TaxIQ

2016 May Meeting

May 5-7, 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 Slides: Important Developments
LB&I Reorganization and Audit Redesign Slides: LB&I Reorganization and Audit Redesign

Affiliated & Related Corporations

Coffee and Doughnuts Primer Slides: Primer on Consolidated Return Topics, Including Affiliation Issues, Stock Basis Adjustments, and Treatment of Boot in an Intercompany Reorganization
Current Events Slides: Current Developments

Banking & Savings Institutions

New Proposed Section 305(c) Regulations Slides: New Section 305(c) Proposed Regulations: Deemed dividends on convertibles – analysis and compliance implications, plus corporate action and combination rule issues under Section 871(m)

Capital Recovery & Leasing

Current Developments Report and Update on Pending Guidance Outline: Current Developments
Examination Items and Issues Pertaining to Tangible Property Outline: Examination Items and Issues Pertaining to Tangible Property

Civil & Criminal Tax Penalties

Endless War: The Status of the IRS/DOJ Campaign Against Foreign Assets and Accounts Slides: Endless War: The Status of the IRS/DOJ Campaign Against Foreign Assets and Accounts
Internal Revenue Service, Criminal Investigation - Update Slides: Internal Revenue Service, Criminal Investigation - Update
Reports of Subcommittees on Important Developments Slides: IRS Investigations and Practices Subcommittee Report
Turning the Tables: The United States as a Tax Haven Destination Outline: Turning the Tables: The United States as a Tax Haven Destination
Turning the Tables: The United States as a Tax Haven Destination Slides: Turning the Tables: The United States as a Tax Haven Destination

Closely Held Businesses

Best Practices for the Planning, Valuation and Sale of Personal Goodwill Outline: Best Practices for the Planning, Valuation and Sale of Personal Goodwill
Dealing with the IRS Collection Division: An Update on IRS Collection Procedures Outline: Dealing with the IRS Collection Division: An Update on IRS Collection Procedures
Dealing with the IRS Collection Division: An Update on IRS Collection Procedures Slides: Dealing with the IRS Collection Division: An Update on IRS Collection Procedures

Corporate Tax

A Little of This, A Little of That: Cherry-Picking Gains and Losses in Transactions Slides: A Little of This, A Little of That: Cherry-Picking Gains and Losses in Transactions

Court Procedure & Practice

Current Developments Outline: Current Developments Panel
IT’S ALIVE! – Exploring Exceptions to the Statutes of Limitations to "Revive" Otherwise Time-Barred Claims Outline: IT’S ALIVE! – Exploring Exceptions to the Statutes of Limitations to "Revive" Otherwise Time-Barred Claims
IT’S ALIVE! – Exploring Exceptions to the Statutes of Limitations to "Revive" Otherwise Time-Barred Claims Slides: IT’S ALIVE! – Exploring Exceptions to the Statutes of Limitations to "Revive" Otherwise Time-Barred Claims
Most Litigated Issues in Tax Court Cases Outline: Most Litigated Issues in Tax Court Cases and Related Principles
Protective Orders: Necessary Evil or Unnecessary Burden in Tax Court? Slides: Protective Orders: Necessary Evil or Unnecessary Burden in Tax Court?

Diversity

Litigating Affordable Care Act Cases Outline: Premium Tax Credit: Emerging Issues
Litigating Affordable Care Act Cases Slides: Affordable Care Act: Emerging Premium Tax Credit Issues
The PATH Act: Changes Affecting Immigrant Families and The Challenges Ahead Outline: PATH Act ITIN Renewal Requirement
The PATH Act: Changes Affecting Immigrant Families and The Challenges Ahead Slides: The PATH Act: Changes Affecting Immigrant Families
Try to See It My Way: Technical, Policy and Advocacy Perspectives on the Home Mortgage Interest Deduction for Same Sex Couples Outline: Try to See It My Way: Technical, Policy and Advocacy Perspectives on the Home Mortgage Interest Deduction for Same Sex Couples

