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2011 Midyear Meeting

January 20-22, Boca Raton, FL

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.

2011 Midyear Meeting Boca Raton, FL

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Important Developments

Administrative Practice

Payments to Foreign Persons: Enforcement of Reporting and Withholding Obligations

Regulation Validity/Judicial Deference

Schedule UTP, Privilege and Tax Risk Management: Preserving Privilege While Satisfying Tax Compliance

Banking & Savings Institutions

Does Dodd-Frank Have Tax Implications Too?

Innovation in Tier 1 Capital

The Good, The Bad and the UTP: Selected Recent Developments

Bankruptcy & Workouts


Capital Recovery & Leasing

Current Developments Report and Update on Pending Guidance

Section 467 issues

Leasing Transactions after Codification of Economic Substance

Civil & Criminal Tax Penalties

Smokin’ Hot Issues in IRS Enforcement

The Tax Professional as the Target Du Jour in Criminal Tax Investigations and Civil Promoter Penalty Audits

Foreign Bank Account Redux: International Money Laundering and Representation Issues Arising Out of Offshore Accounts

Reports of Subcommittees on Important Developments

Closely Held Businesses

Practical, Psychological and Ethical Issues in Representing the Family Business

Giving Away the Store: A Primer on Business Succession Planning and Post-Mortem Financing of Tax Liabilities of Estates Holding Closely Held Business Interests

Corporate Tax

The Section 351(e) and Section 368(a)(2)(F) Investment Company Rules

Recent Developments in Corporate Taxation

Court Procedure and Practice

Update From the Office of Chief Counsel

Update From the Tax Court

The New Application of Transferee Liability

Effective Use of Experts in the Courtroom

Employee Benefits

Hot Employee Benefits Topics

Implementing Health Care Reform. Part II

Pension Plan Update

Target Date Retirement Funds: Fiduciary Best Practices

Fiduciary Update: Investment Advice and Participant Fee Disclosure Issues

Pension Plan Update

Dodd-Frank Legislation

Employee Benefits ESOP, Fiduciary Responsibility/ Plan Investments and Litigation Subcommittees

Employee Benefits Litigation Update

Employee Benefits Subcommittee

Employee Benefits Defined Contribution Plans Update

Employee Benefits Legislative Update

Employee Benefits EEOC, FMLA and Military Leave Update

Employee Benefits Subcommittee on Controlled Groups, Affiliated Service Groups and Employee Status

Employee Benefits Controlled Groups and Employee Status Update

Employee Benefits Subcommittee on Defined Benefit Plans

Employee Benefits Defined Benefit Plans Update

Employee Benefits Subcommittee on Distributions

Employee Benefits Distributions Update

Employee Benefits Subcommittee on ESOPs

Employee Benefits ESOP Update

Employee Benefits Subcommittee on Exempt Organization and Governmental Plans

Employee Benefits Government and Tax Exempt Plans Update

Employee Benefits Subcommittee on Foreign and International Issues

Employee Benefits International Update

Employee Benefits Subcommittee on Mergers & Acquisitions

Employee Benefits Mergers & Acquisitions Update

Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices

Employee Benefits Administrative Practices Update

Employee Benefits Subcommittees on Welfare Plan Design and Funding, Cafeteria Plans and Reimbursement Accounts and HIPAA, COBRA & State Insurance Regulation of Welfare Plans

Employee Benefits Welfare Benefits Design, Funding and Regulation Update

Employment Taxes

Advanced Employment Tax Audit Techniques, Part II of III

Federal Update

State Employment Tax Update

Energy & Environmental Taxes

Energy and Environmental Excise Taxes

Dangers Relating to an Endangered Species Deduction

Estate & Gift Taxes

Current Developments

Moving Forward (2 Years at a Time) With Estate Planning Under the 2010 Act

Split Dollar Arrangements Revisited

Section 2701: A Trap for the Unwary

Tax Planning for Unmarried Couples

Exempt Organizations

Employment Tax Issues in EO Audits

Update on Executive Compensation and Intermediate Sanctions

Give It Back: Donor Fraud, Bankruptcy, Remorse or Mistake

Employment Tax Issues in EO Audits

What Do We Do Now – The Aftermath of Revocation of Tax-Exempt Status

Exploring the Implications of Recent UBIT Cases

Fiduciary Income Tax

Section 1022 - Carryover Basis: A Discredited Concept in Estate Planning

What's Yours is Mine and What's Mine is Mine: Grantor Trust Sections 673 and 676

Power to Adjust and Total-Return Unitrust Regimes – What Every Trustee and Advisor Should Know About State Developments, Minimizing Tax and Investment Dilemmas, Reducing Litigation Exposure and More

