TaxProf Blog

Editor: Paul L. Caron
Pepperdine University School of Law

A Member of the Law Professor Blogs Network

Friday, April 25, 2014

Tax Analysts Hosts Conference Today on Marketing Derivatives to Market for Tax Purposes

Tax NotesTax Analysts hosts a roundtable discussion on Marketing Derivatives to Market for Tax Purposes at the Ronald Reagan Building (1300 Pennsylvania Ave.) today at 3:00 - 5:00 p.m. EST in Washington, D.C.:

Rep. Camp recently proposed requiring all derivatives to be marked to market unless they are part of hedges. Marking derivatives to market is a source of controversy, but it has been under consideration by Treasury for a while. Supporters believe that it is necessary to clearly reflect income and to prevent taxpayers from exploiting different treatment of economically similar products. Critics argue that marking would complicate tax accounting for holders. The discussion will introduce the politics and history of mark-to-market in tax, examine Camp’s derivatives plan in detail, and debate the merits of marking certain types of derivatives

  • Christopher E. Bergin (President and Publisher, Tax Analysts) 
  • Viva Hammer (Legislation Counsel, Joint Committee on Taxation)
  • Yoram Keinan (Partner, Carter Ledyard & Milburn)
  • Lee A. Sheppard (Contributing Editor, Tax Analysts)

April 25, 2014 in Conferences, Tax, Tax Analysts | Permalink | Comments (2)

Monday, April 14, 2014

NYU Tax Law Review Publishes Symposium Issue: The Income Tax at 100


NYU 100The Tax Law Review has published a new issue (Vol. 66, No. 4 (Summer 2013)), NYU/UCLA Tax Policy Symposium: The Income Tax at 100, 66 Tax L. Rev. 357-879 (2013):

Deborah H. Schenk (NYU), Foreword: The Income Tax at 100, 66 Tax L. Rev. 357 (2013)

Panel #1:  The Role of the Corporate Tax:

Panel #2:  International Taxation:

Panel #3:  Taxes and Inequality:

Panel #4:  Taxes and Politics:

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

Papers From the American Taxation Association's 2014 Midyear Meeting

ATA LogoThe American Taxation Association has posted on SSRN the 21 papers from its 2014 Midyear Meeting.

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

Friday, April 11, 2014

Tax Salience Panel at Law & Econ Conference Today at Duke

TriangleThere is a tax panel at today's 5th Annual Triangle Law & Econ Conference on Rethinking Regulation and Reform: Behavioral Economics and the Regulatory State at Duke:

Tax Salience

  • Peter Barnes (Caplin & Drysdale, Washington, D.C.)
  • Jasper Cummings (Alston & Bird, Washington, D.C. & Raleigh, NC)
  • David Gamage (UC-Berkeley)
  • Kathleen Thomas (North Carolina)
  • Larry Zelenak (Duke) (facilitator) 

April 11, 2014 in Conferences, Tax | Permalink | Comments (0)

Thursday, April 10, 2014

Call for Papers: McGill Symposium on Tax Justice and Human Rights

McGillMcGill Faculty of Law, Call for Papers:  Tax Justice and Human Rights Research Collaboration Symposium:

We invite paper proposals for a Tax Justice and Human Rights Research Collaboration Symposium, to be held at the McGill Faculty of Law, Montreal, Quebec, from Wednesday to Friday, 18-20 June, 2014. 

The symposium will explore the fundamental connections between taxation and human rights by providing a forum for collaboration among emerging scholars, established academics, civil society organization representatives, tax justice advocacy groups, tax policy makers, and researchers from around the world. The symposium seeks especially to bring developing-world perspectives into the discourse and to foster scholarly work for dissemination both within and beyond the academic setting.

The plurality of experience, in terms of training, background, country of origin, and area of expertise, will ensure that discussions and activities at the conference will have real-world impact. Indeed, there is a need within the tax-policy world for more cross-pollination between academic researchers and on-the-ground decision-makers. The connections and networking that we envision will take place at this conference should allow for meaningful discussions for years to come.

Paper proposals must be between 300-500 words in length and should be accompanied by a short résumé.

Please submit your proposal to the conference convener Professor Allison Christians, at allison.christians@mcgill.ca.

Deadline for submissions: 30 April 2014. Successful applicants will be notified in early May 2014.

Continue reading

April 10, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Saturday, April 5, 2014

17th Annual Critical Tax Theory Conference Concludes Today at Baltimore

Baltimore Law School LogoThe  17th Annual Critical Tax Theory Conference concludes today at Baltimore:

Critical tax scholars ask why the tax laws are the way they are and what impact tax laws have on historically disempowered groups, such as people of color; women; lesbian, gay, bisexual, and transgendered individuals; low-income and poor individuals; the disabled; and nontraditional families. Critical tax scholarship shares the following goals: (1) to uncover bias in the tax laws; (2) to explore and expose how the tax laws both reflect and construct social meaning; and (3) to educate nontax scholars and lawyers about the interconnectedness of taxation, social justice, and progressive political movements. However, as articulated at the original conference in 1995 to the present, the content of the Critical Tax Theory Conference has not been narrow – the topics discussed have been wide-ranging and have included more conventional tax topics as well.

Session #5:

  • Steven Dean (Brooklyn), Space Madness: Subsidies and Economic Substance 
  • Henry Ordower (St. Louis), Income Imputation: Toward Equal Treatment of Renters and Owners

Session #6:

  • Nan Kaufman (St. Louis), Tax Ladies
  • Keeva Terry (Howard), Divorce Without Marriage? There's Nothing Sexy about Taxing Property Transfers between Unmarried Couples
  • Mildred Robinson (Virginia), Philanthropy in IRC Section 170?

Session #7:

  • Neil H. Buchanan (George Washington), Forced Labor and the Income Tax: The Full Implications of Taking Nozick’s (Now-Repudiated) Claim Seriously
  • Nancy Shurtz (Oregon), Long-Term Care and the Tax Code: A Feminist Perspective
  • Linda Sugin (Fordham), Payroll Taxes, Mythology and Fairness

Session #8:

  • Andrew Blair-Stanek (Maryland), Crisis-Proofing the Tax Code
  • Wendy Gerzog (Baltimore), Façade Easements: Façades of Equity (incubator) Anthony

Prior Critical Tax Theory Conferences:

April 5, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, April 4, 2014

17th Annual Critical Tax Theory Conference Kicks Off Today at Baltimore

Baltimore Law School LogoThe  17th Annual Critical Tax Theory Conference kicks off today at Baltimore:

Critical tax scholars ask why the tax laws are the way they are and what impact tax laws have on historically disempowered groups, such as people of color; women; lesbian, gay, bisexual, and transgendered individuals; low-income and poor individuals; the disabled; and nontraditional families. Critical tax scholarship shares the following goals: (1) to uncover bias in the tax laws; (2) to explore and expose how the tax laws both reflect and construct social meaning; and (3) to educate nontax scholars and lawyers about the interconnectedness of taxation, social justice, and progressive political movements. However, as articulated at the original conference in 1995 to the present, the content of the Critical Tax Theory Conference has not been narrow – the topics discussed have been wide-ranging and have included more conventional tax topics as well.

Session #1:

Session #2:

Session #3:

Session #4:

Prior Critical Tax Theory Conferences:

April 4, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Valparaiso Hosts Symposium Today on Money, Politics, and the IRS

Valpo LogoThe Valparaiso University Law Review hosts a symposium today Money in Politics: The Good, the Bad, and the Ugly, which includes a tax panel:

Snapshot of the Problem: A Taxing Analysis of the IRS Controversy:

  • Philip Hackney (LSU), Should the IRS Never “Target” Taxpayers? An Examination of the IRS Tea Party Affair
  • Lloyd H. Mayer (Notre Dame), Taxing Politics
  • Donald Tobin (Ohio State), The IRS, Politics, and the Crisis of Confidence  

April 4, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

LegalED: Igniting Law Teaching -- A TEDx-Styled Conference

LegaledLegalED hosts its first conference today on Igniting Law Teaching! (webcast):

The conference theme – Igniting Law Teaching – responds to the calls for reform of legal education. This theme was selected so that we could create a forum for professors experimenting with cutting edge technologies and techniques in law teaching with the goal of spreading their ideas to the broader community. We see the conference as a way to showcase professors who are leaders in teaching innovation and to inspire innovation by others as well.

