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Friday, May 15, 2015

The IRS Scandal, Day 736

IRS Logo 2Fox News, House Members Push for IRS Clinton Probe:

Rep. Marsha Blackburn, R-Tenn., is circulating a letter among her colleagues asking IRS Commissioner John Koskinen to review the tax-exempt status of the Clinton Foundation. In the letter, a draft of which was obtained by Chief Congressional Correspondent Mike Emanuel, Blackburn says, “recent media reports have revealed that the Foundation failed to report millions of dollars in grants from foreign governments that it accepted while Hillary Clinton was Secretary of State and that it facilitated private business transactions between foreign entities” and as such, “given the substantial public interest involved, we feel a prompt review of the Foundation’s tax-exempt status is appropriate to determine whether it is acting within the scope of its charitable mission.”

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May 15, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (1)

Thursday, May 14, 2015

Galle: Law and the Problem of Restricted-Spending Philanthropy

Brian Galle (Boston College), Pay It Forward? Law and the Problem of Restricted-Spending Philanthropy, 92 Wash. U.L. Rev. ___ (2016):

American foundations and other philanthropic giving entities hold about $1 trillion in investment assets, and that figure continues to grow every year. Even as urgent contemporary needs go unmet, philanthropic organizations spend only a tiny fraction of their wealth each year, mostly due to restrictive terms in contracts between donors and firms limiting the rate at which donations can be distributed. Law has played a critical role in underwriting and encouraging this build-up of philanthropic wealth. For instance, contributors can typically take a full tax deduction for the value of their contribution today, no matter when the foundation spends their money, and pay no tax on the investment earnings the organization reaps in the meantime.

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May 14, 2015 in Scholarship, Tax | Permalink | Comments (0)

Givati: Economic Theory And The Taxation of Fringe Benefits

Yehonatan Givati (Hebrew University of Jerusalem, Faculty of Law), Googling a Free Lunch: The Taxation of Fringe Benefits, 68 Tax L. Rev. ___ (2015):

How should fringe benefits be taxed? Though fringe benefits are covered in every basic law school course on federal income taxation, no widely accepted economic framework has developed for thinking about their taxation. As a result, policymakers lack a clear picture of the benefits and costs of alternative tax regimes, when faced with situations such as the free luxurious meals provided by Google and Facebook to their employees. This Article fills this gap in the literature, by developing an economic theory of the provision of fringe benefits.

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May 14, 2015 in Scholarship, Tax | Permalink | Comments (1)

Dan Halperin To Retire From Harvard Law School Faculty

HalperinHarvard Law Today:  Legacies of Selfless Scholarship: Undisguised Value, by Alvin C. Warren Jr. (Harvard):

Daniel I. Halperin ’61 will retire at the end of this academic year after more than a half-century as a tax lawyer, professor and government official. Unlike most law professors starting out today, Dan worked as a lawyer for a decade—at the firm Kaye Scholer and in the government—before entering law teaching. Serendipitously, he became Kaye Scholer’s expert in the new field of pension law in his second year, after the sudden departure of the only lawyer at the firm with any experience in the field.

In 1996, Dan was appointed the first Stanley S. Surrey Professor of Law at Harvard Law School. Over the past 19 years, he has continued to write about tax law and policy, and has taught a variety of tax-related courses, covering income taxation, tax policy, pension law, and nonprofit organizations.

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May 14, 2015 in Legal Education, Tax | Permalink | Comments (0)

Senator Hatch Blasts IRS For Retaining Law Firm To Go After Microsoft

Microsoft (2015)Wall Street Journal, Top Republican Sides With Microsoft in IRS Offshore-Profits Scuffle:

A top Republican lawmaker is siding with Microsoft Corp. in its legal scuffle with the Internal Revenue Service involving profits the firm has parked offshore.

In a letter on Wednesday, Finance Committee Chairman Orrin Hatch (R., Utah) questioned the IRS’s unusual decision last year to hire a private law firm to help it go after the high-tech giant.

“The IRS’s hiring of a private contractor to conduct an examination of a taxpayer raises concerns because the action: 1) appears to violate federal law and the express will of the Congress; 2) removes taxpayer protections … and 3) calls into question the IRS’s use of its limited resources,” Mr. Hatch wrote in the letter to IRS Commissioner John Koskinen.

The lawmaker asked the agency to stop using the contractor and also to explain its actions to the committee.

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May 14, 2015 in IRS News, Tax | Permalink | Comments (0)

NTA 45th Annual Spring Symposium: The 20th Century Tax Code In A 21st Century World

The 45th Annual Spring Symposium on The 20th Century Tax Code in a 21st Century World: Where Are the Pressure Points? by the National Tax Association and American Tax Institute kicks off today in Washington, D.C.

