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Pepperdine University School of Law

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Friday, April 17, 2015

Pepperdine Law Review Symposium Today On International Arbitration And The Courts

Brochure 2I am sitting in on a wonderful Pepperdine Law Review symposium on International Arbitration and the Courts, organized by my friends and colleagues Trey Childress and Jack Coe. There is an all-star cast of speakers, including George Bermann (Columbia), Andrea Bjorklund (McGill), Christopher Drahoal (Kansas), Alan Rau (Texas), Jan Schaefer (King & Spalding, Frankfurt), Maxi Scherer (Queen Mary University of London), Abby Cohen Smutny (White & Case, Washington, D.C.), and Jarrod Wong (McGeorge). You can view the live stream here.

April 17, 2015 in Conferences, Legal Education | Permalink | Comments (0)

Friday, April 10, 2015

Tax Presentations at Today's Indiana Symposium on Living Without in America

Indiana (2015)The Indiana Journal of Law and Social Equality hosts a symposium today on Living Without in America.  Tax Prof Ajay Mehrotra is moderating a panel on Economics and Poverty, with two tax presentations:

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April 10, 2015 in Conferences, Tax | Permalink | Comments (0)

Thursday, April 9, 2015

NBER Public Economics Program Meeting

NBERThe National Bureau of Economic Research's two-day Public Economics Program Meeting kicks off today in Boston with several tax papers:

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April 9, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, April 8, 2015

Brown: The IRS Should Report on Tax Returns Filed by All 535 Members of Congress

535National Journal, Congressional Tax Returns Could Tell Us a Lot:

Dorothy Brown, a professor at Emory University who specializes in tax law, has proposed an idea to finally spur tax reform: examining the tax returns of all 535 members of Congress. I recently spoke with her about the proposal, which she calls "The 535 Report." Our conversation has been edited and condensed. ...

How long have you been talking about the 535 Report?

I spoke about this at a Pepperdine University Law School symposium in January 2013 [Tax Advice for the Second Obama Administration] and wrote a law-review article for the symposium that was published that April. [The 535 Report: A Pathway to Fundamental Tax Reform, 40 Pepp. L. Rev. 1155 (2013)] I study presidential tax returns, which are voluntarily disclosed, and I started thinking: Imagine what I'd find if I had congressional tax returns.

What needs to be done to take this idea further?

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April 8, 2015 in Conferences, Congressional News, Scholarship, Tax | Permalink | Comments (0)

Saturday, April 4, 2015

18th Annual Critical Tax Theory Conference Concludes Today at Northwestern

Northwestern (2014)The 18th Annual Critical Tax Theory Conference concludes today at Northwestern:

Critical tax scholarship aims at looking beyond the language of the Code and regulations to examine what the tax law actually does. It has roots in critical legal studies generally, and therefore Critical tax scholars frequently ask why the tax laws are the way they are and what impact tax laws have on historically disempowered groups, such as people of color; women; lesbian, gay, bisexual, and transgendered individuals; low-income and poor individuals; the disabled; and nontraditional families. But Critical tax scholarship is not limited either to those topics or to any particular methodology.

Critical tax scholarship shares the following goals: (1) to uncover bias in the tax laws; (2) to explore and expose how the tax laws both reflect and construct social meaning; and (3) to educate nontax scholars and lawyers about the interconnectedness of taxation, social justice, and progressive political movements. Critical tax scholars employ a variety of methods to achieve these goals such as bringing "outsider" perspectives to the study of tax law; using historical material, contemporary case studies, and personal or fictional narratives to illustrate the practical impact of the tax laws on individuals and groups; interpreting social science and economic data to show how the tax laws impact groups differently; and exploring the interconnectedness of tax laws with economic forces such as the labor market and international financial and political development.

Panel #6:  General Tax Base (Moderator: Alice Abreu (Temple))

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April 4, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Friday, April 3, 2015

18th Annual Critical Tax Theory Conference Kicks Off Today at Northwestern

Northwestern (2014)The 18th Annual Critical Tax Theory Conference kicks off today at Northwestern:

Critical tax scholarship aims at looking beyond the language of the Code and regulations to examine what the tax law actually does. It has roots in critical legal studies generally, and therefore Critical tax scholars frequently ask why the tax laws are the way they are and what impact tax laws have on historically disempowered groups, such as people of color; women; lesbian, gay, bisexual, and transgendered individuals; low-income and poor individuals; the disabled; and nontraditional families. But Critical tax scholarship is not limited either to those topics or to any particular methodology.

Critical tax scholarship shares the following goals: (1) to uncover bias in the tax laws; (2) to explore and expose how the tax laws both reflect and construct social meaning; and (3) to educate nontax scholars and lawyers about the interconnectedness of taxation, social justice, and progressive political movements. Critical tax scholars employ a variety of methods to achieve these goals such as bringing "outsider" perspectives to the study of tax law; using historical material, contemporary case studies, and personal or fictional narratives to illustrate the practical impact of the tax laws on individuals and groups; interpreting social science and economic data to show how the tax laws impact groups differently; and exploring the interconnectedness of tax laws with economic forces such as the labor market and international financial and political development.

