TaxProf Blog

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

Friday, November 24, 2017

Michigan International Tax Symposium

Michigan Law Logo (2015)Tax Symposium, 38 Mich. J. Int'l L. 161-285 (2017):

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November 24, 2017 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Wednesday, November 22, 2017

Cato Institute Reviews Hatfield's Cybersecurity And Tax Reform

CatoChris Edwards (Cato Institute), Tax Reform, the IRS, Cybersecurity, and Privacy (reviewing Michael Hatfield (University of Washington), Cybersecurity and Tax Reform, 93 Ind. L.J. ___ (2018)):

The current tax reform debate has focused on economic growth and the value of cuts to different groups of taxpayers. Tax simplification has received less attention, and Republican bills would only make modest gains in that regard.

Yet a major tax code simplification would not only save time on administration, it would increase financial privacy and deter cyberattacks on the Internal Revenue Service. A new study by Michael Hatfield of the University of Washington looks at the risks posed by the IRS’s vast data collection on 290 million Americans. The more micromanagement there is in the tax code, the more information the IRS collects on our finances, lifestyles, and activities. ...

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November 22, 2017 in Scholarship, Tax | Permalink | Comments (0)

Dimick: Better Than Basic Income? Liberty, Equality, And The Regulation Of Working Time

Matthew Dimick (SUNY-Buffalo), Better than Basic Income? Liberty, Equality, and the Regulation of Working Time, 50 Ind. L. Rev. 473 (2017):

Basic income has attracted the attention of academics, policy makers, and politicians around the globe. Basic income — a no-strings-attached cash transfer made to all citizens of a country, rich or poor — has been lauded as a plan to eliminate poverty, reduce income inequality, redress imbalances in the labor market, remedy the impending problem of mass technology-induced unemployment — the “robot apocalypse” — and make possible meaningful lives for those otherwise dependent on menial work in the labor market. It has also been proposed as an efficient, nonpaternalistic, and stigma-free alternative to existing welfare state policies. This Article compares basic income to an alternative policy proposal: the regulation of maximum working hours in the labor market.

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November 22, 2017 in Scholarship, Tax | Permalink | Comments (0)

Tuesday, November 21, 2017

Williamson Presents Why Americans Are Proud To Pay Taxes Today at Columbia

Read My LipsVanessa S. Williamson (Brookings Institution) presents Read My Lips: Why Americans Are Proud to Pay Taxes (Princeton University Press 2017) at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium Series hosted by Alex Raskolnikov and Wojciech Kopczuk:

Conventional wisdom holds that Americans hate taxes. But the conventional wisdom is wrong. Bringing together national survey data with in-depth interviews, Read My Lips presents a surprising picture of tax attitudes in the United States. Vanessa Williamson demonstrates that Americans view taxpaying as a civic responsibility and a moral obligation. But they worry that others are shirking their duties, in part because the experience of taxpaying misleads Americans about who pays taxes and how much. Perceived "loopholes" convince many income tax filers that a flat tax might actually raise taxes on the rich, and the relative invisibility of the sales and payroll taxes encourages many to underestimate the sizable tax contributions made by poor and working people.

Americans see being a taxpayer as a role worthy of pride and respect, a sign that one is a contributing member of the community and the nation. For this reason, the belief that many Americans are not paying their share is deeply corrosive to the social fabric. The widespread misperception that immigrants, the poor, and working-class families pay little or no taxes substantially reduces public support for progressive spending programs and undercuts the political standing of low-income people. At the same time, the belief that the wealthy pay less than their share diminishes confidence that the political process represents most people.

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November 21, 2017 in Book Club, Colloquia, Scholarship, Tax | Permalink | Comments (1)

NYU Tax Law Review Publishes Symposium Issue: Tax Policy And Upward Mobility

NYUUCLAThe Tax Law Review has published a new issue (Vol. 70, No. 3 (Spring 2017)) on the NYU/UCLA Tax Policy Symposium, Tax Policy and Upward Mobility, 70 Tax L. Rev. 409-543 (2017):

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November 21, 2017 in Scholarship, Tax | Permalink | Comments (0)

Monday, November 20, 2017

Eyal-Cohen Presents The Cost Of Inexperience Today At Loyola-L.A.

Eyal-Cohen (2017)Mirit Eyal-Cohen (Alabama) presents The Cost of Inexperience at Loyola-L.A. today as part of its Tax Policy Colloquium Series hosted by Katie Pratt and Ted Seto:

Free market entry is vital in preventing concentration of market power and eliminating large deadweight losses. Yet, in recent years, studies show that newcomers are less successful than existing firms that have diversifies their products in the market. What might explain this phenomenon?

This Article unveils a regulatory catch 22. It reveals that although a regulation may be efficient in correcting a certain market failure, its distributional effects may create another. It exposes the degree to which “economies of experience” in regulation create significant disadvantages to newcomers and provide substantial advantages to oldtimers. Being well-versed in their marketplace, old-timers possess knowledge, familiarity, and influence over the rulemaking process. New or “green” entities entering regulated market or dealing with a new rule face proportionally larger costs to obtain regulatory insight. Consequently, an anomaly exists when government choice may de facto hamper innovation and survival of newcomers, the same goals it seeks to promote.

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November 20, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (1)

Wells: International Tax Reform By Means Of Corporate Integration

Florida Tax Review  (2015)Bret Wells (Houston), International Tax Reform By Means of Corporate Integration, 20 Fla. Tax Rev. 70 (2016):

This Article focuses on a single organizing question, namely how should a dividend paid deduction regime be designed so that it achieves acceptable international tax outcomes. By focusing on the international tax implications attendant with a dividend paid deduction regime, the author is not attempting to minimize the broader benefits of achieving shareholder-corporate integration. The dividend paid deduction proposal, as to distributed earnings, would equate the tax treatment of debt and equity, and in so doing it would reduce distortions that current law creates with respect to debt and equity in the corporate context. Furthermore, recent economic works suggest that the incidence of the corporate income tax burden is partially shifted to labor and away from shareholders whereas a properly designed integration proposal puts the incidence of business taxation squarely on shareholders. Furthermore, shareholder-corporate integration for C corporations harmonizes the divergent tax treatment that currently exists between C corporations and pass-through entities. Thus, a corporate integration proposal provides a broad spectrum of potential benefits, and so not surprisingly significant scholarship has been dedicated towards how to best achieve shareholder-corporate integration. But, in today’s era, the overwhelming tax policy problem that must be solved rests on finding a solution to the systemic international tax challenges that face the country, and so that is where this Article will focus.