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May 14, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

The IRS Scandal, Day 735

IRS Logo 2Forbes, California Attorney General Can Demand Full IRS Forms From Charity, by Peter J. Reilly:

The Ninth Circuit’s decision in the case of the Center For Competetive Politics v Kamal D. Haris (Attorney General of California) is almost two weeks old and has been covered in other places, so I almost invoked my “You snooze, you lose” rule against myself, but I think I may have something to add. It concerns a fairly obscure issue, but the case does have a loose connection to the interminable IRS scandal (On Day 733 by TaxProf count as I write this).

The Center For Competetive Politics according to its 2013 Form 990 is dedicated to the “Preservation of the First Amendment rights to free political speech, assembly, and petition”. The appointment of the Center’s Chairman, Bradley A. Smith, to the Federal Election Commission was controversial given his vigorous opposition to campaign finance regulation. I guess it kind of looked like putting Daniel Berrigan on the Joint Chiefs of Staff or having Irwin Schiff head up the IRS. The Center received over $1.7 million in contributions and grants in 2013. 

As a 501(c)(3) organization CCP has to tell the IRS who its major donors are. This is done with Schedule B which is attached to the Form 990. Schedule B is not subject to public inspection, so you don’t get to see it on guidestar.org. Many states require charities to attach Form 990 to state filings. The instruction to Form 990 caution charities about not including the schedule of contributors in filings with states that do not ask for it, since they might inadvertently make the donor information publically available. 

It appears that CCP relies very much on a few large donors. The 2013 Form 990 on guidestar.org does not even include a redacted Schedule B, but if you go to the California Attorney General site, there is a Form 990 including a redacted Schedule B for 2011 that shows that of the $1.8 million raised in 2011 over $500,000 came from a single donor. Over $800,000 came from just seven donors who gave between $85,000 and $211,250.

The IRS knows who those seven donors are, but they are not going to tell us. The California Attorney General would also like to know who those donors are, without making them public. So the AG is requiring that CCP provided an unredacted copy of Schedule B. CCP does not want to do that . The Ninth Circuit just told them that they have to.

There were two arguments that CCP made. The first was that the disclosure requirement is injurious to the Center and its supporters’ exercise of their First Amendment rights. They referred to a “chilling risk”. So you feel OK giving money to CCP even thought Lois Lerner’s minions know who you are, but you draw the line when it comes to the California AG. The Court indicated that that sort of concern was subject to “exacting scrutiny” under which the government’s interest in obtainging the information must be weighed against actual damage to First Amendment rights. ...

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May 14, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (2)

Wednesday, May 13, 2015

Columbia Journal of Tax Law Publishes New Issue

Columbia Journal of Tax Law LogoThe Columbia Journal of Tax Law has published  Vol. 6, No. 2:

May 13, 2015 in Scholarship, Tax | Permalink | Comments (0)

FATCA: An American Tax Nightmare

FATCANew York Times op-ed:  An American Tax Nightmare, by Stu Haugen:

No one likes tax cheats. They should be pursued and punished wherever they are hiding. But recent efforts by the United States Congress to capture tax revenues on unreported revenues and assets held in foreign accounts are having disastrous effects on a growing number of Americans living abroad.

The Foreign Account Tax Compliance Act, or Fatca, signed into law in March 2010 but only now coming into full effect, has been a bipartisan lesson in the law of unintended consequences. Pressure is growing to halt its pernicious impact.

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May 13, 2015 in Tax | Permalink | Comments (2)

Talk Of Ryan-Obama Tax Deal Roils Republican-Business Alliance

Bloomberg, Talk of Ryan-Obama Tax Deal Roils Republican-Business Alliance:

The “job creators” are fighting back on tax policy—against their Republican allies.

Small-business groups that have been among the Republicans’ loyal backers are warning their friends in Congress against cutting a deal with President Barack Obama on lowering corporate taxes.

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May 13, 2015 in Tax | Permalink | Comments (0)

Tax Brackets Aren't The Key To Simplifying The Tax Code

Bloomberg, Why Tax Brackets Aren't the Key to Simplifying the Tax Code, by Richard Rubin:

BracketsIn the TurboTax era, simplifying the tax code has almost nothing to do with the number of tax brackets.

You wouldn't know that from listening to Republican presidential hopefuls, who are touting their plans based in part on how aggressively they tear up today's seven-bracket income tax structure for individuals.

