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Friday, September 5, 2014

Cain: Taxation of Same-Sex Couples After United States v. Windsor

Patricia Cain (Santa Clara), Taxation of Same-Sex Couples After United States v. Windsor: Did the IRS Get It Right in Revenue Ruling 2013-17?, 6 Elon L. Rev. 269 (2014):

The tax world for same-sex couples changed dramatically on June 26, 2013, when the United States Supreme Court handed down its decision in United States v. Windsor. The Court ruled that section 3 of the Defense of Marriage Act (DOMA) was unconstitutional. As a result the IRS would be required to recognize same-sex spouses as validly married for tax purposes. There were three major issues facing the IRS after Windsor: (1) Which marriages should be recognized for tax purposes? (2) How much retroactive effect should be given to the decision? (3) Should marriage equivalent statuses such as registered domestic partnerships and civil unions be treated the same as marriages? On August 29, 2013, the IRS issued Revenue Ruling 2013-17 which answered these three questions. This essay asks whether or not the IRS got it right in the ruling and concludes that for the most part it did. However, serious questions are raised by the fact that the IRS refuses to recognize registered partnerships and civil unions as marriages. The essay concludes that more thought should be given to this issue.

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

Scholarly Incentives, Scholarship, Article Selection Bias, and Investment Strategies for Today's Law Schools

Dan Subotnik (Touro) & Laura Ross (Touro), Scholarly Incentives, Scholarship, Article Selection Bias, and Investment Strategies for Today's Law Schools, 30 Touro L. Rev. 615 (2014):

Anecdotal evidence supplied by authors suggested that article acceptance by law reviews was based to a significant extent on the affiliation and prestige of the author. The implication for readers was that most law professors could not expect a fair reading and that, indeed, those from 3rd and 4th tier schools had only the feeblest prospects of cracking the top tier. With many aspects of employment tied to law review placement --e.g. faculty recruitment and tenure -- law professors could understand the need to tamp down career expectations. And law students could begin to see the small benefit they got from law review production. 

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September 5, 2014 in Legal Education, Scholarship | Permalink | Comments (4)

The IRS Scandal, Day 484

IRS Logo 2Judicial Watch Press Release:  New IRS Documents Show Lerner Did Not Need Conservative Group Donor Lists – Emails Mention “Secret Research Project” by Top IRS Official:

Judicial Watch today released a new batch of Internal Revenue Service (IRS) email documents revealing that under former IRS official Lois Lerner, the agency seems to acknowledge having needlessly solicited donor lists from non-profit political groups. According to a May 21, 2012, memo from the IRS Deputy Associate Chief Counsel: “such information was not needed across-the-board and not used in making the agency’s determination on exempt status.” Later, in her May 10, 2013, remarks in which Lerner first revealed in response to question she planted about the IRS targeting of conservative groups, she conceded that the requests for donor names was “not appropriate, not usual.” The new documents obtained by Judicial Watch also reveal that 75% of the groups from whom the lists were solicited were apparently conservative, with only 5% being liberal.

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September 5, 2014 in IRS News, IRS Scandal, Tax | Permalink | Comments (0)

Thursday, September 4, 2014

NY Times Debate: Should Pro-Sport Leagues Get Tax Breaks?

New York Times Debate:  Should Pro-Sport Leagues Get Tax Breaks?:


NY Times Room for DebateThe league offices and associations for several professional sports are tax-exempt nonprofit groups. The teams themselves pay taxes on their revenue, but critics say the leagues are lucrative enough to pay for their administrative expenses without a tax break, especially since some executives get enormous compensation.

Should pro sports leagues enjoy nonprofit status or are taxpayers paying too many of their bills?

  • Ryan Alexander (Taxpayers for Common Sense), End the NFL Tax Breaks:  "Sports leagues like the NFL help teams make money through business ventures – a fine goal for teams, but not one taxpayers need to subsidize. "
  • Patrick Hruby (Journalist), Sports Leagues Do Not Need Taxpayer Help:  "The NFL as a whole takes in over $9 billion in annual revenue, more than the reported 2013 GDP of 49 countries. "
  • Judith Grant Long (University of Michigan), Ending Sports Leagues' Tax-Exempt Status Might Not Bring in More Money:  "Focusing on the nonprofit issue detracts from the more substantial burdens placed on taxpayers in the building and taxing of sports stadiums and arenas."
  • Richard Steinberg (Purdue University), Nonprofit Teams Rather than Leagues? "Many Commercial Organizations Are Nonprofits, as Billion-dollar Universities Sell Education and Hospitals Sell Healthcare."
  • Andrew Zimbalist (Smith College), Nonprofit Status Is Irrelevant:  "The tax exemption does not apply to the individual teams, but to the leagues, which operate as pass-through entities."

September 4, 2014 in Tax | Permalink | Comments (0)

This Is Your Brain on Law School

BrainAbigail A. Patthoff (Chapman), This is Your Brain on Law School: The Impact of Fear-Based Narratives on Law Students, 2015 Utah L. Rev. ___:

Law students regularly top the charts as among the most dissatisfied, demoralized, and depressed of graduate student populations. As their teachers, law professors cannot ignore the palpable presence of this stress in our classrooms – unchecked, it stifles learning, encourages counterproductive behavior, and promotes illness. Yet, in the name of persuasion, professors frequently, and perhaps unwittingly, introduce additional fear into the classroom as a pedagogical tool via a common fear-based narrative: the cautionary tale. By taking lessons from existing social science research about “fear appeals” – scare tactics designed to frighten the listener into adopting a particular behavior – this article suggests that we can actively manage one source of law student anxiety by more thoughtfully using cautionary tales.

September 4, 2014 in Legal Education | Permalink | Comments (1)

Public Pension Funds Stay Mum on Corporate Inversions

New York Times Deal Book:  Public Pension Funds Stay Mum on Corporate Expats, by Andrew Ross Sorkin:

NY Times Dealbook (2013)In the outcry about the recent merger mania to take advantage of the tax avoidance transactions known as inversions, certain key players have been notably silent: public pension funds.

Many of the nation’s largest public pension funds — managing trillions of dollars on behalf of police and fire departments, teachers and others — have major stakes in American companies that are seeking to renounce their corporate citizenship in order to lower their tax bill.

