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Thoughtful Insights. Useful Analysis.
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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 |
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| Important Developments | Slides: Current Developments |
| Navigating the TEFRA Swamp: Managing the Complexities of a Partnership Audit | Slides: Navigating the TEFRA Swamp: Managing the Complexities of a Partnership Audit |
| You've Been Served: Handling IRS Summonses in Audits and Tax Litigation | Slides: You've Been Served: Handling IRS Summonses in Audits and Tax Litigation |
Affiliated & Related Corporations |
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| Do's and Don'ts with Member Stock and Member Debt | Slides: Do's and Don'ts with Member Stock and Member Debt |
| The Doctor Is In - Corporate Tax Issues Facing Professional Service Providers | Slides: The Doctor is In |
Banking & Savings Institutions |
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| Recent Developments | Slides: Recent Developments Affecting the Banking Community |
Bankruptcy & Workouts |
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| The Unanswered Questions of Section 108 | Slides: The Unanswered Questions of § 108 |
Civil & Criminal Tax Penalties |
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| Cross-Examination in a Tax Case | Outline: Cross-Examination Techniques |
| Reports of Subcommittees on Important Developments | Outline: Important Developments - Criminal |
| Reports of Subcommittees on Important Developments | Outline: Monetary Violations and Forfeitures Subcommittee Report |
| Reports of Subcommittees on Important Developments | Outline: Legislative & Administrative Developments |
| Summons Enforcement – Procedure, Privileges and Petitions to Quash | Outline: Use, Enforcement, and Defense of IRS Summons |
Closely Held Businesses |
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| Closely Held Businesses & Tax Debts: An Update on IRS Collection Procedures and Opportunities for Resolving Outstanding Tax Debts | Outline: IRS Collections |
| Closely Held Businesses & Tax Debts: An Update on IRS Collection Procedures and Opportunities for Resolving Outstanding Tax Debts | Slides: IRS Collection Update |
| Payroll Tax Debts: The Good, the Bad and the Criminal | Outline: Employment Taxes, Trust Fund Recovery Penalty & Representing the Responsible Person |
| Payroll Tax Debts: The Good, the Bad and the Criminal | Slides: 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 | Paper: A Retirement Planning Guide for Estate Planners and Family Business Advisors |
| Tax Considerations for Executives and Management Teams in Corporate Transactions | Outline: Tax Consequences for Executives and Management Teams in Corporate Transactions |
| Tax Considerations for Executives and Management Teams in Corporate Transactions | Slides: Tax Consequences for Executives and Management Teams in Corporate Transactions |
Corporate Tax |
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| Corporate Inversions | Slides: Inversions |
| Exploring Voting Power | Slides: Exploring Voting Power |
| Transactional Electivity and Subchapter C | Slides: Transactional Electivity in Subchapter C |
Court Procedure & Practice |
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| Court Procedure and Practice Roundtable Discussion: Pre-Trial Planning & Judicial Precedence | Outline: Pre-Trial Planning & Judicial Precedence |
| Important Developments | Outline: Summary of Important Developments |
| Litigating Financial Products Case Update | Slides: Litigating Financial Products Cases |
| Litigating Tax Penalties Case Update | Outline: Litigating Tax Penalties Case Update |
Diversity |
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| Does One-Size-Fit-All? Creating a Tax Code that Fits Everyone | Slides: 21st Century Federal Income Tax: Diversity Matters |
| If It Quacks Like a Duck: Substance over Form | Slides: If it Quacks Like a Duck: Economic Substance and Related Concepts |
| Section Program: A Primer on Tax Treaties | Outline: A Primer on Tax Treaties |
| Section Program: A Primer on Tax Treaties | Slides: Section Program: Primer on Tax Treaties |
| Tax Issues Affecting Immigration Cases | Outline: Tax Issues Affecting Immigration Cases |
Employment Taxes |
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| Common Employment Tax Mistakes | Slides: Common Employment Tax Mistakes |
| Employment Tax Due Diligence in M&A | Slides: Employment Tax Due Diligence in M&A |
| Federal Employment Tax Update | Slides: Federal Employment Tax Update |
Energy & Environmental Taxes |
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| IRS Enforcement On the US Outer Continental Shelf | Slides: IRS Enforcement on the U.S. Outer Continental Shelf |
| Unit of Property Issues in the Petroleum Industry and How to Resolve Them | Slides: Unit of Property Issues in the Petroleum Industry and How to Resolve Them |
Estate & Gift Taxes |
