TaxIQ

2013 Midyear Meeting

January 24-26, Orlando, FL

Thoughtful Insights. Useful Analysis.
TaxIQ 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 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

Important Developments Selected Recent Developments in Administrative Practice
Privilege Update: IRS Examinations, IDRs, the Summons Process and the Policy of Restraint Slides: Examining Privilege Issues in the IRS Audit
The Procedural Side of FATCA: Witholding Operations, Refunds and Examinations FATCA Administrative Issues
When You Whistle Where You Work: Hot Topics on Federal Tax Whistleblower Law Slides: When You Whistle Where You Work
When You Whistle Where You Work: Hot Topics on Federal Tax Whistleblower Law Additional Materials

Affiliated & Related Corporations

Current Developments in Consolidated Returns Slides: Current Developments in Consolidated Returns
Net Operating Losses and Consolidated Groups Slides: A Primer on Consolidated Return Basics: NOLs and Consolidated Groups

Bankruptcy & Workouts

Annual Update Business Bankruptcy & Workouts - 2012/2013 Tax Update
Tax Problems of Liquidating Trusts Bankruptcy Liquidating Trusts:  Taxation and Tax Reporting
Tax Problems of Liquidating Trusts Fixed and Contingent Claims in Bankruptcy – Liquidating Trusts and Partnerships
Tough Issues in Bankruptcy-tax and Annual Updates Bankruptcy and Workouts
Tough Issues in Bankruptcy-tax and Annual Updates Eliminating Tax Debt Through Bankruptcy
Tough Issues in Bankruptcy-tax and Annual Updates IRS Collection Statute and Bankruptcy Discharge Time Requirements
Tough Issues in Bankruptcy-tax and Annual Updates Outline: Tough Issues in Bankruptcy-tax and Annual Updates
Tough Issues in Bankruptcy-tax and Annual Updates Survey of 2011 CDP Cases

Banking & Savings Institutions

How the Recent Revisions of Circular 230 Affect Tax Advisors to Financial Institutions Slides: The Proposed circular 230 Regulations – a Move in the Right Direction?
Discussion of Recent Economic Substance and Debt/Equity Cases Slides: Recent Substance over Form & Debt vs. Equity Cases

Capital Recovery & Leasing

Current Developments Report and Update on Pending Guidance Current Developments
Electric Generation Property Repair and Capitalization Principles Utility Industry - Industry Issue Resolution (IIR) Projects
Navigating the Depreciation of Airplanes Slides: Navigating the Depreciation of Airplanes

Civil & Criminal Tax Penalties

Identity Theft: Issues for the Tax Practitioner and the Taxpayer Slides: Tax Refund Fraud and Identity Theft
Limitations and Fraud Allen briefs (from Tax Court)
Limitations and Fraud Panel Outline
Limitations and Fraud Stipulations in Allen
Reports of Subcommittees on Important Developments Important Developments — Criminal
Reports of Subcommittees on Important Developments Important Developments on Civil Penalties September, 2012 through December, 2012 Slides: IRS Investigations and Practices Subcommittee Report
Reports of Subcommittees on Important Developments Subcommittee Report: Legislative & Administrative Developments
So You Want to Be a Tax Controversy Associate? Outline - So You Want to Be a Tax Controversy Associate?

Corporate Tax

“Anti-Non Recognition” and Other “Gotchas.” Slides: Anti Non-Recognition  and Other “Gotcha’s”
Current Developments In Subchapter C Slides: Current Developments Panel
Where Does E&P Go? Slides: Where Does E&P Go?

Court Procedure & Practice

Ethical Concerns in Preparing Witnesses Outline: Ethical Concerns in Preparing Witnesses
Important Developments Slides: Deborah Butler Presentation
Important Developments Summary of Current Developments
Using Alternative Dispute Resolution (ADR) to Resolve Tax Cases Slides: Using Alternative Dispute Resolution (ADR) to Resolve Tax Cases
Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties SLIDES: Collection of the FBAR Penalty
Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties Exhibit A McBride
Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties Exhibit B Williams (4th cir)

