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2014 Midyear Meeting

January 23-25, Phoenix, AZ

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.

Materials by Committee

Administrative Practice

Appeals: New Initiatives

LB&I's New IDR Enforcement Process

Affiliated & Related Corporations

Current Developments in Consolidated Returns

Exploring the Intersection of the Federal Consolidated Return Rules and State Tax

Banking & Savings Institutions

Advising Banks and Savings Institutions in 2014

Basel III and deferred tax assets: there's no such thing as a "mere timing difference"

Final and Proposed Section 871(m) Regulations & FATCA Update

Bankruptcy & Workouts

Dealing with State Tax Authorities in Bankruptcy

OPR: The IRS Collection Process and Bankruptcy Tax Issues

Section 336(e) and Bankruptcy Restructuring

Capital Recovery & Leasing

Current Developments Report and Update on Pending Guidance

Experimenting with the Definition of a Prototype: A look at the Proposed Section 174 Regulations

Tangible Property Regulations Update – Transition Guidance Discussion, FAQs, and an Update on the Proposed Regulations

True Lease Analysis – Lease vs. Sale/Financing

Civil & Criminal Tax Penalties

Oil and Water: Mixing the Ambiguous Economic Substance Doctrine with the Onerous Economic Substance Penalty

Reports of Subcommittees on Important Developments

Trends in Criminal Tax Enforcement

US Department of Justice, Tax Division Update

Closely Held Business

Collection Issues Surrounding the BSA under Title 26 and Title 31

Criminal Aspects of the Bank Secrecy Act

Entity Selection and Corporate Governance for Closely-Held Businesses

The Civil Aspects of the Bank Secrecy Act and its Impact on Closely Held Businesses

The Taxation of the Purchase and Sale of Closely-Held Businesses and Professional Practices

Corporate Tax

C Corporation-to-REIT Conversions

Corporate Tax Issues in Private Equity Transactions

Court Procedure & Practice

Ethical Issues Arising from Conflicts of Interest in Litigation

Hot Topics in Captive Insurance and Risk Pooling Arrangements

Important Developments: Recent Tax Litigation and Controversy Updates, including Supreme Court Decision in United States v. Woods

Reaching Agreement - Settling Tax Cases in Litigation

Step One of All Tax Litigation: Burden of Proof


Post-Windsor Decision Health and Retirement Plans Guidance from Treasury and IRS

Providing Pro Bono Legal Services. Our Ethical Obligation to the Profession

Tax Implications of Immigration Cases

Employee Benefits

Administrative Practices Update

Benefit Plans and Private Equity Funds: Problems at the Intersection

Continued Aftermath of the Supreme Court’s DOMA Decision

Defined Benefit Plans Update

Defined Contribution Plans Update

Distributions Update

ESOP Update

Executive Compensation, Fringe Benefits & Federal Securities Law Update

Hot Topics

Legislative Update

Litigation Update

Managing Pension Plan Liabilities: De-Risking and Shared Risk Strategies

Mergers & Acquisitions Update

Multinational Employee Benefits & Compensation Issues

Multiple Employers, PEOs and Controlled Groups Update

Pay Ratio Disclosures for the Proxy Season

Welfare Plan and EEOC, FMLA and Leaves Issues Update

Employment Taxes

Employment Taxes On Tipped Employees: Navigating Tip Credits, Tip Reporting and Service Charges

Federal Update

Quality Stores—The Final Countdown

Tax Controversy: How will the IRS's New IDR Enforcement Policies Impact Employment Tax Examinations?

Energy & Environmental Taxes

Hot Topics In the Energy Industry

Estate & Gift Taxes

Audit Proofing Family Limited Partnerships

Captive Insurance Companies and the Closely Held Business

Current Developments

Self-Settled Asset Protection Trusts

Estate & Gift Taxes and Fiduciary Income Tax

Administering Unusual Assets with Purpose Trusts

Exempt Organizations

Earmarking -- Substance and Form

Exempt Organizations and Employment Taxes

Hot Topics in UBIT

News from the IRS and Treasury

Small Charities -- Problems and Solutions

Fiduciary Income Tax

Current Developments

Income and Estate Tax Aspects of Joint Trusts in Community Property and Common Law Jurisdictions

Residency and Domicile for State Income Tax and Transfer Tax Purposes

Financial Transactions

Bitcoin and Other Virtual Currencies: What are They, and How are they Taxed?

