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2009 Midyear Meeting

January 8-10, New Orleans, LA

Thoughtful Insights. Useful Analysis.

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.

2009 Midyear Meeting, New Orleans, LA

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This is not a final listing. Please check back as more materials will be added over the next few weeks.

Administrative Practice

Methods for Resolving Tax Liabilities

Selected Recent Developments in Administrative Practice

Bankruptcy and Insolvency Effects of Examination and Collection

A Penalty Flag on the Field? Reviewing the New IRS Whistleblower Action in the Big Leagues

Panel PowerPoint

Affiliated & Related Corporations

Intercompany Obligations

Current Developments

Banking and Savings Institutions

Capital Presevation/Recycling Techniques for REITS

REIT Amendments Made by the Housing and Economic Recovery Act of 2008

The States Zero in on Captive REITS

Civil & Criminal Tax Penalties

Important Developments on Civil Penalties (Sep. 2008 - Dec. 2008)

Important Developments - Criminal

Information Reporting and Civil Penalties (in a Nutshell)

Panel PowerPoint

Civil Procedure & Practice

When the Shoe is on the Other Foot

Court Procedure & Practice

Summary of Current Developments

Corporate Tax

Recent Section 382 Guidance

Current Developments and What is This Transaction?

Employee Benefits

Lessons from 401(k) Fee Litigation

ATAT & Emerging Issues

Panel PowerPoint - In-Depth Review and Update on the Employee Plans Compliance Resolution System (“EPCRS”)

Frequently Made Errors on Voluntary Compliance Submissions

Practical Lessons from Litigation: Severance Pay and Stock Options

COBRA and Plan-Based Statutes of Limitations – Litigation-Informed Plan Design

Group Health Plan Coverage Litigation

Statute of Limitations Issues Under ERISA

Claims and Appeals Procedures: Best Practices

Responses to Auditors: Current Issues

Executive Compensation Litigation

Recent Health Plan Litigation

Employment Taxes

Background Materials Compiled by the Council On State Taxation (COST)

Energy & Environmental Taxes

Property Determinations Under Code Section 614

Panel PowerPoint - Fuel Tax 101

Oil and Gas Property Determinations

Estate & Gift Taxes

Current Developments in Estate Planning

Closely Held Business Interests and the Trustee''s Duty to Diversify

Planning for the Increasing Costs of Education

Buy-Sell Agreements for the Closely Held Business

Estate Planning for Unmarried Partners

Exempt Organizations

Conversions and Asset Sales: One Company''s Ordeal with State Attorney Generals

Comparison of Private Non-Operating Foundation and Type1 Supporting Organization

The Current Status of Supporting Organizations

Open Issues for Supporting Organizations: Where are We Now?

Fiduciary Income Tax

Choosing Between the Donor-Advised Fund and the Private Foundation for Charitable Giving

Attorney and Fiduciary Liability: Ten Pounds of Duty in a Five Pound Bag

Recent Developments in Fiduciary Income Tax

Financial Transactions

Interest Disallowance Rules in the Current Environment

Foreign Activities of US Taxpayers

Subpart F Contract Manufacturing Regulations

Subchapter-C Principles in the Cross Border Context – What Isn’t Working and What Should be Done About It?

Foreign Lawyers Forum

Panel PowerPoint: U.S. / Canada Treaty 5th Protocol Anti-Hybrid Provision Restrictions and Opportunities

Panel PowerPoint: Recent OECD Work relating to Cross-Border Portfolio Investment

Formation of Tax Policy

The President Elect’s Tax Proposals?

Individual and Family Taxation

Tax Planning for Business Interests in Divorce Settlements

Joint: Closely Held Businesses and Business Cooperatives & Agriculture

Executive Summary of the Uniform Limited Cooperative Association Act

State Comparative Charts of "New" Unincorporated Cooperation Association Statutes

Limited Cooperative Associations: The Presentation

Joint: FAUST, FLF, Transfer Pricing and USAFTT

Panel PowerPoint

Joint: Young Lawyers Forum and Diversity


Low Income Taxpayers

The Impact of Katrina on Southeast Louisiana -A Disaster Unlike Any Other

Partnerships & LLCs

Panel PowerPoints

Panel Materials

Tax Credit Partnerships: Energy Credit Deals

State Tax Treatment of Limited Liability Companies and Limited Liability Partnerships

State Taxation of Partnerships, Limited Liability Companies and their Owners

Plenary Session

Tax Fallout From the Financial Crisis

Real Estate

Planning for Discharge of Indebtedness

Recent Developments Affecting Real Estate and Pass Through Entities

Section 108 Flow Chart: Income From Discharge of Indebtedness

S Corporations

Current Developments Federal Taxation of S Corporations

Distressed S Corporation Fact Pattern Chart

Distressed S Corporation Fact Pattern Hypothetical

S Corporation Tax Update

Debt Workouts of S Corporations

Sales, Exchanges & Basis

"Reverse" and "Parking" Exchanges Outside the "Safe Harbor"

"Reverse" and "Parking" Exchanges Outside the "Safe Harbor" - Waiting for Bartell

Planning Strategies for Loss Recognition and in Debtor-Creditor Transactions

Sales and Exchanges: Current Developments

Section Program: Corporate Tax

Traps for the Unwary in Negotiating Merger and Acquisition Agreements (Panel PowerPoint)

Section Program: Employee Benefits

Examination Management and Appeals

Examination Management and Appeals

Section Program: FAUST, USAFTT and Transfer Pricing

Panel PowerPoint

Section Program: Tax Shelters and Administrative Practice

Panel Paper

Section Program: Teaching Taxation

Recent Developments in Federal Income Taxation

Standards of Tax Practice

Panel Materials

Panel Materials

State and Local Taxes

U.S. State and Local Taxation of International Business Operations

Panel PowerPoints

Contesting the Local Sales/Use Tax Assessment

A Primer on the Removal of State and Local Tax Disputes to Federal Court, and the Roadblocks You May Meet Along the Way

Handling Transactional Tax Compliance and Audits in Local Tax Jurisdictions

Tax Accounting

Research Credit – Recent Developments

Panel Materials

Tax Practice Management

Panel PowerPoint: Section 6694 Update

Teaching Taxation

Federal Estate and Gift Tax Update (October 2007 through November 2008)

Transfer Pricing

Panel PowerPoint

Panel PowerPoint


Panel PowerPoint - Withholding Tax Developments

Panel PowerPoint: Expatriate Games - New Sections 877A and 2801

VAT & Other Consumption Taxes

Taxation of Financial Services