Panel #1:  Exemptions and Subsidies (Moderator: Evelyn Brody (Chicago-Kent))

  • Neil Buchanan (George Washington), Social Security Is Fair to Future Generations
  • Darryll Jones (Florida A&M), Payments in Lieu of Taxes: The Canary in the Mine of Charitable Property Tax Exemption
  • Richard Schmalbeck (Duke), Declaratory Judgments and Charitable Borders
  • Nancy Shurtz (Oregon) & Maria Di Miceli (IRS), Tax-Exempt Status of Hospitals: Addressing Accountability after the ACA

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April 3, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, March 27, 2015

Minnesota Hosts Symposium Today on Reforming the IRS

Minnesota LogoMinnesota hosts a Tax Policy Symposium today on Reforming the IRS:

Congress asks the IRS to handle a variety of government functions—not just collecting taxes, but also implementing the Affordable Care Act, monitoring the activities of tax-exempt organizations, and administering refundable tax credits designed to accomplish various social welfare goals, among other myriad tasks. Even beyond the controversy over its scrutiny of conservative political organizations, the IRS faces criticism for its handling of many of its congressionally-assigned functions, from its declining ability to handle routine taxpayer phone calls to its efforts to address fraud in the Earned Income Tax Credit program. Meanwhile, Congress has reduced the IRS’s budget, making it difficult for the IRS to accomplish all of its myriad tasks successfully. But even if Congress gave the IRS better funding, could the IRS accomplish all that Congress asks of it effectively? Or has the IRS reached a point institutionally at which it simply cannot do its many jobs well, irrespective of the funding that Congress provides? If it cannot, then what might IRS reform look like? [The symposium papers will be published in the Spring 2016 issue of the Columbia Journal of Tax Law.]

Keynote Address:   Nina Olson (National Taxpayer Advocate), The IRS and Taxpayer Trust: Recent Research on Promoting Compliance

Panel #1:

  • Steve Johnson (Florida State), Law From the Sublime to the Ridiculous and Most Things in Between: Options for Tax Administration in an Era of Growing Responsibilities for Shrinking Budgets
  • Leandra Lederman (Indiana), Does the IRS Need Further Reform? 
  • Commenters:  Andy Grewal (Iowa), Joe Thorndike (Tax Analysts)
  • Moderator:  Morgan Holcomb (Hamline)

Panel #2:

  • Lloyd Mayer (Notre Dame), The Better Part of Valour is Discretion: Should the IRS Surrender Its Oversight of Tax-Exempt Organizations?
  • Amy Monahan (Minnesota), The IRS as Health Care Agency
  • Commenters:  Paul Caron (Pepperdine), Chris Walker (Ohio State)
  • Moderator:  Claire Hill (Minnesota)

Panel #3:

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March 27, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Virginia Tax Study Group Meets Today

Virginia Tax Review (2015)The Virginia Tax Study Group meets today:

Panel #1:  D.C. Panel

  • Cameron Arterton (Deputy Tax Legislative Counsel, U.S. Treasury Department)
  • Tony Coughlin (Tax Counsel, Senate Finance Committee)
  • Rohit Kumar (Principal, PricewaterhouseCoopers)
  • Cecily Rock (Senior Legislation Counsel, Joint Committee on Taxation)
  • Jon Traub (Principal, Deloitte)

Panel #2:  The Significance of Recent Inversion Activity for Business Tax Reform, and Administrative Response

  • Ed Kleinbard (USC), Competitiveness’ Has Nothing to Do With It, 144 Tax Notes 1055 (Sept. 1, 2014)
  • Commentators:  Steve Shay (Harvard), Brenda Zent (Attorney-Advisor, Office of International Tax Counsel, U.S. Treasury Department)
  • Moderator:  Ruth Mason (Virginia)

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March 27, 2015 in Conferences, Tax | Permalink | Comments (0)

Thursday, March 26, 2015

April 1 Call for Papers Deadline: IFA International Tax Symposium

IFAThe International Fiscal Association has issued a Call for Papers for the Second International Tax Research Symposium in Basel, Switzerland:

We are pleased to announce the call for papers for the Second International Tax Research Symposium held in conjunction with the 69th Congress of the International Fiscal Association in Basel, Switzerland (August 30 to September 3, 2015). After the success of the first International Tax Research Symposium held during the IFA Congress in Boston in 2012 we are delighted to invite you for the Second International Tax Research Symposium in Basel. The International Tax Research Symposium aims to provide a platform for international scholars in international taxation. The Second IFA International Tax Symposium will be held on Sunday, August 30, 2015 (afternoon) in Basel and is supported by the International Fiscal Association. 

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March 26, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, March 25, 2015

Kirsch, Schneider Debate Citizenship-Based Taxation v. Residence-Based Taxation

ACAThe American Citizens Abroad Global Foundation has released a new video aimed at breaking down the merits of Residence-based taxation in a clear and simple way for key decision makers and the public:  21st Century Taxation of Americans Abroad: Citizenship-based Taxation vs. Residence-based Taxation

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March 25, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (5)

Conference on Billy Joel and the Law

Billy Joel_Page_1Touro hosted a two-day conference on Billy Joel and the Law this week:

This conference follows in the path of previous conferences exploring connections between the work of a singer-songwriter and the American legal system. In 2005, Widener Law School hosted The Lawyer as Poet Advocate: Bruce Springsteen and the American Lawyer, and in 2011, Fordham Law School hosted Bob Dylan and the Law, co-sponsored by Touro Law Center. Building on the success of these events, we will consider ways in which Billy Joel’s work relates to American law, society, and culture. Sessions will offer a wide range of perspectives, including those of judges, lawyers, law professors, and music scholars. We look forward to a meaningful and entertaining event that will foster thought provoking conversations about the relevance of Billy Joel’s work to our understanding of the American legal system.

