TaxIQ

2016 Midyear Meeting

January 28-30, Los Angeles, CA

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.


Administrative Practice

APA and the Administrative Process: How Has Altera Altered the Landscape? Slides: APA and the Administrative Process: How Has Altera Altered the Landscape?
California Administrative Agencies and Effective Administrative Practice Outline: California Chief Counsel Update
Important Developments Outline: Current Developments Handout
The Dawn of A New Era for Partnership Examinations Slides: The Dawn of a New Era for Partnership Examinations

Affiliated & Related Corporations

The Use of Partnerships by Consolidated Groups (Part II) Slides: The Intersection of Subchapter K and Consolidated Returns – Part II

Banking & Savings Institutions

Bank Regulatory Capital Slides: Total Loss Absorbing Capacity - Debt vs. Equity Issues
Recent Developments: STARS Transactions and Section 871(m) Issues and Concerns Slides: Recent Developments Affecting the Banking Community

Bankruptcy and Workouts

Bankruptcy Rules That Tax Practitioners Should Know: (Other than the 3 year, 240-day and 2-year Rules) Outline: Beyond the Three-Year, 240-Day, and Two-Year Rules: Bankruptcy Rules that Tax Practitioners Should Know
Late Filed Return Judicial Doctrine and the IRS’s Substitute for Return Process Outline: Bankruptcy Options: Post-McCoy: Unpaid Tax Liabilities on Late Filed Returns
Loss Planning for Corporate Taxpayers Slides: Loss Planning for Corporate Taxpayers

Capital Recovery & Leasing

Current Developments Report and Update on Pending Guidance Outline: Current Developments
Tangible Property Regulations – Focus on Rev. Proc. 2015-56 Outline: Retail and Restaurant Remodel-Refresh Safe Harbor: Implementation of the safe harbor method of accounting and potential issues that may arise
The Treatment of Lease Termination Costs post-ABC Beverage Corp Slides: The Treatment of Lease Termination Payments Post ABC Beverage Corp.

Civil & Criminal Tax Penalties

Civil and Criminal Employment Tax Enforcement Efforts – Employers Beware Slides: Civil and Criminal Employment Tax Enforcement Efforts – Employers Beware
Litigating the Accuracy Penalty Slides: Litigating the Accuracy Penalty
Reports of Subcommittees on Important Developments Outline: Monetary Violations and Forfeitures
Reports of Subcommittees on Important Developments Slides: IRS Investigations & Practices Subcommittee Report
To File or Not to File – That is the Question Slides: To File or Not to File – That is the Question

Closely Held Businesses

When the Past is Not the Past: Cleaning Up Our Client’s Past Bad Behavior Outline: When the Past is Not the Past: Resolving Our Client's Past Misdeeds
When the Past is Not the Past: Cleaning Up Our Client’s Past Bad Behavior Slides: When the Past is not the Past: Cleaning Up Our Client’s Bad Behavior
Worker Classification – What's Old is New Again Slides: Worker Classification - What's Old Is New Again
Worker Classification – What's Old is New Again Slides: Worker Classification: What’s Old is New Again

Corporate Tax

"Tightening the Noose": IRS Proposes Regulations on Outbound Transfers of Foreign Goodwill and Workforce in Place Slides: Tightening the Noose: IRS Proposes Regulations on Outbound Transfers of Foreign Goodwill and Workforce in Place
“Mere Change”: The New Final Section 368(a)(1)(F) Regulations Slides: “Mere Change”: The New Final Section 368(a)(1)(F) Regulations

Court Procedure & Practice

Current Developments Outline: Important Developments Panel
Disclosure, FOIA and Tax Litigation Outline: Freedom of Information Act
Roundtable Discussion: Decision Documents and Their Aftermath Slides: Decision Documents and their Aftermath
Who's the Boss? Litigating Employment Tax Cases Slides: Who’s The Boss? Litigating Employment Tax Cases