Employee Benefits

Defined Benefit Plan and Distributions Update Outline: Defined Benefit Subcommittee and Distributions Subcommittee Meeting
Defined Benefit Plan and Distributions Update Outline: Recent PBGC Legislative/Regulatory Developments
Defined Contribution Plans Update Outline: ERISA Claims: Recent Case Updates
Department of Labor Regulation of ERISA Disability Claims and Related Litigation Slides: Recent Developments in Disability Claims
ESOP Update Outline: ESOP Subcommittee
Executive Compensation, Fringe Benefits and Federal Securities Law Update Slides: Impact of Recent Accounting Developments on Executive Compensation
Health and Welfare Benefit Plans Update Outline: Gobeille v. Liberty Mutual Insurance Company: Defining the Field Governed by ERISA
Health and Welfare Benefit Plans Update Outline: Temporary Reprieve from Excise Tax for Subsidized Graduate Student Health Insurance
Health and Welfare Benefit Plans Update Slides: Recent Trends In Health Care Costs and Delivery
IRS and Department of Treasury Technical Sessions Outline: Rollover Issues
Legislative Update Chart: Legislative Tracking Chart for March 2016
Litigation Update Outline: Litigation Update
Mergers & Acquisitions Update Paper: Employee Stock Options Between Signing and Closing
Multinational Employee Benefits & Compensation Issues Update Slides: Non-US Employee Participation in US Qualified Retirement Plans
Multinational Employee Benefits & Compensation Issues Update Slides: Selected FIRPTA/FATCA Issues for Non-US Retirement Plans and Their Participants
Multiple Employers, PEOs and Controlled & Affiliated Service Groups Update Outline: ABA Primer: PEOs and Intersection with Employee Benefits
Necessary Plan Language in Light of Recent Guidance from the Supreme Court and Lower Courts Slides: Protective Plan Provisions
The Fiduciary Regulations Chart: Chart Illustrating Changes from Department of Labor's 2015 Conflict of Interest Proposal to Final

Employment Taxes

Federal Employment Tax Update Slides: Federal Employment Tax Update
R&D Credit and FICA Taxes Slides: R&D Credit and FICA Taxes
The Early Interaction Initiative: Accelerating IRS Collection Intervention for Unpaid Employment Tax Liabilities Slides: IRS Employment Tax Collections “Early Intervention Initiative”
Worker Classification and Section 530 Slides: Worker Classification and Section 530

Energy & Environmental Taxes

Emerging Issues in Oil & Gas Taxation Slides: Emerging Issues in Oil & Gas Taxation
Hot Topics in Renewables Slides: Hot Topics in Renewables

Estate & Gift Taxes

Current Developments Outline: Current Developments in Federal Transfer Taxes
Oh, What a Relief It Is: Curing Estate Plans That No Longer Make Sense in Light of the American Taxpayer Relief Act of 2012 Outline: Oh, What a Relief It Is: Curing Estate Plans That No Longer Make Sense in Light of the American Taxpayer Relief Act of 2012
Oh, What a Relief It Is: Curing Estate Plans That No Longer Make Sense in Light of the American Taxpayer Relief Act of 2012 Slides: Oh, What a Relief It Is: Curing Estate Plans That No Longer Make Sense in Light of the American Taxpayer Relief Act of 2012
Unpacking the Myths and Mysteries of Chapter 14 Outline: Unpacking the Myths and Mysteries of Chapter 14
Unpacking the Myths and Mysteries of Chapter 14 Slides: Unpacking the Myths and Mysteries of Chapter 14

Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittee

How to Prepare and Submit a PLR Outline: When and How to Prepare an IRS Ruling Request

Exempt Organizations

Donor-Advised Funds: Priority Issues for Regulatory Guidance Outline: Donor-Advised Funds: Priority Issues for Regulatory Guidance
Form 990 Schedule B: Balancing Benefits and Burdens Slides and Outline: Form 990 Schedule B: Balancing Benefits and Burdens
IRS Assessment of Governance Practices Outline: Understanding the Redesigned Form 990’s Governance Part (Core Form Part VI) and Its Demands

Fiduciary Income Tax

Current Developments Outline: Recent Developments in Fiduciary Income Tax
Fiduciary Income Tax Aspects of Lifetime Gifting and Education Funding Strategies Draft: Fiduciary Income Tax Aspects of Lifetime Gifting and Education Funding Strategies

