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?)