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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.
Administrative Practice |
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| Implementation of the New BBA Partnership Audit Rules | Slides: The New Partnership Audit Rules |
| Important Developments in Administrative Practice | Outline: Administrative Practice: Important Developments |
| Recent Changes to IRS Appeals Procedures | Slides: Recent Changes to IRS Appeals Procedures |
Affiliated and Related Corporations |
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| Application of the Final Section 385 Regulations to Consolidated Groups | Slides: The Section 385 Regulations |
| The Role of the Courts in Interpreting Consolidated Return Regulations | Slides: Consolidated Return Regulations: Validity Challenges and Interpretive Patterns |
Capital Recovery and Leasing |
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| Capitalized Costs in Failed Acquisitive Transactions | Slides: Capitalized Costs in Failed Acquisitive Transactions |
| Current Developments in Capital Recovery & Leasing | Outline: Current Developments |
Civil and Criminal Tax Penalties |
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| Reports of Subcommittees on Important Developments | Outline: Important Civil Developments October 2016 through December 2016 |
| Reports of Subcommittees on Important Developments | Slides: IRS Investigations & Practices Subcommittee Report |
| Restitution | Outline: Restitution |
| Uncommon Penalties | Slides: Assessable Penalties |
| Uncommon Penalties | Slides: Less Common Penalties in Appeals (Examination) |
| Uncommon Penalties | Slides: Uncommon Penalties, non-FBAR |
Closely Held Businesses |
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| Choice of Entity: Practical Considerations for Practitioners and Clients | Outline: Choice of Business Entity |
| Selling and Buying the Dreaded Tax Embroiled Business | Outline: Selling and Buying the Dreaded Tax Embroiled Business |
Corporate Tax |
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| Current Developments in Corporate Tax | Slides: Current Developments |
| Interesting Issues Arising Under Section 385 | Slides: Section 385 Considerations |
Court Procedure and Practice |
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| Current Developments in Court Procedure and Practice | Outline: Summary of Civil Tax Matters - Highlights |
| How to Affirmatively Defend An FBAR Case | Slides: How to Affirmatively Defend A FBAR Case |
| Let the Sunshine In: FOIA In Tax Litigation | Slides: Finding Hidden Treasure: How to Use the Freedom of Information Act (FOIA) and Other Tools to Uncover Valuable Evidence |
| Let the Sunshine In: FOIA In Tax Litigation | Slides: Let the Sunshine In: FOIA in Tax Litigation |
| Reasoned Decision Making Under the APA: Holding the IRS to a Reasonable Standard | Slides: Reasoned Decision Making Under the APA: Holding the IRS to a Reasonable Standard |
Diversity |
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| The New Markets Tax Credit: Providing Economic Stimulus to Low-Income Communities | Slides: The New Markets Tax Credit |
Employment Taxes |
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| Federal Employment Tax Update | Slides: Federal Employment Tax Update |
| Global Mobility and Frequent Business Travelers | Slides: Payroll Taxes and Withholding Issues Related to Nonresident Aliens Working in the US |
| Who is the Employer? | Slides: Who is the Employer? |
Energy and Environmental Taxes |
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| Energy Tax Current Developments Roundtable | Slides: Energy Tax Current Developments Roundtable |
Estate & Gift Taxes |
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| Current Developments in Estate & Gift Taxes | Outline: Current Developments in Federal Transfer Taxes |
| Pay Early, Pay Less: Maximizing TPT Credit Availability for Married Couples | Outline: Pay Early, Pay Less: How to Save Federal Estate Taxes For Married Couples By Maximizing TPT Credit Availability |
| Should I Stay or Should I Go? Considerations When Switching Domicile to Florida | Outline: Should I Stay or Should I Go? Considerations When Switching Domicile to Florida |
| The Separate Share Rule in Operation | Outline: The Separate Share Rule in Operation |
| Trump Is President and the Republicans Control the House and the Senate: What Does This Mean for Estate Planners Moving Forward? | Slides: Trump Is President and the Republicans Control the House and the Senate: What Does This Mean for Estate Planners Moving Forward? |
Exempt Organizations |
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| State of Play: Compensation and Intermediate Sanctions | Slides: State of Play: Compensation and Intermediate Sanctions |
| Thorny Issues for Private Foundations | Outline: Thorny Issues for Private Foundations: Equivalency Determinations for Foreign Schools |
| US Filing Obligations of Foreign Charities and the Implications for US Funders | Outline: US Filing Obligations of Foreign Charities and the Implications for US Funders |
Fiduciary Income Tax |
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| Current Developments in Fiduciary Income Tax | Outline: Recent Developments in Fiduciary Income Tax |
