2018 Midyear Meeting

Thoughtful Insights. Useful Analysis.
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 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.

 

 

2018 Midyear Meeting - San Diego, CA

Panel TitleMaterials Title

Administrative Practice

Acknowledging the Process: A Discussion of the "Acknowledgement of Facts" IDRSlides: Acknowledging the Process: A Discussion of the Acknowledgement of Facts IDR
Dawn of a New Era Part II – the Next Round of the New Partnership Audit Rules Are Now Upon UsSlides: Dawn of a New Era Part II – the Next Round of the New Partnership Audit Rules Are Now Upon Us
Important Developments in Administrative PracticeSlides: Important Developments

Capital Recovery and Leasing

ASC 730 – R&D LB&I DirectiveSlides: LB&I Directive
Current Developments Report and Update on Pending GuidanceOutline: Current Developments

Civil and Criminal Tax Penalties

Inter-Agency Investigations with IRS-CI: Are Taxes Really the Driving Force in Your Case?Slides: Interagency Investigations with IRS-CI: Are Taxes Really the Driving Force in Your Case?
Reports of Subcommittees on Important DevelopmentsSlides: IRS Investigations & Practices
Reports of Subcommittees on Important DevelopmentsOutline: Important Civil Developments
Reports of Subcommittees on Important DevelopmentsOutline: CCTP Updates—Important Developments: Criminal
Reports of Subcommittees on Important DevelopmentsOutline: Developments in International Tax Enforcement
Skills Workshop: Preparing Witnesses to TestifySlides: Preparing Witnesses to Testify

Closely Held Businesses

280E Current Law and AnalysisSlides: 280E: Overview and Analysis
Collection Issues Affecting Estates, Donors, and DoneesOutline: Collection Issues Affecting Estates, Donors, and Donees
Employee Tax Audit ConsiderationsSlides: Employment Tax Audit Panel
Nuts and Bolts of Estate AuditsOutline: Relevant Internal Revenue Manual Sections Regarding Preparation of Estate and Gift Tax Returns and the Audit Process
Nuts and Bolts of Estate AuditsSlides: Nuts and Bolts of Estate Audits
To Be or Not to Be... a C Corporation or Pass-ThroughSlides: C Corporation or Pass Through? Analyzing the Decision in the Wake of the Tax Act of 2017
Worker Classification – the IRS, the DOL and the State of CaliforniaSlides: Worker Classification for Dentistry and Its Specialties

Corporate Tax

Cross-Border Transactions Under Sections 351, 355, and 368 - A Roadmap for The Casual TouristSlides: Cross-Border Transactions Under Sections 351, 355, and 368: A Roadmap for The Casual Tourist (Plus Tax Reform!)

Court Procedure and Practice

Appealing a Tax Case: The Important Distinctions Between Trial & Appellate StrategiesSlides: Appealing a Tax Case: The Important Distinctions Between Trial & Appellate Strategies
Current Developments in Court Procedure and PracticeOutline: Summary of Recent Opinions
Litigating Tax Issues in Bankruptcy: Possibilities and PitfallsSlides: Litigating Tax Issues in Bankruptcy: Possibilities and Pitfalls
Navigating IRS Challenges to Micro Captive InsurersSlides: Navigating IRS Challenges to Micro Captive Insurers
The Roundabout: Summons Enforcement, Privilege and Tax Court DiscoveryOutline: The Roundabout: Summons Enforcement, Privilege and Tax Court Discovery
The Roundabout: Summons Enforcement, Privilege and Tax Court DiscoverySlides: The Roundabout: Summons Enforcement, Privilege and Tax Court Discovery

Diversity

Estate Planning, Medical Expense Deductions, and Other Tax Considerations for LGBTQ+ Individuals and FamiliesSlides: Estate Planning, Medical Expense Deductions, and Other Tax Considerations for LGBTQ+ Individuals and Families
Tax Effects of the DACA Repeal on Immigrant FamiliesSlides: DACA Updates 2018
To the Shores of Tripoli: A Military Tax OverviewSlides: To the Shores of Tripoli: A Military Tax Overview

