TaxProf Blog

UC-Hastings Hosts Northern California Tax Roundtable Today

UC-Hastings hosts the Spring 2013 Northern California Tax Roundtable today with these papers:

Heather Field (UC-Hastings), Tax Planning and the Ethical Tax Lawyer
Commentator:  Caroline Chen (Santa Clara)

David Gamage (UC-Berkeley), On Double-Distortion Arguments, Distribution Policy, and the Optimal Tax Mix
Commentator: Susie Morse (UC-Hastings)

Stu Karlinsky (Pacific Rim Tax Institute), Back to the Future
Commentator: Mark Gergen (UC-Berkeley)

ABA Tax Section May Meeting

The ABA Tax Section May meeting concludes today in Washington, D.C. The full program is here. Tax Profs with speaking roles include:

• Affiliated & Related Corporations:  Michelle Kwon (Tennessee), Don Leatherman (Tennessee)
• Diversity:  Patricia A. Cain (Santa Clara)
• Employee Benefits Distributions Update:  Kathryn J. Kennedy (John Marshall)
• Exempt Organizations:  Jill S. Manny (NYU)
• Individual & Family Taxation:  David L. Rice (California Polytechnic)
• Pro Bono & Tax Clinics:  Michael Campbell (Villanova), Keith Fogg (Villanova)
• Publications:  Alice Abreu (Temple)
• S Corporations:  Robert K. Morrow (Chapman)
• Sales, Exchanges & Basis:  Bradley T. Borden (Brooklyn), Erik Jensen (Case Western)
• Tax Policy & Simplification:  Itai Grinberg (Georgetown), Roberta F. Mann (Oregon), Erik Jensen (Case Western), Tracy Kaye (Seton Hall)
• Tax Practice Management:  Michael B. Lang (Chapman)
• Teaching Taxation:  Joshua Blank (NYU), Adam S. Chodorow (Arizona State), Deborah A. Geier (Cleveland State), Omri Marian (Florida), Adam Rosenzweig (Washington U.)

Tax Prof Dinner:

Georgetown Symposium on The Intersection of Tax Law, Gender and Sexuality

Symposium, Confronting the Intersection of Tax Law, Gender and Sexuality, 13 Geo. J. Gender & L. 1- 105 (2012):

• Anthony C. Infanti (Pittsburgh), LGBT Taxpayers: A Collision of "Others", 13 Geo. J. Gender & L. 1 (2012)
• Deborah H. Schenk (NYU), Reflections on Women in Tax Law Academia, 13 Geo. J. Gender & L. 47 (2012)
• Nancy Staudt (USC), April Yanyuan Wu (Boston College) & Chao Wang (Fried, Frank, New York), Is Gender-Based Policymaking Relevant in the 21st Century?, 13 Geo. J. Gender & L. 59 (2012)

Pepperdine & ASIL Symposium Today on The Rise of Non-State Law

Pepperdine and The American Society of International Law today are co-hosting International Legal Theory Interest Group Symposium: :

Trends in legal philosophy, international law, transnational law, law & religion, and political science all point towards the increasing role played by non-state law in both public and private ordering.  Numerous organizations, institutions, associations and groups have emerged alongside the nation-state, each purporting to provide their members with rules and norms to govern their conduct and organize their affairs. Indeed, questions regarding non-state law have moved to the forefront of recent debates over legal pluralism and transnational justice, forcing scholars and practitioners to consider the new and multifaceted mechanisms ways in which we govern ourselves.  This International Legal Theory Interest Group Symposium will explore this Rise of Non-State Law by bringing together experts on international law, transnational law, legal theory and political philosophy to consider the growing impact of law that derives from outside the nation-state.

Introduction:  Michael Helfand (Pepperdine), John Linarelli (Swansea)

Panel #1—Global Legal Pluralism: Trends and Challenges

• Moderator: John Linarelli (Swansea)
• Panelists: 
  • Paul Schiff Berman (George Washington)
  • Ralf Michaels (Duke)
  • Peer Zumbansen (Osgoode)

Panel #2—Non-State Law and Non-State Institutions

• Moderator: Donald Earl Childress III (Pepperdine)
• Panelists: 
  • Oren Perez (Bar-Ilan)
  • Sally Merry (NYU)
  • Harlan Cohen (Georgia)
  • Helen Quane (Swansea)

Panel #3—The Role of Religion and Culture in Non-State Law

• Moderator: Mortimer Sellers (Baltimore)
• Panelists:
  • Nomi Stolzenberg (USC)
  • Joel Nichols (St. Thomas)
  • Clark Lombardi (Washington)

Grinberg Presents Emerging Countries and the Taxation of Offshore Accounts Today at NYU

Itai Grinberg (Georgetown) presents Emerging Countries and the Taxation of Offshore Accounts at NYU today as part of its Colloquium Series on Tax Policy and Public Finance convened by Daniel Shaviro (NYU) and William Gale (Tax Policy Center; visiting at NYU):

A new international regime in which financial institutions function as cross-border tax intermediaries is emerging. The contours of that regime will be established during a narrow window of opportunity over the span of the next few years. The resulting regime will have especially important consequences for emerging countries. A uniform, multilateral automatic information exchange system would improve both these jurisdictions’ ability to tax the offshore accounts of their residents and their capacity to tax certain domestic-source income from capital.

Interestingly, multinational financial institutions’ and emerging countries’ concerns with the emerging international regime are largely aligned. As a result, they may find that they are improbable allies in the battle over taxing offshore accounts. With the G-20 as an agenda-setter and international financial law as the model, a governance structure for an automatic information exchange regime that could be useful to emerging countries’ tax administrations and lower multinational financial institutions’ compliance costs could materialize. The paper explores the necessary architecture, as well as steps emerging countries may take to help that architecture develop.

IDC Herzliya Hosts Symposium Today on Current Issues in International Taxation

IDC Herzliya, Radzyner School of Law (Israel) hosts a symposium today on Current Issues in International Taxation:

• Yariv Brauner (Florida), Competitiveness As an Appropriate Standard for Evaluation of Tax Policy
• Yoseph M. Edrey (Haifa University School of Law), Intangible Assets: Capital v. Maintenance Expenses; Ordinary Income v. Capital Gain
• Sagit Leviner (SUNY-Buffalo & Ono Academic College School of Law), The Intricacies of Tax & Globalization
• Yoram Margalioth (Tel Aviv University School of Law). Taxing Wealthy People
• Diane Ring (Boston College), Current Efforts to Tackle International Tax Evasion

ATPI & Rice University Host Conference Today on International Tax Reform

The American Tax Policy Institute and Rice University's Baker Institute host a conference today on Reforming the U.S. System for Taxing International Income in Washington, D.C.:

The President and Members of Congress have called for reforms of our international tax system. Some view the system as broken and in need of fundamental reform. Others advocate incremental changes. Join us for a lively and informative discussion of a new set of papers from experts in law, economics and accounting addressing problems with the U.S. international tax system and analyzing the economic advantages and practical problems of moving to new systems for taxing the profits U.S. firms earn abroad. Discussants and moderators include leading practitioners, academics and policy analysts.

Panel #1:  Fixing the System;  An Analysis of Alternative Proposals for the Reform of International Tax
Moderator
Jane Gravelle (Congressional Research Service)
Authors
Harry Grubert (U.S. Treasury Department)
Rosanne Altshuler (Rutgers)
Discussants
Lee Sheppard (Tax Notes)
John Samuels (VP and Sr. Counsel-Tax Policy and Planning, General Electric)

Panel #2;  Designing a Territorial Tax System When the Treasury Is Empty
Moderator
Reuven Avi-Yonah (Michigan)
Authors
J. Clifton Fleming, Jr. (BYU)
Robert J. Peroni (Texas)
Steve Shay (Harvard)
Discussants
Eric Toder (Urban-Brookings Tax Policy Center)
Chris Sanchirico (Pennsylvania)

Panel #3:  Back to the Drawing Board: The Structural and Accounting Consequences of a Switch to a Territorial System
Moderator
Peter Merrill (PricewaterhouseCoopers)
Authors
Ed Outslay (Michigan State)
Gary McGill (Florida)
Michael Donohoe (Illinois)
Discussants
Mihir Desai (Harvard)
Jennifer Blouin (Pennsylvania)

Keynote Panel:  Three Views on the Most Important Goals for Tax Reform
Reuven Avi-Yonah (Michigan)
Michael Cabbalero (Covington & Burling, Washington, D.C.)
Mihir Desai (Harvard)

Washburn Hosts Tax Law Colloquium Today

Washburn hosts its annual Tax Law Colloquium today:

Each year the Business and Transactional Law Center at Washburn University School of Law hosts a tax law colloquium. The colloquium provides the opportunity for tax scholars from around the country to meet and discuss scholarly projects on which they are working. In an informal setting the participants share ideas, provide feedback regarding scholarly works-in-progress, and enjoy the company of other tax scholars.

• Art Cockfield (Queen's), The Limits of the International Tax Regime as a Commitment Projector
• Zsuzsana Kadar (Thomson Reuters), Taxation of Positive Externalities Versus Taxation of Negative Externalities -- Should Tax be Used as a Regulatory Instrument?
• Leandra Lederman (Indiana), Which Cases Settle? A Large-Scale Empirical Study of U.S. Tax Court Cases
• Lori McMillan (Washburn), An Empirical Examination of the Noncharitable Nonprofit Subsector in Canada
• Shu-Yi Oei (Tulane), In Defense of Tax Priority
• Will Foster (Washburn), Swapping Equity and Efficiency

From last night's pre-conference dinner:

Tax Analysts Hosts Conference Today on State Taxes and the Cloud

Tax Analysts hosts a roundtable discussion on State Taxes and the Cloud at the National Press Club in Washington, D.C. today at 9:00 - 11:00 a.m. EST:

Please join us for a roundtable discussion in which we will consider how states are approaching the challenge of taxing cloud computing technologies, and what they should think about in doing so.

