction to Taxation of S Corporations |
Tax Exempt Financing |
|
| Recent Developments in IRS Enforcement and the Voluntary Closing Agreement Program for Tax-Exempt Bonds | Outline of Issues Pertaining to Panel on Recent Developments in Internal Revenue Service Enforcement and the Voluntary Closing Agreement Program for Tax-Exempt Bonds |
| The Latest News on Legislation, Regulations and Other Guidance for Tax-Exempt Bonds | Panel Outline and Materials |
| What a Section 103 Tax Lawyer Should Know About the SEC. | Panel Outline and Materials |
Tax Policy & Simplification |
|
| Government Perspectives on Tax Reform | Panel Materials |
| What are the Constitutional Parameters of Tax Reform and Simplification? | Erik M. Jensen, Post-NFIB: Does the Taxing Clause Give Congress Unlimited Power?, 136 Tax Notes 1309 (2012). |
| What are the Constitutional Parameters of Tax Reform and Simplification? | Jasper L. Cummings, 222 Years of the Supreme Court, The Constitution, and Federal Tax, 135 Tax Notes 1511 (2011). |
| What are the Constitutional Parameters of Tax Reform and Simplification? | Joseph J. Thorndike, Why Repealing the 16th Amendment Probably Wouldn't Matter, 136 Tax Notes 1369 (2012). |
| What are the Constitutional Parameters of Tax Reform and Simplification? | Slides: Constitutional Parameters of Tax Reform |
| What are the Constitutional Parameters of Tax Reform and Simplification? | Stephen Mazza & Tracy Kaye, Constitutional and Administrative Law: Restricting the Legislative Power to Tax in the United States, 54 Am. J. Comp. L. 641 (2006) |
Tax Practice Management |
|
| Working with CPAs and CFPs: Necessary or Helpful, Advantages and Concerns | Additional Links |
| Working with CPAs and CFPs: Necessary or Helpful, Advantages and Concerns | Outline: United States v. Kovel |
Teaching Taxation |
|
| The Future of Corporate Tax Reform: A Debate | Article: CORPORATE SHAMS |
| The Future of Corporate Tax Reform: A Debate | Article: Meaningless Comparisons: Corporate Tax Reform Discourse In the United States |
| The Future of Corporate Tax Reform: A Debate | The Future of Corporate Tax Reform: A Debate |
Transfer Pricing |
|
| APMA: Past, Present and Future | Slides: APMA: Past, Present and Future |
| Transfer Pricing Elements of OECD BEPS Report | Slides: Base Erosion and Profit Shifting |
US Activities of Foreigners and Tax Treaties |
|
| Coping with FATCA if You’re Not a Foreign Financial Institution | Slides: Coping with FATCA if You’re Not a Foreign Financial Institution |
| Howdy, Partner! US Tax Law Treatment of Foreign Partners | Slides: Howdy Partner! U.S. Tax Law Treatment of Foreign Partners |