TaxProf Blog

Editor: Paul L. Caron
Pepperdine University School of Law

Monday, April 18, 2016

Call For Papers:  Taxation And Migration Conference At Saint Louis

St. Louis (2016)Call for Papers:  Sanford E. Sarasohn Conference on Critical Issues in Comparative and International Taxation II: Taxation and Migration at Saint Louis University School of Law:

As ever growing numbers of individuals seek economic and political refuge in Europe and North America, and increasing numbers of individuals and businesses seek refuge from the tax burdens of their home jurisdictions in lower tax jurisdictions, these in- and out- migrations strain the national economies of affected countries causing them to modify their taxation rules and structures. This conference will explore the effects of taxation on migration and the effects of migration on taxation. Papers on any topic related to taxation and migration of individuals or entities are welcome but those offering a critical perspective or addressing the impact of taxation on, and taxation changes relating to acceptance of, migrants from conflict areas are preferred. Please submit paper proposal abstracts by e-mail to Professor Henry Ordower at ordoweh@slu.edu no later than May 25, 2016. Notification of proposal acceptance is targeted for July 1, 2016.

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April 18, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Sunday, April 17, 2016

The Top 5 Tax Paper Downloads

SSRN LogoThis 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 within the Top 5:

  1. [672 Downloads]  Lexisnexis® Guide to FATCA Compliance: Chapter 1, by Willliam Byrnes (Texas A&M) & Robert J. Munro (Texas A&M)
  2. [320 Downloads]  The Tax Lives of Uber Drivers: Evidence from Internet Discussion Forums, by Shu-Yi Oei (Tulane) & Diane M. Ring (Boston College)
  3. [295 Downloads]  Ownership of the Means of Production, by E. Glen Weyl (Chicago) & Anthony Lee Zhang (Stanford)
  4. [260 Downloads]  The Law of the Platform, by Orly Lobel (San Diego)
  5. [252 Downloads]  Taxing Wealth Seriously, by Edward J. McCaffery (USC)

April 17, 2016 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Friday, April 15, 2016

UCLA Law Prof's Long Legal Fight Over Access To California Bar Admissions Data Headed To Trial

MismatchFollowing up on my earlier post, The Mismatch Critique of Law School Affirmative Action and Its Opponents:  Wall Street Journal, Long Legal Fight Over Access to California Bar Admissions Data Headed for Trial:

It was a decade ago when a UCLA law professor known for his critique of affirmative action first asked the State Bar of California to give him a trove of data on people who applied to practice law in the state.

Professor Richard H. Sander still hasn’t gotten the state bar to turn over the information he wants. But his long legal effort in pursuit of it may have reached a turning point this week when a judge said his case could go to trial over the objections of the state bar.

Mr. Sander is the academic most associated with the “mismatch” theory about affirmative action, the idea that racial and other kinds of admissions preferences can have unintended consequences by putting students in academic settings for which they’re not prepared.

In 2006, he asked the state bar to disclose bar exam scores, grade point averages and LSAT scores of everyone who applied for bar admission between 1972 and 2007, along with each bar applicant’s race and gender. All of the information is stored on the state bar admissions database.

His request didn’t seek disclosure of anyone’s names, but sought admissions data on much more granular level. Mr. Sander has said his request had to do with his research into “the large and persistent gap in bar passage rates among racial and ethnic groups.”

The state bar refused, citing privacy concerns. In 2008, the professor and the California First Amendment Coalition filed suit, arguing that they have a legal right to the information.

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April 15, 2016 in Legal Education, Scholarship | Permalink | Comments (5)

Weekly SSRN Tax Roundup

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April 15, 2016 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Weekly Student Tax Note Roundup

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April 15, 2016 in Scholarship, Tax, Weekly Student Tax Note Roundup | Permalink | Comments (0)

Blank & Osofsky:  Simplexity

Joshua D. Blank (NYU) & Leigh Osofsky (Miami), Simplexity, 65 Emory L.J. ___ (2016):

In recent years, federal government agencies have increasingly attempted to use plain language in written communications with the public. The Plain Writing Act of 2010, for instance, requires agencies to incorporate “clear and simple” explanations of rules and regulations into their official publications. In the tax context, as part of its “customer service” mission, the Internal Revenue Service bears a “duty to explain” the tax law to hundreds of millions of taxpayers who file tax returns each year. Proponents of the plain language movement have heralded this form of communication as leading to simplicity in tax compliance, more equitable access to federal programs and increased open government.

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April 15, 2016 in Scholarship, Tax | Permalink | Comments (0)

Thursday, April 14, 2016

Duncan Presents Tax Incidence In The Presence Of Tax Evasion Today At Indiana

DuncanDenvil Duncan (Indiana-Bloomington) presents Tax Incidence in the Presence of Tax Evasion (with Philipp Doerrenberg (ZEW Mannheim and Institute for the Study of Labor (IZA), Germany) at Indiana-Bloomington today as part of its Tax Policy Colloquium Series hosted by Leandra Lederman:

This paper studies the economic incidence of sales taxes in the presence of tax evasion opportunities. We design a laboratory experiment in which buyers and sellers trade a fictitious good in double auction markets. A per-unit tax is imposed on sellers, and sellers in the treatment group are provided the opportunity to evade the tax whereas sellers in the control group are not. We find that the market equilibrium price in the treatment group is lower than in the control group. This difference is economically and statistically significant, and implies that sellers with access to evasion shift a smaller share of the statutory tax burden onto buyers relative to sellers without tax evasion opportunities.

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April 14, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Doran Presents The Puzzle Of Non-Qualified Retirement Pay Today At Colorado

Doran (2015)Michael Doran (Virginia) presents The Puzzle of Non-Qualified Retirement Pay: Optimal Contracting, Managerial Power, and Taxes at Colorado today as part of its Tax Policy Colloquium Series hosted by David Hasen and Sloan Speck:

Pay arrangements for managers of public corporations typically include substantial amounts of compensation deferred through non-qualified retirement plans. As a departure from the familiar baseline of current payment for current services, this presents a longstanding puzzle. The corporate-governance literature offers two explanations for the practice. The “optimal-contracting account” argues that non-qualified retirement pay represents “inside debt” that aligns the interests of managers with the interests of the corporation’s unsecured general creditors. The “managerial-power account” argues that non-qualified retirement pay represents “stealth compensation” that facilitates managers’ extraction of rents from corporate assets. In this paper, I set out a different explanation based on tax considerations.

