TaxProf Blog

Editor: Paul L. Caron
Pepperdine University School of Law

Thursday, May 12, 2016

Chodorow:  Bitcoin And The Definition Of Foreign Currency

Florida Tax Review  (2015)Adam Chodorow (Arizona State), Bitcoin and the Definition of Foreign Currency, 19 Fla. Tax Rev. ___ (2016):

The IRS recently dealt a blow to Bitcoin enthusiasts by ruling that Bitcoin and other similar currencies should be treated as property – and not foreign currency – for income tax purposes. As a result, those who use bitcoins to purchase goods or services must report gain or loss on each transaction if the bitcoins have changed value between the time they were acquired and spent. Treating Bitcoin as a foreign currency would have permitted individuals to take advantage of the personal use exemption, which could facilitate Bitcoin’s adoption, and required taxpayers to adopt a formulaic system for tracking the basis of commingled bitcoins. The IRS’s decision seems correct as a matter of positive law, but laws can always be changed.

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

Wednesday, May 11, 2016

Sunstein:  Using Increased Chevron Deference To Combat Growing 'Partyism' In America

Cass R. Sunstein (Harvard), Partyism, 2016 U. Chi. Legal F. ___:

“Partyism” is a form of hostility and prejudice that operates across political lines. For example, some Republicans have an immediate aversive reaction to Democrats, and some Democrats have the same aversive reaction to Republicans, so much so that they would discriminate against them in hiring or promotion decisions, or in imposing punishment. If elected officials suffer from partyism – perhaps because their constituents do – they will devalue proposals from the opposing party and refuse to enter into agreements with its members, even if their independent assessment, freed from partyism, would be favorably disposed toward those proposals or agreements. In the United States, partyism has been rapidly growing, and it is quite pronounced – in some ways, more so than racism. It also has a series of adverse effects on governance itself, above all by making it difficult to enact desirable legislation and thus disrupting the system of separation of powers. Under circumstances of severe partyism, relatively broad delegations of authority to the executive branch, and a suitably receptive approach to the Chevron principle, have considerable appeal as ways of allowing significant social problems to be addressed. This conclusion bears on both domestic issues and foreign affairs.

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May 11, 2016 in Scholarship, Tax | Permalink | Comments (2)

Kwon:  The Criminality Of Tax Planning

Florida Tax Review  (2015)Michelle M. Kwon (Tennessee), The Criminality of Tax Planning, 18 Fla. Tax Rev. 153 (2015):

In recent years, the federal government has adopted an aggressive prosecution policy that targets tax advisors who help their clients evade taxes. Increased prosecutions coupled with the present-day sophistication of tax practice call for a critical examination of the willfulness standard applied to tax advisors who use the Code and Treasury regulations as part of their regular practices. This is something no previous legal scholarship has done.

To establish willfulness, the government must show that a person accused of a tax crime intentionally violated a known legal duty. Because knowledge of illegality is an element of the government's tax evasion case, prosecutors must negate a defendant's claim of ignorance or misunderstanding of the law, which is evaluated subjectively. The mistake of tax law defense and the knowledge of illegality standard are anomalies since ignorance of the law usually is not an excuse. The Supreme Court, however, has said that tax law is special due to the need to protect average citizens from prosecution for innocent mistakes made due to the complexity of the tax laws. The same high standard of willfulness that applies to average citizens also applies to tax professionals.

This Article aims to do two primary things. First, it demonstrates that consideration should be given to broadening the current willfulness standard as it is applied to tax advisors. Second, it evaluates the suitability of Samuel Buell and Lisa Kern Griffin's work on “consciousness of wrongdoing” as one possible approach to consider.

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

Clausing:  Profit Shifting and U.S. Corporate Tax Policy Reform

Clausing
  Kimberly A. Clausing (Reed College), Profit Shifting and U.S. Corporate Tax Policy Reform:

This paper argues that the erosion of the U.S. corporate income tax base is a large policy problem. Profit shifting by U.S. multinational corporations is reducing U.S. government tax revenues by more than $100 billion each year, and other countries are facing similar concerns.

Figure 3

Yet given the starting point of the current U.S. corporate tax system, potential reformers face a dilemma. Reforms that would protect the U.S. corporate tax base may not find support in the multinational business community, which is more concerned with perceived competitiveness problems. But reforms that address competitiveness worries—such as the “toothless territorial” system that many in the multinational business community favor—would make the tax base erosion problem far worse.

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

Kuehn:  Clinical Costs — Separating Fact From Opinion

Robert Kuehn (Washington University), Clinical Costs: Separating Fact From Opinion:

The late Senator Daniel Patrick Moynihan once observed, “Everyone is entitled to his own opinion, but not his own facts.” When it comes to expanding clinical legal education, the knee-jerk opinion is that it is too expensive for legal education to follow the lead of other professional schools and ensure that every student graduates with a clinical experience through a law clinic or externship. Even the richest law schools couldn’t resist playing the cost card to scare the ABA out of requiring additional professional skills training: “Requiring all law schools to provide 15 experiential credit hours to each student will impose large costs on law schools, costs that would have to be passed on to students. . . . Even a law school with significant financial resources could not afford such an undertaking.”

Yet, the facts show otherwise — every school, from the well-heeled to the impecunious, can provide a clinical experience to each student without increasing tuition.