Employee Benefits

Administrative Practices UpdateOutline: Overview of Recent Changes to EPCRS
Defined Benefit Plans and Distributions UpdateOutline: Recent PBGC Legislative/Regulatory Developments
Defined Benefit Plans and Distributions UpdateSlides: DOL Audits of Missing Participants
ESOP UpdateOutline: ESOP Update
Exempt Organization and Governmental Plans UpdateOutline: Tax Cuts and Jobs Act: Excise Tax on Excessive Compensation Paid by Tax-Exempt and Governmental Employers
Exempt Organization and Governmental Plans UpdateSlides: Tax Cuts and Jobs Act: UBIT Changes for Tax Exempt Organizations
Foreign Plans and Section 402(b) – What’s an Employer to Do?Slides: Comments on the Application of Section 402(b) to Foreign Plans
Impact of Tax Reform on Executive Compensation and Employee BenefitsSlides: Impact of Tax Reform on Executive Compensation and Employee Benefits
Mergers & Acquisitions UpdateSlides: Dealing with PBGC Issues: A Practical Guide for M&A Practitioners
Mergers & Acquisitions UpdateSlides: PBGC Participant & Plan Sponsor Advocate
Misclassified EmployeesSlides: Misclassified Employees
Proposed Statement on Auditing Standards for Employee Benefit Plan AuditsOutline: Opinion and Reporting on Financial Statements of Plans Subject to ERISA
Welfare Plans and EEOC, FMLA and Leaves Issues UpdateSlides: Purchasing cooperatives of prescription drugs Opioid crisis and employers’ role in battling it
Welfare Plans and EEOC, FMLA and Leaves Issues UpdateOutline: The Rise of the Group Health Insurance Captive
Welfare Plans and EEOC, FMLA and Leaves Issues UpdateSlides: Disability Claims Regulations Update

Employment Taxes

Employment Tax Issues in DealsSlides: Employment Tax Issues in Deals

Estate and Gift Taxes

Buy-Sell Agreements for Closely Held and Family Controlled Business EntitiesOutline: Buy-Sell Agreements and Related Tax Issues for the Closely Held Business
Issue Spotting and Drafting for Flexibility in Estate Planning – both Domestic and InternationalOutline: Issue Spotting and Drafting for Flexibility in Estate Planning – both Domestic and International
Issue Spotting and Drafting for Flexibility in Estate Planning – both Domestic and InternationalSlides: Issue Spotting and Drafting for Flexibility in Estate Planning – both Domestic and International
Planning for Unmarried CouplesOutline: Estate Planning for Unmarried Couples

Exempt Organizations

Advocacy Outside the United StatesSlides: Advocacy Outside the United States
News from the IRS and TreasurySlides: News from the IRS and Treasury
Recent Developments in Hospital AuditsSlides: Recent Developments in Hospital Audits: 501(r), Executive Compensation, and UBIT/JVs
Tax SimplificationOutline: Potential Exempt Organization Impacts from the Non-EO Provisions of the TCJA: A First Cut
Tax SimplificationChart: Tax Reform Bill of 2017: Summary of Changes Affecting Tax-Exempt Organizations (TEOs)
Tax SimplificationSlides: Tax Simplification
When Private Foundation Grantees FailOutline: When Private Foundation Grantees Fail Statuatory Considerations Limiting a Grantor's Right to Enforce Use Restrictions When a Grantee Becomes Insolvent
When Private Foundation Grantees FailOutline: Protecting Private Foundation Grants When Grantees May Fail

Fiduciary Income Tax

"ING" Trusts: Legal and Practical IssuesOutline: "ING" Trusts: Legal and Practical Issues
Back to Basics: The Anatomy of a Life Insurance TrustOutline: Back to Basics: Anatomy of an Insurance Trust
Current Developments in Fiduciary Income TaxOutline: Recent Developments in Fiduciary Income Tax
Foreign Trusts: What You Don’t Know Can Hurt YouOutline: Foreign Trusts: What You Don’t Know Can Hurt You
Foreign Trusts: What You Don’t Know Can Hurt YouSlides: Foreign Trusts: What You Don’t Know Can Hurt You

Financial Transactions

"Currency" in the Digital Age: Cryptocurrency, ICOs and the Future of CommerceSlides: "Currency" in the Digital Age: Cryptocurrency, ICOs and the Future of Commerce
Issues Involving Equity-Linked and Other Complex DebtSlides: Issues Involving Equity-Linked and Other Complex Debt

Individual & Family Taxation

Easy Money? Crowdfunding and Its Tax ConsiderationsSlides: Easy Money? Crowdfunding and Its Tax Considerations
Section 104(a)(2) and the Taxation of Damages Received Pursuant to a Settlement AgreementSlides: Section 104(a)(2) and the Taxation of Damages Received Pursuant to a Settlement Agreement

Insurance Companies

Captive Insurance Companies after Avrahami: What Happens Next?Slides: Captive Insurance Companies after Avrahami: What Happens Next?

