TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Wednesday, January 17, 2018

Merritt:  Faculty Salaries And The Extraordinary Cost Of Research At A Top 25 Law School

Merritt (2018)TaxProf Blog op-ed:  Salaries and Scholarship, by Deborah J. Merritt (Ohio State):

Law professors teach a wide variety of subjects: Property, Civil Procedure, Legal Writing, Law & Economics, Business Associations,  Feminist Legal Theory, Law Clinics. Professors bring diverse backgrounds to this teaching. Some hold JDs, some hold PhDs, some hold both. Some have practiced law, while others have not. Some earned high salaries before joining a law faculty, while others drew more modest paychecks in government, legal aid, nonprofits, or other academic fields.

Despite this variety, there is one constant: professors who focus their teaching on legal writing or clinical courses earn significantly less money than those who teach other types of classes. This is true regardless of degrees, prior professional experience, or past salary level. What explains this pay gap? And what does the gap tell us about our values in legal education?

Before answering those questions, we have to understand the size of the gap. Academics shy away from salary discussions, but silence can hide inequity. To break that silence, I have been gathering information from salary databases released by public universities. I don’t have information on every public law school, but a surprising amount of data is available.

In this post, I will refer to salaries at one leading law school. US Newsranks this school among the top 25 schools nationally, and it is a clear leader in legal education. The salaries at this school, which I’ll call the Myra Bradwell College of Law, do not reflect salaries at every law school. They do, however, illustrate the type of salary gap our schools maintain between professors who teach clinics/legal writing and those who teach other subjects.*

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January 17, 2018 in Legal Education, Scholarship | Permalink | Comments (3)

Christians: Trust In The Tax System — The Problem Of Lobbying

Building TrustAllison Christians (McGill), Trust in the Tax System: The Problem of Lobbying, in Building Trust in Taxation (Bruno Peeters, Hans Gribnau, Jo Badisco ed., 2017):

Fairness in the tax system seems unachievable when the well-advised free-ride on the many benefits of an organized global economy paid for by tax revenues extracted from others. While those publicly accused of ‘tax-dodging’ point to their full compliance with all applicable laws, they are substantially less forth-coming about their efforts to influence the shape of the law to their own benefit. All too often, tax policy appears to respond primarily to those with the resources to influence the policy-makers. As the system becomes increasingly unresponsive to legitimate policy goals and increasingly out of touch with justice — perceived and actual — public perceptions about the system understandably trend toward the cynical.

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January 17, 2018 in Scholarship, Tax | Permalink | Comments (0)

The Ethics Of Baiting And Switching In Law Review Submissions

BaitRyan Scoville (Marquette), The Ethics of Baiting and Switching in Law Review Submissions, 101 Marq. L. Rev. ___ (2018):

Sometimes the authors of law review articles engage in a bait-and-switch: they insert exaggerated claims of novelty or significance into their submission to student editors, and then, after securing a satisfactory offer of publication, moderate those claims in drafts made available to colleagues and the public. By doing so, the authors manage to improve their chances at a desirable placement and avoid unscholarly claims before peers.

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January 17, 2018 in Legal Education, Scholarship | Permalink | Comments (0)

Baker & Raskolnikov: Harmful, Harmless, And Beneficial Uncertainty In Law

Scott Baker (Washington University) & Alex Raskolnikov (Columbia), Harmful, Harmless, and Beneficial Uncertainty in Law, 46 J. Legal Stud. 281 (2017):

This article examines the impact of four types of law-related uncertainty on the utility of risk-neutral agents. We find that greater legal or factual uncertainty makes agents worse off if enforcement is targeted (which means that greater deviations from what the law demands lead to a greater probability of enforcement) or if sanctions are graduated (which means that greater deviations from what the law demands result in higher sanctions). In contrast, agents are indifferent to changes in uncertainty about detection induced by variation in enforcement resources or to changes in uncertainty about sanctions arising from legally irrelevant factors. Finally, risk-neutral agents benefit from greater legal uncertainty if they act only on preapproval by a cautious regulator.

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January 17, 2018 in Scholarship, Tax | Permalink | Comments (0)

Tuesday, January 16, 2018

Prasad Presents Anti-Tax America: The Origins Of Our National Obsession With Tax Cuts Today At Georgetown

PrasadMonica Prasad (Northwestern) presents Anti-Tax America: The Origins of Our National Obsession with Tax Cuts, 24 J. Pol'y Hist. 351 (2012), at Georgetown today as part of its Tax Law and Public Finance Workshop Series hosted by Lilian Faulhaber and Itai Grinberg:

The debt when Reagan entered office was just over $900 billion, not historically high in constant dollars or as a percent of GDP, but by the time Reagan left office it had almost tripled in nominal terms, and in percent of GDP it had gone from 33.4 percent to 51.9 percent. At the end of his term, the debt stood at $2.6 trillion, with a substantial portion of it contributed by Reagan's own policies: a mountain over 160 miles high in loose or tight bricks.

The irony is that the policy that accelerated the growth of that debt was the very policy Reagan was promoting in that first address, the Economic Recovery Tax Act of 1981 (ERTA). This tax cut remains the largest tax cut in American history. Of course, spending increases were also necessary to the creation of the new mountain of debt, but spending has increased many times over the course of the century. What was historically new was the policy of not raising taxes to match those spending increases.

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January 16, 2018 in Colloquia, Scholarship, Tax | Permalink | Comments (1)

Leiserson Presents Dynamic Scoring And Optimal Taxation Today At NYU

GregGreg Leiserson (Washington Center for Equitable Growth) presents Removing the Free Lunch from Dynamic Scores: Reconciling the Scoring Perspective with the Optimal Tax Perspective at NYU today as part of its Tax Policy Colloquium Series hosted by Lily Batchelder and Daniel Shaviro:

Conventional estimates of the revenue effects of proposed tax legislation assume that the legislation would not change macroeconomic aggregates such as output, the capital stock, and employment. Dynamic estimates relax this assumption and—in the emerging consensus approach—replace it with two alternative assumptions. First, the macroeconomic analysis supporting dynamic estimates assumes future policy changes sufficient to address the fiscal imbalances that exist in CBO’s current-law baseline. These changes are assumed to take effect after the period for which economic results are reported. Second, in many but not all cases, the analysis assumes additional future policy changes that offset any change in the government’s present value fiscal position that the proposed legislation would cause, again taking effect after the period for which results are reported.

