1.5.4.1 Meeting Attendance Counts - American Bar … Transfer Pricing, Double Taxation, and Other Complex Multi-Country Tax Matters in a Post-BEPS World 115 Fri Administrative Practice

1.5.4.1 Meeting Attendance Counts

N/C = No Count Recorded

2016 May Meeting

Day Committee/Group Panel/Topic Headcount Fri Administrative Practice Important Developments 100

Fri Administrative Practice

Managing Transfer Pricing, Double Taxation, and Other Complex Multi-Country Tax Matters in a Post-BEPS World 115

Fri Administrative Practice LB&I Reorganization and Audit Redesign 120

Fri Administrative Practice and Court Procedure & Practice Committee Luncheon 99

Fri Affiliated & Related Corporations Coffee and Doughnuts Primer 40

Fri Affiliated & Related Corporations

Stock Basis and Boot Considerations Inside Consolidation 60

Fri Affiliated & Related Corporations Consolidated Group Continuation Issues 90

Fri Affiliated & Related Corporations Current Events 110

Fri Banking & Savings Institutions New Proposed Section 385 Regulations 45

Fri Banking & Savings Institutions New Proposed Section 305(c) Regulations 40

Fri Capital Recovery & Leasing Current Developments Report and Update on Pending Guidance 34

Fri Capital Recovery & Leasing Examination Items and Issues Pertaining to Tangible Property 56

Fri Capital Recovery & Leasing The Lease Accounting Standard and Its Impact on Taxpayers 44

Sat Civil and Criminal Tax Penalties

Reports of Subcommittees on Important Developments 100


Internal Revenue Service, Criminal Investigation - Update 108


U.S. Department of Justice, Tax Division - Update 108


Endless War: The Status of the IRS/DOJ Campaign Against Foreign Assets and Accounts 108


Turning the Tables: The United States as a Tax Haven Destination 112

Fri Closely Held Businesses Best Practices for the Planning, Valuation and Sale of Personal Goodwill 46



Fri Closely Held Businesses Dealing with the IRS Collection Division: An Update on IRS Collection Procedures 28

Sat Corporate Tax The Future of IRS Spin-off PLR Practice 160

Sat Corporate Tax A Little of This, A Little of That: Cherry-Picking Gains and Losses in Transactions 140

Sat Corporate Tax Where Have All the Factors Gone? The Proposed Section 385 Regulations 240

Fri Court Procedure and Practice Most Litigated Issues in Tax Court Cases 101 Fri Court Procedure and Practice Current Developments 152

Fri Court Procedure and Practice Protective Orders: Necessary Evil or Unnecessary Burden in Tax Court? 120

Fri Court Procedure and Practice Tax Court History and Tribute 160

Fri Court Procedure and Practice

IT’S ALIVE! – Exploring Exceptions to the Statutes of Limitations to "Revive" Otherwise Time-Barred Claims 94


Litigating Partnership Tax Cases Under the New Partnership Tax Rules of the Bipartisan Budget Act of 2015 89

Fri Diversity

Try to See It My Way: Technical, Policy and Advocacy Perspectives on the Home Mortgage Interest Deduction for Same Sex Couples 26

Fri Diversity Litigating Affordable Care Act Cases 17

Fri Diversity The PATH Act: Changes Affecting Immigrant Families and The Challenges Ahead 19

Fri Employee Benefits Defined Contribution Plans Update 45

Fri Employee Benefits Executive Compensation, Fringe Benefits and Federal Securities Law Update 50

Fri Employee Benefits Administrative Practices Update 50 Fri Employee Benefits Litigation Update 22

Fri Employee Benefits Multiple Employers, PEOs and Controlled & Affiliated Service Groups Update 25

Fri Employee Benefits Health and Welfare Benefit Plans Update 47

Fri Employee Benefits Exempt Organization and Governmental Plans Update 25

Fri Employee Benefits Fiduciary Responsibilities Update 40 Fri Employee Benefits Legislative Update 13

Fri Employee Benefits Defined Benefit Plan and Distributions Update 45



Fri Employee Benefits Corporate Counsel Forum 8 Fri Employee Benefits ESOP Update 18 Fri Employee Benefits Mergers & Acquisitions Update 39

Fri Employee Benefits Multinational Employee Benefits & Compensation Issues Update 14

Fri Employee Benefits

Department of Labor Employee Benefits Security Administration & Pension Benefit Guaranty Corporation Updates 107

Fri Employee Benefits The Fiduciary Regulations 142

Fri Employee Benefits Department of Treasury/IRS Hot Topics 118

Sat Employee Benefits

Necessary Plan Language in Light of Recent Guidance from the Supreme Court and Lower Courts 65

Sat Employee Benefits IRS and Department of Treasury Technical Sessions 70

Sat Employee Benefits Department of Labor Regulation of ERISA Disability Claims and Related Litigation 55

Fri Employment Taxes Federal Employment Tax Update 46 Fri Employment Taxes R&D Credit and FICA Taxes 37

Fri Employment Taxes

The Early Interaction Initiative: Accelerating IRS Collection Intervention for Unpaid Employment Tax Liabilities 17

Fri Employment Taxes Worker Classification and Section 530 20 Fri Energy & Environmental Taxes Emerging Issues in Oil & Gas Taxation 45 Fri Energy & Environmental Taxes Hot Topics in Renewables 47 Fri Estate & Gift Taxes Current Developments 46

Fri Estate & Gift Taxes

Oh, What a Relief It Is: Curing Estate Plans That No Longer Make Sense in Light of the American Taxpayer Relief Act of 2012 75

Fri Estate & Gift Taxes Unpacking the Myths and Mysteries of Chapter 14 70

Fri

Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittee Committee Luncheon 42

Fri

Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittee How to Prepare and Submit a PLR 49

Fri Exempt Organizations News from the IRS and Treasury 105 Fri Exempt Organizations News from the Hill 95

Fri Exempt Organizations Donor-Advised Funds: Priority Issues for Regulatory Guidance 107



Fri Exempt Organizations Committee Luncheon 87

Fri Exempt Organizations Form 990 Schedule B: Balancing Benefits and Burdens 90

Fri Exempt Organizations IRS Assessment of Governance Practices 54

Fri FAUST, FLF, Transfer Pricing & USAFTT

Current International Tax Developments, Including Section 385 Proposed Regulations 130

Sat Fiduciary Income Tax Current Developments 50 Sat Fiduciary Income Tax New Consistency of Basis Regulations 53

Sat Fiduciary Income Tax Fiduciary Income Tax Aspects of Lifetime Gifting and Education Funding Strategies 27

Sat Fiduciary Income Tax Total Return Unitrusts - Where, When and How to Use Them 37

Fri Financial Transactions The Uncertain Scope of the Foreign Currency Contract Rules 78

Fri Financial Transactions

Reasoning by Analogy: The Cubbyhole Approach to Innovative Financial Products and Other Transactions 80


The Proposed Regulations Under Section 385: What You Need to Know Even if You Couldn’t Care Less About Inversions 80

Fri Foreign Activities of US Taxpayers

"Country-by-Country" Reporting Under Section 6038 121


Section 7874 Temporary Regulations on Corporate Inversions 122

Sat Foreign Lawyers Forum The 2016 EU Anti-Tax Avoidance Package: Find Out What It Means to You 48

Fri Individual & Family Taxation Important Developments 26 Fri Individual & Family Taxation Crime and Marriage 36 Fri Individual & Family Taxation Women and Tax 45 Fri Insurance Companies What is Insurance? 43 Fri Insurance Companies Legislative Update 37 Fri Insurance Companies Insurance Company Reserves 27

Fri Investment Management Unrelated Debt-Financed Income Issues for Private Investment Funds 38

Fri Investment Management Partnership Allocations and Investment Funds 61

Fri Investment Management Updates from the Internal Revenue Service and Investment Company Institute 39

Thurs Low Income Taxpayers Representation Workshop State Tax Issues 45



Thurs Low Income Taxpayers Representation Workshop Property Tax Issues 39

Thurs Low Income Taxpayers Representation Workshop Criminal Tax Issues 45

Thurs Low Income Taxpayers Representation Workshop Addressing ACA Problems in Non-IRS Fora 34

Fri Partnerships & LLCs Disguised Sales of Partnership Interests - Where are We Now? 150

Fri Partnerships & LLCs Partnership-to-Partner (Non?-)Attribution: Is There a “Theory of Everything”? 150

Fri Partnerships & LLCs Recourse or Nonrecourse Matters in the Gasification of Debt 150

Fri Partnerships & LLCs Conversions Are Not Always Changes 150

Sat Partnerships & LLCs

Duties, Decisions and (Deterrable?) Disasters for Partnership Representatives of LLCs and LLPs Under the New Audit Rules: What No One Envisioned 80

Sat Pro Bono & Tax Clinics Update from the Tax Court 41

Sat Pro Bono & Tax Clinics Reflecting on Low Income Tax Clinics and Celebrating Professor Kathryn Sedo 54

Sat Pro Bono & Tax Clinics Jurisdictional Issues 53 Fri Real Estate Hot Topics 99