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March 25, 2015 in Conferences, Legal Education | Permalink | Comments (5)

Friday, March 20, 2015

Tulane Hosts 5th Annual Tax Roundtable Today in New Orleans

Tulane (2015)Tulane hosts its 5th Annual Tax Roundtable today:

The Tulane Tax Roundtable brings together tax scholars from around the country, resident Tulane Faculty, and Tulane students for discussion and debate about important tax policy issues of our time. The roundtable showcases the drafts and works-in-progress of its participants and subjects these works to rigorous analysis in a discussant-driven workshop format.

James Alm (Tulane), Using Public Information to Estimate Self-Employment Earnings of Informal Suppliers (with Brian Erard (B. Erard & Associates))
DiscussantSusan C. Morse (Texas)

Steven A. Dean (Brooklyn), SE(c)(3): A Catalyst for Social Enterprise Crowdfunding (with Dana Brakman Reiser (Brooklyn))
Discussant:  Kirk J. Stark (UCLA)

Andrew T. Hayashi (Virginia), Taxing Committed Consumption and the Simple Economics of Paying in Kind
Discussant:  Mirit Eyal-Cohen (Alabama)

Alex Raskolnikov (Columbia), Rational Decisions Under Legal Uncertainty
Discussant:  James Alm (Tulane)

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March 20, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Minnesota Symposium: Reforming the IRS

Minnesota LogoMinnesota hosts a Tax Policy Symposium next Friday, March 27,  on Reforming the IRS:

Congress asks the IRS to handle a variety of government functions—not just collecting taxes, but also implementing the Affordable Care Act, monitoring the activities of tax-exempt organizations, and administering refundable tax credits designed to accomplish various social welfare goals, among other myriad tasks. Even beyond the controversy over its scrutiny of conservative political organizations, the IRS faces criticism for its handling of many of its congressionally-assigned functions, from its declining ability to handle routine taxpayer phone calls to its efforts to address fraud in the Earned Income Tax Credit program. Meanwhile, Congress has reduced the IRS’s budget, making it difficult for the IRS to accomplish all of its myriad tasks successfully. But even if Congress gave the IRS better funding, could the IRS accomplish all that Congress asks of it effectively? Or has the IRS reached a point institutionally at which it simply cannot do its many jobs well, irrespective of the funding that Congress provides? If it cannot, then what might IRS reform look like? [The symposium papers will be published in the Spring 2016 issue of the Columbia Journal of Tax Law.]

Keynote Address:   Nina Olson (National Taxpayer Advocate), The IRS and Taxpayer Trust: Recent Research on Promoting Compliance

Panel #1:

  • Steve Johnson (Florida State), Law From the Sublime to the Ridiculous and Most Things in Between: Options for Tax Administration in an Era of Growing Responsibilities for Shrinking Budgets
  • Leandra Lederman (Indiana), Does the IRS Need Further Reform? 
  • Commenters:  Andy Grewal (Iowa), Joe Thorndike (Tax Analysts)
  • Moderator:  Morgan Holcomb (Hamline)

Panel #2:

  • Lloyd Mayer (Notre Dame), The Better Part of Valour is Discretion: Should the IRS Surrender Its Oversight of Tax-Exempt Organizations?
  • Amy Monahan (Minnesota), The IRS as Health Care Agency
  • Commenters:  Paul Caron (Pepperdine), Chris Walker (Ohio State)
  • Moderator:  Claire Hill (Minnesota)

Panel #3:

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March 20, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

LegalED: Igniting Law Teaching -- A TEDx-Style Conference on the Future of Legal Education

March 20LegalED hosts its second conference today on Igniting Law Teaching: A TEDx Style Conference on the Future of Legal Education (webcast) at American:

The conference will feature talks by 30 law school academics and practitioners from the US, Canada and England in a TEDx-styled conference to share ideas on teaching methodologies.  LegalED’s Teaching Pedagogy video collection includes many of the talks from last year’s conference, which have been viewed collectively more than 5000 times. ...

The Igniting Law Teaching conference is unlike other gatherings of law professors.  Here, talks will be styled as TEDx Talks, with each speaker on stage alone, giving a well scripted and performed 8 minute talk about an aspect of law school pedagogy.

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March 20, 2015 in Conferences, Legal Education, Teaching | Permalink | Comments (0)

Thursday, March 19, 2015

Chicago Symposium: Grassroots Innovation and Regulatory Adaptation

Chicago Logo 2Symposium, Grassroots Innovation and Regulatory Adaptation, 82 U. Chi. L. Rev. Dialogue 1-115 (2015):

March 19, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, March 16, 2015

Final Day for Proposals: Association for Mid-Career Tax Law Professors

Today is the final day to respond to the Call for Proposals issued by the Association for Mid-Career Tax Law Professors (“AMT”):

Mid-CareerAMT is a recurring conference intended to bring together relatively recently-tenured professors of tax law for scholarly discussion. Our inaugural meeting will be held on Thursday and Friday, June 4 & 5, 2015, on the campus of The Ohio State University Moritz College of Law. We anticipate that official proceedings will wrap up by noon on June 5. Thanks to the generous support of Law, Finance and Governance @ Ohio State and The Ohio State University Moritz College of Law, AMT is able to provide attendees with conference meals and refreshments. AMT can commit to ensuring that these meals will not be “lavish or extravagant under the circumstances.” Attendees will be expected to cover their own travel and lodging expenses.