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| Business Interests in Trusts | Outline: Structuring and Administering Trusts to Own Interests in Closely Held Entities |
| Business Interests in Trusts | Outline: Trust Ownership of Business Interests |
| Current Developments | Outline: Current Developments in Federal Transfer Taxes |
| Estate Planning in the Twilight Zone: US Taxation of Non-Resident Aliens | Outline: Inbound Essentials: Estate and Income Tax Planning for Nonresident Aliens |
| Estate Planning in the Twilight Zone: US Taxation of Non-Resident Aliens | Slides: Estate Planning in the Twilight Zone: U.S. Taxation of Nonresident Aliens |
| Section 6166 Planning Issues | Outline: Section 6166 Planning Issues |
| Section 6166 Planning Issues | Slides: Section 6166 Planning Issues |
Exempt Organizations |
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| Disaster Relief in 2015: Disease as a Disaster & the Criminalization of Humanitarian Aid | Outline: Disaster Relief in 2015: Disease as a Disaster & the Criminalization of Humanitarian Aid |
| Private Foundations: Special Self-Dealing Problems | Slides: Private Foundations: Special Self-Dealing Problems |
Fiduciary Income Tax |
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| Current Developments | Outline: Recent Developments in Fiduciary Income Tax |
| Planning for New Basis at Death | Article: Planning for New Basis at Death |
| Sale Transactions with Notes: Debt v. Equity with Regard to Notes Based on Woebling | Outline: Sale Transactions with Notes: Debt v. Equity with Regard to Notes, Including Discussion of the Woelbing Cases |
| Section 469 Regulations: Update on the Committee’s Comment Writing Task Force | Comment: Comments on Material Participation Under Section 469 |
| Structuring Offshore Trusts | Article: Self-Settled Trusts & Bankruptcy |
Financial Transactions |
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| Negative Interest, Negative Rebate and Similar Issues | Slides: Negative Interest, Negative Rebate and Similar Issues |
| Taxation of Hybrid Instruments: Past, Present and Future | Slides: Taxation of Hybrid Instruments: Past, Present, and Future |
| Withholding Tax Current Developments and Issues | Slides: Withholding Tax Issues We Have Known |
Foreign Activities of US Taxpayers |
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| Moving Overseas: Notice 2014-52 and Future Guidance and the Implications for Inversions | Slides: Corporate Inversions: A Hitchhiker's Guide to Notice 2014-52 |
| Unresolved Issues in US International Tax | Slides: Unresolved Issues in International Tax |
Foreign Lawyers Forum |
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| BEPS is a Big One for the Big Ones | Slides: BEPS is a Big One: Recent Developments in the UK and Germany |
| Everything You Always Wanted To Know About Fiscal State Aid But Were Afraid To Ask | Slides: Fiscal State Aid in the European Union |
Joint International Committee: FAUST, FLF, USAFTT, and TP |
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| Joint Current International Developments Panel | Slides: Joint Current International Developments Panel |
Individual & Family Taxation |
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| Breaking Up Is Hard to Do: Protecting Divorcing Spouses From the IRS and Each Other | Outline: Breaking Up Is Hard To Do: Protecting Divorcing Spouses from the IRS (and Each Other) |
| Penalties and Penalty Abatement: A Refresher / Overview | Slides: IRS "Additions to Tax" |
Insurance Companies |
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| BEPS | Slides: BEPS and the Insurance Industry |
| Life / Non-Life Consolidated Returns | Slides: Life / Non-Life Consolidated Returns: The Tacking Rule and Other Issues |
| Material Changes and Life Insurance Exchanges | Slides: On Grandfathered Contracs, Material Changes, and Partial Exchanges of Life Insurance Contracts |
Investment Management |
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| Tender Option Bond Derivatives and Life After Volcker: Tax issues for Market Participants, Including Funds and Banks | Slides: Tender Option Derivatives and Life After Volker |
Partnerships & LLCs |
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| Maybe It’s Not Too Late: Section 9100 Relief For Late Elections In the Partnership Context | Slides: Maybe It's Not Too Late: Section 9100 Relief for Late Elections in the Partnership Context |
| Oil and Gas Partnerships | Slides: Oil and Gas Partnerships |
| Section 751(b) Proposed Regulations | Slides: Section 751(b) Proposed Regulations |
| Who Can Sign a Partnership Return? | Slides: Who Can Sign a Partnership Return? |
Pro Bono & Tax Clinics |
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| Fraud in the Return Preparation Industry | Slides: Fraud in Tax Preparation |
| Tribal Tax Issues | Paper: The ACA, the IRS, and the Indian Health Care Delivery System |
| Tribal Tax Issues | Article: Circular 230: Representation and the Navajo Nation |
| Tribal Tax Issues | Slides: The ACA, the IRS, and the Indian Health Care Delivery System |
