TaxProf Blog

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

Sunday, July 15, 2018

The Top Five New Tax Papers

SSRN Logo (2018)There 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. [289 Downloads]  Introduction to Tax Policy Theory, by Allison Christians (McGill)
  2. [254 Downloads]  Higher Education Savings and Planning: Tax and Nontax Considerations, by Philip Manns (Liberty) & Timothy Todd (Liberty)
  3. [250 Downloads]  Code Sec. 1031 after the 2017 Tax Act, by Brad Borden (Brooklyn)
  4. [215 Downloads]   The International Provisions of the TCJA: A Preliminary Summary and Assessment, by Reuven Avi-Yonah (Michigan)
  5. [215 Downloads]   Rethinking Legal Taxonomies for the Gig Economy: Tax Law, Employment Law, and Economic Incentives, by Abi Adams, Judith Freedman & Jeremias Prassl (Oxford)

July 15, 2018 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Friday, July 13, 2018

Weekly SSRN Tax Article Review And Roundup: Speck Reviews Christians's Introduction to Tax Policy Theory

This week, Sloan Speck (Colorado) reviews a new work by Allison Christians (McGill), Introduction to Tax Policy Theory (2018).

Speck (2017)In Introduction to Tax Policy Theory, Allison Christians fulfils the Herculean task set forth in her title with deft grace and critical perspective. Christians’s short paper first elucidates three general goals of taxation from the taxing authority’s perspective, which she describes as state-building, internal management, and negotiated expansion. Then, Christians juxtaposes these goals with three metrics well-known among tax policy aficionados: equity, efficiency, and administrative capacity (which easily could be “simplicity”). Out of this analysis, Christians calls for the tax policy community to think and reflect on fundamental questions of approach and methodology—and to acknowledge the “discrepancies and weaknesses” in conventional approaches to tax policy.

Christians’s taxonomy of the goals of taxation is a major contribution, although certain to engender disagreement. Some dissention is inevitable when parsing all of human experience into three bins, each labeled with two words, and Christians presents her “imperfect” but “adequate” categories as poles, or touchstones, rather than as discrete silos.

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July 13, 2018 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Gianni: OECD BEPS (In)Action 1 — Factor Presence As A Solution To Tax Issues Of The Digital Economy

ABA Tax LawyerMonica Gianni (California State-Northridge), OECD BEPS (In)Action 1: Factor Presence as a Solution to Tax Issues of the Digital Economy, 72 Tax Law. ___(2018):

The Organisation for Economic Cooperation and Development (OECD) launched its project to address base erosion and profit shifting (BEPS) in 2013 with an Action Plan of 15 Actions. Action 1 encompasses identifying difficulties the digital economy poses for applying existing international tax rules and developing options to address them. Under current international tax rules, an enterprise generally is not taxed in a country in which it does not have a physical presence. With the economy having evolved so that business can be conducted over the internet with no physical presence in a country, companies have been able to avoid taxation in many jurisdictions from which they generate significant income. The OECD issued a final report on Action 1 in 2015 and a subsequent report in 2018, yet has failed to recommend a solution to address the physical presence issue. In effect, Action 1 has become Inaction 1. Countries and the European Union have grown impatient with the OECD and have taken matters into their own hands, with countries and the European Commission (EC) proposing or enacting legislation to address head on the issue of nontaxation of multinational digital companies, tax authorities assessing tax against multinational companies under the existing rules, and the EC bringing actions against countries for illegal state aid.

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

Thursday, July 12, 2018

Millionaires Flee California After Tax Hike

CalifForbes, Millionaires Flee California After Tax Hike:

According to new research released by Charles Varner, associate director of the Stanford Center on Poverty and Inequality, California lost an estimated 138 high-income individuals following passage of the Proposition 30 income tax increase championed by Gov. Jerry Brown (D) and approved by Golden State voters in 2012.

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July 12, 2018 in Scholarship, Tax | Permalink | Comments (5)

Wednesday, July 11, 2018

SSRN Tax Professor Rankings

SSRN Logo (2018)SSRN 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.  This ranking includes downloads from two 30- and 35-page papers by 12 tax professors on the new tax legislation that garnered a lot of media attention (including the New York Times and Washington Post) and generated a massive amount of downloads (the papers are the most downloaded papers over the past 12 months across all of SSRN and the most downloaded tax papers of all-time by over 200%).  See Brian Leiter (Chicago), 11 Tax Profs Blow Up The SSRN Download Rankings. (For some reason, Mitchell Kane (NYU) — the twelfth academic co-author of the two papers — is not included in the SSRN download rankings (although the downloads are included on his individual author page)).  Here is the new list (through July 1, 2018) 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.)

168,172

Reuven Avi-Yonah (Mich.)

97,797

2

Dan Shaviro (NYU)

106,514

Daniel Hemel (Chicago)

94,022

3

David Gamage (Indiana)

101,928

David Gamage (Indiana)

89,780

4

Lily Batchelder (NYU)

100,987

Darien Shanske (UC-Davis)

89,152

5

Daniel Hemel (Chicago)

97,845

Dan Shaviro (NYU)

88,898

6

Darien Shanske (UC-Davis)

95,894

Manoj Viswanathan (Hastings)

88,702

7

Cliff Fleming (BYU)

92,935

Lily Batchelder (NYU)

87,653

8

David Kamin (NYU)

89,279

Cliff Fleming (BYU)

87,424

9

Rebecca Kysar (Brooklyn)

89,044

Ari Glogower (Ohio State)

86,895

10

Manoj Viswanathan (Hastings)

88,797

David Kamin (NYU)

86,891

11

Ari Glogower (Ohio State)

87,238

Rebecca Kysar (Brooklyn)

86,790

12

Michael Simkovic (USC)

40,328

Gladriel Shobe (BYU)

23,066

13

D. Dharmapala (Chicago)

34,673

Michael Simkovic (USC)

3,605

14

Paul Caron (Pepperdine)

34,532

Richard Ainsworth (BU)

3,594

15

Louis Kaplow (Harvard)

29,943

D. Dharmapala (Chicago)

3,417

16

Richard Ainsworth (BU)

24,937

Jacob Goldin (Stanford)

2,794

17

Ed Kleinbard (USC)

24,870

Omri Marian (UC-Irvine) 

2,629

18

Vic Fleischer (UC-Irvine)

24,707

Kirk Stark (UCLA)   

2,435

19

Jim Hines (Michigan)

23,855

Hugh Ault (Boston College)

2,386

20

Gladriel Shobe (BYU)

23,644

Ruth Mason (Virginia)

2,358

21

Richard Kaplan (Illinois)

22,968

Sam Donaldson (Georgia St.)   