This conference will be unlike other gatherings of law professors. Here, talks will be styled as TEDx Talks, with each speaker on stage alone, giving a well scripted and performed talk about an aspect of law school pedagogy. The goal is to create a collection of short, 10-minute videos on law school-related pedagogy that will inspire innovation and experimentation by law professors around the country to bring more active learning and practical skills training into the law school curriculum. The videos will be available for viewing by the larger academic community on LegalED, a website developed by a community of law professors interested in using online technologies to facilitate more active, problem-based learning in the classroom, in addition to more assessment and feedback.

Michele Pistone, (Villanova), Why Law Schools Need to Change

Panel #1:  Flipping the Law School Classroom

  • William Slomanson (Thomas Jefferson), hy Why Flip? and Macro Design
  • Jennifer Rosa (Michigan State), Legal Writing on Steroids: The Art of Flipping Your Classroom
  • Debora L. Threedy (Utah), Flipping Contracts: The Making of the Videos
  • Wes Reber Porter (Golden Gate), A Better Class to Class Process to Accompany Flipping
  • David Thomson (Denver), Move 1L Online

Panel #2:  Using the Classroom for Active Learning

  • Jamie R. Abrams (Louisville), The Socratic Method, Revisited
  • Erika L. Wood (New York Law School), Borrowing from the Skills Classroom to Teach Doctrine
  • Jeremiah Ho (UMass), Not Your Father’s Case Method: Bringing Skills into Doctrinal Courses
  • Victoria Duke (Indiana Tech), Bringing Exercises in Large Classes
  • Enrique Guerra-Pujol (Barry), Using Film to Teach Torts
  • Victoria Szymczak (Hawaii), Using Video to Convert Student into Teachers

Panel #3:  Applying Learning Theory to LegalEDucation

  • Leah Wortham (Catholic), Graduating Them Whole Not Broken
  • John P. Joergensen (Rutgers-Newark), Scaffolding
  • Paul D. Callister (UMKC), The Metacognition Imperative: Beyond Research Training
  • Warren Binford (Willamette), How to Be the World’s Worst Law Professor
  • Jeffrey B. Ritter (Georgetown), Mapping the Law: Building and Using Visual Mindmaps in Legal Education

Panel #4:  The Craft of Law Teaching

  • Sharon Keller (District of Columbia), Old Professor Tricks
  • Kim Hawkins (New York Law School),  What Law Professors Need to Know About Visual Arts
  • Jill A. Smith (Georgetown), Going Hollywood on your Desktop: Creating Great Screencasts
  • Doni Gewirtzman (New York Law School), Teaching and Theater: The Craft of Law Teaching
  • Leah A. Plunkett (New Hampshire), An Improviser’s Guide to Law Teaching

Luncheon Address:  Leo Martinez (UC-Hastings; President, AALS)

Panel #5:  Simulations, Feedback, & Assessment

  • Shawn Marie Boyne (Indiana-Indianapolis), Disaster in the Classroom: Using Simulations to Teach National Security Law
  • Renee Nicole Allen (Florida A&M), Metacognition and the Value of Reflection in Learning
  • Michele Gilman (Baltimore), Why Use Clickers? To Provide Students Real Time Feedback
  • Sydney Beckman (Lincoln Memorial), Using Technology For Engagement and Assessment
  • Margaret Hahn-Dupont (Northeastern), Learning Through Reflection and Self-Assessment

Panel #6:  Beyond Traditional Law Subjects

  • John M. Bickers (Northern Kentucky), Using a Wok:  How Non-Bar Tested Electives Can Teach Lawyering
  • Susan L. Brooks (Drexel), The ABCs of Communication for Teaching Relational Lawyering and Resilience
  • Ryan Dooley & Allison Robbins (CUNY ), The Law School as a Classroom
  • Vicenç Feliú (Villanova), Clinics and Librarians Collaborating
  • Elizabeth Keyes (Baltimore), Teaching Narrative
  • James G. Milles (SUNY-Buffalo), Returning the Client to Legal Education
  • Emmeline Paulette Reeves (Richmond), Teaching with the End (Bar Passage) in Mind

Panel #7:  Teaching for the 21st Century

  • Dan Jackson (Northeastern), Designing Lawyers: Leading an Experiential Law School Design Lab
  • Jay Gary Finkelstein (DLA Piper), Get Real!: Using Experiential Learning and Collaborative Teaching to Train ‘Practice Aware’ Lawyers
  • Christine P. Bartholomew (SUNY-Buffalo), Finding Tim
  • Jeanne Eicks (Vermont), Game On! Educational Games for Law Students
  • Brett Johnson (Harvard), H2O: Remixing the Casebook

April 4, 2014 in Conferences, Legal Education | Permalink | Comments (0)

Monday, March 31, 2014

AEI Hosts Conference Today on The Economic Effects of Territorial Taxation

AEI LogoThe American Enterprise Institute hosts a conference today on The Economic Effects of Territorial Taxation (webcast):

As Congress deliberates business tax reform options, the international aspects often prove most complex. All Group of Eight countries other than the United States have territorial tax systems that exempt 95 to 100 percent of qualified dividends repatriated from foreign subsidiaries.

This half-day conference, cohosted by AEI and the International Tax Policy Forum, will explore the economic effects of territorial taxation. Panelists will use their international experience to examine the effects of international tax rules on base erosion and profit shifting, repatriation of foreign profits, and cross-border mergers and acquisitions and headquarters location. The conference will conclude with a luncheon address by Jason Furman, chairman of the White House Council of Economic Advisers.

Introductory Remarks:

  • Alex Brill, AEI
  • John Samuels, General Electric

Panel #1:  Base Erosion and Profit Shifting Under Worldwide and Territorial Taxation

  • Dhammika Dharmapala (Illinois)
  • Kevin Markle (University of Waterloo)
  • Alan D. Viard (American Enterprise Institute) (commentator)
  • Michael Graetz (Columbia) (moderator)

Panel II:  Repatriation of Foreign Profits in Japan, the U.K., and the U.S.

  • Sebastien Bradley (Drexel)
  • Peter Egger (ETH Zurich)
  • Fritz Foley (Harvard)
  • Rosanne Altshuler (Rutgers) (commentator)
  • Alan Auerbach (UC-Berkeley) (moderator)

Panel #3:  Home-Country Tax Effects on Mergers, Inversions, and Headquarters Location

  • Susan Morse (Texas)
  • Paul Oosterhuis (Skadden)
  • Johannes Voget (University of Mannheim)
  • James Hines (Michigan) (commentator)
  • Mihir Desai (Harvard) (moderator)

Luncheon Address:  Jason Furman (Council of Economic Advisers)

March 31, 2014 in Conferences, Tax | Permalink | Comments (0)

Thursday, March 27, 2014

Caron & Repetti: Revitalizing the Estate Tax: Five Easy Pieces

TaxSymposiumHeaderPaul L. Caron (Pepperdine) & James R. Repetti (Boston College), Revitalizing the Estate Tax: Five Easy Pieces, 142 Tax Notes 1231 (Mar. 17, 2014) (Symposium on Tax Reform in a Time of Crisis):

In a previous article, we argued that contrary to the state of the law over 35 years ago — when George Cooper wrote his seminal article on the estate tax (A Voluntary Tax? New Perspectives on Sophisticated Estate Tax Avoidance, 77 Colum. L. Rev. 161 (1977)) — taxpayers today generally ‘‘can reduce the value of assets subject to transfer tax in many instances only if they are willing to assume the risk that the reduction may be economically real and reduce the actual value of assets transferred to heirs or, alternatively, in narrow situations if they are willing to incur some tax risk.’’ (The Estate Tax Non-Gap: Why Repeal a Voluntary Tax?, 20 Stan. L. & Pol’y Rev. 153 (2009)) In another article, we documented the dramatic increase in income and wealth inequality over the past 30 years and the accompanying adverse social consequences and long-term negative effect on economic growth. (Occupy the Tax Code: Using the Estate Tax to Reduce Inequality and Spur Economic Growth, 40 Pepp. L. Rev. 1255 (2013)) We argued that tax policy historically has played an important role in reducing inequality and that the estate tax is a particularly apt reform vehicle in light of the role of inherited assets among the very rich and the adverse economic effects of that inherited wealth. In this article, we advance five estate and gift tax reform proposals that would generate needed revenue, reduce inequality, and contribute to economic growth: (1) disallow minority discounts when the transferred asset or business is controlled by family before and after the transfer; (2) maintain parity between the unified credit exemption amounts for the estate and gift taxes; (3) reduce the wealth transfer tax exemptions to $3.5 million, increase the maximum tax rate to 45 percent, and limit the generation-skipping transfer tax (GSST) exemption period to 50 years; (4) restrict the ability for gifts made in trust to qualify for the gift tax annual exclusion; and (5) impose a lifetime cap on the amount that can be contributed to a grantor retained annuity trust (GRAT).