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January 16, 2018 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Muller: The Rise And Fall Of My Use Of Twitter

TwitterFollowing up on Friday's post, Law Profs: Beware The Perils Of Twitter:  Derek Muller (Pepperdine), The Rise and Fall of My Use of Twitter:

I have found that the reward from "status" on Twitter is simply not great. For journalism, it remains, sadly, nearly ubiquitous. A majority of media inquiries now start from a tweet; indeed, a non-trivial number of media mentions fail to even inquire of me and simply (lazily) cite my tweet. Using Twitter less means fewer citations in journalists' pieces, but such is the tradeoff. Furthermore, I've found that a lot of media now focuses on what people say on Twitter, and then how others react to those statements on Twitter—a deeply meta, and often, I think, deeply superficial way of thinking about newsworthiness.

Furthermore, I've watched a number of law professors (and others) lose a significant amount of their credibility (in my eyes, at least, and I think, to some degree, in the eyes of at least some others) by succumbing to the allure of fleeting social media fame. It moves beyond branding into a quasi-celebrity status. It's something that I want to separate myself from. ...

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January 16, 2018 in Legal Education | Permalink | Comments (0)

Taite: A Critical Analysis Of The Capital Gains Tax Preferences

Phyllis Taite (Florida A&M), Saving the Farm or Giving Away the Farm: A Critical Analysis of the Capital Gains Tax Preferences, 53 San Diego L. Rev. 1017 (2016):

Over the years the topic of capital gain preferences has been thoroughly debated. Discussions range between whether the tax rates on capital gains should be raised, reduced, or repealed. Other discussions have centered on whether capital gains has an effect on the economy, and if so, how the research supports those assertions. It would be difficult to cover all aspects of the issues associated with capital gains taxes in one article; therefore this discussion will focus on capital gains as applied to individual income taxes.

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January 16, 2018 in Scholarship, Tax | Permalink | Comments (0)

The Tyranny Of Metrics: 'Not Everything That Is Important Is Measurable, And Much That Is Measurable Is Unimportant'

MetricsWall Street Journal:  A Cure for Our Fixation on Metrics, by Jerry Z. Muller (Catholic University; author, The Tyranny of Metrics (Princeton University Press 2018)):

Measuring results is all the rage in organizations, but it is often wrongheaded and counterproductive.

In recent decades, what I call “metric fixation” has engulfed an ever-widening range of institutions: businesses, government, health care, K-12 education, colleges and universities, and nonprofit organizations. It comes with its own vocabulary and master terms. It affects the way that people talk and think about the world and how they act in it. And it is often profoundly wrongheaded and counterproductive.

Metric fixation consists of a set of interconnected beliefs. The first is that it is possible and desirable to replace judgment with numerical indicators of comparative performance based on standardized data. The second is that making such metrics public (transparency) assures that institutions are actually carrying out their purposes (accountability). Finally, there is the belief that people are best motivated by attaching rewards and penalties to their measured performance, rewards that are either monetary (pay for performance) or reputational (rankings).

But not everything that is important is measurable, and much that is measurable is unimportant. Most organizations have multiple purposes, and that which is measured and rewarded tends to become the focus of attention, at the expense of other essential goals.

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January 16, 2018 in Book Club, Legal Education | Permalink | Comments (3)

Updated Analysis Of Law School Attrition Data — 2018

In October 2015 and February 2016, I posted blogs discussing attrition rates between 2010 and 2014, and 2010 and 2015, respectively. With the release of the 2017 Standard 509 reports in December, I now have compiled attrition data from all of the fully-accredited ABA law schools outside of Puerto Rico for the last seven years, through 2016-17. I have calculated average attrition rates for the class as a whole and then broken out average attrition rates by law schools in different median LSAT categories – 160+, 155-159, 150-154 and <150. (Earlier this month, Brian Tamanaha noted that there are 14 law schools that have non-transfer attrition rates in the 2016-17 academic year in excess of 20%, the threshold set forth in Interpretation 501-3 which the Council for the Section of Legal Education and Admissions to the Bar adopted early in 2017.)

This blog reports that overall first-year non-transfer attrition increased each year until the 2016-17 academic year, going from 5.81% to 7.33% through 2015-16, before dropping back to 6.46% in 2016-17. This overall increase, however, results largely from increases in non-transfer attrition among schools with a median LSAT less than 150, as the non-transfer attrition rates for law schools with a median LSAT of 150 or greater have generally been in a downward trend over this period. Interestingly, one point reflected in this data is the inverse relationship between median LSAT category and attrition rates. “Academic attrition” rates increase significantly as median LSAT of law schools decreases; for four of the last five years, “other attrition” rates also increase as median LSAT decreases. 

The decline in non-transfer attrition in 2016-17 is noteworthy given that it is the first decline in non-transfer attrition in the last several years.  Notably, one significant contributor to the decline in non-transfer attrition in 2016-17 was the exclusion of Charlotte from the calculations given its closure.  (For example, had Charlotte not been included in the 2015-16 non-transfer attrition calculations, the overall non-transfer attrition rate for 2015-16 would have been 6.96% rather than 7.33%.)  That said, even taking into account the "Charlotte" factor, 2016-17 still shows the first decline in overall non-transfer attrition in the last several years.

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January 16, 2018 in Jerry Organ, Law School, Legal Education | Permalink | Comments (0)

Consumer Law As Tax Alternative

Rory Van Loo (Boston University), Consumer Law As Tax Alternative:

The law and economics paradigm has traditionally emphasized tax and transfer as the best way to achieve distributional goals. This Article explores an alternative. Well-designed consumer laws—defined as the set of consumer protection, antitrust, and entry barrier laws that govern consumer transactions—can make markets more efficient and lessen inequality.

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January 16, 2018 in Scholarship, Tax | Permalink | Comments (0)

TaxProf Blog Holiday Weekend Roundup

Monday, January 15, 2018

Leviner Presents Public Opinion And Tax Justice Today At Hebrew University

Leviner (2018)Sagit Leviner (Ono Academic College) presents In the Eye of the Beholder: Public Opinion on Tax Justice at Hebrew University today as part of its Forum for Tax Law:

The tax system is one of the most influential of civic institutions of our time. Taxes often detract at least one third of our income and they present an immediate and consequential effect with respect to a broad array of actions we make daily, when we choose to get married, have kids, go to college, or buy a loaf of bread. And, even though tax cuts and reforms are accordingly appealing to many people, it is worth taking time to ponder over the consequences of such cuts and reforms.