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November 20, 2017 in Scholarship, Tax | Permalink | Comments (0)

Sunday, November 19, 2017

The Top Five New Tax Papers

SSRN LogoThis week's list of the Top 5 Recent Tax Paper Downloads is the same as last week's list:

  1. [402 Downloads]  Background and Current Status of FATCA and CRS, by William Byrnes (Texas A&M)
  2. [295 Downloads]  Rejecting Charity: Why the IRS Denies Tax Exemption to 501(C)(3) Applicants, by Terri Lynn Helge (Texas A&M)
  3. [294 Downloads]  The Rise of Trust Decanting in the United States, by Robert Sitkoff (Harvard)
  4. [201 Downloads]  Slicing and Dicing: The Structural Problems of the Tax Reform Framework, by Reuven Avi-Yonah (Michigan)
  5. [182 Downloads]  Exploiting the Medicare Tax Loophole (review here), by Karen C. Burke (Florida)

November 19, 2017 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Saturday, November 18, 2017

Colon: ETFs And In-Kind Redemptions

Jeffrey M. Colon (Fordham), The Great ETF Tax Swindle: The Taxation of In-Kind Redemptions, 122 Penn St. L. Rev. ___ (2017):

Since the repeal of the General Utilities doctrine over 30 years ago, corporations must recognize gain when distributing appreciated property to their shareholders. Regulated investment companies (RICs), which generally must be organized as domestic corporations, are exempt from this rule when distributing property in kind to a redeeming shareholder.

In-kind redemptions, while rare for mutual funds, are a fundamental feature of exchange-traded funds (ETFs). Because fund managers decide which securities to distribute, they distribute assets with unrealized gains and thereby significantly reduce the future tax burdens of their current and future shareholders. Many ETFs have morphed into investment vehicles that offer better after-tax returns than IRAs funded with after-tax contributions.

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November 18, 2017 in Scholarship, Tax | Permalink | Comments (0)

Friday, November 17, 2017

Weekly SSRN Tax Article Review And Roundup

This week, Sloan Speck (Colorado) reviews a new work by Kitty Richards, An Expressive Theory of Tax, 27 Cornell J.L. & Pub. Pol’y ___ (2018).

Speck (2017)In the early twentieth century, Joseph Schumpeter wrote that “[t]he spirit of a people, its cultural level, its social structure, the deeds its policy may prepare—all this and more is written in its fiscal history.” Following the money tells us more than just who has what; it yields insights into who we are, and what we want to be. Kitty Richard’s interesting and provocative article, An Expressive Theory of Tax, gives a framework for understanding these types of connections between tax law and society, as well as a number of examples “where what the tax code says is explicitly preferenced over what the code does.”

A significant accomplishment of Richards’s project is positive: thick description of “the values and desires that animate policy debates and legal opinions” in taxation. Richards analyzes the expressive aspects of public debates over the taxation of legal brothels in Nevada, the marriage penalties and bonuses doled out by the federal income tax, and the public policy exception for the deductibility of certain expenses. Furthermore, Richards claims that “cheap” talk of (frequently ineffective) incentives obscures the expressive inflection of debates over tax benefits for retirement savings, among other areas.

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November 17, 2017 in Scholarship, Sloan Speck, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Avi-Yonah: Altera, The Arm’s Length Standard, And Customary International Tax Law

Reuven S. Avi-Yonah (Michigan), Altera, the Arm’s Length Standard, and Customary International Tax Law, 38 Mich. J. Int'l L. Opinio Juris 1 (2017):

The recent Altera case in the US Tax Court (on appeal to the Ninth Circuit) raises interesting issues in regard to the much-debated topic of whether customary international tax law (CITL) exists. Altera involved the question whether the cost of employee stock options should be included in the pool of costs that must be shared under a cost sharing agreement. In Xilinx, the Ninth Circuit held under a previous version of the regulations that these costs should not be included because unrelated parties operating at arm’s length would not have agreed to include them. Treasury then amended the regulation to state specifically that “all” costs includes the cost of stock options but did not carve out an exception from the arm’s length standard. In Altera, the Tax Court sitting en banc invalidated the new regulation on the ground that it was inconsistent with the arm’s length standard (ALS).

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November 17, 2017 in Scholarship, Tax | Permalink | Comments (0)

Thursday, November 16, 2017

Goldin Presents Complexity and Take-up of the Earned Income Tax Credit At Northwestern

Goldin (2017)Jacob Goldin (Stanford) presented Complexity and Take-up of the Earned Income Tax Credit at Northwestern yesterday as part of its Advanced Topics in Taxation Workshop Series hosted by Sarah Lawsky:

Tax benefits like the Earned Income Tax Credit (EITC) represent an important source of income to their recipients, but millions of those who are eligible to claim tax benefits fail to do so. One possible explanation is that the rules governing most tax benefits are extraordinarily complex. I consider efforts to increase tax benefit take-up in light of this complexity. A key fact in thinking about this issue is that the vast majority of tax filers today prepare their taxes with assisted preparation methods (APMs) like software or professional assistance. Because APMs eliminate most of the barriers to claiming tax benefits for which one is eligible, I ague that efforts to increase benefit take-up should focus on inducing benefit-eligible individuals to file a tax return using an APM. In contrast, efforts aimed at increasing awareness of a benefit (of the type widely employed by governments and nonprofits) are less likely to be successful, except to the extent they themselves induce an increase in tax filing.

