TaxProf Blog

Editor: Paul L. Caron
Pepperdine University School of Law

Sunday, July 24, 2016

Perry Fleischer Presents Autonomy, Uncertainty and the Poor: Reflections On 'Charity Law And The Liberal State' Today At Melbourne

Fleischer (Miranda)Miranda Perry Fleischer (San Diego) presents Autonomy, Uncertainty and the Poor: Reflections on Matthew Harding's "Charity Law and the Liberal State", 41 Australian J. for Legal Phil. ___ (2016), today at the Australian Society Of Legal Philosophy Annual Conference at Melbourne Law School:

In Charity Law and the Liberal State [Cambridge University Press 2014], Matthew Harding argues that one can best justify the existence, scope, and substance of charity law as reflecting the state’s desire to further the political ideal of autonomy as grounded in Razian principles.  Complicating Harding’s job, however, is the problem of factual uncertainty:  it is frequently hard to identify the impact of a given state policy on a specific currency such as autonomy, equality, opportunity, or well-being. This commentary argues that Harding both under- and over-values the importance of this uncertainty.

He over-values this uncertainty in his discussion of the charitable tax subsidies, when he implies that the complex nature of distributive questions surrounding the subsidies renders them an ultimately unfulfilling line of inquiry.  Despite the fact that the charitable tax subsidies are but one component by which a state might further the autonomy of the poor, however, understanding the extent to which the subsidies do or do not do so is necessary for determining whether the poor in a given state can adequately exercise their autonomy.

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July 24, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Saturday, July 23, 2016

Perry Fleischer Presents How Is The Opera Like The Soup Kitchen? Today At Melbourne

Fleischer (Miranda)Miranda Perry Fleischer (San Diego) presents How is the Opera Like the Soup Kitchen? in The Philosophical Foundations of Tax Law (Oxford University Press, forthcoming 2016) today at the Australian Society Of Legal Philosophy Annual Conference at Melbourne Law School:

The charitable tax subsidies are, at heart, redistributive. Some individuals (the recipients of charitable goods and services, such as students, museum-goers, and soup kitchen patrons) receive benefits. Other individuals pay for these benefits, both voluntarily (through donations) and involuntarily (in the form of higher taxes or reduced benefits). At first glance, it appears that the redistribution effectuated by the subsidies violates commonly-held notions of distributive justice. After all, the subsidies treat charities that serve the wealthy (like the opera) the same as charities that aid the poor (such as the soup kitchen). How can spending public funds on the wealthy in this manner be considered just? As this Chapter shows, so doing is just under expansive interpretations of resource egalitarianism and left-libertarianism that account for expensive tastes and talent-pooling.

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July 23, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, July 14, 2016

Journal of Tax Administration Hosts Workshop Today On U.S. And U.K. Trends In Tax Exceptionalism And Tax Litigation

JOTAThe Journal of Tax Administration hosts a workshop today on Trends in Tax Exceptionalism and Tax Litigation (program):

In the United States, the Supreme Court's 2011 decision in the Mayo Foundation case has fundamentally changed tax litigation and tax administration. Previously, tax administration functioned with a mindset of "tax exceptionalism" from the administrative statutory requirements, legal doctrines, and norms that applied to other federal government agencies. The legal veracity of tax exceptionalism had not been tested; it was an unchallenged assumption, but one that persisted for some decades. In Mayo Foundation, the Supreme Court expressly rejected tax exceptionalism from general administrative law requirements, doctrines, and norms absent "good reason" — which is generally thought to mean unless the Internal Revenue Code provides an express exception.

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July 14, 2016 in Colloquia, Conferences, Scholarship, Tax | Permalink | Comments (0)

UC-Berkeley, Oxford & Tax Policy Center Host Program Today On Corporate Tax For The 21st Century

UCBThe Oxford University Centre for Business Taxation, Robert D. Burch Center for Tax Policy and Public Finance at UC-Berkeley and Tax Policy Center are hosting a program today on Corporate Tax for the 21st Century:

Welcome and Introduction: Michael Devereux (Oxford)

Panel:  The Need for Reform and Current Policy Proposals

  • Alan Auerbach (UC-Berkeley) (moderator)
  • Michael Devereux (Oxford)
  • Michael Graetz (Columbia)
  • Justus S. Hotchkiss (Yale)
  • Mark Mazur (Assistant Secretary for Tax Policy, U.S. Treasury Department)
  • John Vella (Oxford)

Session:  Residual Profit Allocation Proposal

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July 14, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Netanya Hosts Roundtable Today On Taxation And Tax Policy

Friday, July 1, 2016

Oxford 10th Annual Academic Tax Symposium

OxfordThe 10th Annual Academic Tax Symposium concludes today at the Oxford University Centre for Business Taxation:

Allison Christians (McGill University), Not So Soft Law: The OECD BEPS Regime
Discussant:  John Vella (Oxford University)