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April 14, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Pandya & Utz:  Designing The Tax Treatment Of Litigation-Related Costs

Sachin S. Pandya (Connecticut) & Stephen Utz (Connecticut), Designing the Tax Treatment of Litigation-Related Costs:

This paper identifies key tax design issues for how income tax law should treat litigation-related costs paid by defendants, such as attorney fees, court courts, and payments to settle claims or satisfy judgments, fines or penalties. After discussing how US and Germany income tax law treat litigated related costs, the paper identifies four important tax-design issues: (1) how to attribute litigation-related costs to any particular income-producing activity; (2) whether to treat liability insurer payments made on a defendant’s behalf as income to that defendant; (3) whether to coordinate the tax treatment of a payer’s damages payments with the tax treatment of those receipts to the payee; and (4) whether litigation-related costs should be treated as capital expenditures related to the right to receipts established or sought to be established by the litigation itself.

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April 14, 2016 in Scholarship, Tax | Permalink | Comments (0)

Wednesday, April 13, 2016

Gentry Presents Capital Gains Taxation And Entrepreneurship Today At Penn

Penn (2016)William Gentry (Williams College) presents Capital Gains Taxation and Entrepreneurship at Pennsylvania today as part of its Center for Tax Law and Policy Seminar Series hosted by Chris Sanchirico and Reed Shuldiner:

The taxation of capital gains is a perennial issue in tax policy. One critical aspect for understanding the overall effects of capital gains taxation is how these taxes affect entrepreneurs. While many analyses focus on the disincentive effects created by capital gains taxes for investors in large corporations, these disincentives may be even more important for entrepreneurs. This paper discusses several mechanisms through which capital gains taxes can affect entrepreneurs’ decisions. First, capital gains taxes may create an additional level of taxation on successful entrepreneurs. Second, asymmetric taxation of capital gains and losses (in which gains are taxed more heavily than losses) may be an especially important issue for entrepreneurs; the asymmetries in the tax system may discourage entrepreneurs from taking risk. Third, much like the commonly-referenced lock-in effect of capital gains taxes on investments in stock, entrepreneurs may become locked into closely-held businesses; this lock-in effect may distort whether firms are owned by the most efficient manager for the firm. Fourth, capital gains taxes can affect the cost of capital for entrepreneurs.

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April 13, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Hickman Presents Treasury's Retroactivity Today At Cambridge

Hickman 2014 2Kristin Hickman (Minnesota) presents Treasury's Retroactivity at Christ's College, Cambridge today at a conference on The Role of Judges in Developing the Content of Tax Law:

In Bowen v. Georgetown University Hospital, the Supreme Court described retroactivity as "not favored in the law" and generally rejected allowing federal administrative agencies to adopt regulations "altering the past legal consequences of past actions."  Unlike most regulatory agencies, Treasury and the IRS are expressly authorized by Congress to adopt regulations with precisely such primary retroactive effect.  Specifically, IRC § 7805(b) grants Treasury and the IRS the power to backdate tax regulations under a variety of circumstances.  Preliminary analysis shows that Treasury and the IRS utilize this authority regularly with little judicial oversight for abuse of discretion.  Using empirical data, this article will explore more fully Treasury and IRS utilization of the authority to adopt retroactively effective regulations interpreting the Internal Revenue Code

April 13, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (1)

The Taxation Of Crowdfunding

CrowdfundingPaul Battista (Law Office of Paul Battista, Manhattan Beach, CA), The Taxation of Crowdfunding: Income Tax Uncertainties and a Safe Harbor Test to Claim Gift Tax Exclusion, 64 U. Kan. L. Rev. 143 (2015):

Crowdfunding is the process of asking a large number of separate third parties for relatively small amounts of money to fund an endeavor. Although the concept of asking for financial “contributions” is not new, seeking funds from others via websites on the internet is relatively new. As with any distinctly new financing vehicle, there are many legal issues raised by crowdfunding that have not been explored or answered. One such issue is the income tax consequences associated with crowdfunding. The academy has not yet widely addressed the issues and the Internal Revenue Service (IRS) has yet to provide any formal guidance which has created a lack of clarity that needs to be addressed.

This article provides an overview of the most popular types of crowdfunding models and addresses the tax aspects of crowdfunding models that raise funds through a tax-exempt entity and that provide loans or equity investments through crowdfunding. The article also explores the tax uncertainties that arise under current income and gift tax laws and shows that the current tax laws do not provide bright-line answers to whether or not a crowdfunding transaction is taxable income or excluded from tax as a “gift.

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April 13, 2016 in Scholarship, Tax | Permalink | Comments (0)

Tuesday, April 12, 2016

Shay Presents R&D Tax Incentives: Growth Panacea Or Budget Trojan Horse? Today At Georgetown

Shay (2014)Stephen E. Shay (Harvard) presents Essay on R&D Tax Incentives: Growth Panacea or Budget Trojan Horse? (with J. Clifton Fleming, Jr. (BYU) & Robert J. Peroni (Texas)) at Georgetown today as part of its Tax Law and Public Finance Workshop Series hosted by John Brooks and Itai Grinberg:

Research and development (R&D) activity has long held a privileged place in the U.S. income tax system and in policy debates. The premises for R&D tax incentives, however, are grounded in theory regarding a market failure for investment in R&D that does not align well with the target of U.S. R&D tax incentives. Moreover, factors contributing to innovation are now understood to include, in addition to R&D, other “knowledge-based capital” (KBC) investment in training and other human capital development, developing organizational processes, computer software, and architectural and engineering designs. The combination of existing R&D tax incentives, income shifting, and deferral of foreign income from U.S. tax, with intellectual property protection for successful R&D, result a poorly designed mix of overlapping benefits only loosely related to fostering innovation. Proposed “innovation box” tax incentives would add to the incoherence of the existing incentives.