Section 871(m) Update

Foreign Activities of US Taxpayers

Currency Issues of Controlled Foreign Corporations, including Treasury Centers

Investments in United States Property under Section 956 Developments and Unresolved Issues

Joint Current Developments: FAUST, FLF, Transfer Pricing and USAFTT

Foreign Lawyers Forum

Current International IP tax issues– BEPS, patent boxes and more

Redomiciliations, cross-border acquisitions and holding company regime

Indian Tribal Tax

Federal Indian Law and Policy, The Nuts & Bolts

State and Tribal Taxing Jurisdictions, A Complicated Relationship

Individual & Family Taxation

Presentation of Annual Report to Congress

Return Preparer Review after Loving and Under the PAC IRS Review Process

Insurance Companies

Information Reporting on Life Insurance Products

International Developments Affecting Insurers

Recent Developments Affecting Insurers and their Policyholders

Investment Management

Selected Tax Issues Regarding Operational Aspects of Private Investment Funds

The Intersection of Private REITs and Partnerships and Other Issues Related to the Formation and Operation of Private REITs

The Structure Games (Pooled Investment Entity Edition)

Partnerships & LLCs

Considering Retirement in Arizona? Payments to Retiring Partners under Section 736

Hot Topics in Partnership Taxation

Is Private Equity Engaged in the Conduct of a Trade or Business?

Prickliest Provisions in a Partnership Agreement: Allocations

Pro Bono & Tax Clinics

Eliminating Errors and Penalties in Tax Return Preparation

National Taxpayer Advocate’s Annual Report to Congress

The Qualified Offer Rule & Attorney Fees: Where Do We Stand?

Real Estate

Compensation or Capital Gain? An Earn-Out Primer

Controlling REIT Spin-Offs

So What if We’re Related?

When Do Options Transfer Tax Ownership?

S Corporations

Current Developments

Section 179 and Controlled Groups: Are S Corporations In or Out?

Tax Rules Applicable to S Corporation ESOPs

Sales, Exchanges & Basis

Current Developments in Sales, Exchanges & Basis

North Central and its Implications for Related Party Exchanges

Sales, Exchanges, and Basis in the World of Section 1411

Stress Testing “Cash Out” Section 1031 Techniques

To Wed or Not to Wed? The Tax Consequences of Windsor for Intervivos Property Transactions

Standards of Tax Practice

Ensuring Compliance With Circular 230 and Other Practice Rules: What’s a Manager to Do and What Happens if They Don’t?

Ethical Issues in Federal Tax Practice—The Government Perspective

Teaching Ethics—Incorporating Ethical Issues from Basic Tax to LLM Courses

Teaching Ethics—Just Whose Responsibility Is It?

State & Local Taxes

Are Modern Trading Posts Off the Reservation: Do New Federal Regulations Create Tax Havens for non-Native American Businesses Conducted on Tribal Lands?

Private Enforcement of State Tax Laws: False Claims Acts and The Transaction Tax Overpayment Model Act

State Taxation of Pass-Through Entities and Their Owners

The Rush to Extend the Sales Tax to Services: Is It Over or Just Beginning?

Tax Accounting

Current Developments

Guidance Project Addressing the Treatment of Advance Payments

Tangible Property Regulations: Practical Implications

Tax Exempt Financing

Legislative, Treasury and Internal Revenue Service Update

Proposed Arbitrage Regulations

Tax Policy & Simplification

The Role of the Internal Revenue Service in the Administration of Social Welfare Policy

Teaching Taxation

Section Program: Current Developments

Transfer Pricing

New IRS Revenue Procedures for the Competent Authority and APA processes

Update on Transfer Pricing Issues in Developing Countries

US Activities of Foreigners & Tax Treaties

FATCA for Those on This Side of the Ocean/Border

Inbound Financings: Issues and Planning Strategies