Dominika Langenmayr (KU Eichstatt-Ingolstadt & CESifo), Why The Current Tax Rate Tells You Little: Competing for Mobile and Immobile Firms
Discussant:  Johannes Voget (University of Mannheim)

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July 1, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, June 30, 2016

Oxford 10th Annual Academic Tax Symposium

OxfordThe 10th Annual Academic Tax Symposium continues today at the Oxford University Centre for Business Taxation:

Annette Alstadsæter (NMBU), Accounting for Business Income in Measuring Top Income Shares: Integrated Accrual Approach Using Individual and Firm Data from Norway
Discussant:  Brian Bell (University of Oxford)

Jennifer Blouin (University of Pennsylvania), Investment and Tax Uncertainty: Evidence from Fin 48
Discussant:  TBA

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June 30, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, June 29, 2016

Oxford 10th Annual Academic Tax Symposium

OxfordThe 10th Annual Academic Tax Symposium continues today at the Oxford University Centre for Business Taxation:

Lily Batchelder (NYU), Accounting for Behavioral Biases in Business Tax Reform: The Case of Expensing
Discussant:  Michael Devereux (Oxford University)

Jan-Emmanuel De Neve (University of Oxford), Eliciting Taxpayer Preferences Increases Tax Compliance
Discussant:  Nadine Riedel (University of Bochum)

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June 29, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Tuesday, June 28, 2016

Oxford 10th Annual Academic Tax Symposium

OxfordThe 10th Annual Academic Tax Symposium kicks off today at the Oxford University Centre for Business Taxation:

Reuven Avi-Yonah (University of Michigan), Evaluating BEPS
Discussant:  Henk Vording (Leiden University)

Niels Johannesen (University of Copenhagen), The Role of Tax Havens in International Trade With Services
Discussant:  Katarzyna Habu (Oxford University)

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June 28, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, June 24, 2016

Tax Panel At Today's National Business Law Scholars Conference At University Chicago

Chicago LogoTax panel at today's National Business Law Scholars Conference at the University of Chicago Law School:

The Intersection of Business and Tax Law:

  • Ilya Beylin (Columbia), Taxing Fictive Orders: How an Information Forcing Tax Can Reduce Manipulation and Distortion in Financial Product Markets
  • Limor Riza (Carmel Academic Center), Charitable Contributions and Dependent Care Expenses in a Coherent System
  • Sloan G. Speck (Colorado), Competitiveness as a Rationale for International Tax Reform 
  • Eric C. Chaffee (Toledo), Moderator

June 24, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, June 20, 2016

Columbia Journal Of Tax Law Publishes Symposium On Reforming The IRS

Columbia Journal of Tax Law LogoThe Columbia Journal of Tax Law has published Vol. 7, No. 1 (Symposium on Reforming the IRS, University of Minnesota Law School):

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June 20, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, June 17, 2016

ABA Associate Deans Conference On Adapting To A Changing Landscape

ABAThe 2016 ABA Associate Deans Conference on Adapting to a Changing Landscape continues today at the University of St. Thomas School of Law:

There is little about legal education that is not in transition right now. Associate Deans are all adjusting to similar challenges and opportunities across the nation. How do law schools respond to the new accreditation requirements and innovate in curricular design with decreasing resources? How do law schools educate a changing student population that is also facing increasing student debt loads and a legal job market that looks very different from when you graduated? How are you managing the shifting demands on your academic programs, student services, and faculty research? 

Today's morning plenary session is Managing People, Managing Resources, Managing Teams:

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June 17, 2016 in Conferences, Legal Education | Permalink | Comments (0)

Wednesday, June 15, 2016

NYU Call For Papers:  Human Rights And Tax In An Unequal World

NYUCall for Papers: Human Rights and Tax in an Unequal World:

The NYU Center for Human Rights and Global Justice (CHRGJ) invites submissions of scholarly papers for a conference on human rights and tax, to be held at NYU School of Law on September 22-23, 2016. The conference aims to develop a deeper understanding of the ways in which tax policy is a centrally important form of human rights policy, and to consider how the international human rights framework can best be used to promote greater equality and justice through the global tax regime.