March 27, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Tax Analysts Hosts Conference Today on Is It Time For a Taxpayer Bill of Rights?

TA ConfTax Analysts hosts a roundtable discussion on Taxpayers and the IRS: Is It Time For a Taxpayer Bill of Rights? at the National Press Club in Washington, D.C. today at 9:00 - 11:00 a.m. EST:

On January 9, 2014, National Taxpayer Advocate Nina E. Olson released the 2013 Annual Report to Congress, urging the IRS to implement administratively a comprehensive, principle-based TBOR. That proposal, comprising 10 rights modeled on the U.S. Constitution's Bill of Rights, is designed to strengthen the IRS’s ability to serve taxpayers. However, the lack of resources needed to implement these rights could prevent the IRS from proceeding. The speakers and the conversation that follows will provide a historical perspective on prior legislation, discuss recommendations for adopting a TBOR, and debate the timing and politics involved in its implementation.

  • Nina E. Olson (National Taxpayer Advocate)
  • Christopher S. Rizek (Caplin & Drysdale, Washington, D.C.)
  • Alan J. Wilensky (Former Acting Assistant Secretary for Tax Policy, U.S> Treasury Department)
  • Moderator:  Christopher E. Bergin (President and Publisher, Tax Analysts)

March 27, 2014 in Conferences, Tax, Tax Analysts | Permalink | Comments (0)

Wednesday, March 26, 2014

Yin: Reforming (and Saving) the IRS by Respecting the Public’s Right to Know

TaxSymposiumHeaderGeorge K. Yin (Virginia), Reforming (and Saving) the IRS by Respecting the Public’s Right to Know (Symposium on Tax Reform in a Time of Crisis):

The current controversy involving possible political targeting by the IRS in administering the exempt organization (EO) tax laws is simply the latest in a long succession of similar allegations spanning at least five decades. This article proposes to address the problem through increased transparency of the IRS’s administrative actions involving EOs. Greater transparency responds directly to the public’s frustration in not being able to monitor the agency and gain confidence that the laws are being applied in an even-handed manner.

Continue reading

March 26, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Tuesday, March 25, 2014

The Atlantic Hosts Tax Policy Summit Today in Washington, D.C.

The AtlanticThe Atlantic hosts a Tax Policy Summit on Streamlining the System, Fighting Fraud, and Empowering Consumers today (webcast) at the Newseum in Washington, D.C. :

Recent headlines have focused on new tax reform legislation slashing the corporate and individual tax rates. Yet even as the perennial tax reform conversation again dominates Washington, a more fundamental problem continues to plague the tax administration system. Over the last decade, the IRS made an estimated $140 billion in improper payments, the result of fraud, complexity, and individual mistakes in the face of a labyrinthine tax system. This event will convene key tax policy leaders for a conversation about whether, even without comprehensive reform, there are small but significant steps that can be taken now to combat fraud, preserve the integrity of the tax system, and better serve and protect consumers.

Keynote Address:  Senator Ben Cardin (D-MD)
Moderator:  Nancy Cook (Economics Correspondent, National Journal)

Panel Discussion:

  • Leslie Book (Director of Graduate Tax Program, Villanova School of Law)
  • Eric Toder (Co-Director, Urban-Brookings Tax Policy Center)
  • Chi Chi Wu (Attorney, National Consumer Law Center)
  • Nancy Cook (Economics Correspondent, National Journal) (moderator)

March 25, 2014 in Conferences, Tax | Permalink | Comments (0)

Monday, March 24, 2014

Harvey Presents FATCA Background, Developments, and Key Issues Today at Baltimore

HarveyJ. Richard (Dick) Harvey, Jr. (Villanova) delivers the keynote address on Offshore Accounts: FATCA Background, Developments, and Key Issues at the tax symposium today sponsored by the University of Baltimore Graduate Tax Program and the Maryland State Bar Association Tax Section:

FATCA was unilaterally enacted by the US in March 2010 to address tax evasion by US taxpayers using offshore accounts. Much has occurred during the ensuing 4 years as the world prepares for FATCA’s July 1, 2014 effective date. Ultimately the key question is whether FATCA will be successful, and if so, how long will it take?

March 24, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

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

TaxSymposiumHeaderPaul L. Caron (Pepperdine), Tax Reform in a Time of Crisis, 142 Tax Notes 1106 (2014) (104-page pdf of all ten symposium articles):

On January 17, 2014, Pepperdine University School of Law and Tax Analysts sponsored a symposium in Malibu, California, at which 21 of the nation’s leading tax academics, practitioners, and journalists discussed the prospects for tax reform as it is affected by two crises facing Washington, D.C.: dangerously misaligned spending and tax policies, which have resulted in a crippling $17.4 trillion national debt; and the IRS’s alleged targeting of conservative political organizations. This introduction to the symposium summarizes the keynote (Joseph Bankman) and luncheon (Bruce Bartlett) addresses and the three panels. 

Keynote Address (video):  Joseph Bankman (Stanford), Tax Scholarship in a Time of Fiscal Crisis
Edward Kleinbard (USC) (commentator)

Panel #1:  Individual/Estate and Gift Tax Reform (video)

Luncheon Address (video):  Bruce Bartlett (Former Deputy Assistant Treasury Secretary), The History of Tax Reform

Panel #2:  Business/International Tax Reform (video)

Panel #3:  Tax Reform in a Time of Crisis: Institutional Perspectives (video)

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

March 24, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, March 21, 2014

Tulane Hosts 4th Annual Tax Roundtable Today in New Orleans

Tulane LogoTulane hosts its 4th 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), Tax Basis Determinations, Pass-Through Entities, and Taxpayer Noncompliance (with Jay A. Soled (Rutgers))
Discussant:  George Yin (Virginia)

Susannah Tahk (Wisconsin), The Tax War on Poverty
Discussant:  Tessa Davis (Tulane)

Jinyan Li (Osgoode Hall), Combating BEPS through LSAs: The Approach of China and India (with Thaddeus Hwong (York))
Discussant:  Jennifer Bird-Pollan (Kentucky)

Shu-Yi Oei (Tulane), Taxing Human Equity (with Diane Ring (Boston College))
Discussant:  Philip Hackney (LSU)

George Yin (Virginia), Reforming (and Saving) the IRS by Respecting the Public’s Right to Know
Discussant:  Steven Sheffrin (Tulane)

Steven Sheffrin (Tulane), Tax Competition, Agglomeration, and the Mobility of Professional Athletes (with Grant Driessen (Tulane))
Discussant:  Jinyan Li (Osgoode Hall)

Jennifer Bird-Pollan (Kentucky), Electing Fairness: A Proposal for a Check-the-Box Style Regime for Same-Sex Couples’ Filing Status
Discussant:  James Alm (Tulane)

Philip Hackney (LSU), Business Leagues, the Collective Action (Non) Problem and Tax-Exemption
Discussant:  Susannah Tahk (Wisconsin)

March 21, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, March 20, 2014

Utah Symposium on Perpetual Conservation Easements

The Utah Law Review has published a symposium on Perpetual Conservation Easements, 2013 Utah L. Rev. 687-881:

March 20, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, March 17, 2014

IDC Herzliya Hosts Symposium Today on A New Era in Taxation in Honor of Nancy Staudt

StaudtIDC Herzliya, Radzyner School of Law (Israel) hosts a symposium today on A New Era in Taxation in honor of Nancy Staudt (Vice Dean for Faculty and Academic Affairs, Edward G. Lewis Chair in Law and Public Policy, and Academic Director, The Schwarzenegger Institute, USC), organized by Rifat Azam and Ruth Zafran:

Keynote Address:  Nancy Staudt (USC), Corporate Shams around the World

Panel #1:  Tax Base Erosion and Profit Shifting

  • Dr. Rifat Azam (IDC Herzliya), Panel Chair
  • Tsilly Dagan (Bar-Ilan), Tax Policy in an Era of Globalization
  • Tamir Shanan (College of Management Academic Studies), Replacing the Transfer Pricing Regime with Formulary Apportionment Approach in the International Settings
  • Rifat Azam (IDC Herzliya), New Stage in the Multinationals v. The International Tax Regime Game: Some Thoughts on the OECD Action Plan on Base Erosion and Profit Shifting