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April 12, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Kahng Presents Who Owns Human Capital? Today At NYU

Kahng (2017)Lily Kahng (Seattle) presents Who Owns Human Capital?, 93 Wash. U. L. Rev. ___ (2016), at NYU today as part of its Tax Policy Colloquium Series hosted by Daniel Shaviro and Chris Sanchirico:

This Article analyzes the tax law’s capital income preference through the lens of intellectual capital, an increasingly important driver of economic productivity whose value derives primarily from workers’ knowledge, experience and skills. The Article discusses how business owners increasingly are able to “propertize” labor into intellectual capital — to control their workers and appropriate the returns on their labor through the expansive use of intellectual property laws, contract and employment laws, and other legal mechanisms. The Article then shows how the tax law provides significant subsidies to the process of propertization and thereby contributes to the inequitable distribution of returns between business owners and workers. The Article’s analysis further reveals the tax law’s fundamental capital-labor distinction to be questionable, perhaps even illusory, an insight which has profound implications for the tax law.

April 12, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Browde:  The Need For Increased Penalties To Deter Tax Identity Theft

Florida Tax Review  (2015)Pippa Browde (Montana), Many Unhappy Returns: The Need for Increased Tax Penalties for Identity Theft-Based Refund Fraud, 18 Fla. Tax Rev. 53 (2015):

The growing problem of fraudulent tax returns being submitted based on stolen identities is a “tsunami of fraud,” and victims, lawmakers, and law enforcement are struggling with how to deal with the fallout. The issues surrounding identity theft-based tax fraud are complex. Current IRS efforts to stem the tide involve pouring resources into assisting victims, updating IRS processes to detect and prevent refund fraud, and increasing the number of criminal investigations and prosecutions it pursues. The IRS’s approach and pending proposed legislation are not enough to address the problems created by identity theft-based tax fraud. This article argues the IRS and Congress must use a holistic approach to attack this specie of tax fraud. To that end, this article supports enhanced criminal penalties and proposes new civil tax penalties aimed specifically at identity theft tax fraud.

This article pursues two goals. First, it documents and explains the problem of identity theft-based refund fraud, highlighting particular issues with respect to tax compliance. In so doing it analyzes existing civil and criminal tax penalties to punish and deter identity thieves, an analysis which reveals that existing criminal penalties are insufficient and that there is no directly applicable existing civil penalty. Second, to address the gaps in existing law, the article proposes standards for Congress to use in crafting a comprehensive penalty scheme to apply to identity theft-based refund fraud.

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April 12, 2016 in Scholarship, Tax | Permalink | Comments (1)

McCormack:  Postpartum Taxation

Shannon McCormack (University of Washington), Postpartum Taxation: The Internal Revenue Code and the Opt Out Mom, 104 Geo. L.J. ___ (2016):

Legislation seeking to ensure that women receive equal pay for equal work has been on the books for decades. Nevertheless, the average American woman still receives less than eighty cents for every dollar earned by the average American man. Happily, the gender pay gap between men and childless women is narrowing over time. Meanwhile, the gap between mothers and others continues to widen. Career interruptions contribute significantly to this disturbing trend — nearly half of mothers opt out of the workforce at some point in their lives, most often to care for young children. Faced with too-short (or non-existent) maternity leaves, inflexible work schedules and the soaring costs of childcare in the United States, this opt out phenomenon is hardly surprising. But with the decision to opt out comes grave cost. Over 90% of opt out moms want to return to the workforce several years after off ramping. Unfortunately, many discover that they are unable to do so. A mother that does manage to reenter the workforce will find that even a short off ramp results in a sizeable and disproportionate reduction in her annual earnings that will persist for every year of her remaining life.

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April 12, 2016 in Scholarship, Tax | Permalink | Comments (7)

Hasen:  Taxation And Innovation

David Hasen (Colorado), Taxation and Innovation: A Sectorial Approach:

A number of tax rules have been adopted or proposed to promote innovation. The primary justification for these rules is that they can be effective in reducing or eliminating chronic market failure in the innovation sector. This paper argues that special tax rules for innovation generally are inappropriate. The basic circumstance giving rise to market failure in the innovation sector is the positive externality associated with information production. Special tax rules do not correct the externality; they merely compensate for it through other mechanisms that themselves create deadweight loss. In place of special tax rules that promote innovation, policy makers should adopt rules that counteract disproportionately large tax-induced distortions in the innovation sector. Among these distortions is excess risk-taking, a phenomenon attributable to the lognormal nature of returns to risk-bearing.

April 12, 2016 in Scholarship, Tax | Permalink | Comments (0)

Monday, April 11, 2016

Oh Presents How The Rich Drive Progressive Marginal Tax Rates Today At Pepperdine

OhJason S. Oh (UCLA) presents How the Rich Drive Progressive Marginal Tax Rates at Pepperdine today as part of our Tax Policy Workshop Series funded in part by a generous gift from Scott Racine:

Why do income tax systems consistently feature progressive marginal rates? The existing literature tells a political story focusing on the preferences of the poor and middle class – high rates at the top of the rate schedule can fund greater redistribution. This Article argues that progressive marginal rates can alternatively be explained by focusing on the preferences of the middle class and the rich regarding the bottom of the rate schedule. Specifically, these groups benefit from inframarginal rate cuts at low levels of income. This alternative explanation of marginal rate progressivity is attractive because it focuses on the rich, a group which intuition and research suggest wields disproportionate political power.

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April 11, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Fleischer Presents Alpha: Labor Is The New Capital Today At UC-Irvine

Fleischer (2016)Victor Fleischer (San Diego) presents Alpha: Labor is the New Capital at UC-Irvine today as part of its Tax Law and Policy Colloquium Series hosted by Omri Marian:

What taxpayers report as capital gains income is often a form of labor income in disguise. This is especially true at the very top of the income distribution, where a large and rising share of national income is derived from partnership allocations of carried interest, the sale of founders’ stock, and the sale of investment services partnership interests. Rich people sometimes say they are lightly taxed because they have investment income. This is not always true. Often, they are lightly taxed because corporate executives, founders of technology companies, and investment fund managers earn income that measures the value of their labor by reference to the value of a capital asset, thus transforming labor income into capital gains. This kind of income—what I call alpha income—accounts for the lion’s share of the recent rise of income inequality in the United States.