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May 11, 2016 in Legal Education, Scholarship | Permalink | Comments (1)

Tuesday, May 10, 2016

The Tax Strategy Behind Google's Alphabet Reorganization

AlphabetBret N. Bogenschneider (Vienna) & Ruth Heilmeier (Cologne), Google's 'Alphabet Soup' in Delaware, 16 Hous. Bus. & Tax J. 1 (2016):

In this article the tax avoidance planning of Google’s “Alphabet” Delaware reorganization is explored in detail. The recent Google reorganization created an IP parent holding company in Delaware (“Alphabet”) yielding potential state corporate income tax avoidance benefits, including: (1) incremental royalty expense deductions in non-combined reporting states; (2) potential exclusion of foreign royalty income from the tax base in combined reporting states; (3) creation of a constitutional challenge to the taxation of foreign royalty income of Alphabet; and (4) domestic IP license benchmark for foreign affiliates to allow for repatriation of offshore cash by higher royalty payments.

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May 10, 2016 in Scholarship, Tax | Permalink | Comments (1)

Monday, May 9, 2016

Incentivizing And Assessing Law Faculty Committee Work Contributions

Committee Meeting 1Andrea Anne Curcio (Georgia State) & Mary A. Lynch (Albany), Incentivizing and Assessing Faculty Committee Work Contributions: Why Now?, 65 J. Legal Educ. ___ (2016):

Faculty scholarly productivity reaps tangible internal and external rewards while the "reward" for excellent faculty committee work performance often is additional committee work. Some faculty members perform substantial committee work while others spend little time on institutional service, leaving them more time for scholarship. Despite equity issues, this system maintains the faculty self-governance model integral to academic freedom, and the necessary service work gets done. This article suggests that this traditional workload distribution model may be unsustainable.

Innovations in legal education brought about by financial pressures, declining enrollments, and new accreditation standard requirements will result in increased committee workloads while reductions in full-time faculty at many schools leave fewer faculty members available to do that work. Those currently doing the lion's share of the work may be unable, or unwilling, to take on more committee work. This article examines methods for avoiding an institutional governance crisis.

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May 9, 2016 in Legal Education, Scholarship | Permalink | Comments (0)

Sunday, May 8, 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. [811 Downloads]  Lexisnexis® Guide to FATCA Compliance: Chapter 1, by Willliam Byrnes (Texas A&M) & Robert J. Munro (Texas A&M)
  2. [342 Downloads]  Ownership of the Means of Production, by E. Glen Weyl (Chicago) & Anthony Lee Zhang (Stanford)
  3. [307 Downloads]  The Law of the Platform, by Orly Lobel (San Diego)
  4. [271 Downloads]  The Panama Papers and Tax Morality, by Usman W. Chohan (University of New South Wales)
  5. [245 Downloads]  Trust Protectors: Why They Have Become 'The Next Big Thing', by Lawrence Frolik (Pittsburgh)

May 8, 2016 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Friday, May 6, 2016

Weekly SSRN Tax Roundup

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May 6, 2016 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Weekly Student Tax Note Roundup

Thursday, May 5, 2016

Virginia Tax Review Publishes New Issue

Virginia Tax Review (2016)The Virginia Tax Review has published Vol. 35, No. 1 (Summer 2015):

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

Brunson:  It Is Time For The IRS To Enforce The Prohibition On Campaigning By Churches

CHurchSamuel Brunson (Loyola-Chicago), Dear IRS, It Is Time to Enforce the Campaigning Prohibition. Even Against Churches, 87 U. Colo. L. Rev. 143 (2016):

In 1954, Congress prohibited tax-exempt public charites, including churches, from endorsing or opposing candidates for office. To the extent a tax-exempt public charity violated this prohibition, it would no longer qualify as tax-exempt, and the IRS was to revoke its exemption.

While simple in theory, in practice, the IRS rarely penalizes churches that violate the campaigning prohibition, and virtually never revokes a church’s tax exemption. And, because no taxpayer has standing to cuhallenge the IRS’s inaction, the IRS has no external imperative to revoke the exemptions of churches that do campaign on behalf of or against candidates for office.

This argment makes the normative case that, notwithstanding the IRS’s administrative discretion and the inability of taxpayers to challenge its nonenforcement in court, the time has come for the IRS to begin enforcing the campaigning prohibition.

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

Shay, Fleming & Peroni: Designing A 21st Century Corporate Tax

Florida Tax Review  (2015)Stephen E. Shay (Harvard), J. Clifton Fleming Jr. (BYU) & Robert J. Peroni (Texas), Designing a 21st Century Corporate Tax — An Advance U.S. Minimum Tax on Foreign Income and Other Measures to Protect the Base, 17 Fla. Tax Rev. 669 (2015):

The 21st Century has seen unprecedented levels of corporate tax aggressiveness and avoidance. This article continues our exploration of second best international tax reforms that would protect the U.S. corporate tax base and have some likelihood of adoption. In this case, we consider how a U.S. minimum tax on foreign income earned by a controlled foreign corporation should be designed to protect the United States against erosion of its corporate income tax base and to combat tax competition by low-tax intermediary countries. In the authors’ view, a minimum tax should be an interim levy that preserves the residual U.S. tax on foreign income, as distinguished from a final minimum tax that partially eliminates the U.S. residual tax. An interim minimum tax would be a significant improvement over current law and would more effectively limit incentives to seek low-taxed foreign income while ameliorating pressure to retain excess earnings abroad.

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

Call For Corporate Tax Papers:  ClassCrits IX

Class Crits 2ClassCrits IX Call for Papers and Participation: The New Corporatocracy and Election 2016:

We invite panel proposals, roundtable discussion proposals, and paper presentations that speak to this year’s theme, as well as to general ClassCrits themes.  Proposal due: May 16, 2016.

As the U.S. presidential election approaches, our 2016 conference will explore the role of corporate power in a political and economic system challenged by inequality and distrust as well as by new energy for transformative reform.