| International Spotlight: The Common Reporting Standard and FATCA As Applied to Private Clients – What Every Planner Should Know | Slides: International Spotlight: The CRS and FATCA as Applied to Private Client |
| The ABCs of QSBS: The Benefits, Requirements and Planning Opportunities with Qualified Small Business Stock | Outline: The ABCs of QSBS: The Benefits, Requirements and Planning Opportunities with Qualified Small Business Stock |
| The ABCs of QSBS: The Benefits, Requirements and Planning Opportunities with Qualified Small Business Stock | Slides: The ABCs of QSBS: The Benefits, Requirements and Planning Opportunities with Qualified Small Business Stock |
| The New Paradigm of Estate Planning: Fiduciary Income Taxation and Grantor Trusts | Slides: The New Paradigm of Estate Planning: Fiduciary Income Taxation and Grantor Trusts |
Financial Transactions |
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| Current Developments in Financial Products | Slides: Current Developments in Financial Products |
| Final Section 385 Regulations – How Will the Documentation Rules Apply in the Real World? | Slides: Section 385 Regulations |
| Interesting Issues under Section 1234A | Slides: Interesting Issues under Section 1234A |
Foreign Activities of US Taxpayers |
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| Outbound Stock and Asset Transfers | Slides: Outbound Stock and Asset Transfers |
| The Foreign Tax Credit | Slides: The Foreign Tax Credit - New Developments |
Foreign Lawyers Forum |
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| What's Going On? An Update on Tax Treaty and State Aid Developments | Slides: EU State Aid and Tax Rulings |
| What's Going On? An Update on Tax Treaty and State Aid Developments | Slides: EU State aid: Apple |
| What's Going On? An Update on Tax Treaty and State Aid Developments | Slides: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "MLI") |
Individual & Family Taxation |
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| Can You Get Your Business Client Relief Under Section 530 of the Revenue Act of 1978? | Slides: Can You Get Your Business Client Relief Under Section 530 of the Revenue Act of 1978? |
| Deductible Medical Expenses Under Section 213 Take on New Meaning | Slides: Deductible Medical Expenses Under Section 213 Take on New Meaning |
| Form 1099 Issues | Slides: Examinations Based on Information Reporting |
Insurance Companies |
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| Current Issues in Reinsurance Transactions | Slides: Current Issues in Reinsurance Transactions |
| Practical Advice on PBR Implementation | Slides: Practical Advice on PBR Implementation "Where are we, and how are companies preparing?" |
Investment Management |
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| Current Regulatory Initiatives Impacting Regulated Investment Companies (RICs) | Slides: Current Regulatory Initiatives Impacting Regulated Investment Companies |
| The New Section 385 Regulations and Private Funds | Slides: The New Section 385 Regulations and Private Funds |
| The New Section 707 and 752 Regulations and Private Equity Funds | Slides: The New Section 707 and 752 Regulations |
Joint International Committees |
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| Joint Current International Developments Panel | Slides: Joint Current International Developments Panel |
Partnerships & LLCs |
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| Cross Border Partnership Transactions | Slides: Cross Border Partnership Transactions: Recent Regulations and Guidance Adopting the Aggregate Approach |
| New Partnership Regulations under Sections 707 and 752 (Part 2) | Slides: New Partnership Regulations under Sections 707 and 752 |
| Section 708 Technical Terminations | Slides: Section 708(b)(1)(B) |
| Troubled Partnerships | Slides: Debt Workouts and Restructurings |
Pro Bono & Tax Clinics |
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| Disaster Tax Issues | Slides: Tax Issues Arising From Disasters |
Real Estate |
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| Hot Topics in Real Estate | Slides: Hot Topics Partnerships & Real Estate |
| New Partnership Regulations under Sections 707 and 752 (Part 1) | Slides: New Partnership Regulations under Sections 707 and 752 |
| Non-Safe Harbor Reverse Exchanges after Bartell | Slides: Non-Safe Harbor Reverse Exchanges After Bartell |
| Real Property for REIT Purposes | Slides: Real Property for REIT Purposes |
S Corporations |
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| Current Developments in the Federal Income Taxation of S Corporations | Outline: Current Developments in the Federal Income Taxation of S Corporations |
| S Corporations: Tips and Traps for the Unwary | Outline: S Corporations: Tips and Traps for the Unwary |
Sales, Exchanges and Basis |
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| Can Replacement Property be Temporarily Parked Beyond the Rev. Proc. 2000-37 Safe Harbor? | Slides: Can Replacement Property Be Temporarily Parked Beyond the Rev. Proc. 2000-37 Safe Harbor? |
| Current Developments in Sales, Exchanges & Basis | Outline: Current Developments in Like-kind Exchanges |
