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2014 May Meeting

May 8-10, 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

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

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


Loyalty, Care, and Prudence: Conflicts of Interest and Fiduciary Duties

Military Stories: Tax and Legal Issues for Military Families

Employee Benefits

401(k) Plan Pitfalls

Affordable Care Act: Where Are We Now and Where Are We Going?

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

Executive Compensation, Fringe Benefits and Federal Securities Law Update

International Update

Multiple Employers, PEOs and Controlled Groups Update

Welfare Plan and EEOC Issues Update

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)"

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

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

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)

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)

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

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

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

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