TaxIQ

    2015 May Meeting

    May 7-9, 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.

    Administrative Practice
    Important Developments Outline: Selected Recent Developments in Administrative Practice
    Section Program: Choosing Wisely: When to Use (or Not Use) Mediation to Obtain Cost-Effective Closure in Exam & Collection Cases Slides: Choosing Wisely: When to Use (or Not Use) Mediation to Obtain Cost Effective Closure in Exam & Collection Cases
    What's New in IRS Exam and Appeals Slides: The New Way Forward: LB&I Examinations and Appeals

    Affiliated & Related Corporations
    Current Developments Slides: Consolidated Return Current Developments

    Banking & Savings Institutions
    Recent Developments Affecting the Banking Community Slides: Recent Developments Affecting the Banking Community
    Recent Developments on Modifications of Non-Debt Financial Instruments Slides: Mission Creep: IRS Use 0f the Debt Modification Rules to Non-Debt Financial Instruments

    Bankruptcy & Workouts
    Debt Modifications Revisited Outline: Debt Modifications After the Final 1273 Regulations
    Debt Modifications Revisited Slides: Debt Modifications After the Final 1273 Regulations
    Hot Topics in COD Income Slides: Hot Topics in COD Income
    Mediation in Collection Matters – A Brave New World Chart: Fast Track Settlement, Fast Track Mediation, Post-Appeals Mediation
    Mediation in Collection Matters – A Brave New World Slides: Post Appeals Mediation - The Collection Phase

    Capital Recovery & Leasing
    Current Developments Report and Update on Pending Guidance Outline: Current Developments

    Civil & Criminal Tax Penalties
    Day of Reckoning - An Update on Offshore Appeals Slides: Day of Reckoning - An Update on Offshore Appeals
    Reports of Subcommittees on Important Developments Outline: Important Developments - Criminal
    Reports of Subcommittees on Important Developments Outline: Monetary Violations and Forfeitures
    Reports of Subcommittees on Important Developments Slides: IRS Investigations & Practices Subcommittee Report

    CLE Committee
    HUF HUF and Blow the IRS Away: An analysis of a Hindu Undivided Family ("HUF") - Is it an entity or a trust? Neither? A Tenancies in Common? How does it comply with US Tax Laws? Slides: HUF, HUF, HUF and Blow the IRS Away
    HUF HUF and Blow the IRS Away: An analysis of a Hindu Undivided Family ("HUF") - Is it an entity or a trust? Neither? A Tenancies in Common? How does it comply with US Tax Laws? Outline: Deciphering Hindu Undivided Family

    Closely Held Business
    Buy-Sell Agreements for Closely Held Businesses Outline: Buy Sell Agreements for Closely Held Businesses
    Defending Clients From the Trust Fund Recovery Penalty Outline: Resolving Payroll Tax Issues for Closely Held Businesses

    Corporate Tax
    Current Developments Slides: Current Developments
    It's All About That Basis Slides: It's All About That Basis
    Not Free From Doubt? – Corporate Tax Opinions Slides: Not Free From Doubt? - Corporate Tax Opinions

    Court Procedure & Practice
    A Look Inside an IRS Criminal Investigation: The Journey from CI Referral to Indictment - How Did We Get Here Outline: A Look Inside an IRS Criminal Tax Investigation (The Trip from CI Referral to Plea or Indictment - How Did We Get Here?)
    Court Procedure and Practice Roundtable Discussion: First Time Tax Litigation Outline: First Time Tax Litigation
    Important Developments Charts: Important Developments
    Important Developments Outline: Important Developments Report

