TaxIQ

2017 Midyear Meeting

January 19-21, Orlando, FL

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

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

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

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

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

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

Current Developments in Corporate Tax Slides: Current Developments
Interesting Issues Arising Under Section 385 Slides: Section 385 Considerations

Court Procedure and Practice

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

The New Markets Tax Credit: Providing Economic Stimulus to Low-Income Communities Slides: The New Markets Tax Credit

Employee Benefits

Current Issues in Executive Compensation Slides: Hot Topics in Executive Compensation for 2017
Defined Benefit Plan and Distributions Update Outline: Recent PBGC Legislative/Regulatory Developments
Defined Benefit Plan and Distributions Update Slides: Current Trends in M&A
Defined Benefit Plan and Distributions Update Slides: PBGC Regulatory Update
ESOP Update Outline: Case Summaries
Exempt Organization and Governmental Plans Update Outline: Recent Developments Regarding Section 414(h) Pickup Contributions Under Governmental Plans
Implementation Issues Involved with the DOL Fiduciary Regulations and Related Prohibited Transaction Exemptions Slides: Implementation Issues Surrounding the DOL Conflict of Interest Fiduciary Regulations
Mergers & Acquisitions Update Outline: Employee Benefits Mergers & Acquisitions Issues and Updates
Multinational Employee Benefits & Compensation Issues Update Slides: Canada's Retirement System
Multiple Employers, PEOs and Controlled Groups Update Outline: Application of Internal Revenue Code ("Code") Section 162(m)(6) Limit on Deductions for Covered Health Insurance Providers within a Controlled Group
Welfare Plans and EEOC, FMLA and Leaves Issues Update Chart: Mental Health Parity Provisions of the 21st Century Cures Act
Welfare Plans and EEOC, FMLA and Leaves Issues Update Outline: Impact on Employer-Sponsored Group Health Benefit Plans of the MACRA Physician Payment Law and a Possible Repeal of the ACA Medicaid Expansion

Employment Taxes

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

Energy Tax Current Developments Roundtable Slides: Energy Tax Current Developments Roundtable

Estate & Gift Taxes

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

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

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

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

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

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

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

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

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

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

Partnerships & LLCs

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

Disaster Tax Issues Slides: Tax Issues Arising From Disasters

Real Estate

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

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

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

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

Ethical Issues in Federal Tax Practice - The Government Perspective Slides: Ethical Considerations in IRS Settlement Negotiations

State & Local Taxes

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

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

Tax Basics Through Crowd Funding Transactions Outline: Tax Basics Through Crowd Funding Transactions

Tax Collection, Bankruptcy and Workouts

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

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

Parameters for Tax Reform in the New Year Outline: Parameters for Tax Reform in the New Year

Tax Practice Management

Legal Lean Six Sigma for Law Firms Outline: Legal Project Management: The Greatest Thing Since Sliced Bread?

Teaching Taxation and State & Local Taxes

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

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

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

Nuts and Bolts of Criminal Tax Slides: Nuts and Bolts of Criminal Tax