• Christopher E. Bergin (President and Publisher, Tax Analysts) (moderator)
• Cara Griffith (Legal Editor, State Tax Notes)
• Kelley Miller (Reed Smith)
• Mark Nebergall (President, Software Finance and Tax Executives Council)
• Dylan Waits (Managing Senior Policy Counsel, Washington Department of Revenue)

Urban Institute Hosts Program Today on Charity and Government -- Tax Reform and Beyond

The Urban Institute hosts a program today on Charity and Government: Tax Reform and Beyond:

This conference will look broadly at the relationship between the government and nonprofit sectors and their mutual yet distinct roles in the modern economy.

Session #1:  As an Independent Sector, Is Charity a Substitute, Complement, Adversary, or Something Else for Government?:  "This panel will give an overview of the theoretical perspective on the government-nonprofit relationship, including the roles and responsibilities of nonprofit organizations in a democracy. It will also relate to the evolution of government activity in the social welfare sector and trends in charitable activity, examining the data available on how government and charity interact. Important questions include: In what areas might the private sector be better equipped to provide solutions than government? Comparatively, in what areas might the government be better equipped to provide solutions than the private sector? Is it valuable for nonprofits and government to be adversaries, prodding each to be better? What can we learn from the history of philanthropy and charitable deductions in in America, and how does this contrast with other countries?"

• Moderator: Eugene Tempel (University of Indiana)
• Adam Parachin (University of Western Ontario)
• Eugene Steuerle (Urban Institute)
• Joseph Thorndike (Tax Analysts, University of Virginia)

Session #2:  What Is the Definition of Charity, and Who Decides How to Define It?:  "This panel will consider key questions that are arising in public policy debates at all levels of government from tax reform to enforcement and compliance. As funding for traditionally charitable activities has expanded, many activities such as education and health are performed both in the nonprofit and business sectors. In addition, increasing reliance by some nonprofits on government funding, in certain cases the sole source, has blurred a different set of sectorial lines. The growing haziness presents a variety of challenges and potential for confusion, conflict, and inconsistency. At the same time, a diverse charitable sector provides immense economic and social value. The panel will take a closer look at the above questions and the accompanying boundary issues, including how the subsidy and tax-base exclusion theories that underlie tax-favored treatment relate to the questions and their answers."

• Moderator: John Tyler (Kauffman Foundation)
• Bradford Gray (Urban Institute)
• Daniel Halperin (Harvard Law School)
• Alex Reid (Morgan Lewis)
• Marion Fremont-Smith (Hauser Center for Nonprofit Organizations, Harvard University)

Session #3:  Philanthropy’s Relationship to Current Policy Debates:  "This panel will look at current policy proposals that are related to the nonprofit sector, directly or indirectly. Capping the charitable deduction, requiring higher spending minimums by granting organizations, payments in lieu of taxes (PILOTS) by nonprofits, and many other complex policy proposals influence the day-to-day working of charitable organizations across the country. The panel will also look at how both federal and state/local budget pressures have affected this debate."

• Moderator: Elizabeth Boris (Urban Institute)
• Arthur Brooks (American Enterprise Institute)
• Joanne Florino (Philanthropy Roundtable)
• William Galston (Brookings Institution)
• Pat Read (Consultant)

16th Annual Critical Tax Theory Conference Concludes Today at UC-Hastings

The 16th Annual Critical Tax Theory Conference concludes today at UC-Hastings:

Keynote Address:  Pat Cain (Santa Clara)

Panel #6: Complete Papers

• Ted Seto (Loyola-L.A.) (moderator)
• Neil Buchanan (George Washington), The Unfortunate Return of Efforts to Turn Taxing and Spending Decisions into Constitutional Confrontations
• Roberta Mann (Oregon). Economists Are from Mars, Lawyers Are from Venus

Panel #7: Complete Papers

• Heather Field (UC-Hastings) (moderator)
• Emily Cauble (Michigan State), Did Blackstone’s Initial Public Offering Really Work?: A Case Study in Rules and Standards in Tax Law, 14 Fla Tax Rev. ___ (2013)
• Omri Y. Marian (Florida), Meaningful Corporate Tax-Residence

Panel #8: Papers in Progress

• Nancy Staudt (USC) (moderator)
• Andy Grewal (Iowa), Does TurboTax Cause Tax Fraud? 
• Adam Rosenzweig (Washington University), The Judicial Fiscal Power

Panel #9: Papers in Progress

• Leo Martinez (UC-Hastings) (moderator)
• Brian Sawers (Maryland). Poll Taxes and Labor Control in the Postbellum South 
• Shannon Weeks-McCormack (University of Washington), Tax Abuse According To Whom?, 14 Fla. Tax Rev. ___ (2013)

Special Presentation: Adam Chodorow (Arizona State), Death and Taxes and Zombies, 98 Iowa L. Rev. 1207 (2013)

Special Presentation: Eric San Juan (Senior Attorney-Advisor to the National Taxpayer Advocate), Comment on the Newly Released National Taxpayer Advocate’s 2012 Report to Congress

Prior Critical Tax Theory Conferences:

• 2012 Critical Tax Theory Conference (Seton Hall)
• 2011 Critical Tax Theory Conference (Santa Clara)
• 2010 Critical Tax Theory Conference (St. Louis)
• 2009 Critical Tax Theory Conference (Indiana-Bloomington)
• 2008 Critical Tax Theory Conference (Florida State)
• 2007 Critical Tax Theory Conference (UCLA)
• 2005 Critical Tax Theory Conference (Seattle)
• 2004 Critical Tax Theory Conference (Rutgers-Newark)

Infanti Presents The Moonscape of Tax Equality Today at McGill

Anthony C. Infanti (Pittsburgh) presents The Moonscape of Tax Equality at McGill today as part of its three-day conference on After Equality: Family, Sex, Kinship:

From a distance, the moon appears bright, shiny, and attractive. It is revered and romanticized. Lives (and deaths) are planned around its phases and cycles. But, upon closer inspection, this attractive object is actually scarred — pocked with craters left by past violent impacts.

Tax equality is, in some ways, strikingly similar. As of this writing, same-sex couples are fighting to invalidate section three of the federal Defense of Marriage Act (DOMA). Several federal courts have already done so, and the U.S. Supreme Court is likely to take up this issue during the term that starts in October 2012. In the abstract, invalidating DOMA and its unequal treatment of married couples based on their gender and sexual orientation is appealing and draws us in with its own romantic sort of beauty. But when we come face to face with legal equality, we may find that legal equality is not so bright, shiny, and attractive. What we learn is that it is pocked and scarred by the impact of past legal battles that make it less promising and attractive. Indeed, we may find that equality is not all that equal and that the situation post-DOMA may be markedly worse than the situation pre-DOMA.

In this essay, I first describe how we appear to be poised to achieve formal equality for same-sex couples under the federal tax laws. I outline the pending constitutional challenges to DOMA that will place all married couples on ostensibly the same legal footing for federal tax purposes and potentially allow same-sex couples to take advantage of past legal victories that have extended legal recognition to same-sex relationships. Then, I turn to describing the ways in which the post-DOMA federal tax terrain may actually be worse for same-sex couples than the already bleak tax landscape that they face. Same-sex couples already face a debilitating level of uncertainty in determining how the tax laws apply to their relationships. Post-DOMA, same-sex couples will likely see this uncertainty multiply as they not only grapple with how to fill the vacuum of guidance on treating their relationships when they are not recognized for tax purposes, but also with the question of whether and when their relationships will be recognized for tax purposes. Even were these uncertainties to be resolved, I conclude by describing how we may find that federal discrimination designed to erode the progress of same-sex couples toward formal equality has served only to entrench the privileged status of marriage in our tax laws, failing to erase inequitable treatment along lines of marital status and class.

16th Annual Critical Tax Theory Conference Kicks Off Today at UC-Hastings

The 16th Annual Critical Tax Theory Conference kicks off today at UC-Hastings:

Critical tax scholars 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. 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. However, as articulated at the original conference in 1995 to the present, the content of the Critical Tax Theory Conference has not been narrow – the topics discussed have been wide-ranging and have included more conventional tax topics as well.