    Employee Benefits
    Administrative Practices Update Chart: New IRS Qualified Plan Corrections Guidance
    Affordable Care Act After 5 Years Outline: Treasury Issues Guidance and Requests Comments on 'Cadillac' Tax on Higher Cost Health Coverage
    Department of Treasury / IRS Hot Topics Outline: Summary of Selected Guidance Issued by the Department of the Treasury and the Internal Revenue Service during the Past 12 Months
    Department of Treasury / IRS Hot Topics Chart: Associate Chief Counsel
    Department of Treasury / IRS Hot Topics Chart: Division Counsel
    Department of Treasury / IRS Questions and Answers Q&A: Department of Treasury / IRS Questions and Answers
    Distributions and Defined Benefit Plans Updates Slides: Multiemployer Pension Reform Act of 2014
    Distributions and Defined Benefit Plans Updates Slides: Lifetime Income: Recent Developments
    ESOP Update Outline: ESOP Subcommittee Update
    Executive Compensation, Fringe Benefits and Federal Securities Law Update Outline: 457(f) Arrangements
    Executive Compensation, Fringe Benefits and Federal Securities Law Update Slides: SEC Proposed Hedging Rules
    Exempt Organization and Governmental Plans Update Outline: Correction of errors impacting 457(b) and 457(f) plans of Governmental and Tax-Exempt Employers
    Fiduciary Issues and Data Privacy Slides: Privacy and Security Issues Affecting Employee Benefit Plans
    Fiduciary Responsibilities Update Outline: Fiduciary Responsibilities Update
    Legislative Update Chart: Legislative Tracking Chart for March 2015
    Mergers & Acquisitions Update Outline: Ongoing Issues Under Code Sections 409A and 280G in M&A Transactions
    Multinational Employee Benefits & Compensation Issues Slides: Global Share Plans and Cross-Border Equity
    Multiple Employers, PEOs and Controlled Groups Update Outline: Enforcement of Multiple Employer Plan Terms
    Multiple Employers, PEOs and Controlled Groups Update Outline: Key Issues Identified in the Advisory Council on Employee and Pension Benefit Plans' Report on the Outsourcing of Employee Benefit Plan Services
    Multiple Employers, PEOs and Controlled Groups Update Outline: White Paper Describing Proposed Changes to the MEP 413( c) Bad Apple Rule
    Qualified Plan Testing in Controlled Group and Affiliated Service Group Environments Outline: Background Regarding Qualified Retirement Plan Testing Issues Applicable to Controlled Group and Affiliated Service Group Members
    Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: Employer Payment Plans and IRS Notice 2015-17
    Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: The Equal Employment Opportunity Commission's April 20, 2015 Proposed Regulations on Wellness Program Compliance with the Americans with Disabilities Act
    Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Slides: Group Health Plans-Factors Affecting Health Care Providers and Costs for Employers and Participants
    Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: Documenting and Communicating Eligibility Requirements after ACA
    Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: Reporting Eligibility for and Enrollment in Health Coverage

    Employment Taxes
    Exempt Organizations, Employment Taxes and Information Reporting Slides: Employment Taxes and Information Reporting for Students
    Exempt Organizations, Employment Taxes and Information Reporting Slides: Employment Taxes and Information Reporting for Students
    Federal Employment Tax Update Slides: Federal Employment Tax Update
    Recent Tax Court Jurisdictional Opinions for Worker Classification Issues Slides: Recent Tax Court Jurisdictional Opinions for Worker Classification Issues
    The Certified Professional Employer Organization and Enactment of Section 3511: What Does it Mean for Third Party Payroll Providers Slides: Enactment of Section 3511: The Certified PEO

    Energy & Environmental Taxes
    Energy Taxes Hot Topics Update Slides: Energy Tax Hot Topics Updates

    Estate & Gift Taxes
    Current Developments Outline: Current Developments in Federal Transfer Taxes
    Structuring Charitable Gifts: Blending Philanthropic Objectives with Tax Planning Outline: Structuring Charitable Gifts: Blending Philanthropic Objectives with Tax Planning
    Structuring Charitable Gifts: Blending Philanthropic Objectives with Tax Planning Outline: Charitable Split-Interest Trusts
    Top Ten Revenue Rulings for Estate Planners Outline: Top 10 Revenue Rulings Every Estate Practitioner Should Know