While politicians have criticized these types of deals — President Obama has called them “wrong” and he is examining ways to end the practice — public pension funds don’t appear to be using their influence as major shareholders to encourage corporations to stay put.

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September 4, 2014 in Tax | Permalink | Comments (0)

Students Who Exercise Regularly Have Higher GPAs

Purdue University, College Students Working Out at Campus Gyms Get Better Grades:

PurdueCollege students who visit their campus gyms are more likely to succeed in the classroom, according to data from Purdue University.

"Students who worked out at Purdue's gym at least once a week were more likely to earn a higher grade point average than students who visited less or not at all," says Tricia Zelaya, assistant director for student development and assessment at Purdue's Division of Recreational Sports. "Going to the gym is so much more than going to the gym. Students who are motivated by fitness and wellness tend to have better time management skills, and research shows that being fit is good for the mind. It all ties together."

For example, the more than 1,820 students who visit Purdue's France A. Córdova Recreational Sports Center at least 16 times a month earned a GPA of 3.10 or higher. The correlation between grades and gym use also is shown with moderate users. Students who used the gym at least seven times a month had an average GPA of 3.06. The average GPA for students who did not regularly use the gym was a 2.81.

(Hat Tip: Inside Higher Ed.)

September 4, 2014 in Legal Education | Permalink | Comments (2)

Morrow: Repealing the Mortgage Interest Deduction

Rebecca N. Morrow (Wake Forest), Billions of Tax Dollars Spent Inflating the Housing Bubble: How and Why the Mortgage Interest Deduction Failed, 17 Fordham J. L. & Fin. L. 751 (2012):

The mortgage interest deduction is an incredibly popular, politically well-supported and hugely expensive tax incentive. Yet economic studies consistently show that the mortgage interest deduction fails to advance its fundamental purpose. It does not increase the rate of homeownership. On the contrary, to the extent that it is effective in influencing human behavior, it does so by inflating home prices and encouraging borrowing against equity. These effects inflated home prices and excessive borrowing contributed to the economic crisis of 2008. In the years leading up to the crisis, Americans spent billions of tax dollars further inflating a dangerously unstable housing bubble. Even if we had the will to change this policy, we did not have the means. The mortgage interest deduction is insensitive to market conditions and resistant to change. These attributes make the mortgage interest deduction bad policy. Rather than perpetuating this costly deduction, Congress should phase it out in its entirety and replace it with targeted tax incentives designed to stimulate the housing market only when the market is weak. Future tax incentives should avoid the structural flaws that caused the mortgage interest deduction to fail by focusing on market responsiveness, timing and flexibility.

September 4, 2014 in Scholarship, Tax | Permalink | Comments (1)

Northwestern Symposium: 100 Years Under the Income Tax

Northwestern (2014)Symposium, 100 Years Under the Income Tax, 108 Nw. U. L. Rev. 767-1136 (2014):

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

Morriss: The Future of Offshore Financial Centres: The Tax Question

Accountancy Live:  Future of Offshore Financial Centres: The Tax Question, by Andrew Morriss (Dean, Texas A&M):

When the US Congress passed the Foreign Account Tax Compliance Act (FATCA) in 2010 as part of its post-financial crisis efforts at economic stimulus, there was little debate or discussion about the costs or benefits of such a massive expansion of financial regulation. Since then, the UK has adopted its own ‘son of FATCA’ and France a ‘mini-FATCA’.

Elsewhere more such measures are being debated. FATCA and its progeny have spawned a raft of intergovernmental agreements (IGAs) promising transparency to tax authorities around the world. Not to be outdone, prime minster David Cameron is pushing for beneficial ownership registries for the UK, the Crown Dependencies and the Overseas Territories.

New York University’s John Blank and [University of] Virginia’s Ruth Mason argue in a recent Tax Notes article that, taken together, these agreements and laws offer ‘an aspirational new global standard for automatic exchange of information.’ Does this mean the end of offshore financial centres?

No. Critics of offshore financial centres (OFCs), like US senator Carl Levin, the Tax Justice Network, and Oxfam, might wish it were so but the demand for offshore financial services will continue for three reasons.

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September 4, 2014 in Tax | Permalink | Comments (0)

Professor Shoots Himself in the Foot in Classroom. Literally.

ShootIdaho State Journal, ISU Instructor Shoots Himself in the Foot:

An instructor was wounded in the foot after his concealed handgun discharged in a classroom at the Physical Science Complex on the Idaho State University campus at about 4 p.m. Tuesday. ... “It was in his pocket.” ... “He did have an enhanced concealed carry permit.”

The instructor, who was teaching in the chemistry department, was not taken by ambulance to Portneuf Medical Center, but his wound was treated and he was released from the hospital Tuesday evening. “It's unfortunate,” ISU President Arthur Vailas said. “I'm sure the incident was scary and embarrassing.”

Vailas, who is a gun owner and hunter, said he likes guns but not on campus. He joined other Idaho university professors and chief of police from cities with universities during the last Idaho legislative session in opposition to legislation that now allows concealed carry on campuses in Idaho so long as the person has obtained an enhanced permit. Enhanced permits require additional training. ...

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

IRS Releases EITC Overpayment Data

IRS, Compliance Estimates for the Earned Income Tax Credit Claimed on 2006-2008 Returns:

EITC Logo (2014)This report presents information about the nature of errors taxpayers made when claiming the Earned Income Tax Credit (EITC) in Tax Years 2006 through 2008. This is the latest of several analyses of EITC compliance undertaken by the IRS over the years to help understand behavior and develop strategies for improving the administration of the credit. Prior to this report, the most recent analysis was conducted for Tax Year (TY) 1999 in a report commonly called the 1999 Compliance Study. 

As with the earlier studies of compliance, the analysis in this report relies on audit data; in this case, the audits were conducted by IRS’ National Research Program (NRP). NRP audits are like other IRS audits but provide the added benefit that they can be used for population estimates of taxpayer reporting compliance. One challenge with using audit data is that taxpayers do not always respond to or participate in the audit as required. In particular, 15 percent of EITC filers selected for an NRP audit of a TY 2006-2008 return did not participate in the audit, compared to 6 percent selected for an audit for a TY 1999 return. When this happens, the audit outcomes may not reflect their “true” eligibility for the credit.1 To address this uncertainty, two sets of estimates are presented throughout this paper, reflecting different assumptions about the true compliance behavior of these taxpayers: the “higher” estimate assumes that audit nonparticipants are generally noncompliant and the “lower” estimate assumes that the true compliance of audit non-participants is the same as the compliance of otherwise similar audit participants.