Keynote Address: Joe Bankman (Stanford), Using the "Smart Return" to Reduce Tax Evasion

Panel #1: Incubator Papers

• Leo Martinez (UC-Hastings) (moderator)
• Adam Chodorow (Arizona State), Regulation of Gifts to Legislators and Their Staff
• Charlotte Crane (Northwestern), What is an Income Tax? Reflections on the Issues Raised by PPL.
• Nancy Staudt (USC), Planning and Penalties

Panel #2: Complete Papers

• Darien Shanske (UC-Hastings) (moderator)
• Sonia Dhaliwal (Myerson University), Maureen Donnelly (Brock University) & Jonathan Farrar (Myerson University), Procedural, Interpersonal and Informational Tax Fairness: A Content Analysis of Canadian Tax Jurisprudence
• Lily Kahng (Seattle University), Path Dependence in Tax Subsidies for Home Sales: From Leave It to Beaver to Flip This House
• Theodore P. Seto (Loyola-L.A.), Four Principles of Optimal Tax System Design

Panel #3: Complete Papers

• Lily Kahng (Seattle) (moderator)
• Joel Newman (Wake Forest), Deductions on a Higher Plane
• Susie Morse (UC-Hastings), Startup Limited: Tax Planning and Initial Incorporation

Panel #4: Papers in Progress

• Susie Morse (UC-Hastings), Martin Hearson (London School of Economics), Converging or Diverging Policies? Developing Countries and the Social Nature of International Tax
• Nan Kaufman (St. Louis), The Foreign Tax Credit: Rules in Search of Principles

Panel #5: Incubator Papers

• Roberta Mann (Oregon) (moderator)
• Andrew Blair-Stanek (Maryland), Modifying IP Law to Combat Tax Avoidance by Multinational Corporations
• Goldburn P. Maynard Jr. (Washington University), Tension within the Estate Tax Debate
• Katherine Pratt (Loyola-L.A.), Reconsidering the Equity Norm in Tax Policy  

Prior Critical Tax Theory Conferences:

• 2012 Critical Tax Theory Conference (Seton Hall)
• 2011 Critical Tax Theory Conference (Santa Clara)
• 2010 Critical Tax Theory Conference (St. Louis)
• 2009 Critical Tax Theory Conference (Indiana-Bloomington)
• 2008 Critical Tax Theory Conference (Florida State)
• 2007 Critical Tax Theory Conference (UCLA)
• 2005 Critical Tax Theory Conference (Seattle)
• 2004 Critical Tax Theory Conference (Rutgers-Newark)

Call for Papers: University of North Carolina Tax Symposium

The University of North Carolina Kenan-Flagler School of Business has issued a call for papers for its Seveneenth Annual Tax Symposium to be held January 17-18, 2014. The symposium "is designed to bring together leading tax scholars from economics, accounting, finance, law, political science, and related fields." The deadline for the call for papers is October 31, 2013:

Papers should be well developed, but at a stage where they can still benefit from the group's discussion. The symposium will include six to seven papers. Travel and lodging expenses for presenters will be reimbursed up to $500.

You can submit a paper here. Paper selection will be finalized by November 18, 2013.

12th Annual Conducting Empirical Legal Scholarship Workshop

The 12th Annual Conducting Empirical Legal Scholarship Workshop will take place at the USC Gould School of Law on May 22 - 24, 2013:

The workshop is for law school faculty, political science faculty, and graduate students interested in learning about empirical research and how to evaluate empirical work. Leading empirical scholars Lee Epstein and Andrew Martin will teach the workshop, which provides the formal training necessary to design, conduct, and assess empirical studies, and to use statistical software (Stata) to analyze and manage data. Participants need no background or knowledge of statistics to enroll in the workshop.

For more information or to register, see here.

Pepperdine Symposium: The New Normal in College Sports

The Pepperdine Law Review is live webcasting its Sports Law Symposium at 8:30 a.m. to 5:15 p.m. PST (11:30 a.m. to 8:15 p.m. EST),  The New Normal in College Sports: Realigned and Reckoning (schedule here). Among the speakers are:

• Ken Starr (President, Baylor University; Former Dean, Pepperdine)
• Deanell Tacha (Dean, Pepperdine)
• Babette Boliek (Professor, Pepperdine)
• Andrew Brandt (ESPN NFL Business Analyst and Professor, Villanova (Moorad Center for Sports Law))
• Roger Cossack (ESPN Legal Analyst and Professor, Pepperdine)
• Mark Fainaru-Wada (ESPN Investigative Reporter)
• Gabe Feldman (Professor, Tulane (Tulane Sports Law Program))
• Daniel Lazaroff (Professor, Loyola-L.A. (Loyola Sports Law Institute))
• Michael McCann (Legal Analyst, Sports Illustrated and Professor, New Hampshire (Sports and Entertainment Law Institute))
• Matthew Mitten (Professor, Marquette (National Sports Law Institute))
• Jeff Moorad (Founder, Moorad Sports Management)
• Rodney Smith (Professor, Thomas Jefferson (Center for Sports Law and Policy))
• Jeffrey Standen (Associate Dean, Willamette)
• Katherine Sulentic (Assistant Director of Enforcement, NCAA)
• Maureen Weston (Professor, Pepperdine)

Blank: U.S. National Report on Tax Privacy

Joshua D. Blank (NYU), United States National Report on Tax Privacy:

This National Report was prepared for a conference titled Tax Secrecy and Tax Transparency - The Relevance of Confidentiality in Tax Law, which took place in July 2012 in Rust, Austria and was co-hosted by the Institute for Austrian and International Tax Law at the Vienna University of Economics and Business and by Örebro University, Sweden. The Report describes the current tax privacy protections that apply to taxpayers in the United States and provides an overview of the policy considerations that have contributed to their enactment. Portions of this Report were originally published, in part, in Joshua D. Blank, In Defense of Individual Tax Privacy, 61 Emory L.J. 61 265 (2011).

UConn Hosts Conference Today on The Challenge of Retirement in a Defined Contribution World

The University of Connecticut School of Law and the Insurance Law Center are hosting a conference today on The Challenge of Retirement in a Defined Contribution World:

The last forty years have witnessed a shift from defined benefit to defined contribution plans, during which employers have transferred market risk onto workers. This change has created new and difficult issues, including the ability of middle- and lower-income households to bear that risk, the increased volatility of financial markets, the danger of outliving one’s savings, and senior citizens’ ability to continue managing their portfolios when physical or cognitive problems strike. In this symposium, economists, legal scholars, and government officials will come together to discuss how to better understand the defined contribution paradigm and to manage and regulate its risks.

Panel #1:  Perspectives on Challenges in Lifecycle Planning for Retirement

• Richard L. Kaplan (Illinois)
• Russell K. Osgood (Washington U.)
• Moderator:  James Kwak (Connecticut)

Panel #2:  Employer and Employee Perspectives on Pensions:

• Kevin Lembo (State Comptroller, Connecticut)
• Dana M. Muir (Michigan)
• Brishen Rogers (Temple)
• Edward A. Zelinsky (Cardozo)
• Moderator:  Michael Fischl (Connecticut)

Luncheon Keynote Address:  Alicia H. Munnell (Boston College)

Panel #3:  Problems With Defined Contribution Plans:

• Zvi Bodie (Boston University)
• Lawrence A. Frolik (Pittsburgh)
• David Laibson (Harvard)
• Amy Monahan (Minnesota)
• Moderator:  Patricia A. McCoy (Connecticut)

Panel #4:  Going Forward: Solutions and Challenges:

• Mercer E. Bullard, (Mississippi)
• Megan Thibos (Consumer Financial Protection Bureau)
• Moderator:  Dalié Jiménez (Connecticut)

NYU Hosts Ask the Expert (Witness) and Recent Developments in Tax Controversy

The NYU Graduate Tax Program is hosting two events today:

• Ask the Expert (Witness): A Conversation With Professor Dan Shaviro:  "What happens when a law professor becomes an expert witness?  What sorts of challenges and issues does he or she face, what’s it like, and how does it relate to teaching and research activities?  Professor Daniel Shaviro, Wayne Perry Professor of Taxation (NYU), will address these questions and more, based generally on his recent experiences."
• Recent Developments in Tax Controversy, sponsored by New York Region of the Federal Bar Association Tax Section:  "The presentation will include a discussion on recent court opinions on economic substance, debt-versus-equity, expert witness testimony, and discovery. The primary speakers will be Brian Power (Mayer Brown) and Elizabeth McGee (Shearman & Sterling)."

Call for Papers: Global Conference on Environmental Taxation

The 14th Global Conference on Environmental Taxation: Environmental Taxation and Green Fiscal Reform for a Sustainable Future to be held at Kyoto University in Kyoto City, Japan, on October 17-19, 2013 has issued a Call for Papers:

Environmental taxation (or environmental tax reform) includes not only the reform of carbon and energy taxes but also reform of the taxation on environmental pollutants and resource use that are not related to energy. ... Papers which focus on the conference issues and provide innovative policies and solutions will be given priority consideration. Selected papers from the conference will be eligible for publication in Critical Issues in Environmental Taxation published by Edward Elgar Publishing Ltd. ... Abstracts of papers should be submitted by 15 May 2013. Notification of abstract acceptance will be by 15 June 2013.

Video: Pepperdine/Tax Analysts Symposium, Tax Advice for the Second Obama Administration

The Pepperdine IT folks have divided the full 8-hour video of our January 18, 2013 symposium on Tax Advice for the Second Obama Administration into separate files on iTunes and YouTube.

