TaxIQ

2015 Midyear Meeting

January 29-31, Houston, TX

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 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

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

Recent Developments Slides: Recent Developments Affecting the Banking Community

Bankruptcy & Workouts

The Unanswered Questions of Section 108 Slides: The Unanswered Questions of § 108

Civil & Criminal Tax Penalties

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

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

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

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

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

Employee Benefits

409A Turns 10 Outline: 409A Turns 10
Defined Contribution Plans Update Outline: Lifetime Income for Defined Contribution Plan Participants
Distributions and Defined Benefit Plans Updates Outline: Recent PBGC Legislative/Regulatory Developments
Distributions and Defined Benefit Plans Updates Slides: Section 4062(e) Liability: The New Law
Distributions and Defined Benefit Plans Updates Outline: Summary of FAB 2014-01, Fiduciary Duties and Missing Participants in Terminated Defined Contribution Plans
Distributions and Defined Benefit Plans Updates Slides: PBGC Regulatory Update
ESOP Update Outline: Employee Stock Ownership Plan Current Issues
Ethics and Circular 230 Slides: Circular 230 - Revised Final Regulations Affecting Employee Benefits
Ethics and Circular 230 Slides: Circular 230 - Affecting Employee Benefits
Exempt Organization and Governmental Plans Update Outline: Church Plan Litigation Update
Exempt Organization and Governmental Plans Update Outline: Section 414(h)(2): Current Pick-up Issues
Exempt Organization and Governmental Plans Update Outline: Status of Existing Guidance
Hot Topics Outline: Summary of Selected Guidance Issued by the Department of the Treasury and the Internal Revenue Service during the Past 12 Months
Legislative Update Outline: Legislative Update
Mergers & Acquisitions Update Slides: Say on Golden Parachute Disclosure and Advisory Notice
Multiple Employers, PEOs and Controlled Groups Update Outline: U.S. Pension Plan Liabilities of Foreign Entities: Extraterritoriality, Jurisdiction and Enforcement
Multiple Employers, PEOs and Controlled Groups Update Outline: Tri-Party Employment Relationships
Multiple Employers, PEOs and Controlled Groups Update Slides: Small Business Efficiency Act: Federal Recognition of PEOs
Section 457A: Revenue Ruling 2014-18 and Its Impact on Fund Manager Compensation Slides: Section 457A: Revenue Ruling 2014-18 and Its Impact on Fund Manager Compensation
Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: Employer Healthcare Arrangement Do's and Don'ts
Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: The Equal Employment Opportunity Commission’s Latest Salvos Against Wellness Plans That Otherwise Comply with the Tri-Agency Wellness Plan Regulations
Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: HIPAA Excepted Benefits Final and Proposed Regulations
Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: New Proposed Rules for Summaries of Benefits and Coverage

Employment Taxes

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

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

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

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

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

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

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

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

Joint Current International Developments Panel Slides: Joint Current International Developments Panel

Individual & Family Taxation

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

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

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

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

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

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

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

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

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

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

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

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

Practical Tips for Hiring and Retaining Good Tax Lawyers Outline: Practical Tips for Hiring and Retaining Good Tax Lawyers

Teaching Taxation

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

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

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