Investment Management

Disruptive Technologies Impacting Investment Management ProfessionalsSlides: Certain Regulatory Aspects: Disruptive Technologies Impacting Investment Management Professionals
The Tax Cuts and Jobs Act of 2017: Impact on the Investment Management IndustrySlides: The Tax Cuts and Jobs Act of 2017: Impact on the Investment Management Industry

Partnerships & LLCs

Hot Topics in Partnerships & LLCsSlides: Hot Topics
Tax DistributionsOutline: Tax Distributions
Tax DistributionsSlides: Tax Distributions
Transaction CostsSlides: Transaction Cost Issues Unique to Partnerships

Pro Bono & Tax Clinics

ITIN Renewal: Due Process and Language IssuesSlides: ITIN Renewal: Due Process and Language Issues
ITIN Renewal: Due Process and Language IssuesSlides: ITIN Renewal: Language Access Issues

S Corporations

Accumulated Adjustment Account, Distributions and BeyondSlides: Accumulated Adjustment Account and Beyond
Important Developments in the Federal Income Taxation of S CorporationsOutline: Important Developments in the Federal Income Taxation of S Corporations
Important Developments in the Federal Income Taxation of S CorporationsSlides: Important Developments in the Federal Income Taxation of S Corporations

Sales, Exchanges and Basis

Current Developments Relating to Sales, Exchanges & BasisOutline: Current Non-Section 1031 Developments
It’s My (Related) Party and I’ll Cry if I Want ToSlides: It’s My (Related) Party and I’ll Cry if I Want To
The Golden State of Section 1031 ExchangesSlides: Life in the Golden State (Redux): California's Take on IRC 1031
Working with Islamic FinanceSlides: Working with Islamic Finance

Section Programs

Current Developments in Individual, Corporate, Partnership and Estate & Gift TaxationOutline: Federal, Estate, Gift and Generation-Skipping Transfer Tax Recent Developments
Current Developments in Individual, Corporate, Partnership and Estate & Gift TaxationOutline: Recent Developments in Federal Income Taxation
Earthquake-quality Seismic Shift in California State Tax AppealsSlides: Earthquake Magnitude 7.0 Seismic Shift in California State Tax Appeals
The Good, the Bad, the Ugly - Comparing the Administrative Appeals Practices of the StatesSlides: The Good, the Bad, the Ugly - Comparing the Administrative Appeals Practices of the States

Standards of Tax Practice

A Comparison of the California Rules of Professional Conduct and the ABA Model Rules of Professional ConductSlides: A Comparison of the California Rules of Professional Conduct and the ABA Model Rules of Professional Conduct
Ethical Issues in Federal Tax Practice - The Government PerspectiveSlides: Ethical Issues in Federal Tax Practice - The Government Perspective
Recent Updates Regarding Attorney Solicitation and AdvertisingSlides: Recent Updates Regarding Attorney Solicitation and Advertising

State & Local Taxes

Market-Based SourcingSlides: Market-Based Sourcing: Issues Facing California and Washington
Real Estate Transfer Taxes and Changes in Entity Ownership - Avoiding PitfallsSlides: Real Estate Transfer Taxes and Changes in Entity Ownership - Avoiding Pitfalls

Tax Accounting

Comparison of Revenue Recognition Methods Between ASC 606 and Section 451Outline: Comparison of Revenue Recognition Methods between ASC 606 and Section 451
Current Developments in Tax AccountingOutline: Current Developments
Tax ReformSlides: Select Tax Accounting Tax Reform Topics

Tax Collection, Bankruptcy and Workouts

Debt-Equity Considerations for Partnerships and in BankruptcySlides: Debt-Equity Considerations for Partnerships and in Bankruptcy
Debt-Equity Considerations for Partnerships and in BankruptcyOutline: Corporate Debt-Equity Issues After Tax Reform
How to Read IRS Transcripts and Navigate Statutes of LimitationsSlides: IRS Transcripts & Statutes of Limitation
Recent Developments in Tax Collection, Bankruptcy and WorkoutsOutline: Recent Developments in Collection Including Passport Revocations, International Penalties in Collection Due Process and the Use of Private Debt Collectors

Tax Policy and Simplification

Perspectives on the Federal Income Tax SALT (State and Local Taxes) DeductionOutline: Legislative History of the SALT Deduction

Tax Practice Management

Ethics for Tax LawyersOutline: Ethics for Tax Lawyers

Teaching Taxation

Evolving Constraints on Tax AdministrationOutline: Evolving Constraints on Tax Administration
Evolving Constraints on Tax AdministrationOutline: Arguably Unresolved Doctrinal Questions Complicating IRS Tax Administration

U.S. Activities of Foreigners and Tax Treaties

Inbound Tax Planning After the Tax Cuts and Jobs Act (or What the H Happened?)Slides: Inbound Tax Planning After the 2107 Tax Act (or What the H Happened?)

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