We find no discernible change in the overall tendency for noncompliance between 1999 and 2006-2008. This is based on a comparison of “dollar overclaim percentages,” defined as total dollars overclaimed as a percent of total dollars initially claimed for EITC (before considering IRS corrections or enforcement). In TY 2006-2008, the estimates of the overclaim percentage are 28.5 percent (lower estimate) and 39.1 percent (higher estimate).

Table 2b

Comparable figures from the 1999 Compliance Study are 30.9 percent and 35.5 percent. ...

While the overall tendency for noncompliance is little changed, the growth in the EITC program has led to an increase in total dollars of claims and overclaims since 1999. Averaging over returns filed for TY 2006-2008, an estimated 23.7 million taxpayers claimed an annual total of $49.3 billion in EITC, compared with 18.8 million taxpayers claiming a total of $31.3 billion in EITC in TY 1999. Total overclaims for TY 2006-2008 are estimated to be $14.0 billion (lower estimate) or $19.3 billion (higher estimate). Similar figures from the 1999 Compliance Study are $12.3 and $14.0 billion, after adjusting for inflation ($9.7 and $11.1 billion in current dollars).

(Hat Tip: Leslie Book.)

September 4, 2014 in IRS News | Permalink | Comments (0)

The IRS Scandal, Day 483

IRS Logo 2Wall Street Journal editorial:  Tax Collectors in the Cafeteria: The IRS Doesn't Like the Way Silicon Valley Does Lunch:

Having harassed the Tea Party for years, the Internal Revenue Service is now targeting Silicon Valley. The tax collectors are offended by the practice, common in the technology industry, of providing meals to employees without counting the food as taxable compensation. ...

[L]ast week the Treasury published the annual list of IRS priorities and ominously included a plan for new guidance "regarding employer-provided meals." As a large bureaucracy, the IRS has no fewer than 317 such projects on its priority list. In this case they seem to mean it. The Journal reports that IRS auditors are now flagging the issue and demanding back taxes from companies amounting to 30% of the meals' fair-market value, according to lawyers for the firms.

You don't have to be a software programmer to think that the IRS ought to focus on other priorities. For example, not one of the 317 projects is devoted to accurate and complete disclosure of the agency's role in targeting the President's philosophical opponents.

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September 4, 2014 in IRS News, IRS Scandal, Tax | Permalink | Comments (2)

Wednesday, September 3, 2014

Fleischer: Court Challenge to New Inversion Rules Would Face Long Odds

New York Times Dealbook:  Court Challenge to New Inversion Rules Would Face Long Odds, by Victor Fleischer (San Diego):

NY Times Dealbook (2013)The Treasury Department is considering new regulations that would make corporate inversions less profitable.  Hedge fund managers, investment bankers and others are handicapping the timing and scope of any new rules and to whom they would apply. Possibilities include further limiting earnings stripping, reclassifying certain debt held by United States subsidiaries of foreign corporations as equity or restricting the repatriation of untaxed offshore cash from corporations that have gone through an inversion.

Another question is whether any new regulations will hold up in court.  Even Treasury Secretary Jacob J. Lew questioned whether his department had the legal authority to act unilaterally. But after Stephen E. Shay, a law professor at Harvard University, published an article urging Treasury to act, the department’s lawyers began developing some options. Mr. Shay suggested that by looking beyond Section 7874, the specific code section that addresses inversions, the Treasury Department might find other ways to curb some of the economic tax benefits of an inversion. In my view, Professor Shay’s suggestions are indeed within the lawful authority of the Treasury Department.

But reasonable minds may differ. To examine the likelihood of a successful challenge, I thought it would be useful to look at the Treasury’s track record in court. ...

The short answer is that the Treasury’s track record is strong, especially in recent years. Since 1986, just 13 of 55 challenges in the United States Tax Court have been successful, or 23 percent. Of those, just eight survived an appeal. The last successful challenge I found that survived appeal was 14 years ago. ...

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September 3, 2014 in Tax | Permalink | Comments (1)

Believers Flee Pews as Germany Enforces 9% Church Tax on Capital Gains

Wall Street Journal, In Germany, Many Believers Balk at Tweak to Church Tax; As Loophole Closes, Disgruntled German Catholics and Protestants Opt to Officially Leave Churches:

Church TaxI
n Germany, being an official church member usually means paying an extra tax. But a change in the country's tax code is now causing many believers to leave the fold.

Germany is just one of a number of European countries where members of the main organized religions pay a special levy on income to provide the bulk of churches' finances. But when a loophole concerning income from capital gains closes next year, church leaders have good reason to expect an exodus.

So far this year, the number of Germans leaving the country's Protestant and Catholic churches has reached its highest level in 20 years, twice last year's level—a surge many clergy and finance experts blame on the changes in how the tax is levied.

The outflow is now fueling a debate about whether a levy that goes back to the 19th century is an appropriate way to finance churches in an increasingly secularized Germany.

 WSJ

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September 3, 2014 in Tax | Permalink | Comments (1)

Robert Reich: College Is a Ludicrous Waste of Money

Salon:  College Is a Ludicrous Waste of Money, by Robert Reich (UC-Berkeley):

InequalityThis week, millions of young people head to college and universities, aiming for a four-year liberal arts degree. They assume that degree is the only gateway to the American middle class.

It shouldn’t be.

For one thing, a four-year liberal arts degree is hugely expensive. Too many young people graduate laden with debts that take years if not decades to pay off.

And too many of them can’t find good jobs when they graduate, in any event. So they have to settle for jobs that don’t require four years of college. They end up overqualified for the work they do, and underwhelmed by it.

Others drop out of college because they’re either unprepared or unsuited for a four-year liberal arts curriculum. When they leave, they feel like failures.

We need to open other gateways to the middle class. 

Press reports last month noted that Reich earns a $243,000 salary at UC-Berkeley and is teaching one class this semester.

