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2010 Midyear Meeting

January 21-23, San Antonio, TX

Thoughtful Insights. Useful Analysis.

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 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.

2010 Midyear Meeting, San Antonio, TX

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Administrative Practice

Employment Tax Audits

Selected Recent Developments in Administrative Practice

How To Succeed In The Fast Track Settlement Program By Really Trying

Audits in the Age of Electronic Filing?

Affiliated & Related Corporations

Panel Slides

Banking & Savings Institutions

Hot Topics in Federal Tax Controversy

Civil & Criminal Tax Penalties

Capital Recovery and Leasing – Updates

Panel Materials

Panel Presentation

Important Developments - Criminal Tax Penalties

Reports of Subcommittees on Important Developments

The IRS Wealth Squad - Holistic Taxpayer Analysis

Closely Held Businesses

“But IRS I Only Own Part of the Property!” - The Impact of Title of Property on Tax Debt – IRS and Bankruptcy Rules

Ethical Issues in Representing Taxpayers before IRS Collection, Exam and other Divisions

Corporate Tax

Recent Corporate Tax Developments

The Economic Substance Doctrine

Court Procedure & Practice

Transfer Pricing Litigation

Current Developments

Application of Temp. Treas. Reg. § 301.6501(e)-1T(a)(1)(iii) in Smith v. Commissioner

Alamo Revisited

Employee Benefits

Assessing Risk in Executive Compensation

Compensation and Benefits for Partners/Partnerships: Some Good, Some Bad and Some Ugly

Conversation with Employee Benefits Security Administration

Hot Employee Benefits Topics

Ethics Update

Compensation and Benefits for Partners/Partnerships: Some Good, Some Bad and Some Ugly

Employee Benefits Subcommittee on Defined Benefit Plans

Recent PBGC Regulatory Developments (January 1, 2009, to December 31, 2009)

Employee Benefits Subcommittee on Distributions

Employee Benefits Distributions Update

Employee Benefits Subcommittee on EEOC Issues/FMLA, Military and Other Leaves

Employee Benefits EEOC, FMLA and Military Leave Update

Employee Benefits Subcommittee on Foreign and International Issues

Employee Benefits International Update

Employee Benefits Subcommittees on ESOPs, Fiduciary Responsibility/Plan Investments and Litigation

Employee Benefits Fiduciary Responsibility and Litigation Update

Employee Benefits Subcommittees on Executive Compensation and Fringe Benefits and Federal Securities Laws Issues

Employee Benefits Executive Compensation, Fringe Benefits and Securities Law Update

SEC Proxy Disclosure Update (Slides)

Employee Benefits Subcommittee on Welfare Benefits Design, Funding and Regulation Update

COBRA ARRA Extension: Better Late Than Never!

Employment Taxes

The IRS Employment Tax Examination

Important Developments (September, 2009 - January, 2010)

Estate & Gift Taxes

Current Developments in Estate Planning

State Death Taxes - A "Crazy Quilt"

Supplemental Estate Tax Returns - Are They Really Required?

Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittee

Subcommittee Discussion

Exempt Organizations

Foreign Activities and Withholding -- When and How an Exempt Organization Should Withhold US Tax on Payments to Foreign Entities

Accounting Developments Affecting Charities and 990 Reporting

Proposed Regulations on Supporting Organizations

Update on Social Clubs and Section 501(c)(7)

Fiduciary Income Tax

Inbound, Outbound and Rebound: Section 679 and the Taxation of Foreign Trusts with US Beneficiaries

Risks and Opportunities for Private Trust Companies and Family Offices from State and Federal (Non-Tax) Legislative Developments and Proposals

Post Mortem Estate Planning - Executors' Elections (How to Avoid Surcharge Litigation)

Recent Developments in Fiduciary Income Tax

Financial Transactions

Debt-for-Debt Exchanges: History, Current Law, Policy Issues

Current Developments in Financial Transactions

Panel Slides

Foreign Activities of US Taxpayers

Unwind Planning for Potential Check-the-Box and Section 954(c)(6) Repeal

Panel Presentation

Foreign Lawyers Forum

Panel Presentation

Individual & Family Income Taxes

Cancellation of Debt Income: Understanding the Complex Tax Consequences and Reporting Requirements of Debt Discharge

Investment Management

Trading in Energy Derivatives and Electricity Contracts

Investment Company Update: Foreign Account Tax Compliance Act of 2009; Securities Cost Basis Regulations

Preparer Regulation 2010: Section 6694, Circular 230 and the States (!)

