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
Affiliated & Related Corporations
Debt – Shmebt: What's Really at Stake If a Related Party “Note” Is Recast as Equity?
Banking & Savings Institutions
The Increasing Relevance of Penalties and Settlement Payments Under Section 162 for Banks
Bankruptcy & Workouts
Collection Due Process Hearings, and Other Collection Matters in the Appeals Division under AJAC
Objecting to and Litigating a Tax Claim in Bankruptcy
State Corporate Income Tax Issues to Consider in Bankruptcy
Capital Recovery & Leasing
Accounting for Certain Payments for the Use of Property or Services Under Section 467
Current Developments Report and Update on Pending Guidance
Tangible Property Regulations Update – Continuation from the Midyear Meeting – Transition Guidance Discussion, FAQs, and an Update on the Proposed Regulations
Civil & Criminal Tax Penalties
An Update on FBAR penalty litigation and other International Collections Efforts
Internal Revenue Service, Criminal Investigation - Update
Reports of Subcommittees on Important Developments
- Outline: Important Developments - Criminal
- Outline: Subcommittee on Attorney-Client and Constitutional Privileges Important Developments
The Compliance Perfect Storm: Voluntary Disclosures, Investigations of Offshore Financial Entities and FATCA
U.S. Department of Justice, Tax Division - Update
Section Program: How Not to Get Your Client Deported
Closely Held Business
Worker Classification Issues in State and Federal Tax Cases: An Ever Expanding and Dangerous Area of Tax Controversy
Corporate Tax
Ordinary Corporate Transaction or Listed Transaction?
Court Procedure & Practice
Important Developments
Litigating the Administrative Procedures Act – Part 2
Roundtable Discussion: The Trial Countdown
Diversity
Loyalty, Care, and Prudence: Conflicts of Interest and Fiduciary Duties
Military Stories: Tax and Legal Issues for Military Families
- Paper: Military Stories: Legal Issues for Military Families
- Slides: Military Stories: Legal Issues for Military Families
Employee Benefits
401(k) Plan Pitfalls
Affordable Care Act: Where Are We Now and Where Are We Going?
- Chart: Crediting Hours of Service for Leaves of Abscense Under the Look-Back Measurement Method
- Chart: Look-BackMeasurement Method of Determining the Full-Time Status of Employees Under Treas. Reg. §54.4980H-3(d)
- Outline: Affordable Care Act: Where Are We Now and What Have We Learned?
Department of the Treasury/Internal Revenue Service Hot Topics
Department of Treasury/Internal Revenue Service Questions and Answers
New Ideas for Pension Reform
Defined Contribution Plans Update
Fiduciary Responsibilities Update
Legislative Update
Litigation Update
Distributions and Defined Benefit Plans Update
- Outline: Recent PBGC Legislative/Regulatory Developments
- Agenda: Retirement Plans: Uncashed Checks and Missing Participants
- Slides: Same-Sex Marriage and Qualified Retirement Plans
Executive Compensation, Fringe Benefits and Federal Securities Law Update
- Slides: Employment and Separation Agreements
- Summary: Draft Comments with Respect to Proposed 162(m)(6) Regulations
International Update
- Slides: Employee Benefits for Same-Sex Spouses After US v. Windsor
- Supplement: Article 18(1) Language
Multiple Employers, PEOs and Controlled Groups Update
Welfare Plan and EEOC Issues Update
- Outline: International Issues Update IRC 4980H
- Outline: Welfare Plan and EEOC Issues Update
- Outline: Changes to Employer Responsibility Rules Made by Final Section 4980H Regulations
- Outline: High Level Outline of Code Section 4980I Issues
- Chart: Transfer Between Look-Back and Monthly Measurement Methods
- Slides: Employer Reporting Requirements Under ACA
Exempt Organization and Governmental Plans Update
Employment Taxes
Section Program: Collecting Federal Employment Taxes
Taxing the Mobile Workforce: Federal and State Approaches
Update: Employer’s Obligations under the Affordable Care Act
Worker Classification Issues in State and Federal Tax Cases: An Ever Expanding and Dangerous Area of Tax Controversy
Estate & Gift Taxes
Current Developments
Venn Diagrams: Meet Me at the Intersection of Estate & Income Tax (Planning in the ATRA-Math)"
- Paper: Venn Diagrams: Meet Me at the Intersection of Estate & Income Tax
- Slides: Venn Diagrams: Meet Me at the Intersection of Estate & Income Tax
Exempt Organizations
Committee’s Response to the Proposed 501(c )(4) Regulations
News from the Hill
Fiduciary Income Tax
Planning Under the Net Investment Income Tax
The Power to Adjust and The Power to Convert – How, When, Why and What Do Professionals Do, and Defending the Decision
- Outline: When You Must Adjust -- How, When, Why & What Do the Professionals Do?
- Slides: When You Must Adjust -- How, When, Why & What Do the Professionals Do?