2,349

22

Ted Seto (Loyola-L.A.)

22,824

Kyle Rozema (Chicago)  

2,325

23

Katie Pratt (Loyola-L.A.)

21,304

Joe Bankman (Stanford) 

2,290

24

Robert Sitkoff (Harvard)

20,558

Stephen Shay (Harvard)

2,151

25

David Weisbach (Chicago)

20,341

Dennis Ventry (UC-Davis)

2,036

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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July 11, 2018 in Legal Education, Scholarship, Tax, Tax Prof Rankings | Permalink | Comments (0)

Coase and Fireworks

493l4SRQTVOydKrgKSgSugIn my continuing effort to demonstrate what the mundane world looks like through the eyes of a nerdy law professor, today we will talk about Ronald Coase, recipient of the Nobel Prize in economics, and fireworks.

The bulk of this is cross-posted over at PrawfsBlawg.  But since it deals in part with Pigouvian taxes, it may appeal as well to nerdy tax law types.

Before we had dogs, I liked fireworks, at least the professionally staged kind.  Up here in Charlevoix, Michigan, every year in late July the town has a week-long event called Venetian Festival.  The highlight on Friday night is a spectacular fireworks show out over the lake for which our deck is effectively a front row seat.  For the last seventeen years or so, however, I have not been out on the deck nor have I seen the fireworks.  No, I am back in a closet with the door closed, comforting our dog(s) who is/are going batshit crazy.

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July 11, 2018 in Jeff Lipshaw, Legal Education, Scholarship, Tax | Permalink | Comments (2)

Tuesday, July 10, 2018

McGowan: Legal Education And The Ethics of Acceptance

David McGowan (San Diego), Legal Education and the Ethics of Acceptance:

This paper reflects comments made at the 2018 AALS annual meeting regarding positive and normative critiques of the ethics of legal education. Adopting a nexus of contracts approach, the paper argues that guild practices interfere with reasonable student expectations from a normative perspective, though not as a matter of positive law. The difference between the study of law as an object and the study of law as a practice, and the different payoff structures to the two approaches, accounts for some of this difference, but guild considerations are the root cause. The paper advocates greater flexibility in accreditation standards to facilitate experimentation with different models.

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July 10, 2018 in Legal Education, Scholarship, Tax | Permalink | Comments (0)

Brown: Proposing A Single, Simpler Test For Cash Equivalency

ABA Tax LawyerFred B. Brown (Baltimore), Proposing a Single, Simpler Test for Cash Equivalency, 71 Tax Law. 543 (2018):

Under the cash method of accounting, generally taxpayers include income items that are received in the form of cash, checks, and property, in the year in which they are received. Under the cash equivalency doctrine, a promise to pay an amount in the future, even though it is a property right, generally will be included upon receipt only if the promise to pay constitutes a cash equivalent.

Whether an obligation is a cash equivalent is generally determined based on common law standards developed by the courts with some assistance from the Service. As a consequence, the current approach to cash equivalency suffers from the lack of a uniform standard. There is also uncertainty in applying the particular tests, given the fact-intensive, imprecise inquiry that is required. In addition, the current standards for cash equivalency may also present liquidity difficulties for taxpayers.

To address these problems, this article proposes a single test for determining whether an obligation calling for future payments is a cash equivalent.

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July 10, 2018 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0)

Sunday, July 8, 2018

Buckles: Unashamed Of The Gospel Of Jesus Christ — Public Policy And Public Service By Evangelicals

A new article by Tax Prof Johnny Rex Buckles (Houston), Unashamed of the Gospel of Jesus Christ: On Public Policy and Public Service by Evangelicals, 41 Harv. J.L. & Pub. Pol'y 813 (2018):

Congressional committee hearings considering nominees for federal office have increasingly featured extensive scrutiny of, and even hostility toward, nominees who are more than nominally religious. Congressional interrogations of the religiously orthodox raise important questions of law, public policy, and religion in our constitutional democracy. The exchange between Senator Bernie Sanders and Russell Vought, then-nominee for Deputy Director of the White House Office of Management and Budget and an evangelical Christian, is especially instructive. Focusing on this exchange as a springboard for discussion, this Article analyzes the constitutional and policy implications of congressional probing into the religious faiths of nominees. The issues raised by the Sanders-Vought exchange are recurring, and they potentially affect not just evangelical nominees, but also historically orthodox believers, in general.

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July 8, 2018 in Legal Education, Scholarship | Permalink | Comments (0)

The Top Five New Tax Papers

SSRN Logo (2018)There 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. [291 Downloads]  IRC Section 678 and the Beneficiary Deemed Owner Trust (BDOT), by Edwin Morrow
  2. [261 Downloads]  Introduction to Tax Policy Theory, by Allison Christians (McGill)
  3. [243 Downloads]  Higher Education Savings and Planning: Tax and Nontax Considerations, by Philip Manns (Liberty) & Timothy Todd (Liberty)
  4. [239 Downloads]  Code Sec. 1031 after the 2017 Tax Act, by Brad Borden (Brooklyn)
  5. [179 Downloads]   The International Provisions of the TCJA: A Preliminary Summary and Assessment, by Reuven Avi-Yonah (Michigan)

July 8, 2018 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Friday, July 6, 2018

Weekly SSRN Tax Article Review And Roundup: Stevenson Reviews Satterthwaite's Entrepreneurs’ Legal Status Choices And The C Corporation Survival Penalty

This week, Ariel Jurow Stevenson (NYU; moving to San Diego) reviews a new work by Emily Satterthwaite (Toronto), Entrepreneurs’ Legal Status Choices and the C Corporation Survival Penalty (2018).

