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
- Outline: Important Developments - Criminal
- Outline: Monetary Violations and Forfeitures Subcommittee Report
- Outline: Legislative & Administrative 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
- Outline: Employment Taxes, Trust Fund Recovery Penalty & Representing the Responsible Person
- 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
Tax Considerations for Executives and Management Teams in Corporate Transactions
- Outline: Tax Consequences for Executives and Management Teams in Corporate Transactions
- Slides: Tax Consequences 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
Diversity
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
- Outline: Recent PBGC Legislative/Regulatory Developments
- Slides: Section 4062(e) Liability: The New Law
- Outline: Summary of FAB 2014-01, Fiduciary Duties and Missing Participants in Terminated Defined Contribution Plans
- Slides: PBGC Regulatory Update
ESOP Update
Ethics and Circular 230
- Slides: Circular 230 - Revised Final Regulations Affecting Employee Benefits
- Slides: Circular 230 - Affecting Employee Benefits
Exempt Organization and Governmental Plans Update
- Outline: Church Plan Litigation Update
- Outline: Section 414(h)(2): Current Pick-up Issues
- Outline: Status of Existing Guidance
Hot Topics
Legislative Update
Mergers & Acquisitions Update
Multiple Employers, PEOs and Controlled Groups Update
- Outline: U.S. Pension Plan Liabilities of Foreign Entities: Extraterritoriality, Jurisdiction and Enforcement
- Outline: Tri-Party Employment Relationships
- Slides: Small Business Efficiency Act: Federal Recognition of PEOs
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
- Outline: The Equal Employment Opportunity Commission’s Latest Salvos Against Wellness Plans That Otherwise Comply with the Tri-Agency Wellness Plan Regulations
- Outline: HIPAA Excepted Benefits Final and Proposed Regulations
- Outline: New Proposed Rules for Summaries of Benefits and Coverage
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
- Outline: Structuring and Administering Trusts to Own Interests in Closely Held Entities
- Outline: Trust Ownership of Business Interests
Current Developments
Estate Planning in the Twilight Zone: US Taxation of Non-Resident Aliens
- Outline: Inbound Essentials: Estate and Income Tax Planning for Nonresident Aliens
- Slides: Estate Planning in the Twilight Zone: U.S. Taxation of Nonresident 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
BEPS
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
- Paper: The ACA, the IRS, and the Indian Health Care Delivery System
- Article: Circular 230: Representation and the Navajo Nation
- Slides: The ACA, the IRS, and the Indian Health Care Delivery System
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
- Outline: Final Back-to-Back Loan Regulations and the Death of the "Actual Economic Outlay" Requirement - Maybe?
- Slides: Final Back-to-Back Loan Regulations and the Death of the "Actual Economic Outlay" Requirement - Maybe?
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
- Outline: Repeal Section 1031 Non-Recognition for Like-Kind Exchanges
- Paper: Lincoln-Douglas Debate on Code Section 1031
- 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
- Outline: Federal Estate, Gift, and Generation-Skipping Transfer Tax Recent Developments
Transfer Pricing
BEPS Round Two: Risk and Capital
- Slides: Risk and Return
- Slides: BEPS Round Two: Risk and Capital
- Slides: Moral Hazard and Special Measures
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