Panel #2:  Current Issues in Tax Policy

  • Adam Shinar (IDC Herzliya), Panel Chair
  • Yoram Margalioth (Tel-Aviv), Why (and how) Income Tax should be Imposed at the Household Level?
  • Sagit Leviner (Ono), Comparative Evaluation of Tax Policy-Making in Israel: Exploring the Trajectories Where are we coming from and What Lays Ahead
  • Jacob Nussim (Bar-Ilan), The Tax Treatment of Losses

Comments & Closing Remarks:  Nancy Staudt (USC)

March 17, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, March 14, 2014

Chapman Hosts Symposium Today on Business Tax Reform

Chapman Logo (2013)The Chapman Law Review hosts a symposium today on Business Tax Reform: Emerging Issues in the Taxation of U.S. Entities:

Panel I:  Specific Tax Issues Affecting the Business World: The Policies and Reasons Behind Certain Laws
Moderator: Bobby Dexter (Chapman)

Panel II:  Pass-Through Entity Reform: Is a Major Overhaul Necessary?
Moderator: Bahar A. Schippel (Snell & Wilmer)

Keynote Speaker:  Edward D. Kleinbard (USC)

Panel III:  How Federal Business Tax Reform Affects State and Local Tax
Moderator:  Michael Lang (Chapman)

Panel IV:  Corporate Tax Reform: How to Tax Multinational Corporations
Moderator:  Douglas A. Schaaf (Paul Hastings)

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

Wednesday, March 5, 2014

AALS Call for Papers: Bringing Accounting, Finance, and Tax Into the Business Law Curriculum

AALSThe AALS Section on Agency, Partnerships LLCs, and Unincorporated Associations has issued a call for papers for the 2015 AALS Annual Meeting in Washington, D.C.:  Bringing Numbers into Basic and Advanced Business Associations Courses: How and Why to Teach Accounting, Finance, and Tax:

Business planners and transactional lawyers know just how much the “number-crunching” disciplines overlap with business law. Even when the law does not require unincorporated business associations and closely held corporations to adopt generally accepted accounting principles, lawyers frequently deal with tax implications in choice of entity, the allocation of ownership interests, and the myriad other planning and dispute resolution circumstances in which accounting comes into play. In practice, unincorporated business association law (as contrasted with corporate law) has tended to be the domain of lawyers with tax and accounting orientation. Yet many law professors still struggle with the reality that their students (and sometimes the professors themselves) are not “numerate” enough to make these important connections. While recognizing the importance of numeracy, the basic course cannot in itself be devoted wholly to primers in accounting, tax, and finance.

The Executive Committee will devote the 2015 annual Section meeting in Washington to the critically important, but much-neglected, topic of effectively incorporating accounting, tax, and finance into courses in the law of business associations. In addition to featuring several invited speakers, we seek speakers (and papers) to address this subject. Within the broad topic, we seek papers dealing with any aspect of incorporating accounting, tax, and finance into the pedagogy of basic or advanced business law courses.

Any full-time faculty member of an AALS member school who has written an unpublished paper, is working on a paper, or who is interested in writing a paper in this area is invited to submit a 1 or 2-page proposal by May 1, 2014 (preferably by April 15, 2014). The Executive Committee will review all submissions and select two papers by May 15, 2014. A very polished draft must be submitted by November 1, 2014. The Executive Committee is exploring publication possibilities, but no commitment on that has been made. All submissions and inquiries should be directed to Jeff Lipshaw.

March 5, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Tuesday, March 4, 2014

ACTEC Issues Call for Proposals for $20,000 Grant to Host T&E Symposium

ACTECThe Legal Education Committee of the American College of Trust and Estate Counsel requests proposals for a $20,000 grant to host a symposium on trust and estate law during academic year 2015-2016:

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, to bridge the gap between the academic community and practitioners, to provide opportunities for junior academics to present papers and interact with more senior academics, to provide an opportunity for trust and estate professors to interact with each other, to involve academics from other disciplines in discussions of trust and estate topics, and to strengthen ACTEC’s image as the leading organization for trust and estate lawyers, both practitioners and academics.

Please submit your proposal by April 15, 2014 to Susan Gary or Nancy McLaughlin.

March 4, 2014 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

Friday, February 28, 2014

FBA Hosts 38th Annual Tax Law Conference

FBAThe Federal Bar Association Section on Taxation hosts the 38th Annual Tax Law Conference today at the Ronald Reagan Building and International Trade Center, 1300 Pennsylvania Avenue, N.W., Washington, D.C. The featured speakers are:

  • David A. Hubbert (Deputy Assistant Attorney General, U.S. Department of Justice, Tax Division)
  • William J. Wilkins (Chief Counsel, IRS)

February 28, 2014 in Conferences, Tax | Permalink | Comments (0)

The Fossil Fuel Tax Deception

32Tax panel at today's 2014 Public Interest Environmental Law Conference at Oregon:

Fossil Fuel Deception: The Federal Government’s Participation Through Financial Incentives (Organizer: Mona L. Hymel (Arizona))
The deception of oil causes us to think that we can buy cheap stuff from China, we can live in cheap big houses in the exurbs, and we can keep on driving to CostCo in our SUVs to stock up on that cheap stuff from around the world. Is our economy hostage to cheap oil? Our thirst for oil leads to exploitation of pristine lands and exploitation of native people. Concern about oil justifies military buildup. From a tax perspective, “regular” oil tax benefits like percentage depletion, enhanced oil recovery, and IDCs, while relatively minor in terms of total tax expenditures, never expire and illustrate the strength of the fossil fuel lobby, which resists any cut backs. There are also stealth oil benefits: exemption from AMT and passive activity loss rules, the § 199 deduction, and master limited partnerships. Unconventional oil and gas extraction techniques (fracking and tar sands) reduce the net energy benefit of oil. Energy from oil could be used to transition into a fossil-free economy, but we just seem to keep burning it. A carbon tax could help reduce the incentive to keep drilling and digging ourselves even deeper in the climate change hole.

  • Greg Bothun (Oregon) 
  • Neil Buchanan (George Washington)
  • Mona Hymel (Arizona)
  • Roberta Mann (Oregon)
  • Tracey Roberts (Seattle)
  • Walter Wang (San Diego)

February 28, 2014 in Conferences, Tax | Permalink | Comments (0)

Monday, February 24, 2014

American Taxation Association 2014 Midyear Meeting

ATA LogoThe American Taxation Association held its 2014 Midyear Meeting last week in San Antonio. The full program is here.

February 24, 2014 in Conferences, Tax | Permalink | Comments (0)

Sunday, February 23, 2014

Harvard Hosts Conference on Religious Accommodation in the Age of Civil Rights

Harvard hosts a conference on Religious Accommodation in the Age of Civil Rights (Thursday, April 3 - Saturday, April 5, 2014):

HarvardCurrent controversies over marriage equality, antidiscrimination law, and the Affordable Care Act’s contraceptive mandate have raised conflicts between religious claims, on one hand, and LGBT equality and women’s rights, on the other. The conference seeks to deepen our understanding of the competing claims by bringing together nationally recognized scholars in the fields of sexuality, gender, and law and religion. 

Speakers 

  • Anita Allen, University of Pennsylvania Law School
  • Tom Berg, St. Thomas Law School
  • Mary Anne Case, University of Chicago Law School
  • Caroline Corbin, University of Miami Law School
  • William Eskridge, Yale Law School
  • Chai Feldblum, EEOC
  • Katherine Franke, Columbia Law School
  • Richard Garnett, Notre Dame Law School
  • Frederick Gedicks, BYU Law School
  • Malick Ghachem, University of Maine Law School
  • Sarah Barringer Gordon, University of Pennsylvania Law School
  • Michael Helfand, Pepperdine Law School
  • Nan Hunter, Georgetown University Law Center
  • John Inazu, Washington University Law School
  • Andrew Koppelman, Northwestern University Law School
  • Douglas Laycock, University of Virginia Law School
  • Martin Lederman, Georgetown University Law Center
  • Sandy Levinson, University of Texas Law School
  • Michael McConnell, Stanford University Law School
  • Louise Melling, ACLU
  • Ilan Meyer, Williams Institute, UCLA
  • Martha Minow, Harvard Law School
  • Melissa Murray, UC Berkeley Law School
  • Douglas NeJaime, UC Irvine Law School
  • Priscilla Ocen, Loyola LA Law School
  • Alison Dundes Renteln, University of Southern California
  • Reva Siegel, Yale Law School
  • Elizabeth Sepper, Washington University Law School
  • Steven Smith, University of San Diego Law School
  • Nomi Stolzenberg, USC Law School
  • Nelson Tebbe, Brooklyn Law School
  • Mark Tushnet, Harvard Law School
  • Kenji Yoshino, NYU Law School