StevensonThe persistent popularity of the C corporation among closely-held firms is a puzzle. C corporations combine an inflexible governance structure with unnecessary tax cost, imposing a double tax on owners and trapping losses within the entity. Despite these costs and the availability of flexible pass-through forms, the C corporation remains inexplicably common among new firms.

In her recent article, Emily Satterthwaite explores this puzzle by parsing panel data from the Kauffman Firm Survey, which administered in-depth questionnaires to several thousand new businesses from 2004-2011. Her article asks two primary questions. First, given potentially higher entity costs, what is the relationship between the C corporate form and firm survival rate? Second, what types of entrepreneurs choose to form C corporations in spite of their potentially higher costs? The Kauffman survey’s breadth allows Satterthwaite to control for owner demographics, industry, financing source, state fixed effects and other exogenous and endogenous variables that might bias the models’ conclusions. The result is a well-defined, rigorous, and cautious argument.

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July 6, 2018 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Thursday, July 5, 2018

Caveat IRS: Problems With Abandoning The Full Charitable Deduction Rule To Prevent State Circumvention Of The New $10k S&L Tax Cap

Joseph Bankman (Stanford), David Gamage (Indiana), Jacob Goldin (Stanford), Daniel Hemel (Chicago), Darien Shanske (UC-Davis), Kirk Stark (UCLA), Dennis Ventry(UC-Davis) & Manoj Viswanathan (UC-Hastings), Caveat IRS: Problems with Abandoning the Full Deduction Rule, 88 State Tax Notes 547 (May 7, 2018):

Several states have passed — and many more are considering — new tax credits that would reduce tax liability based on donations made by a taxpayer in support of various state, local or non-profit programs. In general, taxpayer contributions to qualifying organizations — including public charities and private foundations, as well as federal, state, local, and tribal governments — are eligible for the federal charitable contribution deduction under section 170. In a previous article, we explained how current law supports the view that qualifying charitable contributions are deductible under section 170, even when the donor derives some federal or state tax benefit by making the donation. We referred to this treatment as the “full deduction rule.”

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July 5, 2018 in Scholarship, Tax | Permalink | Comments (2)

Wednesday, July 4, 2018

Tax Law, Employment Law, And Economic Incentives In The Gig Economy

Abi Adams, Judith Freedman & Jeremias Prassl (Oxford), Rethinking Legal Taxonomies for the Gig Economy: Tax Law, Employment Law, and Economic Incentives, 34 Oxford Rev. Econ. Pol'y 475 (2018):

Recent labour market changes, from an increase in the number of individuals running their own business to the fragmentation of traditional employment relationships into short-term, intermittent work for multiple engagers (“gigs”) have brought a host of challenges for regulators. The law struggles not least because long-established taxonomies used in tax and employment law are coming under increasing pressure. Legal regulation in these areas divides the labour market into a number of predetermined categories, to which benefits and obligations (rights and duties) are then attached. The tests determining into which category an individual falls are unclear and too easily manipulated. In particular, there is a real lack of clarity as to how categories in employment and tax law should map onto each other.

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July 4, 2018 in Scholarship, Tax | Permalink | Comments (0)

Tuesday, July 3, 2018

Curricular Changes In Legal Research Instruction: An Empirical Study

Caroline Osborne (Washington & Lee) & Stephanie Miller (Washington & Lee), Curricular Changes in Legal Research Instruction: An Empirical Study:

This article examines components of curricular design of a legal research class as impacting student performance. Expertise of instructor and use of the inverted, or flipped, classroom are specifically explored. Eight years of exam performance on an oral legal research midterm is used to measure student performance and success of various components of curricular design.

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July 3, 2018 in Scholarship, Tax | Permalink | Comments (0)

Monday, July 2, 2018

 Cryptocurrency And The Shifting IRS Enforcement Model

Dashiell C. Shapiro (Wood LLP, San Francisco), Cryptocurrency and the Shifting IRS Enforcement Model, 1 Stan. Blockchain L. & Pol'y ___ (2018):

This Article reviews the IRS’s previous enforcement models, and considers how these have shifted in recent decades. The IRS has increasingly moved away from a purely punitive system towards one that focuses on customer service, the theory being that a procedurally fair system will increase taxpayer satisfaction and voluntary compliance. Given the IRS’s steady shift to a more holistic tax enforcement approach, the Author believes that the IRS is likely to take a broad-based approach to cryptocurrency tax enforcement.

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July 2, 2018 in Scholarship, Tax | Permalink | Comments (0)

The Impact Of International Tax Reform On Ireland

Figure 1IMF, The Impact of International Tax Reform on Ireland, in Ireland: Selected Issues 18-44 (June 2018):

1.  Over the last two decades, the Irish stock of inbound foreign direct investment (FDI) has risen dramatically from roughly 60 percent of GDP to 275 percent (Figure 1). Several features of Ireland’s economy, including a skilled, English-speaking workforce, membership in the European Union (EU), and a probusiness institutional environment, help attract investment. In addition, Ireland’s relatively low and stable corporate income tax (CIT) rate on active trading income has played a key role in attracting foreign capital.

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July 2, 2018 in Scholarship, Tax | Permalink | Comments (0)

Self-Plagiarism (And The First And Second Laws Of Textual Physics)

June is my intense writing month, by and large, and I just finished up a draft that I described here.

If you are like me, and have been at this for a while, you probably have developed a theme that pervades your work. Mine has to do with how people, and lawyers especially, make tough judgments in the face of uncertainty. Not tough judgments (although they may be) in adjudication, but what to do when your nicely developed lawyerly rationality can give you five good reasons for doing A and five equally good reasons for not doing A. A perfect example was Meryl Streep as Katharine Graham deciding whether to publish the Pentagon Papers (I rented The Post last night), you either take the leap or you don't.  Not to decide is to decide.

Sometimes a sentence or a paragraph or a long footnote from a previous piece seems like it fits in the new one. It's so easy to copy and paste and - voila! - you've written 200 words - a nice chunk of the day's quota. At least at some point in the drafting of Persistence, I did that. Is it okay?  (Spoiler alert: as far as I know I made it okay under even the most stringent standards.) Thoughts on self-plagiarism follow the break.