Chris Christie said Tuesday that he wants three brackets. Marco Rubio says two. Ben Carson is going for the one-bracket flat tax. And Mike Huckabee, a longtime backer of a national retail sales tax, wants no income tax brackets at all.

Here's the reality: Computers do most of the work now, so whether there is one bracket or seven makes virtually no difference to the average taxpayer. No one has to do painful algebra or squint at tables full of numbers.

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May 13, 2015 in Tax | Permalink | Comments (6)

The IRS Scandal, Day 734

IRS Logo 2Forbes, IRS Not Grossly Negligent In Disclosure Of Exempt Application, by Peter J. Reilly:

The order from the United States District Court of Colorado in the ongoing lawsuit Citizens Awareness Project Inc versus Internal Revenue Service is giving me flashbacks.  The case relates to one of the aspects of the perennial, interminable IRS scandal, on Day 732 by TaxProf count as I write this. The lawsuit is in reaction to the improper release of tax-exempt applications to ProPublica.  That story showed up on Day 5 (May 14, 2013) as ProPublica joined in piling on the IRS with a story titled IRS Office That Targeted Tea Party Also Disclosed Confidential Docs From Conservative Groups.  The story actually went back to December 2012. ...

As I looked into the background a bit, it struck me that Citizens Awareness Project could well be a great example of what was upsetting Lois Lerner so much – i.e. dark money using 501(c)(4) to game campaign financing disclosure.

The IRS is not contesting that it screwed up when it released a copy of CAP’s Form 1024.  ProPublica had requested the applications of 67 organizations.  They were organizations that had reported substantial expenditures to the FEC.  On October 16, 2012 CAP reported paying Stephen Clouse & Associates  $993,916.79 for printing, production and postage in opposition to Barrack Obama. The expenditure caught a little coverage with this piece titled Mystery group spends $1 million opposing Obama. ...

The IRS admitted that it was wrong to have released CAP’s 1024 that was still in process, so presumably, it would have cut the organization a check for a grand without a lawsuit.  If the actual damages don’t break $1,000, then presumably CAP does not get to recover the costs of the action, which I suspect are a bit more than the potential claim for actual damages of $4,819.78 that the Court still sees as being in play. ...

Sophia Brown was the IRS employee charged with responding to ProPublica’s request.  Apparently she failed to check whether CAP’s Form 1024 had been ruled on yet.  Since it had not been ruled on, it should not have been released. The Court did not see any gross negligence here.

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May 13, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (1)

Tuesday, May 12, 2015

OECD: Raising Alcohol Tax 10% Would Boost GDP By 1%

OECD Logo (2015)Wall Street Journal, Raise Alcohol Tax to Boost Economic Output, Says OECD:

A tax increase that would raise alcohol prices by 10% is among the most effective means of countering excessive consumption, which reduces economic output in most developed countries and contributes to early death and disability, the Organization for Economic Cooperation and Development said on Tuesday.

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May 12, 2015 in Tax | Permalink | Comments (2)

Is The Apple Watch Tax Deductible?

Apple WatchFollowing up on my previous post, Practicing Law With Your Apple Watch:  Entrepreneur, Is The Apple Watch Tax Deductible?:

I know many of you die-hard Apple fans have already been to an Apple Store and tried on the new watch. Others of you have probably seen the ads and wondered if -- or rather how -- this new device will truly change your life for the better.

So wouldn’t it be nice if the Apple Watch was also deductible as a business expense? It should be, right? You need it in your business in order to be more effective and efficient as a communication tool and the IRS should see it our way…well…maybe hold the phone for a moment.

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May 12, 2015 in Tax | Permalink | Comments (1)

IRS-Affiliated Site For Charities Hit By Data Breach

Accounting Today, IRS-Affiliated Site for Charities Hit by Data Breach:

A site that is used to process tax forms for nonprofit organizations on behalf of the Internal Revenue Service recently suffered a data breach.

The site is operated by the Urban Institute’s National Center for Charitable Statistics, or NCCS. The group announced in February it had recently discovered that an unauthorized party or parties gained access to the Form 990 Online and e-Postcard filing systems for nonprofit organizations.

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May 12, 2015 in IRS News, Tax | Permalink | Comments (0)

The IRS Scandal, Day 733

IRS Logo 2Power Line, Corruption from the IRS to the DOJ:

The pro-Israel group Z Street had its application for tax-exempt status held up at the IRS. When founder Lori Lowenthal Marcus asked why, she was told that IRS auditors had been instructed to give pro-Israel groups special attention and that Z Street’s application had been forwarded to a special IRS unit for additional review. Not to put too fine a point on the legal issues, this isn’t kosher. It’s illegal.