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April 11, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Hemel:  The Vanguard Case Reconsidered

VanguardDaniel Hemel (Chicago), The Vanguard Case Reconsidered, 150 Tax Notes 1466 (Mar. 21, 2016):

Recent news reports have suggested that the Vanguard Group family of mutual funds may need to quadruple investors’ fees to cover corporate income tax liabilities. Professor Reuven Avi-Yonah has estimated that Vanguard’s federal tax liability for the 2007-2014 period is roughly $34.6 billion. For the more than 20 million investors in Vanguard funds, the potential financial implications of the tax dispute are significant: Vanguard would presumably pass its tax costs along to customers, leading to higher expense ratios and lower returns. For observers of the IRS, the issue is an important one as well: A $34.6 billion recovery from Vanguard would be multiples more than what the IRS has ever recouped from a taxpayer in a transfer pricing case.

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April 11, 2016 in Scholarship, Tax | Permalink | Comments (1)

Caron & Soled:  New Prominence Of Tax Basis In Estate Planning

Paul L. Caron (Pepperdine) & Jay A. Soled (Rutgers), New Prominence of Tax Basis in Estate Planning, 150 Tax Notes 1569 (Mar. 28, 2016):

In this article, Caron and Soled discuss how section 1014(b)(6) offers a bridge for taxpayers to maximize the tax basis they have in their assets. Whether Congress should retain this anachronistic provision is an open issue. The authors explain the historical background of section 1014(b)(6), demonstrate the potential income tax savings from applying it, and outline several planning strategies to achieve those savings.

April 11, 2016 in Scholarship, Tax | Permalink | Comments (1)

Should Law Schools Give Summer Grants To Faculty For Teaching Projects As Well As For Research?

Summer GrantsMost law schools offer summer research grants.  The latest Society of American Law Teachers survey reports summer research grant awards at 82 law schools (41% of all law schools), ranging from $3,000 at Gonzaga (ranked #132 in U.S. News) to $27,500 at Georgia (#33).  Only one of the Top 25 law schools (Iowa) responded to the SALT survey, and anecdotal evidence suggests that summer research grants are much higher at those schools, often 2/9 of salary. The Best Practices for Legal Education blog "suggests that in addition to research grants, schools consider summer teaching innovation grants":

At Georgia State, like at many schools, our dean has encouraged us to integrate experiential learning throughout the curriculum.  And, he has put his money where his mouth is.

Faculty can compete for  summer teaching innovation grants which are funded at the same level as research grants. Both junior and senior faculty members have taken advantage of the summer grant  opportunities to either revamp existing courses or create new ones.

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April 11, 2016 in Legal Education, Scholarship, Teaching | Permalink | Comments (2)

Sunday, April 10, 2016

The Top 5 Tax Paper Downloads

SSRN LogoThere is a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with a new paper debuting on the list at #5:

  1. [623 Downloads]  Lexisnexis® Guide to FATCA Compliance: Chapter 1, by Willliam Byrnes (Texas A&M) & Robert J. Munro (Texas A&M)
  2. [300 Downloads]  The Tax Lives of Uber Drivers: Evidence from Internet Discussion Forums, by Shu-Yi Oei (Tulane) & Diane M. Ring (Boston College)
  3. [264 Downloads]  Ownership of the Means of Production, by E. Glen Weyl (Chicago) & Anthony Lee Zhang (Stanford)
  4. [243 Downloads]  Taxing Wealth Seriously, by Edward J. McCaffery (USC)
  5. [233 Downloads]  The Law of the Platform, by Orly Lobel (San Diego)

April 10, 2016 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Friday, April 8, 2016

Weekly SSRN Tax Roundup

Weekly Student Tax Note Roundup

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April 8, 2016 in Scholarship, Tax, Weekly Student Tax Note Roundup | Permalink | Comments (0)

Call For Papers:  NTA 109th Annual Conference On Taxation

NTA LogoThe National Tax Association has issued a Call for Papers for its 109th Annual Conference on Taxation to be held Nov. 10-12, 2016 in Baltimore:

The 109th Annual Conference on Taxation will cover a broad range of topics including, but not limited to, taxation and tax policies; expenditure policies; government budgeting; intergovernmental fiscal relations; and subnational, national, and international public finance. The conference will focus, as always, on policy-relevant research bearing on taxation and government spending.

You are invited to submit a paper or a complete session. May 1, 2016 is the deadline for submitting papers or sessions. Decisions concerning the inclusion of papers and sessions will be announced in July 2016. Authors of accepted papers will be offered the opportunity to include them in the Proceedings. All presenters will be required to register and pay a conference registration fee.

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April 8, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Thursday, April 7, 2016

Kahng Presents Who Owns Human Capital? Today At Indiana

Kahng (2016)Lily Kahng (Seattle) presents Who Owns Human Capital?, 93 Wash. U. L. Rev. ___ (2016), at Indiana-Bloomington today as part of its Tax Policy Colloquium Series hosted by Leandra Lederman:

This Article analyzes the tax law’s capital income preference through the lens of intellectual capital, an increasingly important driver of economic productivity whose value derives primarily from workers’ knowledge, experience and skills. The Article discusses how business owners increasingly are able to “propertize” labor into intellectual capital — to control their workers and appropriate the returns on their labor through the expansive use of intellectual property laws, contract and employment laws, and other legal mechanisms. The Article then shows how the tax law provides significant subsidies to the process of propertization and thereby contributes to the inequitable distribution of returns between business owners and workers. The Article’s analysis further reveals the tax law’s fundamental capital-labor distinction to be questionable, perhaps even illusory, an insight which has profound implications for the tax law.