 

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July 2, 2018 in Jeff Lipshaw, Legal Education, Scholarship | Permalink | Comments (3)

Muller: Federal Judicial Clerkship Report Of Recent Law School Graduates

Derek Muller (Pepperdine), Federal Judicial Clerkship Report of Recent Law School Graduates, 2018 Edition:

This Report offers an analysis of the overall hiring of recent law school graduates into federal judicial clerkships between 2015-2017 for each law school. It includes an overall hiring report, regional reports, overall hiring trends, an elite hiring report, and trends concerning judicial vacancies.

Here are the ten law schools with federal judicial clerkship rates of over 10%:

Top 10

Pepperdine is 5th among the 21 ABA-accredited California law schools:

California

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July 2, 2018 in Legal Education, Scholarship | Permalink | Comments (8)

Sunday, July 1, 2018

The Myth Of The Teaching-Research Nexus In Research-Oriented Law Schools

Alex McKenzie, Lynden Griggs, Rick Snell & Gary Meyers (University of Tasmania Faculty of Law, Australia), The Myth of the Teaching-Research Nexus, 28 Legal Educ. Rev. ___ (2018):

Much has been written about the teaching-research nexus. The view presented in this article is that this nexus is a myth, particularly in research led universities and, from our personal experience, research-led law schools. Arguably, metrics of research performance expectations, combined with other aspirations such as quality teaching and community service, prevent any meaningful opportunity for a research-led law school to connect students to the ongoing and current research of their mentors. This is particularly the case for staff involved in teaching compulsory units.

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July 1, 2018 in Legal Education, Scholarship | Permalink | Comments (0)

The Top Five New Tax Papers

SSRN Logo (2018)This week's list of the Top 5 Recent Tax Paper Downloads is the same as last week's list, with some reshuffling of the order of the papers within the Top 5:

  1. [294 Downloads]  The New U.S. Tax Preference for 'Foreign-Derived Intangible Income', by Chris Sanchirico (Pennsylvania)
  2. [271 Downloads]  IRC Section 678 and the Beneficiary Deemed Owner Trust (BDOT), by Edwin Morrow
  3. [240 Downloads]  Introduction to Tax Policy Theory, by Allison Christians (McGill)
  4. [235 Downloads]  Higher Education Savings and Planning: Tax and Nontax Considerations, by Philip Manns (Liberty) & Timothy Todd (Liberty)
  5. [224 Downloads]  Code Sec. 1031 after the 2017 Tax Act, by Brad Borden (Brooklyn)

July 1, 2018 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Friday, June 29, 2018

Weekly SSRN Tax Article Review And Roundup: Mazur Reviews Aprill's Section 501(c)(4) Social Welfare Organizations

This week, Orly Mazur (SMU) reviews a new work by Ellen P. Aprill (Loyola-L.A.), Examining the Landscape of Section 501(c)(4) Social Welfare Organizations, 21 N.Y.U. J. Legis. & Pub. Pol'y ___ (2018).

Mazur (2017-2)In recent years, there has been a lot of controversy regarding the use of organizations exempt from taxation under section 501(c)(4) of the Internal Revenue Code for political campaigning activities. In her new work, Ellen Aprill takes a broader look at the role and impact of section 501(c)(4) organizations on our tax system and suggests some necessary reforms to strengthen the benefits of that role and minimize any negative impacts.

Aprill begins the article by explaining the requirements to qualify as a tax-exempt section 501(c)(4) “social welfare” organization and the ambiguities that exist in making this determination. She goes on to thoroughly explain the legislative history of the provision, the various additional requirements that have developed over time, and the types of entities that choose to operate in this form. This part of the paper is especially helpful for those of us familiar with 501(c)(3) charitable organizations, but less familiar with 501(c)(4) organizations. It also plays an important part in demonstrating that, contrary to the public media’s portrayal of 501(c)(4) organizations, these organizations engage in many activities beyond political activities, such as community service clubs, volunteer fire departments, and hospital chains. Any reform proposal should also take these other activities into account.

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June 29, 2018 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Can 'Dumb' Contracts Be Made 'Smart'?

Fullrobot-2I don't know if it's ready for Broadway, but the article I mentioned in a post a while back (it's gained two quotation marks since then:  The Persistence of "Dumb" Contracts) is all set for out-of-town previews on SSRN.  

There is a group calling themselves Blockgeeks, and one of their number shows up in footnote 1 for this headline from its website: “Smart Contracts: The Blockchain Technology That Will Replace Lawyers”.

The theme of the article is: "could that be?"  Spoiler alert: Probably not. Here is the abstract:

“Smart contracts” are a hot topic. Presently, smart contracts mostly consist as evidence of property, like crypto-currencies or mortgages, created and/or transferred on blockchain technology. This is an exploration of the theoretical possibilities of artificial intelligence in a far broader range of complex and heretofore negotiated transactions that occur over time. My goal is to understand what it means to make a contract smarter, i.e. to delegate more and more of the creation, performance, and disposition of legally binding transactions to machine thinking. Moreover, I want to do so from the perspective of one who is neither a true believer in the purported technological singularity to come nor a digital Luddite.

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June 29, 2018 in Jeff Lipshaw, Legal Education, Miscellaneous, Scholarship | Permalink | Comments (0)

The Tax Lawyer Publishes New Issue

The Tax Lawyer (2013)The Tax Lawyer has published Vol. 71, No. 3 (Winter 2018):

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June 29, 2018 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0)

Call For International Tax Papers: 2018 Brooklyn International Business Law Scholars' Roundtable

Brooklyn Logo (2016)Call for Papers: 2018 International Business Law Scholars’ Roundtable at Brooklyn Law School:

The Dennis J. Block Center for the Study of International Business Law will sponsor a Scholars’ Roundtable on November 16-17, 2018 at Brooklyn Law School. Scholars writing in a diverse range of fields related to international business, economic, and financial law are invited to submit proposals to present works in progress for an intense day of discussion with other scholars in the field. Participants will be expected to read all papers in advance of the Roundtable and offer commentary on each of the presentations.