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January 15, 2018 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

NY Times: An Einstein For The Subway? A Lawyer — 'B' Student At BU Law School — Suggests A ‘Genius’ Fix

GeniusNew York Times, An Einstein for the Subways? A Lawyer Suggests a ‘Genius’ Fix:

It has been about a month since Craig Avedisian was declared an almost-genius, a finalist in a “genius challenge” contest with a $1 million prize. Whatever else is going on in the right and left hemispheres of his brain, the designation has not sunk in yet, he said.

“Here’s a guy, a solo lawyer, who thought he had an idea, and I got this far,” he said. “It was David versus Goliath, and David got heard. That’s the essence of it.”

Mr. Avedisian, 54, is not one of those a disheveled-looking Nobel Prize types who has tramped around an Ivy League campus the way Albert Einstein or John F. Nash Jr., of “A Beautiful Mind,” did. He is tallish and looks trim in a dark suit, a crisp white shirt and a carefully knotted tie. A commercial litigator, he lives on the Upper East Side of Manhattan. ...

Other measures of exceptionalness? He said he did not know his I.Q. He said he had a B average in law school.

But then, he is only an almost-genius. For now. Maybe he will win the contest and become a full-fledged genius.

He reached his current status because of an idea he submitted when the Metropolitan Transportation Authority announced the “genius challenge” last summer, a few days after Gov. Andrew M. Cuomo declared a state of emergency for the city’s failing subway system. By the agency’s count, Mr. Avedisian’s was one of 438 entries from 23 countries. ...

Mr. Avedisian ... said his idea could expand capacity on subway trains by 40 percent on average and by 65 percent on some trains. He called it “simple” and “user-friendly.” ...

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January 15, 2018 in Legal Education | Permalink | Comments (14)

Lesson From The Tax Court: What Are They Thinking?

Tax Court (2017)I tell my students to be careful with personal pronouns, especially now that the pronoun “they” may properly refer to a singular antecedent. An unclear antecedent can confuse readers.

Today I may have confused you. When you read this post's title, you may have thought “they” refers to “Tax Court.” Maybe you thought this would be a critique of a Tax Court opinion like last week’s post. It’s not. Sorry.

The “they” in the title is deliberately ambiguous, however, because it points to two different antecedents, neither being the Tax Court. First, it points to three taxpayers whose cases were decided last week by the Tax Court. Each case has at least one fact that is so amazing it will leaving you shaking your head (or "SMH" in modern texting parlance) and asking yourself “what were they thinking.”

Second, “they” means Congress. For the past 8 years Congress has adopted a policy of “starving the beast” and forcing the IRS to reduce its workforce. I wrote about that a couple of years ago here. These cases teach us why that Congressional policy is a thoughtless one. 

Each of these three cases shows an educated middle-class taxpayer trying to game the tax system in ways that require significant human resources to combat. In two cases it took human IRS employees to spot the games and defeat them. In the third case, the taxpayer is “winning” his game, at least temporarily, thanks to the Collection Due Process provisions. It will likely take significant additional human effort to collect this taxpayer’s unpaid tax liabilities.

More below the fold.

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January 15, 2018 in Bryan Camp, New Cases, Tax, Tax Practice And Procedure | Permalink | Comments (2)

Group Pushes For New Texas Public Law School In El Paso

El PasoFollowing up on my previous post, Texas Legislators Push For New Public Law School In The Rio Grande Valley Because 'Everybody Has A Law School':  KFOX14, Group of El Pasoans Continue Fight to Bring Law School to the Borderland:

A group of El Pasoans is fighting to bring a law school to the Borderland.

The El Paso Law School Initiative was formed in August 2016 to begin the process of bringing a law school to the Sun City. ...

The El Paso Law School Initiative met Saturday morning to continue efforts to bring a law school to El Paso. They’ve met multiple times over the past year and a half.

In that time, they’ve managed to get some substantial backing from Texas lawmakers. ...

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January 15, 2018 in Legal Education | Permalink | Comments (3)

Sunday, January 14, 2018

The Key To Success Is Not Talent Or Hard Work, But Instead Pruning Your Tasks And Excelling In What's Left On Your Plate

Great at WorkWall Street Journal:  The Key to Success? Doing Less, by Morten T. Hansen (UC-Berkeley; author, Great at Work: How Top Performers Do Less, Work Better, and Achieve More (2018)):

Talent and hard work are important, but most top performers in business have one thing in common: they accept fewer tasks and then obsess over getting them right.

Most Americans work impossibly hard. We put in long hours and maximum effort, but better performance often eludes us. ...

The knee-jerk answer to what distinguishes great performers from others is simple: talent. Social scientists and management experts explain performance at work by pointing to people’s innate gifts and natural strengths. How often have you heard phrases such as “She’s a natural at sales” or “He’s a brilliant engineer”? These talent-based explanations deeply influence our perceptions of what makes for success.

Are they right? Some experts say no, arguing that an individual’s sustained effort is just as critical as talent or even more so in determining success. According to this view, people perform well because they work hard and put in long hours. They end up doing more, taking on many assignments and running to lots of meetings.

But neither of these arguments ... explain[ed] the performance differences I had observed between equally hardworking and talented people.

In 2011, I decided to try to answer the question of why some people outperform others. I recruited a team of researchers with expertise in statistical analysis and began generating a set of hypotheses about which specific behaviors lead to high performance. We then conducted a five-year survey of 5,000 managers and employees, including sales reps, lawyers, actuaries, brokers, medical doctors, software programmers, engineers, store managers, plant foremen, nurses and even a Las Vegas casino dealer.

The common practice we found among the highest-ranked performers in our study wasn’t at all what we expected. It wasn’t a better ability to organize or delegate. Instead, top performers mastered selectivity. Whenever they could, they carefully selected which priorities, tasks, meetings, customers, ideas or steps to undertake and which to let go. They then applied intense, targeted effort on those few priorities in order to excel. We found that just a few key work practices related to such selectivity accounted for two-thirds of the variation in performance among our subjects. Talent, effort and luck undoubtedly mattered as well, but not nearly as much.

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January 14, 2018 in Book Club, Legal Education | Permalink | Comments (2)

Will Law Firm Partners In L.A. & NYC Move To Their Firms' Houston Or Miami Offices Because Of The New Tax Law?

