TaxIQ

    2018 May Meeting

    May 10-12, Washington, DC

    Thoughtful Insights. Useful Analysis.
    Section 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 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
    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
    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
    Tax Considerations for Credit/Loan and Security Agreements Slides: Tax Considerations for Credit Agreements/Loan and Security Agreements

    Capital Recovery and Leasing
    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
    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
    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
    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
    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

    Employee Benefits
    Administrative Practices Update Outline: Administrative Practices Update
    Corporate Counsel Forum Slides: "Tag, You’re It" -- Avoiding the Fiduciary Tag
    Defined Benefit Plans Update Outline: Recent PBGC Legislative/Regulatory Developments
    Defined Benefit Plans Update Outline: Recent Statutory Enactments and Case Law Rulings Affecting Multiemployer Plans
    Department of Treasury/Internal Revenue Service Technical Sessions Outline: Tax and Funding Issues Raised by the Department of Labor’s Adoption of Proposed Association Health Plan Regulations
    Department of Treasury/Internal Revenue Service Technical Sessions Outline: Recommendations to expand health reimbursement accounts per Executive Order
    Department of Treasury/Internal Revenue Service Technical Sessions Outline: Family Leave Credit under the Tax Cuts & Jobs Act of 2017
    Department of Treasury/Internal Revenue Service Technical Sessions Outline: JCEB Technical Session with Treasury/IRS
    Distributions Update Slides: Tax Cuts and Jobs Act and Bipartisan Budget Act of 2018 –Key Provisions Impacting Qualified Plans
    ESOP Update Outline: ESOP Update
    Executive Compensation, Fringe Benefits and Federal Securities Law Update Slides: Executive Compensation Subcommittee
    Exempt Organization and Governmental Plans Update Outline: Open Issues Under Code Section 4960
    Fringe Benefits After Tax Reform: No More Free Lunch? Slides: Fringe Benefits After Tax Reform: No More Free Lunch?
    Legislation & Litigation Update Outline: Legislation & Litigation Update
    Multinational Employee Benefits & Compensation Issues Update Slides: Hot Topics for Employee Benefit Plans - Canada
    Multinational Employee Benefits & Compensation Issues Update Slides: Protecting Defined Benefit Pension Schemes –New White Paper on UK Pension Reforms
    Multinational Employee Benefits & Compensation Issues Update Slides: Irish Pension Reform
    Multiple Employers, PEOs and Controlled & Affiliated Service Groups Update Outline: Issues Related to Establishing and Maintaining 403(b) Multiple Employer Plans
    Pension Benefit Guaranty Corporation Update Outline: Recent PBGC Legislative/Regulatory Developments
    Pension Benefit Guaranty Corporation Update Slides: What Has PBGC Done for You Lately?
    Social Media Policies for Law Firms Outline: Social Media Policies for Law Firms
    Social Media Policies for Law Firms Slides: Social Media Policies for Law Firms
    Welfare Plans and EEOC, FMLA and Leaves Issues Update Outline: Pharmacy Benefits Managers, Group Health Plans and Enrollees: Recent Litigation
    Welfare Plans and EEOC, FMLA and Leaves Issues Update Slides: Taxation of Wellness Program Benefits

    Employment Taxes
    Employment Tax Liabilities and IRS Collections Slides: ABA Employment Tax Liabilities and IRS Collections

    Estate & Gift Taxes
    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
    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
    Uniform Decanting: Coming Soon to a Legislature Near You? Outline: Uniform Decanting: Coming Soon to a Legislature Near You?

    Financial Transactions
    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
    The Global Implications of Corporate Tax Reform: A Practical Guide Slides: The Global Implications of Corporate Tax Reform: A Practical Guide

    Individual & Family Taxation
    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
    A Discussion Regarding Tax Reform Implementation Slides: Tax Reform Implementation
    Litigating an Insurance Case in Tax Court Slides: Litigating Insurance Tax Cases

    Investment Management
    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
    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
    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
    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
    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
    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
    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
    Fundamentals of Tax Litigation: Choice of Forum and Appealing Decisions Slides: Fundamentals of Tax Litigation: Choice of Forum

    Standards of Tax Practice
    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
    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
    Current Developments in Tax Accounting Outline: Current Developments in Tax Accounting
    International Tax Reform Slides: International Tax Reform

    Tax Bridge to Practice
    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
    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
    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
    The Byrd Rule and the Tax Legislative Process Paper: The Byrd Rule and the Tax Cuts and Jobs Act: A Synopsis

    Teaching Taxation
    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
    US Tax Reform Reshapes the Transfer Pricing Landscape Slides: US Tax Reform Reshapes Transfer Pricing Landscape

    Young Lawyers Forum
    Are Some Groups More Equal Than Others? Slides: Are Some Groups More Equal Than Others?