Thursday, November 2, 2017
In a recent post of mine I referenced Game of Thrones (“GOT”), which is an HBO TV series based on the book collection “A Song of Ice and Fire” by George R.R. Martin. A commentator asked “Would it surprise you to know that some of your readers don't have the faintest idea of what your reference to "Game of Thrones" means?”
For such readers, I regret that you have not read this incredible fantasy adventure series. Not only because it’s good, but because references such as mine abound. Me nem nesa. A particularly amusing and creative spin comes from the otherwise staid ABA Section on Taxation. Each year the Tax Section puts out a “Tax Challenge” for both J.D. students and LL.M. students. This year’s Tax Challenge looks at some tax implications from GOT. Here’s how it starts:
You...recently moved to Westeros, a geographic area in the central United States, and accepted a generous offer from the prestigious Westerosi law firm of Citadel & Hightower. One of Westeros’s wealthier residents, Ty Lannister, heard that Citadel & Hightower was hiring some of the brightest young legal minds, and so retained your firm to assist him with planning for and evaluating his income tax burden. .... Archmaester Ebrose, the managing partner of Citadel & Hightower’s tax group, requests you analyze Ty Lannister’s tax issues and prepare a ten page memorandum addressing the questions presented below.
The problem goes on to introduce students to a host of Ty’s tax issues. He has compensation issues from his changing jobs, from being City Manager at King’s Landing for his sister Cindy to being City Manager at Meereen for Danielle Taragon. He has personal injury issues from a tort committed on him. He has inheritance issues when his father dies. He has start-up, expense, and capitalization issues when he starts a fur coat company on the advice of his friend John Snow who is always complaining that “Winter is coming.”
There’s much more to enjoy in this fact pattern. My kudos go to the folks who put this year’s Tax Challenge together!