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April 7, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (1)

Blank Presents The Timing Of Tax Transparency Today At Duke

Blank (2016)Joshua Blank (NYU) presents The Timing of Tax Transparency, 90 S. Cal. L. Rev. ___ (2017), at Duke today as part of its Tax Policy Workshop Series hosted by Lawrence Zelenak:

Fairness in the administration of the tax law is the subject of intense debate in the United States. As recent headlines reveal, the Internal Revenue Service has been accused of failing to enforce the tax law equitably in its review of tax-exempt status applications by political organizations, the international tax structures of multinational corporations, and the estate tax returns of millionaires, among other areas. Many have argued that greater “tax transparency” would better empower the public to hold the IRS accountable and the IRS to defend itself against accusations of malfeasance. Mandatory public disclosure of taxpayers’ tax return information is often proposed as a way to achieve greater tax transparency. Yet, in addition to concerns regarding exposure of personal and proprietary information, broad public disclosure measures pose potential threats to the taxing authority’s ability to enforce the tax law.

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April 7, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Lederman Presents Does Enforcement Crowd Out Voluntary Tax Compliance? At Tulane

Ledderman (2016)Leandra Lederman (Indiana-Bloomnington) presented Does Enforcement Crowd Out Voluntary Tax Compliance? at Tulane as part of its Regulation and Coordination Workshop Series:

Governments commonly use deterrence methods, such as audits and the imposition of penalties, to foster compliance with tax laws. Although this approach is consistent with economic modeling of tax compliance, some scholars caution that deterrence may backfire, “crowding out” intrinsic motivations to pay taxes and thus reducing compliance. This article analyzes the evidence to date to determine the extent of such an effect. Field studies suggest that deterrence tools, such as audits, generally are highly effective at increasing tax collections but that crowding out may occur in some contexts, with respect to certain subgroups of taxpayers.

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April 7, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Prisinzano & Yagan Present Business In The U.S.: Who Owns It And How Much Do They Pay? At NYU

NYU Law (2016)Richard Prisinzano (U.S. Treasury Department, Office of Tax Analysis) & Danny Yagan (UC-Berkeley) presented Business in the United States: Who Owns It and How Much Do They Pay? at NYU as part of its Tax Policy Colloquium Series hosted by Daniel Shaviro and Chris Sanchirico:

"Pass-through" businesses like partnerships and S-corporations now generate over half of U.S. business income and account for much of the post-1980 rise in the top-1% income share. We use administrative tax data from 2011 to identify pass-through business owners and estimate how much tax they pay. We present three findings. (1) Relative to traditional business income, pass-through business income is substantially more concentrated among high-earners. (2) Partnership ownership is opaque: 20% of the income goes to unclassifiable partners, and 15% of the income is earned in circularly owned partnerships. (3) The average federal income tax rate on U.S. pass-through business income is 19%--much lower than the average rate on traditional corporations. If pass-through activity had remained at 1980's low level, strong but straightforward assumptions imply that the 2011 average U.S. tax rate on total U.S. business income would have been 28% rather than 24%, and tax revenue would have been approximately $100 billion higher.

Dan Shaviro (NYU):

This is an important contribution, or rather the first of what are likely to be a series of important contributions, that attempt to increase our knowledge by making use of U.S. federal tax return information about businesses in the U.S. that are taxed as pass-throughs (i.e., partnerships or S corporations). In particular, it seeks to link information from partnership-level Form 1065 returns to that from partner-level Schedule K-1 returns, thereby presenting a comprehensive picture of who reports partnership income and how much U.S. federal income tax is paid on such income. In a more rational world, this would have been done years ago, and doing it would be easier than it actually is. I'll focus here just on partnerships, although there is also some information in the paper in re. S corporations.

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April 7, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Stark Presents Regional Taxation And Regional Tax Base Sharing In State Tax Reform Today At Colorado

Stark (2014)Kirk Stark (UCLA) presents Regional Taxation and Regional Tax Base Sharing in State Tax Reform at Colorado today as part of its Tax Policy Colloquium Series hosted by David Hasen and Sloan Speck:

This article describes and evaluates a specific subset of state tax reforms—i.e., those involving regional approaches to funding subnational public goods. Reforms examined include those where policymakers devise new multijurisdictional fiscal arrangements to address regional objectives that conventional local governments, by virtue of their more limited geographic scope, are unlikely to tackle. As used in this article, the term “region” refers to a geographic area (1) constituting less than the entire jurisdiction of a state, and (2) encompassing more than one local government jurisdiction. A “regional tax” is therefore any tax (fee, assessment, etc....) limited in its application to a geographic area so defined. A closely related policy is “regional tax base sharing”—i.e., the imposition of a tax on a base that is shared among several local jurisdictions, with the proceeds distributed among those localities.

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April 7, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Brunson:  The Taxation Of Mutual Funds

Samuel D. Brunson (Loyola-Chicago), The Taxation of RICs: Replicating Portfolio Investment or Eliminating Double Taxation?, 20 Stan. J.L. Bus. & Fin. 222 (2015):

Mutual FundsMutual funds and other regulated investment companies currently occupy a central space in American households’ financial lives. Is spite of their near-ubiquity, though, regulated investment companies occupy a strange tax limbo as quasi-pass-through entities, neither fully taxable nor fully tax-transparent. To qualify for this quasi-pass-through status, regulated investment companies must, among other things, distribute the bulk of their income to shareholders annually.

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April 7, 2016 in Scholarship, Tax | Permalink | Comments (0)

Wednesday, April 6, 2016

Burman Presents An Analysis Of The Ted Cruz And Bernie Sanders Tax Plans Today At Georgetown

Burman (2016)Len Burman (Tax Policy Center) presents An Analysis of the Ted Cruz and Bernie Sanders Tax Plans at Georgetown today as part of its Tax Law and Public Finance Workshop Series hosted by John Brooks and Itai Grinberg:

Presidential candidate Ted Cruz’s tax proposal would (1) repeal the corporate income tax, payroll taxes for Social Security and Medicare, and estate and gift taxes; (2) collapse the seven individual income tax rates to a single 10 percent rate, increase the standard deduction, and eliminate most other deductions and credits; and (3) introduce a new 16 percent broad-based consumption tax. The plan would cut taxes at most income levels, although the highest-income households would benefit the most and the poor the least. Federal tax revenues would decline by $8.6 trillion (3.6 percent of gross domestic product) over a decade.