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May 5, 2016 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

Wednesday, May 4, 2016

Hemel:  The President's Power To Tax

Daniel Hemel (Chicago), The President's Power to Tax, 102 Cornell L. Rev. ___ (2016):

President Obama and his predecessors have used their regulatory authority to implement significant elements of their domestic policy agendas across a wide range of issue areas—including the environment, immigration, labor, and health care. But recent administrations have been much less willing to exercise regulatory authority in the realm of tax. More precisely, recent administrations have been reluctant to take regulatory actions that raise revenue (although quite willing, in certain cases, to take regulatory actions that move the law in a taxpayer-friendly direction). This is not because the Executive Branch lacks the legal authority to adopt significant revenue-raising tax reforms via regulation: as this article demonstrates, the Executive Branch’s “power to tax” under existing statutes is broad. Nor is it because the President is satisfied with the tax status quo: recent Presidents have repeatedly asked Congress to amend the tax code via legislation. Yet in many cases, the change that the President asks Congress to make is a change that the Executive Branch already has authority to make on its own. What explains the reluctance of recent administrations to raise revenue through regulatory action?

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

Puckett:  Structural Tax Exceptionalism

James M. Puckett (Penn State), Structural Tax Exceptionalism, 50 Ga. L. Rev. 1067 (2015):

This Article argues that it is misleading to declare the death of tax exceptionalism and that structural tax exceptionalism may have important benefits. Part II provides a brief historical overview of the rise of federal agency administration of statutes and especially tax laws. The history trends to detract from anti-tax and anti-agency rhetoric that counsel disempowering the Treasury Department and other administrative agencies from comprehensively enforcing laws and making policy in their relevant domains.

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May 4, 2016 in Scholarship, Tax | Permalink | Comments (1)

Kwak:  Reducing Inequality With A Retrospective Tax On Capital

James Kwak (Connecticut), Reducing Inequality with a Retrospective Tax on Capital, 25 Cornell J.L. & Pub. Pol'y 191 (2015):

Inequality in the developed world is high and growing: in the United States, 1% of the population now owns more than 40% of all wealth. In Capital in the Twenty-First Century, the economist Thomas Piketty argues that inequality is only likely to increase: invested capital tends to grow faster than the economy as a whole, causing wealth to concentrate in a small number of hands and eventually producing a society dominated by inherited fortunes. The solution he proposes, an annual wealth tax, has been reflexively dismissed even by supporters of his overall thesis, and presents a number of practical difficulties. However, a retrospective capital tax — which imposes a tax on the sale of an asset based on its (imputed) historical values — can reduce the rate of return on investments and thereby slow down the growth of wealth inequality. A retrospective capital tax mitigates or avoids the administrative and constitutional problems with a simple annual wealth tax and can reduce the rate of return on capital more effectively than a traditional income tax.

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May 4, 2016 in Scholarship, Tax | Permalink | Comments (2)

Tuesday, May 3, 2016

Prasad Presents Neoliberalism And The 1981 Reagan Tax Cuts Today At NYU

PrasadMonica Prasad (Northwestern) presents The Popular Origins of Neoliberalism in the Reagan Tax Cut of 1981, 24 J. Pol'y Hist. 351 (2012), at NYU today as part of its Tax Policy Colloquium Series hosted by Daniel Shaviro and Chris Sanchirico:

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

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

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May 3, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (1)

The Estate Tax Is Destroying The Environment

Estate TaxBrian Seasholes (Reason Foundation), The Ecologically Destructive Tax: How the Federal Estate Tax Is Ecologically Harmful and How to Fix It:

The ongoing debate over the federal estate tax tends to focus on the tax’s economic impacts, such as on small businesses, employment and capital formation, as well as the very small percentage it constitutes of federal tax receipts. Less well known, however, is the significant harm the estate tax does to the ecology of the United States.

Private lands, especially large, intact pieces of land, are critically important to ecological conservation. Conversely, land broken into smaller pieces is generally of less ecological value. Unfortunately, the estate tax results in private land being broken up, subdivided and sold. Over the past several decades it has become increasingly apparent that:

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May 3, 2016 in Scholarship, Tax, Think Tank Reports | Permalink | Comments (12)

Thimmesch:  Taxing Honesty

Adam B. Thimmesch (Nebraska), Taxing Honesty, 118 W. Va. L. Rev. 147 (2015):

It is commonly accepted that state use taxes, most notably those that are due on Internet purchases, are largely unenforceable against individual consumers. Consistent with that view, states have focused their enforcement efforts on forcing retailers to collect those taxes at the point of sale, and taxpayers have maintained nearly complete indifference toward remitting the tax of their own accord. This combination of factors has transformed the state use tax into a de facto tax on honesty — a tax with which only our most principled, risk-averse, or perhaps foolish even attempt to comply. The current structure of these taxes is further troubling because compliance is a practical impossibility. Unfortunately, however, academic attention to the state use tax has focused almost exclusively on whether and under what conditions states should be allowed to compel vendors to collect that tax.

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May 3, 2016 in Scholarship, Tax | Permalink | Comments (0)

Crawford:  The Best Estate & Gift Tax Articles Of 2014 & 2015

Bridget J. Crawford (Pace), Two Years' Worth of Estate and Gift Tax Law Review Articles, 151 Tax Notes 215 (Apr. 11, 2016):

Legal scholarship produced by law professors can be of great use to tax practitioners and policymakers. In the Tax Notes tradition of publishing "Law Review Summaries," Professor Crawford reviews five estate and gift tax articles from each of 2015 and 2014 that were published in student-run law reviews and which are likely to be of interest to tax professionals.