Introduction and Welcome (iTunes; YouTube)

• Deanell Tacha (Dean, Pepperdine)
• Chris Bergin (President, Tax Analysts)

Keynote Address:  Michael Graetz (Columbia), Tax Advice for the Second Obama Administration, 138 Tax Notes 631 (Feb. 4, 2013) (iTunes; YouTube)

Occupy the Tax Code:  The Buffett Rule, the 1%, and the Fairness/Growth Divide (iTunes; YouTube)

Moderator:      David Brunori (Tax Analysts)

Papers:           Dorothy Brown (Emory), The 535 Report: A Pathway to Fundamental Tax Reform
                         Francine Lipman (UNLV), Access to Tax InJustice
                         Kirk Stark (UCLA) (with Eric Zolt (UCLA)), Tax Reform and the American Middle Class

Commentary:  Bruce Bartlett (New York Times), David Miller (Cadwalader, New York)

Estate and Gift Tax (iTunes; YouTube)

Moderator:      Paul Caron (Cincinnati/Pepperdine)

Papers:           Ed McCaffery (USC), Distracted from Distraction by Distraction: Reimagining Estate Tax Reform
                         Grayson McCouch (San Diego), Who Killed the Rule Against Perpetuities?
                         Jim Repetti (BC) (with Paul Caron), Occupy the Tax Code: Using the Estate Tax to Reduce Inequality and Spur Economic Growth

Commentary:  Joe Thorndike (Tax Analysts)

Luncheon Address:   David Cay Johnston (author/journalist) (iTunes; YouTube)

Business/International Tax #1 (iTunes; YouTube)

Moderator:     Tom Bost (Pepperdine)

Papers:          Steve Bank (UCLA), The Globalization of Corporate Tax Reform
                         Karen Burke (San Diego), Passthrough Entities: The Missing Link in Business Tax Reform
                         Martin Sullivan (Tax Analysts)

Commentary:  Michael Schler (Cravath, New York)

Business/International Tax #2 (iTunes; YouTube)

Moderator:     Khrista McCarden (Pepperdine)

Papers:          Reuven Avi-Yonah (Michigan), Corporate and International Tax Reform: Proposals for the Second Obama Administration
                        Allison Christians (McGill), Putting the Reign Back in Sovereign: Advice for the Second Obama Administration
                        Susan Morse (UC-Hastings), The Transfer Pricing Regs Need a Good Edit

Commentary:  Robert Goulder (Tax Analysts)

Closing Remarks:  What Have We Learned Today?:   David Cay Johnston (author/journalist) (iTunes; YouTube)

Washington U. Hosts Colloquium Today on A New Framework for International Taxation

Washington University hosts a mini-colloquium today on Conceptualizing a New Institutional Framework for International Taxation:

• Allison Christians (McGill)
• Itai Grinberg (Georgetown)
• Michael Lennard (UN Financing for Development Office)
• Diane Ring (Boston College)
• Adam Rosenzweig (Washington University)
• Lee Sheppard (Tax Analysts)

Virginia Tax Study Group Meeting

The Virginia Tax Study Group met last Friday:

D.C. Panel: What Will Happen in 2013?

• Cathy Barrè '98, Director, Legislative Affairs, IRS
• Holly Porter '92, Tax Counsel, Senate Finance Committee
• Cecily Rock '79, Senior Legislation Counsel, Joint Committee on Taxation
• Jon Traub '94, Managing Principal, Tax Policy Group, Deloitte & Touche

Corporate Inversions

• Hal Hicks '85, Partner & Global Head of International Tax Practice, Skadden
• David Lenter, Legislation Counsel, Joint Committee on Taxation
• Bret Wells, Professor, University of Houston Law Center
• Willard Taylor, Of Counsel, Sullivan & Cromwell

Luncheon Speaker:  Jon Talisman '84, Capitol Tax Partners, Washington, D.C.
Former Assistant Secretary of the Treasury for Tax Policy; Democratic Chief Tax Counsel, Senate Finance Committee; Legislation Counsel, Joint Committee on Taxation.

Aspirational Tax Reform:

• Rod DeArment '73, Senior Counsel, Covington & Burling
• Martin McMahon, Professor, University of Florida
• Roberton Williams, Fellow, Tax Policy Center

Impact of Significant Tax Legislation on Government Institutions That Are Responsible for Administration and Enforcement:

• Ellen Aprill, Professor, Loyolaa Law School, Los Angeles
• Mark Holmes, Judge, U.S. Tax Court
• Nina Olson, National Taxpayer Advocate, Taxpayer Advocate Service

ATPI & TPC Host Program Today on The Economic Effects of Corporate Rate Reductions

The American Tax Policy Institute and Tax Policy Center are hosting a program on The Economic Effects of Corporate Rate Reductions today at 8:30-11:00 a.m. (webcast):

An often mentioned element in discussions of changes to federal tax policy is that corporate tax rates will be substantially reduced, with other changes made to the tax code to offset the revenue effects.  This conference will explore the implications of such a policy in a variety of areas that are often not well understood.

This morning conference will provide an overview of four aspects of business taxation directly, or indirectly, affected by changes in the corporate tax rate.  The goal of this program is to help those either involved or interested in the current tax reform debate better understand the complexity of the system and the potential economic effects of a change in the rate structure.

• Eric Toder (Tax Policy Center), Overview of  U.S. Corporate Income Taxation:  "This presentation will set the stage by summarizing major corporate tax provisions, changes in corporate revenues over time, comparison of U.S. corporate rates and revenues to other OECD countries, and data on relative shares of revenue raised by individual and corporate-level taxation of business income."
• George Plesko (Connecticut), Pass-through Entities, Non-Corporate Businesses, and Organizational Form:  "Pass-through and non-corporate businesses follow the same tax rules for determining their income but pay taxes at the individual tax rate. Any business tax base-broadening that is undertaken to offset the cost of a corporate rate reduction will result in a higher income tax burden on these entities. In addition, since 1986, the corporate tax rate has been higher than the individual rate, which and has affected the choice of organization form used by businesses. Were the corporate rate to become substantially lower than the individual rate the incentive for firms to elect to be subject to the corporate tax will substantially increase, with effects on overall federal revenue.
• William Gentry (Williams College), Corporate Finance:  "The corporate tax rate affects the incentives for the use of debt or equity, to pay dividends or repurchase shares, to lease or purchase assets, and the structure of transactions. This session outlines the effects of a lower corporate tax rate could have on these financing activities.
• James Hines (Michigan), International Implications of a Reduced corporate Tax Rate:  "The US system of international taxation has received substantial attention and calls for reform. The US corporate tax rate, apart from other features of international tax system, creates incentives for the location and repatriation of income.This session will discuss the effects a lower corporate rate would have under the current system, and possible implications for the broader reform of international taxation."
• Douglas Shackelford (North Carolina), Financial Reporting:  "Publicly traded corporations are subject to multiple reporting requirements. In addition to their tax filings, these corporations must file financial statements with the SEC. The rules for financial reporting differ in important ways from those of tax reporting, and changes in the corporate tax rate will have a variety of effects on how corporations report income to their shareholders and the public. While a lower corporate tax rate will result in higher after-tax profits, many corporations may find themselves worse off because of the ways the corporate tax rate affects the valuation of certain assets."
• Moderator - Victoria Perry (International Monetary Fund)

Call for Speakers: CALI Conference -- Driving Law School Innovation

Registration is now open for the 23d Annual Conference for Law School Computing to be held Thursday, June 13 through Saturday June 15 in Chicago at Chicago-Kent College of Law. The theme of this year's conference is "Driving Innovation":

Times are tough for legal education. We are in a crisis, but a politician (who now happens to be the Mayor of the city where this year's conference is being held) says that "every crisis is an opportunity." Can our crisis drive all kinds of innovation? New course structures, new tools and new content delivery models are driving innovation from pedagogy to practice, so come to Chicago in June to find out how you can drive innovation at your law school. At this conference, you will hear speakers from dozens of law schools talk about innovative projects, ideas and experience. There will be ample time between sessions for conversation and community-building.

CALI has issued a Call for Speakers to law faculty, librarians, and IT staff (April 5 deadline). Conference registration is free for all speakers. (Disclosure: I am Vice President of the CALI Board of Directors.)

Pepperdine Symposium: The Lawyer of the Future

Symposium, The Lawyer of the Future, 40 Pepp. L. Rev. 337-532 (2013):

The Lawyer of the Future Symposium showcases the lawyers of the past and present, the variety of roles they serve within American society, and what their experiences and models teach us about who the lawyers of the future can and should be. From public servants to philanthropists, government officials to business entrepreneurs, the symposium focuses on the role of lawyers as working models of the rule of law.

The underlying purpose of the symposium is to gain a better understanding of the role that American lawyers have played in the past, what challenges and opportunities they face in the present, and how lawyers will best be equipped in the future to meet the needs and expectations of their clients.

• Deanell Reece Tacha (Dean, Pepperdine), The Lawyer of the Future, 40 Pepp. L. Rev. 337 (2013)
• Paul D. Carrington (Duke), Founding Legal Education in America, 40 Pepp. L. Rev. 343 (2013)
• Robert F. Cochran, Jr. (Pepperdine), Louis D. Brandeis and the Lawyer Advocacy System, 40 Pepp. L. Rev. 351 (2013)
• Stephen Gillers (NYU), How to Make Rules for Lawyers: The Professional Responsibility of the Legal Profession, 40 Pepp. L. Rev. 365 (2013)
• James E. Moliterno (Washington & Lee), The Future of Legal Education Reform, 40 Pepp. L. Rev. 423 (2013)
• Deborah L. Rhode (Stanford), Legal Education: Rethinking the Problem, Reimagining the Reforms, 40 Pepp. L. Rev. 437 (2013)
• William D. Henderson (Indiana-Bloomington), A Blueprint for Change, 40 Pepp. L. Rev. 461 (2013)
• Patricia Oliver (Christian Legal Aid of Los Angeles), Justice for All, 40 Pepp. L. Rev. 509 (2013)

Michigan Conference Today on U.S. Benefits Law

The University of Michigan Stephen M. Ross School of Business hosts a conference today on U.S. Benefits Law: A Meta Assessment. Among the Tax Prof papers are:

• Thomas J. Fitzpatrick (Federal Reserve Bank of Cleveland)  & Amy B. Monahan (Minnesota), Who’s Afraid of Good Governance? State Fiscal Crises, Public Pension Underfunding, and the Resistance to Governance Reform 
• Lawrence A. Frolik (Pittsburgh), Rethinking ERISA’s Promise of Income Security in a World of 401(k) Plans
• Jonathan Barry Forman (Oklahoma), The Cost of ‘Choice’ in a Voluntary Pension System
• Kathryn L. Moore (Kentucky), A Comparison of the Role of the Employer in the French and U.S. Health Care Systems
• Dana M. Muir (Michigan) & Norman P. Stein (Drexel), Two Hats, One Head, No Heart: The Anatomy of the ERISA Settlor/Fiduciary Distinction
• Peter J. Wiedenbeck (Washington U.), Trust Variation and ERISA’s Misbegotten “Presumption of Prudence”

Pittsburgh Hosts 2013 Tax Workshop Today

Pittsburgh hosts 2013 Tax Workshop today:

Panel #1:  Tax Regulation and Judicial Deference:

• Danshera Cords (Albany), “Let’s Get Together:” What Tax Should Learn About Collaborative Regulation Development
• Kristin E. Hickman (Minnesota), Précis: Treasury’s Retroactivity
• Steve R. Johnson (Florida), Auer/Seminole Rock Deference in the Tax Court
• Shannon McCormack (UC-Davis), Tax Abuse According to Whom?