Z Street filed a lawsuit against the IRS in the rosy dawn of the Age of Obama; the lawsuit has yet to get beyond the IRS’s motion for dismissal. The Free Beacon’s Alana Goodman wrote about the lawsuit here last year when the DC District Court denied the IRS motion to dismiss the case. Z Street’s Lori Marcus wrote about it here. John wrote about it in 2013 in the post The Other IRS Scandal.

The legal positions asserted by the IRS are ludicrous. Indeed, they are a pretext to precluded discovery until the chief malefactors serving at the pleasure of President Obama have moved on. It is a sidebar to the political corruption of the IRS that remains one of the great untold stories of the Age of Obama. (Sharyl Attkisson doesn’t cover the IRS scandal, but to understand the Obama playbook for handling it, as I explain in The Attkisson file.)

The IRS appealed the denial of its motion to dismiss to the DC Circuit Court of Appeals. Last week a panel of three DC Circuit judges heard the IRS appeal. The hearing did not go well for the IRS. Indeed, it was an exercise in righteous humiliation of the Department of Justice. The DoJ has asserted ludicrous defenses to gum up the lawsuit and preclude discovery. ...

The Wall Street Journal takes a look at the hearing before the DC Circuit in the reported editorial The IRS Goes to Court.

The Journal editorial concludes:

Poor Ms. McLaughlin was sent to argue the indefensible so the IRS can delay discovery until the waning days of the Obama Administration. “If I were you, I would go back and ask your superiors whether they want us to represent that the government’s position in this case is that the government is free to unconstitutionally discriminate against its citizens for 270 days,” said Judge Garland.

Ms. McLaughlin replied, “Well, I will take that back.” The Beltway media may be bored, but the IRS scandal is a long way from over.

Judge Garland’s query seeks to send a message to higher powers at the Department of Justice. The IRS scandal is a long way from over, and, as one can see here, it extends well beyond the IRS. It would be nice if someone outside the walls of the Wall Street Journal took notice.

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May 12, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (1)

Monday, May 11, 2015

Karen Hawkins To Step Down As Director Of IRS Office Of Professional Responsibility

Hawkins 3Karen Hawkins, Director of the IRS Office of Professional Responsibility for the past six years, has announced that she is stepping down on July 11:

Director’s Farewell Message to Tax Professionals
After 48 continuous years in various professional capacities, thirty-six in the practice of law, the last six as Director of the Office of Professional Responsibility, I have decided to take a little “holiday”. My retirement resignation has been tendered to, and accepted by, Commissioner Koskinen, and we have agreed that my last day as an IRS employee will be July 11, 2015.

When Commissioner Shulman asked me to assume the position of Director, OPR, we shared a vision and multiple goals. The vision was to bring reasonable but firm oversight to the unregulated return preparer industry to ensure tax return preparers were both competent and scrupulous in their dealings with the nation’s taxpayers and with the tax administration system. The goals were to enhance the credibility, visibility and stature of the Office of Professional Responsibility and Circular 230 at all levels of professional tax practice.

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May 11, 2015 in IRS News, Tax | Permalink | Comments (1)

NY Times: Legal Marijuana Faces Another Federal Hurdle: Taxes

Marijuana (2015)New York Times, Legal Marijuana Faces Another Federal Hurdle: Taxes:

The country’s rapidly growing marijuana industry has a tax problem. Even as more states embrace legal marijuana, shops say they are being forced to pay crippling federal income taxes because of a decades-old law aimed at preventing drug dealers from claiming their smuggling costs and couriers as business expenses on their tax returns.

Congress passed that law in 1982 after a cocaine and methamphetamine dealer in Minneapolis who had been jailed on drug charges went to tax court to argue that the money he spent on travel, phone calls, packaging and even a small scale should be considered tax write-offs. The provision, still enforced by the I.R.S., bans all tax credits and deductions from “the illegal trafficking in drugs.”