Diversity

Safe Zones for LGBT Employees: Legal and Tax Implications Shifting from Outsider to Insider: Promoting Inclusion of LGBTQ Gender Nonconformers in the Legal Profession
Safe Zones for LGBT Employees: Legal and Tax Implications Slides: Gender Identity in the Workplace
Safe Zones for LGBT Employees: Legal and Tax Implications Slides: Safe Zones for LGBT Employees
Safe Zones for LGBT Employees: Legal and Tax Implications Slides: Safe Zones for LGBT Legal and Tax Implications
Safe Zones for LGBT Employees: Legal and Tax Implications Safe Zone Training
Safe Zones for LGBT Employees: Legal and Tax Implications Safe Zone Program Training Manual
Safe Zones for LGBT Employees: Legal and Tax Implications USCODE-2010-title26-subtitleA-chap1-subchapB-partVI-sec162

Employee Benefits

Circular 230 Redux and New Proposed Guidance – Ethical Consideration for the ERISA Attorney Slides: Circular 230 - Affecting Employee Benefits
Employment Tax Issues in Executive Compensation Impact of Section 409A on Executive Employment Arrangements
Employment Tax Issues in Executive Compensation New Medicare 0.9 Percent and 3.8 Percent Taxes: Executive Compensation Year-End Tax Planning
EPCRS Correction and Prototype Plan Issues Revenue Procedure 2013-12: Key Changes to the Employee Plans Compliance Resolution System
EPCRS Correction and Prototype Plan Issues Rev. Proc. 2013-12
EPCRS Correction and Prototype Plan Issues Rev. Proc. 2008-50/2013-12
EPCRS Correction and Prototype Plan Issues Slides: Employee Plans Compliance Resolution System:  Failures And Correction Methods
EPCRS Correction and Prototype Plan Issues Slides: Employee Plans Compliance Resolution System: Revenue Procedure 2013-12
EPCRS Correction and Prototype Plan Issues Correction Methods For 401(k) Failures
Health Care Reform in 2013 and Beyond Code §4980H(a) and (b) Pay or Play Penalties Flowchart
Health Care Reform in 2013 and Beyond Overview of HHS Proposed Regulations Implementing Reinsurance Fees Paid by Carriers and Group Health Plans Under the Affordable Care Act
Health Care Reform in 2013 and Beyond Overview of HHS Proposed Regulations Implementing Reinsurance Fees Paid by Carriers and Group Health Plans Under the Affordable Care Act
Hot Topics Redlined Comparison of EPCRS 2008-50 and EPCRS 2013-12
Hot Topics IRS Proposed Regulations on Employer Shared Responsibility
Hot Topics IRS Issues Proposed Rule on ACA Play or Pay Requirements
Hot Topics IRS Q&As on Affordable Care Act Tax Provisions
The Ins and Outs of Granting Equity to Employees of LLCs and Partnerships Rev. Proc 2001-43
The Ins and Outs of Granting Equity to Employees of LLCs and Partnerships Internal Revenue Bulletin: 2005-24
The Ins and Outs of Granting Equity to Employees of LLCs and Partnerships Revenue Procedure 93-27
The Ins and Outs of Granting Equity to Employees of LLCs and Partnerships Slides: The Ins and Outs of Granting Equity to Employees of LLC and Partnerships

