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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 PDF 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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| A Day in the Life of a Partnership Representative | Slides: A Day in the Life of a Partnership Representative |
| Tips and Best Practices for Holding an Effective Virtual Appeals Conference | Slides: Tips & Best Practices for Holding a Virtual Appeals Conference |
Affiliated and Related Corporations |
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| Applying the 2017 Tax Act to Troubled Companies Filing Consolidated Returns—Selected Issues | Slides: Applying the TCJA to Troubled Companies Filing Consolidated Returns – Selected Issues |
| Current Developments and 2017 Tax Act Guidance Themes | Slides: Current Developments and 2017 Tax Act Guidance Themes |
Banking and Savings Institutions |
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| Tax Considerations for Credit/Loan and Security Agreements | Slides: Tax Considerations for Credit Agreements/Loan and Security Agreements |
Capital Recovery and Leasing |
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| Current Developments Report and Update on Pending Guidance | Outline: Current Developments in Capital Recovery & Leasing |
| Tax Reform and Its Implications for Fixed Assets | Slides: Tax Reform Implications for Fixed Assets |
| Tax Reform and Its Implications for Leasing Transactions | Slides: Leasing Tax Update |
Civil and Criminal Tax Penalties |
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| Critical Issues for Cannabis Businesses | Slides: Critical Issues for Cannabis Companies |
| Department of Justice Tax Division – Update | Outline: Important Civil Developments |
| Musings on Marinello | Outline: Musings on Marinello |
| Reports of Subcommittees on Important Developments | Outline: Monetary Violations and Forfeitures Subcommittee Report |
| Reports of Subcommittees on Important Developments | Outline: Important Civil Developments |
| The Life and Taxing of a Cryptocurrency | Slides: The Life and Taxing of a Cryptocurrency |
Closely Held Businesses |
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| Impact of 199A on Closely Held Businesses | Slides: Minimizing Tax Burdens of Closely Held Business Owners in Light of New Section 199A |
| Worker Classification – the States, IRS and Department of Labor | Slides: Worker Classification – the States, IRS and Department of Labor |
Corporate Tax |
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| Current Developments in Corporate Tax | Slides: Current Developments |
| How the 2017 Tax Act Changes the M&A Playbook: Part I –Transactions with Third Parties | Slides: How the 2017 Tax Act Changes the M&A Playbook: Part I –Transactions with Third Parties |
| How the 2017 Tax Act Changes the M&A Playbook: Part II – Post Acquisition Planning and Internal Restructuring | Slides: Ch-Ch-Ch-Changes: Internal Restructurings After the “Tax Cuts and Jobs Act” |
Court Procedure and Practice |
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| ABCs of Summary Accounting Evidence | Slides: ABCs of Summary Accounting Evidence in Tax Court Litigation |
| ABCs of Summary Accounting Evidence | Slides: ABCs of Summary Accounting Evidence in Tax Court Litigation |
| Current Developments in Court Procedure and Practice | Outline: Summary of Recent Opinions |
| Give It Away Now: An Update on Conservation Easements, Charitable Deductions and Substantial Compliance | Outline: Give It Away Now: An Update on Conservation Easements, Charitable Deductions and Substantial Compliance |
| The Gathering Storm: Grappling with the Impact of Restitution Orders on Civil Tax Litigation | Slides: The Gathering Storm: Grappling with the Impact of Restitution Orders on Civil Tax Litigation |
| The Rise of Section 6751(b): Ghouls That Rise from the Graev | Slides: The Rise of Section 6751(b): Ghouls that rise from the Graev |
Employment Taxes |
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| Employment Tax Liabilities and IRS Collections | Slides: ABA Employment Tax Liabilities and IRS Collections |
Estate & Gift Taxes |
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| Current Developments in Estate & Gift Taxes | Outline: Current Developments in Federal Transfer Taxes |
| Dirt and Taxes: Estate Planning for Real Estate Investors | Outline: Dirt and Taxes: Estate Planning for Real Estate Investors |