Fri Real Estate PATH Act – FIRPTA, REIT Technical and Spin-Offs 107

Fri Real Estate Bad Boys: Whatcha Gonna Do? 126

Fri Real Estate New Partnership Audit Provisions – Drafting Considerations 155

Fri Real Estate and Partnerships & LLCs Committee Luncheon

Fri S Corporations Important Developments 211 Fri S Corporations Hot Topics Relating to S Corporations 113

Fri S Corporations Audit Risks of an S Corporation and Its Shareholders 50

Sat Sales, Exchanges & Basis Current Developments in Sales, Exchanges & Basis 42

Sat Sales, Exchanges & Basis

Use of Delaware Statutory Trusts in Non-Syndicated Exchange and Drop-and-Swap Situations 45

Sat Sales, Exchanges & Basis Dealing with Unrecaptured Section 1250 Gain in Drop-Swap Cash-Outs 36

Sat Sales, Exchanges & Basis A Hot Topic: Cuban Claims and Section 1033 19 Sat Section Program Section Luncheon & Plenary Session 183



Sat Section Program

Welcome to International Tax: Fundamentals of Inbound, Outbound, and Tax Treaties: Inbound Taxation 85

Sat Section Program

Welcome to International Tax: Fundamentals of Inbound, Outbound, and Tax Treaties: Outbound Taxation 80

Sat Section Program

Welcome to International Tax: Fundamentals of Inbound, Outbound, and Tax Treaties: Tax Treaties 64

Fri Standards of Tax Practice Ethical Issues in Federal Tax Practice – The Government Perspective 125

Fri Standards of Tax Practice

Data Security, Client Confidences and Ethics Rules Applicable to the Protection of Client Information 125

Fri Standards of Tax Practice What’s the Risk? The Ethics of Advising Clients on Audit Risk 125

Fri State & Local Taxes

State Sovereign Immunity in the Tax World: An Update on California Franchise Tax Board v. Hyatt 48

Fri State & Local Taxes

Tax Audits of Attorney Files – What Keeping Client Confidences Could Cost You: Ethical and Practical Issues 125

Fri State & Local Taxes New IRS Partnership Audit Rules: Federal and State Tax Complexities 89

Fri State & Local Taxes Behind the Scenes at the Supreme Court in SALT – A Peak Behind the Curtain 55

Sat State & Local Taxes Practitioner’s Roundtable 45 Fri Tax Accounting Current Developments 60

Fri Tax Accounting Fines, Penalties and Costs to Settle Litigation 54

Fri Tax Accounting When Is a Trade or Business Separate and Distinct? 49

Fri Tax Accounting Recent Developments in Accounting Method Change Procedures 44

Thurs Tax Bridge to Practice A Conversation with Caroline Ciraolo 70

Thurs Tax Bridge to Practice Tax Tales 2: More Seminal Cases of Subchapter C 58

Thurs Tax Bridge to Practice The Administrative Tax Collection Case 71

Thurs Tax Bridge to Practice Tax Controversy 101: The Tax Court Cases that Every Practitioner Should Know 50



Fri Tax Collection, Bankruptcy and Workouts

IRS – Field Collection: Changes in How the IRS goes about “Collection Enforcement” – Administrative and The Lawyers - “Future State” and Elimination of the “SAUSA” Program: A Brave New World? 50

Fri Tax Collection, Bankruptcy and Workouts

The Tax Court’s Review of Notices of Determination: Judicial Oversight of the IRS Collection Due Hearing – The Bedrock Cases and the Practical Impact on Preparing for a Collection Due Process Hearing 37

Fri Tax Collection, Bankruptcy and Workouts Recent Developments: Judicial Decisions 26

Fri Tax Exempt Financing Legislative, Treasury and Internal Revenue Service Update 39

00Fri Tax Exempt Financing

Tax Issues in Seaport and Airport Financings: "It Is Not Always a Carnival When You Make a Deal with Royal Caribbean, Even If You Are Norwegian." 15

Fri Tax Policy and Simplification Prospects for Tax Legislation in a New Administration 60

Sat Tax Practice Management The Curse of the Billable Hour: Are You Ready for Alternative Fee Arrangements? 30

Fri Teaching Taxation EU State Aid Investigations: Perspectives from both Sides of the Atlantic 75

Fri Teaching Taxation

How to Combine International and Comparative Taxation into “Domestic” US Law Schools' Tax Courses? 22

Fri Transfer Pricing BEPS and Its Impact on Transfer Pricing for the Financial Services Sector 145

Fri Transfer Pricing BEPS and Transfer Pricing Implications for State and Local Tax (Part II) 146

Fri US Activities of Foreigners & Tax Treaties What’s New in the 2016 US Model Treaty? 75

Fri US Activities of Foreigners & Tax Treaties The FIRPTA Provisions of the PATH Act 75

Fri Young Lawyers Forum Tips for Working with the Tax Press 28



2016 Midyear Meeting Day Committee/Group Panel/Topic Headcount


APA and the Administrative Process: How Has Altera Altered the Landscape?

72

Fri

Administrative Practice

The Dawn of A New Era for Partnership Examinations

92

Fri Administrative Practice Important Developments 114


California Administrative Agencies and Effective Administrative Practice

106

Fri

Administrative Practice and Court Procedure & Practice

Committee Luncheon

75

Fri

Affiliated & Related Corporations

The Use of Partnerships by Consolidated Groups (Part II)

Fri


Several Liability and Related Issues

Fri

Banking & Savings Institutions, Financial

Committee Luncheon

Fri

Banking and Savings Institutions

Recent Developments: STARS Transactions and Section 871(m) Issues and Concerns

Fri


FATCA Updates for Financial Institutions

Fri


Bank Regulatory Capital

Fri

Bankruptcy and Workouts

Late Filed Return Judicial Doctrine and the IRS’s Substitute for Return Process

6

Fri


Bankruptcy Rules That Tax Practitioners Should Know: (Other than the 3 year, 240-day and 2- year Rules)

12 Fri Bankruptcy and Workouts Loss Planning for Corporate Taxpayers 16

Fri

Capital Recovery and Leasing

Current Developments Report and Update on Pending Guidance

25

Fri


The Treatment of Lease Termination Costs post- ABC Beverage Corp

25

Fri


Tangible Property Regulations – Focus on Rev. Proc. 2015-56

27


Reports of Subcommittees on Important Developments

103

Sat

Civil and Criminal Tax Penalties

To File or Not to File – That is the Question

103

Sat


Civil and Criminal Employment Tax Enforcement Efforts – Employers Beware

103

Sat


Litigating the Accuracy Penalty

103



Fri


Committee Luncheon

57

Fri

Closely Held Businesses

The Convergence of Immigration & Tax Issues for Closely Held Businesses: Pitfalls for Employers

Fri


Worker Classification – What's Old is New Again

Fri


When the Past is Not the Past: Cleaning Up Our Client’s Past Bad Behavior

32

Fri


Dealing with a Decedents Tax Fraud: Cleaning up our Dead Client’s Bad Behavior

15

Sat Corporate Tax Current Developments 83

Sat Corporate Tax

“Mere Change”: The New Final Section 368(a)(1)(F) Regulations

96

Sat

Corporate Tax

"Tightening the Noose": IRS Proposes Regulations on Outbound Transfers of Foreign Goodwill and Workforce in Place

69


Who's the Boss? Litigating Employment Tax Cases

70

Fri

Court Procedure and Practice

Current Developments

64

Fri


Disclosure, FOIA and Tax Litigation

70

Fri


The Other Shoe is Dropping - Criminal Enforcement and Civil Assessment and

66

Fri

Court Procedure and Practice Roundtable Discussion

Decision Documents and Their Aftermath

Fri

Diversity

The Earned Income Tax Credit: Delivering the Anti-Poverty Mandate

22

Fri

Diversity

Elimination of Bias in the Profession: The LGBT Ally Toolkit

25

Fri

Diversity

FATCA’s Expanding Global Reach: A Concern for Big and Small

12

Fri

Diversity

Committee Luncheon

25

Fri

Employee Benefits

Defined Contribution Plans Update

45

Fri

Employee Benefits

Executive Compensation, Fringe Benefits and Federal Securities Law Update

60

Fri

Employee Benefits

Administrative Practices Update

33


Litigation Update

17

Fri

Employee Benefits

Multiple Employers, PEOs and Controlled Groups Update

11



Fri

Employee Benefits

Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update

29


Defined Benefit Plan and Distributions Update

22

Fri

Employee Benefits

Exempt Organization and Governmental Plans Update

17 Fri Employee Benefits Fiduciary Responsibilities Update 13

Fri

Employee Benefits

Legislative Update

2

Fri

Employee Benefits

Corporate Counsel Forum

8

Fri

Employee Benefits

ESOP Update

15

Fri

Employee Benefits

Multinational Employee Benefits & Compensation Issues Update

Fri

Employee Benefits

Mergers & Acquisitions Update

9


DOL Proposed Fiduciary Regulation and Prohibited Transaction Exemptions

51

Fri

Employee Benefits

Employee Classification under the ACA and NLRB Rules

69

Fri

Employee Benefits

Pension Benefit Guaranty Corporation / Department of Treasury / Internal Revenue

71

Sat

Employee Benefits

Hot Topics for Proxy Season 2016

50

Sat

Employee Benefits

Current and Future Developments Under the Affordable Care Act and for Health and Welfare Plans: Information Reporting, Market Reforms, Wellness Plans, and the Cadillac Tax