Mark Herrmann (Vice President & Deputy General Counsel, Aon), Predictions For 2018 And Beyond: Taxes, M&A, Cordray For Veep, Etc.:

I considered predicting that, in 2018, a surprising number of partners would move from the New York, Chicago, San Francisco, and LA offices of big firms to those firms’ Houston or Miami offices. Here’s why:  As David Lat has noted, the new tax law will dramatically raise the taxes of rich law firm partners who live in states with high state and local taxes. (Those partners can currently deduct state and local taxes on their federal returns. Under the new law, that deduction is capped at $10,000. Partners who are making two or three million bucks (or more) a year are paying a lot more than $10,000 in state and local taxes, so their tax bill is going way up.)

How do you fix that? If you work at a firm with multiple offices, and if you have a national practice, move to an office located in a state with no income tax! Houston or Miami, here I come!

But, no. First, you’d have to take another bar exam if you moved — neither Texas nor Florida offers reciprocity. But Tennessee! Open an office in Memphis or Nashville, waive into the bar, and take advantage of extraordinarily low state taxes!

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January 14, 2018 in Tax | Permalink | Comments (4)

Zelinsky: Taxation And Religion In 2018 — The Parsonage Allowance And The Johnson Amendment

Edward A. Zelinsky (Cardozo), Taxation and Religion in 2018:

2018 will be an interesting year for those concerned about the intersection of taxation and religion. Two important issues – the constitutionality of the parsonage allowance and the future of the Johnson Amendment – are primed for further controversy in the year ahead.

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January 14, 2018 in Tax, Tax Policy in the Trump Administration | Permalink | Comments (0)

The Top Five New Tax Papers

SSRN LogoThere is a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with a new paper debuting on the list at #2. The #1 paper is #1 and the #2 paper is #2 among 13,309 tax papers in all-time downloads (see Brian Leiter (Chicago), 11 Tax Profs Blow Up The SSRN Download Rankings).

  1. [44,130 Downloads]  The Games They Will Play: Tax Games, Roadblocks, and Glitches Under the New Legislation, by Ari Glogower (Ohio State), David Kamin (NYU), Rebecca Kysar (Brooklyn) & Darien Shanske (UC-Davis) et al.
  2. [29,508 Downloads]  The Games They Will Play: An Update on the Conference Committee Tax Bill, by Ari Glogower (Ohio State), David Kamin (NYU), Rebecca Kysar (Brooklyn) & Darien Shanske (UC-Davis) et al.
  3. [574 Downloads]  The Senate Introduced a Pragmatic and Geopolitically Savvy Inbound Base Erosion Rule, by Itai Grinberg (Georgetown)
  4. [573 Downloads]  Tax Reform: Process Failures, Loopholes and Wealth Windfalls, by Stephen Shay (Harvard)
  5. [382 Downloads]  Once More, with Feeling: The 'Tax Cuts and Jobs' Act and the Original Intent of Subpart F, by Reuven Avi-Yonah (Michigan) & Nir Fishbien (S.J.D. 2018, Michigan)

January 14, 2018 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Saturday, January 13, 2018

This Week's Ten Most Popular TaxProf Blog Posts

Seton Hall's Innovative Weekend J.D. Program

Seton Hall 4Following up on my previous post, Loyola-Chicago, Mitchell|Hamline, And Seton Hall Offer Weekend J.D. Programs:  David Frakt, An Innovative Part-Time Program at Seton Hall:

Recently, I raised questions about whether some schools might be exploiting their part-time students, noting that at many law schools, the admissions credentials for part-time students were far lower than for their full-time students, in some cases, dipping dangerously into the high-risk pool of applicants.

Seton Hall was one of the schools that I identified that had a large disparity in the quality of their full-time and part-time classes.  While Seton Hall had very respectable numbers for their full-time entering class in 2016 (LSAT 75/50/25 of 161/157/155),  their 2016 part-time class was not nearly as strong, at 155/150/147.  UGPAs were also much lower:  3.69/3.40/3.07 for full-time vs. 3.46/3.13/2.95.  This was a consistent pattern at Seton Hall for the past several years.

After my column, I learned that for the 2017 entering class Seton Hall had changed the structure of their part-time program from an evening program to a weekend program. ...

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January 13, 2018 in Legal Education | Permalink | Comments (1)

NY Times: A Swiss Banker Helped Americans Dodge Taxes. Was It A Crime?

New York Times, A Swiss Banker Helped Americans Dodge Taxes. Was It a Crime?:

Diane Butrus, a business executive from St. Louis, wandered the streets of Zurich, looking for a bank that would help her keep $1.5 million hidden from America tax collectors.

One bank after another turned her down on that afternoon in 2009. They were worried about a United States crackdown on tax evasion and were no longer willing to shelter American money.

Finally, across the street from a city park, up a discreet elevator, seated in a luxurious conference room, Ms. Butrus found a banker ready to help. His name was Stefan Buck.

Mr. Buck said that his employer, Bank Frey, would be happy to take Ms. Butrus’s money, according to court documents and interviews with Mr. Buck and Ms. Butrus. He instructed her to wire the $1.5 million to Bank Frey. He told her that her name wouldn’t be attached to the new account. It would be known internally as Cardinal, an alias she chose in a nod to her favorite baseball team.

After that, Ms. Butrus contacted Mr. Buck via prepaid cellphones she picked up at a Walgreens drugstore. Every six months or so, she flew to Zurich to withdraw money directly from Mr. Buck. She would return to the United States secretly carrying just under $10,000 in cash — the cutoff for having to make a customs declaration.

The setup allowed Ms. Butrus to avoid paying tens of thousands of dollars in income taxes. And it wouldn’t have been possible without Mr. Buck and Bank Frey.

As much as chocolate and watches, Switzerland is known for bank secrecy. That made the country a destination for money that the wealthy wanted to hide. Last decade, it also made Swiss banks targets for an assault by the United States government, which was tired of Americans escaping taxes on money in offshore accounts.

Many banks came clean, divulging their clients to American authorities. Many Americans, including Ms. Butrus, searched for new places to park their money.

Bank Frey was among the very few to defy the legal onslaught. And Mr. Buck, a clean-cut and self-confident 28-year-old at the time he met Ms. Butrus, was the bank’s public face, responsible for landing and then managing American accounts.

