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Wednesday, December 11, 2013

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

Pepperdine Tax Symposium Brochure_Page_1Please consider joining us for the Pepperdine/Tax Analysts Symposium on Tax Reform in a Time of Crisis on Friday, January 17, 2014 in Malibu, California:

Keynote Address:  Joseph Bankman (Stanford)
Introduction:  Paul Caron (Pepperdine)
Commentary:  Edward Kleinbard (USC)

Panel #1:  Individual/Estate and Gift Tax Reform
Moderator:  Tom Bost (Pepperdine)
Papers:  Dorothy Brown (Emory), Miranda Fleischer (San Diego), James Repetti (Boston College)
Commentary:  Nancy Staudt (USC)

Luncheon Address:  Bruce Bartlett (Former Deputy Assistant Secretary of the Treasury)

Panel #2:  Business/International Tax Reform
Moderator:  Khrista Johnson (Pepperdine)
Papers:  Karen Brown (George Washington), Ruth Mason (Virginia), Richard Winchester (Thomas Jefferson)
Commentary:  Eric Zolt (UCLA)

Panel #3:  Tax Reform in a Time of Crisis: Institutional Perspectives
Moderator:  Joe Thorndike (Tax Analysts)
Papers:  Ellen Aprill (Loyola-L.A.), Donald Tobin (Ohio State), George Yin (Virginia; former Chief of Staff, Joint Committee on Taxation)
Commentary:  Donald Korb (Partner, Sullivan & Cromwell; former IRS Chief Counsel)

Closing Remarks:  What Have We Learned Today?:  Robert Popovich (Pepperdine)

December 11, 2013 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

Tuesday, December 10, 2013

Prawsfest XI at Pepperdine

Pepperdine Law School (2013-2)I am delighted that Pepperdine is hosting Prawfsfest XI, thanks to the efforts of my friend and colleague Michael Helfand.  Here is the line-up of speakers and papers:

December 10, 2013 in Conferences, Scholarship | Permalink | Comments (0)

Friday, December 6, 2013

Valparaiso Hosts Second Annual Tax Roundtable Today

Valparaiso University Law School is hosting its second annual TaxValpo Logo Roundtable today:

  • Samuel Brunson (Loyola-Chicago), Taxing Utopia
  • Emily Cauble (DePaul), Safe Harbors in Tax Law
  • Andy Grewal (Iowa), Mixing Management Fee Waivers with Mayo, 15 Fla. Tax Rev. ___ (2014):
  • David Herzig (Valparaiso), Conforming Up: The Impracticability of Windsor
  • Adam Rosenzweig (Washington University), Defining a Country's Fair Share of Taxes
  • Del Wright, Jr. (Valparaiso), A Step Too Far: Congress' Overreaching and Ineffective Refund Penalty Legislation

December 6, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, November 27, 2013

Conference on Taxation, Transparency, Democracy and Development in São Paulo

SaoThe Center for Fiscal Studies at the Fundação Getúlio Vargas (FGV) (São Paulo, Brazil) host a two-day International Conference of the Center for Fiscal Studies on Taxation, Transparency, Democracy and Development: Building a Positive Agenda Between Treasury and Tax in São Paulo. The conference will address “the main themes of the current tax law from the perspective of building a positive agenda between Treasury and Tax.” The international keynote speakers are:

  • James Alm (Tulane), Paradigms of Tax Administration and Tax Planning
  • Joshua Blank (NYU), Tax Privacy as Tax Enforcement
  • Jeffrey Owens (WU Institute for Austrian and International Tax Law; former Director, Centre for Tax Policy and Administration, OECD), Opening Address

 Photo

Left to right: Eurico Marcos Diniz de Santi (FGV), Isaias Coelho (FGV), Joshua Blank (NYU), Jeffrey Owens (Vienna).

November 27, 2013 in Conferences, Tax | Permalink | Comments (1)

Friday, November 22, 2013

NTA Annual Conference on Taxation

NTA CoverThe National Tax Association 106th Annual Conference on Taxation continues today in Tampa. Tax Prof speakers include:

Abusive Tax Planning, Tax Aggressiveness, and Tax Penalties:

The Big Picture: Major Reforms and Tax Policy Discourse:

  • Daniel Shaviro (NYU) (Organizer and Moderator)
  • Jane Gravelle (Congressional Research Service) & G. Thomas Woodward (Woodward Farm), Clarifying the Relation Between Base-Broadening and Effective Marginal Tax Rates
  • Zachary Liscow (Yale), A Framework for Distribution through Legal Entitlements versus Taxes
  • Roberta Mann (Oregon), Economists Are from Mars, Lawyers Are from Venus: Communication Failure and the Implications for Tax Policy
  • Laurence Seidman (Delaware), Medicare for All: A Public Finance Analysis
  • Discussants:   G. Thomas Woodward (Woodward Farm), Daniel Shaviro (NYU)

Business Taxation: Managerial Incentives and Investment Decisions:

Formulary Approaches to International Taxation:

  • Kimberly Clausing (Reed College) (Organizer and Moderator)
  • Kimberly Clausing (Reed College), Lessons from the U.S. State Experience for International Tax Reform
  • Walter Hellerstein (Georgia), Designing the Limits of Formulary Income Attribution Regimes: Lessons from the Proposed CCCTB and the U.S. States
  • Susan Morse (Texas), The Transfer Pricing Regs Need a Good Edit
  • Discussants:  Chris Sanchirico (Penn), Ruud de Mooij (IMF), Stephen Shay (Harvard)

November 22, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, November 21, 2013

NTA 106th Annual Conference on Taxation

NTA CoverThe National Tax Association 106th Annual Conference on Taxation kicks off today in Tampa. Today's Tax Prof speakers include:

Behavioral Incentives, Tax Compliance, and Choice of Policy Instruments:

Corporate Taxation and Tax History:

Emprical Studies of the Nonprofit Sector:

Nineteenth and Twentieth Century Tax History:

Pathways to Tax Reform:

November 21, 2013 in Conferences, Poll, Tax | Permalink | Comments (0)

Saturday, November 16, 2013

Emory Hosts Southeastern Law Schools Junior-Senior Faculty Workshop

Emory LogoEmory Law School hosts the annual Southeastern Law Schools Junior-Senior Faculty Workshop today.  Tax Profs with speaking roles include:

November 16, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, November 15, 2013

Southwestern Hosts Class Crits VI: Debt, Austerity and the Possibilities of the Political

SW

The Southwestern Law Review hosts a two-day workshop beginning today on Class Crits VI: Stuck in Forward? Debt, Austerity and the Possibilities of the Political, with these tax and legal education panels:

Leveraging Tomorrow for Today With Debt, Austerity, and Taxes for the Masses:

Unequal Education

  • Sumi Cho (DePaul), The Impact of Austerity on Minority Faculty Members in Higher Education
  • Victoria Haneman (UNLV), The Impact of Student Loan Debt on Marriage and Childbearing
  • Lucy Jewel (Tennessee), Tales of a Fourth Tier Nothing: Class Bias in Legal Education Reform
  • Julie Nice (San Francisco), Reproducing Elitism in Legal Education
  • Terry Smith (DePaul), Austerity in Color: Minority Professors and the Transformation of Higher Education
  • Roman J. Hoyos (Southwestern) (moderator)