60 Sat Employee Benefits Upcoming US Supreme Court Decisions 50

Fri

Employment Taxes

Federal Employment Tax Update

30

Fri

Employment Taxes

The Technology Industry and Fringe Benefits

20

Fri Employment Taxes The Gig Economy and Worker Classification 15 Fri Estate & Gift Taxes Current Developments 21



Fri

Estate & Gift Taxes

Power to the People! An Exploration of the Uses of Powers of Appointment in Estate Planning

25

Fri Estate & Gift Taxes

Estate Planning in Hollywood: Special Considerations for Entertainment Clients

32

Fri

Estate & Gift Taxes

Coming Soon to Your State: Community Property

32

Fri

Estate & Gift Taxes and Fiduciary Income Tax

Estate Planning Practice Issues: An Open Forum Discussion

30

Fri

Estate & Gift Taxes and Fiduciary Income Tax

Committee Luncheon

26

Fri

Exempt Organizations

Roundtable Discussion of Current Developments

35

Fri



24

Fri



35 Fri Exempt Organizations News from the IRS and Treasury 75

Fri


Foundation Grants to Foreign Charities: A New Era Under the Final Equivalency Determination Regulations

60 Fri Exempt Organizations Difficult Public Support Test Issues 55 Fri Exempt Organizations Committee Luncheon 60

Fri


The Commerciality Doctrine: Blessing or Curse?

50

Fri


Investing in the Future: What Does Mission Have to Do with It?

50

Sat Fiduciary Income Tax Current Developments 24

Sat Fiduciary Income Tax

Strategies for Dealing with Trust UNI: How to Prevent Income Tax Armageddon

24

Sat

Fiduciary Income Tax

The Beneficiary Defective Irrevocable Trust (“BDIT”) – How does It Work and Who Is It Best Suited For? Should You Just BDIT?

24

Sat


What the FATCA? An Update on Foreign and Informational Reporting Relevant to Estate Planners

24


All Things Bright and Beautiful: Applying the Final Section 871(m) Regulations Beyond Single Name

25

Fri

Financial Transactions

The Cottage Savings Regulations Revisited

28

Fri Financial Transactions The Straddle Rules at Middle Age 25


Taxing Foreign Goodwill & Going Concern Value under Section 367



Fri

Foreign Activities of US Taxpayers

Tax Issues Arising in the Clouds: When the Digital Economy & International Tax Collide

Fri

Foreign Lawyers Forum

The 2016 EU Tax Update - All You Can Eat in Just Two Hours

37

Fri

Individual and Family Taxation

New Approaches and Alternatives to Innocent Spouse Relief

20

Fri Individual and Family Taxation

Late Filed Returns

30

Fri


Athletes, Entertainers and the IRS

30

Fri

Insurance Companies

P&C Loss Reserves

18

Fri

Insurance Companies

International Reporting Issues

8 Fri Insurance Companies Product Update 19

Fri

Investment Management

Offshore Issues for Private Equity Funds

40

Fri


Current Issues for Funds Investing in Index- Linked Financial Transactions

20 Fri Investment Management Current Issues for Investment Companies 13

Fri

Partnerships & LLCs

Partnerships With Related Foreign Partners - Notice 2015-54

Fri

Partnerships & LLCs

Allocations and Varying Interests – the 706 Regulations

Fri

Partnerships & LLCs

What Am I? – Dual Status as Partner and Employee

Fri

Partnerships & LLCs

Hot Topics

Sat

Partnerships & LLCs

Use of Section 336(e) Elections by Pass-through Entity Acquirers

20

Sat

Partnerships & LLCs

Dual Status Partners

20

Sat Pro Bono & Tax Clinics

National Taxpayer Advocate’s Annual Report to Congress

42

Sat Pro Bono & Tax Clinics Earned Income Credit Issues and Updates 42 Sat Pro Bono & Tax Clinics Immigration Issues 42 Fri Real Estate Real Estate Intangibles 59 Fri Real Estate Capital Gain Planning 67

Fri

Real Estate

Fractions Rule Update

61



Fri

Real Estate

Casualties and Condemnations

46

Fri Real Estate and Partnerships & LLCs

Committee Luncheon

65

Fri

S Corporations

Important Developments

33

Fri S Corporations

Pesky S Corporation M&A Issues

37

Fri

S Corporations

State and Local Tax Issues Related to Mergers and Acquisitions of S Corporations

24

Sat

Sales, Exchanges & Basis

Current Developments in Sales, Exchanges & Basis

40

Sat


Section 1031 Transactions, California-Style

40

Sat Sales, Exchanges & Basis

A Close Examination of the Intermediary Installment Sale Transactions

45

Sat


Can the Tenant Provide Tax-Free Financing of the Landlord’s Construction Costs?

25

Sat


Tax-Deferred Exchanges of Franchisees’ and Distributors’ Rights

30

Sat

Section Program

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

33

Sat Section Program

Nuts & Bolts of Tax Court Litigation: Pre-trial Practice

75

Sat Section Program Nuts & Bolts of Tax Court Litigation: Trial 75

Sat Section Program

Nuts & Bolts of Tax Court Litigation: Post-trial Practice

75

Sat

Section Program

Section Luncheon & Plenary Session

173 Fri Section Reception 198

Fri

Standards of Tax Practice

Ethical Issues in Federal Tax Practice – The Government and Local Perspective

75

Fri Standards of Tax Practice Ethical Issues In Setting Engagement Terms 70


Ethical Issues Arising in the Context of International Tax Planning

55

Fri

State & Local Taxes

The Multistate Tax Compact Under Fire: An Update on the California Gillette v. Franchise Tax

63

Fri

State & Local Taxes

Retroactive State Taxation: It’s Back(ward)!

51

Fri State & Local Taxes Applying Deference In Tax Cases 55



Fri

State & Local Taxes

Sunlight as a Disinfectant versus the Possible Perils of Government in a Fishbowl:

55

Sat State & Local Taxes Practitioner’s Roundtable 46

Fri State & Local Taxes and Transfer Pricing

BEPS and Transfer Pricing Implications for State and Local Tax

36

Fri

Tax Accounting


25

Fri

Tax Accounting

Recent Developments in Section 199

31

Fri

Tax Accounting

Timing of Deductions for Ratable Service Contracts

27

Fri

Tax Accounting

Recent Developments Concerning the Research and Development Credit

34

Thurs

Tax Bridge on the Road

A Conversation with…

Thurs


Nuts & Bolts: The Administrative Tax Controversy Case From Examination to Appeals

Thurs


Tax Careers in the Government

Thurs Tax Bridge on the Road Partnerships: The Fundamentals

Thurs Tax Bridge on the Road

Tax Court 101: Everything You Wanted To Know About Litigating Tax Cases

Fri

Tax Exempt Financing

Legislative, Treasury and Internal Revenue Service Update

15

Fri


Public / Private Partnerships: The Impact of the New Mixed Use Treasury Regulations on P3 Transactions

15

Fri


Tax Issues in Seaport and Airport Financings: "It Is Not Always a Carnival When You Make a Deal with Royal Caribbean, Even if You Are Norwegian"

19

Fri Tax Policy and Simplification

Marketplace Fairness Act

22

Sat

Tax Practice Management

Social Media and the Tax Lawyer: An Update on Avoiding Ethical Traps

35

Fri

Teaching Taxation

Inequality and Taxation

22

Fri Transfer Pricing

Media & Entertainment Considerations in Transfer Pricing

20



Fri

Transfer Pricing

REITs and Transfer Pricing: The IRS Takes up the Welcome Mat

25

Fri

US Activities of Foreigners & Tax Treaties

Inbound IP Planning

67

Fri


Advanced Withholding Taxation - A Guide for the Perplexed

70

Fri

Young Lawyers Forum

Solutions - A Law Student Tax Challenge (LSTC) Case Study


September 2015 Chicago, IL. N/C = No Count Recorded

2015 Fall Meeting Day Committee/Group Panel/Topic Headcount


Back to Basics: Who Has Capacity to Sign on Behalf of the Taxpayer

31

Fri


A New Era of IRS Examinations – Doing Less with Less?

78

Fri Administrative Practice Kicking the Habit: Using Kovel Responsibly 74 Fri Administrative Practice Important Developments 53

Fri

Affiliated & Related Corporatio


41

Fri

Affiliated & Related Corporatio

The Intersection of Subchapter K and Consolidated Returns

50

Fri

Banking & Savings Institutions

Banking & Savings Tax Update

11

Fri


Dual Consolidated Loss Issues for Banking Entities

6

Fri


Embedded Loan Regulations: A Step in the Right Direction for Tax Treatment of Swaps?

