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