Employee Benefits Subcommittees

Employee Benefits Subcommittee on Defined Benefit Plans
Defined Benefit Plans Update A Window into PBGC’S Practice: Current Issues and Trends
Defined Benefit Plans Update Recent PBGC Regulatory Developments
Employee Benefits Subcommittee on Defined Contribution Plans
Defined Contribution Plans Update American Taxpayer Relief Act of 2012 Excerpts
Defined Contribution Plans Update EBSA News - Employee Benefit Plans in Wake of Hurricane Sandy
Defined Contribution Plans Update IRS Announcement 2012-44 - Hurricane Sandy Relief
Defined Contribution Plans Update IRS Chart of Significant Changes to EPCRS under Rev. Proc. 2013-12
Defined Contribution Plans Update IRS Revenue Procedure 2013-12 - EPCRS
Defined Contribution Plans Update Proposed Amendment to Prohibited Transaction Exemption 2006-06
Defined Contribution Plans Update Outline: Defined Contribution Plans Update
Defined Contribution Plans Update Proposed Amendments to Abandoned Plan Program - Fact Sheet
Defined Contribution Plans Update Proposed Amendments to Abandoned Plan Regulations
Employee Benefits Subcommittee on Distributions
Distributions Update Outline: Distributions Update
Employee Benefits Subcommittee on Employee Benefit Legislation
Legislative Update Legislative Update for September 2012
Legislative Update Major Legislation Affecting Employee Benefit Plans - 1974-2012
Employee Benefits Subcommittee on ESOPs
ESOPs Update Meeting Agenda with case summaries
Employee Benefits Subcommittees on Executive Compensation, Fringe Benefits and Federal Securities Law and Foreign and International Issues
Executive Compensation, Fringe Benefits and Securities Law Update US Taxation of Foreign Pension Plans
Employee Benefits Subcommittee on Fiduciary Responsibility/Plan Investments
Employee Benefits Subcommittee on Foreign and International Issues
Fiduciary Responsibilities Update Fiduciary Responsibility Update
Employee Benefits Subcommittee on Foreign and International Issues
International Update 2012 Global Equity Incentives Survey
International Update Slides: 2012 Global Equity Incentives Survey
International Update Slides: Clawbacks and Compliance Topics in Global Equity Plans
Litigation Update Employee Benefits Litigation Update
Multiple Employers, PEOs and Controlled Groups Update An Introduction To The Controlled Group Rules
Multiple Employers, PEOs and Controlled Groups Update A Multiple Employer Plans (MEPs) Primer
Multiple Employers, PEOs and Controlled Groups Update DOL Has Spoken: What’s Next for Open MEPs?
Multiple Employers, PEOs and Controlled Groups Update IRS Manual 7.11.7
Multiple Employers, PEOs and Controlled Groups Update LRM 86A MEPs
Multiple Employers, PEOs and Controlled Groups Update Sun Capital Partners III
Multiple Employers, PEOs and Controlled Groups Update GAO Report - Federal Agencies Should Collect Data and Coordinate Oversight of Multiple Employer Plans
Multiple Employers, PEOs and Controlled Groups Update Selected Resources
Administrative Practices Update Revenue Procedure 2013-12: Key Changes to the Employee Plans Compliance Resolution System
Administrative Practices Update Form 8950 (draft)
Administrative Practices Update Form 8951 (draft)
Administrative Practices Update Form i8950 (draft)
Administrative Practices Update Rev. Proc. 2013-12
Administrative Practices Update Slides: IRS Determination Letters: Current Status & Issues
Employee Benefits Subcommittee on Mergers and Acquisitions
Mergers & Acquisitions Update Slides: Mergers & Acquisitions Update
Employee Benefits Subcommittee on Multiple Employers, PEOs and Controlled and Affiliated Service Groups
Multiple Employers, PEOs and Controlled Groups Update PBGC v Asahi Tec Corporation
Multiple Employers, PEOs and Controlled Groups Update Agenda for Subcommittee on MEPs PEOs CG & ASG
Multiple Employers, PEOs and Controlled Groups Update Comparison of MEWAs and Open MEPS
Employee Benefits Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices
Administrative Practices Update Slides: Subcommittee on Self-Correction, Determination Letters and Other Administrative Practices
Employee Benefits Subcommittee on Welfare Plan Design, EEOC, FMLA and Leaves Issues and Cafeteria Plans and Reimbursement Accounts
Welfare Benefits Design, EEOC and FMLA Update Health Care Reform Update: Proposed Regulations Regarding Essential Health Benefits, Actuarial Value, and Accreditation Standards
Welfare Benefits Design, EEOC and FMLA Update Examining New Proposed Regulations on Employer Shared Responsibility Payments
Welfare Benefits Design, EEOC and FMLA Update IRS January 2, 2013 Proposed Regulations: IRC §4980H Guidance on Determining Status as an “Applicable Large Employer” and Resulting Exposure to the Employer Shared Responsibility “Assessable Payments”