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June 15, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Boston College Symposium:  The Centennial of the Estate Tax

Boston College (2017)Symposium, The Centennial of the Estate Tax: Perspectives and Recommendations, 57 B.C. L. Rev. 801-1078 (2016):

Keynote Address:  Michael J. Graetz (Columbia), "Death Taxes" and Politics, 57 B.C. L. Rev. 801 (2016)

Panel #1

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June 15, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Saturday, June 11, 2016

11th Annual Junior Tax Scholars Workshop Concludes Today At UC-Irvine

UC Irvine Logo (2016)Panel #5:  Exempt Organizations/Individual Planning

Manoj Viswanathan (UC-Hastings), Tax Compliance in a Decentralizing Economy
Commentators:  Philip Hackney (LSU), Khrista Johnson (Pepperdine)

Philip Hackney (LSU), Subsidizing the Heavenly(?) Chorus
Commentators:  Manoj Viswanathan (UC-Hastings), Lilian Faulhaber (Georgetown)

Tessa Davis (South Carolina), Reconsidering Alimony and Tax
Commentators:  Khrista Johnson (Pepperdine), Sloan Speck (Denver)

Panel #6:  Grab Bag

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June 11, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, June 10, 2016

11th Annual Junior Tax Scholars Workshop Kicks Off Today At UC-Irvine

UC Irvine Logo (2016)Panel #1:  Tax Bases

Erin Scharff (Arizona State), Pigouvian User Fees
Commentators:  Goldburn Maynard (Louisville), Tessa Davis (South Carolina)

Goldburn Maynard (Louisville), A Plea for Courts to Abolish the Judicially Created Right of the Wealthy to Avoid Estate Taxes
Commentators:  Erin Scharff (Arizona State), Philip Hackney (LSU)

Emily Satterthwaite (Toronto), Chain Effects and the Small Supplier Election
Commentators:  Ari Glogower (Ohio State), Omri Marian (UC-Irvine)

Ari Glogower (Ohio State), Wealth Integration
Commentators:  Emily Satterthwaite (Toronto), Andrew Hayashi (Virginia)

Panel #2:  Compliance

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June 10, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

NYLS Hosts Third National Symposium On Experiential Learning In Law

NYLS

Third National Symposium On Experiential Learning In Law (agenda):

The 2016 Third National Symposium on Experiential Learning in Law will take a careful look at how to identify and effectively assess experiential learning outcomes in the legal education context. This symposium will offer highly interactive sessions that will provide learning designed to improve the quality of assessment in law schools’ experiential programs.

Assessment is the pedagogical topic of our time.

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June 10, 2016 in Conferences, Legal Education | Permalink | Comments (1)

Wednesday, June 8, 2016

AEI Hosts Panel Discussion On U.S. Corporate Tax Reform in 2017

AEI (2016)American Enterprise Institute, U.S. Corporate Tax Reform in 2017: Exploring the Options:

On June 7 at AEI, two expert panels discussed business- and shareholder-level taxation in pursuit of solving current problems with corporate taxation.

The Senate Finance Committee’s Christopher H. Hanna remarked that tax reform efforts almost exclusively promote efficiency and economic growth and that the US tax system is largely obsolete.

On the first panel, Columbia University’s David M. Schizer voiced the popular sentiment that the corporate tax rate must be reduced. Columbia Business School’s R. Glenn Hubbard argued that one type of tax could not alone address the income shifting problem. The University of Southern California’s Edward D. Kleinbard encouraged focusing on the effective tax rate rather than statutory rates, while Alan J. Auerbach of the University of California, Berkeley, suggested removing incentives for companies to go offshore rather than cutting the corporate rate.

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June 8, 2016 in Conferences, Tax | Permalink | Comments (0)

Friday, June 3, 2016

Today's Law, Society & Taxation Panels

L&SToday's Law, Society, and Taxation panels at the 2016 Law & Society Association Annual Meeting in New Orleans (program here):

  • Panel #6:  Inequality
  • Panel #7:  International Tax Issues
  • Panel #8:  Retirement
  • Panel #9:  Theory and Jurisprudence

Panel #6:  Inequality (Toni Robinson (Quinnipiac), Chair/Discussant))

  • Daniel Hemel (Chicago), Taxation and House Price Risk
  • Michelle Layser (Georgetown), How We Can Win the Tax War on Poverty: Looking Beyond Efficiency to Design a More Effective Low Income Housing Tax Credit
  • Francine Lipman (UNLV) & Matthew Bruenig (Demos.org), De/reconstructing Poverty
  • Goldburn Maynard (Louisville), America’s “Ideal Vision” for the Distribution of Wealth by Race

Panel #7: International Tax Issues (Shu-Yi Oei (Tulane), Chair/Discussant)

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June 3, 2016 in Conferences, Tax | Permalink | Comments (0)

Thursday, June 2, 2016

Today's Law, Society & Taxation Panels

L&SToday's Law, Society, and Taxation panels at the 2016 Law & Society Association Annual Meeting in New Orleans (program here):

  • Panel #1:  Business Taxes
  • Panel #2:  Controversies in Theory and Practice
  • Panel #3:  Comparative Tax Issues
  • Panel #4:  Evasion and Compliance
  • Panel #5:  Deterrence and Enforcement

Panel #1:  Business Taxes (Diane Ring (Boston College), Chair/Discussant))