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November 16, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (1)

Knoll: The Disparate Federal Income Tax Treatment Of Business And Non-Business State And Local Taxes

Michael S. Knoll (Pennsylvania), Not Too SALT-y: The Disparate Federal Income Tax Treatment of Business and Non-Business State and Local Taxes:

The Tax Cuts and Jobs Act, H.R. 1, would eliminate the federal income tax deduction for nonbusiness state and local taxes while maintaining the deduction for business state and local taxes. That disparate treatment has generated a storm of negative commentary. In this short essay, I consider whether the federal tax law should allow a deduction for business state and local taxes assuming that there is no deduction for nonbusiness state and local taxes. I argue that investors and businesses, including pass-through businesses, should be allowed to deduct state and local property and sales taxes, but not general income taxes. 

November 16, 2017 in Scholarship, Tax | Permalink | Comments (0)

Herzfeld: A History Of The ABA Tax Section

ABA Tax Section (2017)Mindy Herzfeld (Florida), How Lawyers Dominate: A History of the ABA Tax Section:

The story of how tax attorneys came to dominate the fields of tax policy and sophisticated tax practice is the success story of an organized professional association. The prominence of the role of attorneys in the development and practice of the tax law was not a foregone prerequisite of the U.S. federal income tax system. Rather, the professional organization of attorneys into a specialized group within bar associations has played a significant role in making lawyers the central players in tax policy and tax practice in the U.S.

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November 16, 2017 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0)

Wednesday, November 15, 2017

Lockwood Presents Regressive Sin Taxes Today At Penn

LockwoodBenjamin B. Lockwood (Pennsylvania) presents Regressive Sin Taxes (with Dmitry Taubinsky (UC-Berkeley)) at Pennsylvania today as part of its Tax Policy Workshop Series hosted by Chris Sanchirico and Reed Shuldiner:

A common objection to “sin taxes” — corrective taxes on goods like cigarettes, alcohol, and sugary drinks, which are believed to be over-consumed — is that they fall disproportionately on low-income consumers. This paper studies the interaction between corrective and redistributive motives in a general optimal taxation framework. On the one hand, redistributive concerns amplify the corrective benefits of a sin tax when sin good consumption is concentrated on the poor, even when bias and demand elasticities are constant across incomes. On the other hand, a sin tax can generate regressivity costs, raising more revenue from the poor than from the rich.

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November 15, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (1)

Ring Reviews Hatfield's Cybersecurity And Tax Reform

Jotwell (Tax) (2016)Diane Ring (Boston College), Cybersecurity and Tax Information: A Vicious Cycle? (JOTWELL) (reviewing Michael Hatfield (University of Washington), Cybersecurity and Tax Reform, 93 Ind. L.J. ___ (2018)):

The international tax arena is awash with calls for tax transparency, and a variety of reforms are underway at the national, regional and global level to bring such transparency to fruition. See, e.g., Joshua Blank’s recent article The Timing of Tax Transparency [90 S. Cal. L. Rev. 449 (2017)], reviewed by Omri Marian earlier this year. Of course, with great caches of information comes great potential for security breaches of all types. Michael Hatfield, in his forthcoming article, Cybersecurity and Tax Reform, draws attention to the immensely important cybersecurity risks and challenges of a tax system founded on government collection and use of significant quantities of information. Quoting a former FBI Assistant Director, Hatfield describes IRS taxpayer information as “the gold standard” for being a “treasure trove of information” from the perspective of cyber criminals—large quantities of very valuable data housed in one agency. Is the IRS ready? Maybe not.

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November 15, 2017 in Scholarship, Tax | Permalink | Comments (0)

Tuesday, November 14, 2017

Call For Papers: International Tax Law And Policy

Call For Papers: International Tax Law And Policy:

Media reports of tax avoidance scandals have drawn unprecedented attention to the importance of robust international tax law and policy. Although without the same level of media fanfare, the OECD’s base erosion and profit shifting (BEPS) program has similarly commanded substantial attention over the last five years.

For many tax scholars, the draw of these twin pillars — tax avoidance scandals and BEPS — has been irresistible and much international tax scholarship has focused on engaging with the details of those issues. However, the pervasive and critical challenges of appropriate international tax system design remain.

This Special Issue asks scholars to look beyond the dominant conversations and to survey the changing landscape of international tax law and policy.

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November 14, 2017 in Scholarship, Tax | Permalink | Comments (0)

Chorvat: Anti-Inversion Regulation Invalidated In Federal Court

Elizabeth Chorvat (Illinois), Anti-Inversion Regulation Invalidated in Federal Court, 157 Tax Notes 401 (Oct. 16, 2017):

Under the Supreme Court’s Mayo decision, legislative and interpretive regulations are accorded Chevron deference if they comply with the Administrative Procedure Act (APA) notice and comment requirements. In Chamber of Commerce v. IRS on September 29, the U.S. District Court for the Western District of Texas extended the rule to temporary regulations, invalidating reg. section 1.7874-8T, the so-called multiple acquisition rule, for failure to comply with the notice and comment procedures under the APA. Reg. section 1.7874-8T was issued as part of the 2016 temporary regulations designed to limit the U.S. tax benefits following an inversion.

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November 14, 2017 in Scholarship, Tax | Permalink | Comments (0)

Monday, November 13, 2017

Herzig Presents Structural Inequities Of Exchange Traded Funds Today At Loyola-L.A.

Herzig (2018)David Herzig (Valparaiso) presents Structural Inequities of Exchange Traded Funds at Loyola-L.A. today as part of its Tax Policy Colloquium Series hosted by Katie Pratt and Ted Seto:

Exchange Trade Funds (ETFs) have almost as many assets under management as Mutual Funds. ETFs are often compared to Mutual Funds as a more efficient version of the same structure. The popular narrative espouses that these tax efficiencies account for the growth of the sector. This narrative is incomplete and misleading. These two structures have key differences other than tax efficiency. These structural differences have created an environment where aggressive bets against their performance, e.g. shorts, and high levels of internal leverage of the fund take place. Because of the vulnerabilities caused by the structural differences between ETFs and Mutual Funds, ETFs may not be the better structure but, rather, be the canary in the coal mine for the next market crash. This article proposes both tax and regulatory rules to rein in ETFs.