Scholars selected for the Roundtable will receive a $500 stipend from Brooklyn Law School to defray the cost of attendance.

Requirements for Submission

  • Applicants must hold a fulltime tenured, tenure-track, or visitor/fellowship position at a law school or university. Scholars from outside the U.S. are encouraged to apply.
  • Scholars who anticipate holding a faculty appointment in the 2019-2020 academic year are also welcome.
  • Applicants should submit a 2-5 - page proposal, abstract, or summary of the paper. All papers presented must be unpublished at the time of the Roundtable. Papers that have been accepted for publication but are not yet in print are welcome.

Possible topics include:

  • Conflicts of laws / private international law
  • Corporate law, securities, and international banking
  • Dispute resolution and arbitration
  • International business transactions
  • International economic law (e.g. trade and investment)
  • International intellectual property
  • International taxation
  • Law and development
  • “Mega-regional” economic integration agreements
  • Regulation of corrupt business practices

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June 29, 2018 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, June 28, 2018

U.S. Tax Reform Presentation Slides

Reuven S. Avi-Yonah (Michigan), US Tax Reform: Potential Impact on Europe and EU Corporations (Presentation Slides):

Tax Cuts and Jobs Act (“TCJA”) signed into law by President Trump on 22 December 2017 contains multiple provisions that significantly impact Europe and the way European corporations are being taxed by the US. The US corporate tax rate is set to be 21% (reduced from 35%). Most importantly, the shift towards participation exemption and the adoption of the base erosion anti-abuse tax (“BEAT”), the global intangible low-taxed income (“GILTI”) and the foreign-derived intangible income (“FDII”) changed the delicate balance of US-EU taxation. Nonetheless, TCJA should not be considered as a ‘tax war’: it is a long-overdue response to the BEPS by US and a correct application of the single tax principle to prevent double non-taxation.

Mindy Herzfeld (Florida), US Tax Reform: Worth Waiting 30 Years For? (Presentation Slides):

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June 28, 2018 in Scholarship, Tax | Permalink | Comments (0)

Wednesday, June 27, 2018

Oei & Osofsky: Constituencies And Control in Statutory Drafting — Interviews With Government Tax Counsels

Shu-Yi Oei (Boston College) & Leigh Osofsky (Miami; moving to North Carolina), Constituencies and Control in Statutory Drafting: Interviews with Government Tax Counsels, 104 Iowa L. Rev. ___ (2019):

Tax statutes have long been derided as convoluted and unreadable. But there is little existing research about drafting practices that helps us contextualize such critiques. In this Article, we conduct the first in-depth empirical examination of how tax law drafting and formulation decisions are made. We report findings from interviews with government counsels who participated in the tax legislative process over the past four decades. Our interviews revealed that tax legislation drafting decisions are both targeted to and controlled by experts. Most counsels did not consider statutory formulation or readability important, as long as substantive meaning was accurate. Many held this view because their intended audience was tax experts, regulation writers, and software companies, not ordinary taxpayers. When revising law, drafters prioritize preserving existing formulations so as to not upset settled expectations, even at the cost of increasing convolution. While Members, Member staff, and committee staff participate in high-level policy decisions, statutory formulation decisions are largely left to a small number of tax law specialists.

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June 27, 2018 in Scholarship, Tax | Permalink | Comments (0)

Avi-Yonah: The International Provisions Of The Tax Cuts And Jobs Act

Reuven S. Avi-Yonah (Michigan), The International Provisions of the TCJA: A Preliminary Summary and Assessment:

The Tax Cuts and Jobs Act (TCJA), as passed by Congress and signed into law on December 22, 2017, represents the most far reaching reform of the US international tax rules since Subpart F was enacted in 1962. Most importantly, TCJA for the first time since the income tax was enacted in 1913 changes the rule that US resident taxpayers have to pay tax on all income “from whatever source derived” (US Constitution, Amendment XVI; IRC section 61). Under the TCJA, dividends paid to US corporate parents from non-Subpart F income of their foreign subsidiaries are exempt from US tax. That remains true even if the dividend was not subject to a withholding tax at source and was paid out of earnings that were not subject to foreign tax in the country where the subsidiary is incorporated.

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June 27, 2018 in Scholarship, Tax | Permalink | Comments (1)

Chodorow: The Parsonage Exemption

Adam Chodorow (Arizona State), The Parsonage Exemption, 51 UC Davis L. Rev. 849 (2018):

The parsonage exemption allows “ministers of the gospel” to exclude the value of housing benefits from income, whether received in-kind or as a cash allowance. Critics argue that the provision violates the First Amendment’s Establishment Clause, while supporters contend that it does not single religion out for a cognizable benefit. Alternately, supporters claim that it is a permissible accommodation for religion under the First Amendment’s Free Exercise Clause. This Article fills an important gap in the debate by offering a nuanced explanation of how the parsonage exemption and other housing provisions function within the tax code.

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June 27, 2018 in Scholarship, Tax | Permalink | Comments (0)

Monday, June 25, 2018

Abreu & Greenstein Review Lawsky's A Logic For Statutes

Jotwell (Tax) (2016)Alice Abreu (Temple) & Richard Greenstein (Temple), Rules vs Standards (JOTWELL) (reviewing Sarah Lawsky (Northwestern), A Logic for Statutes 20 Fla. Tax Rev. ___ (2018)):

Professor Sarah Lawsky (Northwestern) has written a fascinating and thought-provoking essay on the logic of statutory interpretation—specifically as it applies to the Internal Revenue Code. Notwithstanding a long tradition of scholarship addressing the interpretation of legislative texts in general, careful attention to interpretation of the Code has received comparatively little attention. An important reason for this, as we have argued in previously published articles, has been the tendency to frame Code provisions as rules and to apply them deductively to the facts of particular cases. Such a practice pushes in the direction of a more-or-less mechanical interpretation of the Code, which in turn makes questions regarding statutory interpretation seem fairly uninteresting. Professor Lawsky’s essay engages directly and critically with this practice.