| The Anatomy of the 706 – An Overview of the Federal Estate Tax Return and Tips on Reporting Entries | Outline: The Anatomy of the 706 |
Exempt Organizations |
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| Donor Advised Funds | Outline: Summary of Comments On Notice 2017-73, Request for Comments on Application of Excise Taxes with Respect to Donor Advised Funds in Certain Situations |
| New Section 4968: The Excise Tax on Investment Income of Private Colleges and Universities | Outline: The New Excise Tax on the Net Investment Income of Private Colleges & Universities (Internal Revenue Code Section 4968) |
| New Section 512(a)(6): Unrelated Business Taxable Income Silos – Separating the Corn from the Wheat | Slides: New Section 512(a)(6): Unrelated Business Taxable Income Silos – Separating the Corn from the Wheat |
| New Sections 4960 and 512(a)(7): The Entity Level Tax on Excess Compensation and UBIT on Certain Fringe Benefits | Slides: New Sections 4960 and 512(a)(7): The Entity Level Tax on Excess Compensation and UBIT on Certain Fringe Benefits |
| News from IRS, Treasury and the Hill | Slides: News from the IRS, Treasury, and Hill |
Fiduciary Income Tax |
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| Uniform Decanting: Coming Soon to a Legislature Near You? | Outline: Uniform Decanting: Coming Soon to a Legislature Near You? |
Financial Transactions |
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| Debt Restructurings in Response to the 2017 Tax Act | Slides: Debt Restructurings in Response to the 2017 Tax Act |
| Issues Involving New Section 163(j) | Slides: Issues Involving New Section 163(j) |
Foreign Lawyers Forum |
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| The Global Implications of Corporate Tax Reform: A Practical Guide | Slides: The Global Implications of Corporate Tax Reform: A Practical Guide |
Individual & Family Taxation |
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| Helping the Gig Workforce – Practice and Policy Perspectives | Slides: Helping the Gig Workforce – Practice and Policy Perspectives |
| Nudging and Educating Taxpayers to Comply: Reevaluating Traditional Approaches to Taxpayer Compliance | Slides: Nudging and Educating Taxpayers to Comply: Reevaluating Traditional Approaches to Taxpayer Compliance |
Insurance Companies |
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| A Discussion Regarding Tax Reform Implementation | Slides: Tax Reform Implementation |
| Litigating an Insurance Case in Tax Court | Slides: Litigating Insurance Tax Cases |
Investment Management |
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| Planning for Fund Managers and GPs after Tax Reform | Slides: Tax Planning for Fund Managers and GPs After Tax Reform |
| Treaty Issues for Offshore Funds and Foreign Investments | Slides: Treaty Issues for Offshore Funds and Foreign Investments (Multilateral Instrument) |
| Treaty Issues for Offshore Funds and Foreign Investments | Slides: Treaty Issues for Offshore Funds and Foreign Investments –Loan Origination |
| Updates from the Internal Revenue Service and Investment Company Institute | Slides: Updates from the Internal Revenue Service and Investment Company Institute |
Low Income Taxpayers Representation Workshop |
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| History and Context: “Tax Reform” Efforts of the Past 50 Years | Slides: History and Context: “Tax Reform” Efforts of the Past 50 Years |
| The 2017 Tax Act and Low-Income Families | Slides: The 2017 Tax Act and Low-Income Families |
| The 2017 Tax Act and Self-Employed Workers | Slides: The 2017 Tax Act and Self-Employed Workers |
Partnerships & LLCs |
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| Application of Section 1061: The Quest for Congressional Intent | Slides: Application of Section 1061: The Quest for Congressional Intent |
| Code Section 163(j) | Slides: Partnerships and Section 163(j) |
| Code Section 199A | Slides: Code Section 199A |
| Who’s the “Taxpayer”? | Slides: Who’s the “Taxpayer”? |
Pro Bono & Tax Clinics |
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| Advanced Lien Issues for Low-Income Taxpayer Representatives | Outline: IRS Liens |
| Taxpayer Rights: To What End (Part 2) | Outline: Taxpayer Rights: To What End (Part 2) |
| Update from the Tax Court | Slides: Update from the Tax Court |
Real Estate |
