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