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June 25, 2018 in Scholarship, Tax | Permalink | Comments (0)

Appel Posts Two International Tax Papers

Alan Appel (New York Law School), A Guide to Understanding the U.S. Tax Consequences of Foreign Person Investing in U.S. Real Property:

This paper describes some of the possible structuring alternatives a foreign investor may use to limit his or her U.S. tax exposure with respect to ownership and subsequent disposition of U.S. real estate.

Alan Appel (New York Law School), Transparency, Tax Law and the U.S. As the World's Favorite Tax Haven:

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June 25, 2018 in Scholarship, Tax | Permalink | Comments (0)

Call For Papers: Midwestern Law & Economics Association Annual Meeting At Alabama

Alabama LogoCall for Papers: Midwestern Law & Economics Association Annual Meeting

The University of Alabama School of Law (UASL) is pleased to host the 18th Annual Meeting of the Midwestern Law & Economics Association (MLEA) September 14-15, 2018 in Tuscaloosa, Alabama. ...

We invite participants from across the nation (not just the Midwest) and abroad. There are no registration or membership fees. Participants will finance their own travel and hotel costs.

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June 25, 2018 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Sunday, June 24, 2018

The Top Five New Tax Papers

SSRN Logo (2018)There is quite 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. [272 Downloads]  The New U.S. Tax Preference for 'Foreign-Derived Intangible Income', by Chris Sanchirico (Pennsylvania)
  2. [258 Downloads]  IRC Section 678 and the Beneficiary Deemed Owner Trust (BDOT), by Edwin Morrow
  3. [229 Downloads]  Higher Education Savings and Planning: Tax and Nontax Considerations, by Philip Manns (Liberty) & Timothy Todd (Liberty)
  4. [207 Downloads]  Code Sec. 1031 after the 2017 Tax Act, by Brad Borden (Brooklyn)
  5. [194 Downloads]  Introduction to Tax Policy Theory, by Allison Christians (McGill)

June 24, 2018 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Friday, June 22, 2018

Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews Mason's The Tax Subsidy War

This week, Mirit Eyal-Cohen (Alabama) reviews a new article by Ruth Mason (Virgina), The Tax Subsidy War (June 2018). 

Mirit-Cohen (2018)In her article, Mason discusses European anti-subsidy rules in an era of large-scale tax avoidance by multinationals. This Article is especially timely in light of the recent announcements of the European Commission (EC), the European Union’s (EU) executive body, requiring EU Members States to recover amounts of tax subsidies they provided multinational conglomerates such as Apple, Amazon, Chrislaer-Fiat, Starbucks, and others. In the case of Apple, the EC ordered Ireland to collect from Apple the largest tax deficiency in world history — $14.5 billion (plus interest). Under Europe’s state-aid rules, Member States are prevented from distorting private competition by granting exclusive subsidies to particular firms. The EC concluded that Ireland colluded with, and illegally subsidized, Apple by issuing confidential administrative rulings that significantly relieved Apple from Irish tax. These EC decisions involving U.S. multinationals created much turmoil. U.S. Treasury Department issued a white paper stating that such recoveries would violate tax treaties between the United States and EU Member States. Members of Congress proposed waging a “tax war” urging Treasury to consider imposing retaliatory taxes on the EU. In an unprecedented move, the United States sought to intervene in the upcoming Apple appeal, but the EU courts held that it lacked standing. 

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June 22, 2018 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Avi-Yonah & Mazzoni: Due Diligence In International Tax Law

Reuven S. Avi-Yonah (Michigan) & Gianluca Mazzoni (S.J.D. 2018, Michigan), Due Diligence in International Tax Law:

The concept of due diligence has been primarily developed in the state context (e.g., investor protection, environmental law), where it has been stated that “[t]he obligation to take preventative measures is one of due diligence, not an absolute guarantee against the occurrence of harm.” In international finance law, the concept is applied to private actors, especially financial institutions. The concept was first developed in the prevention of money laundering (covered elsewhere in this book) but then applied to prevention of tax evasion. In that context, since it would put an unreasonable burden on financial institutions to completely prevent tax evasion, all that is required is due diligence.

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June 22, 2018 in Scholarship, Tax | Permalink | Comments (0)

Thursday, June 21, 2018

Rasmussen: Lessons For Academic Leaders From Modern Restructuring Practice

Robert K. Rasmussen (Former Dean, USC), Lessons for Academic Leaders from Modern Restructuring Practice, 92 Am. Bankr. L.J. 233 (2018):

Financial distress has hit higher education. More and more universities and colleges are facing existential challenges as the competition for a dwindling number of students has put a strain on revenues. Unlike leaders in other industries, the presidents and chancellors of a financially distressed institutions of higher education cannot explore the possibility of a Chapter 11 filing under the Bankruptcy Code to restructure their obligations so that they align better with their revenues. Federal law prohibits Title IV loans — the lifeblood of virtually every university and college — from being made to students who attend a school that is in an insolvency proceeding. Yet academic leaders can take lessons from modern Chapter 11 practice: they can, in advance of financial distress, ensure that their boards of trustees have members who can provide advice to the schools’ leaders as to the difficult choices that they face; they can employ restructuring professionals who have experience in turning around operations without a bankruptcy filing; finally, given that many of these institutions have relatively few creditors, they can attempt to negotiate a restructuring support agreement that would restructure the schools’ debts without a bankruptcy filing.

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June 21, 2018 in Legal Education, Scholarship | Permalink | Comments (0)

Does Feedback Really Improve Law Student Performance?

National Law Journal, Feedback on Feedback:

Giving law students more feedback and assessments such as practice exams translate into better grades, right?

Not so fast. An upcoming edition of the University of Detroit Mercy Law Review takes up the subject of so-called formative reviews, but the authors of two articles reach different conclusions about the ability of professor interaction and feedback to improve student performance [Symposium, The Impact of Formative Assessment: Emphasizing Outcome Measures in Legal Education, 94 U. Det. Mercy L. Rev. 387-457 (2017)].