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January 13, 2018 in IRS News, Scholarship, Tax | Permalink | Comments (0)

Lipman: (Anti)Poverty Measures Exposed

Florida Tax Review  (2015)Francine J. Lipman (UNLV), (Anti)Poverty Measures Exposed, 21 Fla. Tax Rev. 256 (2017):

Few economic indicators have more salience and pervasive financial impact on everyday lives in the United States than poverty measures. Nevertheless, policymakers, researchers, advocates, and legislators generally do not understand the details of poverty measure mechanics. These detailed mechanics shape and reshape poverty measures and the too often uninformed responses and remedies. This Article will build a bridge from personal portraits of families living in poverty to the resource allocations that failed them by exposing the specific detailed mechanics underlying the Census Bureau’s official (OPM) and supplemental poverty measures (SPM). Too often, when we confront the problem of poverty, the focus is on the lives and behavior of those suffering the burdens of poverty and not on the inadequacy of resource allocations in antipoverty programs. The purpose of poverty measures should be to expose the effectiveness and failures of antipoverty programs so that they can be improved, not to scrutinize the lives and characteristics of those who are enduring these hardships.

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January 13, 2018 in Scholarship, Tax | Permalink | Comments (0)

Friday, January 12, 2018

Weekly SSRN Tax Article Review And Roundup: Speck Reviews Mehrotra's Taxation And The Modern Liberal State

This week, Sloan Speck (Colorado) reviews a new work by Ajay Mehrotra (American Bar Foundation; Northwestern), Fiscal Forearms: Taxation as the Lifeblood of the Modern Liberal State, in The Many Hands of the State: Theorizing the Complexities of Political Authority and Social Control (Kimberly Morgan & Ann Orloff eds., Cambridge University Press 2017).

Speck (2017)Ajay Mehrotra’s forthcoming book chapter, Fiscal Forearms, serves as a meditation on, and an expansion of, the important ideas advanced in his 2013 monograph, Making the Modern American State. Mehrotra, like the larger edited volume in which his chapter falls, starts from Bourdieu’s metaphor of the state divided into spending and fiscal spheres: a “left hand” comprised of (in Bourdieu’s words) the “social workers . . . which are the trace, within the state, of the social struggles of the past,” and a “right hand” made up of the ministers and technocrats at the treasury, as well as the public and private banks that underwrite the state. Mehrotra develops this metaphor, describing fiscal administration as “the forearms of the body politic” and taxation itself as “the lifeblood of the modern state.” More critically, Mehrotra challenges the claim that social struggle leaves an imprint only on the spending side of the ledger, showing through historical examples that taxation—and especially income taxation—is a contested concept deployed to construct relationships between state and citizen and in service of societal change.

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January 12, 2018 in Scholarship, Sloan Speck, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Weekly Legal Education Roundup

Tax Policy In The Trump Administration

Tax Profs:

Other:

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January 12, 2018 in Tax, Tax Policy in the Trump Administration | Permalink | Comments (0)

Apple Could Get A $4 Billion Boost From Tax-Law Quirk

Apple LogoBloomberg, Apple Could Get a $4 Billion Boost From Tax-Law Quirk:

Companies that stockpiled trillions of dollars offshore free of U.S. income tax may get one last break before paying up -- provided their fiscal years don’t follow the calendar year.

A timing quirk in the tax overhaul that President Donald Trump signed last month may be good news for companies such as Apple Inc., Microsoft Corp. and Cisco Systems Inc., all of which began their fiscal years before Jan. 1. Firms including Alphabet Inc., Amgen Inc. and General Electric Co. -- with fiscal years that began on Jan. 1 -- appear to be shut out of the benefit.

Apple alone, which disclosed an offshore cash hoard of $252 billion as of Sept. 30, may be able to lop more than $4 billion off a future tax bill, according to Stephen Shay, a tax and business law professor at Harvard Law School who wrote about what he called the “potential loophole” last month [Will Treasury Close Loophole In Treatment Of Deferred Foreign Income In The Tax Cuts And Jobs Act?]. He characterized the boon as a side effect of the speed with which congressional Republicans passed their tax bill.

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January 12, 2018 in Tax, Tax Policy in the Trump Administration | Permalink | Comments (0)

Law Profs: Beware The Perils Of Twitter

Twitter logoLaw.com, For Law Profs, Beware the Perils of Twitter:

Twitter was awash with law professors proffering legal opinions a year ago when activists sued President Donald Trump for alleged violations of the emoluments clause.

Not all those weighing in were constitutional law experts with a firm grasp on the somewhat obscure statute barring officials in the federal government from receiving gifts from foreign governments, however.

That’s a problem, according to Carissa Byrne Hessick, a professor at the University of North Carolina School of Law and author of a new essay urging her colleagues to exercise caution on Twitter in order to protect their professional reputations and preserve the standing of the legal academy.

With more law professors using Twitter to weigh in on the issues of the day—and sometimes veering into the platform’s culture of snark and incivility—it’s time for law professors to have a conversation about how best to use the medium, Hessick argues in her draft article, Towards a Series of Academic Norms for #LawProf Twitter, which will appear in an upcoming edition of the Marquette Law Review.

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January 12, 2018 in Legal Education | Permalink | Comments (1)

NY Times: Women Force A Reckoning Over Bias In Economics

AEAFollowing up on my previous post, Women Economists Face A 'Toxic' Work Environment:  New York Times, Wielding Data, Women Force a Reckoning Over Bias in the Economics Field:

It is not difficult to find an all-male panel at the annual January mega-gathering of American economists. They are as common as PowerPoint presentations and pie charts. One such panel this year met to sleepily critique President Trump’s economic policies, but it was overshadowed by another panel, two ballrooms away, that jolted a profession that prides itself on cool rationality.

That panel on Friday was stocked with women, each of whom presented new research that revealed a systemic bias in economics and presaged a move by the field’s leaders to promise to address some of those issues.

Paper after paper presented at the American Economic Association panel showed a pattern of gender discrimination, beginning with barriers women face in choosing to study economics and extending through the life cycle of their careers, including securing job opportunities, writing research papers, gaining access to top publications and earning proper credit for published work.