Employment Taxes

Employment Tax Issues in Executive Compensation Slides: Employment Tax Issues in Executive Compensation
Employment Tax Issues in Executive Compensation Impact of Section 409A on Executive Employment Arrangements
Employment Tax Issues in Executive Compensation Panel Outline
Employment Tax Issues in Executive Compensation New Medicare 0.9 Percent and 3.8 Percent Taxes
Federal Update Outline: Federal Update
On Hold: What to Tell Your Clients While Waiting for a Final Disposition inthe Quality Stores Case United States v. Quality Stores, et al.
One if by Air; Two if by Sea One if by Air; Two if by Sea: U.S. Employment Tax Reporting and Withholding Obligations in Connection with Nonresident Aliens Performing Services in U.S. Airports, Seaports, or in U.S. Territorial Waters, as Crew Members of an Airplane, Cruise Ship, Fishing or Cargo Vessel, or on the Outer Continental Shelf
One if by Air; Two if by Sea TAM 201014051
The National Taxpayer Advocate Summary : The Diminishing Role of the Revenue Officer Has Been Detrimental to the Overall Effectiveness of IRS Collection Operations
The National Taxpayer Advocate Summary: Early Intervention, Offers in Compromise, and Proactive Outreach Can Help Victims of Failed Payroll Service Providers and Increase Employment Tax Compliance
The National Taxpayer Advocate The Diminishing Role of the Revenue Officer Has Been Detrimental to the Overall Effectiveness of IRS Collection Operations
The National Taxpayer Advocate Early Intervention, Offers in Compromise, and Proactive Outreach Can Help Victims of Failed Payroll Service Providers and Increase Employment Tax Compliance

Energy & Environmental Taxes

The Nuclear Reactor Tax Credit, Post-Fukushima Slides: The Nuclear Reactor Tax Credit, Post-Fukushima
Renewable Energy Tax and Grant Updates Slides: Renewable Energy Tax  and Grant Updates

Estate & Gift Taxes

Current Developments Current Developments in Estate Planning
Displaying Value: Special Issues in Valuing Art for Estate, Gift and Income Tax Reporting Art Is Long, Life Is Short: Estate Planning For the Artist and the Art Collector
Home Sweet Home: Planning Issues for Residences Home Sweet Home: Planning Issues for Residences

Exempt Organizations

Circular 230 Redux: What the Changes Mean for EO Practitioners Slides: Circular 230 Overview:  Proposed Revisions
Circular 230 Redux: What the Changes Mean for EO Practitioners Circular 230 Comment Matrix
News from the IRS and Treasury Outline of Current Regulatory and Other Developments
Non-Exempt Nonprofits – Not an Oxymoron Materials Index
Non-Exempt Nonprofits – Not an Oxymoron Taxability (Other than UBTI) of Exempt/Formerly Exempt/Benefit Corporations
Non-Exempt Nonprofits – Not an Oxymoron Consequences of Revocation:  Issues in Calculating “Taxable Income” When Jurisdiction over Entity Moves Out of TE/GE-Exempt Organization Division
Non-Exempt Nonprofits – Not an Oxymoron Chart -- Legal Treatment Of Nonprofit Organizations
Non-Exempt Nonprofits – Not an Oxymoron Scenarios for Discussion
Non-Exempt Nonprofits – Not an Oxymoron Taxation of Revoked Tax-Exempt Organizations: The Synanon Case
Non-Exempt Nonprofits – Not an Oxymoron Internal Revenue Manual – 4.75.31 Conversion of Returns Upon Revocation of Exemption
Non-Exempt Nonprofits – Not an Oxymoron Gen. Couns. Mem. 39813
Non-Exempt Nonprofits – Not an Oxymoron Slides
Single Member LLCs and Exempt Organizations Use of Single Member Limited Liability Companies by Tax-Exempt Organizations
Text It; Tweet It; Blog It; Delete It – Social Media and Exempt Organizations Social Media Outline with attachments

Fiduciary Income Tax

Post-Mortem Income Tax Issues: A Fiduciary’s Handbook Post-Mortem Income Tax Issues
Post-Mortem Income Tax Issues: A Fiduciary’s Handbook Recent Updates: Overview of the 3.8% Surtax for Trust and Estates
Recent Developments Recent Developments in Fiduciary Income Tax
Turbocharging the Estate Plan Turbocharging the Estate Plan
What Estate Planners Need to Know about Marital Law A Prenuptial Agreement Primer for the Estate Planning Attorney
What Estate Planners Need to Know about Marital Law Slides: A Prenuptial Agreement Primer for the Estate Planning Attorney 