February 23, 2014 in Conferences, Legal Education | Permalink | Comments (1)

Saturday, February 22, 2014

University of Washington Third Annual Tax Forum

UWThe University of Washington School of Law and the Tax Executives Institute hosted the Third Annual Tax Forum yesterday with these panels:

  • BEPS, OECD, G20 and US Tax Reform and Industry Response
  • Domestic Planning and Pass-Through Entities
  • IRS Developments and Current Tax Enforcement and Examination Update
  • State Push into New Nexus Theories and the Related Implications for Sourcing of Receipts
  • Treasury Workshop

February 22, 2014 in Conferences, Tax | Permalink | Comments (0)

Friday, February 21, 2014

Duke Hosts Conference Today on Taking Administrative Law to Tax

Duke Law (2014)The Duke Law Journal hosts a symposium today on Taking Administrative Law to Tax:

Panel #1:  The Tax Exceptionalism Debate

Bryan Camp (Texas Tech), Reimagining Regulations: Thinking Outside the Tax Exceptionalism Box
Discussant:  Andy Grewal (Iowa)

Larry Zelenak (Duke), Maybe Just a Little Bit Special, After All?
Discussant:  Richard Murphy (Texas Tech)

Panel #2:  Adjudicating Tax Issues

Steve Johnson (Florida State), Reasoned Explanation and IRS Adjudication
Discussant:  Richard Pierce (George Washington)

Leandra Lederman (Indiana), (Un)Appealing Deference to the Tax Court
Discussant:  Keith Fogg (Villanova)

Panel #3:  A Functional Look at the IRS

Ellen Aprill (Loyola-L.A.), A Case Study of Legislation v. Regulation: Defining Political Campaign Intervention under Federal Tax Law
Discussant:  Rich Schmalbeck (Duke)

Kristin Hickman (Minnesota), Administering the Tax System We Have
Discussant:  Stuart Benjamin (Duke)

Update (courtesy of Leandra Lederman):

Duke

February 21, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Marian Presents How Bitcoin Challenges the Federal Income Tax System Today at Ohio State

MarianOmri Marian (Florida) presents How Bitcoin Challenges the Federal Income Tax System at Ohio State today as part of its sympsoium on In Bitcoin We Trust? A Forward Look at the Regulation, Use, and Growth of the Digital Currency hosted by The Ohio State Entrepreneurial Business Law Journal:

I explore the challenges that Bitcoin transactions present to the U.S. federal income tax system. I divide these challenges to substantive challenges (i.e., how Bitcoin transactions should be taxed), and collection challenges (i.e., how income on Bitcoin transactions should be reported and how the tax can be collected). I suggest that in the substantive category the challenges are sometimes overstated. Much effort is spent trying to decide what is Bitcoin for tax purposes. This exercise is not always necessary. In most circumstances the tax-classification of personal property is based on the use of the asset in the hands of the taxpayer, and not on the nature of the asset. Bitcoin is no exception. Looking at the process by which Bitcoins are generated and circulated (i.e., how they are used) I conclude that Bitcoin mining income is always ordinary income that must be recognized upon receipt of the Bitcoins, regardless of Bitcoin’s “classification”. Moreover, once Bitcoin enters circulation, the only major threshold issue is whether Bitcoin is a nonfunctional currency. I suggest that under current regulatory framework Bitcoin should not be classified as a nonfunctional currency. Once this issue is resolved, most substantive questions relating to Bitcoin transactions find answers under current guidance. That said, there might be good policy reasons to change certain guidance when it comes to Bitcoins.

Continue reading

February 21, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Florida Tax Institute

FloridaThe three-day Florida Tax Institute concludes today at the Grand Hyatt in Tampa.  Tax Prof speakers include:

  • Samuel A. Donaldson (Georgia State), Annual Update
  • Lawrence Lokken (Florida), Current Developments in International Taxation
  • Martin J. McMahon, Jr. (Florida), Current Developments in Federal Income Taxation 

February 21, 2014 in Conferences, Tax | Permalink | Comments (0)

Call for Papers: Arizona State Legal Scholars Conference

ASU

On March 14-15, 2014, Arizona State hosts the Fifth Annual Legal Scholars Conference:

The purpose of the conference is to gather together “juniorish” academics (generally, those who have been in the academy for fewer than 10 years) to receive constructive feedback on their scholarship, to network, and to enjoy Arizona’s March weather!

We charge no registration fees and provide for free: (1) dinner and drinks the night before (Friday March 14th); (2) a spring training game (Cubs vs. Dodgers) or outing to the PHX Zoo for interested attendees; and (3) breakfast and lunch the day of the conference (Saturday March 15th). Attendees, however, must cover all travel and hotel costs. ...

[E]ach registrant will be asked to submit something for comment and feedback. The paper can be a draft of a work in progress, a recently accepted piece, or even just a half-baked idea; the only limitation is that it should not be a piece that is already published (because the whole point of the conference is to get feedback to improve the piece). Based on the subject of the paper, each conference attendee will be assigned to a group of other attendees with similar scholarly interests. The members of each group will read the papers of the other members of the group, and then provide feedback on those papers. In the past five years, we have had more than 200 law professors from around the country attend and exchange ideas—join this ever-growing group and come to the conference on March 14 & 15th!

February 21, 2014 in Conferences, Legal Education, Scholarship | Permalink | Comments (0)

Thursday, February 13, 2014

Call for Tax Papers: University of Oxford

OxfordThe Oxford University Centre for Business Taxation has issued a call for papers for its annual symposium:

The symposium will take place at the Saïd Business School in Oxford, from Tuesday 24 – Friday 27 June, 2014. As ever, we welcome research on any topics related to business taxation in its broadest sense, including papers from economics, law and other disciplines, as well as interdisciplinary contributions. 

Submissions can be either completed but unpublished papers or extended abstracts (at least 2 pages) of work in progress that will be completed by the date of the conference. The deadline for submissions is 1 March 2014 and papers should be submitted using the electronic form.  

Selections will be completed, and invitations extended, by 15 March 2014.  

The programme will follow that of previous years; there will be a limited number of formal presentations, and plenty of time for informal interaction and private work, together with social events. This year we will also have two keynote presentations by Joel Slemrod (University of Michigan) and David Weisbach (University of Chicago).

Please forward this call to young scholars working in the area of business taxation. The author of the best paper presented by a young scholar will be awarded a prize. The only submission criterion for this section is that all authors of a paper must have gained their PhD within the last three years.

This year’s symposium convenor is John Vella. Please email John if you have any questions about the academic content of the symposium. If you have any questions regarding the logistics, please contact Clare.  

Accommodation will be organised for presenters and discussants, and the costs of accommodation, meals and social events will be met by the Centre. We have limited funds to reimburse travel costs, and we would like to target our support to participants who are unlikely to be able to attend without such help. If you need financial assistance with travel costs, then please make this known to us on the ‘additional info/comments’ section when you submit your paper/abstract.

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

Saturday, February 8, 2014

Love and Law Conference Today at Pepperdine

Love and Law 2I am delighted to be moderating a panel at today's conference on Love and Law at Pepperdine:

In a provocative essay, philosopher Jeffrie Murphy asks: "What would law be like if we organized it around the value of Christian love [agape]?" Agape love is love that is focused on the good of the other and is distinguished from other forms of love—from friendship, romance, and sexual love. Murphy notes that agape love is not simply concerned with making people's lives more pleasant--it is not "cuddly." If agape is the aim, a polity might "design legal practices and institutions with a view to the moral and spiritual improvement of affected citizens." Other theological and moral traditions also wrestle with the relationship between law and religious concepts of love, including Judaism's hesed and ahava, Islam's rahman, and Hinduism's kama.

The notion of law grounded in love has a rich history. Jesus summarized the Mosaic Law as love of God and neighbor. John Calvin said that all nations' laws "must be in conformity to that perpetual rule of love." Over the centuries groups have sought to ground law in love, to good and ill effect. The idea that law should be a manifestation of love stands in tension with modern and post-modern notions that law should be solely concerned with individual autonomy or efficiency or that law is by nature only a matter of power.

