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2015 Midyear Meeting

January 29-31, Houston, TX

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

Important Developments

Navigating the TEFRA Swamp: Managing the Complexities of a Partnership Audit

You've Been Served: Handling IRS Summonses in Audits and Tax Litigation

Affiliated & Related Corporations

Do's and Don'ts with Member Stock and Member Debt

The Doctor Is In - Corporate Tax Issues Facing Professional Service Providers

Banking & Savings Institutions

Recent Developments

Bankruptcy & Workouts

The Unanswered Questions of Section 108

Civil & Criminal Tax Penalties

Cross-Examination in a Tax Case

Reports of Subcommittees on Important Developments

Summons Enforcement – Procedure, Privileges and Petitions to Quash

Closely Held Businesses

Closely Held Businesses & Tax Debts: An Update on IRS Collection Procedures and Opportunities for Resolving Outstanding Tax Debts

Payroll Tax Debts: The Good, the Bad and the Criminal

Retirement Planning Guide for Estate Lawyers: Helping Your Client Plan for a Financially Successful Retirement

Tax Considerations for Executives and Management Teams in Corporate Transactions

Corporate Tax

Corporate Inversions

Exploring Voting Power

Transactional Electivity and Subchapter C

Court Procedure & Practice

Court Procedure and Practice Roundtable Discussion: Pre-Trial Planning & Judicial Precedence

Important Developments

Litigating Financial Products Case Update

Litigating Tax Penalties Case Update


Does One-Size-Fit-All? Creating a Tax Code that Fits Everyone

If It Quacks Like a Duck: Substance over Form

Section Program: A Primer on Tax Treaties

Tax Issues Affecting Immigration Cases

Employee Benefits

409A Turns 10

Defined Contribution Plans Update

Distributions and Defined Benefit Plans Updates

ESOP Update

Ethics and Circular 230

Exempt Organization and Governmental Plans Update

Hot Topics

Legislative Update

Mergers & Acquisitions Update

Multiple Employers, PEOs and Controlled Groups Update

Section 457A: Revenue Ruling 2014-18 and Its Impact on Fund Manager Compensation

Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update

Employment Taxes

Common Employment Tax Mistakes

Employment Tax Due Diligence in M&A

Federal Employment Tax Update

Energy & Environmental Taxes

IRS Enforcement On the US Outer Continental Shelf

Unit of Property Issues in the Petroleum Industry and How to Resolve Them

Estate & Gift Taxes

Business Interests in Trusts

Current Developments

Estate Planning in the Twilight Zone: US Taxation of Non-Resident Aliens

Section 6166 Planning Issues

Exempt Organizations

Disaster Relief in 2015: Disease as a Disaster & the Criminalization of Humanitarian Aid

Private Foundations: Special Self-Dealing Problems

Fiduciary Income Tax

Current Developments

Planning for New Basis at Death

Sale Transactions with Notes: Debt v. Equity with Regard to Notes Based on Woebling

Section 469 Regulations: Update on the Committee’s Comment Writing Task Force

Structuring Offshore Trusts

Financial Transactions

Negative Interest, Negative Rebate and Similar Issues

Taxation of Hybrid Instruments: Past, Present and Future

Withholding Tax Current Developments and Issues

Foreign Activities of US Taxpayers

Moving Overseas: Notice 2014-52 and Future Guidance and the Implications for Inversions

Unresolved Issues in US International Tax

Foreign Lawyers Forum

BEPS is a Big One for the Big Ones

Everything You Always Wanted To Know About Fiscal State Aid But Were Afraid To Ask

Joint International Committee: FAUST, FLF, USAFTT, and TP

Joint Current International Developments Panel

Individual & Family Taxation

Breaking Up Is Hard to Do: Protecting Divorcing Spouses From the IRS and Each Other

Penalties and Penalty Abatement: A Refresher / Overview

Insurance Companies


Life / Non-Life Consolidated Returns

Material Changes and Life Insurance Exchanges

Investment Management

Tender Option Bond Derivatives and Life After Volcker: Tax issues for Market Participants, Including Funds and Banks

Partnerships & LLCs

Maybe It’s Not Too Late: Section 9100 Relief For Late Elections In the Partnership Context

Oil and Gas Partnerships

Section 751(b) Proposed Regulations

Who Can Sign a Partnership Return?

Pro Bono & Tax Clinics

Fraud in the Return Preparation Industry

Tribal Tax Issues

Real Estate

Hot Topics

I Think I Have a Busted REIT. What Do I Do Now?

Real Estate Fund Allocation Issues

Tenant Improvements and Other Leasing Issues

S Corporations

Current Developments

S Corporations and Back-to-Back Loans

S Corporations and Passive Activities

S Corporations Banks

Sales, Exchanges & Basis

Current Developments in Sales, Exchanges & Basis

Exchanges in the Oil Patch

Sharing Arrangements in the Upstream Oil & Gas Industry

Standards of Tax Practice

Ethical Issues in Federal Tax Practice – The Government Perspective

Special Issues for Tax Practitioners Representing Partnerships, Tax Matters Partners or Partners in Partnerships (and Other Pass-Through Entities): Ensuring Compliance With Circular 230 and Other Practice Rules

What’s a Young Tax Attorney to Do When....?

State & Local Taxes

How Are The Economic Substance Doctrine and Related Principles Being Applied in State Tax Cases?

Market Based Sourcing Regulations: Where the Rubber Meets the Road

State & Local Tax Issues Affecting the Oil & Gas Industry

Tax Accounting

Accounting Methods Considerations for the Oil and Gas and Mining Industries

Current Developments

How Has the IRS Changed the Change in Accounting Method Procedures?

Treatment of Deferred Revenue in Taxable Asset Sales and Acquisitions

Tax Policy & Simplification

Reorganizing the Internal Revenue Service to Achieve its Mission(s): Past, Present, and Future

The Future of Energy Tax Policy

Tax Practice Management

Practical Tips for Hiring and Retaining Good Tax Lawyers

Teaching Taxation

Repealing Section 1031? A Debate

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

Transfer Pricing

BEPS Round Two: Risk and Capital

Intangibles in Litigation

US Activities of Foreigners & Tax Treaties

Foreign Investment in US Energy Assets

Selected Traps for the Unwary Pertaining to Foreign Investments in the United States