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June 21, 2018 in Legal Education, Scholarship | Permalink | Comments (6)

Grossberg: Using The Step Transaction Doctrine To Attack Tax Shelters

Jonathan Grossberg (American), Attacking Tax Shelters: Galloping Toward a Better Step Transaction Doctrine, 78  La. L. Rev.  369 (2018):

Since the beginning of the Internal Revenue Code, taxpayers have sought to lower their tax bills through creative tax planning. The step transaction doctrine is one of several tools used by the Internal Revenue Service and courts to challenge tax shelters and tax evasion. The step transaction doctrine provides that the courts may combine two or more allegedly separate steps in a multi-step transaction into a single step to better reflect the economic reality of the taxpayer’s actions. Derived from Supreme Court decisions in the 1930s, the doctrine deserves renewed scrutiny today because serious conceptual issues exist regarding the three current tests that courts use to determine when to combine various steps in a tax-motivated multiple-step transaction. This Article addresses two perennial themes in tax law: the role of judicial doctrines in a statutory system and the difficulty of taxing related-party transactions.

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June 21, 2018 in Scholarship, Tax | Permalink | Comments (0)

Wednesday, June 20, 2018

Containing Systemic Risk By Taxing Banks Properly

Mark Roe (Harvard) & Michael Troege (ESCP Europe), Containing Systemic Risk By Taxing Banks Properly, 35 Yale J. on Reg. 181 (2018):

Tax specialists normally don’t focus on financial stability and financial regulators and analysts typically do not focus on taxes. This is too bad because the corporate tax structure affects financial stability and does so significantly, as we analyze in this article.

The reason is simple: tax rules influence the capital structure choices of corporations in general and banks in particular, by allowing tax benefits to debt—principally the deductibility of interest—that equity lacks. Today, the corporate tax penalizes equity finance and subsidizes debt relative to equity. As a consequence, corporations overall use more debt than they would in a tax-neutral world.

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June 20, 2018 in Scholarship, Tax | Permalink | Comments (0)

We Should Tax The Clintons And Other Former Senior Government Employees At A Higher Rate

Limor Riza (Ono Academic College), Should We Tax the 'Clintons' and Other Former Senior Civil Servants More? Yes, We Should, 18  U.C. Davis Bus. L.J. 109 (2017):

This paper debates whether former civil servants should be taxed differentially. It argues that whenever public officials’ post-retirement income in the private sector is derived from their previous office, an additional tax should be levied on them, since in such situations the ability-to-pay principle is an insufficient horizontal equity criterion. This idea is grounded in equity propositions and may be justified by various liberal theories of equal opportunities and utilitarianism.

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June 20, 2018 in Scholarship, Tax | Permalink | Comments (3)

Miller: Advice For Jeff Bezos — Social Welfare Organizations As Grantmakers

David S. Miller (Proskauer Rose, New York), Advice for Jeff Bezos: Social Welfare Organizations as Grantmakers, 21 N.Y.U. J. Legis. & Pub. Pol'y ___ (2018):

This paper responds to Jeff Bezos’ request for philanthropic ideas, but with a suggestion for the structure of his grant making. Gifts of appreciated stock should be made to section 501(c)(3) organizations only to the extent that Bezos will be able to use the charitable deduction that the donation generates before it expires. A social welfare organization should receive all other gifts of appreciated stock.

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June 20, 2018 in Scholarship, Tax | Permalink | Comments (0)

Rossman: In Search Of Smarter Homeowner Subsidies

Matthew J. Rossman (Case Western), In Search of Smarter Homeowner Subsidies, 40 U. Haw. L. Rev. 270 (2017):

Critics have long assailed the federal tax code’s principal homeowner subsidies as lucrative tax breaks for upper income households that are essentially worthless to those financially constrained from purchasing a home. This article examines the subsidies through a different lens and reveals another serious flaw. It demonstrates how the homeowner subsidies, which represent a massive federal investment in homeownership, do very little to contain and instead probably increase costs on others that result from certain types of housing choices and that other federal policies seek to remedy. These negative housing externalities include: (i) blight, deterioration, and public health risks in disinvested housing markets, (ii) an array of individual and societal harms associated with heightened economic and racial housing segregation, (iii) environmental degradation, and (iv) taxpayer funded disaster relief for those who reside in environmental hotspots. In effect, the subsidies pay for housing choices that the government later pays to cleans up after.

This article provides several explanations for this disconnect. Among these is an idealization of homeownership, reflected in the tax code, which sees only its benefits. Accordingly, the subsidies reward homeowner decisions at large and are insensitive to the varying amounts of positive and negative externalities that follow from particular types of homeowner choices. For this reason, the article contends that the current subsidies are not “smart.”

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June 20, 2018 in Scholarship, Tax | Permalink | Comments (0)

Tuesday, June 19, 2018

Call For Papers: The Commerce Clause And The Global Economy

Chapman Logo (2017)The Chapman Law Review is pleased to invite article submissions on the theme: The Commerce Clause and the Global Economy. Publications will appear in a symposium edition, and authors will receive an honorarium.

With the growth of online retailers and the rise of the global marketplace, federal and state governments have been charged with the task of navigating the waters of the global economy and its inevitable collision with the Commerce Clause. In June, the United States Supreme Court is expected to render a decision in South Dakota v. Wayfair, in which South Dakota has asked the Court to reconsider its ruling in Quill v. North Dakota and allow states to require out-of-state retailers that do not have a physical presence in the state to collect local sales taxes from their customers. Regardless of the outcome, this case has opened up a series of questions about the scope of the Commerce Clause in an increasingly global economy—specifically the ability of state and local governments to regulate global economic actors in order to protect communities against the adverse effects of globalization.

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June 19, 2018 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Newman: Modern Day Lessons From Two New York Tax Opinions By Benjamin Cardozo

Joel S. Newman (Wake Forest), Two New York Tax Cases, 34 Touro L. Rev. 301 (2018):

While he was on the New York Court of Appeals, Benjamin Cardozo wrote a number of opinions on state tax issues. People ex rel. Studebaker Corp. v. Gilchrist was an early transfer pricing case. Studebaker Corporation established a number of sales subsidiaries, so that income could be shifted away from states with corporate franchise taxes. As a result of its manipulation, a net loss of over $400,000 was reported to New York State in 1920, even though Studebaker earned a profit of over $11 million nationwide. The New York State Tax Commission and the Appellate Division reallocated the income, but the Court of Appeals reversed. Cardozo disagreed with the method of allocation used below. However, his opinion left the door open for reallocations in subsequent cases. Curiously, the facts would have lent themselves to transfer pricing analysis, which is used in modern international tax cases, rather than the formulary apportionment used by the courts below, which has become the standard method in state cases.