Diversity

Elimination of Bias in the Profession: The LGBT Ally Toolkit Slides: Elimination of Bias in the Profession: An LGBT Ally Toolkit
The Earned Income Tax Credit: Delivering the Anti-Poverty Mandate Outline: Navajo Courts: Clan Children as Foster Children for EIC
The Earned Income Tax Credit: Delivering the Anti-Poverty Mandate Slides: The Earned Income Tax Credit: An antipoverty tool for the 21st century

Employee Benefits

Administrative Practices Update Chart: New Voluntary Correction program Fee Schedule for Qualified Plans and 403(b) Plans Regular Submissions
Administrative Practices Update Outline: Summary of Key Changes to Determination Letter Process
Current and Future Developments Under the Affordable Care Act and for Health and Welfare Plans: Information Reporting, Market Reforms, Wellness Plans, and the Cadillac Tax Outline: IRS extends the Affordable Care Act information reporting due dates
Current and Future Developments Under the Affordable Care Act and for Health and Welfare Plans: Information Reporting, Market Reforms, Wellness Plans, and the Cadillac Tax Outline: Treasury and IRS issue year‐end guidance on a wide range of Affordable Care Act issues
Defined Benefit Plan and Distributions Update Outline: Recent PBGC Legislative/Regulatory Developments
Defined Benefit Plan and Distributions Update Slides: A Guide to PBGC’s New Reportable Events Rules
Defined Benefit Plan and Distributions Update Slides: Electronic Certification for Hardship Distributions
Defined Benefit Plan and Distributions Update Slides: Hybrid Pension Plans: Guidance Old and New
DOL Proposed Fiduciary Regulation and Prohibited Transaction Exemptions Outline: DOL Proposes Major Changes to Fiduciary Advice Definition
DOL Proposed Fiduciary Regulation and Prohibited Transaction Exemptions Outline: Overview of DOL’s 2015 Proposed Revisions to Existing Class Exemptions and Introduction of New Class Exemptions
Employee Classification under the ACA and NLRB Rules Outline: Employee Classification Under the ACA and NLRB Rules
Employee Classification under the ACA and NLRB Rules Slides: Employee Classification Under the ACA and NLRB Rules - A Primer on Worker Classification
Employee Classification under the ACA and NLRB Rules Slides: Worker Misclassification - the Game Change and Consequences
ESOP Update Outline: ESOP Update
ESOP Update Outline: ESOP Update
Executive Compensation, Fringe Benefits and Federal Securities Law Update Slides: Executive Compensation in Non-Profits
Hot Topics for Proxy Season 2016 Slides: Hot Topics for Proxy Season 2016
Litigation Update Outline: Case Summaries
Multinational Employee Benefits & Compensation Issues Update Slides: Challenges in Operating an International ESPP
Multinational Employee Benefits & Compensation Issues Update Slides: US Sanctions (Office of Foreign Asset Control) and Their Impact on US Pension Plans
Multiple Employers, PEOs and Controlled Groups Update Outline: Savings Arrangements Established by States for Non-Governmental Employees
Upcoming US Supreme Court Decisions Slides: Upcoming US Supreme Court Decisions
Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update Outline: Pace Act and Other Recent Legislative Developments Affecting Employer-Sponsored Welfare Benefit Plans

Employment Taxes

Federal Employment Tax Update Slides: Federal Employment Tax Update
The Gig Economy and Worker Classification Slides: The Gig Economy and Worker Classification
The Technology Industry and Fringe Benefits Slides: The Technology Industry and Fringe Benefits

Estate & Gift Taxes

Current Developments Outline: Current Developments in Federal Transfer Taxes
Estate Planning in Hollywood: Special Considerations for Entertainment Clients Outline: Estate Planning in Hollywood: Special Considerations for Entertainment Clients
Power to the People! An Exploration of the Uses of Powers of Appointment in Estate Planning Outline: Power to the People! An Exploration of the Uses of Powers of Appointment in Estate Planning
Power to the People! An Exploration of the Uses of Powers of Appointment in Estate Planning Slides: Power to the People! An Exploration of the Uses of Powers of Appointment in Estate Planning