 

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November 13, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Applications To Attend 2018 Tax Court Judicial Conference At Northwestern Are Due Nov. 17

Northwestern Tax Court
The 2018 Tax Court Judicial Conference will be held at Northwestern Law School on March 26-28, 2018 (press release; FAQ):

The purpose of the judicial conference is to provide attendees with the opportunity to (1) review and discuss issues of material interest regarding the tax litigation process, (2) discuss ways in which the tax litigation process in the Court may be improved, and (3) network with fellow Tax Court practitioners. In addition to the Judges of the United States Tax Court, the Court intends to invite representatives from the Internal Revenue Service, the Department of Justice, private practice, low-income taxpayer clinics, academia, Capitol Hill, and other courts. A variety of plenary and breakout sessions will address issues relevant to practice before the Court.

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November 13, 2017 in Conferences, Scholarship, Tax | Permalink | Comments (0)

An Expressive Theory of Tax

Kitty Richards, An Expressive Theory of Tax, 26 Cornell J.L. & Pub. Pol'y ___ (2017):

The tax code is full of ineffective, inefficient, inequitable, or otherwise problematic provisions that make little sense when evaluated through the lens of traditional tax policy analysis, yet remain popular with citizens and legislators alike. The tax literature is equally full of carefully-researched, technically precise, and theoretically sound proposals for reform that nonetheless fail to get traction in the public debate. Why?

What tax scholarship is missing is the importance of social meaning: what do our tax laws say about our society’s values, and how is taxation being used to construct cultural ideals in contested spaces?

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November 13, 2017 in Scholarship, Tax | Permalink | Comments (0)

Sunday, November 12, 2017

Increases In Federal Student Loan Limits Do Not Induce Private Law Schools To Raise Tuition

Robert Kelchen (Seton Hall), An Empirical Examination of the Bennett Hypothesis in Law School Prices:

Whether colleges increase tuition in response to increased federal student loan limits (the Bennett Hypothesis) has been a topic of debate in the higher education community for decades, yet most studies have been based on small increases to Pell Grant or undergraduate student loan limits. In this paper, I leverage a large increase in Grad PLUS loan limits that took place in 2006 to examine whether law schools responded by raising tuition or other living expenses and whether student debt levels also increased. Using data from 2001 to 2015 across public and private law schools and both interrupted time series and difference-in-differences analytical techniques, I found rather modest relationships across both public and private law schools. I conclude with some possible explanations for the lack of strong empirical support for the Bennett Hypothesis.

Debt

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November 12, 2017 in Legal Education, Scholarship | Permalink | Comments (1)

Johnson Posts Tax Papers On SSRN

SSRN LogoCalvin H. Johnson (Texas) has posted several tax papers on SSRN:

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November 12, 2017 in Scholarship, Tax | 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 #1 paper and a new paper debuting on the list at #5:

  1. [370 Downloads]  Background and Current Status of FATCA and CRS, by William Byrnes (Texas A&M)
  2. [292 Downloads]  Rejecting Charity: Why the IRS Denies Tax Exemption to 501(C)(3) Applicants, by Terri Lynn Helge (Texas A&M)
  3. [285 Downloads]  The Rise of Trust Decanting in the United States, by Robert Sitkoff (Harvard)
  4. [186 Downloads]  Slicing and Dicing: The Structural Problems of the Tax Reform Framework, by Reuven Avi-Yonah (Michigan)
  5. [163 Downloads]  Exploiting the Medicare Tax Loophole (review here), by Karen C. Burke (Florida)

November 12, 2017 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Saturday, November 11, 2017

NTA 110th Annual Conference On Taxation

National Tax Association (2016)The three-day National Tax Association 110th Annual Conference on Taxation concludes today in Philadelphia.  Today's highlights include:

Session #70: Capital Gains and Wealth Taxation

Session Organizer:  David Kamin (NYU)
Session Chair:  Jon Bakija (Williams College)

Tim Dowd (Joint Committee on Taxation), Robert McClelland (Urban Institute) & Jacob Mortenson (Joint Committee on Taxation), Do Tax Elasticities Change Over the Business Cycle? Evidence From the Sale of Capital Assets
Discussant:  Jon Bakija (Williams College)

Ari Glogower (Ohio State), Taxing Income and Wealth
Discussant:  William Gentry (Williams College)

David Kamin (NYU) & Jason Oh (UCLA), The Effects of Capital Gains Rate Uncertainty on Realization
Discussant:  Jon Bakija (Williams College)

David Miller (Proskauer Rose, New York), A Comprehensive Mark-to-Market Tax
Discussant:  William Gentry (Williams College)

Session #78:  Tax Law and Finance

Session Organizer:  David Kamin (NYU) 
Session Chair & Discussant:  Brian Galle (Georgetown)

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November 11, 2017 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Friday, November 10, 2017

Weekly SSRN Tax Article Review And Roundup

This week, Orly Mazur (SMU) reviews a new work by Anthony Polito (Suffolk), Mandatory Passthrough Taxation for Non-Publicly Traded Businesses?, 36 Va. Tax Rev. 449 (2017).

Mazur (2017-2)Anthony Polito’s timely new work considers whether passthrough taxation should be made available to all non-publicly traded businesses, without regard to form of business entity, and whether such tax treatment should be mandatory. 

Currently, most closely held businesses (except for those organized in the corporate form) may elect to benefit from a single level of taxation, whereas corporate business entities and most publicly traded entities are taxed as C corporations and subject to double taxation. As a result, newly-formed, non-publicly traded entities are only subject to subchapter C by choice. So when would an entity voluntarily subject itself to the double taxation regime? As the Article explains, a business would elect corporate taxation over passthrough taxation when an “insider shelter” tax strategy is available: namely, when the tax burden on a taxable corporate entity is less than on a passthrough entity. 