The articles from 2015 are:

  1. Steven J. Arsenault (Charlotte), Grantor Retained Annuity Trusts: After $100 Billion, It's Time to Solve the Great GRAT Caper, 63 Drake L. Rev. 373 (2015)
  2. Stephanie R. Hoffer (Ohio State), Making the Law More ABLE: Reforming Medicaid for Disability, 76 Ohio St. L.J. 1255 (2015)
  3. Sergio Pareja (New Mexico), How the Über-Wealthy Benefit From Investing Outside Retirement Plans (and How You Can Too), 64 Cath. U. L. Rev. 563 (2015)
  4. Margaret Ryznar (Indiana-Indianapolis), The Odd Couple: The Estate Tax and Family Law, 76 La. L. Rev. 523 (2015)
  5. Reid Kress Weisbord (Rutgers), Trust Term Extension, 67 Fla. L. Rev. 73 (2015)

The articles from 2014 are:

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May 3, 2016 in Scholarship, Tax | Permalink | Comments (0)

Grit And Legal Education:  Female Students Are Grittier Than Male Students

True GritEmily Zimmerman (Drexel) & Leah Brogan (Drexel), Grit and Legal Education, 36 Pace L. Rev. 114 (2015):

Although research indicates that grit predicts successful performance in a variety of contexts, grit is underexplored in the context of legal education. We investigated the relationship between grit and law school grade point average (GPA) among recent law school graduates. Contrary to expectations, a statistically significant correlation did not emerge between grit and law school GPA. However, average grit scores of women and men did significantly differ, with women reporting higher overall grit scores than men. Female and male participants’ law school GPAs did not significantly differ. This article discusses our research project and the questions regarding legal education that our findings raise. We also identify areas for further research regarding grit, legal education, and law practice.

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May 3, 2016 in Legal Education, Scholarship | Permalink | Comments (4)

Monday, May 2, 2016

The Evolution of Wealth Inequality: The Role of Skills, Taxes And Institutions

Barıs Kaymak (Université de Montréal) & Markus Poschke (McGill University), The Evolution of Wealth Inequality Over Half a Century: The Role of Skills, Taxes and Institutions:

Over the last 50 years, the US economy saw significant changes in its fiscal structure. Notable among these are the introduction and expansion of social security programs and Medicare, and the transformation of the tax system. These institutional changes took place against a backdrop of developments in the technology of production that increasingly favored skilled workers. In this paper, we analyze how the interplay between these institutional and technological factors might have shaped the distributions of income, wealth, consumption and welfare. We find that while changes in income inequality are mostly attributable to technological factors, the increase in wealth inequality has further been compounded by the expansion of social security and Medicare, which have reduced saving incentives for retirement, in particular for low and middle income groups. As a result, they have substantially increased wealth concentration in US. Results suggest that approximately 25% of the rise in the share of wealth held by the wealthiest 1% is explained by larger transfers to senior population.

Estate Tax 1

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May 2, 2016 in Scholarship, Tax | Permalink | Comments (2)

Borden:  Reforming REIT Taxation (Or Not)

REITBradley T. Borden (Brooklyn), Reforming REIT Taxation (Or Not), 53 Hous. L. Rev. 1 (2015):

Tax law treats the income of real estate investment trusts (REITs) differently from the income of regular corporations. Income distributed by regular corporations is subject to an entity-level tax and a shareholder-level tax, while taxable income distributed by REITs is subject to tax only at the shareholder level. To qualify for that single-level of tax, REITs must hold primarily real estate assets, and their income must be primarily from such assets. After being a relatively insignificant part of the economy for the first three decades of their existence, REITs have become relevant over the last twenty years, with the market capitalization of publicly traded REITs eclipsing 5% of U.S. GDP at the end of 2014. Reports about REITs appear frequently in major media outlets, with an emphasis on corporate-tax-base erosion that results from REIT taxation. Calls for REIT reform have been answered with proposed legislation that would change various aspects of REIT taxation. Recent work in this area shows that even though REITs do erode the corporate tax base, the requirement that they distribute income and the higher tax rates of REIT shareholders offset corporate-tax-base erosion and minimize the tax-revenue effects of REIT taxation.

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

Walker:  Junior Law Prawfs FAQs Series On How To Become A Voice In One's Field

Chris Walker (Ohio State) has produced an indispensable 13-part Junior Law Prawfs FAQs Series on how to become a voice in one's field (or, as I put it on an AALS panel nearly ten years ago, Building and Marketing Your Scholarly "Brand"):

  1. How Do I Become a Voice in My Field? (See Also: D Merritt, Going Meta on the Jr. Law Prawfs FAQ Series)
  2. How Does My Research Fit Within the Types of Legal Scholarship?
  3. Should I Say Write a Response to a Law Review Article (or Allow the Law Review to Solicit Responses to Mine)?
  4. Is Publishing a Book Review in a Law Review Still a Worthwhile Pretenure Endeavor? (See Also: P Horwitz, Yes (With Caveats), Publishing a Book Review is Still a Worthwhile Endeavor for Untenured Law Professors)
  5. How Do I Make Sense of Online Law Reviews?
  6. How Do I Increase the Chance My Scholarship Will Be Read?
  7. How Should I Respond to Requests to Read Draft Articles in My Field?
  8. How Can I Increase In-Person Scholarly Interaction with Limited Resources?
  9. Is Blogging Worth It? (See Also: M Froomkin, The Plural of Anecdote is "Blog"; O Kerr, Legal Academic Blogging and Influence vs. Credit)
  10. Is There Any Reason Not To Be on Twitter?
  11. What About Podcasts? What About Media Consultations? (See Also: C Turner, Podcasts; C Walker, Rethinking Law Review Podcasts)
  12. Should I Join Law Prof Amicus Briefs, Write White Papers, Or Do Other Advocacy Work?
  13. Am I Asking the Right Questions? (See Also: M Rich, Hard Prawf Choices)