  • Karie Davis-Nozemack (Georgia Tech), The Conceptual Incompatibility of Corporate Tax Avoidance with CSR and Stakeholder Theory
  • Calvin Johnson (Texas), A Conceptual Framework for Capital Gains
  • Melina Rocha Lukic & José Roberto Afonso (Fundacao Getulio Vargas), An Empirical Analysis of the Allowance for Corporate Equity (ACE) System in Brazil
  • Doron Narotzki (Akron), Corporate Social Responsibility and Taxation: The Next Step of the Evolution, 16 Hous. Bus. & Tax J. 167 (2016)

Panel #2:  Controversies in Theory and Practice (Philip Hackney (LSU), Chair/Discussant)

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June 2, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Villanova Hosts Symposium Today On Tax Policy And The 2016 Election

Villanova Grad Tax Program LogoThe Villanova Graduate Tax Program hosts its inaugural tax policy symposium today on Fundamental Tax Reform and Tax Policy Issues in Election Year 2016:

Welcome:  Edward A. Liva (Professor of Practice and Director, Villanova Graduate Tax Program)

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June 2, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

16th Annual Oregon Tax Institute

OregonThe 16th Annual Oregon Tax Institute kicks off today in Portland.  Tax Prof speakers include:

  • Howard Abrams (San Diego), Partnership Leveraged Distributions: Traps Getting In and Tips on Getting Out

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June 2, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, May 25, 2016

2d Annual Mid-Career Tax Professors Workshop Concludes At UC-Davis

UC Davis Logo (2016)Panel #5:  Issues in Enforcement and Inter-Governmental Relations

David Gamage (UC-Berkeley), Tax Cannibalization and Fiscal Federalism in the United States, 110 Nw. U. L. Rev. ___ (2016)
Commentator: Adam Rosenzweig (Washington University)

Dennis Ventry (UC-Davis), Stitches for Snitches: Lawyers as Whistleblowers, 50 U.C. Davis L. Rev. ___ (2017)
Commentator: Will Foster (Arkansas)

Darien Shanske (UC-Davis), State Fiscal Constitutions and the Common Law of Public Finance
Commentator: Jake Brooks (Georgetown)

Panel #6:  Insurance and Employee Benefits

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May 25, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, May 23, 2016

2d Annual Mid-Career Tax Professors Workshop Kicks Off Today At UC-Davis

UC Davis Logo (2016)Panel #1:  Tax Administration

Susie Morse (Texas), Regulating by Example
Commentator: Emily Cauble (DePaul)

Sarah Lawsky (Northwestern), Picturing the Code
Commentator: David Gamage (Berkeley)

Will Foster (Arkansas), Uncoupling Competence
Commentator: Dennis Ventry (UC-Davis)

Panel #2:  International

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May 23, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Sunday, May 22, 2016

Symposium:  Legal Education In A Time Of Change

UNLV Logo (2016)Symposium, Legal Education in a Time of Change: Challenges and Opportunities,  16 Nev. L.J. 143-274 (2015):

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May 22, 2016 in Conferences, Legal Education, Scholarship | Permalink | Comments (4)

Friday, May 20, 2016

Fordham Symposium:  We Are What We Tax

Fordham Law ReviewSymposium, We Are What We Tax, 84 Fordham L. Rev. 2413-2753 (2016):

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May 20, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, May 16, 2016

Graetz:  'Death Tax' Politics

BCACTEC 2Michael J. Graetz (Columbia), 'Death Tax' Politics, 57 B.C. L. Rev. ___ (2016):

In his Keynote Address 'Death Tax' Politics at the October 2, 2015 Boston College Law School and American College of Trust and Estate Counsel Symposium, The Centennial of the Estate and Gift Tax: Perspectives and Recommendations, Michael Graetz describes the fight over the repeal of the estate tax and its current diminished state. Graetz argues that the political battle over the repeal of the estate tax reflects a fundamental challenge to our nation’s progressive tax system.

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May 16, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, May 13, 2016

NTA 46th Annual Spring Symposium:  Tax Policy At The Crossroads

NTA 2The 46th Annual Spring Symposium on Tax Policy at the Crossroads: What Direction Next? hosted by the National Tax Association and American Tax Policy Institute concludes today in Washington, D.C.:

Panel #1:  Base Erosion and Profit Shifting (BEPS) Project

  • Stephen Shay (Harvard) (organizer & moderator)
  • Kimberly Clausing (Reed)
  • Ruth Mason (Virginia)
  • Victoria Perry (IMF)
  • Robert Stack (U.S. Treasury Department)

Panel #2:  The Economic Consequences of Taxing the Rich

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May 13, 2016 in Conferences | Permalink | Comments (1)

Thursday, May 12, 2016

NTA 46th Annual Spring Symposium:  Tax Policy At The Crossroads

The 46th Annual Spring Symposium on Tax Policy at the Crossroads: What Direction Next? hosted by the National Tax Association and American Tax Policy Institute kicks off today in Washington, D.C.  Today's highlight is the presentation of the Davie-Davis Award for Public Service to Leonard Burman (Director, Tax Policy Center; Professor, Syracuse University) by Daniel Shaviro (NYU).