September 3, 2014 in Legal Education | Permalink | Comments (4)

Burger King: It's Not the Taxes. Experts: Dollars to Doughnuts, That's a Whopper

Bloomberg:  Burger King: It's Not the Taxes. Experts: Dollars to Doughnuts, That's a Whopper, by Zachary R. Mider:

BKTHDaniel Schwartz, chief executive officer of Burger King Worldwide Inc., said last week he doesn’t expect “meaningful tax savings” when the company adopts a new legal address in Canada through the purchase of a doughnut chain there.

While Schwartz’s statement may have blunted criticism from U.S. politicians who are calling the Miami-based hamburger maker’s address change a tax dodge, it’s hard to square with the reality of the countries’ tax laws, according to experts on both sides of the border. “If they don’t see any tax benefits going forward, they are probably not looking very hard,” said Edward Kleinbard, a tax professor at the University of Southern California and a former partner at New York-based Cleary Gottlieb Steen & Hamilton LLP.

Kleinbard and other authorities [Reuven Avi-Yonah, Dick Harvey, Robert Willens] said in interviews that Burger King will almost certainly reduce its taxes because Canada’s corporate income tax system is simply less expensive for multinational companies. Canadian companies can collect dividends from most foreign subsidiaries without paying more tax in their home country -- an advantage over the U.S., which is one of the few countries that apply a second layer of tax on foreign income.

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September 3, 2014 in Tax | Permalink | Comments (1)

Law School, I Love You

Gawker:  Law School, I Love You, by David Shapiro (Brooklyn Law School 3L):

LoveI went to NYU for college and finished as fast as I could because I didn't enjoy it and wasn't engaged by what I was studying (economics, history, metropolitan studies). After that, for about two years, I worked at a part-time clerical job so menial that I couldn't tell my best friends what I did. I made $13,689.60 a year. My mom told me that when she found out what I was doing, her heart sunk. One time, on the phone, my Dad asked me how old I thought I would be before he stopped supporting me. ...

I was sitting in my Civil Procedure class when I realized I loved law school. ... I sent a Google Chat message to my friend who was sitting next to me that said, "i think i love law school? is that possible/reasonable?" She didn't respond because she was focusing on the lecture. I Googled it and found a message board posting entitled, simply, "does anyone else love law school." The common thread running through the replies was incredulity. Nobody had ever told me, or any of these students on this message board apparently, that law school could be a thing that you could love. I thought it was just a thing you had to drag yourself through before you could become a lawyer. It would be like if someone told me to go to the dentist not only to get my teeth cleaned but also because I might really have a good time hanging out with the dentist.

I also noticed, for the first time, I didn't dread getting out of bed to go to school. I was going to office hours with my professors just to talk. ... More than anything, I loved learning about the rational underpinnings for the beliefs of people I disagree with—for a liberal law student, reading one of Justice Scalia's opinions is like going on an ideological safari through an awe-inspiring argument in a parallel universe. In the winter, before finals, I sat in the library, seven days a week, most days until after midnight. I'd never worked harder, cared more about what I was doing, or been happier. Over winter break after my first semester, my Dad hung my grades up on the refrigerator. They weren't perfect grades but, for the first time, he said he was proud of me.

After two years of law school, I still feel this way about it, but there is a lingering problem: It can be really embarrassing to tell people that I go to law school. I think that's driven in part by a long-held belief that people who go to law school can't hack it in the professional world, are cursedly uncreative, or have given up on their dreams. (Some students in law school confirm this; most don't.)

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September 3, 2014 in Legal Education | Permalink | Comments (3)

Yin: Stopping Corporate Inversions Sensibly and Legally

Tax Analysys Logo (2013)George K. Yin (Virginia), Stopping Corporate Inversions Sensibly and Legally, 144 Tax Notes 1087 (Sept. 1, 2014):

A recent article by Mindy Herzfeld, What Can Treasury Do About Inversions?, 144 Tax Notes 895 (Aug. 25, 2014), overlooks a simple and sensible alternative available to the Treasury Department that is not of questionable legality. Treasury could submit a proposal to Congress to redefine a corporation's "residence" for tax purposes -- which determines whether the entire panoply of U.S. tax rules applies to it -- based on the location of the enterprise's principal customer base.

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September 3, 2014 in Scholarship, Tax, Tax Analysts | Permalink | Comments (1)

WSJ: Law Schools Boost Enrollment After Price Cuts

Wall Street Journal: Law Schools Boost Enrollment After Price Cuts; Some Institutions Trim Tuition Amid Dearth of New Students, by Jennifer Smith:

A strategy rarely employed in legal education—price-cutting—appears to be paying off for a handful of law schools.

Three institutions that trimmed tuition for some or all students [Iowa, Roger Williams, La Verne] are set to boost their first-year class sizes by 22% to 52% this fall compared with 2013, according to an analysis of preliminary enrollment data compiled by The Wall Street Journal. At a fourth {Penn State], a new grant program that effectively cuts the cost of tuition nearly in half for all in-state students has also been followed by a substantial jump in new students.

The gains—which at two of the schools were accompanied by a slight downtick in test scores—are notable given the broader plunge in U.S. law-school enrollment since 2010 amid a grim legal job market. ...

First-year enrollment figures at two law schools outside the 100 top-ranked schools [Akron, Ohio Northern] slid even after they reduced cost. ...

After a three-year downturn in enrollment, many law schools across the U.S. are weighing whether to maintain tuition revenue by loosening admission standards, or keep classes smaller to avoid jeopardizing their rankings. Among the tuition-choppers, the median LSAT score dipped by one point at Iowa Law, to 160, though the school's median GPA increased to 3.64, compared with 3.59 in 2013. At Roger Williams, the median LSAT also went down one point, to 148, and the median GPA dropped slightly, from 3.18 in 2013 to 3.16.

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September 3, 2014 in Legal Education | Permalink | Comments (0)

Death of Brittany McGrath (J.D. 2014, Brooklyn Law School)

Daily Hampshire Gazette:  A Father-Daughter Bond That Ended Far Too Soon:

EdWednesday morning at 10, people who loved Edward Daniel McGrath Jr. and his daughter, Brittany Danielle McGrath, gather in Northampton to attempt what must seem impossible: Accept that this doting dad and loving child, joined for a late-summer motorcycle ride and both in love with partners who appreciated their unique ways, died because a driver addled by heroin allegedly nodded off and crossed the center line. ...