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November 10, 2017 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

NTA 110th Annual Conference On Taxation

National Tax Association (2016)The three-day National Tax Association 110th Annual Conference on Taxation continues today in Philadelphia.  Today's highlights include:

Session 45:  Taxing the Future

Session Organizer:  David Kamin (NYU)
Session Chair & Discussant:  David Herzig (Valparaiso)

Other Tax Prof presentations today include:

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November 10, 2017 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, November 9, 2017

NTA 110th Annual Conference On Taxation

National Tax Association (2016)The three-day National Tax Association 110th Annual Conference on Taxation kicks off today in Philadelphia.  Today's highlights include:

Session #5:  Redistribution

Session Organizer: David Kamin (NYU)
Session Chair & Discussant: Jeremy Bearer-Friend (NYU)

Session #14:  Tax Expenditures

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November 9, 2017 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Barry Presents Collusion In Markets With Syndication Today At Pepperdine

Barry (2017)Jordan Barry presents Collusion in Markets With Syndication (with John Hatfield (Texas), Scott Kominers (Harvard) & Richard Lowery (Texas)) at Pepperdine today as part of our Faculty Workshop Series hosted by Babette Boliek:

Many markets, including the markets for IPOs and debt issuances, are syndicated, in that a bidder who wins a contract will often invite competitors to join a syndicate that will fulfill the contract. We model syndicated markets as a repeated extensive form game, and show that standard intuitions from industrial organization can be reversed: Collusion may become easier as market concentration falls, and market entry may in fact facilitate collusion. In particular, price collusion can be sustained by a strategy in which firms refuse to join the syndicate of any firm that deviates from the collusive price, thereby raising total production costs. Our results can thus rationalize the apparently contradictory empirical facts that the market for IPO underwriting exhibits seemingly collusive pricing despite its low level of market concentration.

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November 9, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Wednesday, November 8, 2017

Cardozo Hosts Book Launch Today For Zelinsky's Taxing The Church

Taxing the churchCardozo is hosting a panel discussion with Miranda Perry Fleischer (San Diego), Brian Galle (Georgetown), and Daniel Hemel (Chicago) to discuss the new book by Edward A. Zelinsky (Cardozo), Taxing the Church: Religion, Exemptions, Entanglement, and the Constitution (Oxford University Press 2017):

  • Explores the taxation and exemption of churches and other religious institutions, both empirically and normatively
  • Reveals that churches and other religious institutions are treated diversely by the federal and state tax systems
  • Focuses on church-state entanglements with respect to taxing or exempting churches and other sectarian entities
  • Discusses improvements that can be made in legal and tax policy trade-offs, such as the protection of internal church communications and the expansion of the churches' sales tax liabilities
  • A clear, balanced, and comprehensive treatment of the topic that is broadly accessible to tax policymakers, lawyers, nonlawyers, judges, tax specialists, and even those with no background in the subject

Peter J. Reilly has an extensive review on Forbes.  Other reviews:

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November 8, 2017 in Book Club, Conferences, Scholarship, Tax | Permalink | Comments (1)

Viard Presents Taxes, Transfers, Progressivity, And Redistribution Today At Penn

Viard (2016)Alan D. Viard (American Enterprise Institute) presents Taxes, Transfers, Progressivity, And Redistribution, Part 1, 140 Tax Notes 1437 (Sept. 5, 2016) and Part 2, 140 Tax Notes 1879 (Sept. 26, 2017) (with Sita N. Slavov (George Mason)), at Pennsylvania today as part of its Tax Policy Workshop Series hosted by Chris Sanchirico and Reed Shuldiner:

In Part 1, Slavov and Viard explain how to measure the extent of redistribution induced by a tax transfer system, the impact of the size and progressivity of taxes and transfers, and the proper comparison of the effects of taxes and transfers. In Part 2, Slavov and Viard discuss the policy issues regarding the choice of a fiscal system’s size and progressivity.

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November 8, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Satterthwaite: Can Audits Encourage Tax Evasion?

Florida Tax Review  (2015)Emily Ann Satterthwaite (Toronto), Can Audits Encourage Tax Evasion?: An Experimental Assessment, 20 Fla. Tax Rev. 1 (2016):

Governments and tax administrators around the world rely on the premise that random audits can be used to reduce tax evasion through two channels of deterrence: first, the ex ante indirect threat of audit will induce taxpayers to truthfully report their income and, second, that the lived experience of audit will deter audited taxpayers from cheating in the future (“direct deterrence,” Alm et al. 2009). This paper provides original experimental evidence of the failure of the direct deterrence channel. Contrary to the predictions of the standard economic model of tax compliance, I find that random audits are ineffective in fostering higher post-audit levels of compliance. Surprisingly, they induce experiment participants to cheat more in the tax periods after the audit (the “bomb crater” effect).

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November 8, 2017 in Scholarship, Tax | Permalink | Comments (2)

Tuesday, November 7, 2017

Aprill: The Tax Consequences Of Legal Defense Funds

LDFEllen Aprill (Loyola-L.A.), Tax Consequences of Legal Defense Funds:

President Trump and a number of his associates have established legal defense funds (LDFs) in connection with various Congressional investigations, the investigation by Special Counsel Mueller, and in anticipation of possible legal action.  Legal defense funds for government officials have a long history.  The U.S. Senate and the House have detailed rules regarding LDFs for their members.  The most famous LDFs were the two Clinton LDFs.  Over the years, the Office of Government Ethics (OGE) has given some guidance on LDFs for members of the executive branch, particularly with regard to the solicitation and receipt of gifts. For example, it informed President Clinton that, although he was not subject as president to rules limiting the acceptance of gifts, because he and his wife established his first LDF, he and his agents were subject to laws forbidding executive branch official from soliciting gifts for that LDF.  OGE guidance regarding LDFs is far less complete than the Senate and House rules.  Recently, OGE issued an advisorythat an LDF must prohibit contributions from anonymous sources. 

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November 7, 2017 in Scholarship, Tax | Permalink | Comments (0)

Monday, November 6, 2017

Tillotson Presents Give and Take: The Citizen-Taxpayer And The Rise Of Canadian Democracy Today At McGill

Give and TakeShirley Tillotson (Dalhousie University) presents Give and Take: The Citizen-Taxpayer and the Rise of Canadian Democracy (University of British Columbia Press Nov. 15, 2017) at McGill today as part of its Spiegel Sohmer Tax Policy Colloquium Series convened by Allison Christians:

Can a book about tax history be a page-turner? You wouldn’t think so. But Give and Take is full of surprises. A Canadian millionaire who embraced the new federal income tax in 1917. A socialist hero, J.S. Woodsworth, who deplored the burden of big government. Most surprising of all, Give and Take reveals that taxes deliver something more than armies and schools. They build democracy.