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May 12, 2016 in Conferences, Tax | Permalink | Comments (0)

Saturday, May 7, 2016

ABA Tax Section May Meeting

The ABA Tax Section May meeting concludes today in Washington, D.C.  The full program is here.  Today's highlights are:

SedoPro Bono & Tax Clinics, Reflecting on Low Income Tax Clinics and Celebrating Professor Kathryn Sedo

This program will look back at low income tax clinics since their inception with a particular focus on retiring clinic Professor Kathryn Sedo of the University of Minnesota. Professor Sedo has been a part of the low income taxpayer community as one of the founders of one of the oldest clinics in the country. As she retires from her current position, we have the opportunity to look at the changes in the tax system as it relates to low income taxpayers over the course of her career and to look forward.

  • Frank DiPietro (Minnesota) (moderator)
  • Leslie Book (Villanova)
  • Keith Fogg (Harvard)
  • Peter Panuthos (Chief Special Trial Judge, U.S. Tax Court)

GideonPosthumous Presentation, 2016 Distinguished Service Award Recipient Ken Gideon

The Section of Taxation is pleased to honor Kenneth W. (“Ken”) Gideon as the recipient of its 2016 Distinguished Service Award in recognition for his distinguished career in recognition of his service to the profession, service to the government, and service to the Section. 

The Distinguished Service Award is the highest honor awarded by the Section of Taxation. The Award is given to individuals who have had a distinguished career in taxation and “who have provided an aspirational standard for all tax lawyers to emulate.” In the fall of last year, the Distinguished Service Award Committee unanimously selected Ken to be this year’s recipient. As is the custom of the Committee, the plan was to inform Ken of the Award at the Council Dinner during the January meeting in Los Angeles. Ken passed away unexpectedly on January 10, 2016, two weeks before the Los Angeles meeting. [See Michael Graetz, Farewell To Ken Gideon.]

Other Tax Profs with speaking roles today include:

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May 7, 2016 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0)

Friday, May 6, 2016

ABA Tax Section May Meeting

ABA Tax SectionThe ABA Tax Section May meeting continues today in Washington, D.C.  The full program is here.  Yesterday's highlight was the annual Laurence Neal Woodworth Memorial Lecture in Federal Tax Law and Policy on What Has the Tax Court Been Doing? An Update delivered by Senior Tax Court Judge James S. Halpern. Today's highlights are the two Teaching Taxation programs:

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May 6, 2016 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0)

Thursday, May 5, 2016

Call For Corporate Tax Papers:  ClassCrits IX

Class Crits 2ClassCrits IX Call for Papers and Participation: The New Corporatocracy and Election 2016:

We invite panel proposals, roundtable discussion proposals, and paper presentations that speak to this year’s theme, as well as to general ClassCrits themes.  Proposal due: May 16, 2016.

As the U.S. presidential election approaches, our 2016 conference will explore the role of corporate power in a political and economic system challenged by inequality and distrust as well as by new energy for transformative reform.

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May 5, 2016 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

Friday, April 29, 2016

Call For Papers:  University Of Washington Symposium On Protecting Taxpayer Rights

University of Washington Logo (2016)The University of Washington’s Graduate Tax Program has issued a call for papers for its Fourth Annual Tax Symposium on October 7, 2016:

The 2016 Symposium will focus on Protecting Taxpayer Rights and feature keynote remarks by Nina E. Olson, the National Taxpayer Advocate.

Papers should be well developed, but at a stage where they can still benefit from the group’s discussion. Priority will be given to papers that are consistent with the chosen theme. The symposium will include twelve to fifteen papers. Dinner with the keynote speaker will be held on the day of the conference.

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April 29, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Wednesday, April 27, 2016

Call For Papers:  AALS Program On Philanthrocapitalism

AALS (2017)Call for Papers:  Joint Program of the AALS Sections on Agency, Partnerships LLCs, and Unincorporated Associations & Nonprofit and Philanthropy on LLCs, New Charitable Forms, and the Rise of Philanthrocapitalism:

In December 2015, Facebook founder Mark Zuckerberg and his wife, Dr. Priscilla Chan, pledged their personal fortune—then valued at $45 billion—to the Chan-Zuckerberg Initiative (CZI), a philanthropic effort aimed at “advancing human potential and promoting equality.” But instead of organizing CZI using a traditional charitable structure, the couple organized CZI as a for-profit Delaware LLC. CZI is perhaps the most notable example, but not the only example, of Silicon Valley billionaires exploiting the LLC form to advance philanthropic efforts. But are LLCs and other for-profit business structures compatible with philanthropy? What are the tax, governance, and other policy implications of this new tool of philanthrocapitalism? What happens when LLCs, rather than traditional charitable forms, are used for “philanthropic” purposes?