15

Fri

Banking & Savings Institutions,

Committee Luncheon

28

Fri



29

Fri


The Interaction of §263(a) and §263A: How Do the Tangible Property Regulations and the Uniform Capitalization Rules Work Together?

29

Fri Capital Recovery and Leasing

Tangible Property Regulations Update – Continuation from the May Meeting

27

Sat



36

Sat


Aggressive IRS Audit Techniques – Tales from the Trenches

79

Sat


Tax Preparer Fraud: Strategies for Defending the Tax Preparer or Promoter in Criminal and Civil Injunction Litigation

48

Sat


Sentencing in Tax Cases

30 Fri CLE Section CLE Committee 17

Fri

Closely Held Businesses (TX) an

Breaking Up is Hard to Do: Tax and Practical Implications of Unwinding Business Affairs Among Multiple Partners

19

Fri


Selling the Dreaded C-Corp While Minimizing the Double Taxation

19

Fri


The Nuts & Bolts of Captive Insurance Companies

30



Fri


Old MacDonald Has a Farm... With Corporate Farming Statutes Here and Special Use Valuation There, What Kind of Planning Can He Do?

13

Fri Companion Events

Companion Event Committee

Sat

Corporate Tax

Section 361(c) and Its Discontents

81

Sat Corporate Tax Current Developments 89

Fri


Roundtable Discussion: Effective Writing in the Tax Court - "Prologue and Postscript: The Pretrial Memorandum and Post-Trial Brief, With Views from the Bench"

52 Fri Court Procedure and Practice Important Developments 50

Fri


Strategically Assembling a Transfer Pricing Case

52

Fri


Conflicts and Chaos: The Importance of Timely Recognizing and Managing Conflicts of Interest in Tax Litigation

44

Fri Court Procedure and Practice Ethical Issues Arising in Discovery 42

Fri

Diversity

Obergefell v. Hodges: Tax and Estate Planning Issues for Employers and Individuals

17

Fri

Diversity

The Influence of Cultural Differences on Estate, Tax, and Employment Benefit Planning, Part I

19

Fri

Diversity

The Influence of Cultural Differences on Estate, Tax, and Employment Benefit Planning, Part II

26

Fri Employee Benefits Defined Contribution Plans Update 31


Executive Compensation, Fringe Benefits and Federal Securities Law Update

33

Fri

Employee Benefits


35

Fri Employee Benefits Litigation Update 13


Multiple Employers, PEOs and Controlled & Affiliated Service Groups Update

22

Fri

Employee Benefits

Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues

39

Fri

Employee Benefits

Defined Benefit Plan and Distributions Update

24

Fri

Employee Benefits

Exempt Organization and Governmental Plans Update

17

Fri

Employee Benefits

Fiduciary Responsibilities Update

13

Fri

Employee Benefits

Legislative Update

2

Fri Employee Benefits New Employee Benefits Attorneys Forum 6


Corporate Counsel Forum

6



Fri

Employee Benefits

ESOP Update

8

Fri Employee Benefits Mergers & Acquisitions Update 13


Multinational Employee Benefits & Compensation Issues

16

Fri

Employee Benefits

2015 Health Plan Advice: Ethics, Technical & Practical Challenges

65

Fri

Employee Benefits

Employer Wellness Programs and EEOC Proposed Rules Under the ADA

50

Fri

Employee Benefits

Department of Treasury and Internal Revenue Service Hot Topics

65

Sat

Employee Benefits

The Future of the Determination Letter Process

76

Sat Employee Benefits

Over 20 Years of IRC Section 162(m) and 30 Years of IRC Section 280G – Has It Made a Difference in

78

Sat

Employee Benefits

Keeping or Closing the Employer Stock Fund After Dudenhoeffer and Tatum – A Fiduciary Process

78

Fri

Employment Taxes


15

Fri

Employment Taxes

Employment Tax Primer for Small Businesses: I'm Ready to Hire My First Employee. What Should I

11

Fri Employment Taxes Payroll Service Providers 18

Fri Employment Taxes

The Count Down Continues: Affordable Care Act (ACA)

11

Fri

Estate & Gift Taxes (TX) and In


55

Fri


Section 2801 Uncovered: Taxation of Gifts and Bequests from Covered Expatriates

60

Fri


The Middle Way: The Uniform Trust Decanting Act

48

Fri


Death, Divorce and Reproductive Technology: What Every Practitioner Needs to Know Now About Planning For the Future

35

Fri

Estate & Gift Taxes and Fiducia

Understanding Valuation Discounts

27

Fri Estate & Gift Taxes, Fiduciary I Committee Luncheon

Fri Exempt Organizations


7



Fri



13

Fri



4

Fri



7

Fri



2

Fri


News from the IRS and Treasury

51

Fri


Best Practices: Prizes, Sweepstakes, Contests and Awards

45

Fri


Section 501(c)(6) Trade Associations: Tax Issues, Governance, Controversies

40

Fri Exempt Organizations Committee Luncheon

Fri Exempt Organizations

Coloring Outside the Lines: The Art of Gifting Art

24

Fri


Not So Fast: Exempt Organization Changes and Your State Attorney General

34

Fri

FAUST, FLF, Transfer Pricing an

Committee Luncheon

Sat Fiduciary Income Tax (TX) and Current Developments 38

Sat Fiduciary Income Tax (TX) and

Income Tax Deductions for Charitable Bequests of IRD

53

Sat

Fiduciary Income Tax (TX) and

Section 2704(b) Proposed Regulations and Valuation Discounts on Transfers of Closely Held Entities

49

Sat

Fiduciary Income Tax (TX) and

Implementation and Administration of Self- Cancelling Installment Notes

35

Fri


Financial Products and Partnership Interests

32

Fri


Section 864(b) and Financial Transactions

33

Fri Financial Transactions Current Developments and Issues 36

Fri Foreign Activities of US Taxpay

Incorporations and Liquidations of Foreign Entities

51

Fri

Foreign Activities of US Taxpay

Issues Arising Under Section 956 – Part I

65

Fri

Foreign Activities of US Taxpay

Joint Current International Developments Panel

48

Fri


Household Employee Tax Compliance

13

Fri Individual and Family Taxation

Taxpayer Filing Status - Options and Recent Law

13

Fri


Penalty Panel Part II

13



Fri

Insurance Companies

Retaliatory Taxes and Other State Premium Tax Issues

13

Fri

Insurance Companies

Litigation / Administrative Update

16

Fri Insurance Companies Reinsurance Update 12

Fri Investment Management

Current Issues for Regulated Investment Companies

11

Fri


Thinking About Converting to an RIC? Important Considerations

17

Fri


Current Issues for Private Investment Funds and their Managers

29

Sat

Joint Section Program

Tax, Immigration, and Employment Issues for Household Employees

5

Sat


Obergefell: Remaining Estate Planning and Tax Issues and a Look Into the Future

25

Sat


Estate Tax Return Preparation and Audit Mitigation Strategies

19

Fri

Membership & Marketing


13

Fri

Partnerships & LLCs

Staying Dry Under The Umbrella: Avoiding PTP Issues In Umbrella Partnership Structures

66

Fri

Partnerships & LLCs

Partnership Debt vs. Debt-Like Equity

63

Fri Partnerships & LLCs Management Fee Waivers 103 Fri Partnerships & LLCs Issues Arising Under Section 956 – Part II 49

Sat Partnerships & LLCs Dual Status by Design 25

Sat

Partnerships & LLCs

Report on the Drafting Committee’s work on the Uniform Law Commission’s Series of Unincorporated Business Entities Act

25

Sat

Pro Bono & Tax Clinics

Recent Developments Affecting Low-Income Taxpayers

35

Sat


Designing a Pro Bono Project for Your Firm

24

Sat


Basics of IRS Collection Alternatives

43 Fri Real Estate Hot Topics 52

Fri

Real Estate

Dealer vs. Investor - Caselaw Update

49

Fri

Real Estate

Motivating the Real Estate Deal and Fund Team – Part Deux

38



Fri

Real Estate

Federal Tax Impact of Using State Tax Credits

40

Fri

Real Estate and Partnerships &

Committee Luncheon

Fri

S Corporations


12

Fri S Corporations S Corporation Valuations Issues 22 Fri S Corporations Primer on S Corporation Shareholders 10

Fri

S Corporations

Trusts Decanting with S Corporation Shareholders

12

Sat


The "Partnership Installment Note" Transaction

18

Sat Sales, Exchanges & Basis Current Developments 17 Sat Sales, Exchanges & Basis A Primer on Section 1031 Transactions 20

Sat


Negotiating and Drafting Tax Provisions in Rental Real Estate Purchase Agreements

16

Sat

Section Program

Joint Section Luncheon & Plenary Session

108

Fri Sponsorships Sponsorships 5


Ethical Issues in Federal Tax Practice - The Government and Local Perspective

65

Fri Standards of Tax Practice Ethics Two-Minute Drill 44 Fri Standards of Tax Practice Procedures to Ensure Compliance 29

Fri

State & Local Taxes

Illinois Legislative and Tax Policy Update

44

Fri

State & Local Taxes

State Resident Tax Credits After the Supreme Court’s Wynne Decision

28

Fri

State & Local Taxes

Revising the Uniform Unclaimed Property Act

28

Fri

State & Local Taxes

Alternative Tax Controversies

31

Sat State & Local Taxes Practitioner’s Roundtable 31

Sat State & Local Taxes

Publication Subcommittees

13

Fri

Tax Accounting


34

Fri

Tax Accounting

Tax Accounting Method Issues for Financial Institutions and Financial Products

34

Fri

Tax Accounting

Update on Prevalent Tangible Property Regulations Issues and Anticipated Guidance

30

Fri

Tax Accounting

Transaction Costs in Business Acquisitions: Recent Developments and Hot Topics

32



Thurs


A Conversation with Richard Lipton

35

Thurs


Social Media: Ethics in the Internet Age

35

Thurs


State Income, Double Taxation, and Tax Discrimination in the Post-Wynne World

35

Thurs Tax Bridge on the Road Ethical Issues for Newer Attorneys 35

Fri

Tax Compliance

Roundtable Discussion

8

Fri

Tax Policy and Simplification

Estate Tax on Farms: Repeal, Retain, or Reform?

