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