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May 2, 2016 in Legal Education, Scholarship | Permalink | Comments (0)

Sunday, May 1, 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:

  1. [790 Downloads]  Lexisnexis® Guide to FATCA Compliance: Chapter 1, by Willliam Byrnes (Texas A&M) & Robert J. Munro (Texas A&M)
  2. [327 Downloads]  Ownership of the Means of Production, by E. Glen Weyl (Chicago) & Anthony Lee Zhang (Stanford)
  3. [299 Downloads]  The Law of the Platform, by Orly Lobel (San Diego)
  4. [267 Downloads]  Taxing Wealth Seriously, by Edward J. McCaffery (USC)
  5. [243 Downloads]  The Panama Papers and Tax Morality, by Usman W. Chohan (University of New South Wales)

May 1, 2016 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Saturday, April 30, 2016

University Of Minnesota Study:  Enhanced Individualized Feedback In One Core 1L Class Improves Student Performance In All Of Their Other Classes

Daniel Schwarcz (Minnesota) & Dion Farganis (Minnesota), The Impact of Individualized Feedback on Law Student Performance:

For well over a century, first-year law students have typically not received any individualized feedback in their core "doctrinal" classes other than their final exam grades. Although this pedagogical model has long been assailed by critics, remarkably limited empirical evidence exists regarding the extent to which enhanced feedback improves law students' outcomes. This Article helps fill this gap by focusing on a natural experiment at the University of Minnesota Law School.

The natural experiment arises from the random assignment of first-year law students to sections that take a common slate of classes, only some of which provide individualized feedback. Meanwhile, students in two different sections are occasionally grouped together into a "double section" first-year class. In these double section classes, students in sections that have previously or concurrently had a class providing individualized feedback consistently outperform students in sections that have not received any such feedback. The effect is both statistically significant and hardly trivial in magnitude, approaching about 1/3 of a grade increment even after controlling for students’ LSAT scores, undergraduate GPA, gender, race, and country of birth. The positive impact of feedback also appears to be stronger among lower-performing students.

These findings substantially advance the literature on law school pedagogy, demonstrating that individualized feedback in a single class during the first-year of law school can improve law students' performance in all of their other classes. Against the background of the broader literature on the importance of formative feedback in effective teaching, these findings also have a clear normative implication: law schools should systematically provide first-year law students with individualized feedback in at least one “core” doctrinal first-year class.

Note that the authors (at p.12) "defined individualized feedback to include assigning grades to individual students’ work products, providing individualized written comments to students, or providing individualized or small-group oral feedback to students. By contrast, we did not consider individualized feedback to include instances in which instructors provided students with only a model answer, grading rubric, or generalized oral comments regarding common mistakes."

Larry Solum (Georgetown):

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April 30, 2016 in Legal Education, Scholarship | Permalink | Comments (0)

Lazear:  America’s Coming Tax Increase

Wall Street Journal op-ed:  America’s Coming Tax Increase (data here), by Edward P. Lazear (Stanford):

The debt held by the public has approximately doubled since President Obama took office and is now equal to 74% of gross domestic product. It is true that with the right policy mix, economic growth—stuck at just over 2% during the Obama “recovery”—will help close federal deficits and pay down the debt. At the end of World War II, for example, the debt-to-GDP ratio was at 104% and shrank to a low of 23% by 1974. But letting growth or future belt-tightening close the gap is the exception, not the rule. More often, higher taxes are the result.

Chart 1

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April 30, 2016 in Scholarship, Tax | Permalink | Comments (9)

Friday, April 29, 2016

Marian Presents The State Administration Of International Tax Avoidance Today At City University London

Marian (2016)Omri Marian (UC-Irvine) presents The State Administration of International Tax Avoidance, 7 Harv. Bus. L. Rev. ___ (2016), at a Discussion Workshop on Corruption and the Role of Tax Havens at City University London:

This Article documents a process in which a national tax administration in one jurisdiction, is consciously and systematically assisting taxpayers to avoid taxes in other jurisdictions. The aiding tax administration collects a small amount tax from the aided taxpayers. Such tax is functionally structured as a fee paid for government-provided tax avoidance services. Such behavior can be easily copied (and probably is copied) by other tax administrations. The implications are profound. On the normative front, the findings should fundamentally change our understanding of the concept of international tax competition. Tax competition is generally understood to be the adoption of low tax rates in order to attract investments into the jurisdiction. Instead, this Article identifies an intentional “bagger thy neighbor” behavior, aimed at attracting revenue generated by successful investments in other jurisdictions, without attracting actual investments. The result is a distorted competitive environment, in which revenue is denied from jurisdictions the infrastructure and workforce of which support economically productive activity. On the practical front, the findings suggest that internationally coordinated efforts to combat tax avoidance are misaimed. Current efforts are largely aimed at curtailing aggressive taxpayer behavior. Instead, the Article proposes that the focus of such efforts should be curtailing certain rogue practices adopted by national tax administrations.

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April 29, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Weekly SSRN Tax Roundup

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April 29, 2016 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Weekly Student Tax Note Roundup

SSRN Tax Professor Rankings

SSRN LogoSSRN has updated its monthly rankings of 750 American and international law school faculties and 3,000 law professors by (among other things) the number of paper downloads from the SSRN database.  Here is the new list (through April 1, 2016) 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.)