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March 16, 2015 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

Wednesday, March 4, 2015

Blouin Presents The Role of 'Check-the-Box' on Multinational Tax Planning Today at Penn

Blouin (2015)Jennifer Blouin (Pennsylvania) presents Does Organizational Form Affect Firms' Foreign Operations? The Role of 'Check-the-Box' on Multinational Tax Planning at Pennsylvania today as part of its Tax Law and Policy Workshop Series hosted by Chris William Sanchirico and Reed Shuldiner:

This study investigates the effect of the 1997 check-the-box tax legislation on the current effective income tax rates of U.S. multinational firms. Following the empirical methodology developed in Dyreng and Lindsey (2009), we measure the effect that the change in legislation has on the average worldwide, U.S., and foreign taxes paid on worldwide, federal and foreign pretax book income for a large sample of U.S. multinational firms. We find that on average U.S. multinational firms’ worldwide tax rates declined by 4.3% in the post-1996 period. Further, we find that the effect of the legislation was greater on U.S. multinational firms’ average foreign tax rates as compared to their average U.S. foreign tax rates. Our results also suggest that the effect is concentrated in the U.S. multinational firms that had a greater change in their ownership structures and a greater change in the balance of their intercompany payments in the post-1996 period. Although our results do suggest that the 1997 legislation served to reduce U.S. tax collections, our results imply that the 1997 legislation had a greater effect on firms’ foreign tax burdens.

March 4, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Saturday, February 28, 2015

Pepperdine Hosts Conference on Wisdom Law and Lawyers

WisdomI had the honor today of participating in the annual Nootbaar Institute on Law, Religion, and Ethics conference at Pepperdine on Wisdom Law and Lawyers (program) organized by Robert F. Cochran and Michael Helfand:

At a time when law is seen by many as purely a matter of power politics and the lawyer's role as purely a matter of pursuing client economic interests, we want to consider how wisdom should influence deliberations in legislative chambers, courts, and lawyers' offices. Both theoretical wisdom and practical wisdom have much to say about law. We hope to learn from many traditions, both religious and secular.

The conference will be organized around three general themes:

1. The Nature of Wisdom – What do our traditions teach about the nature of wisdom? Speakers are likely to address the conference topics from Greek, Jewish, Christian, Islamic, Buddhist, and Confucian perspectives.

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February 28, 2015 in Conferences, Legal Education | Permalink | Comments (0)

Thursday, February 26, 2015

American Taxation Association 2015 Midyear Meeting

ATA LogoThe three day 2015 Midyear Meeting of the American Taxation Association kicks off today in Washington, D.C. The full program is here.

February 26, 2015 in Conferences, Tax | Permalink | Comments (0)

Friday, February 20, 2015

Chapman Symposium: Business Tax Reform

Chapman Logo (2014)Symposium, Business Tax Reform: Emerging Issues in the Taxation of U.S. Entities, 18 Chap. L. Rev. 1-314 (2014):

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February 20, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, February 18, 2015

Call for Papers: International Energy Taxation

Call for papers:  International Taxation in the Energy Sector:

Oil, Gas and Energy Law Intelligence invites submissions for a special issue on International Taxation in the Energy Sector. ... Submissions of relevant tax articles are invited for inclusion in this special tax issue. It is intended that the majority of papers will cover international taxation, but country specific tax issues related to the energy sector will also be welcomed. Potential topics related to these international tax issues could include:

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February 18, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, February 12, 2015

Zolt: Politics and Taxation

Eric M. Zolt (UCLA), Politics and Taxation: An Introduction, 67 Tax L. Rev. 453 (2014):

This essay provides some observations about the relationship of politics and taxation and reviews the articles and commentaries that were prepared for the Third Annual NYU/UCLA Tax Policy Conference on Politics and Taxation held in Los Angeles on October 18, 2013. Understanding the relationship between politics and taxation is important for several reasons. First, it may help explain why countries adopt different taxing and spending patterns. It may also explain why the frequency, success and stability of tax reform efforts vary among countries. Finally a better understanding of politics and taxation may provide insights into such questions on how institutions shape policy outcomes and how tax policy may contribute to successful democratic governments.

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February 12, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, February 6, 2015

Call for Papers: Citizenship and Taxation Symposium at Michigan

Michigan Law Logo (2015)Call for Papers:

We invite paper proposals for a Citizenship and Taxation Symposium, to be held at the University of Michigan Law School, Ann Arbor, Michigan, on Friday, October 9, 2015. This symposium will focus on ongoing developments regarding the unique US practice of taxing citizens who live permanently overseas. With the adoption of regimes such as the expatriation tax added by IRC § 877A and the Foreign Account Tax Compliance Act (FATCA), the taxation of non-residents with US person status now has serious and tangible implications. ...

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February 6, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, February 4, 2015

Call for Speakers: CALI Conference at Denver Law School

CALI (2015)CALI has issued a Call for Speakers to law faculty, librarians, and IT staff (April 3 deadline) for its 25th Annual CALI Conference for Law School Computing on  June 18-20, 2015 at the University of Denver Sturm College of Law.  The conference registration fee is reduced to $95 for speakers.

For the 25th Annual Conference for Law School Computing® (aka CALIcon), we wanted a theme that embraced the changes and opportunities in Legal Education. Yes, we are in a crisis, but we are also in the middle of one of the most innovative and experimental periods in legal education history. The freedom and encouragement to change our pedagogies and curricula has been given like never before. Flipped classrooms, experiential learning, incubators, formative assessment - the list goes on and on.