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April 6, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (2)

Prisinzano Presents Business In The U.S.: Who Owns It And How Much Do They Pay? Today At Penn

Penn (2016)Richard Prisinzano (U.S. Treasury Department, Office of Tax Analysis) presents Business in the United States: Who Owns It and How Much Do They Pay? at Pennsylvania today as part of its Center for Tax Law and Policy Seminar Series hosted by Chris Sanchirico and Reed Shuldiner:

"Pass-through" businesses like partnerships and S-corporations now generate over half of U.S. business income and account for much of the post-1980 rise in the top-1% income share. We use administrative tax data from 2011 to identify pass-through business owners and estimate how much tax they pay. We present three findings. (1) Relative to traditional business income, pass-through business income is substantially more concentrated among high-earners. (2) Partnership ownership is opaque: 20% of the income goes to unclassifiable partners, and 15% of the income is earned in circularly owned partnerships. (3) The average federal income tax rate on U.S. pass-through business income is 19%--much lower than the average rate on traditional corporations. If pass-through activity had remained at 1980's low level, strong but straightforward assumptions imply that the 2011 average U.S. tax rate on total U.S. business income would have been 28% rather than 24%, and tax revenue would have been approximately $100 billion higher.

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April 6, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (1)

Faulhaber Presents Designing R&D Credits And Patent Boxes In The Age Of BEPS At Northwestern

FaulhaberLily Faulhaber (Georgetown) presented Tax Incentives for Innovation: Designing R&D Credits and Patent Boxes in the Age of BEPS at Northwestern yesterday as part of its Advanced Topics in Taxation  Workshop Series hosted by Herbert Beller, Charlotte CraneDavid Cameron, Philip Postlewaite, Jeffrey Sheffield, and Robert Wootton:

For decades, governments have turned to their tax codes to support research and development and innovation. In recent years, countries have added yet another tool to their repertoire of tax incentives for R&D: innovation boxes, sometimes referred to as patent boxes or IP boxes, which provide benefits to income from intellectual property. In response to the increasing number of innovation boxes, the forty-four OECD and G-20 member countries involved in the recent BEPS Project developed a requirement known as the nexus approach that places limits on the design of these tax incentives.

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April 6, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Lipman Presents The Individual Tax Penalty And The Affordable Care Act Today At UNLV

LipmanFrancine Lipman (UNLV) presents Irresponsibly Taxing Irresponsibility: The Individual Tax Penalty and the Affordable Care Act, 23 Geo. J. on Poverty L. & Pol'y ___ (2016) (with James Owens (J.D. 2015, UNLV)) at the Western Decision Sciences Institute Annual Meeting today at UNLV:

This article first details and then revises the newly implemented penalty tax (the Shared Responsibility Payment or the “SRP”) under the Affordable Care Act. The SRP was designed by Congress to ensure that every American obtains minimum essential healthcare coverage so that comprehensive and affordable health care coverage can be achieved for all qualifying Americans. While the penalty tax was deemed constitutional by the United States Supreme Court, it is extremely complicated and has challenged many Americans especially lower-income individuals.

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April 6, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (1)

The Tax Lawyer Publishes New Issue

The Tax Lawyer (2013)The Tax Lawyer has published Vol. 69, No. 2 (Winter 2016):

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April 6, 2016 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0)

Tuesday, April 5, 2016

Knoll & Mason:  Economic Foundation Of The Dormant Commerce Clause

Michael S. Knoll (Pennsylvania) & Ruth Mason (Virginia), Economic Foundation of the Dormant Commerce Clause, 102 Va. L. Rev. ___ (2016):

Last Term, a sharply divided Supreme Court decided a landmark dormant Commerce Clause case, Comptroller of the Treasury of Maryland v. Wynne. Wynne represents the Court’s first clear acknowledgement of the economic underpinnings of one of its main doctrinal tools for resolving tax discrimination cases, the internal consistency test. In deciding Wynne, the Court relied on economic analysis we provided. This Essay explains that analysis, why the majority accepted it, why the dissenters’ objections to the majority’s reasoning miss their mark, and what Wynne means for state taxation.

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April 5, 2016 in Scholarship, Tax | Permalink | Comments (1)

ACTEC Issues Request For Proposals For $20,000 Grant To Host T&E Symposium

ACTECThe Legal Education Committee of the American College of Trust and Estate Counsel (ACTEC) requests proposals for a $20,000 grant to host an academic symposium on trust and estate law during the 2017-18 academic year:

The ACTEC Foundation Symposium is intended to be the premier academic symposium on trust and estate law in the United States. The goals of the symposium are to stimulate development of scholarly work in trust and estate law, bridge the gap between the academic community and practitioners, provide opportunities for junior academics to present papers and interact with more senior academics, provide an opportunity for trust and estate professors to interact with each other, involve academics from other disciplines in discussions of trust and estate topics, and strengthen ACTEC’s image as the leading organization for trust and estate lawyers, both practitioners and academics.

The grant associated with this RFP is contingent on approval by the ACTEC Foundation.

RFPs are due by Monday, May 2, 2016, and will be considered by the Symposium Subcommittee of the ACTEC Legal Education Committee at ACTEC’s Summer Meeting in Boston, Massachusetts, in June 2016. Please submit RFPs (RFP content and guidelines are set forth below) to:

Nancy A. McLaughlin
Professor of Law, University of Utah SJ Quinney College of Law
Co-Chair, ACTEC Legal Education Committee
nancy.mclaughlin@law.utah.edu

Electronic submissions are fine (subject line of email should read “ACTEC Symposium RFP”).

I. RFP Content

The RFP should provide the following information.