Exempt Organizations

Difficult Public Support Test Issues Outline: Difficult Public Support Test Issues
The Commerciality Doctrine: Blessing or Curse? Outline: Income-Generating Activities consistent with Exempt Status

Fiduciary Income Tax

Current Developments Outline: Recent Developments in Fiduciary Income Tax
Strategies for Dealing with Trust UNI: How to Prevent Income Tax Armageddon Outline: Strategies for Dealing with Trust UNI: How to Prevent Income Tax Armageddon
The Beneficiary Defective Irrevocable Trust (“BDIT”) – How does It Work and Who Is It Best Suited For? Should You Just BDIT? Slides: The Beneficiary Defective Irrevocable Trust ("BDIT") How does It Work and Who Is It Best Suited For? Should You Just BDIT?

Financial Transactions

All Things Bright and Beautiful: Applying the Final Section 871(m) Regulations Beyond Single Name NPCs Slides: All Things Bright and Beautiful: Applying the Final Section 871(m) Regulations Beyond Single Name NPCs
The Cottage Savings Regulations Revisited Slides: Cottage Saving Regs Revisited

Foreign Lawyers Forum

The 2016 EU Tax Update - All You Can Eat in Just Two Hours Slides: The 2016 EU Tax Update

Individual & Family Taxation

Athletes, Entertainers and the IRS Outline: Athletes and Entertainers in the Eyes of the IRS, States, Cities, and the International Olympic Committee
Late Filed Returns Outline: The Impact of Bankruptcy on Late-Filed Returns
New Approaches and Alternatives to Innocent Spouse Relief Outline: Innocent Spouse or ID Theft
New Approaches and Alternatives to Innocent Spouse Relief Outline: Section 6015 - Joint Returns

Insurance Companies

P&C Loss Reserves Slides: Property and Casualty Reserve Issues
Product Update Slides: Life Insurance Product Tax Update

Investment Management

Current Issues for Funds Investing in Index-Linked Financial Transactions Slides: Current Issues for Funds Investing in Index-Linked Financial Transactions
Current Issues for Investment Companies Slides: RICs, Partnerships, and the Separate Account Dividends-Received Deduction
Current Issues for Investment Companies Slides: Taxation of Independent Director Compensation

Partnerships & LLCs

Allocations and Varying Interests – the 706 Regulations Slides: Allocations and Varying Interests: The Final Section 706 Regulations
Hot Topics Slides: Hot Topics in Partnership Taxation
Partnerships With Related Foreign Partners - Notice 2015-54 Slides: Partnerships With Related Foreign Partners--Notice 2015-54
What Am I? – Dual Status as Partner and Employee Outline: Employee Benefits Aspects of Partnerships and LLCs
What Am I? – Dual Status as Partner and Employee Slides: What Am I? – Dual Status as Partner and Employee

Pro Bono & Tax Clinics

Earned Income Credit Issues and Updates Slides: Earned Income Credit Basics

Real Estate

Casualties and Condemnations Slides: Casualties and Condemnations
Fractions Rule Update Slides: Fractions Rule Update
Real Estate Intangibles Slides: Real Property Intangibles Hot Topics & Current Developments

S Corporations

Important Developments Outline: Current Developments in the Federal Income Taxation of S Corporations
Pesky S Corporation M&A Issues Outline: Pesky S Corporation M&A Issues
Pesky S Corporation M&A Issues Slides: Selected Tax Issues in S Corporation M&A Transactions
State and Local Tax Issues Related to Mergers and Acquisitions of S Corporations Slides: State and Local Tax Issues Related to Mergers and Acquisitions of S Corporations