Hedge Funds and Offshore Funds: Cross Border Lending

Joint: FAUST, FLF, Transfer Pricing and USAFTT

Survey of 2009 CDP Cases

Current Developments in US International Tax (Slides)

Transfer Pricing Current Developments

Joint: Young Lawyers Forum & Diversity

Keeping Your Nose Clean: How to Stay Out of Jail

Low Income Taxpayers

Summary of IRS Return Preparer Review: Findings and Recommendations

Section 6015(f) Lantz Update

Opening Remarks by the Chair

Partnerships & LLCs

Panel Overview and Paper

Partner/Partnership Wars: Ethical, Professional and Tax Aspects of Inconsistent Reporting Positions Involving Pass-through Entities

Hot Topics

Feel the Love: Allocating COD Income Among Partners

Your Built-in Gain is My Built-in Pain: Section 704(c) Issues and Insights

Pro Bono

Ethics of Limited Representation

Real Estate

Sale Leasebacks – An Update on the Current Market

LLCs in Distress – Character Matters (and so does Characterization) in a Down Economy

Current Real Estate Tax Issues

Buying Debt to Buy Property

S Corporations

Restructuring Debt of an S Corporation

Important Developments

State Taxation of Nonresident Shareholders on Sale of S Corporation Stock

Impact of New Tax Rates on Choice of Entity Issues

Sales, Exchanges & Basis

Panel Presentation

Current Developments

Aircraft Like-Kind Exchanges that Require Holding Title

Current Developments in Like-Kind Exchanges

Section Program: Due Diligence: State and Local Tax Issues Affecting Business Acquisitions

Due Diligence Guide (Sample)

Panel Discussion

Section Program: Change We'd like to Believe in: the Prospects for Federal Civil Tax Penalty Reform

Panel Discussion

Section Program: Current Developments in Individual, Corporate, Partnership and Estate & Gift Taxation

Panel Discussion

Standards of Tax Practice

Young Lawyers Panel: Representing Practitioners in Ethics and Disciplinary Actions

Help! Legal Ethics Problems Mid-Trial

State & Local Taxes

Responding to Unique Tax Collection Procedures

What’s That, You Say? New Property Tax Regimes

State Administrative Procedure Acts: Procedural Avenues to Attack Faulty Regulations and Tax Assessments

Trend Towards Gross Receipts and Value Added Taxes in the Business Tax Reform Movement

Austin Court of Appeals Ruling Creates New Opportunities for Texas Taxpayers to Be Heard

Tax Accounting

Credit Cards—Are Fees for a Service or for the Use of Money and When Are They Taken into Account?

Current Developments

Uniform Cost Capitalization under Section 263A

Tax Exempt Financing

Report on Standards of Practice

IRS Enforcement, Compliance and Tax Administration Update

IRS, Department of Treasury and Legislative Update

Tax Policy & Simplification

Corporate and International Tax Reform: Long, Medium, and Short Term Proposals

Death (Taxes) be Not Proud: Estate Tax Reform, a National and Comparative Perspective

Teaching Taxation

Taxes and Injuries: The Intersection of Tax Policy and Tort Policy

Transfer Pricing

Transfer Pricing Adjustments: Primary, Correlative and Conforming

Walking the Tight Rope: Transfer Pricing, FIN 48, Work Product Privilege, Spoliation

US Activities of Foreigners and Tax Treaties

Foreign Inbound Investment in Energy and Infrastructure

State and Local Tax Issues Affecting Inbound Foreign Investment