Law might bear several sorts of relationships to love. Love might be the motivation behind the work of lawyers, judges, legislators, police, and politically active citizens. The adoption and enforcement of wise laws can be among the most loving things that someone can do. It may also be that law can teach and encourage love.

The idea of law grounded in love generates numerous big questions which will be addressed throughout this conference by people from the fields of philosophy, political science, law, economics, theology, and literature.

I am moderating the panel today on Love and Law, Violence and Freedom (3:45  - 5:15 p.m.):

  • Jeff Baker (Pepperdine), Trifling Violence: The U.S. Supreme Court, Domestic Violence and a Theory of Love
  • David Dominguez (BYU), Turning Juvenile Detention Hearings into Community Healing: Why Settle for the Minimum of American Law When We Are Called to Fulfill God’s Justice?
  • Jim Gash (Pepperdine), Putting Agape into Action: How the Partnership between Pepperdine Law School and the Ugandan Judiciary Sets Juvenile Prisoners Free

Other speakers include:

February 8, 2014 in Conferences, Legal Education, Tax | Permalink | Comments (0)

Friday, February 7, 2014

TPC & USC Conference: Growing Income Inequality: Is Tax Policy the Cause, the Cure or Irrelevant?

USC

The Tax Policy Center and USC Gould School of Law host a conference today on Growing Income Inequality: Is Tax Policy the Cause, the Cure or Irrelevant? (flyer) beginning at 8:30 a.m. PST (free webcast):

Panel #1:  Measuring Inequality

Panel #2:  How The Tax System Fosters Inequality

Luncheon Keynote Address:  Ron Wyden (U.S. Senator, Oregon)

Panel #3:  Tax Policy or Fiscal Policy

Panel #4:  The Income Tax as an Anti-Poverty Tool

February 7, 2014 in Conferences, Tax | Permalink | Comments (0)

Wednesday, February 5, 2014

University of North Carolina 17th Annual Tax Symposium

UNC 2University of North Carolina Kenan-Flagler School of Business Seventeenth Annual Tax Symposium (Jan. 17-18, 2014):

February 5, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, February 3, 2014

TPC & USC Conference: Growing Income Inequality: Is Tax Policy the Cause, the Cure or Irrelevant?

USC

The Tax Policy Center and USC Gould School of Law host a conference on Growing Income Inequality: Is Tax Policy the Cause, the Cure or Irrelevant? (flyer) this Friday, February 7, 2014:

Panel #1:  Measuring Inequality

  • Moderator:  Paul Caron (Pepperdine)
  • Emmanuel Saez (UC-Berkeley), Income Concentration and Top Income Tax Rates
  • Scott Winship (Manhattan Institute), Has Income Inequality Risen, and If Yes, Between Whom?

Panel #2:  How The Tax System Fosters Inequality

  • Moderator:  Todd Molz (Managing Director and General Counsel, Oaktree Capital)
  • Leonard Burman & Eric Toder (Tax Policy Center), The Role of Capital Gains Tax Preferences in Generating Wealth and Income Inequality
  • Victor Fleischer (San Diego) & Steven Rosenthal (Tax Policy Center), How the Rich Get Richer through the Income Tax

Luncheon Keynote Address:  Ron Wyden (U.S. Senator, Oregon)

Panel #3:  Tax Policy or Fiscal Policy

  • Moderator:  Eric Zolt (UCLA)
  • Edward Kleinbard (USC), From Progressive Tax to Progressive Fiscal Systems
  • Donald Marron (Tax Policy Center), Can Distributional Analyses Combine Taxes and Spending?

Panel #4:  The Income Tax as an Anti-Poverty Tool

  • Moderator:  Ellen Aprill (Loyola-L.A.)
  • Miles Corak (University of Ottawa), Intergenerational Mobility: What Makes America Different?
  • John Colombo (Illinois), Using the Charitable Deduction to Stimulate Social Change 

February 3, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Friday, January 31, 2014

Call for Speakers: CALI Conference at Harvard Law School -- The Next Wave

CALI 2CALI has issued a call for speakers for law faculty, librarians, and IT staff (April 4 deadline) at its 24th Annual Conference for Law School Computing to be held Thursday, June 19 through Saturday June 21 at Harvard Law School. The theme of this year's conference is "The Next Wave":

CALI has been around for over 30 years. In that time, it has pioneered technology in legal education and in applications that improve access to justice and has worked with the innovators and early adopters in those fields. And now, excitingly, the next wave is here. Technology isn’t just something for hard core Teknoids. It’s become accessible and accepted in the law school and legal environments.

We know that you need to be looking out for the next wave. Much like waves constantly coming into shore, waves of change are constantly hitting legal education. How you approach them matters. To some people they may feel like tsunamis that are going to destroy everything and their inclination is to run and hide from them. Some people are going to hold fast and then be gradually eroded away and altered by the constant wave action. And some people are going to want to swim out to meet the waves and ride in on them on a surf board.

For 24 years, the CALI Conference has organized its schedule at nearly the last minute in order to bring the most relevant and up-to-date presentations to attendees. This year is no different and we are looking for law school faculty, librarians, and technologists with strong opinions, great ideas, interesting projects and useful advice. Come and share and be challenged. If you are willing and able to speak, your conference registration fee is just $95!

(Disclosure:  I am President of the CALI Board of Directors.)

January 31, 2014 in Conferences, Legal Education | Permalink | Comments (0)

Tuesday, January 28, 2014

California Bar Hosts 1st Annual Young Tax Lawyers Conference

California State BarThe State Bar of California hosts its First Annual Young Tax Lawyers Conference today:

Luncheon Address:  Karen L. Hawkins (Director of the IRS Office of Professional Responsibility)
Panels:
Practice Tips And War Stories From Tax Court
The Evolving Role of Young Lawyers in Modern Tax and Estate Planning
Ask the Director of the IRS Office of Professional Responsibility

(Hat Tip: Michael Wood.)

January 28, 2014 in Conferences, Tax | Permalink | Comments (0)

Monday, January 27, 2014

2014 USC Tax Institute

USC CoverThe three-day 2014 USC Gould School of Law Tax Institute kicks off today.  The keynote speakers are:

  • Monday:  Steven A. Bank (UCLA)
  • Tuesday:  Lawrence Gibbs (former IRS Commissioner; Miller & Chevalier, Washington, D.C.)
  • Wednesday:  Edward J. McCaffery (USC)

Other Tax Prof speakers include Richard Granat (Florida Coastal), Don Leatherman (Tennessee), Kevin Mohr (Western State), and Jeffrey Pennell (Emory)

January 27, 2014 in Conferences, Tax | Permalink | Comments (0)

Friday, January 24, 2014

ABA Tax Section Midyear Meeting

ABA Tax Section Logo (2012)The ABA Tax Section midyear meeting kicks off today in Phoenix. The full program is here. Tax Profs with speaking roles today include:

  • Bankruptcy & Workouts: Don Leatherman (Tennessee)
  • Current Developments: Alan Appel (New York Law School)
  • Diversity:  Sandy Freund (Rutgers-Newark)
  • Employee Benefits:  Kathryn Kennedy (John Marshall-Chicago)
  • Partnerships and LLCs:  Noel Brock (West Virginia)
  • Publications:  Alice Abreu (Temple)
  • S Corporations:  Robert W. Jamison (Indiana-Indianapolis)
  • Standards of Tax Practice and Teaching Taxation:  Peter Barnes (Duke), Linda Beale (Wayne State), Danshera Cords (Albany), Linda Galler (Hofstra),  Michael Hatfield (University of Washington), Mona Hymel (Arizona), Michael Lang (Chapman), Diane Ring (Boston College), Phyllis Smith (Florida A&M), Donald Tobin (Ohio State)
  • Tax Policy and Simplification:  Michelle Drumbl (Washington & Lee), Jonathan Forman (Oklahoma), Susannah Camic Tahk (Wisconsin)

January 24, 2014 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0)

Thursday, January 23, 2014

Call for Participants: Workshop on Historical Approaches to Fiscal Sociology

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

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

The workshop will be held on Wednesday, November 5th, in Toronto in conjunction with the annual meetings of the Social Science History Association (SSHA). Interested students will also have a chance to present their own work on Thursday, November 6th, as part of the SSHA conference.