Real Estate |
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| Hot Topics | Slides: Hot Topics in Partnership Taxation |
| I Think I Have a Busted REIT. What Do I Do Now? | Outline: Fixing a Hole Where the REIT Fell In |
| Real Estate Fund Allocation Issues | Slides: Real Estate Fund Allocation Issues |
| Tenant Improvements and Other Leasing Issues | Slides: Leasehold Improvements and Other Aspects of Leasing |
S Corporations |
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| Current Developments | Outline: Current Developments in the Federal Income Taxation of S Corporations |
| S Corporations and Back-to-Back Loans | Outline: Final Back-to-Back Loan Regulations and the Death of the "Actual Economic Outlay" Requirement - Maybe? |
| S Corporations and Back-to-Back Loans | Slides: Final Back-to-Back Loan Regulations and the Death of the "Actual Economic Outlay" Requirement - Maybe? |
| S Corporations and Passive Activities | Slides: Passive Activities |
| S Corporations Banks | Slides: S Corporations Banks |
Sales, Exchanges & Basis |
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| Current Developments in Sales, Exchanges & Basis | Outline: Current Non-Section 1031 Developments |
| Current Developments in Sales, Exchanges & Basis | Outline: IRC § 1031/§ 1033 Current Developments |
| Exchanges in the Oil Patch | Slides: Like Kind Exchanges in the Oil and Gas Industry (Redux) |
| Sharing Arrangements in the Upstream Oil & Gas Industry | Slides: Sharing Arrangements in the Upstream Oil and Gas Industry |
Standards of Tax Practice |
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| Ethical Issues in Federal Tax Practice – The Government Perspective | Slides: 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 | Slides: Special Issues for Tax Practitioners Representing Partnerships, Tax Matters Partners or Partners in Partnerships (and Other Pass-Through Entities) |
| What’s a Young Tax Attorney to Do When....? | Slides: What’s a Young Tax Attorney to Do When....? |
State & Local Taxes |
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| How Are The Economic Substance Doctrine and Related Principles Being Applied in State Tax Cases? | Slides: 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 | Slides: Market Based Sourcing Regulations - Where the Rubber Meets the Road |
| State & Local Tax Issues Affecting the Oil & Gas Industry | Slides: State & Local Tax Issues Affecting the Oil & Gas Industry |
Tax Accounting |
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| Accounting Methods Considerations for the Oil and Gas and Mining Industries | Slides: Accounting Methods Considerations for the Oil and Gas and Mining Industries |
| Current Developments | Outline: Current Developments |
| How Has the IRS Changed the Change in Accounting Method Procedures? | Outline: How Has the IRS Changed the Change in Accounting Method Procedures? - Overview |
| Treatment of Deferred Revenue in Taxable Asset Sales and Acquisitions | Slides: Treatment of Deferred Revenue in Taxable Asset Sales & Acquisitions |
Tax Policy & Simplification |
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| Reorganizing the Internal Revenue Service to Achieve its Mission(s): Past, Present, and Future | Paper: Reorganizing the Internal Revenue Service to Achieve its Mission(s): Past, Present, and Future |
| The Future of Energy Tax Policy | Outline: The Future of Energy Tax Policy - Background Paper and Bibliography |
Tax Practice Management |
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| Practical Tips for Hiring and Retaining Good Tax Lawyers | Outline: Practical Tips for Hiring and Retaining Good Tax Lawyers |
Teaching Taxation |
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| Repealing Section 1031? A Debate | Outline: Repeal Section 1031 Non-Recognition for Like-Kind Exchanges |
| Repealing Section 1031? A Debate | Paper: Lincoln-Douglas Debate on Code Section 1031 |
| Repealing Section 1031? A Debate | Outline: Background Materials on Section 1031 |
| Section Program: Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation | Outline: Recent Developments in Federal Income Taxation |
| Section Program: Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation | Outline: Federal Estate, Gift, and Generation-Skipping Transfer Tax Recent Developments |
Transfer Pricing |
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| BEPS Round Two: Risk and Capital | Slides: Risk and Return |
| BEPS Round Two: Risk and Capital | Slides: BEPS Round Two: Risk and Capital |
| BEPS Round Two: Risk and Capital | Slides: Moral Hazard and Special Measures |
| Intangibles in Litigation | Slides: Intangibles in Litigation: Defining and Valuing Compensable "Intangibles" |
US Activities of Foreigners & Tax Treaties |
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| Foreign Investment in US Energy Assets | Slides: Foreign Investment in U.S. Energy Assets |
| Selected Traps for the Unwary Pertaining to Foreign Investments in the United States | Slides: Selected Traps for the Unwary: Inbound Investments |