November 15, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, November 8, 2013

Widener Hosts Delaware Tax Institute Today

DelawareWidener hosts the 2013 Delaware Tax Institute today on After the Storm, Picking Up the Pieces: Healthcare, Portability, and Taxes.  John L. Buckley, former Chief Democratic Tax Counsel for the House Ways and Means Committee and former Chief of Staff for the Joint Committee on Taxation, delivers the keynote address.  Other topics include:

  • 2013 Income Tax Developments
  • Discussion of recent developments in Estate Planning
  • The Affordable Care Act—Implementing Health Ca re Reform in 2013 a nd 2014
  • Estate Planning for Couples After the 2012 Act and the DOMA Decision 

November 8, 2013 in Conferences, Tax | Permalink | Comments (0)

Wednesday, November 6, 2013

24th Annual Philadelphia Tax Conference

Friday, November 1, 2013

Florida Hosts 9th Annual International Taxation Symposium Today

Florida Logo (GIF)The University of Florida Graduate Tax Program hosts its Ninth Annual International Taxation Symposium today:

  • Michael S. Kirsch (Notre Dame), Revisiting The Tax Treatment of Citizens Abroad: Reconciling Principle And Practice (Commentator: Omri Marian (Florida))
  • Ekkehart Reimer (Ruprecht-Karls-Universität Heidelberg, Institut für Finanz- und Steuerrecht, Heidelberg, Germany), 5 + 7 = Odd: A Plea for More Consistency Between the PE Definition and Profit Allocation Rules in the OECD Model Tax Convention (Commentator: Yariv Brauner (Florida))
  • Stephen E. Shay (Harvard), Modernizing U.S. CFC Rules: A Minimum Tax to Limit Deferral (Commentator: Martin J. McMahon, Jr. (Florida))

November 1, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Elon Hosts Symposium Today on The Implications of Windsor and Perry

Elon Law Review LogoThe Elon Law Review hosts a symposium today on Implications of United States v. Windsor and Hollingsworth v. Perry for Family Law, Constitutional Law, Tax Law, and Society (program). Here is the tax panel:

Feds vs. States: Tax Changes with Windsor and Perry:  This panel will examine federal and state taxes under DOMA and how where you live may affect what and how you pay. It will also look at estate planning, inheritance taxes, and how Windsor and Perry are fueling heated tax debates

  • Andy Haile (Elon) (moderator)
  • Jennifer Bird-Pollan (Kentucky)
  • Patricia Cain (Santa Clara)
  • David Herzig (Valparaiso)

November 1, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Tax Analysts Hosts Conference Today on The Project to Rewrite UDITPA

UDITPATax Analysts hosts a roundtable discussion on The Project to Rewrite UDITPA: Does Model Legislation Have an Expiration Date? at the National Press Club in Washington, D.C. today at 9:00 - 11:00 a.m:

Please join us for a discussion of the Multistate Tax Commission's rewrite of the Uniform Division of Income for Tax Purposes Act:

  • Christopher E. Bergin (President and Publisher, Tax Analysts)
  • Shirley K. Sicilian (General Counsel, Multistate Tax Commission)
  • Prentiss Willson (Of Counsel, Sutherland Asbill & Brennan)
  • Richard Pomp (Alva P. Loiselle Professor of Law, University of Connecticut)
  • Arthur R. Rosen (Partner, McDermott Will & Emery)

November 1, 2013 in Conferences, Tax | Permalink | Comments (0)

Thursday, October 31, 2013

8th Annual Conference on Empirical Legal Studies at Penn

PennHere are the tax and legal education papers presented at last week's 8th Annual Conference on Empirical Legal Studies at Penn:

Tax:

Legal Education:

October 31, 2013 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

Friday, October 25, 2013

Seton Hall Hosts Symposium Today on Legal Education Looking Forward

 

SHThe Seton Hall Law Review hosts a symposium today on Legal Education Looking Forward.:

Is law school still economically viable? Should it last two years instead of three? Would increasing “skills classes” increase preparedness? Could an apprenticeship program or post-graduate “low bono” service clinic give students a means of building experience in a tough legal market? Do we need the bar exam?  

PhotoTax Prof participants include:

  • Joshua Blank (NYU), Adjusting the Curriculum
  • Dorothy Brown (Emory), Bold Approaches to Reform

The full program is here.

Photo:  Tax Profs Joshua Blank (NYU), Tracy Kaye (Seton Hall), Dorothy Brown (Emory).

October 25, 2013 in Conferences, Legal Education | Permalink | Comments (0)

Thursday, October 24, 2013

9th Annual USD-Procopio International Tax Law Institute

Wednesday, October 23, 2013

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

2014TaxSaveTheDatePlease consider joining us for the Pepperdine/Tax Analysts Symposium on Tax Reform in a Time of Crisis on Friday, January 17, 2014 in Malibu, California:

Keynote Address:  Joseph Bankman (Stanford)
Introduction:  Paul Caron (Pepperdine)
Commentary:  Edward Kleinbard (USC)

Panel #1:  Individual/Estate and Gift Tax Reform
Moderator:  Tom Bost (Pepperdine)
Papers:  Dorothy Brown (Emory), Miranda Fleischer (San Diego), James Repetti (Boston College)
Commentary:  Nancy Staudt (USC)

Luncheon Address:  Bruce Bartlett (Former Deputy Assistant Secretary of the Treasury)

Panel #2:  Business/International Tax Reform
Moderator:  Khrista Johnson (Pepperdine)
Papers:  Karen Brown (George Washington), Ruth Mason (Virginia), Richard Winchester (Thomas Jefferson)
Commentary:  Eric Zolt (UCLA)

Panel #3:  Tax Reform in a Time of Crisis: Institutional Perspectives
Moderator:  Joe Thorndike (Tax Analysts)
Papers:  Ellen Aprill (Loyola-L.A.), Donald Tobin (Ohio State), George Yin (Virginia; former Chief of Staff, Joint Committee on Taxation)
Commentary:  Donald Korb (Partner, Sullivan & Cromwell; former IRS Chief Counsel)

Closing Remarks:  What Have We Learned Today?:  Robert Popovich (Pepperdine)

October 23, 2013 in Conferences, Legal Education, Scholarship, Tax, Tax Analysts | Permalink | Comments (0)

Tuesday, October 22, 2013

NYU Hosts Meet the Tax Press Today

NYU Logo (2013)NYU hosts Meet the Tax Press today:

Please join us for a discussion with Zach Carter (Huffington Post), Jia Lynn Yang (Washington Post) and Reihan Salam (National Review), three reporters who cover tax stories. The panel will discuss what makes a great “tax story”, the sources of information for tax stories, why certain tax issues are often misreported in the press and, of course, tax issues in the ongoing budget debate. Professor Erin Scharff will moderate the discussion.

