TaxIQ

    2018 Midyear Meeting

    February 8-10, San Diego, 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 PDF 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.

    Materials by Committee

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

    Capital Recovery and Leasing
    ASC 730 – R&D LB&I Directive Slides: LB&I Directive
    Current Developments Report and Update on Pending Guidance Outline: 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 Developments Slides: IRS Investigations & Practices
    Reports of Subcommittees on Important Developments Outline: Important Civil Developments
    Reports of Subcommittees on Important Developments Outline: CCTP Updates—Important Developments: Criminal
    Reports of Subcommittees on Important Developments Outline: Developments in International Tax Enforcement
    Skills Workshop: Preparing Witnesses to Testify Slides: Preparing Witnesses to Testify

    Closely Held Businesses
    280E Current Law and Analysis Slides: 280E: Overview and Analysis
    Collection Issues Affecting Estates, Donors, and Donees Outline: Collection Issues Affecting Estates, Donors, and Donees
    Employee Tax Audit Considerations Slides: Employment Tax Audit Panel
    Nuts and Bolts of Estate Audits Outline: Relevant Internal Revenue Manual Sections Regarding Preparation of Estate and Gift Tax Returns and the Audit Process
    Nuts and Bolts of Estate Audits Slides: Nuts and Bolts of Estate Audits
    To Be or Not to Be... a C Corporation or Pass-Through Slides: 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 California Slides: Worker Classification for Dentistry and Its Specialties

    Corporate Tax
    Cross-Border Transactions Under Sections 351, 355, and 368 - A Roadmap for The Casual Tourist Slides: 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 Strategies Slides: Appealing a Tax Case: The Important Distinctions Between Trial & Appellate Strategies
    Current Developments in Court Procedure and Practice Outline: Summary of Recent Opinions
    Litigating Tax Issues in Bankruptcy: Possibilities and Pitfalls Slides: Litigating Tax Issues in Bankruptcy: Possibilities and Pitfalls
    Navigating IRS Challenges to Micro Captive Insurers Slides: Navigating IRS Challenges to Micro Captive Insurers
    The Roundabout: Summons Enforcement, Privilege and Tax Court Discovery Outline: The Roundabout: Summons Enforcement, Privilege and Tax Court Discovery
    The Roundabout: Summons Enforcement, Privilege and Tax Court Discovery Slides: The Roundabout: Summons Enforcement, Privilege and Tax Court Discovery

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

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

    Employment Taxes
    Employment Tax Issues in Deals Slides: Employment Tax Issues in Deals

    Estate and Gift Taxes
    Buy-Sell Agreements for Closely Held and Family Controlled Business Entities Outline: Buy-Sell Agreements and Related Tax Issues for the Closely Held Business
    Issue Spotting and Drafting for Flexibility in Estate Planning – both Domestic and International Outline: 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 International Slides: Issue Spotting and Drafting for Flexibility in Estate Planning – both Domestic and International
    Planning for Unmarried Couples Outline: Estate Planning for Unmarried Couples

    Exempt Organizations
    Advocacy Outside the United States Slides: Advocacy Outside the United States
    News from the IRS and Treasury Slides: News from the IRS and Treasury
    Recent Developments in Hospital Audits Slides: Recent Developments in Hospital Audits: 501(r), Executive Compensation, and UBIT/JVs
    Tax Simplification Outline: Potential Exempt Organization Impacts from the Non-EO Provisions of the TCJA: A First Cut
    Tax Simplification Chart: Tax Reform Bill of 2017: Summary of Changes Affecting Tax-Exempt Organizations (TEOs)
    Tax Simplification Slides: Tax Simplification
    When Private Foundation Grantees Fail Outline: 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 Fail Outline: Protecting Private Foundation Grants When Grantees May Fail

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

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

    Individual & Family Taxation
    Easy Money? Crowdfunding and Its Tax Considerations Slides: Easy Money? Crowdfunding and Its Tax Considerations
    Section 104(a)(2) and the Taxation of Damages Received Pursuant to a Settlement Agreement Slides: 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 Professionals Slides: Certain Regulatory Aspects: Disruptive Technologies Impacting Investment Management Professionals
    The Tax Cuts and Jobs Act of 2017: Impact on the Investment Management Industry Slides: The Tax Cuts and Jobs Act of 2017: Impact on the Investment Management Industry

    Partnerships & LLCs
    Hot Topics in Partnerships & LLCs Slides: Hot Topics
    Tax Distributions Outline: Tax Distributions
    Tax Distributions Slides: Tax Distributions
    Transaction Costs Slides: Transaction Cost Issues Unique to Partnerships

    Pro Bono & Tax Clinics
    ITIN Renewal: Due Process and Language Issues Slides: ITIN Renewal: Due Process and Language Issues
    ITIN Renewal: Due Process and Language Issues Slides: ITIN Renewal: Language Access Issues

    S Corporations
    Accumulated Adjustment Account, Distributions and Beyond Slides: Accumulated Adjustment Account and Beyond
    Important Developments in the Federal Income Taxation of S Corporations Outline: Important Developments in the Federal Income Taxation of S Corporations
    Important Developments in the Federal Income Taxation of S Corporations Slides: Important Developments in the Federal Income Taxation of S Corporations

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

    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
    Earthquake-quality Seismic Shift in California State Tax Appeals Slides: Earthquake Magnitude 7.0 Seismic Shift in California State Tax Appeals
    The Good, the Bad, the Ugly - Comparing the Administrative Appeals Practices of the States Slides: 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 Conduct Slides: 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 Perspective Slides: Ethical Issues in Federal Tax Practice - The Government Perspective
    Recent Updates Regarding Attorney Solicitation and Advertising Slides: Recent Updates Regarding Attorney Solicitation and Advertising

    State & Local Taxes
    Market-Based Sourcing Slides: Market-Based Sourcing: Issues Facing California and Washington
    Real Estate Transfer Taxes and Changes in Entity Ownership - Avoiding Pitfalls Slides: Real Estate Transfer Taxes and Changes in Entity Ownership - Avoiding Pitfalls

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

    Tax Collection, Bankruptcy and Workouts
    Debt-Equity Considerations for Partnerships and in Bankruptcy Slides: Debt-Equity Considerations for Partnerships and in Bankruptcy
    Debt-Equity Considerations for Partnerships and in Bankruptcy Outline: Corporate Debt-Equity Issues After Tax Reform
    How to Read IRS Transcripts and Navigate Statutes of Limitations Slides: IRS Transcripts & Statutes of Limitation
    Recent Developments in Tax Collection, Bankruptcy and Workouts Outline: 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) Deduction Outline: Legislative History of the SALT Deduction

    Tax Practice Management
    Ethics for Tax Lawyers Outline: Ethics for Tax Lawyers

    Teaching Taxation
    Evolving Constraints on Tax Administration Outline: Evolving Constraints on Tax Administration
    Evolving Constraints on Tax Administration Outline: 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?)