Financial Transactions

Reasoning by Analogy: The Cubbyhole Approach to Innovative Financial Products and Other Transactions Slides: What Is It? Taxing the Odd

Foreign Lawyers Forum

The 2016 EU Anti-Tax Avoidance Package: Find Out What It Means to You Slides: The 2016 EU Anti-Tax Avoidance Package: Find Out What It Means to You

Individual & Family Taxation

Crime and Marriage Slides: Keeping your Client and Yourself out of Jail – Criminal Tax and Money Laundering Issues
Important Developments Outline: Important Updates 2015 to March 2016
Women and Tax Outline: The Impact of Tax on Family and Women

Insurance Companies

Insurance Company Reserves Slides: Insurance Company Reserves: Principle-based reserves for individual life insurance
Legislative Update Chart: Legislative Dialogue
What is Insurance? Slides: The Evolving Definition of Insurance: Where Are We and What Prong Are We Talking About?

Investment Management

Updates from the Internal Revenue Service and Investment Company Institute Slides: Updates from the IRS and ICI

Low Income Taxpayers Representation Workshop

Addressing ACA Problems in Non-IRS Fora Outline: Appeals before the Health Benefit Exchange
Addressing ACA Problems in Non-IRS Fora Slides: Appeals in the Health Insurance Marketplace
Property Tax Issues Outline: Philadelphia Property Tax Assistance Programs for Senior Homeowners
Property Tax Issues Outline: Reverse Mortgage Fact Sheet
Property Tax Issues Slides: Property Tax Issues
State Tax Issues Chart: State and Local Taxpayer Advocates
State Tax Issues Slides: Financial Hardship in Illinois: The IDOR Board of Appeals
State Tax Issues Slides: Working with State and Local Revenue Offices to Resolve Your Client's State Tax Problems

Partnerships & LLCs

Conversions Are Not Always Changes Slides: Conversions Are Not Always Changes
Disguised Sales of Partnership Interests - Where are We Now? Slides: Disguised Sales of Partnership Interests─Where are We Now?
Partnership-to-Partner (Non?-)Attribution: Is There a “Theory of Everything”? Slides: Partnership-to-Partner (Non?-)Attribution: Is There a “Theory of Everything”?
Recourse or Nonrecourse Matters in the Gasification of Debt Slides: Recourse or Nonrecourse Matters in the Gasification of Debt

Pro Bono & Tax Clinics

Jurisdictional Issues Slides: Jurisdictional Issues: The EITC Ban
Reflecting on Low Income Tax Clinics and Celebrating Professor Kathryn Sedo Slides: Legacy of Kathryn Sedo: A Selective Review of Litigated Cases
Update from the Tax Court Outline: United States Tax Court Update

Real Estate

Bad Boys: Whatcha Gonna Do? Slides: Effect of “Bad Boy” Nonrecourse Loan Carveouts on Partnership Liability Allocations: CCA 201606027
New Partnership Audit Provisions – Drafting Considerations Slides: Potential Surprises Lurking in the Bipartisan Budget Act
PATH Act – FIRPTA, REIT Technical and Spin-Offs Slides: PATH Act – FIRPTA, U.S. REIT Act and Spin-Offs

S Corporations

Audit Risks of an S Corporation and Its Shareholders Outline: Audit Risks of S Corporations and their Shareholders by SB/SE
Hot Topics Relating to S Corporations Outline: Application of Section 165(g)(3) to S Corporations
Important Developments Outline: Current Developments in the Federal Income Taxation of S Corporations

Sales, Exchanges & Basis

A Hot Topic: Cuban Claims and Section 1033 Slides: Taxation of Cuban Claims Recoveries
Current Developments in Sales, Exchanges & Basis Outline: Current Non-Section 1031 Developments
Current Developments in Sales, Exchanges & Basis Outline: IRC 1031 Current Developments
Dealing with Unrecaptured Section 1250 Gain in Drop-Swap Cash-Outs Slides: Drop-Swap Cash-Outs
Use of Delaware Statutory Trusts in Non-Syndicated Exchange and Drop-and-Swap Situations Slides: Use of Delaware Statutory Trusts in Non-Syndicated Exchange and Drop-and-Swap Situations