October 22, 2013 in Conferences, Tax | Permalink | Comments (0)

Friday, October 18, 2013

3rd Annual NYU/UCLA Tax Policy Symposium: Politics and Taxation

NYU UCLAThe Third Annual NYU/UCLA Tax Policy Symposium, Politics and Taxation, takes place today at UCLA:

Paper #1:  Mitt Romney, the 47 Percent, and the Future of the Mass Income Tax

  • Deborah Schenk (NYU) (presenting paper by Larry Zelenak (Duke)
  • Commentators: Alan Auerbach (UC-Berkeley), Daniel Shaviro (NYU)

Paper #2:  Cheating on Their Taxes: Are Tax Limitation Initiatives Effective at Limiting Taxes?

  • Mathew D. McCubbins (Duke)
  • Commentators: Joel D. Aberbach (UCLA), Kirk Stark (UCLA)

Paper #3:  Tax Legislation in the Contemporary U.S. Congress

  • Michael Doran (Georgetown)
  • Commentators:  Victor Fleischer (San Diego), Jason Oh (UCLA)

Paper #4:  Tax Attitudes in the Obama Era

  • Andrea Louise Campbell (MIT)
  • Commentators:  Jeffrey B. Lewis (UCLA), Edward McCaffery (USC)

October 18, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, October 17, 2013

39th Annual Notre Dame Tax & Estate Planning Institute

ND_TaxEstate_Oct2013_booklet_Page_1The 39th Annual Notre Dame Tax & Estate Planning Institute kicks off today. Tax Prof speakers include:

  • Gerry Beyer (Texas Tech), An Estate Planning Trilogy: Digital Assets, Guns and Pets
  • Larry Frolik (Pittsburgh), Monitoring Trustees: When, Why and How to Use a Trust Protector
  • David Herzig (Valparaiso), Evaluating Mistakes Made With Commonly-Used Techniques (The Screw-ups) And Evaluating e Risks Associated With Certain Techniques
  • William LaPiana (New York Law School), It’s Yours If You Do as I Say: Conditional Gifts and In Terrorem Clauses
  • Jeffrey Pennell (Emory), Myths, Mysteries and Mistakes: Common Transfer Tax Concepts That Are Not Well-Known or Understood
  • Jeffrey Schoenblum (Vanderbilt), Using DINGs, NINGs and Other Trusts to Reduce or Eliminate State Income Taxes

October 17, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Saturday, October 12, 2013

Midwestern Law & Economics Association Annual Meeting at Illinois

Illinois LogoThe 12th Annual Midwestern Law & Economics Association Annual Meeting concludes today at Illinois with these tax and legal education papers:

Tax:

  • Victor Fleischer (San Diego), The Inferiority of Pigouvian Taxes
  • Ajay K. Mehrotra (Indiana-Bloomington) & Steve Bank (UCLA), Corporate Taxation and the Regulation of Modern Business

Legal Education:

  • Michael Alexeev (Indiana-Bloomington) & Jeffrey E. Stake (Indiana-Bloomington), Who Responds to U.S. News & World Report’s Law School Rankings?
  • Nicholas L. Georgakopoulos (Indiana-Indianapolis), Bar Passage: GPA and LSAT, not Bar Reviews

October 12, 2013 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

Friday, October 11, 2013

Midwestern Law & Economics Association Annual Meeting at Illinois

Illinois LogoThe 12th Annual Midwestern Law & Economics Association Annual Meeting kicks off today at Illinois with this tax panel:

October 11, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, October 4, 2013

University of Washington Hosts 2013 Tax Symposium Today

UW 3The University of Washington hosts the 2013 Tax Symposium today:

Panel #1:  Multiple Purposes of the Tax System

  • Deborah H. Schenk (NYU) (moderator)
  • Miranda Perry Fleischer (San Diego), Charity, Poverty and Duty
  • Kristin E. Hickman (Minnesota), Administering the Tax System We Have
  • Nancy Staudt (USC), Taxing Guns

Panel #2:  Taxpayer Ethics, Citizenship and Compliance

  • Jasper Smith (Tax Analysts) (moderator)
  • Joshua D. Blank (NYU), Collateral Compliance, 162 U. Pa. L. Rev. ___ (2013)
  • Michelle L. Drumbl (Washington & Lee), When Helpers Hurt: Protecting Taxpayers from their Return Preparers
  • Lawrence A. Zelenak (Duke), Taxpaying and Fiscal Citizenship

Panel #3:  IRS Duties and Discretion

  • Ilesa McAuliffe (University of Washington) (moderator)
  • Steve R. Johnson (Florida State), Can Taxpayers and Their Advisors Rely on Favorable IRS Guidance? What Happens when the IRS's Responsibilities to Particular Taxpayers Clash with Its Responsibilities to the System as a Whole?
  • Lily Kahng (Seattle), IRS Administrative Discretion: Uses and Abuses

Panel #4:  Avoidance, Ethics, and International Perspectives

  • Shannon McCormack (University of Washington) (moderator)
  • David Duff (British Columbia), Departure Trades and Offshore Trust Arrangements: Reflections on the Tax Avoidance Industry in Canada
  • Shu-Yi Oei (Tulane), The Ethics of Taxing Exits

Panel #5:  Tax Professions and Professional Responsibility

Panel #6:  Duties and Regulation

  • Scott Schumacher (University of Washington) (moderator)
  • Heather M. Field (UC-Hastings), Aggressive Tax Planning and the Ethical Tax Lawyer
  • Michael Hatfield (Texas Tech), Legal Ethics and Tax Advice, 1965-1985, 14 Fla Tax Rev. ___ (2014)
  • Michael Lang (Chapman), Can the IRS Effectively Regulate the Quality of Tax Planning Advice?
  • Richard Lavoie (Akron), Vox Clamantis in Deserto: The Role of the Individual in Forging a Strong Duty to the Tax System

October 4, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

New York Law School Hosts Symposium Today on The 100th Anniversary of the Income Tax

NYLSThe New York Law School Law Review hosts a symposium today on The 100th Anniversary of the Revenue Act of 1913: Marking a Century of Income Tax Law in the United States:

On October 3, 1913, President Woodrow Wilson signed into law the Revenue Act of 1913. This symposium and the companion Law Review issue will examine a century of change and continuity in federal income tax law, tax policy, and the practice of tax law, highlighting the pressing technical and policy issues that are yet to be resolved.

Keynote Address:  Edward Kleinbard (USC)

Panel #1:  Withholding and Information Reporting from 1913 to FATCA

  • Ann F. Thomas (New York Law School) (Chair)
  • Alan Appel (New York Law School)
  • Valeriya Avdeev (William Paterson University, College of Business)
  • Michael Hirschfeld (Dechert, New York)
  • Lee A. Sheppard (Tax Analysts)

Panel #2:  Debt, Taxes and the Economy

  • Richard Beck (New York Law School) (Chair)
  • Diane Fahey (New York Law School)
  • Maria Pirrone (St. John’s)
  • Dennis Ventry (UC-Davis)

Panel #3:  U.S. Tax Policy in a Global Economy

  • Reuven Avi-Yonah (Michigan) (Chair)
  • Peter H. Blessing (KPMG, New York)
  • Diane Ring (Boston College)
  • Fadi Shaheen (Rutgers-Newark)

Panel#4:  Perspectives on the Practice of Tax Law

  • William LaPiana (New York Law School) (Chair)
  • Megan Brackney (Kostelanetz & Fink, New York)
  • Elizabeth Kessenides (Berdon, New York)
  • Michael L. Schler (Cravath, Swaine & Moore, New York) LLP

Closing Keynote Address:  Stephen E. Shay (Harvard)

October 4, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Saturday, September 28, 2013

Oklahoma City Hosts Conference Today on Wills, Trusts & Estates Meets Gender, Race & Class

OCUOklahoma City University School of Law hosts a conference today on Wills, Trusts & Estates Meets Gender, Race & Class:

[The conference] will bring the insights of progressive property theory to the area of inheritance and succession law and will address the many points of intersection between inheritance law, gender and race, social structure, wealth inequality, domestic violence, and indigenous people’s rights, among others. Recognizing that inheritance law is a society’s DNA, the conference will present both theoretical, historical and practical approaches to ways it has and continues to maintain social structure and ways it can change it.