Unraveling Family Limited Partnership’s
Financial Transactions
Hot Issues Under Section 475
Joint Current International Developments Panel – Part II
Foreign Activities of US Taxpayers
Returning Cash to the US
Investments in United States Property under Section 956 Developments and Unresolved Issues
Joint International Committee: FAUST, FLF, USAFTT, and TP
Joint Current Developments: FAUST, FLF, Transfer Pricing and USAFTT
Foreign Lawyers Forum
BEPS Won’t Wait: It's Here and Now and You Need to Know About It! How BEPS is Already Affecting International Tax Planning
Individual & Family Taxation
“Eggshell” Audits and Avoiding a Criminal Referral
- Outline: Eggshell Audits
- Slides: Eggshell Audits: Handling IRS Examinations of Closely Held Businesses When There Are Criminal Tax Issues
Learning the Basic Rules and Staying Updated on Recent Changes to Requesting Innocent Spouse Relief
Taxpayer Uncertainty from Damage Awards and Settlements
Insurance Companies
Captive Insurance Companies and Employee Benefits: How Do These Areas Intersect and What Are the Tax Issues?
Section 4371 Excise Tax on Foreign-Issued Insurance and Reinsurance Contracts: What Are Some of the Issues, and How Are Companies Affected by the Recent Validus Case?
Investment Management
Current Issues Being Addressed by the Investment Company Institute
FATCA Update for Onshore and Offshore Private Investment Funds: Risks, Responsibilities and Oversight
IRS Office of Chief Counsel Update on Regulated Investment Company Issues.
Low Income Taxpayers Representation Workshop
Communicating with Clients who have Health, Learning, or Mental Disabilities or Trauma
Communicating with Immigrant Communities
Communicating with Third Parties
Handling Communication Breakdowns
Partnerships & LLCs
Built-in Losses, Section 704(c) Layers, Mandatory Basis Adjustments, and Basis Adjustment Apportionments
Related Issues: Proposed Regulations on Section 752 and Related Party Rules
Risky Risk of Loss and Disguised Sale Proposed Regulations (Part II)
- Outline: Proposed Regulations on Debt Allocations: Controversial, and Deservedly So
- Slides: Risky Risk of Loss and Disguised Sale Proposed Regulations
- Slides: Top Ten Isues with the Proposed Regulations Under Section 752
Pro Bono & Tax Clinics
Loving Tax Return Preparers
Recent Developments at the Tax Court of Interest to Low Income Taxpayers
Real Estate
Risky Risk of Loss and Disguised Sale Proposed Regulations (Part I)
- Outline: Proposed Regulations on Debt Allocations: Controversial, and Deservedly So
- Slides: Risky Risk of Loss and Disguised Sale Proposed Regulations
- Slides: Top Ten Isues with the Proposed Regulations Under Section 752
Section 1234A, Pilgrim’s Pride, Abandonment, and Capital vs. Ordinary Losses
S Corporations
Current Developments
Elections Under Section 336(e) Compared to Section 338(h)(10) Elections: Issues and Implications for S Corporations
- Chart: Section 336(e) - Another Tool in the Toolbox
- Slides: Section 336(e) - Another Tool in the Toolbox
The Impact on S Corporations of the New Net Investment Income Tax
Sales, Exchanges & Basis
Current Developments in Sales, Exchanges & Basis
Don’t Fall In: Pool v. Commissioner’s Impact Upon Capital Gain Preservation Transactions
Rescissions –Where Are We Now?
TICs and DST transactions: They’re Back!
What Can an Exchange Accommodation Titleholder Acquire?
Standards of Tax Practice
Ethical Issues in Federal Tax Practice – The Government Perspective
Serving Two Masters: The Practitioner’s Duties Under Circular 230 and As an Advocate for a Client
The Fallout from Loving: How Broad an Impact on Circular 230?
State & Local Taxes
Aftershave: Multistate Tax Compact Election Litigation Sweeps the Nation
Handling an Equitable Apportionment Case
McNeil Trusts v. Pennsylvania and Lewis Linn, Trustee of the Autonomy Trust 3 v Illinois - What is a resident trust for state income tax purposes?
Tax Accounting
Accounting Methods and Employee Compensation
Current Developments
Tax Accounting Issues in the Retail Industry
The Timing of Deductions for Executory Service Contracts – Economic Performance, Prepayments and Severability
Tax Bridge to Practice
Nuts & Bolts Series: International Tax Enforcement: FBARs, FATCA, and more
Nuts & Bolts Series: The Affordable Care Act and Employer Shared Responsibility Penalty
- Paper: Putting the Shared Responsibility Penalty Puzzle Together
- Slides: Putting the Shared Responsibility Penalty Puzzle Together Planning for 2015 Liability Measured By 2014 Operations
Nuts & Bolts Series: Trying Cases Before the Tax Court
Tax Exempt Financing
Legislative, Treasury and Internal Revenue Service Update
Tax and Bond Lawyers as “Municipal Advisors” for Purposes of the SEC
Tax Policy & Simplification
Do Inversions Matter? How Should Inversion Transactions Affect Our Thinking About U.S. International Tax Reform?
Corporate Tax Aggressiveness
Tax Practice Management
Planning for Disaster: Making Sure the Flood, Fire, Hurricane or Tornado Isn’t a Disaster for Your Practice
Teaching Taxation
EITC: A More Complete Story of Error Rates, Compliance, and Recipients
Transfer Pricing
The OECD Discussion Draft and the Future of Transfer Pricing Documentation
- Paper: Key Points
- Slides: The OECD Discussion Draft and the Future of Transfer Pricing Documentation
Transfer Pricing UTP Disclosures: Looking Back and Forward
US Activities of Foreigners & Tax Treaties
Meeting the Ethical Challenges of Inbound Controversies
When Can You Actually Claim Treaty Benefits? Navigating the Thornier Issues of the Limitation on Benefits Article