    Exempt Organizations
    Energy Crisis? Climate Change? The Future of Exempt Organizations Focused on Energy and the Environment Outline: The Future of Exempt Organizations Focused on Energy and the Environment
    The EO Practitioner's Perspective: Addressing Common Exempt Organizations Issues that Lack Up-to-Date Guidance Slides: The EO Practitioner's Perspective:  Addressing Common Exempt Organizations Issues that Lack Up-to-Date Guidance
    Volunteers in Exempt Organizations Slides: Tax-Exempt Organizations with Volunteers

    Fiduciary Income Tax
    Charitable Contribution Deductions for Estates and Trusts under Section 642©: Timing, Traps and Techniques Slides: Charitable Contribution Deductions for Estates and Trusts Under Section 642©: Timing, Traps and Techniques
    Current Developments Outline: Recent Developments in Fiduciary Income Tax
    State Fiduciary Law Update Outline: Surg-ING Trusts: State Income Tax Savings
    State Fiduciary Law Update Outline: Chasing Bases with the Delaware Tax Trap - Good Idea for Florida and Others?
    State Fiduciary Law Update Outline: State Fiduciary Income Taxation of Trusts

    Foreign Lawyers Forum
    General Anti-Abuse Rules (GAAR) Rapidly Gaining Territory in Double Tax Treaties Slides: General Anti-Abuse Rules (GAAR) Rapidly Gaining Territory in Double Tax Treaties
    Lux Tax Leaks Become EU Tax Leaks: 2016 Automatic Exchange of Tax Rulings in the EU Slides: Lux Tax Leaks Become EU Tax Leaks: 2016 Automatic Exchange of Tax Rulings in the EU

    Joint International Committee: FAUST, FLF, USAFTT, and TP
    Joint Current International Developments Panel Slides: Joint Current International Developments Panel

    Individual & Family Taxation
    Affordable Care Act Implementation Issues Impacting Individuals and Families Slides: Affordable Care Act: Implementation Issues Impacting Individuals and Families
    Recent Developments in the Tax-Related Identity Theft Slides: Recent Developments in the Tax-Related Identity Theft

    Insurance Companies
    Captive Insurance Update Slides: Captive Insurance Update
    Legislative Update Slides: Legislative Update

    Investment Management
    Current Regulated Investment Company Issues Slides: Current Issues for Regulated Investment Companies

    Low Income Taxpayers Representation Workshop
    Tax Court Pre-Trial Practice Outline: Tax Court Pre-Trial Practice
    Tax Court Trial and Appeals Outline: Trial and Post-Trial Procedures
    Tax Court Trial and Appeals Slides: Tax Court Trial and Appeals

    Partnerships & LLCs
    Hot Topics in Partnership Taxation Slides: Hot Topics
    May Company Regulations Slides: May Company Regulations
    Partnership Compliance Issues Slides: Partnership Compliance Issues

    Pro Bono & Tax Clinics
    Handling Cases With Potential Criminal Issues Slides: Handling Cases with Potential Criminal Issues
    Hot Topics Outline: Hot Topics Impacting Low Income Taxpayers and Practitioners
    Update from Tax Court Outline: Update from the Tax Court
    W-2 and Worker Classification Issues Slides: Worker Classification: Implications for the Low-Income Taxpayer

    Real Estate
    Motivating the Real Estate Deal and Fund Team Slides: Motivating the Real Estate Deal and Fund Team

    S Corporations
    Important Developments Outline: Current Developments in the Federal Income Taxation of S Corporations
    Section 1374(d)(7) Recognition Period Slides: Section 1374(d)(7) Recognition Period

    Sales, Exchanges & Basis
    A Critical Look at "Deferred Sales Trusts" Slides: A Critical Look at "Deferred Sales Trusts"
    Current Developments in Sales, Exchanges & Basis Outline: Current Non-Section 1031 Developments
    Current Developments in Sales, Exchanges & Basis Outline: IRC 1033 Current Developments
    Taxation of Fees for Distribution Rights and Franchises Slides: Taxation of Fees for Distribution Rights and Franchises
    The Long and the Short of the Effects of Long on Long Term Capital Gains Outline: Litigation Finance the Separate Legal Status of a Cause of Action is No Longer a Long Shot
    The Long and the Short of the Effects of Long on Long Term Capital Gains Outline: Capital Gains Under an Irresponsibly-Written Statute

