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Thoughtful Insights. Useful Analysis.
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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.
Materials by Committee
Administrative Practice |
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| Administrative Practice Important Developments | Outline: Outline of Important Developments |
| Administrative Practice Important Developments | Slides: Administrative Practice Important Developments |
| LB&I Compliance Campaigns | Slides: LB&I Campaigns |
| Managing SB/SE Exams | Outline: Advanced Examination Techniques and the Practitioner's Role in Protecting Taxpayer's Rights |
Affiliated and Related Corporations |
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| SALT Issues in Transactions Among Consolidated Group Members | Slides: SALT Issues in Transactions Among Consolidated Group Members |
| Section 355 in Consolidation: Is it Different? | Slides: Section 355 in Consolidation: Is it Different? |
| Worthless Securities Deductions in Consolidated Groups | Slides: Worthless Securities Deductions in Consolidated Groups |
Capital Recovery and Leasing |
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| Current Developments Report and Update on Pending Guidance | Outline: Current Developmentss |
| Tax Reform and Its Impact on Capitalization and Cost Recovery | Chart: Comparison of Business Tax Proposals |
Civil and Criminal Tax Penalties |
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| Above the 20 | Outline: Civil Tax Penalties Above 20% |
| Department of Justice Tax Division - Update | Outline: Department of Justice Tax Division - Update |
| Internal Revenue Service, Criminal Investigation - Update | Outline: Important Developments: Criminal |
| IRS Employment Tax Audits Part II (When the Rubber Hits the Road) | Outline: IRS Employment Tax Audits Part II |
| Reports of Subcommittees on Important Developments | Outline: Important Civil Developments: Mid-January 2017 through Mid-April 2017 |
| Reports of Subcommittees on Important Developments | Outline: Important Developments: Criminal |
| Reports of Subcommittees on Important Developments | Slides: IRS Investigations and Practices Update |
Closely Held Businesses |
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| Selling or Dissolving Your Law Practice: Practical and Ethical Considerations | Outline: Selling or Dissolving Your Law Practice: Practical and Ethical Considerations |
Corporate Tax |
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| Recent Developments in Corporate Taxation | Slides: Recent Corporate Tax Developments |
| Tax Planning Under the Tax Reform Act of 2017 | Slides: Tax Planning Under the (Hypothetical) Tax Reform Act of 2017 |
Court Procedure and Practice |
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| Best Practices in Appeals | Slides: Best Practices in Dealing with IRS Appeals |
| Current Developments in Court Procedure and Practice | Outline: Current Developments |
| Let the Sunshine In: Appealing a FOIA Determination | Slides: Let the Sunshine In: Appealing a FOIA Determination |
Diversity |
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| Federal Tax Reform: Beyond Dollars and Cents | Slides: Federal Tax Reform: Beyond Dollars and Cents |
Employment Taxes |
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| Federal Employment Tax Update | Slides: Federal Employment Tax Update |
| IRS Employment Tax Audits Part I | Slides: IRS Employment Tax Audits Part I |
| Workforce Tax Issues - Employment Tax and Other Aspects of Tax Enforcement and Compliance Affecting Employers | Slides: Workforce Tax Issues - Employment Tax and Other Aspects of Tax Enforcement and Compliance Affecting Employers |
| Workforce Tax Issues - Employment Tax and Other Aspects of Tax Enforcement and Compliance Affecting Employers | Slides: Form 941 and Form W-2 Combined Annual Wage Reporting |
Estate & Gift Taxes |
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| Current Developments in Estate & Gift Taxes | Outline: Current Developments in Federal Transfer Taxes |
| Planning for Privacy in a Public World: The Ethics and Mechanics of Protecting Your Client’s Privacy and Personal Security | Outline: Planning for Privacy in a Public World: The Ethics and Mechanics of Protecting Your Client's Privacy and Personal Security |
| The Private Family Trust Company: A Fully Empowered Platform for Family Flourishing | Slides: The Private Family Trust Company: A Fully Empowered Platform for Family Flourishing |
| An Insider’s View to the Guidance and Rulemaking Process | Outline: Rulemaking at the Department of Treasury and IRS Office of Chief Counsel |
Exempt Organizations |
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| Fostering Entrepreneurship and Innovation - Issues and Approaches for Exempt Organizations | Outline and Slides: Fostering Entrepreneurship and Innovation - Issues and Approaches for Exempt Organizations |
| News from the Hill | Slides: News from Capitol Hill |