Panel #2:  Tax Litigation, Lawyers & Ethics:

• Charlotte Crane (Northwestern), Maintaining Class Actions in Tax Cases: Why Have Federal Litigants Been So Much Less Successful?
• David J. Herzig (Valparaiso), Justice for All: The IRS Reimagined
• Heather M. Field (UC-Hastings), “Loophole” is Not a Four-Letter Word: Tax Planning and the Ethical Tax Lawyer
• Leandra Lederman (Indiana), Which Cases Settle? A Large-Scale Empirical Study of U.S. Tax Court Cases

Panel #3:  Tax Legislation and Tax Compliance:

• Michelle Drumbl (Washington & Lee), Those Who Know, Those Who Don’t, and Those Who Won’t: Balancing Complexity, Sophistication, and Accuracy on Tax Returns 
• William E. Foster (Washburn), Partisan Politics and Income Tax Rates
• Andy Grewal (Iowa), The Congressional Revenue Service
• Shu-Yi Oei (Tulane), Taxing in the Shadow of Bankruptcy Law: A Collections Defense of Tax Priority
• John Plecnik (Cleveland State), Officers under the Appointments Clause

TPC & ITPF Host Conference Today on Tax Policy and U.S. Manufacturing

The Urban-Brookings Tax Policy Center and International Tax Policy Forum host a conference today on Tax Policy and U.S. Manufacturing in a Global Economy:

In his 2013 State of the Union address, President Obama stated "Our first priority is making America a magnet for new jobs and manufacturing." His “Framework for Business Tax Reform” would support this priority by focusing and deepening the existing tax deduction for domestic manufacturing activities. Others, including Senator Orrin Hatch, ranking minority member of the Finance Committee, are cool to the idea, saying, "We're starting to come back in manufacturing, and I don't think you need the government to show the way for them." This will assess the current state of U.S. manufacturing, its contribution to U.S. economic growth, and whether tax reform should maintain, deepen, or eliminate preferential income tax treatment of manufacturing income.

Introduction:

• William G. Gale (Co-Director, Urban-Brookings Tax Policy Center)
• John Samuels (Vice President and Senior Counsel, Tax Policy and Planning, General Electric)

The State of U.S. Manufacturing:

• Martin Neil Baily (Senior Fellow, Urban-Brookings Tax Policy Center)
• William G. Gale (Co-Director, Urban-Brookings Tax Policy Center)

The Impact of Taxation on Location of Manufacturing Activities:

• Mihir Desai (Professor, Harvard Business School) (moderator)
• Fritz Foley (Professor, Harvard Business School)
• Paul Oosterhuis (Partner, Skadden, Arps, Slate, Meagher & Flom)

Should the U.S. Reform the Taxation of Manufacturing?:

• James R. Hines Jr. (Professor, University of Michigan Law School) (moderator
• Robert D. Atkinson (President, Information Technology and Innovation Foundation)
• Donald Marron (Co-Director, Urban-Brookings Tax Policy Center)
• Pam Olson (Deputy Tax Leader, PricewaterhouseCoopers)
• Damon Silvers (Director of Policy and Special Counsel, AFL-CIO)

Keynote Address:  Laura D. Tyson (Professor, University of California Berkeley Haas School of Business)

Call for Tax Papers: ClassCrits VI

ClassCrits VI has issued a Call for Papers and Participation for a conference on  Stuck in Forward? Debt, Austerity and the Possibilities of the Political to be held at Southwestern Law School on November 15-16, 2013:

The theme of this year’s workshop--the sixth meeting of ClassCrits--is debt, austerity and the possibilities of the political. The economic crisis of 2008 was a referendum on the failures of deregulation and neoliberal ideology all over the world. Far from being a sophisticated mechanism to absorb and diffuse systemic economic risk, the crisis exposed a fragile global financial system characterized by dysfunctional imbalances of increasingly precarious and largely unregulated risk societies. In the United States, the social contract of class mobility and the “American Dream” financed with “easy” credit was exposed as an empty promise. In the European context, the sovereign debt crisis resulted in the imposition of draconian austerity measures in several nation-states, like Greece, undermining social safety nets and wage structures, rupturing traditional alliances, and driving down individual standards of living. At the same time, the Occupy Movement—and similar movements across the globe—refocused attention on socio-economic inequality for the first time in decades. The old ways of seeing things proved inadequate for framing the changing realities of the new post-recession world. But whatever the initial shock to the social order, political and financial elites everywhere have since doubled down on the failed neoliberal project with a mania for balancing budgets in the name of discredited austerity policies which have only accelerated neoliberalism’s upward transfer and concentration of wealth and intensified the class stratification in contemporary global societies.  Stuck in the grip of austerity groupthink and faced with nation states captured by elite interests─a trend only made worse in the United States by Citizens United─any movement forward will require creatively leveraging national political and legal systems as instruments for progressive economic change and deleveraging social class divides.

What are the possibilities and alternatives for a genuinely progressive economic project in an age of resurgent neoliberal policies and politics, worldwide shifts in population and demographics, and hegemonic economics? How can we address the challenges of our age including, but not limited to: globalization; shifting power relationships between the developed world and formerly “third world” countries; massive intergenerational and upward transfers of wealth; abject poverty; staggering debt; wage stagnation; a declining middle class; an increasingly dysfunctional food system; and environmental and climate risks that will require concerted national and international efforts. Stuck in Forward? Debt, Austerity and the Possibilities of the Political will address these questions by bringing together scholars, economists, activists, policymakers, and others to critically examine and take stock of who wins, who loses, how the law facilitates the hierarchical and spatial distribution of winners and losers, and how we may use law and politics to develop both real and utopian interstitial spaces of classlessness within the new post-recession global order.

We invite panel proposals and paper presentations that speak to this year’s theme as well as to general ClassCrits themes. ...  In addition, we extend a special invitation to junior scholars (i.e., graduate students or any non-tenured faculty member) to submit proposals for works in progress. A senior scholar as well as other scholars will comment upon each work in progress in a small, supportive working session.

Please submit your proposal by email to classcrits@gmail.com by March 20, 2013.

Florida State Hosts Symposium Today on One-Hundred Years of the Federal Income Tax

Florida State's two-day symposium on One-Hundred Years of the Federal Income Tax concludes today with these speakers:

David Gamage (UC-Berkeley), More on Tax Salience: Operative Mechanisms and Limiting Factors:  "Will discuss possible operative mechanisms underlying observed results related to tax salience and factors that might limit the relevance of these results for tax policy design. Will discuss possible operative mechanisms underlying observed results related to tax salience and factors that might limit the relevance of these results for tax policy design."
Commentator:  Jeffrey H. Kahn (Florida State)

Steve R. Johnson (Florida State), Reforming Federal Tax Litigation: An Agenda: "Will review key events and trends in federal tax procedure in order to adduce the values — providing efficacious remedies for taxpayers and third parties, protecting the revenue, and promoting process efficiency — that should guide policy. Will prioritize these values and apply them to possible reforms of the system for litigating federal tax controversies. Will consider possible creation of a national court of tax appeals, changes to the jurisdiction of the Tax Court and the Court of Federal Claims, modification of the TEFRA unified partnership audit/litigation rules and the collection due process rules, clarifying tax suits based on the Administrative Procedure Act, and abolishing the Flora “full payment” prerequisite to tax refund suits."
Commentator:   Leandra Lederman (Indiana-Bloomington)

Cincinnati Law Faculty Provide CLE for Student Scholarships

Yet another reason why I love the University of Cincinnati College of Law and my colleagues:  the law school faculty today is holding a "Teach-In", offering 12 CLE programs for lawyers with all proceeds going toward student scholarships (were I not in Malibu, there would have been 13):

• Marjorie Aaron: Client Science: Toward Loyal Clients Who Trust Their Lawyers and Believe the Bad News
• Lynn Bai, Broker-Dealers' Obligations as Clients: What Does Fiduciary Duties Add to the Palette?
• Marianna Bettman, Hot Cases from the Ohio Supreme Court
• Chris Bryant, Constitutional Law Update: Federalism After the "ObamaCare" Ruling
• Jacob Cogan, International Sales: How Do We Advise Thee? Let Us Count the Laws!
• Emily Houh, Is Mutual Assent Extinct or Still the Contract Linchpin?
• Bert Lockwood, Contemporary Slavery
• Brad Mank, An Environmental and Energy Law Overview on Climate Change Issues
• Stephanie McMahon, What Non-Tax Folks Should Know About Federal Taxes for Selling a Business
• Janet Moore, Fact-Busting, Theory-Building, and Storyboarding: Narrative Strategies for Litigation
• Ronna Greff Schnieder, Hop Topics Under the First Amendment
• Carrie Wood, Politics, DNA, and the Innocence Revolution

Florida State Hosts Symposium Today on One-Hundred Years of the Federal Income Tax

Florida State hosts a two-day symposium on One-Hundred Years of the Federal Income Tax:

2013 is the centennial of the modern U.S. income tax. Florida State will host a distinguished array of experts who will offer perspectives on what we have learned in 100 years and where we should go in the future. 