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January 12, 2018 in Legal Education | Permalink | Comments (1)

American College of Employee Benefits Counsel Student Writing Competition

ACBThe American College of Employee Benefits Counsel is sponsoring its 14th Annual Employee Benefits Writing Competition on any topic in the field of employee benefits law. The competition is open to any J.D. and graduate (L.L.M. or S.J.D) law students enrolled at any time between August 15, 2017 and August 15, 2018.

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January 12, 2018 in Legal Education, Tax, Teaching | Permalink | Comments (0)

The IRS Scandal, Day 1709: Victims Of IRS's Tea Party Bias — And Taxpayers — Deserve To See Lois Lerner's Testimony

IRS Logo 2Forbes, Victims Of IRS's Tea Party Bias — And Taxpayers — Must See Lois Lerner's Testimony, Lawyer Says:

Lois Lerner, formerly of the Internal Revenue Service when it discriminated against applicants for tax exemptions based on their viewpoints, claims Americans have no right to read statements she made under oath about why she did it.

Lerner, the former director of the IRS’s Exempt Organizations Division, wants U. S. District Judge Michael Barrett to maintain under seal a deposition she gave in June for a civil suit that victims brought in 2013. Unsealing it would place her safety in jeopardy, she says.

Her former IRS colleague, Holly Paz, seeks the same after they targeted groups with “tea party” names and groups that didn’t like how the government was run.

Among those opposed are the very plaintiffs who sued the IRS in Barrett’s Ohio court. Attorney Edward Greim, who represents the Norcal Tea Party Patriots, says a pending settlement in their case shouldn’t create a reason for the depositions to stay secret. “Class members must know the content of their testimony to consider the fairness of the settlement, and the public must have access to help ensure that similar conduct never occurs again,” he wrote in November. ...

He’s not alone. It was the Cincinnati Enquirer that moved to unseal the depositions on Oct. 25, the same day a proposed settlement was announced to the court. The state of Ohio and the Judicial Watch group in Washington have also moved for leave to argue for unsealing as friends of the court. ...

Lerner and Paz have said the release of their depositions “would expose them and their families to harassment and threat of serious bodily injury or even death.”

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January 12, 2018 in IRS News, IRS Scandal, Tax | Permalink | Comments (2)

Thursday, January 11, 2018

Donaldson: Understanding The New Tax Law

Samuel A. Donaldson (Georgia State), Understanding the Tax Cuts and Jobs Act:

This manuscript summarizes key provisions of the so-called "Tax Cuts and Jobs Act" affecting United States individuals, small businesses, estates, and trusts. It does not cover changes made to pension and retirement accounts, provisions applicable only to certain industries, rules applicable to tax-exempt organizations, international tax reform, or repeal of the individual mandate under the Patient Protection and Affordable Care Act.

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January 11, 2018 in Scholarship, Tax, Tax Policy in the Trump Administration | Permalink | Comments (0)

Economic Inequality Is About To Get Even Worse

Washington Post, Massive New Data Set Suggests Economic Inequality Is About to Get Even Worse:

The “endless inegalitarian spiral” may be coming for us sooner than we think.

In his best-selling 2014 book “Capital in the Twenty-First Century,” French economist Thomas Piketty warned that if the already rich were able to accumulate wealth faster than economies were able to grow, inequality would skyrocket in the coming decades, potentially destabilizing societies in the process.

Wealth, after all, is self-perpetuating. You put cash in a savings account, and it grows. You buy a home, and its value (typically) appreciates. You invest in the stock market and see an annual rate of return.

Work, on the other hand, isn't like that. If you don't have wealth and want to make money, you have to keep working. If the economy is strong enough, your wages will grow, and eventually you'll be able to build up some wealth of your own. And if your wages are increasing more quickly than wealth is growing, there's a chance that someday, you could catch up with the person who started off with a million-dollar trust fund.

Conversely, if your wages are growing more slowly than wealth is increasing, you'll never be able to catch up. You can work as hard as you want and save as much as you want, but you'll never close the gap with that lucky trust-funder. To use a baseball analogy, not only did they start on third base, they're also running faster than you are.

But inquiries into how fast wealth grows relative to the economy have been hampered by a lack of good, complete, comparable long-term data on the rates of return for various assets: stocks, bonds, real estate and the like. You'd want this to know what you'd expect a “natural” rate of return to be in an economy such as ours: How much would you expect home prices to appreciate over time? What about the expected return on the stock market over the decades? How about government bonds?

Now a working paper, written by Federal Reserve Bank of San Francisco economist Òscar Jordà and others, purports to calculate just that: “The Rate of Return on Everything.”

After compiling this first-of-its-kind data set, Jordà's team makes a startling conclusion: If anything, Piketty's book underestimates the historical rate of return on wealth. “The same fact reported [by Piketty] holds true for more countries and more years, and more dramatically,” the researchers conclude.

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January 11, 2018 in Scholarship, Tax | Permalink | Comments (1)

What Law School Curriculum Committees Can Learn From Architecture Schools

Howard E. Katz (Cleveland State), What Law School Curriculum Committees Can Learn from Architecture Schools, 18 Transactions 622 (2016):

This article discusses the critical review ("crit") and the studio as the signature pedagogies of architecture schools, and suggests how that model might apply or help us to think about experiential education (both simulation and clinical instruction) in law schools.

January 11, 2018 in Scholarship, Tax | Permalink | Comments (0)

Cockfield: Examining Canadian Offshore Tax Evasion

Arthur J. Cockfield (Queen's University), Examining Canadian Offshore Tax Evasion, 65 Canadian Tax J. 651 (2017):

This article reviews academic and government studies that assess the magnitude of Canadian offshore tax evasion, as well as what tax-haven data leaks such as the Panama Papers have told us. This evidence, along with Canada’s historically poor performance in auditing, investigating, and prosecuting offshore tax cheats, calls for an ongoing and measured legal and policy response to inhibit offshore tax evasion.

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January 11, 2018 in Scholarship, Tax | Permalink | Comments (0)

Trump Administration Opts For Speed Over Accuracy In Implementing New Tax Law

Washington Post, Trump Administration Opts For Speed Over Accuracy in Implementing New Tax Law:

The Trump administration is pushing American businesses to withhold less in taxes from paychecks by February, aiming to quickly deliver the boost in take-home pay that Republicans promised their tax law would bring.

But the rush could expose millions of workers to the risk of underpaying taxes to the government now, which means they might owe more than they are expecting when they file tax returns in April 2019.