Financial Transactions

Fear and Loathing in Section 1092 Slides: Fear and Loathing (and Loving) in Section 1092: The use of identified mixed straddles and other techniques to accelerate unrealized gains
Recent Developments and Current Issues Slides: Current Developments and Shop Talk
Taxing Derivatives: Do Look-through Rules Work? Slides: Taxing Derivatives: Do Deemed Ownership Rules Work?
Outbound Stock and Asset Transfers Slides: Foreign Activities of U.S. Taxpayers "Outbound Stock and Asset Transfers"

Foreign Activities of US Taxpayers

Technical Aspects of International Tax Reform Proposals Slides: Technical Aspects of International Reform Proposals

Foreign Lawyers Forum

FATCA and the Intergovernmental Agreements – The View From the Other Side FATCA and Intergovernmental Agreements – The View from the Other Side

Indian Tribal Tax

Exploring The Unique Environment of The Tribal-IRS Relationship Slides: The Tribal-IRS Relationship
Exploring The Unique Environment of The Tribal-IRS Relationship CRS Reviews Indian Tribal Governmental Tax Status Act
Exploring The Unique Environment of The Tribal-IRS Relationship Internal Revenue Manual - 22.41.1 Indian Tribal Governments Outreach
Exploring The Unique Environment of The Tribal-IRS Relationship Internal Revenue Manual - 4.86.1 Indian Tribal Governments Administration
Exploring The Unique Environment of The Tribal-IRS Relationship Overview of Federal Tax Provisions Relating to Native American Tribes and Their Members
Exploring The Unique Environment of The Tribal-IRS Relationship Rev Rul 67-284
Exploring The Unique Environment of The Tribal-IRS Relationship Rev Rul 94-16
Exploring The Unique Environment of The Tribal-IRS Relationship Rev Rul 94-81
IRS Enforcement in Indian Country Streitz Indian Taxation Presentation
IRS Enforcement in Indian Country Attachment A. IRS Protocols for Tribal Contacts
IRS Enforcement in Indian Country Attachment B. Prior Treasury Department Consultation Policy
IRS Enforcement in Indian Country Attachment C. Current Treasury Department Consultation Process
IRS Enforcement in Indian Country Attachment D. Draft Treasury Department Tribal Consultation Progress Report
IRS Enforcement in Indian Country Attachment E. IRS Notice 2012-75
IRS Enforcement in Indian Country Attachment F. NCAI Requests for Consultation on Trust Per Capita Payments Issue
IRS Enforcement in Indian Country Attachment G. IRS Notice 12-60
IRS Enforcement in Indian Country Attachment H. NCAI Follow Up Letter on Trust Per Capita Payments Issue
IRS Enforcement in Indian Country Attachment I. Miccosukee Decisions

Insurance Companies

Reports From the Frontier Between Insurance and Employee Benefits (Or, Don’t Shoot the Messenger!) Summary of Lifetime Income Guidance Released by Treasury and IRS
Unique Financial Products Issues that Affect Issuers of Variable Annuities Slides: Hedging of Guaranteed Benefits on Variable Annuities
Waiting to Exhale: Current Developments From the IRS and Treasury, Including the Treatment of Extracontractual Obligations Slides: Current Developments: Waiting To Exhale

Investment Management

Current Developments Regarding Tax Issues for Regulated Investment Companies 1 - Slides: RIC Modernization Act 2010 Defining the “Reasonable Cause and Not Willful Neglect” Standard
Current Developments Regarding Tax Issues for Regulated Investment Companies 2 - RIC Modernization Act 2010 Reasonable Cause Exception Authorities
Current Developments Regarding Tax Issues for Regulated Investment Companies 3 - Slides: Lack of Integration of Sub M and Excise Tax
Current Developments Regarding Tax Issues for Regulated Investment Companies 4 - Lack of Integration of Sub M and Excise Tax Authorities
Current Developments Regarding Tax Issues for Regulated Investment Companies 5 - Slides: RICs and Declarations of Spillback Dividends: Special Issues
Current Developments Regarding Tax Issues for Regulated Investment Companies 6 - RICs and Declarations of Spillback Dividends: Special Issues Authorities
Current Developments Regarding Tax Issues for Regulated Investment Companies 7 - Slides: ICI Updates on U.S. and International Tax Issues
Current Developments Regarding Tax Issues for Regulated Investment Companies 8 - ICI Updates on U.S. and International Tax Issues Authorities
Structuring and Operational Issues for Venture Capital Funds Slides: Structuring and Operational Issues for Venture Capital Funds
Structuring and Planning Issues for MLP Investments Recent Relevant IRS Private Letter Rulings for Master Limited Partnerships
Structuring and Planning Issues for MLP Investments Slides: Structuring and Planning Issues for MLP Investments