  • Keynote Address:  Al Brophy (North Carolina), Commentator: William P. LaPiana (New York Law School)
  • Panel #1:  A Critical Trusts and Estates Research Agenda:  Anthony Infanti (Pittsburgh), Bridget Crawford (Pace)
  • Panel #2:  Class Matters:  Naomi Cahn (George Washington), Phyllis Smith (Florida A&M), Palma Strand (Creighton), Lee-Ford Tritt (Florida)
  • Panel #3:  Past and Present:  Steven Clowney (Kentucky), Stuart Gold (Partner, Mandelbaum Salsburg, West Orange, NJ), Casey Ross-Petherick (Oklahoma City), Kent Schenkel (New England)
  • Panel #4:  Formalities and Language:  Deborah Gordon (Drexel), Anne Marie Rhodes (Loyola-Chicago), Karen Sneddon (Mercer),
  • Panel #5:  Families and the Home:  Shelly Kreiczer-Levy (Academic Center of Law and Business, Tel Aviv, Israel), Browne Lewis (Cleveland State), Alan Oxford (Appalachian), Danaya Wright (Florida)

September 28, 2013 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (1)

Friday, September 27, 2013

Tax Analysts Hosts Conference Today on Private Equity as a Trade or Business: The Sun Capital Decision

Tax AnalystsTax Analysts hosts a roundtable discussion on Private Equity as a Trade or Business: The Sun Capital Decision at the National Press Club in Washington, D.C. today at 3:00 - 5:00 p.m. EST:

Please join us for a roundtable discussion in which we will debate the tax implications of the "trade or business" analysis in the recent Sun Capital court decision.

  • Christopher E. Bergin (President and Publisher, Tax Analysts)
  • Patrick B. Fenn (Partner, Akin Gump Strauss Hauer & Feld, Washington, D.C.)
  • John C. Hart (Partner, Simpson Thacher & Bartlett, New York)
  • Steven M. Rosenthal (Visiting Fellow, Urban-Brookings Tax Policy Center)
  • Stephen E. Shay (Professor of Practice, Harvard Law School)
  • Lee A. Sheppard (Contributing Editor, Tax Analysts)

September 27, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Villanova Hosts Symposium Today on Selective Issues in Tax Administration

Villanova Law LogoThe Villanova Law Review hosts a symposium today on Selective Issues in Tax Administration:

Introductory Remarks:  Joy Mullane (Villanova)

Panel #1:  The Increasing Importance of the Whistleblower Provisions in U.S. Tax Administration

  • J. Richard “Dick” Harvey (Villanova) (moderator)
  • Jeremiah Coder (Greenberg Traurig, McLean, VA)
  • Dennis J. Ventry, Jr. (UC-Davis)
  • Dean A. Zerbe (Zerbe, Fingeret, Frank & Jadav; Counsel to National Whistleblower's Center)

Panel #2:  The IRS’s Efforts to Regulate Unlicensed Tax Return Preparers

  • Leslie Book (Villanova) (moderator)
  • Dan Alban (Institute for Justice)
  • Michelle L. Drumbl (Washington & Lee)
  • Lawrence B. Gibbs (Miller Chevalier, Washington, D.C.)
  • Steve R. Johnson (Florida State)

Keynote Address:  Kathryn Keneally (Assistant Attorney General (Tax), U.S. Department of Justice), The View From the Department of Justice

Panel #3:  Criminal Tax Sentencing: Fairness and Deterrence

  • Peter Hardy (Post & Schell, Pittsburgh) (moderator)
  • Steve Chanenson (Villanova)
  • Caroline D. Ciraolo ( Rosenberg Martin Greenberg, Pittsburgh)
  • Kathryn Keneally (Assistant Attorney General (Tax), U.S. Department of Justice)
  • Scott Schumacher (University of Washington)
  • John Townsend (Townsend & Jones, Houston)

September 27, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, September 23, 2013

Call for Tax Papers and Panels: SEALS Annual Conference

SEALs Logo (2013)From Jennifer Bird-Pollan (Kentucky):

For the past few years we have had a sizable contingency of tax scholars at the annual SEALS conference [e.g., 2010, 2011, 2012 (here, here, here), and 2013 (here, here, here, here)], including a lively discussion group on general tax policy subjects. Submissions for the 2014 conference (which will be held from August 1-7 in Amelia Island, Florida) are now open. I would be happy to coordinate panels and discussion groups, based on people's proposed topics. In general, the panels have about four presenters, and the discussion groups have about ten participants. If you are interested in presenting in either format, if you send me an email with your tentative topic, the name of your law school, and whether or not your law school is a SEALS member, I'd be happy to compose panels made up of interested folks. In order to make our submissions in a timely manner, please let me know by Tuesday, October 1 if you are interested in participating.

September 23, 2013 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

Saturday, September 21, 2013

ABA Tax Section Fall CLE Meeting

ABA Tax Section Logo (2012)The ABA Tax Section concludes its Joint Fall CLE Meeting with the ABA Real Property, Trust and Estate Law Section today in San Francisco. The full program is here.  Tax Profs with speaking roles today include:

  • Corporate Tax:  Michelle Kwon (Tennessee)
  • Employee Benefits:  Kathryn Kennedy (John Marshall)
  • Pro Bono & Tax Clinics:  Leslie Book (Villanova), Patricia Cain (Santa Clara), Tony Infanti (Pittsburgh), George Willis (Chapman)
  • Sales, Exchanges & Basis:  Howard Abrams (San Diego), Bradley Borden (Brooklyn), Erik Jensen (Case Western)
  • Section Luncheon & Plenary Session:  From Tax Reform to Fiscal Soundness:  Alan Auerbach (UC-Berkeley), Ed Kleinbard (USC), Ann Thomas (New York Law School)
  • Section Program: Hot Practice Tips for Representing an Individual Taxpayer:  Stephen Black (Texas Tech)

September 21, 2013 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0)

Friday, September 20, 2013

ABA Tax Section Fall CLE Meeting

ABA Tax Section Logo (2012)The ABA Tax Section continues its Joint Fall CLE Meeting with the ABA Real Property, Trust and Estate Law Section today in San Francisco. The full program is here.  Tax Profs with speaking roles today include:

  • Diversity:  Patricia Cain (Santa Clara)
  • Exempt Organizations:  Christopher Hoyt (UMKC), Elaine Wilson (West Virginia)
  • Insurance Companies:  Patricia Cain (Santa Clara)
  • Partnerships & LLCs:  Don Leatherman (Tennessee), George Yin (Virginia)
  • Publications:  Alice Abreu (Temple)
  • Real Estate:  Howard Abrams (San Diego)
  • S Corporations:  Christopher Hoyt (UMKC), Robert Morrow (Chapman)
  • Standards of Tax Practice:  Linda Beale (Wayne State), Richard Lavoie (Akron)
  • Tax Policy & Simplification:  Alan Auerbach (UC-Berkeley), Jordan Barry (San Diego), Linda Beale (Wayne State), Jonathan Forman (Oklahoma), David Gamage (UC-Berkeley), Roberta Mann (Oregon), Alex Raskolnikov (Columbia)
  • Tax Practice Management:  Michael Lang (Chapman)
  • Teaching Taxation:  David Cameron (Northwestern), Danshera Cords (Albany), Shu-Yi Oei (Tulane), Nancy Shurtz (Oregon)
  • U.S. Activities of Foreigners & Tax Treaties: Patricia Brown (Miami)

September 20, 2013 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0)

Thursday, September 19, 2013

Call for Tax Papers and Panels: Law & Society Annual Meeting

Law & Society (2013)Neil H. Buchanan (George Washington) has issued his annual call for tax papers and panels for next year's annual meeting of the Law & Society Association in Minneapolis (May 29-June 1, 2014):

For the tenth consecutive year (wow, we're all getting old!), I will organize sessions for the Law, Society, and Taxation group (Collaborative Research Network 31).

The good news is that Law & Society has finally upgraded their online system, which will significantly simplify the process of submitting proposals this year. The only bad news is that the deadline has been moved up by two months.

Although there is an official call for papers, please remember that you are not bound by the official theme of the conference. I will give full consideration to proposals in any area of tax law, tax policy, distributive justice, interdisciplinary approaches to tax issues, and so on.

To submit a proposal, you should start at this page. The instructions on that page are admirably clear and succinct. Please create a profile, and then submit a paper proposal by following the instructions.

After all of the proposals have been submitted online, I will organize papers with common themes into full sessions. To give me enough time to do that, you need to submit your proposals at least one week before the official deadline for submissions. Therefore, please submit your proposals by Tuesday, October 8, 2013.

For your proposal to be included among the tax panels that I will create, you need to do two extra things:

1. Put "CRN31:" at the beginning of your paper title. For example, if your paper title is "Why Tax Law Is the Most Interesting Subject Ever," please submit the title "CRN31: Why Tax Law Is the Most Interesting Subject Ever."

2. When you have finished your submission, you will receive an email with the subject line: "LSA 2014 - Paper Submission has been received." Please forward that email to me.

Your paper need not yet be written, and the only requirement is that you have at least something (an outline, a first draft, etc.) that can be sent to your session chair by about 30 days before the meetings (early May).

Note also that each participant is limited to ONE participation as a Paper Presenter OR a Roundtable Participant. (You will also be able to act as a chair and/or discussant in two sessions, which I will determine later.)

September 19, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, September 18, 2013

Hudson Institute Hosts Program Today on IRS + 501(c)(4) = SOS?

HudsonThe Hudson Institute hosts a program today on IRS + 501(c)(4) = SOS?:

“So I guess my bottom line here is that we at the IRS should apologize for that, it was not intentional, and as soon as we found out what was going on, we took steps to make it better and I don’t expect that to reoccur.” So stated director of the IRS Exempt Organizations division Lois Lerner last May 10, as she explained to a meeting of the American Bar Association that her employees had singled out for extended examination scores of applicants for 501(c)(4) status that “used names like Tea Party or Patriots and they selected cases simply because the applications had those names in the title.”

“That was wrong, that was absolutely incorrect, insensitive, and inappropriate,” she concluded.

If she had hoped that her admission would enable the IRS to “get out in front” of negative publicity, she must have been disappointed, because within days, and after a very critical review of IRS practices by its own Inspector General, the IRS was embroiled in a controversy that has yet to subside.

Was this merely a case of bureaucratic bungling, as Lerner suggested? Or was the IRS deliberately targeting groups known to be unfriendly to the Obama Administration, as others have argued? Does this episode point to larger, institutional deficiencies that require substantial revisions in the way we understand the 501(c)(4) designation, and the limits on political activity in which such organizations may engage?

These and other questions will be addressed on September 18th by our expert panel, including John Pomeranz of Harmon, Curran, Spielberg & Eisenberg and a key participant in the Bright Lines project; Cleta Mitchell, partner at Foley & Lardner, who has filed a lawsuit in federal court challenging the IRS actions; and Marcus Owens of Caplin & Drysdale and former director of the IRS Exempt Organizations Division. Hudson Institute's William Schambra will moderate the discussion. ...

Required Readings:

September 18, 2013 in Conferences, Tax | Permalink | Comments (0)

FBA Tax Section & Fordham Host Program Today on The Taxation of Intangibles

FBAThe Federal Bar Association Section on Taxation, in conjunction with the Fordham Law School Corporate Law Center, is pleased to present a panel discussion on Recent Developments in the Taxation of Intangibles:

The panelists will focus on recent proposals by the Obama Administration and the OECD on base erosion and profit shifting.

  • Marc M. Lewis (Vice President of Tax and Insurance, Novartis)
  • Karen Milhoua Director (Transfer Pricing, IBM)
  • Stanley Sherwood (International Tax Counsel, Kering)
  • Brian Power (Mayer Brown) (moderator)

September 18, 2013 in Conferences, Tax | Permalink | Comments (0)

Tuesday, September 17, 2013

AEI Hosts Program Today on Senator Lee's Tax Reform Plan

AEI LogoThe American Enterprise Institute hosts a forum today on Tax Reform, the Family, and the Pursuit of Happiness: A New Plan by Senator Mike Lee:

Join us for an AEI event featuring Senator Mike Lee (R-UT), who will present a new tax reform plan that seeks to restore middle-class opportunity and promote the upward mobility of working families. In addition to lowering rates and eliminating distortive loopholes, Senator Lee’s plan provides parents with relief from the unfair tax treatment they receive for their investment in their children.

Senator Lee’s remarks will be followed by a question-and-answer period and a panel discussion in which experts with varying views will review the plan’s policy implications.

Introduction: Arthur C. Brooks
Remarks:  Senator Mike Lee
Discussion:  Alex Brill, Elaine Maag, Ramesh Ponnuru, W. Bradford Wilcox, Alan D. Viard

September 17, 2013 in Conferences, Congressional News, Tax | Permalink | Comments (0)

Tuesday, September 10, 2013

Michigan Hosts Conference Today on The Federal Income Tax at 100

Michigan Ross LogoThe IRS Office of Tax Policy Research, National Tax Association, and Tax Policy Center host a program today on The Federal Income Tax at 100: How Did We Get Here and Where Should We Go Next? A Forum of Tax Policy Experts and Tax Policy Makers:

Welcome & Opening Remarks
Len Burman (Director, Tax Policy Center)

Introduction and Preview of Survey Results
Diane Lim (The Pew Charitable Trusts and President, National Tax Association)
Joel Slemrod (University of Michigan)

PART I. HOW DID WE GET HERE?