Section Programs

Welcome to International Tax: Fundamentals of Inbound, Outbound, and Tax Treaties: Inbound Taxation Slides: Welcome to International Tax: Fundamentals of Inbound Taxation

Standards of Tax Practice

Data Security, Client Confidences and Ethics Rules Applicable to the Protection of Client Information Slides: Data Security, Client Confidences and Ethics Rules Applicable to the Protection of Client Information
Ethical Issues in Federal Tax Practice – The Government Perspective Slides: Litigation Update
Ethical Issues in Federal Tax Practice – The Government Perspective Slides: Office of Professional Responsibility: Update
What’s the Risk? The Ethics of Advising Clients on Audit Risk Slides: What’s the Risk? The Ethics of Advising Clients on Audit Risk

State & Local Taxes

New IRS Partnership Audit Rules: Federal and State Tax Complexities Slides: New IRS Partnership Audit Rules: Federal and State Tax Complexities
State Sovereign Immunity in the Tax World: An Update on California Franchise Tax Board v. Hyatt Slides: State Sovereign Immunity in the Tax World: An Update on California Franchise Tax Board v. Hyatt
Tax Audits of Attorney Files – What Keeping Client Confidences Could Cost You: Ethical and Practical Issues Outline: Hypotheticals
Tax Audits of Attorney Files – What Keeping Client Confidences Could Cost You: Ethical and Practical Issues Outline: Tax Audits of Attorney Files – What Keeping Client Confidences Could Cost You: Ethical and Practical Issues
Tax Audits of Attorney Files – What Keeping Client Confidences Could Cost You: Ethical and Practical Issues Slides: Tax Audits of Attorney Files – What Keeping Client Confidences Could Cost You: Ethical and Practical Issues

Tax Accounting

Current Developments Outline: Current Developments
Recent Developments in Accounting Method Change Procedures Slides: Recent Developments in Accounting Method Change Procedures

Tax Bridge to Practice

Tax Tales 2: More Seminal Cases of Subchapter C Slides: Tax Tales 2: More Seminal Cases of Subchapter C
The Administrative Tax Collection Case Outline: The Administrative Tax Collection Case

Tax Collection, Bankruptcy & Workouts

IRS – Field Collection: Changes in How the IRS goes about “Collection Enforcement” – Administrative and The Lawyers - “Future State” and Elimination of the “SAUSA” Program: A Brave New World? Outline: IRS – Field Collection: Changes in How the IRS goes about “Collection Enforcement” – Administrative and The Lawyers - “Future State” and Elimination of the “SAUSA” Program: A Brave New World?

Tax Exempt Financing

Legislative, Treasury and Internal Revenue Service Update Chart: Partnership Allocation Example
Legislative, Treasury and Internal Revenue Service Update Outline: ABA Tax Section Tax-Exempt Financing Committee 2016 May Meeting Legislative, Treasury and Internal Revenue Service Update
Tax Issues in Seaport and Airport Financings: "It Is Not Always a Carnival When You Make a Deal with Royal Caribbean, Even If You Are Norwegian." Outline: Speaker’s Outline and Handout Examples for ABA TEFC Airport and Seaport Finance Panel

Tax Policy & Simplification

Prospects for Tax Legislation in a New Administration Slides: Tax Plans of the Presidential Candidates

Tax Practice Management

The Curse of the Billable Hour: Are You Ready for Alternative Fee Arrangements? Outline: Alternative Fee Arrangements

Teaching Taxation

EU State Aid Investigations: Perspectives from both Sides of the Atlantic Slides: Interested Parties Intervention in State Aid Proceedings Relating to Tax Rulings

Transfer Pricing

BEPS and Its Impact on Transfer Pricing for the Financial Services Sector Slides: BEPS and Its Impact on Transfer Pricing for the Financial Services Sector
BEPS and Transfer Pricing Implications for State and Local Tax (Part II) Slides: Part II: BEPS and Transfer Pricing Implications for State & Local Tax

US Activities of Foreigners & Tax Treaties

The FIRPTA Provisions of the PATH Act Slides: The FIRPTA Provisions of the PATH Act

Young Lawyers Forum

Tips for Working with the Tax Press Outline: Tips for Working with the Tax Press