Business and taxpayers looking for clarity will be appealing to an Internal Revenue Service that, according to an internal watchdog report Wednesday, is underfunded and ill-prepared to answer basic questions. ...

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January 11, 2018 in Tax, Tax Policy in the Trump Administration | Permalink | Comments (3)

'Dancing Backwards In High Heels': Study Finds Students Set Higher Standards For Female Profs

FredInside Higher Ed, 'Dancing Backwards in High Heels': Study Finds Female Professors Experience More Work Demands and Special Favor Requests, Particularly From Academically "Entitled" Students:

Numerous studies have found that female professors shoulder a disproportionate amount of service work compared to their male peers. Research also suggests that students hold female instructors to a different standard than they do male faculty members, especially when it comes to personality. Women are expected to be more nurturing and are perceived harshly when they’re not, for example.

Both sets of findings matter because they have negative implications for women’s professional success: service is generally the least valued criterion in the tenure and promotion triad of research, teaching and service, and students who view female professors as unfriendly may rate their teaching poorly as a result.

Both lines of inquiry also intersect in a new paper, which says that students request more special favors and friendship behaviors from their female professors than they do of men — resulting in more actual work demands and emotional labor. The paper also suggests that "academically entitled" students more strongly expect that women will grant their favor requests than will male professors, and that they react strongly when women deny those requests.

“If students set higher standards for their female professors, it is more difficult for female professors to meet student expectations, perhaps resulting in poorer course evaluations, and putting more work demands and emotional strain on female professors,” lead author Amani El-Alayli, an associate professor of psychology at Eastern Washington University, said Tuesday. “Female professors may consequently be more likely to experience burnout and low job satisfaction than their male counterparts.”

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January 11, 2018 in Legal Education | Permalink | Comments (1)

Bach:  (Re)Viewing The American Social Welfare State

Florida Tax Review  (2015)Wendy A. Bach (Tennessee), Poor Support/Rich Support: (Re)Viewing the American Social Welfare State, 20 Fla. Tax. Rev. 495 (2017):

Since at least the 1970s a variety of scholars have redefined the U.S. social welfare state to include not only traditional benefit programs (for example Food Stamps and social security) but also a variety of tax benefits that are “hidden” or “submerged” forms of “welfare for the wealthy.” Including these benefits in the overall picture of U.S. social welfare provision reveals a system that is both larger in size than popularly believed and that, in addition to providing some support for the poor, distributes significant benefits regressively, to households with substantial wealth. Although a variety of scholars and policy analysts have described these outcomes, scholars have yet to focus on the ways in which structural inequality is written directly into the means of administration of U.S. social welfare programs. This article is the first to turn to those questions and to systematically demonstrate that those who are economically (and disproportionately racially) disadvantaged are offered a social welfare state that is meager, punitive and tremendously risky for those who receive its benefits.

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January 11, 2018 in Scholarship, Tax | Permalink | Comments (1)

Exploring The Meaning Of Experiential Deaning

Margaret Martin Barry (Vermont), Robert Dinerstein (American), Phyllis Goldfarb (George Washington), Peggy Maisel (Boston University) & Linda Morton (California Western), Exploring the Meaning of Experiential Deaning, 67 J. Legal Educ. ___ (2018):

This article explores the position of associate dean of experiential education in law schools across the country and the central role associate deans play in the changing landscape of legal education. Experiential deans have broad responsibility for overseeing law schools’ experiential education programs. Additional responsibilities differ between institutions, but range from leading efforts to comply with new ABA standards to overseeing the integration of experiential education into the broader curriculum. Analyzing survey data collected from associate experiential deans across the country, the authors find the structure, content, and authority of the position is under-developed.

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January 11, 2018 in Legal Education | Permalink | Comments (0)

Wednesday, January 10, 2018

National Taxpayer Advocate Delivers Annual Report To Congress; Discusses Tax Reform Implementation, Unveils 'Purple Book'

NTAIR-2018-03 (Jan. 10, 2018), National Taxpayer Advocate Delivers Annual Report to Congress; Discusses Tax Reform Implementation and Unveils “Purple Book”:

National Taxpayer Advocate Nina E. Olson today released her 2017 Annual Report to Congress, describing challenges the IRS will face as it implements the recently enacted tax reform legislation and unveiling a new publication, “The Purple Book,” that presents 50 legislative recommendations intended to strengthen taxpayer rights and improve tax administration.  The report also examines a wide range of other tax administration issues, including the IRS’s administration of the private debt collection program, the agency’s increasing emphasis on online taxpayer accounts, and its implementation of a recent law that would deny or revoke the passports of taxpayers with significant tax debts.

Implementation of Tax Reform Legislation
The National Taxpayer Advocate’s report says the reduction in IRS funding since FY 2010, approximately 20 percent in inflation-adjusted terms, has challenged the agency’s ability to perform the basic tasks of administering the tax system.  “As the National Taxpayer Advocate, I see daily the consequences of reduced funding of the IRS and the choices made by the agency in the face of these funding constraints,” Olson wrote in the preface to the report.  “These impacts are real and affect everything the IRS does.  Funding cuts have rendered the IRS unable to provide acceptable levels of taxpayer service, unable to update its technology to improve its efficiency and effectiveness, and unable to maintain compliance programs that both promote compliance and protect taxpayer rights.  ’Shortcuts’ have become the norm, and ‘shortcuts’ are incompatible with high-quality tax administration.” ...

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January 10, 2018 in IRS News, Tax | Permalink | Comments (4)

Shay: Will Treasury Close Loophole In Treatment Of Deferred Foreign Income In The Tax Cuts And Jobs Act?

Stephen E. Shay (Harvard), Treasury Can Close a Potential Loophole in the Treatment of Deferred Foreign Income in the Tax Cuts and Jobs Act – Will It Act?:

This paper points out a potential TJCA loophole allowing a reduction in aggregate foreign cash subject to the 15.5% rate unless Treasury takes steps to implement an anti-abuse rule. If Treasury does not act, aggressive taxpayers may be rewarded and cautious taxpayers may have incentives to make second-best uses of their offshore cash.