9

Fri


The Design of Tax Incentives: Lessons from Energy and Environmental Incentives

12

Fri

Tax Practice Management (TX)

How to Practice Law, Abide by the Rules of Professional Conduct, and Have a Life that Rules

11

Fri

Teaching Taxation

The Status of the Tax Court post-Kuretski: Significant Shift, Minor Adjustment, or Nothing New?

30

Fri

Transfer Pricing

Tax Litigation Developments from the Transfer Pricing Front

19

Fri

Transfer Pricing

Preparing for Country by Country Reporting

19

Fri

US Activities of Foreigners & Ta

The New US Model Treaty and Treasury Explanation: What is Proposed and What is Needed

56

Fri US Activities of Foreigners & Ta Residence: Beyond the Basics 67 Fri Young Lawyers Forum Why a Law Student Tax Challenge (LSTC)? 10

Fri

Young Lawyers Forum

What Makes a Winning LSTC Team?

12


May 2015 Washington, DC N/C = No Count Recorded

2015 May Meeting

Day Committee/Group Panel/Topic Headcount Sat

Vice-Chairs, Officers and Council Breakfast

N/C

Fri

ACTC Board of Regents Meeting

17

Sat

ACTC Fellows Breakfast

49

Fri


Important Developments.

109

Fri


What’s New in IRS Exam and Appeals

145

Fri


Memories Fade But Emails are Forever: New Electronic Discovery Rules in US Tax Court

210

Fri

Court Procedure & Practice Lunch

93

Thurs

Administrative Practice Dinner

N/C

Fri

Affiliated and Related Corporations

Current Developments.

59

Fri

Affiliated and Related Corporations

Consolidated Groups Recover "Previously Taxed Income?"

75

Fri

Appointments to the Tax Court (Executive Session)

2

Fri


Recent Developments on Modifications of Non- Debt Financial Instruments.

43

Fri


Section 871(m) Final Regulations

32

Fri

and Investment Management Joint Panel

44

Fri

Banking & Savings Institutions, Financial Transactions, Insurance Companies, Investment Management and Tax Exempt

29 Fri


Debt Modifications Revisited.

45

Fri


Hot Topics in COD Income.

56

Fri


Mediation in Collection Matters – A Brave New World.

21

Fri

Breakfast Forum- Tax Analysts

63

Fri

Capital Recovery & Leasing


45

Fri


Tangible Property Regulations and the Real Estate Industry

57



2015 May Meeting

Day Committee/Group Panel/Topic Headcount Fri


Continuation from the September Meeting – Industry Issues/Guidance, FAQs, and Related

57

Sat

Civil & Criminal Tax Penalties


73

Sat


Internal Revenue Service, Criminal Investigation - Update.

89

Sat


Department of Justice, Tax Division - Update.

73

Sat


Day of Reckoning - An Update on Offshore Appeals.

121

Sat


Money Laundering - IRS Seizure and forfeiture post October 25, 2014

73

Fri

Civil & Criminal Tax Penalties Luncheon (offsite)

100

Fri


Buy-Sell Agreements for Closely Held Businesses.

65


Defending Clients From the Trust Fund Recovery Penalty.

40

Fri

Companions Breakfast

13

Sat

Corporate Tax


155

Sat

Corporate Tax

It's All About That Basis

124

Sat

Corporate Tax

Not Free From Doubt? – Corporate Tax Opinions

138

Fri

Corporate Tax and Affiliated & Related Corporations Luncheon (Ticketed Event)

72 Fri

Court Procedure & Practice

Important Developments.

120

Fri


Journey from CI Referral to Indictment - How Did We Get Here

60

Fri


Transfer Pricing, International Enforcement Issues, and Other Offshore Related Hot Topics

57

Fri


Cross Border Privileges Issues.

84

Sat

Officers and Subcommittee Chairs Breakfast (Ticketed

24

Fri

Court Procedure & Practice Roundtable Discussion

95

Fri

Diversity

Working with Your Client: Perspectives from In- House Counsel

13



2015 May Meeting


Diversity

Ensuring Ethical Client Solicitations.

50

Fri

Diversity and Young Lawyers Forum Networking Reception

170

Fri

Diversity Luncheon (Ticketed Event)

34

Fri

Employee Benefits

Administration & Pension Benefit Guaranty Corporation Updates.

185

Fri

Employee Benefits

Department of Treasury / IRS Hot Topics.

190

Fri

Employee Benefits

Department of Treasury / IRS Questions and Answers.

216

Fri

Employee Benefits

Treasury / IRS Fireside Chat

132

Fri

Employee Benefits

Corporate Counsel Corner

24

Sat

Employee Benefits

Affordable Care Act After 5 Years.

107

Sat

Employee Benefits

Qualified Plan Testing in Controlled Group and Affiliated Service Group Environments

81

Sat

Employee Benefits

Fiduciary Issues and Data Privacy.

85

Fri


72

Fri

Employee Benefits Defined Contribution Plans Update

74

Fri

Department of Labor Fireside Chat

120

Fri

Distributions and Defined Benefit Plans Updates

PBGC Fireside Chat

57

Fri

Distributions and Defined Benefit Plans Updates

Subcommittees

62

Fri

Employee Benefits ESOP Update

32

Fri

Compensation, Fringe Benefits and Federal

60

Fri

Organization and Governmental Plans Update

29

Fri

Employee Benefits Fiduciary Responsibilities Update

46

Fri

Employee Benefits Legislative Update

10

Fri

Employee Benefits Litigation Update

38



2015 May Meeting


Employee Benefits Mergers & Acquisitions Update

56

Fri

Multinational Employee Benefits & Compensation

24

Fri

Employers, PEOs and Controlled Groups Update

44

Fri

Employee Benefits Networking Reception

97

Fri

Employee Benefits New Employee Benefits Attorneys Forum

4 Fri

Employee Benefits Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update

36 Fri

Employment Taxes


59

Fri

Employment Taxes

Recent Tax Court Jurisdictional Opinions for Worker Classification Issues

56

Fri

Employment Taxes

and Enactment of Section 3511: What Does it Mean for Third Party Payroll Providers.

40

Fri

Employment Taxes

IRS Employment Tax Refund Procedures

26

Sat

Employment Taxes & Exempt Organizations Joint Panel

15

Fri

Energy & Environmental Taxes

37

Fri

Fiduciary Income Tax Young Lawyers Subcommittees

38

Fri

Estate and Gift Taxes


52

Fri


Structuring Charitable Gifts: Blending Philanthropic Objectives with Tax Planning.

48

Fri


Top Ten Revenue Rulings for Estate Planners.

52

Fri


Committee Business.

N/C

Fri


News from the IRS and Treasury

115

Fri


News from the Hill

128

Fri


Common Exempt Organizations Issues that Lack Up-to-Date Guidance.

107

Fri


Exempt Organizations Committee Luncheon

N/C



2015 May Meeting



Exempt Organizations Focused on Energy and the Environment.

99

Fri


Volunteers in Exempt Organizations

69

Fri

Exempt Organizations Luncheon

79

Fri

Subcommittee on Health-Care Organizations

5

Fri

Subcommittee on Political and Lobbying Organizations

30

Fri

Subcommittee on Private Foundations, Unrelated

33

Fri

Subcommittee on Religious Organizations

7

Fri

and USAFTT Luncheon (Ticketed Event)

93

Sat


Current Developments.

62

Sat


State Fiduciary Law Update

56

Sat


Including Capital Gains in DNI

35

Sat


and Trusts under Section 642(c): Timing, Traps and Techniques

35

Fri


Differing Views of Tax Law within the IRS Office of Chief Counsel.

75

Fri


Related Party Financing: Current Law and Policy Considerations.

75

Fri


Current Developments and Issues.