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February 4, 2015 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

Tuesday, February 3, 2015

ABA Tax Section Midyear Meeting

ABA Tax Section Logo (2012)Tax Prof speakers at last week's ABA Tax Section Midyear Meeting in Houston (full program here):

  • Linda Beale (Wayne State), Standards of Tax Practice
  • Brad Borden (Brooklyn), Danshera Cords (Albany), Elaine Gagliardi (Montana), Michael Lang (Chapman), Charlene Luke (Florida), Roberta Mann (Oregon), Bruce McGovern (South Texas), Marty McMahon (Florida), Teaching Taxation 

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February 3, 2015 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0)

Friday, January 30, 2015

UCLA & Tax Policy Center Host Conference Today on International Tax Reform

UCLAUCLA and the Tax Policy Center host a conference today on International Tax Reform from 9:00 a.m. - 4:00 p.m. PST (webcast here):

Panel #1:  Political Economy of International Tax Reform

Presenters:  Alan Auerbach (UC-Berkeley), Jon Talisman (Capitol Tax Partners)
Commentator:  Jason Oh (UCLA)

Panel #2:  Inversions: Where Do We Go From Here?

Presenters:  Mihir Desai (Harvard), Victor Fleischer (San Diego)
Commentator:  Larry Stein (Latham & Watkins)

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January 30, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Tuesday, January 27, 2015

TPC Program on Dynamic Scoring: Now What?

The Tax Policy Center hosted a program yesterday on Dynamic Scoring: Now What? (video here):

On January 26, the Urban-Brookings Tax Policy Center and the Hutchins Center on Fiscal and Monetary Policy at Brookings took a close look at how dynamic scoring is done, the models that JCT and CBO use for macroeconomic analysis of tax bills and other major legislation (immigration, Affordable Care Act, infrastructure), and how to communicate this analysis accurately.

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January 27, 2015 in Conferences, Congressional News, Tax | Permalink | Comments (0)

15th Annual Conducting Empirical Legal Scholarship Workshop

Wash.U. LogoThe 15th Annual Workshop on Conducting Empirical Legal Scholarship, co-taught by Lee Epstein (Washington University) and Andrew D. Martin (Michigan), will run from June 15-17 at Washington University in St. Louis. The workshop is for law school faculty, lawyers, political science faculty, and graduate students interested in learning about empirical research and how to evaluate empirical work. It provides the formal training necessary to design, conduct, and assess empirical studies, and to use statistical software (Stata) to analyze and manage data.

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January 27, 2015 in Conferences, Legal Education | Permalink | Comments (0)

Monday, January 26, 2015

FBA Tax Section Hosts Tax Practice & Procedure Monthly Roundtable Today

FBA Tax SectionThe Federal Bar Association Tax Section hosts its free Tax Practice & Procedure Monthly Roundtable today from 1:00-2:00 p.m. EST (dial-in number: 866-690-2070; Password:  3008455329):

Auditing of Large Partnerships
Monte Jackel, Jackel Tax Law

The GAO recently issued a report on the audit of large partnerships. There was also a panel discussion on the topic at the most recent University of Chicago Tax Institute. The GAO report concludes that the audit rate is very low. But that is not really where the problem is. Monte Jackel, who has spent decades working on partnership issues on behalf of the government and the IRS, will address the significance of the developing IRS approach to auditing partnership returns

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January 26, 2015 in Conferences, Tax | Permalink | Comments (0)

Friday, January 23, 2015

ITPF, TPC Conference Today on Corporate Inversions and Tax Policy

TPC 2The International Tax Policy Forum and Tax Policy Center are co-hosting a conference today at the Brookings Institution from 8:50 - 11:15 a.m. (webcast here) on Corporate Inversions and Tax Policy:

Corporate inversions, which change the tax home of a multinational corporation by merging it with a foreign company that then becomes the parent of the multinational group, received considerable attention in 2014, including from the IRS, which in September released a notice describing regulations the government intends to issue to reduce the tax benefits of future inversion transactions. Corporate inversions elicit strong reactions: some call U.S. companies involved in these transactions “unpatriotic,” while others view them as symptomatic of an out-of-step U.S. corporate tax system, with its high rate and worldwide reach that differs from the territorial taxes widely used by other countries. These inversions are also not unique to the U.S, with firms in the United Kingdom and elsewhere also using them during periods when their foreign incomes were subject to high rates of domestic taxation.

On Friday, January 23rd, the Urban-Brookings Tax Policy Center and the International Tax Policy Forum will co-host a conference examining the history, causes, and consequences of corporate inversions, the policy response in the United Kingdom, and what actions the U.S. should take. Experts from a variety of backgrounds will share their perspectives, and Senator Orrin Hatch will give keynote remarks at the close of the event.

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January 23, 2015 in Conferences, Tax | Permalink | Comments (0)

Tuesday, January 13, 2015

49th Annual Heckerling Institute on Estate Planning

Heckerling Cover_Page_1Tax Prof speakers at this week's 49th Annual Heckerling Institute on Estate Planning in Orlando:

  • Sam Donaldson (University of Washington), Recent Developments 2014
  • David Herzig (Valparaiso), The Most Important Elements, Clauses and Ideas for Trust Design
  • Susan Gary (Oregon), Restricted Charitable Gifts: Drafting Agreements that Stand the Test of Time
  • Tom Gallinas (Iowa), A Closer Look at Powers of Appointment in the Current Planning Environment
  • Mary Radford  (Georgia State), Case Studies in the Ethical Considerations in Acting as an Executor or Trustee

January 13, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Monday, January 12, 2015

Joint Tax Committee Releases List of Expiring Federal Tax Provisions, 2014-2024

Joint Tax CommitteeThe Joint Committee on Taxation has released its annual List of Expiring Federal Tax Provisions 2014-2024 (JCX-1-15):

This document ... provides a listing of Federal tax provisions (other than those providing time-limited transition relief after the repeal of an underlying rule) that expired or are currently scheduled to expire in 2014-2025 (with references to the applicable section of the Internal Revenue Code of 1986 or other applicable law).