55,096

Reuven Avi-Yonah (Mich)

10,291

2

Michael Simkovic (S. Hall)

31,513

Michael Simkovic (S. Hall)

4590

3

Paul Caron (Pepperdine)

30,679

D. Dharmapala (Chicago)

3936

4

D. Dharmapala (Chicago)

26,229

Paul Caron (Pepperdine)

2316

5

Louis Kaplow (Harvard)

25,639

Richard Ainsworth (BU)

2218

6

Vic Fleischer (San Diego)

22,198

Jeff Kwall (Loyola-Chicago)

1892

7

James Hines (Michigan)

21,571

Robert Sitkoff (Harvard)

1863

8

Richard Kaplan (Illinois)

20,893

Nancy McLaughlin (Utah)

1737

9

Ted Seto (Loyola-L.A.)

20,843

Louis Kaplow (Harvard)

1737

10

Ed Kleinbard (USC)

19,617

David Weisbach (Chicago)

1635

11

Katie Pratt (Loyola-L.A.)

18,629

Jack Manhire (Texas A&M)

1622

12

Richard Ainsworth (BU)

17,517

Ed Kleinbard (USC)

1608

13

Carter Bishop (Suffolk)

16,821

Chris Hoyt (UMKC)

1605

14

Robert Sitkoff (Harvard)

16,772

Brad Borden (Brooklyn)

1586

15

Brad Borden (Brooklyn)

16,688

Omri Marian (UC-Irvine)

1580

16

David Weisbach (Chicago)

16,656

Dan Shaviro (NYU)

1549

17

Jen Kowal (Loyola-L.A.)

16,399

Vic Fleischer (San Diego)

1496

18

Chris Sanchirico (Penn)

16,270

Katie Pratt (Loyola-L.A.)

1405

19

Dennis Ventry (UC-Davis)

15,925

Steven Bank (UCLA)

1384

20

Francine Lipman (UNLV)

15,720

Richard Kaplan (Illinois)

1377

21

Bridget Crawford (Pace)

15,399

Gregg Polsky (N. Carolina)

1344

22

David Walker (BU)

14,917

Yariv Brauner (Florida)

1331

23

Dan Shaviro (NYU)

14,568

Chris Sanchirico (Penn)

1297

24

Steven Bank (UCLA)

13,194

William Byrnes  (Texas A&M)

1236

25

Herwig Schlunk (Vanderbilt)

13,131

Francine Lipman (UNLV)

1209

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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April 29, 2016 in Legal Education, Scholarship, Tax, Tax Prof Rankings | Permalink | Comments (0)

Call For Papers:  University Of Washington Symposium On Protecting Taxpayer Rights

University of Washington Logo (2016)The University of Washington’s Graduate Tax Program has issued a call for papers for its Fourth Annual Tax Symposium on October 7, 2016:

The 2016 Symposium will focus on Protecting Taxpayer Rights and feature keynote remarks by Nina E. Olson, the National Taxpayer Advocate.

Papers should be well developed, but at a stage where they can still benefit from the group’s discussion. Priority will be given to papers that are consistent with the chosen theme. The symposium will include twelve to fifteen papers. Dinner with the keynote speaker will be held on the day of the conference.

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April 29, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (1)

Thursday, April 28, 2016

The Intersection Of EU State Aid And U.S. Tax Deferral

Florida Tax Review  (2015)Romero J.S. Tavares, Bret N. Bogenschneider & Marta Pankiv (Vienna University), The Intersection of EU State Aid and U.S. Tax Deferral: A Spectacle of Fireworks, Smoke, and Mirrors, 21 Fla. Tax Rev. ___ (2017):

The Advance Pricing Agreements or transfer pricing rulings granted to U.S. multinationals by Ireland, the Netherlands, and Luxembourg were principally designed to achieve U.S. tax deferral and not EU tax avoidance. Adverse BEPS effects within the European Union would be immaterial in comparison to the deferral of U.S. tax on residual IP related profits, and would have occurred primarily in countries other than those charged with the granting of unlawful State aid. The Irish, Dutch, and Luxembourgish treasuries have not foregone tax revenues in favor of the U.S. multinationals they allegedly aided, which is a requirement for a finding of prohibited State aid.

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April 28, 2016 in Scholarship, Tax | Permalink | Comments (0)

Wednesday, April 27, 2016

Ventry:  Lawyers As Whistleblowers

Dennis J. Ventry, Jr. (UC-Davis), Stiches for Snitches: Lawyers as Whistleblowers, 50 U.C. Davis L. Rev. ___ (2017):

This Article challenges the prevailing wisdom that ethics rules forbid lawyers from blowing the whistle on a client’s illegal conduct. While a lawyer is not free to disclose confidential information in every jurisdiction for every legal violation, the ethics rules in all jurisdictions permit disclosure of confidential information pertaining to a client’s illegal activities under certain conditions. Proving the lie of the prevailing wisdom, this Article examines a high profile case in the state of New York that ruled a lawyer whistleblower violated the state’s ethics rules by revealing confidential information to stop his employer-client from engaging in a tax fraud of epic proportions. The Article argues that the court undertook a deficient analysis of New York ethics rules pertaining to permissive disclosure of confidential client information. Even if the whistleblower had violated his ethical obligations, the New York False Claims Act (the statute under which he brought his action) expressly protects disclosure of confidential employer information made in furtherance of the statute. In addition to New York’s statutory shield, federal courts across the country have developed a public policy exception safeguarding whistleblowers for disclosing confidential information that detects and exposes an employer’s illegal conduct.

