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    TaxIQ

    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

    Diversity

    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