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

Please submit materials via e-mail to the following three faculty conveners no later than February 21, 2014:
Monica Prasad, Department of Sociology, Northwestern University; and
Ajay Mehrotra, Maurer School of Law, Indiana University – Bloomington; and
Isaac Martin, Department of Sociology, UC-San Diego

January 23, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, January 22, 2014

Individual Tax Reform in a Time of Crisis

Tax ReformLuca Gattoni-Celli, Scholar Calls for 'Distributive Justice' in Charitable Tax Reform, 2014 TNT 13-7 (Jan. 21, 2014):

Tax subsidies for charitable giving need to be reformed with an eye toward "distributive justice," a tax law professor said at a conference on tax reform on January 17.

Miranda Perry Fleischer of the University of San Diego School of Law said the activities of charitable organizations should be examined to ensure they are benefiting the economically disadvantaged.

The discussion was part of a tax reform symposium in Malibu, Calif., organized by Pepperdine University School of Law and cosponsored by Tax Analysts. ...

Emory Law School professor Dorothy Brown cited research suggesting that racial minorities are adversely affected by the tax system. Pivoting from a study of her own that compared the Obamas' tax returns from 2000 through 2004 with tax return data from white taxpayers earning similar incomes, Brown focused on racial disparities in tax outcomes, saying middle-income African-Americans pay higher taxes on average than their economic peers.

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

January 22, 2014 in Conferences, Scholarship, Tax, Tax Analysts | Permalink | Comments (1)

Friday, January 17, 2014

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

Tax ReformPlease join us via free live webcast today (8:45 a.m. - 4:30 p.m. PST) for the Pepperdine/Tax Analysts Symposium on Tax Reform in a Time of Crisis.  You can Tweet questions for the panelists at #PeppTaxReform.

Keynote Address

  • Joe Bankman (Stanford), Tax Scholarship in a Time of Fiscal Crisis
  • Introduction:  Paul Caron (Pepperdine)
  • Commentary:  Ed Kleinbard (USC)

Panel #1:  Individual/Estate and Gift Tax Reform

  • Dorothy Brown (Emory), Barack and Michelle Obama: The Early Years
  • Miranda Fleischer (San Diego), Charity, Poverty, and Duty
  • Jim Repetti (Boston College), Revitalizing the Estate Tax: Five Easy Pieces (with Paul Caron (Pepperdine))
  • Commentary:  Nancy Staudt (USC)
  • Moderator:  Tom Bost (Pepperdine)

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

Panel #2:  Business/International Tax Reform

  • Karen Brown (George Washington), Addressing International Income Inequality in a Time of Crisis
  • Ruth Mason (Virginia), Exporting FATCA: International Enforcement in a Time of Crisis (with Josh Blank (NYU))
  • Richard Winchester (Thomas Jefferson), Carried Interest for the Common Man
  • Commentary:  Eric Zolt (UCLA)
  • Moderator:  Khrista Johnson (Pepperdine)

Panel #3:  Tax Reform in a Time of Crisis: Institutional Perspectives

  • Ellen Aprill (Loyola-L.A.), Nonprofits and Political Activity: Some Lessons From Other Countries
  • Donald Tobin (Ohio State), The 2013 IRS Crisis, Independent Organizations, and Proposed Regulation 1.501(c)(4)-1: Where Do We Go From Here?
  • George Yin (Virginia; former Chief of Staff, Joint Committee on Taxation), Reforming the IRS (to Save It)
  • Commentary:  Donald Korb (Partner, Sullivan & Cromwell; former IRS Chief Counsel)
  • Moderator:  Joe Thorndike (Tax Analysts)

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

January 17, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, January 10, 2014

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

Pepperdine Tax Symposium Brochure_Page_1Please join us in person (free registration required) or via free live webcast for the Pepperdine/Tax Analysts Symposium on Tax Reform in a Time of Crisis next Friday, January 17, 2014:

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)

January 10, 2014 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

Thursday, January 9, 2014

TPC & USC Conference: Growing Income Inequality: Is Tax Policy the Cause, the Cure or Irrelevant?

USC

The Tax Policy Center and USC Gould School of Law host a conference on Growing Income Inequality: Is Tax Policy the Cause, the Cure or Irrelevant? on Friday, February 7, 2014:

Panel #1:  Measuring Inequality

  • Moderator:  Paul Caron (Pepperdine)
  • Emmanuel Saez (UC-Berkeley), Income Concentration and Top Income Tax Rates
  • Scott Winship (Manhattan Institute), Has Income Inequality Risen, and If Yes, Between Whom?

Panel #2:  How The Tax System Fosters Inequality

  • Moderator:  Todd Molz (Managing Director and General Counsel, Oaktree Capital)
  • Leonard Burman & Eric Toder (Tax Policy Center), The Role of Capital Gains Tax Preferences in Generating Wealth and Income Inequality
  • Victor Fleischer (San Diego) & Steven Rosenthal (Tax Policy Center), How the Rich Get Richer through the Income Tax

Luncheon Keynote Address:  Ron Wyden (U.S. Senator, Oregon)

Panel #3:  Tax Policy or Fiscal Policy

  • Moderator:  Eric Zolt (UCLA)
  • Edward Kleinbard (USC), From Progressive Tax to Progressive Fiscal Systems
  • Donald Marron (Tax Policy Center), Can Distributional Analyses Combine Taxes and Spending?

Panel #4:  The Income Tax as an Anti-Poverty Tool

  • Moderator:  Ellen Aprill (Loyola-L.A.)
  • Miles Corak (University of Ottawa), Intergenerational Mobility: What Makes America Different?
  • John Colombo (Illinois), Using the Charitable Deduction to Stimulate Social Change 

January 9, 2014 in Conferences, Tax | Permalink | Comments (0)

Sunday, January 5, 2014

Today's AALS Annual Meeting Highlights

AALSToday's highlights at the AALS Annual Meeting in New York:

Presidential Workshop on Tomorrow’s Law Schools:  Economics, Governance and Justice (8:45 a.m. - 3:30 p.m.):

  • Leo P. Martinez (UC-Hastings) (welcome)
  • Carol A. Needham (Saint Louis) (introduction) 

Law School Administration and Finance:  Legal Education Affordability and the Responsibility of Law Schools (10:45 a.m. - 12:15 p.m.):

This session will be a panel discussion between faculty, administrators, and policy makers about whether legal education affordability should be a national issue and what might be the fiscal responsibilities of law schools from policy and practical perspectives.

  • Michael S Dean (Mercer) (co-moderator)
  • Jerome M. Organ (University of St. Thomas) (co-moderator)
  • Philip G. Schrag (Georgetown) (speaker)
  • James R. Silkenat (Sullivan & Worcester) (speaker)

Concurrent Session:  Law Professors of the Future: A New Balance of Teaching, Scholarship and Service? (12:15 - 1:45 p.m.):

If tomorrow’s law school will look different than today’s, the law professor of the future may look different as well. At many schools, the current model of a law teacher emphasizes scholarly training and ambition. The law professor of the future might be required to spend less time on scholarship and more on teaching. And if teaching is to be practice-oriented and skills-focused, the background required of an effective teacher may change as well. Further, if the characteristics required of a law professor continue to evolve, pressure to modify or eliminate the system of academic tenure may continue to grow. This session will examine whether and how the law professor of the future will differ from the current model of the legal educator.

  • Nora V. Demleitner (Washington & Lee) (speaker)
  • Meera Deo (Thomas Jefferson) (speaker)
  • Judith A. McMorrow (Boston College) (speaker)
  • Thomas D. Morgan (George Washington) (moderator)
  • Rebecca H. White (Georgia) (speaker)

Concurrent Session:  Technology in Legal Education (12:15 - 1:45 p.m.):
This session will focus on the various ways in which technology is changing the nature of practice and the delivery of legal instruction.

  • Deborah W. Post (Touro) (speaker)
  • Rebecca Purdom (Vermont) (speaker)
  • Tanina Rostain (Georgetown) (speaker)
  • Carole Silver (Northwestern) (moderator)
  • Ronald W. Staudt (Chicago-Kent) (speaker)

Section on Taxation Program:  Tax Reform and the Legislative Process (2:00 - 3:45 p.m.):
“Broaden the base and lower the rates.” The mantra of the 1986 Tax Reform Act was a unifying principle that yielded a broadly bi-partisan legislative process in a time of a divided Congress and a polarizing president. Today, the Congress is again divided, perhaps more so than in 1986. The legislative process has changed too. Committee Chairs have ceded more power to Congressional leadership and markups of tax legislation are less frequent. If tax reform is to take root, what sort of a legislative process will emerge? Who will make the key decisions? Who will represent the Executive branch within the Congress? How will the Ways and Means and Finance Committees work across the aisle and across the Capitol? What role will the revenue estimating staff play? Perhaps most importantly, how will the substantive areas of tax reform be addressed in the process? This panel will examine the current legislative process for tax reform, touching on areas affecting corporate and individual taxpayers and exempt organizations.