Session 1. The Evolution of the Current Income Tax
Joseph Thorndike (Tax Analysts), The Income Tax Through the End of World War II
Eugene Steuerle (Tax Policy Center), Post-War Up to the Tax Reform Act of 1986
Bruce Bartlett (Columnist), Life After the Tax Reform Act of 1986

PART II. WHERE SHOULD WE GO NEXT?

Session 2. The Fiscal Trilemma: Tax Reform and Deficit Reduction, Economic Growth, and Income Inequality
Maya MacGuineas (Committee for a Responsible Federal Budget)
Robert Greenstein (Center on Budget and Policy Priorities)
Leonard Burman (Tax Policy Center)
Donald Marron (Tax Policy Center)

Session 3. Replacing or Supplementing the Income Tax With Consumption Taxes
Robert Carroll (Ernst & Young) & Alan Viard (American Enterprise Institute), Substitution of a Consumption Tax
Michael Graetz (Columbia), Value-Added Tax as Add-on or Partial Replacement
Adele Morris (Tax Policy Center), Carbon Tax or Other Energy/Environmental Taxes

Session 4. Reforming the Existing Income Tax
William Gale (Tax Policy Center), Reform of Capital Income Taxation
Daniel Shaviro (NYU), Corporate/International Tax Reform
Eric Toder (Tax Policy Center), Alternatives for Limiting Tax Expenditures
Joel Slemrod (Michigan), Simplification Options

PART III. WHAT DO PEOPLE WANT?

Session 5. Expert and General Public Opinions
Diane Lim (Pew Charitable Trusts)
Joel Slemrod (Michigan)
Karlyn Bowman (American Enterprise Institute)

September 10, 2013 in Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Thursday, August 29, 2013

Call for Proposals: Tax Law and Love

Pepperdine Campus PhotoThe Herbert and Elinor Nootbaar Institute on Law, Religion and Ethics at Pepperdine has issued a Call for Proposals on Love and Law: "What would law be like if we organized it around the value of Christian love [agape]?" at Pepperdine on Feb. 7-8, 2014:

In a provocative essay, philosopher Jeffrie Murphy asks the question which serves as the subtitle of this conference: "What would law be like if we organized it around the value of Christian love [agape]?" Analogous questions arise within other theological and moral traditions. What would be the implications for the substance of law and for the practice of law? Join us for the conversation. The following speakers are already confirmed:

  • Barbara Armacost (Virginia), Restorative Justice
  • Stephen Bainbridge (UCLA), The Relevance of Agape to Fiduciary Duties, If Any
  • Patrick Brennan (Villanova), Love, Justice, and Polity in Catholic Social Doctrine
  • Zachary Calo (Valparaiso), Sacralizing Law? Political Forgiveness and Liberal Justice
  • Charles Mathewes (Virginia), Be Instructed, All You Who Judge the Earth: The Dialectic of Law and Love During the World in Psalm 2:10 and Augustine
  • Richard Mouw (Fuller Theological Seminary), Calvin, Law, and Love
  • Jeffrie Murphy (Arizona State), Law Like Love: Does Love Require the Abandonment of Punishment?
  • Joel A. Nichols (St. Thomas), Love, Indeterminacy, and Family Law
  • Ellen Pryor (UNT Dallas), Agape and Legal Education
  • Meghan J. Ryan (SMU), Dignity and Rehabilitation
  • Chaim Saiman (Villanova), Law As Love: A View From the Talmud
  • Michael Scaperlanda (Oklahoma), Love, Law, and the Immigrant
  • Varun Soni (USC), Love as Law: From Dharma to Kama
  • Najeeba Syeed-Miller (Claremont), Humanizing Legal Systems: Exploring the Capacity for a Humane Approach to Justice from a Muslim Perspective
  • Amy Uelmen (Georgetown), Love, Obligation, and the Common Law No Duty to Rescue
  • David VanDrunen (Westminster Seminary), Why Christian Love Is an Improper Category to Apply to Civil Law: A Contrarian Perspective
  • Robert K. Vischer (St. Thomas), Is Agape the Last, Best Hope for the Legal Profession?
  • James Boyd White (Michigan), Agape: the Activity of Reframing

If you would like to present a paper or organize a panel, please submit your proposal by September 13, 2013 via email. Proposals should include a short abstract and bio (one page total). Speakers will be arranged into panels and will have 12-15 minutes to present. Unfortunately, we are unable to assist with funding. If you have questions about the substance of the conference, contact Bob Cochran.

August 29, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Monday, August 19, 2013

Aspiring Law Profs Conference

AspiringArizona State is hosting the 5th Annual Aspiring Law Professors Conference on September 28:

Designed for Visiting Assistant Professors, Fellows and others who plan to go on the academic teaching market, but valuable to anyone considering a career as a law professor.

  • Learn to succeed in the entry-level law teaching market
  • Obtain an insiders perspective on the appointments process from faculty with extensive hiring experience
  • Participate in a mock interview or mock job talk and gain feedback from law professors

Delivering this year’s keynote address is Christine Hurt, Illinois law professor ...  The Aspiring Law Professors’ Conference is being offered free of charge to all attendees ... [F]or former attendees who are now teaching, please email Doug Sylvester—we are interested in hearing your stories and, if you are interested, having you come and help educate the next generation of potential scholars.

August 19, 2013 in Conferences, Legal Education | Permalink | Comments (1) | TrackBack (0)

Friday, August 9, 2013

Tax Panel Today at SEALS

SEALs Logo (2013)The Southeastern Association of Law Schools 2013 Annual Conference continues today at The Breakers in Palm Beach, FL with this tax panel:

Workshop on Taxation
Estate and Gift Tax in 2013 and Beyond

This panel will address the future of the transfer tax regime within the United States Internal Revenue Code. Because so many of the current estate and gift tax provisions were set to expire at the end of 2012, 2013 brings great opportunities to examine the future of the transfer tax, as well as possible reforms to improve its effectiveness. These presentations will range from a theoretical examination of the foundational principles of the estate tax, to an examination of specific elements of the tax, and suggestions for improving them.

  • Steven Morrison (North Dakota) (moderator)
  • Jennifer Bird-Pollan (Kentucky)
  • Don Castleman (Wake Forest)
  • Joseph Dodge (Florida State)
  • Brant Hellwig (Washington & Lee)

August 9, 2013 in Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Thursday, August 8, 2013

Tax Panel Today at SEALS

SEALs Logo (2013)The Southeastern Association of Law Schools 2013 Annual Conference continues today at The Breakers in Palm Beach, FL with this tax panel:

Workshop on Taxation
Discussion Group: Tax Policy Discussion Group

This discussion group is broadly concerned with issues of taxation. Discussants will address individual income tax, corporate income tax, state & local tax, estate & gift tax, tax expenditure policy, international tax and entitlements. While these disparate themes might seem only loosely related, a common thread of the difficulties of balancing equity, simplicity, incentives and transparency runs through all of them. These scholars will grapple with the central tax topics of the day, and address the looming concerns that must be dealt with by all levels of government.