75

Thurs

First-Time Attendees Dinner (RSVP Required)

N/C

Fri


The Intersection of Partnerships & Subpart F

103

Fri


Alternative Proposals for International Tax Reform.

119

Thurs


41

Fri

Foreign Activities of US Taxpayers Business Meeting

18

Fri

Taxpayers, US Activities of Foreigners and Tax Treaties,

85

Sat


General Anti-Abuse Rules (GAAR) Rapidly Gaining Territory in Double Tax Treaties.

75



2015 May Meeting

Day Committee/Group Panel/Topic Headcount Sat


Lux Tax Leaks Become EU Tax Leaks: 2016 Automatic Exchange of Tax Rulings in the EU

50

Fri

Foreign Lawyers Forum Business Meeting

14

Thurs

Government Guest Cocktail Reception

N/C

Thurs

Incoming Officers & Council Orientation

N/C

Fri


Recent Developments in the Tax-Related Identity Theft.

44

Fri


Affordable Care Act Implementation Issues Impacting Individuals and Families

58

Fri

Insurance Companies

Health Insurance Update

40

Insurance Companies

Captive Insurance Update

40

Insurance Companies

Legislative Update.

45

Fri


Current Regulated Investment Company Issues

39

Fri


Tax Planning for Non - US Investors in Debt Funds.

40

Thurs

IRS SB/SE Commissioner

N/C

Fri

Joint International Committees Dinner

N/C

Fri

Law Student Tax Challenge Planning Meeting

13

Sat

LLCs and LLPs Subcommittee of Partnerships & LLCs

Partnership Divisions: Opportunity or Nightmare.

62

Sat

LLCs and LLPs Subcommittee of Partnerships & LLCs

concerning partners and whether they can also have the status of an employee.

51

Thurs

Low Income Taxpayers Representation Workshop

Client Intake to Filing a Tax Court Petition

60

Thurs


Tax Court Pre-Trial Practice

72

Thurs


Tax Court Trial and Appeals

72

Thurs


Handling a Section 6015 Case

50

Fri


17

Thurs

Officers & Council Luncheon

N/C



2015 May Meeting

Day Committee/Group Panel/Topic Headcount Thurs

Officers & Council Meeting

N/C

Fri

Partnerships & LLCs

Partnership Compliance Issues.

112

Fri

Partnerships & LLCs

Hot Topics in Partnership Taxation.

150

Fri

Partnerships & LLCs

May Company Regulations.

157

Thurs

Philanthropy Professors Meeting

9

Sat


Update from Tax Court.

45

Sat


Handling Cases With Potential Criminal Issues.

53

Sat


W-2 and Worker Classification Issues

45

Sat


Hot Topics

46

Fri

Publications (Executive Session)

12

Fri

Real Estate

Legislative Update

90

Fri

Real Estate

FIRPTA, Section 892 & REITs

90

Fri

Real Estate

Motivating the Real Estate Deal and Fund Team.

80

Fri

& LLCs Committees Luncheon (Offsite)

N/C

Sat

LLCs and S Corporations “Shop Talking” Breakfast

90

Fri

S Corporations


119

Fri

S Corporations

Hot Topics Relating to S Corporations.

89

Fri

S Corporations

Section 1374(d)(7) Recognition Period.

78

Sat


Current Developments in Sales, Exchanges & Basis

45

Sat


The Long and the Short of the Effects of Long on Long Term Capital Gains

42

Sat


Taxation of Fees for Distribution Rights and Franchises.

40

Sat


A Critical Look at "Deferred Sales Trusts."

46



2015 May Meeting


Section CLE

19

Sat

Section Luncheon & Plenary Session (Ticketed Event)

215

Sat

Wisely, When to Use (or NOt Use) Mediation to Obtain Cost Effective Closure in Exam & Collection Cases

47 Sat

Section Program: Huf Huf and Blow the IRS Away

12

Fri

Section Reception

314

Fri

Sponsorships

10

Fri


Ethical Issues in Federal Tax Practice — The Government Perspective.

135

Fri


of Ethical and Practice Standards Questions Arise for a New Client Representation?

112

Fri

Committee Luncheon (Ticketed Event)

42

Thurs

State & Local Taxes Executive Committee Dinner (Offsite)

N/C

Sat

State & Local Taxes Practitioners Roundtable

53

Sat

State & Local Taxes: Publication Subcommittees

11

Fri

State and Local Taxes

‘Just Add SaLT!’ When and How to Consider State Tax Ethical Issues in Advising Clients

85

Fri


The State of State Tax Courts

63

Fri


Hot Topics in the State Taxation of International Operations.

50

Sat

Chairs’ Planning Meeting (By Invitation Only)

10

Fri

Tax Accounting

Section 199 - Recent Developments and Hot Topics.

62

Fri

Tax Accounting


62

Fri

Tax Accounting

Tangible Property Regulations Guidance Update.

60

Fri

Tax Accounting

Accounting Methods Considerations for Partnerships.

55

Thurs

Tax Bridge to Practice

Nuts & Bolts: Introduction to Life Insurance Company & Contracts Taxation

70



2015 May Meeting

Day Committee/Group Panel/Topic Headcount Thurs


Nuts and Bolts: Federal Estate, Gift and Generation-Skipping Transfer Tax

79

Thurs


Tax Tales: The Seminal Cases of Subchapter C

70

Thurs


On the Road Toward Diversity and Inclusion: Leading to Opportunities for All.

45

Fri

Tax Compliance (Formerly Tax Shelters)

23

Fri


Legislative, Treasury and Internal Revenue Service Update.

32

Fri


Political Subdivision Comment Project

34

Fri


Transportation Bonds, Private Business Use and Comment Project

35

Fri


Economic Development Financings and Private Lending

32

Fri


with the OECD Base Erosion and Profit Shifting (BEPS) Project and Other Developments Around

56

Fri


Tax and Spending Policy in the Long Run.

50

Sat

Tax Practice Management

20

Fri

Teaching Taxation

70

Fri

Transfer Pricing

How Will IRS’s Transfer Pricing Operations Move Forward in the BEPS Environment?

60

Transfer Pricing

Advance Pricing and Mutual Agreement (APMA) - Hot Topics.

89

Fri

Transfer Pricing Business Meeting

13

Fri

and Tax Treaties Business Meeting

24

Fri


156

Thurs

Welcome Reception

158

Thurs

Woodworth Lecture

52

Fri

Young Lawyers Forum

25


Midyear 2015 Houston, TX N/C = No Count Recorded


Fri

14th Annual Law Student Tax Challenge Final Rounds - Young Lawyers Forum

N/C

Fri

14th Annual Law Student Tax Challenge Semi-Final Rounds - Young Lawyers Forum

N/C Sat

ACTC 2014 Griswold Lecture

N/C

Sat

ACTC Annual Business Meeting

N/C

Fri

ACTC Board of Regents Meeting

15

Fri


Navigating the TEFRA Swamp: Managing the Complexities of a Partnership Audit - Administrative Practice

48 Fri Administrative Practice Important Developments - Administrative Practice 52 Fri


You've Been Served: Handling IRS Summonses in Audits and Tax Litigation - Administrative Practice

65

Fri

Administrative Practice | Court Procedure and Practice

Administrative Practice and Court Procedure and Practice Luncheon

76 Fri


Do's and Don'ts with Member Stock and Member Debt - Affiliated & Related Corporations

37

Fri


The Doctor Is In - Corporate Tax Issues Facing Professional Service Providers - Affiliated & Related Corporations

30 Fri

Appointments to the Tax Court

Appointments to the Tax Court

20

Fri


Recent Developments - Banking & Savings Institutions

16

Fri


Oil and Gas Financing - Banking & Savings Institutions

14

Fri


Reaching Consensus on Capital - Banking & Savings Institutions

10

Fri

Banking & Savings Institutions | Financial Transactions | Insurance Companies | Investment Management | Tax Exempt Financing

Banking & Savings Institutions, Financial Transactions, Insurance Companies, Investment Management, Tax Exempt Financing - Committees Luncheon

28 Fri


Bankruptcy and Workouts - Bankruptcy and Workouts

22




Fri


Tangible Property Regulations Update - Continuation from the September Meeting - Disposition Regulations, FAQs, and Related Discussions - Capital Recovery and Leasing

37 Fri


Current Developments Report and Update on Pending Guidance - Capital Recovery and Leasing

29

Fri


Hot Topics in the Oil and Gas Industry - Capital Recovery and Leasing

36

Fri Careers in Tax Dinner 35 Sat


Cross-Examination in a Tax Case - Civil and Criminal Tax Penalties

80

Sat


Summons Enforcement – Procedure, Privileges and Petitions to Quash - Civil and Criminal Tax Penalties

105

Sat


Tax Penalty Principles at Play in the Bankruptcy Court: Recent Discharge Cases Interpreting Tax Evasion and Failure to File - Civil and Criminal Tax Penalties

71 Fri


Civil and Criminal Tax Penalties Committee Luncheon

53

Sat


Reports of Subcommittees on Important Developments - Civil and Criminal Tax Penalties