Today's speakers:

Steven Bank (UCLA), Corporate Tax and the Remants of 1935:  "Two of the most anomalous structural features of the corporate income tax are the graduated marginal rate system and the dividends received deduction. One appears to target large corporations for higher rates of tax while the other appears to permit large corporations to avoid those high rates by dividing up into a series of smaller corporations. Moreover, as currently codified, both provisions are quite puzzling, with rates and exemptions that appear to lack any policy justification at all. Perhaps the most intriguing aspect of these seemingly inconsistent provisions is that they were both enacted at the same time as part of the Revenue Act of 1935. This paper will examine the common origins of these provisions, how they strayed from their original mission, and why it will make sense to revisit their continued existence in light of changed circumstances."

Joseph M. Dodge (Florida State), Simplification of the Income Tax:  "Will propose moves for simplification of the individual income tax, with a view to making the income tax intelligible and capable of compliance by “ordinary” individuals without the aid of tax preparation software or outside assistance. Simplification will be offered as a “ good government” project. Some of the proposals involve tax reform, but many do not."
Commentator:  Joseph Bankman (Stanford)

Douglas A. Kahn (Michigan), A Proposed Replacement of the Tax Expenditure Concept and a Different Perspective on Accelerated Deprecation:  "Will argue that the tax expenditure concept is grounded on an erroneous vision of the structure of an income tax system. The tax expenditure concept adopts a binary view of income taxation. It posits that there is an ideal or pure income tax system whose provisions are elements of the normal structure of that system without any influence from non-tax policy considerations. Tax provisions are described either as falling within those core provisions or outside of them. There are no other categories. To the contrary, this article will contend that tax provisions lie on a continuum in which some are in the core and some are at different distances from the core. The article will contend that virtually all tax provisions, including those within the core, reflect policy considerations. The decision whether to adopt or retain a provision takes into account both its proximity to the core and also the economic and societal consequences (both positive and negative) that the provision will cause. There is no universal tax system for all times. Tax laws are (and should be) constructed to coordinate with the needs and values of society as they change over time. The article also will contend that there is not just one proper method of depreciation, and that accelerated depreciation is as consistent with neutral tax principles as is straight-line depreciation."

Gregg D. Polsky (North Carolina), Will Technology Save or Destroy the Federal Income Tax?: "Will discuss how future technological innovations may affect tax compliance, administration, and policy over the next hundred years, including whether innovations could make transition to a consumption tax more feasible, administratively and politically."

Daniel N. Shaviro (NYU), The Forgotten Henry Simons (PowerPoint Slides):  "Will look at some of the classic literature from the early years of the federal income tax — including works of Simons, Fisher, and Adams — to examine what has changed and what remains the same in our understanding of the issues. Will consider contemporary literature on optimal income taxation, income versus consumption tax, and international tax."
Commentator:   Chris William Sanchirico (Pennsylvania)

Lawrence A. Zelenak (Duke), Will the Fabulous Invalid Survive for a Second Century?: "Will speculate on the prospects of the income tax surviving for another hundred years. This entails having a sense of what makes the income tax an income tax and thus what features would have to have survived in order for the income tax to have survived. Will argue that, in the popular understanding, taxing income (rather than consumption) is only one of these defining features, and probably not the most important one. Other major features are mass direct taxation of individuals, progressive rates, and significant use of exclusion, deductions, and credits. Will predict that most of these features are likely to survive foreseeable future, even if the base of the tax is converted from income to consumption. Thus, the income tax as understood by the public is likely to survive even if the income tax as understood by tax specialists disappears."

Dinner Speaker:   Clarissa Potter (Deputy Tax Director, AIG; Former Deputy Chief Counsel, IRS), Current Climate for Tax Reform

Photo courtesy of Leandra Lederman.

Conference Today on Tax Policies for Multijurisdictional Income

The California State Bar Association Tax Section, San Jose State University College of Business, and Tax Executives Institute host a Tax Policy Conference today on Tax Policies for Multijurisdictional Income. Among the speakers is Susan C. Morse (UC-Hastings). For the full program, see here.

TPC Hosts Program Today on The Charitable Deduction

The Tax Policy Center hosts a program today on The Charitable Deduction: A View from the Other Side of the Cliff (free webcast here):

As the vehicle of state leaned over one fiscal cliff, Congress pulled it back but kept the motor running. In this session, we will examine the recent debate over tax changes, the resulting effect on charities, and the likely forthcoming debate in early 2013. Panelists will discuss how federal fiscal policy and proposed changes to tax law, in particular the charitable deduction, may affect charitable giving and the political scene for nonprofits going forward into an uncertain future.

Looking Back at the Cliff
This panel will take a look back at the debate leading up to the “fiscal cliff.” The panelists will discuss the various proposals that would have affected the charitable deduction, the response of the nonprofit sector, and the effect of the ultimate deal that was reached. 

      Moderator: Eugene Steuerle, Urban Institute
          Diana Aviv, Independent Sector
          Jon Bakija, Williams College
          Rick Cohen, Nonprofit Quarterly 
          Joseph Rosenberg, Urban-Brookings Tax Policy Center

The Road Forward
This panel will discuss what lies ahead for the charitable deduction in an environment of continued budget pressure. The speakers will describe various proposed reforms to the charitable deduction and discuss how these reforms may affect nonprofits, for better or for worse. 

      Moderator: Elizabeth Boris, Urban Institute
          Joseph Cordes, George Washington University 
          Tim Delaney, National Council of Nonprofits
          Brian Flahaven, Council for Advancement and Support of Education
          Jane Gravelle, Congressional Research Service

Hamilton Project Hosts Program Today on Entitlements, Taxation, and Revenues in the Federal Budget

The Hamilton Project hosts a program today on Real Specifics: 15 Ways to Rethink the Federal Budget—Part II: Addressing Entitlements, Taxation, and Revenues:

Budget battles continue in Washington even after the White House and Congress cut a last-minute deal to avert the so-called “fiscal cliff.”  With the imminent threat of default removed for now, the next potential challenge to the economy could come from sequestration, set to go into effect on March 1.

The Hamilton Project asked experts from a variety of backgrounds—the policy world, academia, and the private sector—and from both sides of the political aisle, to provide innovative, pragmatic proposals for lowering the deficit by reducing expenditures or raising revenues, and that take into account impacts to the economy at large. 

The resulting 13 proposals range across budget groups, and include options to reduce mandatory and discretionary programs, to improve economic efficiency, and touch on topics as wide ranging as immigration, transportation, healthcare, and mortgage interest.  This diverse group of authors will convene in at a forum today in Washington, D.C. to discuss their ideas in a series of roundtable discussions.

Here are the tax-related panels:

Panel #2:  Innovative Approaches to Tax Reform:

Robert Greenstein (Center on Budget and Policy Priorities) (moderator)

• Joseph E. Aldy (John F. Kennedy School of Government, Harvard University), Eliminating Fossil Fuel Subsidies:  "This paper looks at how limiting subsidies for fossil fuels could raise revenue for the federal government and while also benefiting the environment. It proposes the elimination of twelve tax provisions that subsidize the production of fossil fuels in the United States."
• Karen Dynan (The Brookings Institution), Better Ways to Promote Saving through the Tax System:  "Government programs and tax provisions aimed at encouraging people to save are essential to promoting economic security, but can subsidize savings that would have occurred anyway. This paper examines the design of better savings programs, outlining how one could reform savingsrelated programs to increase security but lower budgetary cost."
• Diane Lim (Pew Charitable Trusts), Limiting Individual Income Tax Expenditures: "This paper takes another approach to individual income tax expenditures, proposing an across-the-board reduction in deductions and exclusions rather than targeting specific provisions."
• Alan Viard (American Enterprise Institute), Replacing the Home Mortgage Interest Deduction: "Tax reform discussions often end up calling for a broader base—eliminating or limiting tax exclusions and deductions that can distort taxpayer decisions. This paper addresses replacing the mortgage interest deduction with a refundable credit to raise revenue and improve the efficiency of the tax code."

Panel #3:  New Sources of Revenue and Efficiency:

Michael Greenstone (The Hamilton Project, The Brookings Institution) (moderator)

• Tyler Duvall (McKinsey & Company), User Fees for Transportation Infrastructure:  "Investments in infrastructure are essential for a vital economy, but much of U.S. transportation infrastructure is in disrepair and overly congested. This paper looks to user fees as a way to raise revenues while also encouraging smarter use of infrastructure."
• Bill Gale (The Brookings Institution) & Ben Harris (The Urban Institute), Creating an American Value-Added Tax:  "Creating a value-added tax (VAT) in the United States could help raise revenue in a manner that does not distort saving and investment choices, that makes our system more consistent with the rest of the world’s, and that has been proven to be feasible administratively. This paper considers how a VAT could contribute to a fiscal solution and discusses its design."
• Adele Morris (The Brookings Institution), The Many Benefits of a Carbon Tax:  "A carbon tax could provide a new source of revenue while also addressing climate change more efficiently than many current regulations in place. This paper lays out a plan to implement a carbon tax while consolidating and limiting other regulations targeting climate change."
• Pia Orrenius (Federal Reserve Bank of Dallas), Overhauling the Temporary Work Visa System:  "A simplified immigration system designed to meet the needs of the economy would allow the United States to maximize the many benefits of immigration. This paper explores how reforms to the employment-based immigration system could increase the economic benefits of immigration while also raising revenue by auctioning visas."
• Phillip Swagel (School of Public Policy, University of Maryland), Increasing the Role of the Private Sector in Housing Finance:  "Government support for housing has allowed Americans to get mortgages and refinance at low interest rates, but it also leave taxpayers exposed to an immense amount of risk. This paper presents an overview of how changes in housing policies and reform of government-sponsored enterprises could contribute to budget savings as well as improve the distributional consequences and efficiency of federal housing policy."