    Standards of Tax Practice
    Ethical Issues in Federal Tax Practice — The Government Perspective Slides: Ethical Issues in Federal Tax Practice - The Government Perspective
    Initiating a New Client Engagement: What Kinds of Ethical and Practice Standards Questions Arise for a New Client Representation? Outline: Joint Representation (included with engagement of multiple individuals)
    Initiating a New Client Engagement: What Kinds of Ethical and Practice Standards Questions Arise for a New Client Representation? Slides: Initiating a New Client Engagement - Ethical and Practice Standards

    State & Local Taxes
    'Just Add SaLT!' When and How to Consider State Tax Ethical Issues in Advising Clients Slides: 'Just Add SaLT!' When and How to Consider State Tax Ethical Issues in Advising Clients
    Caught in the Net – Social Networking for Judges and Lawyers from the Perspective of a Local Tax Judge Slides: Caught in the Net
    Hot Topics in the State Taxation of International Operations Slides: Hot Topics in the State Taxation of International Operations
    Hot Topics in the State Taxation of International Operations Slides: Schlumberger Technology Corp. & Subsidiaries v. Alaska Department of Revenue, 331 P. 3d 334 (Alaska 2014)
    The State of State Tax Courts Agenda: Tentative Agenda for Panel Presentation: "The State of State Tax Courts Today"
    The State of State Tax Courts Slides: The Art of Persuasion
    The State of State Tax Courts Slides: Short History of the Indiana Tax Court

    Tax Accounting
    Accounting Methods Considerations for Partnerships Outline: Accounting Method Considerations for Partnerships
    Section 199 - Recent Developments and Hot Topics Slides: Section 199: Recent Developments and Hot Topics
    Tangible Property Regulations Guidance Update Outline: Tangible Property Regulations Guidance Update

    Tax Bridge to Practice
    Nuts & Bolts: Introduction to Life Insurance Company & Contracts Taxation Slides: Introduction to Life Insurance Company and Contracts Taxation
    On the Road Toward Diversity and Inclusion: Leading to Opportunities for All Slides: On the Road Toward Diversity and Inclusion: Leading to Opportunities for All
    Tax Tales: The Seminal Cases of Subchapter C Slides: Tax Tales! The Seminal Cases of Subchapter C

    Tax Policy & Simplification
    Tax and Spending Policy in the Long Run Outline: Tax and Spending Policy in the Long Run, Background Paper and Bibliography
    Tax and Spending Policy in the Long Run Slides: Dead Men Ruling: Tax & Spending Policy in the Long Run
    Tax and Spending Policy in the Long Run Slides: Dead Men Ruling: Tax & Spending Policy in the Long Run

    Teaching Taxation
    Changing the Conversation About Tax Reform: Dynamic Scoring Outline: Issues in Dynamic Scoring
    Changing the Conversation About Tax Reform: Dynamic Scoring Slides: Changing the Conversation About Tax Reform: Dynamic Scoring
    Changing the Conversation About Tax Reform: Dynamic Scoring Slides: Changing the Conversation about Tax Reform: Dynamic Scoring
    Changing the Conversation About Tax Reform: Dynamic Scoring Slides: Issues in Dynamic Scoring

    Transfer Pricing
    Advance Pricing and Mutual Agreement (APMA) - Hot Topics Slides: Advance Pricing & Mutual Agreement Procedure Panel
    How Will IRS's Transfer Pricing Operations Move Forward in the BEPS Environment? Slides: Going Forward: The IRS's Approach in the BEPS Environment

    Young Lawyers Forum
    Hot Topics in International Tax Slides: Hot Topics in International Tax: Foreign Tax Compliance