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Attorney-Client Privilege and Work Product Doctrine in Tax Controversies

From the ALI CLE program, "Attorney-Client Privilege and Work Product Doctrine in Tax Controversies" (December 15. 2017)

Original Date(s): December 15, 2017
Segment Runtime: 02:01:29
Speakers: Jerald David August

Includes the following course materials:

  • Attorney-Client Privilege and Work Product Doctrine in Tax Controversies and Tax Litigation
  • IRS Disclosure Statement Form 8275
  • IRS Schedule UTP for Form 1120
  • Petition to Quash IRS Summons for Production of TAWS Wells Fargo & Co v. U.S.

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Current Developments in Estate and Tax Planning 2017

From the ALI CLE program, "Current Developments in Estate and Tax Planning 2017" (December 13. 2017)

Original Date(s): December 13, 2017
Segment Runtime: 01:31:10
Speakers: Mickey R. Davis, Howard M. Zaritsky and Diana S.C. Zeydel

Includes the following course materials:

  • What’s Hot and What’s Not - Recent Tax Developments For Estate Planners

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Advanced Estate Planning Practice Update: Fall 2017

From the ALI CLE program, "Advanced Estate Planning Practice Update: Fall 2017" (November 2. 2017)

Original Date(s): November 2, 2017
Segment Runtime: 01:59:55
Speakers: Jeffrey N. Pennell, Kimberly E. Cohen, Lawrence P. Katzenstein, and Kathleen R. Sherby

Includes the following course materials:

  • Advanced Estate Planning Practice Update: Fall 2017

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The New Partnership Audit Rules: How Will They Impact Privately-Owned Businesses and Family Partnerships?

From the ALI CLE program, "The New Partnership Audit Rules: How Will They Impact Privately-Owned Businesses and Family Partnerships?" (September 26. 2017)

Original Date(s): September 26, 2017
Segment Runtime: 02:34:09
Speakers: Jerald David August and Gregory T. Armstrong

Includes the following course materials:

  • Proposed Regulations - Centralized Partnership Audit Regime (June 14, 2017)
  • Statute (Bipartisan Budget Act of 2015, Section 1101)
  • Technical Corrections to Centralized Partnership Audit Rules (H.R. 6439)
  • The New Partnership Audit Rules: Guidance Needed

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When A Tax Goes Unpaid: Understanding Fiduciary and Transferee Liability

From the ALI CLE program, "When A Tax Goes Unpaid: Understanding Fiduciary and Transferee Liability" (July 11. 2017)

Original Date(s): July 11, 2017
Segment Runtime: 01:58:54
Speakers: Jerald David August

Includes the following course materials:

  • Appendix
  • When A Tax Goes Unpaid: Understanding Fiduciary and Transferee Liability

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Advanced Estate Planning Practice Update: Summer 2017

From the ALI CLE program, "Advanced Estate Planning Practice Update: Summer 2017" (June 28. 2017)

Original Date(s): June 28, 2017
Segment Runtime: 01:59:28
Speakers: Jeffrey N. Pennell, Kimberly E. Cohen, Lawrence P. Katzenstein, and Kathleen R. Sherby

Includes the following course materials:

  • Advanced Estate Planning Practice Update: Summer 2017

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Drafting for the New Partnership Audit Rules in Operating Agreements

From the ALI CLE program, "Drafting for the New Partnership Audit Rules in Operating Agreements" (June 27. 2017)

Original Date(s): June 27, 2017
Segment Runtime: 01:34:53
Speakers: John M. Cunningham

Includes the following course materials:

  • Drafting for the New Partnership Audit Rules in Operating Agreements - Materials
  • Drafting for the New Partnership Audit Rules in Operating Agreements - Slides

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Cross-Border Estate Planning: Traps, Challenges, and Opportunities

From the ALI CLE program, "Cross-Border Estate Planning: Traps, Challenges, and Opportunities" (February 9. 2017)

Original Date(s): February 9, 2017
Segment Runtime: 01:31:19
Speakers: Ellen K. Harrison and Carlyn S. McCaffrey

Includes the following course materials:

  • Cross Border Planning: the “Traps,” Challenges and Planning Opportunities
  • Cross Border Planning: the “Traps,” Challenges and Planning Opportunities - Slides

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Disregarded Entities: Tax Planning Opportunities and Pitfalls

From the ALI CLE program, "Disregarded Entities: Tax Planning Opportunities and Pitfalls" (February 6. 2017)

Original Date(s): February 6, 2017
Segment Runtime: 01:58:00
Speakers: Jerald David August

Includes the following course materials:

  • Federal Income Taxation of Single Member Entities: 'Tax Nothings'
  • IRS Form 2553
  • IRS Form 8832
  • Rev. Proc. 2013-30, 2013-36 IRB 173 -- IRC Sec(s). 1362, 08-14-2013

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Obtaining IRS Private Letter Rulings: Remove the Uncertainty of Tax Consequences

From the ALI CLE program, "Obtaining IRS Private Letter Rulings: Remove the Uncertainty of Tax Consequences" (January 30. 2017)

Original Date(s): January 30, 2017
Segment Runtime: 01:00:27
Speakers: Ronald D. Aucutt and Stephanie Loomis-Price

Includes the following course materials:

  • IRS Private Letter Rulings: Removing Tax Uncertainties - Slides
  • When and How to Prepare an IRS Ruling Request

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Current Developments in Estate and Tax Planning

From the ALI CLE program, "Current Developments in Estate and Tax Planning" (December 13. 2016)

Original Date(s): December 13, 2016
Segment Runtime: 01:32:43
Speakers: Turney P. Berry, Amy E. Heller and Jeffrey N. Pennell

Includes the following course materials:

  • A Few Interesting Federal Transfer Tax Developments from 2016
  • Notable State Law Developments
  • Planning for High Net Worth Individuals Under the New Administration - Slides
  • Proposed §2704 Regulations
  • Tax Planning for High-Net-Worth Individuals under a Trump Presidency
  • Things I Think About When I Think About Transfer Tax Changes

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The New Section 385 Regulations: What You Need To Know

From the ALI CLE program, "The New Section 385 Regulations: What You Need To Know" (December 6. 2016)

Original Date(s): December 6, 2016
Segment Runtime: 01:04:14
Speakers: Layla J. Asali and Elizabeth G. Hale

Includes the following course materials:

  • The Final and Temporary Regulations Under Section 385 of the Internal Revenue Code (Federal Register / Vol. 81, No. 204)
  • The New Section 385 Regulations: What You Need To Know - Slides

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Advanced Estate Planning Practice Update: Fall 2016

From the ALI CLE program, "Advanced Estate Planning Practice Update: Fall 2016" (October 26. 2016)

Original Date(s): October 26, 2016
Segment Runtime: 01:58:35
Speakers: Jeffrey N. Pennell, Kimberly E. Cohen, Lawrence P. Katzenstein and Kathleen R. Sherby

Includes the following course materials:

  • Advanced Estate Planning Practice Update: Fall 2016

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"Open Mic” Questions and Answers

From the ALI CLE program, "Creative Tax Planning for Real Estate Transactions 2016" (September 26. 2016)

Original Date(s): September 26-27, 2016
Segment Runtime: 42:43
Speakers: Faculty

Includes the following course materials:

  • 'Bad Boy' Nonrecourse Carve-outs in Real Estate Loan Cause it to be Recourse -- or Do They?
  • Condominium Developers Can Avoid the Long-Term Contract Rules While Waiting for Code Sec. 460 Regulations
  • Final and Proposed Regulations Regarding Partnership Noncompensatory Options
  • Fundamentals of Partnership Taxation
  • IRS Stretches to Help a Taxpayer in New Disguised Sale Private Letter Ruling
  • Is it Cancellation of Debt (COD) Income?: New IRS Chief Counsel Advice Takes the Gas out of Great Plains Gasification
  • New Partnership Audit Rules: What You Need to Know and Do Now
  • New Taxpayer Favorable PLRs Allow Gain on Sale of Partnership Assets to be Offset by Disallowed Loss on Earlier Sale of Partnership Interest
  • Recent Developments Affecting Real Estate and Pass Through Entities
  • Testimony Before the Subcommittee on Select Revenue Measures Committee on Ways and Means United States House of Representatives