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April 27, 2016 in Scholarship, Tax | Permalink | Comments (0)

Call For Papers:  AALS Program On Philanthrocapitalism

AALS (2017)Call for Papers:  Joint Program of the AALS Sections on Agency, Partnerships LLCs, and Unincorporated Associations & Nonprofit and Philanthropy on LLCs, New Charitable Forms, and the Rise of Philanthrocapitalism:

In December 2015, Facebook founder Mark Zuckerberg and his wife, Dr. Priscilla Chan, pledged their personal fortune—then valued at $45 billion—to the Chan-Zuckerberg Initiative (CZI), a philanthropic effort aimed at “advancing human potential and promoting equality.” But instead of organizing CZI using a traditional charitable structure, the couple organized CZI as a for-profit Delaware LLC. CZI is perhaps the most notable example, but not the only example, of Silicon Valley billionaires exploiting the LLC form to advance philanthropic efforts. But are LLCs and other for-profit business structures compatible with philanthropy? What are the tax, governance, and other policy implications of this new tool of philanthrocapitalism? What happens when LLCs, rather than traditional charitable forms, are used for “philanthropic” purposes?

From the heart of Silicon Valley, the AALS Section on Agency, Partnerships LLCs, and Unincorporated Associations and Section on Nonprofit and Philanthropy Law will host a joint program tackling these timely issues. In addition to featuring invited speakers, we seek speakers (and papers) selected from this call.

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April 27, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Foundation Press Publishes Election Law Stories (36th Book in the Law Stories Series)

Election LawFoundation Press has published Election Law Stories (2016), by Joshua A. Douglas (Kentucky) & Eugene D. Mazo (Rutgers):

One of the most dynamic fields in the legal academy now has its own Stories book. This title offers a rich and detailed account of the most significant cases in election law, including the landmark decisions of Reynolds v. Sims, Bush v. Gore, Citizens United v. Federal Election Commission, and Shelby County v. Holder. The book relies on a unique encapsulated approach to storytelling, as each of its authors surveys an important doctrinal area in the field through the telling of his or her story. The volume’s thirteen cases concern the right to vote, redistricting and gerrymandering, campaign finance, and election administration. The book is suited for courses in the law of democracy at both the graduate and undergraduate levels.

The table of contents is here.  Other titles in the Law Stories Series (for which I serve as Series Editor) are:

April 27, 2016 in Book Club, Legal Education, Scholarship | Permalink | Comments (0)

May 1 Deadline For Call For Papers For 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 27, 2016 in Conferences, Scholarship, Tax | Permalink | Comments (0)

Tuesday, April 26, 2016

Zelenak Presents Tax-Free Basis Step-Up At Death And The Charitable Deduction Of Unrealized Appreciation Today At Georgetown

Zelenak (2016)Lawrence Zelenak (Duke) presents The Tax-Free Basis Step-Up at Death, the Charitable Deduction of Unrealized Appreciation, and the Persistence of Error at Georgetown today as part of its Tax Law and Public Finance Workshop Series hosted by John Brooks and Itai Grinberg:

This article recounts, as a study in the remarkable persistence of early error even when the error is promptly recognized and addressed, the legislative and administrative histories of the taxfree basis step-up at death and the charitable deduction for unrealized appreciation. Part I describes the early development of the basis rules for property transferred by gift or bequest, and Part II covers the early history of the charitable deduction for appreciated property. Parts III and IV are concerned with less ancient events. Part III recounts the short unhappy life of the 1976 carryover basis reform, and Part IV does the same for the 1986 AMT reform. Part V briefly concludes.

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April 26, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (3)

Gravelle Presents Policy Options To Address Corporate Profit Shifting: Carrots Or Sticks? Today At NYU

GravelleJane Gravelle (Congressional Research Service) presents Policy Options to Address Corporate Profit Shifting: Carrots or Sticks? at NYU today as part of its Tax Policy Colloquium Series hosted by Daniel Shaviro and Chris Sanchirico:

Issues surrounding the U.S. tax treatment of foreign source income, focused in large part in the past on real investment, may, to some degree, have given way to concern about tax minimization strategies that allow firms to shift profits into low and no tax countries. Firms can benefit from profit shifting because, although the United States has a worldwide income tax system with a credit for foreign taxes paid, income earned by U.S. multinationals’ foreign subsidiaries is not subject to tax until it is repatriated, that is, paid to the parent firm as a dividend. (Current law requires some income easily subject to abuse, called Subpart F income, to be taxed currently). In addition, firms can shield repatriated profits from low tax countries from U.S. tax if they have excess foreign tax credits from operations in high tax countries. Profit shifting is largely a problem of lost revenue rather than inefficient location of investment, although widespread manipulation of the tax rules to avoid taxes also may undermine voluntary compliance with the tax system by others.

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April 26, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Monday, April 25, 2016

Kahng Presents Who Owns Human Capital? Today At Pepperdine

Kahng (2017)Lily Kahng (Seattle) presents Who Owns Human Capital?, 93 Wash. U. L. Rev. ___ (2017), at Pepperdine today as part of our Tax Policy Workshop Series funded in part by a generous gift from Scott Racine:

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.

Update:  Post-presentation lunch:

Lunch

April 25, 2016 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Shaviro:  The Mapmaker's Dilemma In Evaluating High-End Inequality

Daniel Shaviro (NYU), The Mapmaker's Dilemma in Evaluating High-End Inequality:

The last thirty years have witnessed rising income and wealth concentration among the top 0.1 percent of the population, leading to intense political debate regarding how, if at all, policymakers should respond. Often, this debate emphasizes the tools of public economics, and in particular optimal income taxation. However, while these tools can help us in evaluating the issues raised by high-end inequality, their extreme reductionism – which, in other settings, often offers significant analytic payoffs – here proves to have serious drawbacks. This paper addresses what we do and don’t learn from the optimal income tax literature regarding high-end inequality, and what other inputs might be needed to help one evaluate the relevant issues.