From the heart of Silicon Valley, the AALS Section on Agency, Partnerships LLCs, and Unincorporated Associations and Section on Nonprofit and Philanthropy Law will host a joint program tackling these timely issues. In addition to featuring invited speakers, we seek speakers (and papers) selected from this call.

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April 27, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

May 1 Deadline For Call For Papers For NTA 109th Annual Conference On Taxation

NTA LogoThe National Tax Association has issued a Call for Papers for its 109th Annual Conference on Taxation to be held Nov. 10-12, 2016 in Baltimore:

The 109th Annual Conference on Taxation will cover a broad range of topics including, but not limited to, taxation and tax policies; expenditure policies; government budgeting; intergovernmental fiscal relations; and subnational, national, and international public finance. The conference will focus, as always, on policy-relevant research bearing on taxation and government spending.

You are invited to submit a paper or a complete session. May 1, 2016 is the deadline for submitting papers or sessions. Decisions concerning the inclusion of papers and sessions will be announced in July 2016. Authors of accepted papers will be offered the opportunity to include them in the Proceedings. All presenters will be required to register and pay a conference registration fee.

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April 27, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

ABA Teleconference Today On The Tax Code And Income Inequality

LogoThe ABA Section of Civil Rights and Social Justice and the ABA Tax Section are offering a free teleconference today at 3:30 - 5:00 EST on The Tax Code and Income Inequality: Limitations and Political Opportunities:

“Welfare” has become “workfare,” delivered through the Tax Code, e.g., the Earned Income Tax Credit and Child Tax Credit. How well is that really working for low and middle income Americans, much less those in poverty? At the same time, tax deductions, credits—and avoidance/evasion schemes—are increasingly benefitting wealthy individuals and big corporations, which increasingly pay a smaller portion of federal tax revenue—revenue that could fund government programs, bolster economic growth and benefit the bottom 99% by providing jobs and increase skills of lower income American. Panelists will discuss how changes to the Tax Code can address income inequality in the U.S. and political opportunities for reform.

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April 27, 2016 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0)

Thursday, April 21, 2016

Pepperdine Symposium:  The Impact Of King v. Burwell On Judicial Deference To IRS Determinations

Pepperdine Law ReviewSymposium, The Impact of King v. Burwell on Judicial Deference to IRS Determinations, 2015 Pepp. L. Rev. 1-81:

I previously blogged the online version of the symposium, published  just four months after the decision in King v. Burwell.  The Pepperdine Law Review has now released a hard copy of the symposium, pictured on the right.  This is the third major tax symposium produced by the Pepperdine Law Review over the past three years:

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April 21, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Monday, April 18, 2016

Call For Papers:  Taxation And Migration Conference At Saint Louis

St. Louis (2016)Call for Papers:  Sanford E. Sarasohn Conference on Critical Issues in Comparative and International Taxation II: Taxation and Migration at Saint Louis University School of Law:

As ever growing numbers of individuals seek economic and political refuge in Europe and North America, and increasing numbers of individuals and businesses seek refuge from the tax burdens of their home jurisdictions in lower tax jurisdictions, these in- and out- migrations strain the national economies of affected countries causing them to modify their taxation rules and structures. This conference will explore the effects of taxation on migration and the effects of migration on taxation. Papers on any topic related to taxation and migration of individuals or entities are welcome but those offering a critical perspective or addressing the impact of taxation on, and taxation changes relating to acceptance of, migrants from conflict areas are preferred. Please submit paper proposal abstracts by e-mail to Professor Henry Ordower at ordoweh@slu.edu no later than May 25, 2016. Notification of proposal acceptance is targeted for July 1, 2016.

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April 18, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, April 13, 2016

Hickman Presents Treasury's Retroactivity Today At Cambridge

Hickman 2014 2Kristin Hickman (Minnesota) presents Treasury's Retroactivity at Christ's College, Cambridge today at a conference on The Role of Judges in Developing the Content of Tax Law:

In Bowen v. Georgetown University Hospital, the Supreme Court described retroactivity as "not favored in the law" and generally rejected allowing federal administrative agencies to adopt regulations "altering the past legal consequences of past actions."  Unlike most regulatory agencies, Treasury and the IRS are expressly authorized by Congress to adopt regulations with precisely such primary retroactive effect.  Specifically, IRC § 7805(b) grants Treasury and the IRS the power to backdate tax regulations under a variety of circumstances.  Preliminary analysis shows that Treasury and the IRS utilize this authority regularly with little judicial oversight for abuse of discretion.  Using empirical data, this article will explore more fully Treasury and IRS utilization of the authority to adopt retroactively effective regulations interpreting the Internal Revenue Code

April 13, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Friday, April 8, 2016

Call For Papers:  NTA 109th Annual Conference On Taxation

NTA LogoThe National Tax Association has issued a Call for Papers for its 109th Annual Conference on Taxation to be held Nov. 10-12, 2016 in Baltimore:

The 109th Annual Conference on Taxation will cover a broad range of topics including, but not limited to, taxation and tax policies; expenditure policies; government budgeting; intergovernmental fiscal relations; and subnational, national, and international public finance. The conference will focus, as always, on policy-relevant research bearing on taxation and government spending.