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“Open Mic” Questions and Answers

From the ALI CLE program, "Creative Tax Planning for Real Estate Transactions 2016" (September 26. 2016)

Original Date(s): September 26-27, 2016
Segment Runtime: 52:05
Speakers: Faculty

Includes the following course materials:

  • A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition In UPREIT and Other Partnership Contribution Transactions
  • Capital Gains in Real Estate Transactions
  • Defeasing Conduit Loans: Tax Issues, Premiums, Like-Kind Exchanges and 'New York Style'
  • Hot Like-Kind Exchange Issues
  • Making Section 704(C) Work for You
  • Maximizing Capital Gains in Real Estate Transactions
  • Partnerships and Disregarded Entities in Like-Kind Exchanges
  • Rev. Rul. 2003-56 Provides New Guidance on Like-Kind Exchanges of Leveraged Property
  • Rev. Rul. 99-43: When to Hold'em, When to Fold'em, and When to Book-Down

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Creative Deal Structures

From the ALI CLE program, "Creative Tax Planning for Real Estate Transactions 2016" (September 26. 2016)

Original Date(s): September 26-27, 2016
Segment Runtime: 56:56
Speakers: Messrs. R. Levine and Owen

Includes the following course materials:

  • Creative Deal Structures

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Creative Planning For Partnership Liability Allocations, Including the New Proposed Regulations

From the ALI CLE program, "Creative Tax Planning for Real Estate Transactions 2016" (September 26. 2016)

Original Date(s): September 26-27, 2016
Segment Runtime: 01:19:17
Speakers: Mr. Rubin and Ms. Whiteway

Includes the following course materials:

  • Creative Planning for Partnership Liability Allocations, including the New Proposed Regulations
  • The Proposed Regulations on Partnership Allocations with Respect to Contributed Property

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Fundamentals of Partnership Taxation

From the ALI CLE program, "Creative Tax Planning for Real Estate Transactions 2016" (September 26. 2016)

Original Date(s): September 26-27, 2016
Segment Runtime: 56:59
Speakers: Messrs. R. Levine and Rubin

Includes the following course materials:

  • 'Bad Boy' Nonrecourse Carve-outs in Real Estate Loan Cause it to be Recourse -- or Do They?
  • Fundamentals of Partnership Taxation

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Hot Like-Kind Exchange Issues

From the ALI CLE program, "Creative Tax Planning for Real Estate Transactions 2016" (September 26. 2016)

Original Date(s): September 26-27, 2016
Segment Runtime: 01:01:06
Speakers: Messrs. R. Levine and Schachat

Includes the following course materials:

  • Defeasing Conduit Loans: Tax Issues, Premiums, Like-Kind Exchanges and 'New York Style'
  • Hot Like-Kind Exchange Issues
  • Partnerships and Disregarded Entities in Like-Kind Exchanges
  • Rev. Rul. 2003-56 Provides New Guidance on Like-Kind Exchanges of Leveraged Property

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Hot Topics from the Government Perspective

From the ALI CLE program, "Creative Tax Planning for Real Estate Transactions 2016" (September 26. 2016)

Original Date(s): September 26-27, 2016
Segment Runtime: 47:04
Speakers: Mr. Rubin and Mss. Borosh and Young

Includes the following course materials:

  • Condominium Developers Can Avoid the Long-Term Contract Rules While Waiting for Code Sec. 460 Regulations
  • Final and Proposed Regulations Regarding Partnership Noncompensatory Options
  • IRS Stretches to Help a Taxpayer in New Disguised Sale Private Letter Ruling
  • Is it Cancellation of Debt (COD) Income?: New IRS Chief Counsel Advice Takes the Gas out of Great Plains Gasification
  • New Taxpayer Favorable PLRs Allow Gain on Sale of Partnership Assets to be Offset by Disallowed Loss on Earlier Sale of Partnership Interest
  • Testimony Before the Subcommittee on Select Revenue Measures Committee on Ways and Means United States House of Representatives

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