JOINT: Closely Held Businesses and Bankruptcy & Workouts

The Exit Strategy from Retirement Accounts for the Financially Challenged: The IRS Collection Process and Bankruptcy Protection Protection from Creditors and the IRS: Misconceptions, Foot Faults and Some Suggestions
The Exit Strategy from Retirement Accounts for the Financially Challenged: The IRS Collection Process and Bankruptcy Protection USA v. Cooper
IRS Collection & Bankruptcy Alternatives IRS Collection & Bankruptcy Alternatives
Tales from the Crypt: Dealing with a Decedent’s Tax Fraud Materials - Tales from the Crypt: Dealing with a Decedent's Tax Fraud

JOINT: Closely Held Businesses Committee and Civil & Criminal Tax Penalties

The ABCs of Summons Enforcement, Including Recent Developments in the Area of 5th Amendment Issues for Closely Held Businesses Outline: Use, Enforcement, and Defense of IRS Summons
The ABCs of Summons Enforcement, Including Recent Developments in the Area of 5th Amendment Issues for Closely Held Businesses Slides: Use, Enforcement, and Defense of IRS Summons
Update on LB&I Global High Wealth Group Examinations Slides: Update On Global High Wealth Industry Group Examinations

JOINT: Foreign Activities of US Taxpayers, Foreign Lawyers Forum, Transfer Pricing and US Activities of Foreigners and Tax Treaties

Joint Current International Developments Panel DRAFT SLIDES: Joint Current International Developments Panel

JOINT: Individual & Family Taxation and Pro Bono & Tax Clinics

Hot Practice Tips for Representing an Individual Taxpayer Before and During an IRS Examination Slides: Hot Practice Tips for Representing an Individual Taxpayer Before and During an IRS Examination
Proposed Changes to the Guidelines for Innocent Spouse Relief Comments on Proposed Changes to the Guidelines for Innocent Spouse Relief in Revenue Procedure 2003-61
Proposed Changes to the Guidelines for Innocent Spouse Relief Outline: Proposed Changes to the Guidelines for Innocent Spouse Relief
Vanishing Time Limits for Equitable Relief Vanishing Time Limits for Equitable Relief
Vanishing Time Limits for Equitable Relief Hypotheticals
Vanishing Time Limits for Equitable Relief Additional Materials

JOINT: Individual & Family Taxation, Standards of Tax Practice and Tax Practice Management

Practical and Ethical Strategies in Representing Couples Panel Materials
Practical and Ethical Strategies in Representing Couples Additional Materials

JOINT: Teaching Taxation and Tax Policy & Simplification

Panel Discussion of We’re Not Broke Slides: What Tax Professionals should understand about Transfer Pricing
Panel Discussion of We’re Not Broke The “Price of Offshore” Revisited
Panel Discussion of We’re Not Broke Towards Unitary Taxation of Transnational Corporations
Panel Discussion of We’re Not Broke Utopian Visions toward a Grand Unified Global Income Tax
The Prospects for Tax Reform in President Obama’s Second Term Tax Reform Today
The Prospects for Tax Reform in President Obama’s Second Term Slides: Tax Reform - Nellen
The Prospects for Tax Reform in President Obama’s Second Term Slides: Tax Reform: Will It Happen?
The Prospects for Tax Reform in President Obama’s Second Term Slides: Tax Reform
The Prospects for Tax Reform in President Obama’s Second Term Slides: Prospects for Tax Reform  in Pres. Obama’s 2nd Term
The Prospects for Tax Reform in President Obama’s Second Term The Time for Tax Reform is Now
The Prospects for Tax Reform in President Obama’s Second Term The Complexity of the Tax Code