For purposes of compiling this list, the staff of the Joint Committee on Taxation considers a provision to be expiring if, at a statutorily specified date, the provision expires completely or reverts to the law in effect before the present-law version of the provision. Certain provisions terminate on dates that refer to a taxpayer’s taxable year and not a calendar year. For these provisions, the expiration dates listed in this document apply with respect to calendar year taxpayers. The expiration dates of such provisions may differ, however, with respect to fiscal year taxpayers or taxpayers with short taxable years. Years in which there are no expiring provisions are not listed in the document. Under present law, there are no Federal tax provisions scheduled to expire in years after 2021.

January 12, 2015 in Conferences, Tax | Permalink | Comments (0)

Tuesday, January 6, 2015

Villanova Symposium: Selective Issues in Tax Administration

Villanova Law LogoSymposium, Selective Issues in Tax Administration, 59 Vill. L. Rev. 409-648 (2014):

The Increasing Importance of the Whistleblower Provisions in U.S. Tax Administration

The IRS's Efforts to Regulate Unlicensed Tax Return Preparers

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January 6, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, January 5, 2015

Today's AALS Annual Meeting Highlights

AALSToday's highlights at the AALS Annual Meeting in Washington, D.C.:

  • Retirement Policy: Incremental v. Fundamental Reform (8:30 - 10:15) (Maryland Suite B, Lobby Level):  Norman Stein (Drexel), Nancy Altman (Social Security Works), Daniel Halperin (Harvard), Regina Jefferson (Catholic)
  • Differential Affordability: Understanding the Net Cost of Law School (10:30 - 12:15) (Maryland Suite A, Lobby Level):  Michael Dean (Mercer), Jerome Organ (St. Thomas)
  • Tenure, Austerity, and Academic Freedom (10:30 - 12:15) (Delaware Suite B, Lobby Level):  Anthony Paul Farley (Albany), Tayyab Mahmud (Seattle), Natsu Taylor Saito (Georgia State), Terry Smith (DePaul), Donna Young (Albany)
  • Merit Scholarship Policies and the Impact on our Classes and Legal Education (10:30 - 12:15) (Maryland Suite B, Lobby Level):  R. Jay Shively (Wake Forest), Susan Bogart (Penn State), Cary Cluck (Mississippi), Tracy Simmons (McGeorge)

January 5, 2015 in Conferences, Legal Education | Permalink | Comments (0)

Sunday, January 4, 2015

Today's AALS Annual Meeting Highlights

AALSToday's highlights at the AALS Annual Meeting in Washington, D.C.:

  • Center for Computer-Assisted Legal Instruction (CALI) Breakfast and Annual Members Meeting (7:15 - 8:30) (Marriott Balcony B, Mezzanine Level)
  • Full-time, Long-term Bar Passage Required: Understanding the New Legal Job Market (8:30 - 10:15) (Maryland Suite C, Lobby Level):  Adam Chodorow (Arizona State), James Leipold (NALP), Regina Pisa (Goodwin Procter, Boston)
  • Bringing Numbers into Basic and Advanced Business Associations Courses: How and Why to Teach Accounting, Finance, and Tax (10:30 - 12:15) (Virginia Suite A, Lobby Level) Jeffrey Lipshaw (Suffolk), Lawrence Cunningham (George Washington), Andrew Haile (Elon), Usha Rodrigues (Georgia), Christyne Vachon (North Dakota), Eric Chaffee (Toledo), Franklin Gevurtz (McGeorge)
  • Taxation, Inequality, and Social Mobility (2:00 - 3:45) (Thurgood Marshall North, Mezzanine Level):  Miranda Perry Fleischer (San Diego), Miles Corak (Ottawa), Lily Kahng (Seattle), Edward McCaffery (USC), James Repetti (Boston College), Kerry Ryan (St. Louis)

January 4, 2015 in Conferences, Legal Education | Permalink | Comments (0)

Saturday, January 3, 2015

Pepperdine Reception Tonight at the AALS Annual Meeting

Pepperdine LogoIf you are at the AALS Annual Meeting in Washington, D.C.:  please stop by the Pepperdine reception tonight from 5:00 - 7:00 p.m. to say hello (and enjoy some wine and hors d'oeuvres before Markelfest).  The reception is in the Marriott Wardman Park, Center Tower Suite 1022.