You are invited to submit a paper or a complete session. May 1, 2016 is the deadline for submitting papers or sessions. Decisions concerning the inclusion of papers and sessions will be announced in July 2016. Authors of accepted papers will be offered the opportunity to include them in the Proceedings. All presenters will be required to register and pay a conference registration fee.

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April 8, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Tuesday, April 5, 2016

ACTEC Issues Request For Proposals For $20,000 Grant To Host T&E Symposium

ACTECThe Legal Education Committee of the American College of Trust and Estate Counsel (ACTEC) requests proposals for a $20,000 grant to host an academic symposium on trust and estate law during the 2017-18 academic year:

The ACTEC Foundation Symposium is intended to be the premier academic symposium on trust and estate law in the United States. The goals of the symposium are to stimulate development of scholarly work in trust and estate law, bridge the gap between the academic community and practitioners, provide opportunities for junior academics to present papers and interact with more senior academics, provide an opportunity for trust and estate professors to interact with each other, involve academics from other disciplines in discussions of trust and estate topics, and strengthen ACTEC’s image as the leading organization for trust and estate lawyers, both practitioners and academics.

The grant associated with this RFP is contingent on approval by the ACTEC Foundation.

RFPs are due by Monday, May 2, 2016, and will be considered by the Symposium Subcommittee of the ACTEC Legal Education Committee at ACTEC’s Summer Meeting in Boston, Massachusetts, in June 2016. Please submit RFPs (RFP content and guidelines are set forth below) to:

Nancy A. McLaughlin
Professor of Law, University of Utah SJ Quinney College of Law
Co-Chair, ACTEC Legal Education Committee
nancy.mclaughlin@law.utah.edu

Electronic submissions are fine (subject line of email should read “ACTEC Symposium RFP”).

I. RFP Content

The RFP should provide the following information.

A. Theme. The theme of the symposium should be related to trust and estate law, defined to include any topic related to the gratuitous transfer of property (e.g., probate law, trust law, elder law, transfer tax law). A broad theme permits a wide range of papers and is more likely to be successful. Past themes have included Trust Law in the 21st Century (Cardozo 2005); Inheritance Law in the 21st Century (UCLA 2008); Philanthropy Law in the 21st Century (Chicago-Kent 2009); The Uniform Probate Code: Remaking of American Succession Law (Michigan 2011); and The Role of Federal Law in Private Wealth Transfer (Vanderbilt 2014). The theme of the most recent symposium, which took place at Boston College Law School in October 2015, was The Centennial of the Estate Tax: Perspectives and Recommendations (articles will be published in the Boston College Law Review May 2016 symposium edition).

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April 5, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

University Of Basel Call For Papers:  Global Histories Of Taxation And State Finances Since The Late 19th Century

BaselVanessa Ogle (Pennsylvania) and the Institute for European Global Studies at the University of Basel (Switzerland) have issued a  Call for Papers for a symposium on Global Histories of Taxation and State Finances Since the Late 19th Century to be held at the University of Basel on December 1-3, 2016.  The deadline for submitting proposals is May 31, 2016.

Taxation has wide-ranging implications for global as well as domestic orders, ranging from budgets and public finances to inequality, the social fabric of societies, and worldwide competition for corporate profits. Since the global financial crisis of 2008 in particular, taxation and the reform of tax systems have become talking points in many parts of the North Atlantic world. Tax reform is often said to be required for fostering a more attractive business climate through reducing the tax burden and thus increasing tax competitiveness. Other voices focus on government revenues in times of empty coffers and instead call for higher tax rates especially for top earners. Thomas Piketty and his Capital in the Twenty-First Century as well as the Occupy movement in the United States have galvanized attention on the connections between taxes and inequality. Outrage at the rise of the “One Percent” is accompanied by calls for shutting down tax havens available mostly to the super rich. Whether in the United States or Britain, however, multinationals such as Google and Apple successfully play the inversion game by splitting up into multiple units and reincorporating in lower-tax countries for the purpose of obtaining better tax conditions.