A. Theme. The theme of the symposium should be related to trust and estate law, defined to include any topic related to the gratuitous transfer of property (e.g., probate law, trust law, elder law, transfer tax law). A broad theme permits a wide range of papers and is more likely to be successful. Past themes have included Trust Law in the 21st Century (Cardozo 2005); Inheritance Law in the 21st Century (UCLA 2008); Philanthropy Law in the 21st Century (Chicago-Kent 2009); The Uniform Probate Code: Remaking of American Succession Law (Michigan 2011); and The Role of Federal Law in Private Wealth Transfer (Vanderbilt 2014). The theme of the most recent symposium, which took place at Boston College Law School in October 2015, was The Centennial of the Estate Tax: Perspectives and Recommendations (articles will be published in the Boston College Law Review May 2016 symposium edition).

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April 5, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

University Of Basel Call For Papers:  Global Histories Of Taxation And State Finances Since The Late 19th Century

BaselVanessa Ogle (Pennsylvania) and the Institute for European Global Studies at the University of Basel (Switzerland) have issued a  Call for Papers for a symposium on Global Histories of Taxation and State Finances Since the Late 19th Century to be held at the University of Basel on December 1-3, 2016.  The deadline for submitting proposals is May 31, 2016.

Taxation has wide-ranging implications for global as well as domestic orders, ranging from budgets and public finances to inequality, the social fabric of societies, and worldwide competition for corporate profits. Since the global financial crisis of 2008 in particular, taxation and the reform of tax systems have become talking points in many parts of the North Atlantic world. Tax reform is often said to be required for fostering a more attractive business climate through reducing the tax burden and thus increasing tax competitiveness. Other voices focus on government revenues in times of empty coffers and instead call for higher tax rates especially for top earners. Thomas Piketty and his Capital in the Twenty-First Century as well as the Occupy movement in the United States have galvanized attention on the connections between taxes and inequality. Outrage at the rise of the “One Percent” is accompanied by calls for shutting down tax havens available mostly to the super rich. Whether in the United States or Britain, however, multinationals such as Google and Apple successfully play the inversion game by splitting up into multiple units and reincorporating in lower-tax countries for the purpose of obtaining better tax conditions.

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April 5, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Monday, April 4, 2016

Shobe:  Supercharged IPOs, The Up-C, And Private Tax Benefits In Public Offerings

Gladriel Shobe (BYU), Supercharged IPOs, the Up-C, and Private Tax Benefits in Public Offerings, 88  U. Colo. L. Rev. ___ (2016):

The “supercharged IPO”, a new and increasingly popular financial transaction, has fundamentally changed the nature of IPOs for many companies. Traditionally, an IPO was a tax nonevent for the company and the owners, meaning it created no tax liability for either. Through creative and questionable tax planning, companies have found a way to do better than this by effectively generating a negative tax liability for the company and its owners. These transactions have received substantial attention from practicing lawyers, investment bankers, journalists, and even briefly caught the attention of Congress. Yet these transactions have attracted surprisingly little scrutiny from scholars, and the attention they have received has failed to consider the different types of supercharged IPOs, which is necessary for understanding why these transactions exist, why they have increased in popularity, and whether they are justified legally and normatively. This Article examines the costs and benefits of the different types of supercharged IPOs to show that some of these transactions have greater tax benefits than scholars have realized. It places a particular emphasis on the Up-C, a structure with the greatest tax benefits, which scholars have overlooked even though it is by far the most common, and increasingly popular, form of supercharged IPO. A closer examination of the Up-C, separate from other supercharged IPOs, reveals that this structure produces tax benefits that are not justified by the regulations that supposedly allow them.

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April 4, 2016 in Scholarship, Tax | Permalink | Comments (0)

Oei, Simkovic Debate The Knowledge Tax

Shu-Yi Oei (Tulane), Supply, Demand, and the Taxation of Knowledge, 82 U. Chi. L. Rev. Dialogue 268 (2016):

In The Knowledge Tax, 82 U. Chi. L. Rev. 1981 (2015), Professor Michael Simkovic tackles the question of why rates of return on higher education are higher than rates of return on other types of investments, such as equity and real estate. Dissatisfied with existing economic explanations, the additional account that he offers is distortionary taxation: specifically, we tax higher education less favorably than other investments, thereby driving down demand for higher education relative to alternatives, creating an undersupply of labor, and buttressing education’s rate of return. In this invited response essay, I explore some of the issues raised but left open by The Knowledge Tax. I largely accept the article’s factual premise — that pretax rates of return on higher education are higher than returns on equity — but question some aspects of the argument and develop other aspects. I make three basic points: First, it is not clear that higher education is, in fact, taxed less favorably than traditional investments. Second, the analysis rests on the assumption that higher education and capital investment are substitutes, but it is not clear the extent to which this is the case. Finally, to the extent that tax considerations play a role in the decisions of potential students, we need a more robust account of which tax incentives matter.

Michael Simkovic (Seton Hall), Taxes, Subsidies, and Knowledge: A Reply to Professor Oei, 82 U. Chi.. L. Rev. Dialogue ___ (2016):

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April 4, 2016 in Scholarship, Tax | Permalink | Comments (0)

Sunday, April 3, 2016

The Top 5 Tax Paper Downloads

SSRN LogoThere is a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with a new #1 paper and other reshuffling of the order within the Top 5:

  1. [509 Downloads]  Lexisnexis® Guide to FATCA Compliance: Chapter 1, by Willliam Byrnes (Texas A&M) & Robert J. Munro (Texas A&M)
  2. [459 Downloads]  What Now? A Boomer's Baedeker for the Distribution Phase of Defined Contribution Retirement Plans, by Richard Kaplan (Illinois)
  3. [288 Downloads]  The Tax Lives of Uber Drivers: Evidence from Internet Discussion Forums, by Shu-Yi Oei (Tulane) & Diane M. Ring (Boston College)
  4. [227 Downloads]  Ownership of the Means of Production, by E. Glen Weyl (Chicago) & Anthony Lee Zhang (Stanford)
  5. [222 Downloads]  Taxing Wealth Seriously, by Edward J. McCaffery (USC)

April 3, 2016 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Saturday, April 2, 2016

19th Annual Critical Tax Theory Conference Concludes Today At Tulane

Tulane (2015)The 19th Annual Critical Tax Theory Conference concludes today at Tulane:

Panel #4:  Tax Expenditures, Social Insurance, and Younger Generations (Chair: Charlotte Crane (Northwestern))