American Taxation Association Midyear Meeting

The 19th Annual American Taxation Association 2013 Midyear Meeting concludes today in San Diego (program here):

• JATA Conference
• Research in Progress
• New Faculty and PhD Students
• Uncertain Tax Positions
• Tax Avoidance in an International Setting

Tulane Hosts Tax Roundtable Today in New Orleans

Tulane hosts its 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) & Jay Soled (Rutgers Business School), The Internal Revenue Code and Automobiles: A Case Study of Taxpayer Noncompliance
Discussant:  Philip Hackney (LSU)

Terrence Chorvat (George Mason), The Failure of the Facebook IPO and a Justification for Debt-Equity Tax Distinction
Discussant:  Steven Sheffrin (Tulane)

Tessa Davis (Tulane), Two Households Both Alike in Dignity: Family as Status and Family as Contract in the Tax Code
Discussant:  Lori McMillan (Washburn)

Lori McMillan (Washburn), Noncharitable Nonprofit Organizations in Canada: An Empirical Examination
Discussant:  James Alm (Tulane)

Ajay Mehrotra (Indiana), Sharing the Burden: Law, Politics, and the Making of the Modern American Fiscal State, 1880-1930
Discussant:  Marjorie Kornhauser (Tulane)

Shu-Yi Oei (Tulane), Taxing in the Shadow of Bankruptcy Law: The Collections Case for Tax Priority
Discussant:  Ajay Mehrotra (Indiana)

Steven Sheffrin (Tulane), What Role Can Desert Play in Designing Tax Policies?
Discussant:  Nancy Staudt (USC)

Nancy Staudt (USC) & Victor Fleischer (Colorado), The Supercharged IPO
Discussant:  Terrence Chorvat (George Mason)

UW-TEI Host Tax Forum Today in Seattle

The University of Washington and Tax Executives Institute host a Tax Forum today in Seattle. Among the speakers in Kristin Hickman (Minnesota), An Update on Transfer Pricing – The Number One Tax Enforcement Issue Worldwide.

Tax Analysts Hosts Conference Today on The Federal Income Tax: Has It Run its Course?

Tax Analysts hosts a roundtable discussion on The Federal Income Tax: Has It Run its Course? at the National Press Club in Washington, D.C. today at 9:00 - 11:00 a.m. EST:

Please join us for a roundtable discussion on whether the federal income tax, which celebrates its 100th birthday this year, can retain its role as a prime federal revenue source.

• Christopher E. Bergin (President and Publisher, Tax Analysts) (moderator)
• Jared Bernstein (Senior Fellow, Center on Budget and Policy Priorities)
• Robert Goulder (Editor in Chief of International Publications, Tax Analysts)
• Michael J. Graetz (Professor of Tax Law, Columbia Law School)
• Joseph J. Thorndike (Director of the Tax History Project, Tax Analysts)

Call for Participants: Workshop on Historical Approaches to Fiscal Sociology

Social Science History Association, 5th Annual Workshop on Comparative Historical Approaches to Fiscal Sociology:

In recent years, scholars from a variety of disciplines have embarked on an innovative wave of multidisciplinary research on the social and historical sources and consequences of taxation. We invite interested graduate students from history, law, and the social sciences to participate in a one-day workshop on this “new fiscal sociology.” In addition to brief lectures introducing students to the basics of taxation and the comparative history of taxation, the workshop will consist of discussion of classic and contemporary texts.

The workshop will be held on Wednesday, November 20th, in Chicago, IL in conjunction with the annual meetings of the Social Science History Association (SSHA). Interested students will also have a chance to present their own work on Thursday, November 21st, as part of the SSHA conference.

Space is limited. Small housing and travel stipends will be provided for a limited number of applicants under a grant from the National Science Foundation.

Applicants should submit a CV and a paragraph explaining their interest in this workshop, and (if applicable) a draft of a research paper that they would be willing to present at the SSHA. Preference will be given to students who also submit conference papers, but we encourage applications from all students interested in the workshop, including those at early stages of their graduate career.

Submit materials via e-mail to:
Monica Prasad, Department of Sociology, Northwestern University; and
Ajay Mehrotra, Maurer School of Law, Indiana University – Bloomington; and
Isaac Martin, Department of Sociology, University of California – San Diego,
no later than February 22, 2013.

Caron: Tax Advice for the Second Obama Administration

Paul L. Caron (Cincinnati & Pepperdine), Tax Advice for the Second Obama Administration, 40 Pepp. L. Rev. __ (2013):

Twenty-five of the nation’s leading tax academics, practitioners, journalists, and public intellectuals gathered in Malibu, California on the Friday before President Obama’s second inauguration to plead for tax reform. The papers published in this issue of the Pepperdine Law Review provide very different prescriptions for America’s tax ills. But there is a unanimous diagnosis that the country’s tax system is sick indeed. A re-elected president’s inauguration offers a particularly propitious moment to put politics aside and embark on a treatment plan. If our lawmakers are interested in healing our tax wounds, the ideas presented in these pages offer a good place to begin. They run the gamut from relatively minor procedures to total transplantation. But all would improve the health of our current tax system.

Keynote Address:  Michael Graetz (Columbia), Tax Advice for the Second Obama Administration, 138 Tax Notes 631 (Feb. 4, 2013)

Panel #1:  The Buffett Rule, the 1%, and the Fairness/Growth Divide

• Dorothy A. Brown (Emory), The 535 Report: A Pathway to Fundamental Tax Reform, 40 Pepp. L. Rev. ___ (2013)
• Francine J. Lipman (UNLV), Access to Tax InJustice, 40 Pepp. L. Rev. ___ (2013)
• Kirk Stark (UCLA) & Eric M. Zolt (UCLA), Tax Reform and the American Middle Class, 40 Pepp. L. Rev. ___ (2013)
• David Brunori (Tax Analysts) (moderator)
• Bruce Bartlett (New York Times) (commentator)
• David S. Miller (Cadwalader, Wickrsham & Taft, New York) (commentator)

Panel #2:  Estate and Gift Tax

• Paul L. Caron (Cincinnati & Pepperdine) & James R. Repetti (Boston College), Occupy the Tax Code: Using the Estate Tax to Reduce Inequality and Spur Economic Growth, 40 Pepp. L. Rev. ___ (2013)
• Edward J.  McCaffery (USC), Distracted from Distraction by Distraction: Reimagining Estate Tax Reform, 40 Pepp. L. Rev. ___ (2013)
• Grayson M. P. McCouch (San Diego), Who Killed the Rule Against Perpetuities?, 40 Pepp. L. Rev. ___ (2013)
• Paul L. Caron (Cincinnati & Pepperdine) (moderator)
• Joseph J. Thorndike (Tax Analysts) (commentator)

Panel #3:  Business and International Taxation (1)

• Steven A. Bank (UCLA), The Globalization of Corporate Tax Reform, 40 Pepp. L. Rev. ___ (2013)
• Karen C. Burke (San Diego), Passthrough Entities: The Missing Element in Business Tax Reform, 40 Pepp. L. Rev. ___ (2013)
• Martin A. Sullivan (Tax Analysts), A Proposal for the Tax Treatment of Interest in a Territorial System, 40 Pepp. L. Rev. ___ (2013)
• Thomas G. Bost (Pepperdine) (moderator)
• Michael L. Schler (Cravath, Swain & Moore, New York)

Panel #4:  Business and International Taxation (2)

• Reuven S. Avi-Yonah (Michigan), Corporate and International Tax Reform: Proposals for the Second Obama Administration, 40 Pepp. L. Rev. ___ (2013)
• Allison Christians (McGill), Putting the Reign Back in Sovereign: Advice for the Second Obama Administration , 40 Pepp. L. Rev. ___ (2013)
• Susan C. Morse (UC-Hastings), The Transfer Pricing Regs Need a Good Edit, 40 Pepp. L. Rev. ___ (2013)
• Khrista Johnson (Pepperdine) (moderator)
• Robert Goulder (Tax Analysts) (commentator)

Luncheon Address and Closing Remarks (What Have We Learned Today?):  David Cay Johnston (author/journalist)

NYU Hosts Program Today on Tax Reform and the Future of Fiscal Policy

NYU hosts a forum today on Cliffs Forever? Tax Reform and the Future of Fiscal Policy:

After weeks of negotiations, in the first days of January, Congress and the Obama Administration struck a last-minute deal that averted the so-called "fiscal cliff," a combination of federal tax increases and budget cuts. Yet this compromise merely deferred until March 1 "sequestration," which will cause the military and dozens of other government agencies to face about $1 trillion in automatic budget cuts over the coming decade. And, the debt limit again looms later in the year. Did Congress make progress toward reducing our fiscal shortfalls by enacting tax increases earlier this year? What is likely to happen in the upcoming sequestration negotiations and how will it affect the economy? Is tax reform the way forward, or is it a distraction? And why do budget and tax debates appear to occur only when the clock is ticking on looming high-stakes deadlines?