| News from the IRS and Treasury | Slides: News from the IRS and Treasury |
| The Current Climate for Nonprofit Enforcement | Outline: The Current Climate for Nonprofit Enforcement |
Fiduciary Income Tax |
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| Back to Basics: Analyzing the Differences Between Fiduciary Accounting Income ("FAI") and Distributable Net Income ("DNI") | Slides: Back to Basics: Analyzing the Differences Between Fiduciary Accounting Income ("FAI") and Distributable Net Income ("DNI") |
| Changing the Income Tax Status of a Trust: Consequences, Complications and Considerations | Slides: Grantor Trust Liabilities An income tax analysis: When a grantor trust becomes a complex trust When a complex trust becomes a grantor trust |
| Current Developments in Fiduciary Income Tax | Outline: Recent Developments in Fiduciary Income Tax |
| Reverse-Engineering Life Insurance to Meet a Client's Specific Planning Needs: A Case Study | Outline: Case Study: Life Insurance Planning and Financial Analysis |
Financial Transactions |
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| Call "Security": The Definitions Are Running Amok | Slides: Call "Security": The Definitions Are Running Amok |
Individual & Family Taxation |
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| IRS Bitcoin Enforcement Panel | Slides: Bitcoin and Virtual Currencies: What Are They? How Are They Taxed? Trends In IRS Enforcement |
| Reporting to Consumers: Issues Relating to For-Profit Schools and Housing | Outline: Information Return Problems: Student Loans as a Case Study |
| Reporting to Consumers: Issues Relating to For-Profit Schools and Housing | Slides: Systemic Approaches to Information Return Issues |
| Reporting to Consumers: Issues Relating to For-Profit Schools and Housing | Slides: Americans Are Losing Hundreds of Billions Of Dollars In Tax Deductions Because Banks And Mortgage Servicers Are Failing To Correctly Report On Form 1098 Payments Of Capitalized Or Defaulted Mortgage Interest |
| Section 152 Proposed Regulations | Slides: Section 152 Proposed Regulations |
Investment Management |
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| Impact of Tax Reform on the Investment Management Industry | Slides: Impact of Tax Reform on the Investment Management Industry |
| Primer on Structuring Real Estate Funds | Slides: Primer on Structuring Real Estate Funds |
Low Income Taxpayers Representation Workshop |
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| Death of a Small Business | Outlines: Death of a Small Business |
| Death of a Small Business | Slides: Death of a Small Business |
| Inception of a Small Business | Slides: Top Ten Tax Traps for Small Businesses |
| Inception of a Small Business | Slides: Inception of a Small Business |
| Operation of a Small Business | Slides: Operation of a Small Business |
| Recent Developments in Low Income Taxpayer Representation | Outline: Recent Developments in Federal Income Taxation Affecting Low-Income Taxpayers |
Partnerships & LLCs |
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| Breaking Bad – Dealing with the Partnership Audit Rules and Partnership Agreement Drafting Considerations | Outline: Breaking Bad – Dealing with the Partnership Audit Rules and Partnership Agreement Drafting Considerations |
| Breaking Bad – Dealing with the Partnership Audit Rules and Partnership Agreement Drafting Considerations | Slides: Breaking Bad – Dealing with the Partnership Audit Rules and Partnership Agreement Drafting Considerations |
| Hot Topics in Partnerships & LLCs | Slides: Hot Topics |
| Issues Arising Under Section 721(c) Guidance | Slides: Issues Arising Under Section 721(c) Guidance |
| The Partnership Anti-Abuse Rule 20 Years Later – What’s The Verdict? | Slides: The Partnership Anti-Abuse Rule 20 Years Later —What’s The Verdict? |
Pro Bono & Tax Clinics |
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| Litigating the "Merits" of a Tax Liability in Collection Due Process Cases Under Sections 6320 and 6330: What Are The "Merits" of a Tax Liability and When Can You Raise Them in a CDP Case? | Outline: Litigating the "Merits" of a Tax Liability in Collection Due Process Cases under Sections 6320 and 6330: What Are the "Merits" of a Tax Liability and When Can You Raise Them in a CDP Case? |
| Litigating the "Merits" of a Tax Liability in Collection Due Process Cases Under Sections 6320 and 6330: What Are The "Merits" of a Tax Liability and When Can You Raise Them in a CDP Case? | Slides: Litigating the "Merits" of a Tax Liability in Collection Due Process Cases under Sections 6320 and 6330: What Are the "Merits" of a Tax Liability and When Can You Raise Them in a CDP Case? |
| Tax Benefits for Working Families: Lessons Learned and Ideas for Reform | Slides: A Brief History of the Earned Income Tax Credit (EITC) |
| Tax Benefits for Working Families: Lessons Learned and Ideas for Reform | Slides: Tax Benefits For Working Families: Lessons Learned and Ideas for Reform |
| Update from the Tax Court | Outline: United States Tax Court Update |