April 25, 2016 in Scholarship, Tax | Permalink | Comments (1)

Sunday, April 24, 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. [746 Downloads]  Lexisnexis® Guide to FATCA Compliance: Chapter 1, by Willliam Byrnes (Texas A&M) & Robert J. Munro (Texas A&M)
  2. [309 Downloads]  Ownership of the Means of Production, by E. Glen Weyl (Chicago) & Anthony Lee Zhang (Stanford)
  3. [281 Downloads]  The Law of the Platform, by Orly Lobel (San Diego)
  4. [259 Downloads]  Taxing Wealth Seriously, by Edward J. McCaffery (USC)
  5. [170 Downloads]  The Panama Papers and Tax Morality, by Usman W. Chohan (University of New South Wales)

April 24, 2016 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

The Accreditation Battle Over Canada's First Christian Law School

Trinity WesternFollowing up on my previous posts (links below):  Richard Moon (University of Windsor), The Accreditation of Trinity Western University's Law Program:

There is a debate at the moment about whether the law societies (which regulate the legal profession in the various provinces) must accredit a law program to be offered by Trinity Western University [TWU], a private Evangelical Christian college. The Law Society of Upper Canada [LSUC], along with the law societies of British Columbia and Nova Scotia, refused to the accredit the proposed program because of the school’s discriminatory admissions policy and in particular the covenant that all students are required to sign, in which they agree, among other things, not to engage in sex outside of marriage and sex with a same-sex partner. The issue in the TWU accreditation case is whether the covenant is simply an internal matter (a rule that applies simply to the internal operations of a voluntary religious association) or whether it impacts outsiders to the religious community or the public interest, more generally. As I understand it, the law societies are not claiming that the members of a religious community need to be protected from oppressive or discriminatory internal rules. There are two ways in which it may be argued that the TWU program (and the covenant in particular) will have an impact on the public interest.

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April 24, 2016 in Legal Education, Scholarship | Permalink | Comments (1)

Friday, April 22, 2016

Weekly SSRN Tax Roundup

Weekly Student Tax Note Roundup

Smith:  The PACT Act And The Constitutionality Of The Marketplace Fairness Act

Florida Tax Review  (2015)Eric Smith (Weber State), The PACT Act as Indicium of the Due Process Validity of the Marketplace Fairness Act, 19 Fla. Tax Rev. ___ (2016):

If passed into law, the Marketplace Fairness Act would impose a federal duty on out-of-state sellers to collect a state-defined and state-benefitting use tax. This unique exercise of federal power implicates due process. The PACT Act represents the only other instance in which Congress has similarly compelled state law compliance. Two circuit courts of appeals have found the PACT Act vulnerable on concerns of due process. This Article relies on the PACT Act analogue to simulate how the Marketplace Fairness Act would fare under similar scrutiny. To this end and in this uncommon context, two novel constitutional questions are considered: 1) with which sovereign, the federal government or the state, are minimum contacts measured; and 2) if measured with the state, is a single sale sufficient to meet due process thresholds?

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April 22, 2016 in Scholarship, Tax | Permalink | Comments (0)

Thursday, April 21, 2016

Delaney Thomas Reviews Weeks McCormack's The Childcare Tax Squeeze

Jotwell (Tax) (2016)Kathleen DeLaney Thomas (North Carolina), It's Time to Revisit the Tax Treatment of Working Childcare Costs (reviewing Shannon Weeks McCormack (University of Washington), Over-Taxing the Working Family: Uncle Sam and the Childcare Squeeze, 114 Mich. L. Rev. 559 (2015)):

Childcare costs have soared in recent years while wages remain stagnant. To make matters worse, relief by provided by the tax code is extremely limited. Parents may be able to claim a tax credit for a portion of their childcare costs and may be able to divert limited funds to a pretax flexible spending account. But in many cases, these tax benefits capture only a minor portion of parents’ costs. It is no surprise, then, that with an election year upon us, a number of proposals to expand the current childcare tax credit have resurfaced in recent months. These proposals echo years of debate over whether the tax system discourages work by secondary earners and treats working parents unfairly vis-à-vis their non-parent counterparts.

But current proposals to modestly expand the childcare credit will make only a small dent in working parents’ childcare costs. Recognizing the inadequacy of such an approach, Shannon Weeks McCormack proposes a more fundamental reform in her forthcoming article, Over-Taxing the Working Family: Uncle Sam and the Childcare Squeeze. The childcare tax credit, she argues, should be replaced with an above-the-line deduction for childcare expenses that is not subject to phase-outs or dollar limitations. In essence, Weeks McCormack calls for according childcare expenses the same treatment as deductible trade or business expenses.

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April 21, 2016 in Scholarship, Tax | Permalink | Comments (0)

Gergen:  How To Tax Capital

Mark P. Gergen (UC-Berkeley), How to Tax Capital, 69 Tax L. Rev. ___ (2016):

This paper proposes a new system for taxing capital that can collect the same amount of revenue as the existing system with much lower administrative and compliance costs, and with somewhat lower distortionary impact. Its pillar is a flat annual tax assessed on the market value of publicly traded securities paid by an issuer. Wealth represented by a string of publicly traded securities is taxed once by giving an issuer a credit for amounts remitted with respect to publicly traded securities it owns. The securities tax will cover around 75 to 80 percent of income producing capital that is presently subject to the individual and corporate income taxes.

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April 21, 2016 in Scholarship, Tax | Permalink | Comments (0)

Wells:  International Tax Reform By Means Of Corporate Integration

Florida Tax Review  (2015)Bret Wells (Houston), International Tax Reform By Means of Corporate Integration, 19 Fla. Tax Rev. ___ (2016):

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

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April 21, 2016 in Scholarship, Tax | Permalink | Comments (0)