  • Samuel Brunson (Loyola-Chicago) & David Herzig (Valparaiso), The Effect of Obergefell on the Tax Exemption of Churches and Religiously-Affiliated Organizations
  • Neil Buchanan (George Washington), Social Security, Inequality, and Younger Generations
  • Nancy Shurtz (Oregon), Rethinking the Taxable Unit: Why Dependency Trumps Marriage as the Preferred Reference Standard

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April 2, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Kleinbard Presents Fiscal Policy In An Age Of Inequality Today At AAA Conference

Kleinbard (2015)Edward Kleinbard (USC) presents Fiscal Policy in an Age of Inequality at the American Accounting Association 2016 Conference and Doctoral/Early Scholar Consortium today in Orlando, Florida:

Federal budget deficits are always easy news fodder, and the Congressional Budget Office’s deficit projections for the next 10 years are uncomfortably high by most measures. Government today is operating in a budget deficit lull, but the pace of deficit growth is predicted to increase again after 2018, and under the CBO’s baseline assumptions are projected to reach 4.9 percent of GDP in 2026.

But deficit projections convey less information than is generally understood, both because the assumptions underlying the projections abstract from realistic outcomes in various respects, and because deficits themselves are the net of two numbers, government revenues and government expenses. Are taxes too low, or government spending too high? Or are both too low relative to our needs?

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April 2, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Friday, April 1, 2016

19th Annual Critical Tax Theory Conference Kicks Off Today At Tulane

Tulane (2015)The 19th Annual Critical Tax Theory Conference kicks off today at Tulane:

Critical tax scholarship aims at looking beyond the language of the Code and regulations to examine what the tax law actually does. It has roots in critical legal studies generally, and therefore Critical tax scholars frequently ask why the tax laws are the way they are and what impact tax laws have on historically disempowered groups, such as people of color; women; lesbian, gay, bisexual, and transgendered individuals; low-income and poor individuals; the disabled; and nontraditional families. But Critical tax scholarship is not limited either to those topics or to any particular methodology.

Critical tax scholarship shares the following goals: (1) to uncover bias in the tax laws; (2) to explore and expose how the tax laws both reflect and construct social meaning; and (3) to educate nontax scholars and lawyers about the interconnectedness of taxation, social justice, and progressive political movements. Critical tax scholars employ a variety of methods to achieve these goals such as bringing "outsider" perspectives to the study of tax law; using historical material, contemporary case studies, and personal or fictional narratives to illustrate the practical impact of the tax laws on individuals and groups; interpreting social science and economic data to show how the tax laws impact groups differently; and exploring the interconnectedness of tax laws with economic forces such as the labor market and international financial and political development.

Panel #1:  Tax Compliance and Tax Regime Design (Chair: Adam Rosenzweig (Washington University))

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April 1, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Blank Presents The Timing Of Tax Transparency Today At Virginia

Blank (2016)Joshua Blank (NYU) presents The Timing of Tax Transparency, 90 S. Cal. L. Rev. ___ (2017), at Virginia today as part of its Faculty Workshop Series:

Fairness in the administration of the tax law is the subject of intense debate in the United States. As recent headlines reveal, the Internal Revenue Service has been accused of failing to enforce the tax law equitably in its review of tax-exempt status applications by political organizations, the international tax structures of multinational corporations, and the estate tax returns of millionaires, among other areas. Many have argued that greater “tax transparency” would better empower the public to hold the IRS accountable and the IRS to defend itself against accusations of malfeasance. Mandatory public disclosure of taxpayers’ tax return information is often proposed as a way to achieve greater tax transparency. Yet, in addition to concerns regarding exposure of personal and proprietary information, broad public disclosure measures pose potential threats to the taxing authority’s ability to enforce the tax law.

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April 1, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Drumbl Presents Poverty, Tax, And Noncompliance Today In Australia

DrumblMichelle Drumbl (Washington & Lee) presents Beyond Polemics: Poverty, Tax, and Noncompliance today at the 12th International Conference on Tax Administration (program) hosted by the University of New South Wales in Sydney, Australia:

The earned income tax credit (EITC) is the most significant earnings-based refundable credit in the U.S. tax system. Designed as an anti-poverty program, it is a social benefit administered by the Internal Revenue Service. The EITC reaches more than 27 million households annually. Studies show it has a positive impact upon the children whose families receive it. Despite its many positives, however, the EITC is a program that for years has been plagued by taxpayer noncompliance: the estimated rate of improper payments on EITC claims has ranged between 20 and 30%, totaling billions of dollars annually. Though it is believed that the majority of EITC noncompliance may be unintentional, public reports of misconduct and fraud add fuel to the political rhetoric about a revenue system in which nearly half of Americans pay no federal income tax.

This article unpacks the rhetoric. It describes why the term “improper payments” is not synonymous with fraud. It places EITC noncompliance within the broader context of the U.S. “tax gap” and examines what intentional EITC noncompliance has in common with sole proprietor noncompliance. It explores motivations for intentional EITC noncompliance and also examines the role of inadvertent error in the overclaim rate. It describes the ways in which self-prepared returns present wholly different challenges than those completed by paid preparers.

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April 1, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (1)

Weekly SSRN Tax Roundup

Thursday, March 31, 2016

Goldin Presents Rethinking The Taxation Of Single Parents Today At Duke

GoldinJacob Goldin (Stanford) presents Beyond Head of Household: Rethinking the Taxation of Single Parents (with Zachary Liscow (Yale)) at Duke today as part of its Tax Policy Workshop Series hosted by Lawrence Zelenak:

Under current law, unmarried taxpayers with children can take advantage of the head of household filing status (HHFS) to reduce their federal income taxes. We argue that the design of the filing status is largely obsolete, geared toward alleviating a “marriage penalty” in the tax code that is much less important than when the filing status was first established. At the same time, the growth in the fraction of Americans raising children outside of traditional two-parent households has dramatically raised the cost of the filing status to the fisc.

In this article, we highlight two features of the design of HHFS that undermine its goal of providing support to single parent households.

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March 31, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)