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April 5, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Saturday, April 2, 2016

19th Annual Critical Tax Theory Conference Concludes Today At Tulane

Tulane (2015)The 19th Annual Critical Tax Theory Conference concludes today at Tulane:

Panel #4:  Tax Expenditures, Social Insurance, and Younger Generations (Chair: Charlotte Crane (Northwestern))

  • Samuel Brunson (Loyola-Chicago) & David Herzig (Valparaiso), The Effect of Obergefell on the Tax Exemption of Churches and Religiously-Affiliated Organizations
  • Neil Buchanan (George Washington), Social Security, Inequality, and Younger Generations
  • Nancy Shurtz (Oregon), Rethinking the Taxable Unit: Why Dependency Trumps Marriage as the Preferred Reference Standard

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April 2, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Kleinbard Presents Fiscal Policy In An Age Of Inequality Today At AAA Conference

Kleinbard (2015)Edward Kleinbard (USC) presents Fiscal Policy in an Age of Inequality at the American Accounting Association 2016 Conference and Doctoral/Early Scholar Consortium today in Orlando, Florida:

Federal budget deficits are always easy news fodder, and the Congressional Budget Office’s deficit projections for the next 10 years are uncomfortably high by most measures. Government today is operating in a budget deficit lull, but the pace of deficit growth is predicted to increase again after 2018, and under the CBO’s baseline assumptions are projected to reach 4.9 percent of GDP in 2026.

But deficit projections convey less information than is generally understood, both because the assumptions underlying the projections abstract from realistic outcomes in various respects, and because deficits themselves are the net of two numbers, government revenues and government expenses. Are taxes too low, or government spending too high? Or are both too low relative to our needs?

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April 2, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Friday, April 1, 2016

19th Annual Critical Tax Theory Conference Kicks Off Today At Tulane

Tulane (2015)The 19th Annual Critical Tax Theory Conference kicks off today at Tulane:

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:  Tax Compliance and Tax Regime Design (Chair: Adam Rosenzweig (Washington University))

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April 1, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Pepperdine Symposium Today On The U.S. Vice Presidency

Great symposium today at Pepperdine on The U.S. Vice Presidency with several prominent speakers, including former Vice President Dick Cheney, former U.S. Attorney General Ed Meese, Illinois Dean Vik Amar, and Pepperdine's own former U.S. Ambassador Doug Kmiec and Pulitizer Prize-winning historian Ed Larson.  You can watch live here beginning at 9:00 a.m. PST. (Vice President Cheney is speaking from 9:15-10:15.)

Symposium

Throughout our history, the powers and responsibilities of the nation’s second highest office have evolved. Caustically described by its first occupant as “the most insignificant office” ever contrived, many vice presidents have now had a profound impact on their place and time. Yet from its original inception to the ratification of the Twelfth 12th Amendment and beyond, many questions continue to surround this office. What did the founders envision as the role of the vice president? What is its place in the constitutional framework of government? What were the special characteristics of notable vice presidents? What is the future of the vice presidency? Could the office serve as an important tool in ending government gridlock?

At this symposium, renowned legal scholars, practitioners, and politicians will explore important questions surrounding the vice presidency. As a special treat, the Honorable Richard Cheney, 46th Vice President of the United States, will join us for a lively discussion of these issues and other experiences from his time as Vice President.

April 1, 2016 in Conferences, Legal Education | Permalink | Comments (1)

Thursday, March 31, 2016

2016 Florida Tax Institute

Florida Tax InstituteThe two-day 2016 Florida Tax Institute (program), sponsored by the Florida Tax Education Foundation with all proceeds benefiting the University of Florida Graduate Tax Program, concludes today.  Tax Prof speakers include:

  • Karen Burke (Florida) & James Sowell (KPMG), Hot Asset Distributions and New Rules Under Section 751(b)
  • Sam Donaldson (Georgia State), Current Developments in the Transfer Tax Arena

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March 31, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Conference On The Fate Of Scholarship In American Law Schools

FateBaltimore hosts a two-day conference beginning today on The Fate of Scholarship in American Law Schools:

The conference will reexamine first principles of legal scholarship – its value (to legal education, to the legal profession, to society) and its essential aspects – and will survey particular issues of contemporary concern, including emerging scholarly forms and technologies and the relationship among legal scholarship, journalism and new media.

The two-day conference will consist of themed plenary sessions, concurrent small-group sessions, opportunities to interact informally and a keynote address by Jack M. Balkin, Knight Professor of Constitutional Law and the First Amendment at Yale Law School.

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March 31, 2016 in Conferences, Legal Education, Scholarship | Permalink | Comments (1)

Friday, March 18, 2016

Tax Notes Symposium:  The Future Of Tax Administration

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March 18, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, March 11, 2016

Tulane Hosts 6th Annual Tax Roundtable

TulaneTulane hosts its 6th 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), Evaluating the Economic Effects of Flat Tax Reforms Using Synthetic Control Methods (with Bibek Adhikari (Tulane))
Discussant:  Brian Galle (Georgetown)

Leigh Osofsky (Miami), Simplexity (with Joshua Blank (NYU))
Discussant:  Lawrence Zelenak (Duke)

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March 11, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)