Tillotson launches her story with the 1917 war income tax, takes us through the tumultuous tax fights of the interwar years, proceeds to the remaking of income taxation in the 1940s and onwards, and finishes by offering a fresh angle on the fierce conflicts surrounding tax reform in the 1960s.

Taxes show us the power of the state, and Canadians often resisted that power, disproving the myth that we have all been good loyalists. But Give and Take is neither a simple tale of tax rebels nor a tirade against the taxman. Canadians also made real contributions to democracy when they taxed wisely and paid willingly.

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November 6, 2017 in Book Club, Colloquia, Scholarship, Tax | Permalink | Comments (0)

Haufler Presents Bonus Taxes And International Competition For Bank Managers Today At UC-Berkeley

HauflerAndreas Haufler (University of Munich) presents Bonus Taxes and International Competition for Bank Managers (with Daniel Gietl (University of Munich)) at UC-Berkeley today as part of its  Robert D. Burch Center for Tax Policy and Public Finance Seminar Series:

We analyze the competition in bonus taxation when banks compensate their managers by means of fixed and incentive pay and bankers are internationally mobile. Banks choose bonus payments that induce excessive managerial risk-taking to maximize their private benefits of existing government bailout guarantees. In this setting the international competition in bonus taxes may feature a ‘race to the bottom’ or a ‘race to the top’, depending on whether bankers are a source of net positive tax revenue or inflict net fiscal losses on taxpayers as a result of incentive pay.

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November 6, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Clausing Presents Corporate Tax Reform In The Age Of Trump Today At Loyola-L.A.

Clausing (2018)Kimberly Clausing (Reed College) presents Corporate Tax Reform in the Age of Trump at Loyola-L.A. today as part of its Tax Policy Colloquium Series hosted by Katie Pratt and Ted Seto:

After the failure of Ryan/Brady Blueprint, which relied on a destination-based cash flow tax, the Republicans have proposed dramatic changes to corporate taxation in their Unified Framework. This presentation will consider these reform proposals within the context of the larger role of the corporate tax. The corporate tax is an indispensible part of our larger tax system. It is our only comprehensive tool for taxing capital income, it helps protect the individual income tax system, and it plays an essential role in both the efficiency and equity of our tax system. Given the many functions that the corporate tax performs, potential reform proposals should address how they are affecting each of these considerations.

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November 6, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Sunday, November 5, 2017

The Top Five New Tax Papers

SSRN LogoThis week's list of the Top 5 Recent Tax Paper Downloads is the same as last week's list, with some re-shuffling of the order within the Top 5. The #1 paper is #21 among 13,081 tax papers in all-time downloads.

  1. [4,818 Downloads]  Private Benefits in Public Offerings: Tax Receivable Agreements in IPOs, by Gladriel Shobe (BYU)
  2. [361 Downloads]  Background and Current Status of FATCA and CRS, by William Byrnes (Texas A&M)
  3. [279 Downloads]  Rejecting Charity: Why the IRS Denies Tax Exemption to 501(C)(3) Applicants, by Terri Lynn Helge (Texas A&M)
  4. [277 Downloads]  The Rise of Trust Decanting in the United States, by Robert Sitkoff (Harvard)
  5. [176 Downloads]  Slicing and Dicing: The Structural Problems of the Tax Reform Framework, by Reuven Avi-Yonah (Michigan)

November 5, 2017 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Saturday, November 4, 2017

Weekly SSRN Tax Article Review And Roundup

This week, David Gamage (Indiana) reviews a new draft paper by Daniel Hemel (Chicago), Easy on the SALT: A Qualified Defense of the Deduction for State and Local Taxes.

Gamage (2019)Prompted — at least in part — by Congressional Republicans’ recently released tax reform proposals, Daniel Hemel has written a thoughtful new piece on the state and local tax (SALT) deduction. Although Hemel’s paper is currently in preliminary draft form, this draft is nevertheless well worth a read for anyone interested in taxation at either the federal or state levels in the United States.

Hemel thoughtfully reviews arguments both for and against the SALT deduction, concluding that “the case against the SALT deduction fails on its own terms, and that the status quo of partial deductibility offers a number of underappreciated advantages vis-à-vis the alternative of full repeal.”

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November 4, 2017 in David Gamage, Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Friday, November 3, 2017

Max Planck, Norwegian Centre For Taxation & Notre Dame Host Conference On BEPS: Tax Evasion Or Tax Avoidance

ConferenceThe Max Planck Institute for Tax Law and Public Finance, Norwegian Centre for Taxation, and Notre Dame are hosting a conference on From Panama to BEPS: Tax Evasion or Tax Avoidance —International and National Policies to Confront Personal and Corporate Tax Strategies in Bergen, Norway (program):

Session #1:  Shifting Income Between Schedules

Session #2:  Income and Investment Shifting

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November 3, 2017 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Book: Improving Refundable Credits While Reflecting The Lives Of The Working Poor

Leslie Book (Villanova), Meeting Taxpayers Where They Live: Improving US Refundable Credits While Reflecting the Lives of the Working Poor, 3 J. Tax Admin. ___ (2017):

This paper looks at the American experience in using tax law to deliver benefits to low and moderate-wage workers. First, examining two recent court cases where individuals improperly claimed the earned income tax credit, this paper explores some of the challenges to both taxpayers and tax administrators associated with using the tax system to deliver benefits that are dependent on levels of attachment to children and the presence of earned income. The paper then explores two approaches to improve compliance. One approach is a proposal in a recent Heritage Foundation policy briefing recommending that only parents with legal custody of their children should be entitled to receive the earned income tax credit. The state of California, in adopting the other approach, excludes self-employment income from its definition of earned income in its state earned income tax credit. Both measures fail to reflect characteristics of the lives of the working poor, including a growing reliance on multi-generational living arrangements and shared care of children and a surge in nontraditional employment associated with the gig economy.

