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?