James Walter Ainsworth ... will face two counts of felony motor vehicle homicide under the influence of drugs, as well as operating to endanger, possession of heroin and driving with a suspended license. Police say Ainsworth climbed into a potentially lethal weapon, an SUV, and allowed it to collide with innocent people.

According to an Easthampton police report, witnesses at the scene said Ainsworth climbed out of the SUV and looked passively at the wrecked motorcycle. He lit a cigarette. A witness reported seeing Ainsworth slumped minutes before against the driver’s side window, apparently asleep. He was heard to say at the scene, “The curb woke me up.” ...

Ed and Brittany liked to ride together, her obituary said. It was part of their bond. She was about to take a job with a British law firm, having just graduated magna cum laude from Brooklyn Law School, following years in New York City studying at Fordham University. Their Thursday afternoon ride north toward Northampton was surely a joyous reunion.

Obituary, Brittany McGrath (1985-2014):

BrittanyAfter graduating from Fordham with honors and awards she went on to work for the Manhattan District Attorney's office as a trial prep assistant. Her experience working at the DA's office deepened her desire to pursue social justice, so she pursued an education in law, continuing studies at Brooklyn Law School. While at Brooklyn Law she continued leading her Moot Court team to multiple international victories, including at Oxford University. Continuously on the Dean's list she was a member of the Law Review and was sought after by many professors to assist in legal research. Just three short months ago, she graduated magna cum laude from BLS, and had accepted a position at an international British law firm, Allen and Overy. She would have started on September 15th volunteered for the coalition of the homeless, was a member of the board of directors for the Harlem Youth Baseball Organization, and was a fierce advocate for as a junior associate. She children and animal rights, both adopting and placing many homeless animals. She had a magical connection with everyone she met, and will forever be missed. ...

Brittany is survived by her mother, Iris McGrath, best friend and sister Chelsea McGrath, and her partner and love of her life, Juan Reinoso, and their household: dogs Valencia, Mocha, Nala, Smokey, and cats Tuxedo, Misu, and Lolita.

Services will be Wednesday, Sept. 3, at 10 a.m. at Ahearn Funeral Home at 783 Bridge Road in Northampton. Flowers can be sent to the funeral home. In lieu of flowers, donations can be sent to Louie's Legacy Animal Rescue.

September 3, 2014 in Legal Education, Obituaries | Permalink | Comments (0)

UNLV Law School Faces $3 Million Budget Shortfall Due to 25% Enrollment Decline

Las Vegas Review-Journal, Financial Stresses Challenge UNLV Law School:

UNLV LogoIn a state with few higher education bragging rights, UNLV’s law school stands out. The law school is ranked among the top 100 by U.S. News and World Report and its graduates are in demand locally, with students doing well on the state bar exam.

But the school’s success could plummet quickly if something isn’t done about the gap in its budget. ... The school once saw 150 students enrolling every year; the new norm is 110-115. The result: A $3 million shortfall.

The University of Nevada Board of Regents is asking for $1.5 million in state funds to help the law school adjust to the economic reality. The rest of the loss likely will be absorbed through cost cutting, a tuition hike, philanthropy and new programs.

Boyd is looking to add a new signature program — a master’s in gaming law and regulation — as well as offer more educational opportunities for business professionals. The faculty already has approved the new gaming law master’s program. The regents will vote Friday on whether or not to approve the program, which would be the first of its kind in the nation. If approved, Boyd will recruit internationally, targeting Macau and Singapore for students, [Dean Daniel] Hamilton said. ...

The other solutions Boyd is implementing to weather its financial predicament are less palatable to students and faculty. Tuition for Boyd students will gradually go up, 4 percent next academic year and 4 percent the following year. ... Boyd has implemented a hiring freeze, planned phased-out retirements of faculty and is exploring the idea of voluntary buyouts for faculty, Hamilton told regents when advocating for additional state funds Aug. 22.

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September 3, 2014 in Legal Education | Permalink | Comments (1)

The IRS Scandal, Day 482

Tuesday, September 2, 2014

WSJ: IRS to Tax Free Employee Meals in Silicon Valley

Wall Street Journal:  Silicon Valley Cafeterias Whet Appetite of IRS; Free, Employer-Provided Meals Are Viewed as a Taxable Fringe Benefit, by Mark Maremont:

TwitterThere is a grumpy new face in line at Silicon Valley's lavish freebie cafeterias: the Internal Revenue Service.

Staffers at technology companies such as Google, Facebook and Twitter long have enjoyed free gourmet meals, courtesy of their employers. The groaning buffets, in-house pizza joints, and kitchens stocked with organic produce are an intrinsic part of the culture in much of Silicon Valley, encouraging both collaboration and longer work hours.

The IRS, arguing that these freebies are a taxable fringe benefit, has given new attention to the issue in recent months during routine audits of some companies, tax lawyers said. When employers haven't been withholding taxes related to the meals, the IRS increasingly has sought back taxes that can amount to 30% of the meals' fair-market value, the lawyers said. ...

In another sign of a new focus on the issue, the IRS and U.S. Treasury Department last week included taxation of "employer-provided meals" in their annual list of top tax priorities for the fiscal year ending next June. The agencies said they intend to issue new "guidance" on the matter, but gave no specifics about timing or what the guidance would say.

Tax lawyers expect some employers will fight the IRS over the matter, and said the issue is likely to be decided in the courts. Any broad IRS crackdown could spur complaints about petty government interference with the culture of a crucial industry. But allowing free meals to go untaxed, critics say, distorts the economy and gives some employers an unfair edge. ...

IRS interest in the free-meals issue ticked up last year, after The Wall Street Journal published an article focusing on whether the food should be considered a taxable benefit. ...

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September 2, 2014 in Tax | Permalink | Comments (0)

Symposium: Teaching Trusts & Estates

T&ESymposium, Teaching Trusts and Estates, 58 St. Louis U. L.J. 643-846 (2014):

September 2, 2014 in Legal Education, Scholarship, Tax, Teaching | Permalink | Comments (1)

The Top 10 Law Schools for Hispanic Students

HispanicHispanic Business Magazine has published its annual ranking of the Top 10 Law Schools for Hispanics:

  1. Florida International
  2. Florida State
  3. Miami
  4. American
  5. Nova
  6. Texas
  7. USC
  8. San Francisco
  9. UCLA
  10. New Mexico

(Hat Tip: Francine Lipman.)