  • Jennifer Bird-Pollan (Kentucky) (moderator)
  • Neil Buchanan (George Washington)
  • Don Castleman (Wake Forest)
  • Tessa Davis (Tulane)
  • Brant Hellwig (Washington & Lee)
  • David Herzig (Valparaiso)
  • Francine Lipman (UNLV)
  • Charlene Luke (Florida)
  • Omri Marian (Florida)
  • Kathryn Moore (Kentucky)
  • Christopher Pietruszkiewicz (Dean, Stetson)
  • Gregg Polsky (North Carolina)
  • Phyllis Smith (Florida A&M)
  • Donald Tobin (Ohio State)
  • Patrick Tolan (Barry)

August 8, 2013 in Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Tuesday, August 6, 2013

Tax Panel Today at SEALS

SEALs Logo (2013)The Southeastern Association of Law Schools 2013 Annual Conference continues today at The Breakers in Palm Beach, FL with this tax panel:

Workshop on Taxation
Social Engineering and the Tax Code: A Record of Success?

The U.S. Treasury publishes an annual “tax expenditure” budget highlighting the money spent through the tax code on all sorts of activity. One can think of this function of the tax code as social engineering. This panel will look at the record of success of the tax code and the estate and gift tax subtitles in social engineering on a diverse group of subject matters such as health care, charity, business activities and redistribution of wealth. The panel will consider what types of tax rules work from a social standpoint and why some others may not, how the judiciary views such spending, and whether the tax code is the best place to accomplish such social goals.

  • Tessa Davis (Tulane) (moderator)
  • Bobby Dexter (Chapman)
  • Philip Hackney (LSU)
  • Phyllis Smith (Florida A&M)
  • Del Wright (Valparaiso)

August 6, 2013 in Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Monday, August 5, 2013

Tax Panel Today at SEALS

SEALs Logo (2013)The Southeastern Association of Law Schools 2013 Annual Conference continues today at The Breakers in Palm Beach, FL with this tax panel:

Workshop on Taxation and Administrative Law
Perspectives on Tax Enforcement, Collections, and Compliance

This panel addresses the question of how regulatory, administrative, and tax collections procedures should be designed in order to achieve desired tax compliance results. The panelists will present multiple perspectives on tax collections and compliance matters, drawing upon insights from economics, criminal enforcement, financial regulation, and bankruptcy scholarship. Issues to be discussed include: What level of tax compliance is desirable? How should tax compliance and enforcement rules be designed, given limited resources and in the light of taxpayer behaviors? What role can disclosure play in regulating investor and taxpayer behavior and in generating compliance? To what degree should tax compliance be demanded in cases of taxpayer financial distress or insolvency?

  • Leandra Lederman (Indiana)
  • Omri Marian (Florida)
  • Shu-Yi Oei (Tulane)
  • Leigh Osofsky (Miami)

August 5, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Wednesday, July 24, 2013

Call for Papers: NYLS Symposium on The 100th Anniversary of the Income Tax

NYLS Logo (2013)The New York Law School Law Review has issued a call for papers for its October 4, 2013 symposium, The 100th Anniversary of the Revenue Act of 1913: Marking a Century of Income Tax Law in the United States:

On October 3, 1913, President Woodrow Wilson signed into law the Revenue Act of 1913. This symposium and the companion Law Review issue will examine a century of change and continuity in federal income tax law, tax policy, and the practice of tax law, highlighting the pressing technical and policy issues that are yet to be resolved. Prominent tax practitioners, policymakers, and scholars will discuss timely and emerging issues in the field. The event is being organized by the Law Review and the Graduate Tax Program at New York Law School. The symposium chair is Ann F. Thomas, Otto L. Walter Distinguished Professor of Tax Law at New York Law School.

The Law Review is currently accepting abstracts for papers to be considered for publication in fall 2014. Included below is a list of topics expected to be addressed at the symposium by prominent tax practitioners, scholars, and policymakers. The Law Review will also consider papers on other topics relating to the theme of the symposium.

  • Panel I:  Withholding and Information Reporting from 1913 to FATCA
  • Panel II:  Debt, Taxes, and the Economy
  • Panel III:  U.S. Tax Policy in a Global Economy
  • Panel IV:  Perspectives on the Practice of Tax Law (including tax attorneys’ professional and ethical responsibilities and the provision of pro bono legal services)

To be considered for publication, please send by September 3, 2013, an abstract of no more than 500 words and CV to Editor-in-Chief G. William Bartholomew.

July 24, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Monday, July 15, 2013

UConn Symposium: Are Law Schools Passing the Bar?

FBA Tax Section Hosts Program Today on Windsor and Wells Fargo

FBA The Federal Bar Association Section on Taxation Practice and Procedure Discussion Group hosts a program today:

Windsor and the Defense of Marriage Act: What It Means for Tax Lawyers:  We have all read press accounts of the U.S. Supreme Court’s decision in Windsor, which held the Defense of Marriage Act unconstitutional. What has been the subject of less reporting is the fact that the case arose in the context of tax law issues. In fact, issues regarding the status of same-sex marriages will arise in many different areas of tax law. Our discussion will briefly summarize the Supreme Court’s decision and then bring together specialists from several different specialties with the tax law (estate tax, employee benefits, income tax) to begin identifying and analyzing the myriad legal issues which will arise for tax lawyers. 

  • John Boyd (Baker Hostetler)
  • Lillian Gonzalez (Gonzalez & Associates)
  • Chad Makuch (Baker Hostetler)

Tax Accrual Workpapers: Wells Fargo v. United States:  On June 4, a federal district court in Minnesota issued an important opinion on the recurring question of whether the IRS may summon a corporation’s tax accrual workpapers during an audit. The workpapers, which were prepared by a team of company employees, outside auditors and lawyers, evaluated the susceptibility of various positions taken on the corporation’s tax returns in order to establish an appropriate tax accounting reserve. If it obtained the workpapers, the IRS would have a very useful roadmap for conducting its audit of the taxpayer. The taxpayer, and its outside auditors, resisted on the basis of attorney-client and work product protection. Following an evidentiary hearing and extensive briefing, the district court filed a 101-page opinion which upheld portions of the summons and quashed other portions while addressing a host of issues concerning work product protection and attorney-client privilege. The opinion’s approach differs from two prior appellate decisions—one in favor of the IRS and one in favor of the taxpayer. Our discussion will summarize the opinion, the legal issues, and likely future action in this area.

  • Stuart Bassin (Baker Hostetler)
  • Susan Hu (Kilpatrick Townsend & Stockton)

July 15, 2013 in Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Monday, July 8, 2013

Southern Federal Tax Institute Offers to Comp Tax Profs

Southern_federal_tax_instituteThe Board of Trustees of the Southern Federal Tax Institute invites all full-time tax professors to attend the Forty-Eighth Annual Institute (program) in Atlanta on October 21-25, 2013, as guests of the Trustees (the $995 registration fee will be waived). If you would like to attend, please email here. If you have any other questions, please contact Brant Hellwig (Washington & Lee), who serves as Special Advisor to the Institute.