Recent Developments

Financial Transactions

Current Developments

Securitization in a Financially Distressed World

Bad Debt Deductions: Advanced Topics

Foreign Activities of US Taxpayers

International Outbound Reporting Panel

Foreign Tax Credit Panel

Foreign Lawyers Forum

European Holding Company Locations

Developments in Brazil and Mexico

Individual & Family Taxation

The Greatest Wealth is Health: Tax Provisions of the Patient Protection and Affordable Care Act

Elder Law Taxation - A Changing of the Guard and a Need for Reformation

Insurance Companies

Partial Annuitization Legislation and Other Recent Tax Developments Affecting Insurance Companies and Products

Proposed Regulations on Series LLCs and Cell Companies – Next Steps

The Tax Regime for Health Insurance and Health Insurers – Perspectives After Health Care Reform

Investment Management

Withholding on US Equity Swaps under the HIRE Act

FATCA Issues

Mutual Fund Mergers: Tax Update

Joint: Closely Held Businesses and Bankruptcy & Workouts

The Federal Tax Lien

A Primer on Nominee Liens and the Foreclosure of the Federal Tax Lien

Treatment of the Secured Tax Claim in Bankruptcy

Joint: Estate & Gift Taxes and Fiduciary Income Taxes


Joint: Estate & Gift Taxes and Fiduciary Income Taxes Young Lawyers Subcommittee

Use of Debt Instruments in Estate Planning

Joint: FAUST, FLF, Transfer Pricing & USAFTT

Joint International Developments

Joint: Low Income Taxpayer and Pro Bono

Filing a refund claim and a refund suit

Joint: Tax Policy & Simplification and State and Local Taxes

So You Think You Can Dance: Coordinating Federal and State Tax Policy

Joint: Tax Practice Management & Young Lawyers Forum

A Panel Discussion on the Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010

Joint: Young Lawyers Forum & Diversity

To Recognize Or Not To Recognize Gain or Loss On Corporate Formation - That is the question

Low Income Taxpayers

Highlights from the National Taxpayer Advocate’s Annual Report

IRS Collection Law and Policy

Partnerships & LLCs

Hot Topics in Partnerships

Installment Sales in Partnership Transactions

Transfers of Partial Interests in Partnerships:  Is it Really That Complicated?  

Pro Bono

Tax Counseling for the Exploding Population of Elderly

Real Estate

What Does it Mean To Be “Encumbered By” Debt?

Structuring Considerations in Light of Canal

Legislative Update and other Real Estate Hot Topics

Like-kind Exchange Issues in a Struggling Economy

S Corporations

Important Developments

The Impact of the New Health Care Bills on Closely Held Businesses

Terminations of S Elections

Sales, Exchanges & Basis

Like-Kind Replacement Property in a Depressed Market

Back to Basics: Safe Harbor Reverse Exchanges After Ten Years

Non-§1031 Current Developments

Economic Substance 2.0

Section 1031 Developments

Installment Sale Acceleration and Unwinding Installment Sales –What Works and What Doesn't?

Section Program: Insurance Companies

Specialized Uses of Insurance and Transactions to Manage Risk – The Need for Careful Planning

Section Program: Tax Exempt Financing and Exempt Organizations Committee

Practical Approaches to Implement Post Issuance Compliance after Issuance of Tax-Exempt or Direct Pay Subsidy Bonds

Section Program: Teaching Taxation

Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation

Standards of Tax Practice

What if Uncle Jim is Under Audit, or Your Client Wants to Give You a Porsche? Ethical Issues when there is a Personal Connection with a Client

Ethical Issues in Federal Tax Practice – The Government Perspective

Young Lawyers Address Ethical Issues Arising in Day To Day Practice

State & Local Taxes

We Are a Non-Profit, So We Don't Have to Pay Any State and Local Taxes. Right?

The ABA Model Tax Tribunal Act and the Practical Aspects of Lobbying Model Legislation in Your State

Series LLCs. No, It Is Not a New TV Series

Pyrrhic Victories in State Taxation

Tax Accounting

Accounting Method Changes – Current and Future State

Legislative Update

Recent Developments in Tax Accounting Methods

Accrual of Bonus Payments

Tax Exempt Financing

Legislative Developments and Tax Policy

Legal Issues Related to the Paid Preparer Requirements for Forms 8038

IRS and Department of Treasury Update

Tax Policy & Simplification

Options for Corporate Tax Reform in 2011

Teaching Taxation

Transfer Pricing

OECD Transfer Pricing Developments

Current Advance Pricing Agreement Program Developments

US Activities of Foreigners & Tax Treaties

Treaty Overrides including FATCA's Expansive Reach; Grandfathered Obligations & Latest News

US Activities of Foreigners & Tax Treaties

Planning for Mobile Executives and Business Owners Relocating to the US

US Activities of Foreigners & Tax Treaties

Treaty Overrides including FATCA's Expansive Reach; Grandfathered Obligations & Latest News