September 2, 2014 in Law School Rankings, Legal Education | Permalink | Comments (2)

Businesses Are Winning Cat-and-Mouse Tax Game: 'Self-Help Tax Reform'

New York Times Deal Book:  Businesses Are Winning Cat-and-Mouse Tax Game, by David Gelles:

NY Times Dealbook (2013)A pharmaceutical company moved its headquarters to Ireland, sharply reducing its tax rate. A billboard company reclassified itself as a real estate concern, meaning it will no longer pay corporate taxes. And a big oil producer split itself in two, cleaving off a multibillion-dollar division that now operates tax-free.

Across corporate America, companies large and small are finding new ways to address one of the business world’s oldest irritations: paying taxes.

By exploiting existing loopholes and devising new ones, some of the country’s best-known companies are making it harder than ever for the federal government to replenish its already depleted coffers.

As a result, business income tax revenue remains stagnant at about 2 percent of gross domestic product even as corporate profits hit records.

Business taxes now make up less than 10 percent of federal revenue, and in some years as little as 6.6 percent. That is sharply down from the years after World War II, when about 30 percent of federal revenue came from corporate taxes.

The decline is the result of the rise of untraditional business structures, the effects of a more globalized economy and a labyrinth of subsidies and tax credits. And though the erosion has happened gradually over decades, the surging popularity of inversions — acquisitions of overseas companies that allow American corporations to reincorporate abroad — is raising concerns that an already precarious situation is growing untenable.

“There’s been a long, slow, steady decline,” said William G. Gale, co-director of the Urban-Brookings Tax Policy Center and an economic adviser to President George H. W. Bush. “It’s a confluence of a bunch of things, and it’s increasingly difficult to figure out how to effectively tax corporations.” ...

“It’s self-help tax reform,” said Kyle E. Pomerleau, an economist at the Tax Foundation. “If Congress is not willing to reform the corporate tax code, companies are going to do it for themselves.” ...

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September 2, 2014 in Tax | Permalink | Comments (0)

Harrison: Faculty Jobs for Spouses Reduce Opportunities for Others

Gainesville Sun op-ed:  Faculty Jobs for Spouses Can Reduce Opportunities for Others, by Jeffrey L. Harrison (Florida):

Trailing SPouse 2A front-page story in The Sun on Aug. 23 described efforts to accommodate the trailing spouses of highly desirable faculty candidates. It tells the sunnier side of the story, but not the things fair-minded people should consider. That is, if “fair” means equal opportunity, no cutting in line and hiring the best people.

When a trailing spouse is involved, there typically is no public notice that a job is open. Oftentimes a job paying tens of thousands of taxpayer dollars is manufactured. No other person may apply for that job or is likely to even know about the job regardless of his or her qualifications.

In the modern version of the “ol' boy” and “who do you know” systems, it adds the “who are you sleeping with” system. ...

Marriages and partnerships unfortunately fall apart. When they do, UF is stuck with an employee that it would never have hired (and perhaps a position it never would have created) but for the relationship. Since “trailing” was a requirement of being hired, shouldn't there be a re-evaluation when the relationship ends in which all job seekers are finally given a chance for the position?

Does anyone really believe that a trailing spouse is held to the same standard as others? Put differently, do you want to be the dean who says no to someone when the outcome is the loss of an eminent faculty member in another department who the dean there and the president of the university, on whom your position and greatly enhanced salary depend, desperately want to keep?

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September 2, 2014 in Legal Education | Permalink | Comments (5)

O'Reilly: Trends in Tax Legal Scholarship

Terrance O'Reilly (Willamette), Tax Legal Scholarship to 1970, 34 Va. Tax Rev. ___ (2014):

This article examines the evolution of method and styles in tax legal scholarship from 1913 through the 1960s. It focuses on legal scholarship published in law reviews. Section I provides some numerical measures of trends in early and mid-twentieth century tax legal scholarship. Section II is a brief survey of significant casebooks and treatises during the period examined. Section III looks at the development of tax legal scholarship through the 1960s, emphasizing trends in style and method.

Table 1

Figure 2

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September 2, 2014 in Scholarship, Tax | Permalink | Comments (1)

Kennedy: DOMA Implications for Employee Benefit Plans

Tax Analysys Logo (2013)Kathryn J. Kennedy (John Marshall), DOMA Implications for Employee Benefit Plans: Round 2, 144 Tax Notes 947 (Aug. 25, 2014):

This report updates Kennedy’s earlier Tax Notes article on employee benefits guidance issued by the IRS and the Department of Labor soon after the Supreme Court’s 2013 decisions in Hollingsworth v. Perry and United States v. Windsor on the constitutionality of the Defense of Marriage Act. The IRS has since issued additional helpful guidance, and there has been a groundswell of federal and state litigation contesting states’ same-sex marriage bans. In this report, Kennedy discusses the current state of affairs and highlights many of the questions not addressed by the IRS and Labor Department guidance. She argues that without additional regulatory guidance, which appears unlikely, those questions will have to be resolved through future litigation.

September 2, 2014 in Scholarship, Structuring a Tax Workshop Series, Tax Analysts | Permalink | Comments (0)

Tax Foundation: Burger King and Corporate Tax Rates and Revenues

Tax Foundation:  Canada's Lower Corporate Tax Rate Raises More Tax Revenue:

Tax Foundation logoCanada is apparently becoming an attractive place to do business. This week Burger King announced plans to move its headquarters to Canada, via a merger with Tim Hortons. Other U.S. companies that have recently moved or announced plans to move to Canada include Bausch and Lomb, Allergan, and Auxilium. A Bloomberg analysis indicates Tim Hortons was once a U.S. company, until it inverted to Canada in 2009.

Part of the attraction is the substantial tax reforms that occurred over the last 15 years in Canada. First among these is the dramatic reduction in the corporate tax rate, from 43 percent in 2000 to 26 percent today. The U.S. currently has a corporate tax rate of 39 percent, but lawmakers are reluctant to do what Canada did, i.e. lower the tax rate, for fear of losing tax revenue.