  • Roger Colinvaux (Catholic) (speaker)
  • David Kamin (NYU) (speaker)
  • Rebecca Kysar (Brooklyn) (speaker)
  • Leandra Lederman (Indiana) (moderator)
  • Clarissa Potter (AIG) (speaker)
  • George K. Yin (Virginia) (speaker)

Update:  Chronicle of Higher Education, Educators Make the Case for Going to Law School

January 5, 2014 in Conferences, Legal Education, Tax | Permalink | Comments (0)

Saturday, January 4, 2014

Today's AALS Annual Meeting Highlights

AALSToday's highlights at the AALS Annual Meeting in New York:

Plenary Session:  Rank Amateurs?  New Alternatives to the U.S. News Law School Ranking (9:00 a..m. - 10:15 a.m.):
Over the last three decades, the highly influential ranking of law schools by U.S. News & World Report has spawned many proponents and detractors. A number of recent attempts have been made to provide different kinds of comparisons of law schools, including The National Law Journal’s Go-To Law Schools and other employment-related lists, as well as other student-oriented rankings this year from Above the Law and National Jurist. Our panelists will discuss whether these rankings provide useful perspectives for prospective law students and others, and how they could be improved. Ample time will be set aside for panelists to answer questions from the audience.

  • Charles G. Cannon (UC-Irvine) (moderator)
  • Katrina Dewey (Lawdragon) (speaker)
  • Dimitra Kessenides (Bloomberg BNA) (speaker)
  • Robert Morse (U.S. News & World Report) (speaker)
  • Elie Mystal (Above the Law) (speaker)
  • Karen Sloan (National Law Journal) (speaker)

Plenary Session:  Crystal Ball:  What Does the Future Have in Store? (2:00 - 3:15 p.m.):
For the past few years, legal education has been under constant attack for being too expensive and for not preparing graduates for the changing legal profession. As a result, applications have plummeted and prospective benefactors including alumni are questioning the value of their support for our institutions. The panelists will share their views on how we can create positive messages as we reach out to prospective donors and applicants alike.

  • Erwin Chemerinsky (UC-Irvine) (speaker)
  • Austen L. Parrish (Indiana) (speaker)
  • Julia A. Yaffee (Santa Clara) (moderator) 

Wall Street Journal, Law 2014: Paring Back at U.S. Law Schools Continues:

It’s been some tough sledding for law schools in recent years, as enrollment plummets and recent graduates scramble to land legal jobs.

This week legal educators are gathering in New York to discuss those topics and more at the annual meeting of the Association of American Law Schools. On the docket: the myriad challenges law schools face, and the steps some are taking to adjust — including experiments with how law is taught, and who teaches it.

January 4, 2014 in Conferences, Law School Rankings, Legal Education, Tax | Permalink | Comments (0)

Friday, January 3, 2014

Today's AALS Annual Meeting Highlights

AALSToday's highlights at the AALS Annual Meeting in New York:

AALS Hot Topic/Bridge Program:  After the JD: A Look at the Evolving Careers of Lawyers Who Entered Practice in 2000 (8;30 - 10:15 a.m.):
This session will report on the results of the third wave of the After the J.D. longitudinal study. It will assess career progress of the cohort of lawyers who began their careers in 2000. We address questions about how much mobility has occurred; how incomes and practice settings have changed over the 12 years; dimensions of stratification in the legal profession; impacts of race, ethnicity and gender; the management of debt; and career satisfaction as it relates to the other categories.

The relevance of the research has increased over the course of the three waves of the study. In particular, the question of the value of a law degree has become a subject of intense debate in the media and in the legal profession. The AJD Project provides the only longitudinal information on debt, how lawyers have paid down debt, and its impact on their lives. The third wave also provides unique data on the impact of the economic downturn on this cohort of lawyers. This would be the first formal release of the Wave 3 AJD Report, and we think that the topic fits the call for “hot topics”, since it is very relevant to schools rethinking their curriculum and approaches to legal education in the face of the continuing decline of applicants to law schools.

  • Ronit Dinovitzer (Toronto) (speaker)
  • Bryant G. Garth (UC-Irvine) (speaker)
  • William D. Henderson (Indiana) (discussant)
  • Lynn Mather (SUNY-Buffalo) (discussant)
  • Lauren K. Robel (Indiana) (discussant)
  • Joyce S. Sterling (Denver) (moderator) 

ABA Section of Legal Education and Admissions to the Bar Program:  Workshop on Innovation in Legal Education: Likely New Approach to Variances and Room for Innovation Within the Standards (10:30 - 11:30 a.m.):
Law schools should constantly be considering how to improve their legal education programs. The ABA Standards for the Approval of Law Schools are often cited as one, or a primary, reason that schools do not innovate. This program will consider ways in which the Standards constrain innovation and the considerable room they allow for innovation. Moreover, while it is not possible to predict whether the Accreditation Committee or Council of the Section would approve a particular request for a variance, this workshop will explain how the variance process works, where it is likely headed, and offer guidance on how to seek a variance.

  • Catherine L. Carpenter (Southwestern) (moderator and speaker)
  • Scott F. Norberg (ABA Section on Legal Education and Admissions to the Bar) (speaker)
  • Frank H. Wu (UC-Hastings) (speaker)
  • David N. Yellen (Loyola-Chicago) (speaker)

Section on Scholarship Program:  Legal Scholarship Beyond the Law Review:  Books, Briefs, Letters, and Other Avenues of Influence (1:30 - 3:15 p.m.):
Many law professors publish exclusively or primarily in law reviews. Others make different choices and author books, write essays, draft amicus briefs, prepare comment letters to regulators, or blog. Some do a combination of the above. Panelists will discuss why they have chosen to disseminate their ideas outside of the conventional law review format. Why write a book? What kind of scholarship is more appropriate for a book as opposed to a series of articles? When should one try to draft an amicus brief, or prepare a comment letter to a regulator? The panel will be asked to discuss choices they have made in deciding how they disseminate their ideas and try to influence lawyers, colleagues, policy-makers and others.

  • Douglas A. Berman (Ohio State) (speaker)
  • Matthew T. Bodie (Saint Louis) (speaker)
  • Michelle Dempsey (Villanova) (moderator)
  • Mary L. Dudziak (Emory) (speaker)
  • Greg Lastowka (Rutgers-Camden) (speaker)

Section on Taxation Program:  Now You See It, Now You Don’t:  Salience in Taxation (3:30 - 5:15 p.m.):
The tax law and scholars who study it often operate under the assumption that taxpayers behave rationally. Yet, as legislators seem to know, often we do not. One cognitive failure that influences the scope and shape of taxes is our tendency to fixate on some facts while ignoring others. For example, employer withholding of taxes from an employee's salary should make the tax no less burdensome than if it were paid directly by the employee. Nevertheless, some taxpayers who didn’t seek excess withholding to force savings irrationally celebrate the receipt of a federal or state tax refund as if it were a windfall. Similarly, shoppers react differently to posted prices that include or don’t include sales tax, even though the total cost of the item is the same. The panel will consider the systemic implications of tax salience (and its absence) on both tax policy and the tax system’s regulatory functions.

  • Steven A. Dean (Brooklyn) (moderator)
  • Brian D. Galle (Boston College) (speaker)
  • David Gamage (UC-Berkeley) (speaker)
  • Andrew Hayashi (Virginia) (speaker)
  • Leigh Osofsky (Miami) (speaker)

January 3, 2014 in Conferences, Tax | Permalink | Comments (0)

Monday, December 30, 2013

Columbia and Hebrew University Host Conference Today on Taxation and Public Policy

ConfereceColumbia Law School and Hebrew University Faculty of Law host a conference today on Taxation and Public Policy:

Session #1:  Chair:  Yoram Margaliot (Tel Aviv University Faculty of Law)

Session #2:  Chair: Ilan Benshalom (Hebrew University Faculty of Law)

December 30, 2013 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, December 19, 2013

Tax Panel at Today's Israeli Law & Society Association Annual Conference

Tax panel at today's Israeli Law and Society Association Annual Conference on Communities & Borders in Israel and the Global World:

From Local to Global: Tax Policy & Society in the 21th Century:

December 19, 2013 in Conferences, Poll, Tax | Permalink | Comments (0)