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| Hot Topics in Real Estate | Slides: Hot Topics in Subchapter K |
| Tax Reform - Section 163(j), Part I | Slides: Tax Reform - Section 163(j), Part I |
S Corporations |
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| Choice of Entity Under the 2017 Tax Act | Slides: Choice of Entity Under the 2017 Tax Act |
| Hot Topics in S Corporations | Slides: Hot Topics |
| Important Developments in the Federal Income Taxation of S Corporations | Outline: Important Developments in the Federal Income Taxation of S Corporations |
Sales, Exchanges and Basis |
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| Capital Gain Or Loss, Without a Sale or Exchange? Perhaps, under Section 1234A | Slides: Capital Gain or Loss, Without a Sale or Exchange? Perhaps, under Section 1234A |
| Current Developments Relating to Sales, Exchanges & Basis | Outline: Current Non-Section 1031 Developments |
| Current Developments Relating to Sales, Exchanges & Basis | Outline: Current Developments in Like-Kind Exchanges |
| The Tax Exemption for Small Business Stock is Big Business | Slides: Section 1202 Qualified Small Business Stock |
| When Does a Sale of a Contract to Provide Future Services Produce Capital Gain? | Outline: When Does a Sale of a Contract to Provide Future Services Produce Capital Gain?: Never and for Very Good Reason |
Section Programs |
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| Fundamentals of Tax Litigation: Choice of Forum and Appealing Decisions | Slides: Fundamentals of Tax Litigation: Choice of Forum |
Standards of Tax Practice |
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| Ethics Issues in Criminal Representations and Fraud Examinations | Slides: Ethics Issues in Civil Fraud Exams and Criminal Representations |
| Primer on Ethics and Circular 230 Issues for Young Attorneys | Outline: ABA Ethics: Primer on Ethics and Circular 230 Issues for Young Attorneys |
State & Local Taxes |
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| Post Wynne Challenges | Slides: Post Wynne Challenges: The Fate of Income Tax Credits and State and Local Tax Systems |
| SALT + Transfer Pricing | Slides: SALT + Transfer Pricing |
Tax Accounting |
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| Current Developments in Tax Accounting | Outline: Current Developments in Tax Accounting |
| International Tax Reform | Slides: International Tax Reform |
Tax Bridge to Practice |
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| Dude, Where’s My Refund? An Overview of Joint Committee Review of Tax Refunds | Slides: Where's My Refund? An Overview of JCT Reviews of Tax Refund Claims |
Tax Collection, Bankruptcy and Workouts |
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| Collection Abroad – Passport Revocation and Beyond | Outline: "Certifying" A Seriously Delinquent Tax Debt: IRC §7325 and the IRS |
| Collection Abroad – Passport Revocation and Beyond | Outline: International Collection – Beyond Passport Revocation |
| Collection of Title 26 International Penalties | Outline: Contesting and Compromising the Title 26 Based International Penalties |
| Collection of Title 31 International Penalties | Slides: Collection of Title 31 International Penalties |
Tax Exempt Financing |
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| Legislative, IRS, and Treasury Update | Outline: Legislative, IRS and Treasury Update Panel |
| Tax Reform Fallout | Outline: Tax Reform Fallout |
| The Multipurpose Allocation Rules Still Have an Impact | Outline: The Multipurpose Allocation Rules Still Have an Impact |
Tax Policy and Simplification |
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| The Byrd Rule and the Tax Legislative Process | Paper: The Byrd Rule and the Tax Cuts and Jobs Act: A Synopsis |
Teaching Taxation |
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| The Tax Consequences of Initial Coin Offerings | Slides: What are Decentralized Apps, Coins, Tokens, and ICOs? |
| The Tax Consequences of Initial Coin Offerings | Slides: The Tax Consequences of Initial Coin Offerings |
Transfer Pricing |
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| US Tax Reform Reshapes the Transfer Pricing Landscape | Slides: US Tax Reform Reshapes Transfer Pricing Landscape |
Young Lawyers Forum |
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| Are Some Groups More Equal Than Others? | Slides: Are Some Groups More Equal Than Others? |