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September 2, 2014 in Tax, Think Tank Reports | Permalink | Comments (3)

The IRS Scandal, Day 481

TaxProf Blog Holiday Weekend Roundup

Monday, September 1, 2014

Flying Home to an Empty Nest

My wife Courtney and I are flying back to Malibu today, after helping our daughter Jayne get settled in her apartment in Madison, Wisconsin over the weekend before she starts her job tomorrow at Epic Systems, a health care software company.  Jayne graduated from college three months ago and spent one last special summer with us studying for the MCAT, which she took last Wednesday:

Jayne

Jayne will be living with her brother Reed, who has been working at Epic since his graduation from college last year.  With both of our children now on their own, our new nest is now physically empty (except for Josie), but is overflowing with precious memories of raising two incredible children and launching them into the world.  I will never forget holding hands with Courtney and Jayne this morning, bawling like a baby while praying over Jayne's new life and thanking God for the countless blessings he has showered on us over the past 22 wonderful years.

Empty Nest

September 1, 2014 in Legal Education, Tax | Permalink | Comments (1)

Don’t Want Me to Recline My Airline Seat? You Can Pay Me

New York Times:  Don’t Want Me to Recline My Airline Seat? You Can Pay Me, by Josh Barro:

Seat ReclineI fly a lot. When I fly, I recline. I don’t feel guilty about it. And I’m going to keep doing it, unless you pay me to stop.

I bring this up because of a dispute you may have heard about: On Sunday, a United Airlines flight from Newark to Denver made an unscheduled stop in Chicago to discharge two passengers who had a dispute over seat reclining. According to The Associated Press, a man in a middle seat installed the Knee Defender, a $21.95 device that keeps a seat upright, on the seatback in front of him.

A flight attendant asked him to remove the device. He refused. The woman seated in front of him turned around and threw water at him. The pilot landed the plane and booted both passengers off the flight.

Obviously, it’s improper to throw water at another passenger on a flight, even if he deserves it. But I’ve seen a distressing amount of sympathy for Mr. Knee Defender, who wasn’t just instigating a fight but usurping his fellow passenger’s property rights. When you buy an airline ticket, one of the things you’re buying is the right to use your seat’s reclining function. If this passenger so badly wanted the passenger in front of him not to recline, he should have paid her to give up that right.

I wrote an article to that effect in 2011, noting that airline seats are an excellent case study for the Coase Theorem. ...

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September 1, 2014 in Legal Education, Tax | Permalink | Comments (34)

President Obama Appoints Ronald Pearlman to the IRS Oversight Board

The White House has announced the appointment of Ronald Pearlman to the Internal Revenue Service Oversight Board:

IRS Oversight BoardRonald Alan Pearlman recently retired as a Professor of Law at the Georgetown University Law Center, a position he held from 1999 to 2014. Previously, he was a Tax Partner at Covington & Burling from 1991 to 2000. Mr. Pearlman was Chief of Staff on the Joint Committee on Taxation of the U.S. Congress from 1988 to 1990 and a Tax Partner at Bryan Cave from 1986 to 1988. Prior to Bryan Cave, Mr. Pearlman served at the Department of the Treasury, first as the Deputy Assistant Secretary for Tax Policy from 1983 to 1984, and subsequently as Assistant Secretary for Tax Policy from 1984 to 1985. Before joining Treasury, Mr. Pearlman was a Tax Partner at Thompson & Coburn from 1969 to 1983. Mr. Pearlman received a B.A. from Northwestern University, a J.D. from the Northwestern University School of Law, and an L.L.M. from the Georgetown University Law Center.

September 1, 2014 in IRS News, Tax | Permalink | Comments (0)

The IRS Scandal, Day 480

Sunday, August 31, 2014

U.S. Hikes Fee to Renounce Citizenship By 422%

Following up on my recent post, Record Numbers of Americans Are Renouncing Their U.S. Citizenship:  Forbes, U.S. Hikes Fee To Renounce Citizenship By 422%, by Robert W. Wood:

PassportOver the last two years, the U.S. has had a spike in expatriations. It isn’t exactly Ellis Island in reverse, but it’s more than a dribble. With global tax reporting and FATCA, the list of the individuals who renounced is up. For 2013, there was a 221% increase, with record numbers of Americans renouncing. The Treasury Department is required to publish a quarterly list, but these numbers are under-stated, some say considerably.

The presence or absence of tax motivation is no longer relevant, but that could change. After Facebook co-founder Eduardo Saverin departed for Singapore, Senators Chuck Schumer and Bob Casey introduced a bill to double the exit tax to 30% for anyone leaving the U.S. for tax reasons. That hasn’t happened, but taxes are still a big issue for many.

To leave America, you generally must prove 5 years of U.S. tax compliance. If you have a net worth greater than $2 million or average annual net income tax for the 5 previous years of $157,000 or more for 2014 (that’s tax, not income), you pay an exit tax. It is a capital gain tax as if you sold your property when you left. At least there’s an exemption of $680,000 for 2014. Long-term residents giving up a Green Card can be required to pay the tax too.

Now, the State Department interim rule just raised the fee for renunciation of U.S. citizenship to $2,350 from $450. Critics note that it’s more than twenty times the average level in other high-income countries. The State Department says it’s about demand on their services and all the extra workload they have to process people who are on their way out.

August 31, 2014 | Permalink | Comments (2)

Love Does

Love DoesOne of my favorite things about Pepperdine is the opportunity to meet some of the interesting people drawn to this place.  At last Wendesday's inaugural law school bible study, I met Bob Goff, an adjunct professor who is a legend on campus.  After meeting Bob, I bought and devoured his wonderful book, Love Does: Discover a Secretly Incredible Life in an Ordinary World:

As a college student he spent 16 days in the Pacific Ocean with five guys and a crate of canned meat. As a father he took his kids on a world tour to eat ice cream with heads of state. He made friends in Uganda, and they liked him so much he became the Ugandan consul. He pursued his wife for three years before she agreed to date him. His grades weren't good enough to get into law school, so he sat on a bench outside the Dean’s office for seven days until they finally let him enroll. 

Bob Goff has become something of a legend, and his friends consider him the world's best-kept secret. Those same friends have long insisted he write a book. What follows are paradigm shifts, musings, and stories from one of the world’s most delightfully engaging and winsome people. What fuels his impact? Love. But it's not the kind of love that stops at thoughts and feelings. Bob's love takes action. Bob believes Love Does.

When Love Does, life gets interesting. Each day turns into a hilarious, whimsical, meaningful chance that makes faith simple and real. Each chapter is a story that forms a book, a life. And this is one life you don't want to miss.

