TaxIQ

    2013 May Meeting

    May 9-11, Washington, DC

    Thoughtful Insights. Useful Analysis.
    TaxIQ 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.

    Materials by Committee

    Administrative Practice
    Hey, Somebody Stole My Tax ID! Business identity theft is on the rise
    Hey, Somebody Stole My Tax ID! Business Identity Theft Resource Guide
    Hey, Somebody Stole My Tax ID! Despite warnings, most states slow to confront corporate ID theft
    Hey, Somebody Stole My Tax ID! ID theft stings Captain D's franchisee
    Hey, Somebody Stole My Tax ID! Slides: Hey, Somebody Stole My Tax ID!
    Hey, Somebody Stole My Tax ID! Slides: The growing implications of employer identity theft
    Hey, Somebody Stole My Tax ID! Tax refund scams can involve costly employer identity theft
    Hey, Somebody Stole My Tax ID! USDOJ_ US Attorney's Office - Northern District of Texas
    Hey, Somebody Stole My Tax ID! Will the Real John Doe Please Stand Up?: Tax Identity Theft Developments
    Important Developments Paper: Selected Recent Developments in Administrative Practice
    Managing International Tax Audits and Tax Risks in a Changing Global Landscape Slides: Managing International Audits and Tax Risk in a Changing Global Environment

    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
       

    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 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 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