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November 3, 2017 in Scholarship, Tax | Permalink | Comments (1)

Thursday, November 2, 2017

Kamin & Kysar: Temporary Tax Laws And The Budget Baseline

David Kamin (NYU) & Rebecca M. Kysar (Brooklyn), Temporary Tax Laws and the Budget Baseline, 157 Tax Notes 125 (Oct. 2, 2017):

In this article, we discuss the inconsistent use of the current policy baseline by policymakers, which undermines budget enforcement and represents a deep violation of Senate norms. We further describe how the potentially dangerous disruption to the budget process provides an opportunity to improve the official baseline.

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November 2, 2017 in Scholarship, Tax | Permalink | Comments (0)

Assessing President Trump's Child Care Proposals

Lily L. Batchelder (NYU), Elaine Maag (Urban Institute), Chye-Ching Huang (Auckland) & Emily Horton (Center on Budget and Policy Priorities), Assessing President Trump's Child Care Proposals, 70 Nat'l Tax J. ___ (2017):

During the presidential campaign, Donald Trump proposed three tax benefits for child care: a credit for low-income families, an above-the-line deduction, and tax-subsidized savings accounts. While these proposals laudably bring attention to the heavy burden that child care costs place on many low- and middle-income families, they are a case study in how not to reform child care policy. They are unduly complicated, arbitrarily exclude certain low-income families, deliver support well after child care payments are due, and provide the largest benefits to higher-income families who need the least help.

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November 2, 2017 in Scholarship, Tax | Permalink | Comments (0)

Macroeconomic Modeling Of Tax Policy: A Comparison Of Current Methodologies

Alan Auerbach (UC-Berkeley), Itai Grinberg (Georgetown), Thomas Barthold (Joint Committee on Taxation), Nicholas Bull (Joint Committee on Taxation), Gavin Elkins (Tax Foundation), Pamela Moomau (Joint Committee on Taxation), Rachel Moore (Joint Committee on Taxation), Benjamin Page (Tax Policy Center), Brandon Pecoraro (Joint Committee on Taxation) & Kyle Pomerleau (Tax Foundation), Macroeconomic Modeling of Tax Policy: A Comparison of Current Methodologies, 70 Nat'l Tax J. ___ (2017):

The macroeconomic effects of tax reform are a subject of significant discussion and controversy. In 2015, the House of Representatives adopted a new “dynamic scoring” rule requiring a point estimate within the budget window of the deficit effect due to the macroeconomic response to certain proposed tax legislation. The revenue estimates provided by the staff of the Joint Committee on Taxation (JCT) for major tax bills often play a critical role in Congressional deliberations and public discussion of those bills. The JCT has long had macroeconomic analytic capability, and in recent years, responding to Congress’ interest in macrodynamic estimates for purposes of scoring legislation, outside think tank groups — notably the Tax Policy Center and the Tax Foundation — have also developed macrodynamic estimation models. The May 2017 National Tax Association (NTA) Spring Symposium brought together the JCT with the Tax Foundation and the Tax Policy Center for a panel discussion regarding their respective macrodynamic estimating approaches. This paper reports on that discussion.

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November 2, 2017 in Scholarship, Tax | Permalink | Comments (0)

Yin: Constructing Tax Legislation In A Highly Polarized Congress

George K. Yin (Virginia), Of Geodesic Domes and Mud Huts: Constructing Tax Legislation in a Highly Polarized Congress:

This essay attempts to connect the process and product of tax legislation. It argues that changes in the tax legislative process over the last 25-30 years have affected the type of legislation produced by Congress. After identifying several developments, including the changing composition of professional tax staffers working on legislation, the essay shows that a decline in one particular category of legislation — complex change to improve the execution of current policies by advancing the efficiency, equity, or administrability of existing law — may be a natural outgrowth of changing legislator and staff interests and incentives.

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November 2, 2017 in Scholarship, Tax | Permalink | Comments (1)

Wednesday, November 1, 2017

Tahk Presents The New Welfare Rights Today At Northwestern

Tahk (2017)Susannah Tahk (Wisconsin) presents The New Welfare Rights, 82 Brook. L. Rev. ___ (2017), at Northwestern as part of its Advanced Topics in Taxation Workshop Series hosted by Sarah Lawsky:

Participating in the tax system gives rise to what could be enormously powerful rights for poor people. The tax system has become one of the main tools the U.S. uses to fight poverty. A thick bundle of tax rights accompanies the many tax antipoverty programs. This paper is the first to recognize the potentially substantial rights that poor people have through the tax code. For decades, poverty law advocates and scholars have lamented the decline of the “welfare rights” that poor people once had in their benefits. No one has yet recognized that in fact poor people still have substantial rights in the tax code. These “new welfare rights” are not rights that lawmakers are attempting to weaken but rights that they are strengthening. However, lawyers and lawmakers have yet to unlock the potential that tax rights have to improve the lives of poor people. This paper discusses two methods by which this can happen.

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November 1, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Shaheen Presents Income Tax Treaty Aspects Of Nonincome Taxes Today At Penn

Shaheen (2017)Fadi Shaheen (Rutgers) presents Income Tax Treaty Aspects of Nonincome Taxes at Pennsylvania today as part of its Tax Policy Workshop Series hosted by Chris Sanchirico and Reed Shuldiner:

This discussion draft — prepared for the 7th Annual NYU/UCLA Tax Policy Symposium on New Approaches to Calculation and Allocation of the International Tax Base held on October 27, 2017 — considers the income tax treaty aspects of nonincome taxes such as the retail sales tax, the value added tax, the flat tax, the X tax and the destination-based cashflow tax. The current draft focuses on three main issues: one that the literature has thus far missed, another regarding an argument I disagree with, and a third the discussion of which was avoided. The point that was missed is the question of residence, which is a critical treaty gateway issue. The argument is that if the United States replaces the existing income tax with any nonincome tax discussed here, the affected U.S. taxpayers would no longer be U.S. residents for treaty purposes and as such would no longer be entitled to benefits under existing income tax treaties.