Partnerships & LLCs Clinics

Dipping our Toes in Foreign Waters Slides: Dipping Our Toes in Foreign Waters: Outbound International Partnership Issues
Dipping our Toes in Foreign Waters The Schizophrenic Partnership: IRS Issues Notice 2010-41 Addressing Partnership Blocker to Subpart F Inclusions
Dipping our Toes in Foreign Waters Notice 2009-7: IRS Designates “Partnership Blocker” to Subpart F Inclusions as a New Transaction of Interest
Is Your Partner Under the Boardwalk? Slides: Is Your Partner Under the Boardwalk?
Fun with a "D": Management Fee Waivers and Clawback Issues for Private Equity and Hedge Funds Slides: Fun with a “D”: Management Fee Waivers and Clawback Issues for Private Equity and Hedge Funds

Pro Bono & Tax Clinics

Issues Involving Cancellation of Debt Income Slides: Issues involving Cancellation of Debt Income
Presentation of Annual Report to Congress Outline: Report from the National Taxpayer Advocate on her 2012 Annual Report to Congress
Tax Issues in Immigration Law Slides: New ITIN rules THE IRS response to TIGTA reports
Tax Issues in Immigration Law Slides: Taxing Immigrants:  A Primer
Tax Issues in Immigration Law Case Studies on Immigration and Tax
Tax Issues in Immigration Law Community Interpreter Internship Syllabus
Tax Issues in Immigration Law Additional Handouts
Tax Issues in Immigration Law Slides: Strategies for Delivering Tax Services to Rural Migrants

Real Estate

Hot Topics Slides: Hot Topics
New Guidance Regarding Impact of State Law on Classification of Section 1031 Exchange Property IRS Muddies the Like-Kind Waters in Guidance Considering State Law Classification
New Guidance Regarding Impact of State Law on Classification of Section 1031 Exchange Property Slides: State Law Characterization and Section 1031
Noncore REITs and Other Hot REIT Issues Slides: Developing Trends in REIT Conversions and Related Issues
Update on the 3.8% Tax on Net Investment Income and its Impact on Real Estate Section 1411 Proposed Regulations
at to Expect in the Post-Election Environment Slides: Tax Legislative Outlook

S Corporations

Recent Developments in State and Local Taxation of S Corporations Slides: Recent Developments in State and Local Taxation of S Corporations
S Corporation Compensation Reclassification Risks Materials: S Corporation Compensation Reclassification Risks
S Corporation Compensation Reclassification Risks Slides: S Corporation Compensation Reclassification Risks
Subchapter S Valuation: To Tax Effect, or Not to Tax Effect, Is Not Really the Question Paper: Sub S Valuation: To Tax Effect, Or Not To Tax Effect, Is Not Really The Question
Subchapter S Valuation: To Tax Effect, or Not to Tax Effect, Is Not Really the Question Slides: Sub S Valuation: To Tax Effect, Or Not To Tax Effect, Is Not Really The Question
The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations Slides: The Proposed Section 1411 “Medicare Tax” Regulations and S Corporations

Sales, Exchanges & Basis

Current Developments in Sales, Exchanges and Basis, Including Sections 1031 & 1033 Current Non-Section 1031 Developments
Current Developments in Sales, Exchanges and Basis, Including Sections 1031 & 1033 IRC § 1031/1033 Current Developments
Everything You Need to Know About the Tax Issues in National Federation of Independent Business v. Sebelius Course Materials
Ponzi Scheme Update: Tax Treatment of Clawbacks and Other Items Before It's Too Late, Reconsidering the IRS Relief for Madoff Losses
Ponzi Scheme Update: Tax Treatment of Clawbacks and Other Items Slides: Ponzi Scheme Update:  Tax Treatment of Clawbacks and Other Items
Tax Issues Involving Flawed Securitizations Slides: Tax Disqualification Issues Facing REMICs

Section Program

Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation Federal Estate, Gift and Generation-Skipping Transfer Tax Update
Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation Recent Developments in Federal Income Taxation
Healthcare Reform Update 2013 Medicare Taxes For Investors, Business Entities & Their Owners, Trusts & Estates - Outline 1
Healthcare Reform Update Proposed IRS Regulations On PPACA Shared Responsibility (Employer Mandate) Provisions
Healthcare Reform Update 4980H proposed regulation
Healthcare Reform Update Add'l Medicare Tax Proposed Reg
Healthcare Reform Update Net Investment Income Proposed Regs
Healthcare Reform Update Net Investment Income Tax FAQ
Healthcare Reform Update PCORTF fee reg
Healthcare Reform Update Questions and Answers for the Additional Medicare Tax
Healthcare Reform Update Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act