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January 10, 2018 in Scholarship, Tax | Permalink | Comments (0)

IRS Dodges Oversight, Refuses To Measure Economic Impact Of Its Rules

CACause of Action Institute, IRS Dodges Oversight, Refuses to Measure Economic Impact of its Rules:

Cause of Action Institute (“CoA Institute”) today released a groundbreaking investigative report, Evading Oversight: The Origins and Implications of the IRS Claim that its Rules Do Not Have an Economic Impact, that reveals how the IRS has developed a series of self-bestowed exemptions allowing the agency to evade several legally required oversight mechanisms. The report outlines in detail how the IRS created this exemption to exempt itself from three critical reviews intended to provide our elected branches and the public an opportunity to assess the economic impact of rules before they are finalized.

Read about the report in today’s Wall Street Journal [The IRS Evades Accountability—And Its Excuse Is Ridiculous], including suggestions for how the White House and Congress can work together to end this harmful practice.

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January 10, 2018 in Tax | Permalink | Comments (6)

Cryptocurrency & Robots: How To Tax And Pay Tax On Them

Sami Ahmed (J.D. 2017, Yale), Cryptocurrency & Robots: How to Tax and Pay Tax on Them, 68 S.C. L. Rev. ___ (2018):

New technologies, such as blockchain, cryptocurrency (e.g., Bitcoin), and artificial intelligence are rapidly changing how transactions occur in the United States. While scholars have started to examine how a number of areas of law should adapt, very little work has been done on what these changes mean for taxation. Yet these developments could have a huge impact on tax revenues. For example, some approaches to taxing transactions using cryptocurrency could result in these transactions being conducted abroad, beyond the reach of the U.S. taxing authorities. And if robots replace large segments of the labor force, this could drastically shrink federal and state income tax bases.

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January 10, 2018 in Scholarship, Tax | Permalink | Comments (1)

ABA Hits Back Against Cooley Law School In Accreditation Lawsuit

Thomas Cooley Logo (2017)Following up on my previous posts (links below):

Law.com, ABA Hits Back Against Cooley Law School in Accreditation Suit:

The American Bar Association is pulling no punches in its fight over Western Michigan University Cooley Law School’s tenuous accreditation status.

The ABA’s newly filed motion for summary judgment in a lawsuit brought by the Michigan-based law school highlights a series of problems at the school, from falling Law School Admission Test scores among the students it enrolls to plummeting bar pass rates among its graduates.

“The record amply demonstrates that Cooley has done just that, admitting many students who do not appear capable of graduating and being admitted to the bar, implicating the [ABA standards’] purpose to protect students from investing in an education that does not deliver,” reads the motion, filed Jan. 8. ...

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January 10, 2018 in Legal Education | Permalink | Comments (2)

Crane Reviews Rosenthal & Austin's The Dwindling Taxable Share Of U.S. Corporate Stock

Jotwell (Tax) (2016)Charlotte Crane (Northwestern), Who Gets Taxed When A U.S. Corporation Pays Dividends? (JOTWELL) (reviewing Steven M. Rosenthal & Lydia S. Austin (Tax Policy Center), The Dwindling Taxable Share Of U.S. Corporate Stock, 151 Tax Notes 923 (May 16, 2016)):

The Dwindling Taxable Share Of U.S. Corporate Stock, written by Steven M. Rosenthal and Lydia S. Austin, analyzes the available data regarding the ownership of corporate stock in the United States. Over the history of the income tax, most business capital has been invested in corporations, so an assumption that the income taxation of business meant income taxation of corporations was a reasonable assumption. Similarly, most owners of domestic capital were assumed to be taxable individuals. ...

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January 10, 2018 in Scholarship, Tax | Permalink | Comments (0)

ABA Journal: Judge Accused Of Bullying Law Students For Sex

ABA Journal (2014)ABA Journal, Italian Judge Accused of Bullying Law Students for Sex:

After accusations that he pressured female students for sex, made merit scholarship recipients sign secrecy and loyalty oaths and implemented a dress code that mandated miniskirts for women, an Italian judge and law school leader has been barred from teaching and faces removal from the bench.

Francesco Bellomo, who the Washington Post says sits on one of the country’s highest courts, was also director of Diritto e Scienza, a school that prepares students for the state exam to become a judge.

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January 10, 2018 in Legal Education | Permalink | Comments (0)

Profiles Of California's 21 Law Schools

California DreaminCalifornia Dreamin', preLaw, Fall 2017, p. 19:

The Golden State is golden with law schools. Want to rub shoulders with Hollywood stars? Go to a Tinsel-Town area law school and that may happen. ...

California may be considered laid-back, but a number of its law schools will challenge that perception, [] with their academic demands. ... The state is so large and home to so many law schools that options abound.

California offers many dynamic choices. We start in San Diego and travel north. Grab your sunblock. ...

Pepperdine University School of Law
Pepperdine is perhaps best known for is beautiful location on a hill in Malibu that overlooks the Pacific Ocean. But it likes to focus on other strengths and aims to be the nation’s premier Christian law school by combining academic and research excellence with a deep-rooted commitment to a Christian mission that welcomes people of all faiths and backgrounds. Practical training continues to be one of its hallmarks. Few schools do it better.

Honors
No. 4 Most Devout — Christian School
No. 5 Practical Training
No. 15 Best Moot Courts of the Decade

January 10, 2018 in Legal Education | Permalink | Comments (0)

Tuesday, January 9, 2018

The Tax Lawyer Publishes New Issue

The Tax Lawyer (2013)The Tax Lawyer has published Vol. 71, No. 1 (Fall 2017):

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January 9, 2018 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0)

'America-Last Tax Policy': New Law May Drive Factories And Jobs Abroad

New York Times, Tax Law May Send Factories and Jobs Abroad, Critics Say:

In Indiana, Missouri and Pennsylvania, President Trump used the same promise to sell the tax bill: It would bring jobs streaming back to struggling cities and towns. “Factories will be pouring into this country,” Mr. Trump told a crowd in St. Charles, Mo., in November. “The tax cut will mean more companies moving to America, staying in America and hiring American workers right here.”

The bill that Mr. Trump signed, however, could actually make it attractive for companies to put more assembly lines on foreign soil.

Under the new law, income made by American companies’ overseas subsidiaries will face United States taxes that are half the rate applied to their domestic income, 10.5 percent compared with the new top corporate rate of 21 percent.

“It’s sort of an America-last tax policy,” said Kimberly Clausing, an economist at Reed College in Portland, Ore., who studies tax policy. “We are basically saying that if you earn in the U.S., you pay X, and if you earn abroad, you pay X divided by two.”

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January 9, 2018 in Tax, Tax Policy in the Trump Administration | Permalink | Comments (3)