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June 19, 2018 in Scholarship, Tax | Permalink | Comments (0)

Monday, June 18, 2018

Christians: Introduction To Tax Policy Theory

Allison Christians (McGill), Introduction to Tax Policy Theory:

Taxation involves the compulsory transfer of resources among members of society. Tax policy is concerned with how societies carry out taxation. That is a technical and legal question, but it is inescapably a political, social, and cultural one as well. To study tax policy is to engage simultaneously with the existential philosophical foundations of taxation: why and how societies tax. This introduction to tax policy theory presents an overview of tax policy discourse. The goal is to outline a working framework for reflection and analysis to examine the ways in which current assumptions and approaches require further development.

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June 18, 2018 in Scholarship, Tax | Permalink | Comments (0)

Sunday, June 17, 2018

The Top Five New Tax Papers

SSRN Logo (2018)This week's list of the Top 5 Recent Tax Paper Downloads is the same as last week's list, with some reshuffling of the order of the papers within the Top 5:

  1. [290 Downloads]  The 2017 Tax Cuts: How Polarized Politics Produced Precarious Policy, by Michael Graetz (Columbia)
  2. [244 Downloads]  IRC Section 678 and the Beneficiary Deemed Owner Trust (BDOT), by Edwin Morrow
  3. [236 Downloads]  The New U.S. Tax Preference for 'Foreign-Derived Intangible Income', by Chris Sanchirico (Pennsylvania)
  4. [223 Downloads]  Higher Education Savings and Planning: Tax and Nontax Considerations, by Philip Manns (Liberty) & Timothy Todd (Liberty)
  5. [185 Downloads]  Code Sec. 1031 after the 2017 Tax Act, by Brad Borden (Brooklyn)

June 17, 2018 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Saturday, June 16, 2018

13th Annual Junior Tax Scholars Workshop Concludes Today

Colorado Logo (2016)Panel #4: Business Taxation

Manoj Viswanathan (UC-Hastings), A Worker-Centric Model for Sharing Economy 
Commentators: Pippa Browde (Montana), Jacob Goldin (Stanford)

Emily Satterthwaite (Toronto), Signaling by Small Suppliers Through Voluntary VAT Registration
Commentators: Edward Fox (NYU), Clint Wallace (South Carolina)

Ari Glogower (Ohio State), Requiring Reasonable Compensation in a C Corp
Commentators: Jacob Goldin (Stanford), Ariel Stevenson (San Diego)

Panel #5: International

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

Friday, June 15, 2018

Weekly SSRN Tax Article Review And Roundup: Glogower Reviews Kysar's Tax Law And The Eroding Budget Process

This week, Ari Glogower (Ohio State) reviews a new work by Rebecca Kysar (Brooklyn, moving to Fordham), Tax Law and the Eroding Budget Process, 81 Law & Contemp. Probs. 61 (2018).

Glogower (2016)

Rebecca Kysar’s new work describes the evolution of the budget process and its effect upon tax policy, through a detailed study of the process leading to the 2017 tax legislation. At the same time, the work also describes how political pressures are changing the budget process and eroding longstanding norms.

The work begins with a brief history of the reconciliation process since its inception in the Congressional Budget Act of 1974. In this account reconciliation—which allows the Senate to pass legislation conforming to budget instructions with a simple majority—was originally intended as a way to assist Congress in reducing deficits and balancing the budget. The process was soon expanded, however, as a way to sidestep the filibuster for a broader range of legislation and social policy. To curb this trend, the Byrd Rule was adopted in the 1980s, which limited the ability of Congress to use reconciliation for legislation that is extraneous to the budget or that increased deficits beyond the specified budget window.

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

13th Annual Junior Tax Scholars Workshop Kicks Off Today At Colorado

Colorado Logo (2016)Panel #1: SALT and Transfer Programs

Pippa Browde (Montana), Cannabis Complexities in State-Tribal Tax Revenue Sharing Compacts
Commentators: Sloan Speck (Colorado), Hayes Holderness (Richmond)

Mary Leto Pareja (New Mexico), Work Requirements for Medicaid and Other Safety Net Programs: Giving Real Credit for Community Engagement
Commentators: Emily Satterthwaite (Toronto), Goldburn Maynard (Louisville)

Ariel Stevenson (San Diego), User Fees and Public Accountability
Commentators: Young Ran (Christine) Kim (Utah), Zachary Liscow (Yale)

Hayes Holderness (Richmond), Wither Transactional Nexus?
Commentators: Ariel Glogower (Ohio State), Edward Fox (NYU)

Panel #2: Tax Administration and Compliance

Goldburn Maynard (Louisville), Legislating with Tall Tales
Commentators: Mary Leto Pareja (New Mexico), Clint Wallace (South Carolina)

Sloan Speck (Colorado), The Taxation of Crowdfunding for Health Care
Commentators: Jacob Goldin (Stanford), Genevieve Tokić (Northern Illinois)

Zachary Liscow (Yale), Democratic Law and Economics
Commentators: Manoj Viswanathan (UC-Hastings), Ariel Stevenson (San Diego)

Panel #3: Political Economy/Redistribution

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June 15, 2018 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, June 14, 2018

McCarden: Uncovering Assets Hidden From Spouses And Tax Authorities

Khrista McCarden (Pepperdine), Till Offshore Do Us Part: Uncovering Assets Hidden from Spouses and Tax Authorities, 62 St. Louis U. L.J. 19 (2017):

This paper explores how U.S. tax authorities may assist spouses in the uncovering of offshore assets in divorce proceedings and thus decrease the ability of some of the wealthiest taxpayers to use offshore accounts to escape taxation.

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June 14, 2018 in Scholarship, Tax | Permalink | Comments (0)

Wednesday, June 13, 2018

Virginia Tax Review Publishes New Issue

Virginia Tax Review (2016)The Virginia Tax Review has published Vol. 37, No. 3 (Spring 2018):

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