Standards of Tax Practice

An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies Panel Materials - An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies
An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies Slides - An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies
Ethical Issues in Federal Tax Practice – The Government Perspective Slides: Ethical Issues in Federal Tax Practice – The Government Perspective
The Proposed (or Final) Amendments to Circular 230 Comments on Proposed Reg- 138367-06 Relating to Practice Before the Internal Revenue Service
The Proposed (or Final) Amendments to Circular 230 The Proposed Amendments to Circular 230: How They Would Affect OPR’s Practice Standards Oversight Activity, What Additional Guidance and Requirements They Would Establish and How Practitioners Should Respond
The Proposed (or Final) Amendments to Circular 230 IRS Office of Professional Responsibility Disbars Return Preparer Accused of Filing False Returns
The Proposed (or Final) Amendments to Circular 230 Motion for Decision by Default Denied as Moot; Motion for Summary Adjudication Granted In Part; Order Imposing Sanction of  Disbarment
The Proposed (or Final) Amendments to Circular 230 IRS Statement on Court Ruling Related to Return Preparers
The Proposed (or Final) Amendments to Circular 230 Loving
The Proposed (or Final) Amendments to Circular 230 Loving Stay Motion

State & Local Taxes

Current Trends in Economic Nexus for State Income Taxes Slides: Current Trends in Economic Nexus for State Income Taxes
Is the Multistate Tax Compact Apportionment Election Still Available? State Multistate Tax Compact Enactments - Articles III.1 and IV
Is the Multistate Tax Compact Apportionment Election Still Available? Is the Multistate Tax Compact Apportionment Election Still Available?
Is the Multistate Tax Compact Apportionment Election Still Available? Model Multistate Tax Compact
State and Local Taxation of the Mobile Workforce Appendix
State and Local Taxation of the Mobile Workforce Slides: The Stalled Mobile Workforce Project
State Tax Administration in Theory and in Practice: Evaluating Transparency in State Tax Administration Measuring Transparency In State Tax Administration
State Tax Administration in Theory and in Practice: Evaluating Transparency in State Tax Administration Transparency in State Taxation — Part I: Discretionary Authority
State Tax Administration in Theory and in Practice: Evaluating Transparency in State Tax Administration Transparency in State Taxation, Part 2: Legislative Process and Letter Rulings

Tax Accounting

Current Developments Current Developments Materials
Hot Topics in Healthcare Slides: Hot Topics in Healthcare
Tangible Property Regulations Update Slides: Tangible Property Regulations Update

Tax Exempt Financing

New Rules for Tax-Exempt Financing Tax Lawyers Under Circular 230; Rules of Ethics Applicable to Opinions Given by Tax-Exempt Financing Tax Lawyers Circular 230 and Ethics Discussion Outline
New Rules for Tax-Exempt Financing Tax Lawyers Under Circular 230; Rules of Ethics Applicable to Opinions Given by Tax-Exempt Financing Tax Lawyers Excerpts from Circular 230
New Rules for Tax-Exempt Financing Tax Lawyers Under Circular 230; Rules of Ethics Applicable to Opinions Given by Tax-Exempt Financing Tax Lawyers Proposed Circular 230 Operative Sections
New Rules for Tax-Exempt Financing Tax Lawyers Under Circular 230; Rules of Ethics Applicable to Opinions Given by Tax-Exempt Financing Tax Lawyers ABA Comments to Circular 230 Proposal
Treasury and Internal Revenue Service Update Treasury and IRS Updates Panel
Will the Historical Approach of Exempting Interest on Municipal Bonds be Radically Changed by the New Congress? Outline For Remarks on Current Proposals Affecting Tax Exempt Bonds

Transfer Pricing

Planning for Intangible Property Migration in an Uncertain Environment Slides: Planning for Intangible Property Migration in an Uncertain Environment

US Activities of Foreigners & Tax Treaties

Inbound Mergers and Acquisitions: Recent Trends and Considerations Slides: Inbound Mergers & Acquisitions: Recent Trends & Considerations 
Understanding Tax Issues for Foreign Persons Investing in US Real Estate Slides: Foreign Persons Investing in U.S. Real Estate