Real Estate |
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| Completed Contract Method for Land Developers Under Section 460 | Slides: Completed Contract Method for Land Developers Under Section 460 |
S Corporations |
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| Converting Stock Sales to Assets Sales (and Back Again) | Slides: Converting Stock Sales to Assets Sales (and Back Again) |
| Hot Topics in S Corporations | Slides: Hot Topics |
| Important Developments in S Corporations | Outline: Important Developments in the Federal Income Taxation of S Corporations |
Sales, Exchanges and Basis |
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| Current Developments and Legislative Prospects Relating to Sales, Exchanges & Basis | Outline: Current Non-Section 1031 Developments |
| Current Developments and Legislative Prospects Relating to Sales, Exchanges & Basis | Outline: Current Developments in Like-Kind Exchanges |
| "My Principal Purposes in Acquiring Related Party Property Didn't Include Tax Avoidance" | Slides: What's New from Malulani? |
| What's New Concerning Cancellation of Qualified Real Property Business Indebtedness? | Outline: What's New Concerning Cancellation of Qualified Real Property Business Indebtedness? |
| When Can a Federal Appointee's Gain on Divestiture Be Trumped by Section 1043? | Outline: When Can a Federal Appointee’s Gain on Divestiture Be Trumped by § 1043? |
| When Can a Federal Appointee's Gain on Divestiture Be Trumped by Section 1043? | Slides: When Can a Federal Appointee's Gain on Divestiture Be Trumped by Section 1043? |
Section Programs |
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| International Information Reporting | Slides: International Tax Compliance |
Standards of Tax Practice |
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| Ethical Issues in Federal Tax Practice - The Government Perspective | Slides: Office of Professional Responsibility Update |
| Ethical Issues in Preserving and Collecting Evidence | Slides: Ethical Issues in Preserving and Collecting Evidence |
| Ethical Issues in Representing Tax Professionals | Slides: Ethical Issues in Representing Tax Professionals |
State & Local Taxes |
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| Credit for Sales/Use Tax Paid to Other States | Slides: Credit for Sales/Use Tax Paid to Other States |
| Recent State Legislative Developments in Taxation | Slides: Recent State Legislative Developments in Taxation |
Tax Accounting |
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| Current Developments in Tax Accounting | Outline: Current Developments |
| Harmonizing the Rules for Advance Payments | Slides: Harmonizing the Rules for Advance Payments |
| Mark-to-Market Accounting Method Issues | Slides: Section 475 Accounting Methods |
Tax Bridge to Practice |
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| Common Cross-Border Issues in M&A and Tax Planning | Slides: Common Cross-border Issues in M&A and Tax Planning |
| Notice 2016-73 and the Repatriation of Offshore Earnings | Slides: Notice 2016-73 and a Brief History of Cross-Border Triangular Reorganizations |
| Practicing Constitutional Law Every Day | Slides: Nuts & Bolts of State and Local Tax: Practicing Constitutional Law Every Day |
Tax Collection, Bankruptcy and Workouts |
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| Managing the IRS Collection Process - The IRS Field Collection Operations | Slides: Knowing Collection in 2017 |
| Managing the IRS Collection Process - The IRS Field Collection Operations | Slides: Managing the IRS Collection Process - The IRS Field Collection Operations |
| New Developments in Tax Collection, Bankruptcy and Workouts | Outline: Recent Developments in Tax Collection, Bankruptcy, and Workouts |
| Ultimate Tax Collection - Can’t Pay? | Slides: Ultimate Tax Collection: Bankruptcy v. Offer in Compromise: Alternatives to Resolving Tax Debts A Comparative Approach |
Tax Exempt Financing |
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| Selected Tax Issues in Refundings – Is It Lost? | Outline: Multipurpose Allocations in the Refunding and Pool Bond Context |
Tax Policy and Simplification |
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| Treasury Regulations and Guidance: Impact of the Administrative Procedure Act (APA) and Other Regulatory Guidance Processes | Outline: Regulatory Guidance Processes: Treasury and OMB Need to Reevaluate Longstanding Exemptions of Tax Regulations and Guidance |
Transfer Pricing |
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| The Latest in Transfer Pricing Litigation | Slides: Transfer Pricing Litigation Round-Up |
| State Aid Allegations by the European Union: Policy and Technical Transfer Pricing Implications | Slides: State Aid Allegations by the European Union: Policy and Technical Transfer Pricing Implications |
Young Lawyers Forum |
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| Ethical Issues Under a Changing Legal Environment | Slides: Ethical Issues Under a Changing Legal Environment |