TaxIQ

2017 May Meeting

May 11-13, 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.

Materials by Committee


Administrative Practice

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

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

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

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

Selling or Dissolving Your Law Practice: Practical and Ethical Considerations Outline: Selling or Dissolving Your Law Practice: Practical and Ethical Considerations

Corporate Tax

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

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

Federal Tax Reform: Beyond Dollars and Cents Slides: Federal Tax Reform: Beyond Dollars and Cents

Employee Benefits

Affordable Care Act "Repeal and Replace" Legislation - What Does it Mean for Employers? Slides: ACA Repeal and Replace: What does it mean for employers?
Corporate Counsel Forum Slides: ACA Mandates - Beyond Reconciliation Process
Corporate Counsel Forum Slides: Planning for 2018
Defined Benefit Plans and Distributions Update Outline: Pension Benefit Guaranty Corporation Update
Defined Benefit Plans and Distributions Update Slides: Lifetime Income: Recent Developments
Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates Outline: Pension Benefit Guaranty Corporation Update
Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates Slides: PBGC Participant & Plan Sponsor Advocate
Exempt Organization and Governmental Plans Update Slides: State Administered and State Sponsored Private Employer Plans
Fiduciary Responsibilities Update Outline: Fiduciary Responsibilities Update
IRS and Department of Treasury Technical Sessions Outline: Technical Sessons on RMD Uncashed Checks
Legislation and Litigation Update Outline: Retirement Issues
Mergers & Acquisitions Update Outline: Carried Interest Plans: Partnership Equity-Based Compensation
Multinational Employee Benefits & Compensation Issues Update Slides: International Assignment Agreements and Tax Planning
Retirement Plans Legislative and Regulatory Update Outline: Retirement Plans Legislative and Regulatory Update
Unauthorized Practice of Law and the Practice of Benefits Law Slides: Unauthorized Practice of Law and the Practice of Benefits Law
Welfare Plans and EEOC, FMLA and Leaves Issues Update Outline: Employer-Sponsored Group Health Benefit Plans: Issues to Consider When Changing Plan Design to Encourage Value-Based Health Care
Welfare Plans and EEOC, FMLA and Leaves Issues Update Slides: Prescription Drug Costs Drive Controversy - What Employers Should Know

Employment Taxes

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

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

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

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

Call "Security": The Definitions Are Running Amok Slides: Call "Security": The Definitions Are Running Amok

Individual & Family Taxation

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

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

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

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

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

Completed Contract Method for Land Developers Under Section 460 Slides: Completed Contract Method for Land Developers Under Section 460

S Corporations

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

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

International Information Reporting Slides: International Tax Compliance

Standards of Tax Practice

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

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

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

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

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

Selected Tax Issues in Refundings – Is It Lost? Outline: Multipurpose Allocations in the Refunding and Pool Bond Context

Tax Policy and Simplification

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

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

Ethical Issues Under a Changing Legal Environment Slides: Ethical Issues Under a Changing Legal Environment