July 8, 2013 in Conferences, Legal Education, Tax | Permalink | Comments (0) | TrackBack (0)

Wednesday, July 3, 2013

Rosenthal & Needham Debate: The Tax Treatment of Private Equity Funds and Their Partners

Tax AnalystsSteven M. Rosenthal (Tax Policy Center) & Andrew W. Needham (Cravath), Taxing PE Funds and Their Partners: A Debate on Current Law,  139 Tax Notes 1327 (June 10, 2013):

The following is the text of a debate that occurred between Rosenthal and Needham at the May meeting of the ABA Section of Taxation in Washington regarding the proper tax treatment of private equity funds and their partners under current law.

All Tax Analysts content is available through the LexisNexis® services.

July 3, 2013 in ABA Tax Section, Conferences, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Saturday, June 29, 2013

Brookings Program on Evaluating the Homebuyer Tax Credit

BrookingsThe Brookings Institution hoasted a program yesterday on Tools for Supporting the Housing Market: Evaluating the Homebuyer Tax Credit and Other Policies:

After the bursting of the home price bubble in the mid-2000s sent the housing market into a downward spiral, the government introduced a variety of new measures aimed at sustaining the flow of mortgage credit and boosting housing demand. One such measure was a program that provided a tax credit to homebuyers of up to $8,000. Although advocates of the program argued that it was a critical tool for absorbing excess inventories, critics complained that it simply accelerated sales that would have occurred anyway. Other measures aimed at stabilizing the housing market included various foreclosure prevention and mitigation initiatives, programs that facilitated refinancing, and the Federal Reserve’s considerable efforts to reduce interest rates.

With several years of experience of these policies now behind us, it is time to take stock of their effects. Establishing a better understanding of how they worked will help us learn what tools to use to combat future episodes of housing market distress and what measures the government should have in place now to encourage the nascent housing market recovery that has emerged over the past year.

Co-Directors of Economic Studies Karen Dynan and Ted Gayer presented a new paper on the impact of the federal and state homebuyer tax credits [An Evaluation of Federal and State Homebuyer Tax Incentives (Presentation]. A panel discussion followed to discuss how it compared to other government efforts to help the housing market:

  • William G. Gale (Co-Director, Urban-Brookings Tax Policy Center) (moderator)
  • Ed Brady (National Association of Home Builders)
  • Jonathan Hanks (Sr. Vice President and COO, Utah Housing Corporation)
  • Jed Kolko (Chief Economist and Vice President of Analytics, Trulia)
  • Christopher J. Mayer (Professor, Columbia Business School)

June 29, 2013 in Conferences, Tax, Think Tank Reports | Permalink | Comments (0) | TrackBack (0)

Friday, June 28, 2013

California State Bar Hosts 2013 Annual Income Tax Seminar Today

StateThe California State Bar's 2013 Annual Income Tax Seminar takes place today at Golden Gate, San Diego, Whittier Law Schools. Tax Prof speakers incluce:

  • Jordan M. Barry (San Diego), Income Tax Update 2013
  • Michael B. Lang (Chapman), Recent Developments in Ethics for Tax Practitioners, Including Actual and Existing Conflicts of Interest
  • John A. Swain (Arizona), State Taxation of Cloud and E-Commerce

June 28, 2013 in Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Saturday, June 22, 2013

American Taxation Association Annual Meeting

ATAThe annual meeting for the American Accounting Association will be held August 3-7 in Anaheim, CA. At the meeting, the American Taxation Association will offer an exciting program of tax research. This year’s ATA program consists of fourteen sessions covering a variety of topics including Financial Reporting of Taxes, Uncertain Tax Positions, Tax Avoidance, Tax Incentives and Investment, and State and Local Tax Research. In addition, Joseph J. Thorndike, director of the Tax History Project at Tax Analysts, will serve as the speaker for the ATA luncheon on Monday, August 5. His remarks will touch on the 100th Anniversary of the U.S. Federal Income Tax.

June 22, 2013 in Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Thursday, June 20, 2013

IRS-TPC Research Conference: Tax Administration at the Centennial

TPC-IRSThe IRS and Tax Policy Center are hosting a research conference today on Tax Administration at the Centennial with these presentations and papers (webcast):

Keynote Speaker:  Michael Durst (Senior Counsel, Steptow & Johnson, Washington, D.C.)

Welcome and Introductions:

  • Eric Toder (Co-Director, Tax Policy Center)
  • Rosemary Marcuss (Director, IRS Office of Research, Analysis, and Statistics) 

Session #1  Individual Income Tax Dynamics

  • Moderator: Elaine Maag (Tax Policy Center)
  • Len Burman & Liu Tian (Syracuse University), Norma Coe (University of Washington) & Kevin Pierce (IRS:RAS), Older Taxpayers’ Responses to Taxation of Social Security Benefits
  • Pat Langetieg, Mark Payne & Melissa Vigil (IRS: RAS), Preparer Industry Dynamics and the Return Preparer Initiative
  • Maggie R. Jones (Census Bureau), Changes in EITC Eligibility and Participation, 2005-2009
  • Discussant: Dayanand Manoli (University of Texas)

Session #2:  Business Compliance Behavior

  • Moderator: Eric Toder (Tax Policy Center)
  • Tom Beers, Eric LoPresti & Eric San Juan (IRS:Taxpayer Advocate Service), Factors Influencing Voluntary Compliance by Small Businesses: Preliminary Survey Results
  • Kenneth Klassen (University of Waterloo, Canada), Petro Lisowsky (University of Illinois) & Devan Mescall (University of Saskatchawan, Canada), Transfer Pricing: Strategies, Practices, and Tax Minimization
  • Peter Bickers, Michael Slyuzberg, Tracey Lloyd & Bhaskaran Nair (Inland Revenue, New Zealand), Demand for Aggressive Tax Planning
  • Discussant: Amy Dunbar (University of Connecticut)

Session #3:  Corporation Income Tax Enforcement

  • Moderator: Javier Framiñan (IRS)
  • Dave Macias & Kimmy Wang (IRS: LB&I), Analysis of Ten-Year Trends in Large Business Examination Results (2001- 2011)
  • Jason DeBacker (Middle Tennessee State University), Bradley Heim & Anh Tran (Indiana University) & Alexander Yuskavage (U.S. Treasury: Office of Tax Analysis), The Impact of Legal Enforcement: An Analysis of Corporate Tax Aggressiveness After an Audit
  • Margot Howard (University of North Carolina), IRS Enforcement and State Corporation Income Tax Revenues
  • Discussants: Jonathan Feinstein (Yale University) & Brian Erard (B. Erard & Associates)

Session #4:  Lessons From Other Tax Administrations

  • Moderator: Rahul Tikekar (IRS)
  • Cary Christian (Georgia Southern University), Why Evasion Under a National Sales Tax Would Explode the Tax Gap: Lessons Learned from the States
  • David Merriman (University of Illinois) & Natalie Davila & Hector M. Vielma (Illinois Department of Revenue), The Influence of Tax Form Design on Use Tax Compliance
  • Alice Cleland (Inland Revenue, New Zealand), Filling in the Black Hole: Research and Evaluation into the Hidden Economy
  • Discussant: Alan Plumley (IRS:RAS)
Wrap-up:  Janice Hedemann (Conference Chair, IRS:RAS)

June 20, 2013 in Conferences, IRS News, Tax | Permalink | Comments (0) | TrackBack (0)