Update:  Photo from post-reception Tax Prof dinner:

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January 3, 2015 in Conferences, Legal Education, Tax | Permalink | Comments (0)

Today's AALS Annual Meeting Highlights

AALSToday's highlights at the AALS Annual Meeting in Washington, D.C.:

  • Designing a Regulatory System for the Age of Decentralized Virtual Currencies (8:30 - 10:15) (Delaware Suite, Lobby Level):  Victor Fleischer (San Diego), James Gatto (Pillsbury Winthrop Shaw Pittman), Jim Harper (Global Policy Counsel, The Bitcoin Foundation), Sarah Jane Hughes (Indiana), Omri Marian (Florida), Nicco Mele (EchoDitto), Christopher Peterson (Utah)
  • Implementing Innovation in Law Schools (10:30 - 12:15) (Roosevelt 1 & 2, Exhibition Level):  Daniel Rodriguez (Northwestern; AALS President), Martin Katz (Denver), Paul Lippe (OnRamp Systems), Michael Madison (Pittsburgh), Kelllye Testy (University of Washington)
  • IRS Oversight of Charitable and Other Exempt Organizations – Broken? Fixable? (10:30 - 12:15) (Maryland Suite B, Lobby Level):  Ellen Aprill (Loyola-L.A.), Philip Hackney (LSU), James Fishman (Pace), Terri Helge (Texas A&M), Donald Tobin (Maryland), Daniel Tokaji (Ohio State)
  • Recent Developments in Human Capital Investing (3:30 - 5:15) (Roosevelt 1 & 2, Exhibition Level):  Diane Ring (Boston College), John Brooks (Georgetown), Victor Fleischer (San Diego), Heather Hughes (American), Benjamin Leff (American), Shu-Yi Oei (Tulane), Michael Simkovic (Seton Hall)

Photo of Tax Court Judge Halpern from last night's Tax Prof Dinner (from Leandra Lederman):

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January 3, 2015 in Conferences, Legal Education | Permalink | Comments (0)

Friday, January 2, 2015

2015 AALS Annual Meeting: Legal Education at the Crossroads

AALSIn the parable of the Delta blues player, the musician considers carefully his choice: to make his pact with the Devil and preserve his guitar greatness or to take the other path. He considers this fateful decision at the crossroads. We are at the crossroads. Our law schools face critical choices: Are we going to continue on the path which, while suitable to the previous world in which we pursued glory and economic progress and our graduates took their rightful place in the generally remunerative legal economy, now has significant pitfalls and predicaments. Or are we going to take the path toward a more promising, albeit risky and uncertain, destination for our students, our faculty, our profession?

As faculty members and law school leaders, we are engaged deeply with questions concerning the efficacy of our current educational and economic model. Some prophesize the demise of this model and, with it, doom and gloom for (many? most? all?) or our member schools; others, for sure, remain ever optimistic. Moreover, we are engaged with complex questions of pedagogical strategy and educational performance. In our teaching, in our scholarship, and in our external engagement with the bench, bar, and business sector, we ask: Are we doing all we can and should to prepare our students for this dynamic new world? Ideally, these questions should be omnipresent parts of our strategies. But, realistically, they have garnered our focused attention in this era in which law schools are under pressure and, in a meaningful way, under siege.

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January 2, 2015 in Conferences, Legal Education | Permalink | Comments (2)

Monday, December 29, 2014

Call for Business Tax Papers: Oxford University Symposium

OxfordCall for Papers: Oxford University Centre for Business Taxation 9th Annual Symposium:

We invite you to submit a paper for the ninth annual symposium of the Oxford University Centre for Business Taxation. The symposium will take place at the Saïd Business School in Oxford, from Monday 22 – Thursday 25 June 2015. As ever, we welcome research on any topics related to business taxation in its broadest sense, including papers from economics, law and other disciplines, as well as interdisciplinary contributions. The programme from last year’s symposium can be found here.

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December 29, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, December 18, 2014

Sanchirico Presents Two Tax Papers in Italy

SanchiricoChris Sanchirico (Pennsylvania) presents two papers at the 10th Annual Conference of the Italian Society of Law and Economics at the University of Rome:

As American as Apple Inc.: International Tax and Ownership Nationality, 68 Tax L. Rev. ___ (2014):

The ownership nationality of large US multinational companies plays an implicit but important role in the current debate over how such companies should be taxed. This paper identifies that role and investigates what is actually known about where these companies’ shareholders reside. 

Self-Constructed Assets and Efficient Tax Timing:

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December 18, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, December 15, 2014

Brookings Hosts Conference Today on The Long Run Outlook for the Federal Budget

BrookingsThe Brookings Institution hosted a conference today on The Long Run Outlook for the Federal Budget: Do We Know Enough to Worry?:

Other commentators:

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December 15, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, December 1, 2014

Vanderbilt Symposium: The Role of Federal Law in Private Wealth Transfer

VandySymposium, The Role of Federal Law in Private Wealth Transfer, 67 Vand. L. Rev. 1531-2006 (2014):

December 1, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, November 20, 2014

Pepperdine/Tax Analysts Symposium Papers: Tax Reform in a Time of Crisis

TaxSymposiumHeaderHere are links to the eleven published papers from the Pepperdine/Tax Analysts Symposium on Tax Reform in a Time of Crisis (Jan. 17, 2014):

Thanks to the paper commentators:  Donald Korb (Partner, Sullivan & Cromwell; former IRS Chief Counsel), Nancy Staudt (Dean, Washington University), and Eric Zolt (UCLA)

November 20, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (2)

Saturday, November 15, 2014

Federalist Society Panel: Is Higher Education Run for the Benefit of Students, Faculty or Administrators?