| Current Developments in Sales, Exchanges & Basis | Outline: Current Non-Section 1031 Developments |
| Current Section 336(e) Issues for Partnerships Buying Corporations | Slides: Current Section 336(e) Issues for Partnerships Buying Corporations |
Section Programs |
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| 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 |
| Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation | Slides: Current Developments in Individual, Corporate, Partnership, and Estate and Gift Taxation |
| Nuts & Bolts of State and Local Tax: Practicing Constitutional Law Every Day | Slides: Nuts & Bolts of State and Local Tax: Practicing Constitutional Law Every Day |
| Nuts & Bolts of State and Local Tax: What Tax is More than the State Income Tax? - The Sales Tax: Everything You Need to Know But Were Afraid to Ask | Slides: What Tax is More than the State Income Tax? - The Sales Tax: Everything You Need to Know But Were Afraid to Ask |
Standards of Tax Practice |
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| Ethical Issues in Federal Tax Practice - The Government Perspective | Slides: Ethical Considerations in IRS Settlement Negotiations |
State & Local Taxes |
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| Is McLeod Immortal? Transactional Nexus and the SALT Implications of Failing to Distinguish between Sales Taxes and Use Taxes | Slides: Is McLeod Immortal? Transactional Nexus in the 21st Century |
| The Current State of Factor Presence Nexus Standards | Slides: The Current State of Factor Presence Nexus Standards |
| Will 2017 Usher in Sweeping Federal Tax Reform Legislation? What Are the State Tax Implications? | Slides: Will 2017 Usher in Sweeping Federal Tax Reform Legislation? What Are the State Tax Implications? |
Tax Accounting |
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| Accounting for Advance Payments Update | Outline: Accounting for Advance Payments Update |
| Accounting for Advance Payments Update | Slides: Accounting for Advance Payments Update |
| Current Developments in Tax Accounting | Outline: Current Developments |
| How New Financial Accounting Standards Will Impact Method Changes | Outline: How New Financial Accounting Standards Will Impact Method Changes |
| Long-Term Contracts | Outline: Tax Accounting for Construction Contracts under Section 460: Recent Developments |
Tax Bridge on the Road |
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| Tax Basics Through Crowd Funding Transactions | Outline: Tax Basics Through Crowd Funding Transactions |
Tax Collection, Bankruptcy and Workouts |
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| CDP Update: No Face-To-Face Conference | Outline: Tax Collection, Bankruptcy and Workouts Committee Materials |
| Defending the Absolutes: Litigation in the United States District Courts | Outline: Tax Collection, Bankruptcy and Workouts Committee Materials |
| Quiet Title Actions: The Sword - Not a Shield! | Outline: Tax Collection, Bankruptcy and Workouts Committee Materials |
| Quiet Title Actions: The Sword - Not a Shield! | Slides: Quiet Title Actions -(18 U.S.C. §2410) and Federal Tax Liens |
Tax Exempt Financing |
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| Management Contracts – What is a Safe-Harbor, That is the Question | Outline: Management Contracts – What is a Safe-Harbor, That is the Question |
| Multipurpose Allocations in the Refunding and Pool Bond Context: What is Reasonable? | Outline: Multipurpose Allocations in the Refunding and Pool Bond Context |
Tax Policy and Simplification |
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| Parameters for Tax Reform in the New Year | Outline: Parameters for Tax Reform in the New Year |
Tax Practice Management |
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| Legal Lean Six Sigma for Law Firms | Outline: Legal Project Management: The Greatest Thing Since Sliced Bread? |
Teaching Taxation and State & Local Taxes |
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| Taxation of the Sharing Economy: Major Issues and Trends | Slides: Airbnb Tax Collection Agreements |
| Taxation of the Sharing Economy: Major Issues and Trends | Slides: Worker Misclassification: Understanding Game-Changing Consequences |
Transfer Pricing |
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| From Technology to Taxation: Interaction Between Tax, IP and Valuation in Transfers of Intangibles Between Related Parties | Slides: From Technology to Taxation: Interaction Between Tax, IP and Valuation in Transfers of Intangibles Between Related Parties |
| Transfer Pricing Issues in Latin America | Slides: Transfer Pricing Issues In Latin America |
| Transfer Pricing Litigation Through the Lens of Medtronic | Slides: Transfer Pricing Litigation Through the Lens of Medtronic |
US Activities of Foreigners and Tax Treaties |
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| Current Developments in Information Reporting | Slides: Current Developments in Information Reporting |
| Planning Under the Section 385 Regulations | Slides: Planning Under the Section 385 Regulations for Inbound Taxpayers |
Young Lawyers Forum |
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| Nuts and Bolts of Criminal Tax | Slides: Nuts and Bolts of Criminal Tax |