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November 1, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Marian Presents Is All Corporate Tax Planning Good For Shareholders? Today At Toronto

Marian (2016)Omri Marian (UC-Irvine) presents Is All Corporate Tax Planning Good for Shareholders? at Toronto today as part of its James Hausman Tax Law and Policy Workshop Series:

Multiple commentators argue that corporate managers have an affirmative duty to engage in corporate tax planning. Underlying this argument is the assumption that reduced corporate tax liability enhances shareholder value. In this article, I explain that this common perception is frequently incorrect. Corporate tax reduction schemes may increase the overall tax burden on shareholders. I make the following descriptive arguments in this regard:

First, I show that in many cases, successful (and legal) corporate tax planning schemes are not Pareto-optimal to shareholders. Some classes of shareholders (generally, tax-exempt shareholders) may see a net benefit, while other shareholders (usually taxable shareholders) experience a net loss. Second, I show that in certain instances it is reasonable to expect that legal corporate tax planning schemes will be overall inefficient. Meaning, the losses to taxable shareholders may exceed the gains to tax-exempt shareholders. Lastly, I show that because of an underappreciated agency problem, shareholders approve inefficient corporate tax plans, even when information about the potential detriment is freely available.

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November 1, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

SSRN Tax Professor Rankings

SSRN LogoSSRN has updated its monthly rankings of 750 American and international law school faculties and 3,000 law professors by (among other things) the number of paper downloads from the SSRN database.  Here is the new list (through October 1, 2017) of the Top 25 U.S. Tax Professors in two of the SSRN categories: all-time downloads and recent downloads (within the past 12 months):

 

 

All-Time

 

Recent

1

Reuven Avi-Yonah (Mich.)

72,112

Reuven Avi-Yonah (Mich.)

12,456

2

Michael Simkovic (USC)

37,386

Lily Batchelder (NYU)

7585

3

Paul Caron (Pepperdine)

33,609

D. Dharmapala (Chicago)

3792

4

D. Dharmapala (Chicago)

31,996

Michael Simkovic (USC)

3489

5

Louis Kaplow (Harvard)

28,618

Richard Ainsworth (BU)

3400

6

Vic Fleischer (San Diego)

24,032

Michael Graetz (Columbia)

2978

7

Ed Kleinbard (USC)

23,474

Andy Grewal (Iowa)

2940

8

James Hines (Michigan)

23,181

David Gamage (Indiana)

2926

9

Richard Kaplan (Illinois)

22,268

David Weisbach (Chicago)

2598

10

Ted Seto (Loyola-L.A.)

22,243

Ed Kleinbard (USC)

2451

11

Richard Ainsworth (BU)

22,137

Louis Kaplow (Harvard)

2079

12

Katie Pratt (Loyola-L.A.)

20,565

Hugh Ault (Boston College)

2075

13

David Weisbach (Chicago)

19,790

Darien Shanske (UC-Davis)

2027

14

Robert Sitkoff (Harvard)

19,293

Daniel Shaviro (NYU)

1891

15

Brad Borden (Brooklyn)

18,735

Steven Bank (UCLA)

1801

16

Carter Bishop (Suffolk)

18,366

William Byrnes (Texas A&M)

1771

17

Francine Lipman (UNLV)

17,969

Omri Marian (UC-Irvine)

1759

18

Chris Sanchirico (Penn)

17,924

Bridget Crawford (Pace)

1656

19

Daniel Shaviro (NYU)

17,883

Jordan Barry (San Diego)

1590

20

Jen Kowal (Loyola-L.A.)

17,734

Jeff Kwall (Loyola-Chicago)

1549

21

Bridget Crawford (Pace)

17,654

Paul Caron (Pepperdine)

1491

22

Dennis Ventry (UC-Davis)

16,634

Stephen Shay (Harvard)

1486

23

Steven Bank (UCLA)

15,762

Francine Lipman (UNLV)

1465

24

David Walker (BU)

15,759

Cliff Fleming (BYU)

1450

25

Gregg Polsky (Georgia)

14,286

Brad Borden (Brooklyn)

1439

Note that this ranking includes full-time tax professors with at least one tax paper on SSRN, and all papers (including non-tax papers) by these tax professors are included in the SSRN data.

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November 1, 2017 in Scholarship, Tax, Tax Prof Rankings | Permalink | Comments (0)

Tuesday, October 31, 2017

Zwick Presents Capitalists In The Twenty-First Century Today At Columbia

ZwickEric Zwick (Chicago) presents Capitalists in the Twenty-First Century (with Matthew Smith (U.S. Treasury Department), Danny Yagan (UC-Berkeley) & Owen Zidar (Chicago)) at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium Series hosted by Alex Raskolnikov and Wojciech Kopczuk:

Have passive rentiers replaced the working rich at the top of the U.S. income distribution? Using administrative data linking 15 million firms to their owners, this paper shows that private business owners who actively manage their firms are key for top income inequality. Private business income accounts for most of the rise of top incomes since 2000, and the majority of top earners receive private business income — most of which accrues to active owner-managers of mid-market firms in relatively skill-intensive and unconcentrated industries. Profit falls substantially after premature owner deaths. Top-owned firms are twice as profitable per worker as other firms despite similar risk, and rising profitability without rising scale explains most of their profit growth.

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October 31, 2017 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Of Piketty And Perpetuities

PikettyEric A. Kades (William & Mary), Of Piketty and Perpetuities:

For the first time since independence, in a nation founded in large part on the rejection of a fixed nobility determined by birth and perpetuated by inheritance, America is paving the way for the creation of dynastic family wealth. Abolition or evisceration of the Rule Against Perpetuities in over half the states along with the likely repeal of the federal estate tax mean that there soon will be no obstacles to creating large pools of wealth that will insure lavish incomes to lucky heirs for generations without end.

The timing of these legal changes could hardly be worse. Marshaling innovative economic data extending back centuries, Thomas Picketty convincingly argues that the relatively egalitarian incomes enjoyed in developed economies from the end of World War II until around 1980 were an aberration and that we are in the process of returning to the historical norm of much greater income and wealth inequality. The driving force is the return to a world in which the rate of return to capital (r) exceeds the growth rate of national income (g) — another historical norm temporarily abrogated during the 20th century. The wealthy hold an extremely high fraction of national wealth, and when returns to that wealth exceed the growth rate of national income, their relative economic power (and all that goes with that) increases proportionally.

Table 1

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October 31, 2017 in Scholarship, Tax | Permalink | Comments (0)