• Rosanne Altshuler (Chair, Department of Economics, Rutgers University)
• Joshua Blank (NYU)
• David Kamin (NYU)
• Daniel Shaviro (NYU)

Villanova Symposium: Taxation of Offshore Accounts, Executive Compensation

Norman J. Shachoy Symposium: U.S. Taxation of Offshore Activity and Regulation of Executive Compensation, 57 Vill. L. Rev. 421-673 (2012):

Leslie Book (Villanova), Introduction:  Offshore Accounts, Corporate Income Shifting, and Executive Compensation, 57 Vill. L. Rev. 421 (2012)

Taxation of Offshore Accounts

• Michael C. Durst (Tax Analysts), Some Suggestions for Tax Reform, 57 Vill. L. Rev. 433 (2012)
• Keith T. Fogg (Villanova), Go West: How the IRS Should Foster Innovation in its Agents, 57 Vill. L. Rev. 441 (2012)
• J. Richard (Dick) Harvey, Jr. (Villanova), Offshore Accounts: Insider's Summary of FATCA and its Potential Future, 57 Vill. L. Rev. 471 (2012)
• Leandra Lederman (indiana-Bloomington), The Use of Voluntary Disclosure Initiatives in the Battle Against Offshore Tax Evasion, 57 Vill. L. Rev. 499 (2012)
• Susan C. Morse (UC-Hastings), Ask for Help, Uncle Sam: The Future of Global Tax Reporting, 57 Vill. L. Rev. 529 (2012)

Regulation of Executive Compensation

• Kathryn J. Kennedy (Loyola-Chicago), The Use of Federal Law to Curb Excessive Executive Compensation: Lessons in Past Failures and Lessons for the Future, 57 Vill. L. Rev. 551 (2012)
• Andrew C.W. Lund (Pace), Tax's Triviality as a Pay-Reforming Device, 57 Vill. L. Rev. 571 (2012)
• Joy Sabino Mullane (Villanova), Perfect Storms: Congressional Regulation of Executive Compensation, 57 Vill. L. Rev. 589 (2012)
• Gregg D. Polsky (North Carolina), Fixing Section 409A: Legislative and Administrative Options, 57 Vill. L. Rev. 635 (2012)
• David I. Walker (Boston University), Who Bears the Cost of Excessive Executive Compensation (and Other Corporate Agency Costs)?, 57 Vill. L. Rev. 653 (2012):

Utah Hosts Symposium Today on Perpetual Conservation Easements

Utah hosts a symposium today on Perpetual Conservation Easements: What Have We Learned and Where Should We Go From Here? (webcast here):

The public is investing billions of dollars in conservation easements, which now protect more than 18 million acres throughout the United States. But uncertainties in the law and abusive practices threaten to undermine public confidence in and the effectiveness of conservation easements as land protection tools. This conference will explore these issues, with the goal of minimizing abuse and helping to ensure that conservation easements actually provide the promised conservation benefits to the public over the long term. Leaders in their respective fields will address (i) the federal tax incentives offered with respect to easements donated as charitable gifts to certain qualified holders, (ii) the state conservation easement enabling statutes, (iii) federal and state oversight of charities, and (iv) the role of state attorney general offices in the charitable sector and in the protection of charitable assets on behalf of the public.

Introduction:  Nancy A. McLaughlin (Utah)

Federal Tax Incentives History:

• History:  Theodore S. Sims (Boston University)
• IRS Response to Abuses:  Karin Gross (Supervisory Attorney, IRS Office of Chief Counsel)
• Proposed Reforms:  Roger Colinvaux (Catholic) 

State Enabling Statutes: 

• History:  K. King Burnett (Uniform Law Commissioner)
• Unintended Consequences of “Easement” Terminology:   Michael Allan Wolf (Florida)
• Reforms:  Jeffrey Pidot (Former Chief, Maine Attorney General’s Office)

Charity Oversight Cases and Controversies:

• Cases and Controversies:  Nancy A. McLaughlin (Utah)
• Law History:  Marion R. Fremont-Smith (Harvard)
• Limits of Self-Regulation:  Melanie B. Leslie (Cardozo)

Working With State Attorney General Offices:

• Overview of Attorney General’s Role in Charitable Sector:  Mark A. Pacella (Pennsylvania Office of the Attorney General)
• Working With the Attorney General’s Office in New Hampshire:  Terry M. Knowles (Department of Attorney General of New Hampshire)
• Working With the Attorney General’s Office in California:  Darla Guenzler (Executive Director, California Council of Land Trusts)

Concluding Remarks­­—Taking The Long View:  Wendy Fisher (Executive Director, Utah Open Lands Conservation Association)

Yale Hosts Program Today on Justice in Tax Policy

The three-day conference on The Structural Roots of Global Poverty: Theory Meets Practice kicks off today at Yale with a panel on Justice in Tax Policy:

• Anne Alstott (Yale)
• Reuven Avi-Yonah (Michigan)
• Stephen Cohen (Georgetown)
• Daniel Reeves (Retired Senior Advisor for IRS Offshore Compliance Initiatives)

Ventry Presents Protecting Clients in Rendering Tax Advice Today at San Diego

Dennis J. Ventry, Jr. (UC-Davis) presents Probability, Professionalism, and Protecting Clients in Rendering Tax Advice at San Diego today as part of its Tax Law Speaker Series:

Tax professionals get paid to predict whether a transaction or reporting position will withstand regulatory or judicial scrutiny. Yet few can describe with any precision how they go about ascertaining probabilities of success or attaining levels of certainty, especially on novel, aggressive, or grey-area positions. Instead they rely on the subjective “smell test,” on trusting their gut, or on borrowing from the science of handicapping horses. But that doesn’t cut it. Not for the regulator nor the court, not for the client, and not for the practitioner’s malpractice insurer (nor her firm’s). Indeed, in a world of accepted practice standards, of ethical codes and disciplinary rules, and of statutory accuracy requirements for taxpayers and their advisors, the tax practitioner must do more than rely on her intuition when faced with a tough call.

This article offers a more rigorous framework for undertaking probability assessments in rendering tax advice. It posits several analytical models that treat tax advice, both simple and sophisticated, as inherently an act of probability and thus as a behavior subject—at least in part—to empirical methods. The models, moreover, comport with the affirmative obligations imposed on tax advisors under the prevailing standards of care in rendering tax advice. In this way, we are not asking practitioners to do anything they are not already required to do. But we are asking them to consider an analytical framework that reinforces duties to their clients, to the tax system, and to their own professionalism.

Tax Policy Center Hosts Program Tomorrow on Time to Rethink Retirement Saving Policy?

The Tax Policy Center hosts a program tomorrow on Tax Expenditures and the Deficit: Time to Rethink Retirement Saving Policy?:

As policymakers continue to search for ways to shore up the nation’s fiscal status, tax subsidies may be ripe for the picking. Tax subsidies for retirement saving account for more than $90 billion annually in lost Treasury revenue. New research suggests that the tax subsidy for contributions to retirement accounts only affects the behavior of certain financially sophisticated households and does not raise overall saving significantly, however, automatic enrollment can raise both retirement saving and overall saving. Over 60 million Americans participate in 401(k) plans. Are there less expensive, more progressive ways to generate the same or more retirement saving and overall saving than the current tax treatment of contributions to retirement accounts? ... 

[A] new study ... examines whether a nudge or a subsidy is a better way to increase saving. [Active vs. Passive Decisions and Crowd-Out in Retirement Savings Accounts] The study also draws crucial distinctions between active and passive savers and the implications of the two groups for retirement saving policy. Speakers include study co-authors Raj Chetty and John Friedman of Harvard University, as well as Director of the Retirement Security Project William Gale.  

USC 16th Amendment Anniversary Conference

The USC Gould School of Law two-day 16th Amendment Anniversary Conference concludes today:

Panel #3:

Ed Kleinbard (USC), Corporate Capital and Labor Stuffing in the New Tax Rate Environment
Commentator:  Theodore Seto (Loyola-L.A.)

Joshua Blank (NYU) & Nancy Staudt (USC), Planning and Penalties
Commentator:  Katherine Pratt (Loyola-L.A.)

Panel #4:

Dennis Ventry (UC-Davis), Predicting Outcomes Amidst Uncertainty
Commentator:  Mark Phillips (USC)

Elliot Brownlee (UC-Santa Barbara), Fiscal Consolidation: An Overview of its History in the United States
Commentator:  Steve Bank (UCLA)

USC 16th Amendment Anniversary Conference

The USC Gould School of Law two-day 16th Amendment Anniversary Conference kicks off today:

Panel #1:

Edward McCaffery (USC), The Original Sin of Income Taxation
Commentator: Kirk Stark (UCLA)

Deborah Schenk (NYU), 100 Years without an “Income” Tax
Commentator: Jason Oh (UCLA)

Panel #2:

Rebecca Kysar (Brooklyn), The “Shell Bill” Game
Commentator: Ellen Aprill (Loyola-L.A.)

Dan Shaviro (NYU). The Forgotten Henry Simons
Commentator: Miranda Fleischer (Colorado)

Pat Cain (Santa Clara), The IRS and State Law: The Problem with FRMPs
Commentator: Tom Griffith (USC)

Keynote: 

Introduction: Robert Rasmussen (Dean, USC)
Speech: Larry Summers (Harvard)
Moderator: Edward McCaffery (USC)
Commentary: Pat Cain (Santa Clara), Edward Kleinbard (USC)