60

Fri


Tax Considerations for Executives and Management Teams in Corporate Transactions - Closely Held Businesses

21 Fri


Retirement Planning Guide for Estate Lawyers: Helping Your Client Plan for a Financially Successful Retirement - Closely Held Businesses

20 Fri

Closely Held Businesses | Employment Taxes | Civil and Criminal Tax Penalties

Closely Held Businesses & Tax Debts: An Update on IRS Collection Procedures and Opportunities for Resolving Outstanding Tax Debts - Closely Held Businesses | Employment Taxes | Civil and Criminal Tax Penalties

20 Fri

Closely Held Businesses | Employment Taxes | Civil and Criminal Tax Penalties

Payroll Tax Debts: The Good, the Bad and the Criminal - Closely Held Businesses | Employment Taxes | Civil and Criminal Tax Penalties

17 Fri

Committee Chairs, Vice- Chairs, Officers & Council Breakfast

N/C Fri

Companion Event Committee

N/C

Fri Companions Breakfast 13 Sat

Corporate Tax

Transactional Electivity and Subchapter C - Corporate Tax

93

Sat Corporate Tax Corporate Inversions - Corporate Tax 120 Sat Corporate Tax Exploring Voting Power - Corporate Tax 98



2015 Midyear Meeting Day Committee/Group Panel/Topic Headcount Fri

Corporate Tax | Affiliated & Related Corporations

Corporate Tax and Affiliated & Related Corporations Committees Luncheon

67

Fri


Litigating Financial Products Case Update - Court Procedure and Practice

60

Fri


Offshore Account Disclosure Case Update - Court Procedure and Practice

80

Fri


Litigating Tax Penalties Case Update - Court Procedure and Practice

68

Fri


Important Developments - Court Procedure and Practice

48

Sat


Court Procedure and Practice Officers and Subcommittee Chairs Breakfast - Court Procedure and Practice

26 Fri

Court Procedure and Practice | Diversity

Court Procedure and Practice Roundtable Discussion - Court Procedure and Practice | Diversity

70 Fri

Distinguished Service Award

Distinguished Service Award

N/C

Fri

Diversity

Does One-Size-Fit-All? Creating a Tax Code that Fits Everyone - Diversity

21

Fri Diversity Tax Issues Affecting Immigration Cases - Diversity 14 Fri Diversity Diversity Luncheon 21 Fri

Diversity | Corporate Tax

Getting a Foothold: Fundamental Cases, Rulings, and Concepts for the Novice Corporate Tax Attorney - Diversity | Corporate Tax

25 Sat

Diversity | U.S. Activities of Foreigners and Tax Treaties

Section Program: A Primer on Tax Treaties - Diversity | US Activities of Foreigners and Tax Treaties

52 Fri

Diversity | Young Lawyers Forum

Diversity & Young Lawyers Forum Networking Reception - Diversity | Young Lawyers Forum

95

Sat Employee Benefits 409A Turns 10 - Employee Benefits 83 Fri

Employee Benefits

Employee Benefits Multinational Employee Benefits & Compensation Issues - Employee Benefits

16 Fri Employee Benefits Treasury / IRS Fireside Chat - Employee Benefits 80 Fri Employee Benefits Corporate Counsel Corner - Employee Benefits N/C Fri

Employee Benefits

Employee Benefits New Employee Benefits Attorneys Forum - Employee Benefits

5

Sat Employee Benefits Ethics and Circular 230 - Employee Benefits 75 Fri

Employee Benefits

Hybrid Plan Treasury Regulations - Increased Flexibility and Retirement Security - Employee Benefits

70 Fri Employee Benefits Hot Topics - Employee Benefits 80 Fri

Employee Benefits

Employee Benefits Fiduciary Responsibilities Update - Employee Benefits

27

Fri

Employee Benefits

Employee Benefits Litigation Update - Employee Benefits

N/C




Employee Benefits

Employee Benefits ESOP Update - Employee Benefits

20

Fri

Employee Benefits

Employee Benefits Administrative Practices Update - Employee Benefits

36

Fri

Employee Benefits

Employee Benefits Multiple Employers, PEOs and Controlled Groups Update - Employee Benefits

32

Fri

Employee Benefits

Employee Benefits Distributions and Defined Benefit Plans Updates - Employee Benefits

32

Fri

Employee Benefits

Employee Benefits Welfare Plans, Cafeteria Plans and Reimbursement Accounts, and EEOC Issues Update - Employee Benefits

25 Fri

Employee Benefits

Employee Benefits Defined Contribution Plans Update - Employee Benefits

41

Fri

Employee Benefits

Employee Benefits Legislative Update - Employee Benefits

11

Fri

Employee Benefits

Employee Benefits Mergers & Acquisitions Update - Employee Benefits

26

Sat Employee Benefits ACA Developments - Employee Benefits 89 Fri

Employee Benefits

Section 457A: Revenue Ruling 2014-18 and Its Impact on Fund Manager Compensation - Employee Benefits

66 Fri

Employee Benefits

Employee Benefits Exempt Organization and Governmental Plans Update - Employee Benefits

27

Fri

Employee Benefits

Employee Benefits Executive Compensation, Fringe Benefits and Federal Securities Law Update - Employee Benefits

47 Fri Employee Benefits Networking Reception - Employee Benefits 90 Fri

Employment Taxes

Employment Tax Due Diligence in M&A - Employment Taxes

10

Fri

Employment Taxes

Federal Employment Tax Update - Employment Taxes

27

Fri

Employment Taxes

Common Employment Tax Mistakes - Employment Taxes

24

Fri

Employment Taxes | Employee Benefits

Comply with the Affordable Care Act’s “Cadillac Tax.” - Employment Taxes | Employee Benefits

26

Fri


Ask the Experts - Hot Topics In Energy Taxes - Energy & Environmental Taxes

8

Fri


IRS Enforcement On the US Outer Continental Shelf - Energy & Environmental Taxes

29

Fri


Unit of Property Issues in the Petroleum Industry and How to Resolve Them - Energy & Environmental Taxes

25 Fri

Estate & Gift Taxes

Estate Planning in the Twilight Zone: US Taxation of Non- Resident Aliens - Estate & Gift Taxes

44

Fri Estate & Gift Taxes Business Interests in Trusts - Estate & Gift Taxes 45 Fri Estate & Gift Taxes Current Developments - Estate & Gift Taxes 39




Estate & Gift Taxes

Going Through the Drill: An Overview of Oil and Gas In Estates and Trusts - Estate & Gift Taxes

33

Fri

Estate & Gift Taxes | Fiduciary Income Tax

Estate & Gift Taxes and Fiduciary Income Tax - Estate & Gift Taxes | Fiduciary Income Tax

22

Fri

Estate & Gift Taxes | Fiduciary Income Tax

Estate & Gift Taxes and Fiduciary Income Tax Young Lawyers Subcommittee - Estate & Gift Taxes | Fiduciary Income Tax | Young Lawyers

24 Fri


Roundtable Discussion of Current Developments - Exempt Organizations Subcommittee on Political and Lobbying Organizations

11 Fri


News from the IRS and Treasury - Exempt Organizations

43

Fri


Virtual Currency and Open Source - Exempt Organizations

N/C

Fri


Private Foundations: Special Self-Dealing Problems - Exempt Organizations

36

Fri


Disaster Relief in 2015: Disease as a Disaster & the Criminalization of Humanitarian Aid. - Exempt Organizations

39 Fri Exempt Organizations Cash Bar - Exempt Organizations 25 Fri Exempt Organizations Committee Business - Exempt Organizations 45 Fri Exempt Organizations Exempt Organizations Committee Luncheon 33 Fri


Roundtable Discussion of Current Developments - Exempt Organizations Subcommittee on Health-Care Organizations

6

Fri


Roundtable Discussion of Current Developments - Exempt Organizations Subcommittee on Private Foundations, Unrelated Business Income and International Philanthropy

19 Fri


Roundtable Discussion of Current Developments - Exempt Organizations Subcommittee on Religious Organizations

9 Sat Fiduciary Income Tax Current Developments - Fiduciary Income Tax 39 Sat Fiduciary Income Tax Structuring Offshore Trusts - Fiduciary Income Tax 42 Sat


Planning for New Basis at Death - Fiduciary Income Tax

34

Sat


Sale Transactions with Notes: Debt v. Equity with Regard to Notes Based on Woebling - Fiduciary Income Tax

47 Sat


Section 469 Regulations: Update on the Committee’s Comment Writing Task Force - Fiduciary Income Tax

47 Fri


Negative Interest, Negative Rebate and Similar Issues - Financial Transactions

35

Fri


Taxation of Hybrid Instruments: Past, Present and Future - Financial Transactions

44





Withholding Tax Current Developments and Issues - Financial Transactions

22

Thu

First-Time Attendees Orientation Dinner

30

Fri

Foreign Activities of U.S. Taxpayers

Moving Overseas: Notice 2014-52 and Future Guidance and the Implications for Inversions - Foreign Activities of U.S. Taxpayers