Federalist SocietyAt today's 2014 National Lawyers Convention: Millennials, Equity and the Rule of Law:

Showcase Panel III:  Higher Education: Run for the Benefit of Students or Faculty or Administrators?:

Success in today’s global economy virtually requires a college or post graduate degree, but colleges and law schools have raised tuition enormously. The government subsidizes students to take huge loans to pay for college and law schools, loans which inflict an increasing burden on students, including law students in a troubled economy. Do these loans pay as much for faculty research and administrators as for direct student education? Are faculties producing research that justifies these costs? Are students getting a good deal now? Could or will on line education provide students with similar education at a fraction of the cost? Is it time to ask some hard questions about higher education? Does education policy benefit average and below average students or does it merely benefit the top of the class? This panel will focus to a significant degree on law schools.

  • Paul F. Campos (Colorado)
  • Daniel Polsby (Dean, George Mason)
  • Richard Kent Vedder (Ohio University)
  • Thomas D. Morgan (George Washington) (moderator)

November 15, 2014 in Conferences, Legal Education | Permalink | Comments (7)

NTA 107th Annual Conference on Taxation

NTA CoverThe National Tax Association 107th Annual Conference on Taxation concludes today in Santa Fe. Tax Prof speakers include:

The Philosophy of Taxation:
Session Chair:  Brian Galle (Boston College)
Papers:

Discussants:  Brian Galle (Boston College), Linda Sugin (Fordham)

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November 15, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, November 14, 2014

Class Crits VII Conference Kicks Off Today at UC-Davis

Class CritsThe two-day Class Crits VII Conference on Poverty, Precarity, & Work: Struggle & Solidarity in an Era of Permanent(?) Crisis kicks off today at UC-Davis.  Tax Prof speakers include:

Debt & Taxes:

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November 14, 2014 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (2)

NTA 107th Annual Conference on Taxation

NTA CoverThe National Tax Association 107th Annual Conference on Taxation continues today in Santa Fe. Tax Prof speakers include:

Conceptualizing the Social and Regulatory Nature of Taxation:

Session Chair:  David Gamage (UC-Berkeley)
Papers:

  • David Hasen (Colorado), Income Taxation and Risk-Taking
  • Tracey Roberts (UC-Hastings), Law,  The Taxing Power as a Check on Private Property Rights and a Source of Regulatory Authority
  • Theodore Seto (Loyola-L.A.), Some Implications of Preference-Shifting for Optimal Tax Theory

Discussants: David Gamage (UC-Berkeley), Leandra Lederman (Indiana)

Hitting the Target: Public and Private Savings:
Session Chair:  Travis St. Clair (Maryland)
Papers:

Discussants:  Elizabeth Chorvat (Illinois), Jason Seligman (Ohio State), Travis St. Clair (Maryland)

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November 14, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, November 13, 2014

NTA 107th Annual Conference on Taxation

NTA CoverThe National Tax Association 107th Annual Conference on Taxation kicks off today in Santa Fe. Tax Prof speakers include:

Tax Enforcement and Collections Discretion:
Session Chair:  Leigh Osofsky (Miami)
Papers:

  • Joshua Blank (NYU), Reconsidering Corporate Tax Privacy
  • Andrew Hayashi (Virginia), An Economic Analysis of Taxpayer Liquidity
  • Shu-Yi Oei (Tulane), What is Fair Tax Administration?
  • Leigh Osofsky (Miami),  Announcing Enforcement Priorities

Discussants:  Leandra Lederman (Indiana), Diane Ring (Boston College)

Municipal, Local, and Global Tax Incentives:
Session Chair:  Neil Buchanan (George Washington)
Papers:

  • Mirit Eyal-Cohen (Alabama), Urban Mavericks
  • Omri Marian (Florida), Corporate Inversions, Tax Residence, and Real Economic Effects: A Case Study Approach
  • Agustin Leon-Moreta (New Mexico), Tax-Expenditure Limitations and Special District Finance in the United States
  • Erin Scharff (Arizona State), Powerful Cities, Efficient Revenues: Limits on Municipal Taxing Authority and What to do About it

Discussant:  Neil Buchanan (George Washington)

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November 13, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

40th Annual Notre Dame Tax and Estate Planning Institute

ND_TaxEstate_booklet coverThe 40th Annual Notre Dame Tax and Estate Planning Institute kicks off today:

The 40th Annual Institute will present topics relevant for all individuals, even those not exposed to the estate tax because of the high exemptions. Several sessions are designed to evaluate financial products and planning techniques so that one can better understand and evaluate these products and proposals in determining not only the tax and financial advantages they offer, but also their limitations. In addition, the Institute offers topics not found in most estate planning CLE programs such as protecting the elderly from scams and exploitation. As part of the objective of refreshing areas that can expand one’s practice, a session will review the income tax consequences of debt cancellation, foreclosures, and debt restructuring. Recognizing the importance of the income tax, the Institute will continue to devote sessions to income tax planning techniques clients can use immediately.

Tax Profs with speaking roles include:

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November 13, 2014 in Conferences, Tax | Permalink | Comments (0)

Wednesday, November 12, 2014

Vanderbilt Roundtable on Comptroller v. Wynne

Vandy 2The Vanderbilt Law Review En Banc Roundtable takes up Maryland State Comptroller of the Treasury v. Wynne, to be argued today in the Supreme Court:

In Wynne, the Court considers whether the Constitution bans a state from taxing its residents’ income, wherever earned, by requiring a credit for taxes paid on income taxed in other states. The Court could answer many questions: How far is the reach of the dormant Commerce Clause in the context of income taxation? What is the extent of a state’s power to enforce personal income taxes on its residents? What kinds of residents are subject to double taxation and why? .

November 12, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)