Light and fun, unique and profound, the lessons drawn from Bob's life and attitude just might inspire you to be secretly incredible, too.

I now have the title picked out for my first non-tax book:  Love Blogs.

August 31, 2014 in Book Club, Legal Education, Tax | Permalink | Comments (0)

Top 5 Tax Paper Downloads

SSRN LogoThere is a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads on SSRN, with a new paper debuting on the list at #3.  The #1 paper is now #22 in all-time downloads among 10,264 tax papers:

  1. [2722 Downloads]  'Competitiveness' Has Nothing to Do with it, by Edward D. Kleinbard (USC)
  2. [467 Downloads]  Guide to FATCA Compliance (Chapter 1, Background and Current Status of FATCA) (LexisNexis 2d ed. 2014), by William Byrnes (Thomas Jefferson), Denis Kleinfeld, & Alberto Gil Soriano
  3. [311 Downloads]  2013 Developments in Connecticut Estate and Probate Law, by Jeffrey A. Cooper (Quinnipiac) & John R. Ivimey (Reid and Riege, Hartford)
  4. [181 Downloads]  The Futility of Tax Protester Arguments, by Allen D. Madison (South Dakota)
  5. [153 Downloads]  The Most Critical Issue Facing Tax Administration Today -- And What to Do About It, by George K. Yin (Virginia)

August 31, 2014 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

The IRS Scandal, Day 479

Details Emerge in Murder of Dan Markel

Markel[Continually Updated]  More details are emerging in the July 18 murder of Dan Markel, D’Alemberte Professor of Law at Florida State and founder of PrawfsBlawg, as the result of a shooting in his home:

I have collected links to the many tributes to Dan here.

Dan Markel Memorial Fund To Benefit His Sons, Benjamin Amichai Markel and Lincoln Jonah Markel:

Markel

August 31, 2014 in Legal Education | Permalink | Comments (9)

Saturday, August 30, 2014

Rachel Moran Will Not Seek Second Term as UCLA Dean

Moran 2From: Moran, Rachel
Sent: Friday, August 29, 2014 11:02 AM
To: All Faculty & Staff
Subject: A Message from Dean Moran

Dear Friends and Colleagues,

I am writing to share with you that after careful consideration, I have decided not to pursue a second term as Dean. Over the coming months, Executive Vice Chancellor Scott Waugh will be forming a search committee to seek a replacement, and I have offered to stay in place until a successor is named to ensure a seamless and successful transition.

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August 30, 2014 in Legal Education | Permalink | Comments (0)

This Labor Day Weekend, End the Tyranny of 24/7 Email

New York Times:  End the Tyranny of 24/7 Email, by Clive Thompson:

DisconnectThis Labor Day weekend, odds are you’ll peek at your work email on your “day off” — and then feel guilty about it.

You might envy the serene workers at Daimler, the German automaker. On vacations, employees can set their corporate email to “holiday mode.” Anyone who emails them gets an auto-reply saying the employee isn’t in, and offering contact details for an alternate, on-call staff person. Then poof, the incoming email is deleted — so that employees don’t have to return to inboxes engorged with digital missives in their absence. “The idea behind it is to give people a break and let them rest,” a Daimler spokesman told Time magazine. “Then they can come back to work with a fresh spirit.”

Limiting workplace email seems radical, but it’s a trend in Germany, where Volkswagen and Deutsche Telekom have adopted policies that limit work-related email to some employees on evenings and weekends. If this can happen in precision-mad, high-productivity Germany, could it happen in the United States? Absolutely. It not only could, but it should.

White-collar cubicle dwellers complain about email for good reason. They spend 28 percent of their workweek slogging through the stuff, according to the McKinsey Global Institute. They check their messages 74 times a day, on average, according to Gloria Mark, an authority on workplace behavior and a professor at the University of California, Irvine. And lots of that checking happens at home.

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August 30, 2014 in Legal Education, Tax | Permalink | Comments (1)

Suffolk Law School Offers Buyouts to All Of Its Tenured Faculty

Following up on last month's post, Boston Law Schools Shrink Enrollments, Faculties:  Boston Globe, Suffolk University Abruptly Replaces President:

Sufolk Law SchoolJust days before the start of the new school year, Suffolk University Wednesday abruptly replaced president James McCarthy with a year remaining on his contract, and tapped a veteran educator with a reputation for turning around struggling colleges to serve as interim leader. At an afternoon meeting, the university’s board of trustees voted unanimously to appoint Norman R. Smith, 68, who is best known for his tenure at Wagner College in New York City, where he led a small school on the brink of closing to new prominence.. ...

Given the general decline in law school enrollment, Smith said he would expect to take a “quality over quantity” approach in assembling new classes. “I don’t think there’s growth there,” he said, referring to enrollment. ...

The unexpected change in leadership comes as Suffolk seeks to stabilize its finances and attract students in the college-dense region. Facing a decline in enrollment and revenue, the university announced in June it would freeze employee salaries for the next fiscal year.

It also offered buyouts to all law school faculty members with tenure or renewable long-term contracts.

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August 30, 2014 in Legal Education | Permalink | Comments (1)

The IRS Scandal, Day 478

Friday, August 29, 2014

Medtronic Will Pay CEO’s $25 Million Tax Bill on Merger

Bloomberg:  Medtronic Will Pay CEO’s $25 Million Tax Bill on Merger, by Michelle Fay Cortez & Zachary R. Mider:

MedtronicMedtronic plans to pick up a $25 million tax bill for Chief Executive Officer Omar Ishrak, the cost of a special penalty imposed by Congress on executives who shift their company’s tax domiciles out of the U.S. The company is also paying a $38 million tab for the rest of its top officers and directors, Minneapolis-based Medtronic said in a filing with U.S. regulators. The tax penalty arises from Medtronic’s plan to adopt an Irish address as part of its takeover of Covidien Plc.

The requirement stems from a 2004 law meant to discourage CEO’s from lowering their companies’ tax bills by shifting their legal addresses out of the U.S. It imposes an excise tax, currently 15 percent, on the value of any restricted stock or unexercised options the executives hold at the time of the transaction.

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August 29, 2014 in Tax | Permalink | Comments (0)

Weekly Tax Roundup

Weekly SSRN Tax Roundup

August 29, 2014 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Weekly Legal Education Roundup