61 Fri


Unresolved Issues in US International Tax - Foreign Activities of U.S. Taxpayers

61

Fri


Foreign Activities of U.S. Taxpayers Business Meeting

12

Fri

Foreign Activities of U.S. Taxpayers | Foreign Lawyers Forum | Transfer Pricing | U.S. Activities of Foreigners and Tax Treaties

Joint Current International Developments Panel - Foreign Activities of U.S. Taxpayers | Foreign Lawyers Forum | Transfer Pricing | US Activities of Foreigners and Tax Treaties

49 Fri

Foreign Activities of U.S. Taxpayers | Foreign Lawyers Forum | Transfer Pricing | U.S. Activities of Foreigners and Tax Treaties

Foreign Activities of U.S. Taxpayers , Transfer Pricing and U.S. Activities of Foreigners and Tax Treaties Luncheon

76 Fri


BEPS is a Big One for the Big Ones - Foreign Lawyers Forum

41

Fri


Everything You Always Wanted To Know About Fiscal State Aid But Were Afraid To Ask - Foreign Lawyers Forum

41 Fri Foreign Lawyers Forum Foreign Lawyers Forum Business Meeting 20 Fri


The National Taxpayer Advocate Discusses the Taxpayer Bill of Rights and How It Impacts Taxpayers - Individual and Family Taxation

35 Fri


Breaking Up Is Hard to Do: Protecting Divorcing Spouses From the IRS and Each Other - Individual and Family Taxation

37 Fri


Penalties and Penalty Abatement: A Refresher / Overview - Individual and Family Taxation

38

Fri Insurance Companies BEPS - Insurance Companies 14 Fri

Insurance Companies

Material Changes and Life Insurance Exchanges - Insurance Companies

12

Fri

Insurance Companies

Life / Non-Life Consolidated Returns - Insurance Companies

16

Fri


How BEPS Is Changing The International Tax Landscape - Investment Management

20




Fri


Tender Option Bond Derivatives and Life After Volcker: Tax issues for Market Participants, Including Funds and Banks - Investment Management

16 Fri


State Tax Considerations and Developments for Mutual Funds and Their Advisors - Investment Management

18 Fri Membership & Marketing Membership & Marketing 19 Fri Nominating Nominating Committee 27 Sat

Partnerships & LLCs

Service Firms (LLCs and LLPs) and/or Their Members in Bankruptcy: Tax and Non-Tax Aspects – Part 2. - Partnerships & LLCs

16 Sat

Partnerships & LLCs

Treating LLC Members Who Hold Small Interests as Employees - Partnerships & LLCs

27

Fri Partnerships & LLCs Oil and Gas Partnerships - Partnerships & LLCs 68 Fri

Partnerships & LLCs

Section 751(b) Proposed Regulations - Partnerships & LLCs

77

Fri

Partnerships & LLCs

Who Can Sign a Partnership Return? - Partnerships & LLCs

54

Fri

Partnerships & LLCs

Maybe It’s Not Too Late: Section 9100 Relief For Late Elections In the Partnership Context - Partnerships & LLCs

49 Fri

Partnerships & LLCs | Real Estate

Partnerships & LLCs and Real Estate Committees Luncheon

58

Sat

Pro Bono and Tax Clinics

Update from the Tax Court - Pro Bono and Tax Clinics

46

Sat

Pro Bono and Tax Clinics

National Taxpayer Advocate’s Annual Report to Congress - Pro Bono and Tax Clinics

45

Sat Pro Bono and Tax Clinics Tribal Tax Issues - Pro Bono and Tax Clinics 35 Sat

Pro Bono and Tax Clinics | Individual and Family Taxation

Fraud in the Return Preparation Industry - Pro Bono and Tax Clinics | Individual and Family Taxation

33 Fri Publications Publications N/C Fri Real Estate Real Estate Fund Allocation Issues - Real Estate 70 Fri Real Estate Hot Topics - Real Estate 61 Fri

Real Estate

Tenant Improvements and Other Leasing Issues - Real Estate

45

Fri

Real Estate

I Think I Have a Busted REIT. What Do I Do Now? - Real Estate

45

Sat

Real Estate | Partnerships & LLCs | S Corporations

Real Estate, Partnerships & LLCs and S Corporations “Shop Talking” Breakfast

82

Fri S Corporations Current Developments - S Corporations 31 Fri

S Corporations

S Corporations and Passive Activities - S Corporations

41

Fri

S Corporations

S Corporations and Back-to-Back Loans - S Corporations

37

Fri S Corporations S Corporations Banks - S Corporations 26



2015 Midyear Meeting Day Committee/Group Panel/Topic Headcount Sat


Current Developments in Sales, Exchanges & Basis - Sales, Exchanges & Basis

25

Sat


Tax Basis Treatment of Grantor Trusts - Sales, Exchanges & Basis

45

Sat


Exchanges in the Oil Patch - Sales, Exchanges & Basis

33

Sat


Sharing Arrangements in the Upstream Oil & Gas Industry - Sales, Exchanges & Basis

23

Sat


Helping Clients with Virtual Currency Transactions and Open Issues - Sales, Exchanges & Basis

21

Fri Section CLE Committee 17 Sat

Section Luncheon & Plenary Session

176

Fri Section Reception 211 Fri Sponsorships Sponsorships 5 Fri


Special Issues for Tax Practitioners Representing Partnerships, Tax Matters Partners or Partners in Partnerships (and Other Pass-Through Entities): Ensuring Compliance With Circular 230 and Other Practice Rules - Standards of Tax Practice

34 Fri


Ethical Issues in Federal Tax Practice - The Government Perspective - Standards of Tax Practice

86 Fri

Standards of Tax Practice | Young Lawyers Forum

What’s a Young Tax Attorney to Do When....? - Standards of Tax Practice | Young Lawyers Forum

30

Fri State & Local Taxes State & Local Taxes Luncheon 46 Fri

State & Local Taxes

Market Based Sourcing Regulations: Where the Rubber Meets the Road - State & Local Taxes

52

Fri

State & Local Taxes

How Are The Economic Substance Doctrine and Related Principles Being Applied in State Tax Cases? - State & Local Taxes

38 Fri

State & Local Taxes

State & Local Tax Issues Affecting the Oil & Gas Industry

43

Sat State & Local Taxes State & Local Taxes: Publication Subcommittees 10 Sat State & Local Taxes State & Local Taxes Practitioner’s Roundtable 38 Sat State & Local Taxes State & Local Taxes Vice-Chairs’ Planning Meeting N/C Fri

Tax Accounting

Treatment of Deferred Revenue in Taxable Asset Sales and Acquisitions - Tax Accounting

40

Fri

Tax Accounting

How Has the IRS Changed the Change in Accounting Method Procedures? - Tax Accounting

37

Fri Tax Accounting Current Developments - Tax Accounting 34 Fri

Tax Accounting

Accounting Methods Considerations for the Oil and Gas and Mining Industries - Tax Accounting

34

Fri


The History of Tax Exemption - Tax Exempt Financing

14

Fri


Private Business Use Implications of Accountable Care Organizations - Tax Exempt Financing

18





Transportation Bonds and PPP - Tax Exempt Financing

14

Fri


Legislative, Treasury and IRS Update - Tax Exempt Financing

20

Fri


Reorganizing the Internal Revenue Service to Achieve its Mission(s): Past, Present, and Future - Tax Policy and Simplification

30 Fri

Tax Policy and Simplification | Energy & Environmental Taxes

The Future of Energy Tax Policy - Tax Policy and Simplification | Energy & Environmental Taxes

21 Sat

Tax Practice Management | Diversity | Young Lawyers Forum

Practical Tips for Hiring and Retaining Good Tax Lawyers - Tax Practice Management | Diversity | Young Lawyers Forum

15 Sat

Teaching Taxation

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

43 Fri

Teaching Taxation | Sales, Exchanges & Basis | Real Estate

Repealing Section 1031? A Debate - Teaching Taxation | Sales, Exchanges & Basis | Real Estate

35 Fri Transfer Pricing BEPS Round Two: Risk and Capital - Transfer Pricing 41 Fri Transfer Pricing Intangibles in Litigation - Transfer Pricing 37 Thu Transfer Pricing Transfer Pricing Student Symposium 53 Fri Transfer Pricing Transfer Pricing Business Meeting 10 Thu

Transfer Pricing

Texas Tax Directors’ Roundtable - BEPS: More Questions Than Answers - Transfer Pricing

50

Fri

U.S. Activities of Foreigners and Tax Treaties

Selected Traps for the Unwary Pertaining to Foreign Investments in the United States - U.S. Activities of Foreigners and Tax Treaties

74 Fri


Foreign Investment in US Energy Assets - U.S. Activities of Foreigners and Tax Treaties

67 Fri


U.S. Activities of Foreigners and Tax Treaties Business Meeting

10 Thu Welcome Reception 171 Fri

Young Lawyers Forum | Pro Bono and Tax Clinics

Making Public Service Part of Your Practice - Young Lawyers Forum | Pro Bono and Tax Clinics

15