Sales, Exchanges & Basis

A Close Examination of the Intermediary Installment Sale Transactions Slides: Intermediary Installment Sale Transactions
Can the Tenant Provide Tax-Free Financing of the Landlord’s Construction Costs? Slides: Can the Tenant Provide Tax-Free Financing of Landlord’s Construction Costs?
Current Developments in Sales, Exchanges & Basis Outline: Current Non-Section 1031 Developments
Section 1031 Transactions, California-Style Slides: Life in the Golden State: California's Take on IRC 1031

Section Programs

Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation Outline: Federal Estate, Gift and Generation-Skipping Transfer Tax recent Developments
Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation Outline: Recent Developments in Federal Income Taxation
Nuts & Bolts of Tax Court Litigation: Pre-trial Practice Slides: Nuts & Bolts of Tax Court Litigation: Pre-Trial
Nuts & Bolts of Tax Court Litigation: Post-trial Practice Outline: Nuts & Bolts of Tax Court Litigation: Post-trial Practice

Standards of Tax Practice

Ethical Issues in Federal Tax Practice – The Government and Local Perspective Slides: Ethical Issues in Federal Tax Practice - The Government Perspective

State & Local Taxes

Applying Deference In Tax Cases Outline: Applying Deference in Tax Cases
Applying Deference In Tax Cases Slides: Applying Deference in Tax Cases
Sunlight as a Disinfectant versus the Possible Perils of Government in a Fishbowl: Transparency in Tax Administration and the Role of the Tax Department Slides: Sunlight as a Disinfectant versus the Possible Perils of Government in a Fishbowl: Transparency in Tax Administration and the Role of the Tax Department
The Multistate Tax Compact Under Fire: An Update on the California Gillette v. Franchise Tax Board Case and Litigation of This Issue in Other States Slides: Multistate Tax Compact Litigation

State & Local Taxes and Transfer Pricing

BEPS and Transfer Pricing Implications for State and Local Tax Slides: BEPS and Transfer Pricing Implications for State & Local Tax

Tax Accounting

Current Developments Outline: Current Developments
Recent Developments in Section 199 Slides: Recent Developments in Section 199
Timing of Deductions for Ratable Service Contracts Outline: Accounting for Ratable and Non-Ratable Service Contracts

Tax Bridge on the Road

Nuts & Bolts: The Administrative Tax Controversy Case From Examination to Appeals Outline: The Administrative Tax Controversy Case – Examinations & Ethical Considerations for Responses to the Internal Revenue Service
Nuts & Bolts: The Administrative Tax Controversy Case From Examination to Appeals Slides: Nuts & Bolts: The Administrative Tax Controversy Case From Examination to Appeals

Tax Exempt Financing

Public / Private Partnerships: The Impact of the New Mixed Use Treasury Regulations on P3 Transactions Outline: Example: Partner Nonrecourse Deductions
Public / Private Partnerships: The Impact of the New Mixed Use Treasury Regulations on P3 Transactions Outline: P3s and the New Mixed Use Treasury Regulations

Tax Policy & Simplification

Marketplace Fairness Act Outline: Marketplace Fairness Act Overview
Marketplace Fairness Act Slides: Marketplace Fairness Act
Marketplace Fairness Act Slides: Marketplace Fairness Act Overview of the Sales and Use Tax Reform

Tax Practice Management

Social Media and the Tax Lawyer: An Update on Avoiding Ethical Traps Outline: Social Media and the Tax Lawyer: An Update on Avoiding Ethical Traps

Teaching Taxation

Inequality and Taxation Outline: Estate Tax Stories

Transfer Pricing

Media & Entertainment Considerations in Transfer Pricing Slides: Media & Entertainment Considerations in Transfer Pricing
REITs and Transfer Pricing: The IRS Takes up the Welcome Mat Slides: REITs and Transfer Pricing: The IRS Takes up the Welcome Mat

US Activities of Foreigners & Tax Treaties

Advanced Withholding Taxation - A Guide for the Perplexed Slides: Advanced Withholding Taxation: A Guide for the Perplexed