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May 11, 2015 in Tax | Permalink | Comments (0)

Manhire: A Government Perspective On Voluntary Tax Compliance

J. T. Manhire (U.S. Treasury Department), What Does Voluntary Tax Compliance Mean?: A Government Perspective, 164 U. Pa. L. Rev. Online ___ (2015):

One of the IRS’s principle goals is to maximize voluntary compliance. Yet, there is often a great deal of confusion and consternation when taxpayers discover that the IRS refers to the annual filing and payment ritual as “voluntary;” especially since most taxpayers do not believe they have a choice when it comes to filing and paying their taxes. What does voluntary compliance mean? Does it mean taxpayers can volunteer to file returns and pay taxes, much as one might volunteer to make a charitable donation? Does it mean taxpayers don’t have to comply with the tax laws if they don’t feel like it? How can it be a federal crime to not file or pay taxes if compliance is voluntary? This essay offers a government perspective as to why the IRS uses this sometimes perplexing term. After investigating (and dismissing) a possible literal defense, the essay surveys the IRS’s history to see why voluntary compliance is such a critical part of the U.S. tax system. The essay then recommends changing the term from voluntary to cooperative compliance to retain the government’s meaning while lessening taxpayer confusion.

May 11, 2015 in IRS News, Scholarship, Tax | Permalink | Comments (0)

Kahng: The Taxation of Women in Same-Sex Marriages

Lily Kahng (Seattle), The Not-So-Merry Wives of Windsor: The Taxation of Women in Same-Sex Marriages, 101 Cornell L. Rev. __ (2015):

In United States v. Windsor, the Supreme Court invalidated the Defense of Marriage Act definition of marriage as “between one man and one woman” and is now poised to recognize a constitutional right to same-sex marriage. Windsor cleared the way for same-sex couples to be treated as married under federal tax laws, and the Obama administration promptly announced that it would recognize same-sex marriages for tax purposes. Academics, policymakers, and activists lauded these developments as finally achieving tax equality between gay and straight married couples. This Article argues that the claimed tax equality of Windsor is illusory and that the only way to achieve actual equality is to eliminate taxation on the basis of marital status.

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May 11, 2015 in Scholarship, Tax | Permalink | Comments (0)

The IRS Scandal, Day 732

IRS Logo 2The Hill, Two Years Later, IRS Probes Drag On:

Exactly two years after the IRS first admitted improperly scrutinizing Tea Party groups, congressional investigations into the tax agency show no sign of drawing to a close anytime soon.

Congressional Republicans say they are deeply irritated that they haven’t finished off the investigations launched after Lois Lerner apologized for the IRS on May 10, 2013, and insist that President Obama’s Justice Department has stonewalled their efforts.

Top lawmakers like Senate Finance Chairman Orrin Hatch (R-Utah) note that they’ve only just received thousands of emails to and from Lerner that the IRS said were unrecoverable close to a year ago.

Hatch recently said he hoped a bipartisan Finance report, which members once thought could be released more than a year ago, could come out by the end of June. But congressional investigators maintain that they'll need to make sure they have a fuller accounting of Lerner's email trail before any reports are circulated.

Asked about the repeated delays, Hatch said simply: “Every time we turn around we get more emails.”

Congressional committees have received about 5,000 of the roughly 6,400 newly recovered Lerner emails they expect from Treasury’s inspector general for tax administration, a GOP aide said Friday. The aide said that there appears to be little new in the emails, and that the inspector general is expected to issue a broader report on the emails in the coming weeks.

Hatch is far from the only GOP lawmakers fuming about the status of the IRS investigation.

“That’s so egregious, for the tax collection agency of the United States to be in that kind of shape,” said Sen. Pat Roberts (R-Kan.). “They have nobody to blame but themselves. I’d just like to see some accountability, you know?”

But even some Republicans acknowledge that the IRS controversy wasn’t quite the slam dunk case they thought it was two years ago, and House Republicans at least have seemed to put more emphasis on their investigation into the Benghazi attacks over the last year.

Still, Republicans aren't the only group frustrated by the IRS investigations – underscoring that the partisan divisions marking the inquiries aren’t going away, and that controversy will linger long after any reports are issued.

Tea Party groups say some organizations are still facing delays from the IRS, and that they believe Lerner and other agency officials are getting off easy.

“It's clear the IRS would like this scandal to disappear,” Jordan Sekulow, whose American Center for Law and Justice represents dozens of groups challenging the IRS in court, said recently.

Congressional Democrats, though, say that two years’ worth of investigations, costing millions of taxpayer dollars, have found what they long suspected – that the IRS’s scrutiny of Tea Party groups was caused not by political bias, but by bureaucratic mismanagement. ...

And while Republicans don’t want to speculate on when their IRS efforts might come to a close, Roskam dropped some hints that their interest in both the agency and Lerner won’t fade anytime soon.

“The statute of limitations doesn’t lapse until after the new administration comes in, so you could very easily see a newly constituted Justice Department having a new attitude about Lerner,” Roskam said.

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May 11, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (1)

TaxProf Blog Weekend Roundup

Sunday, May 10, 2015

The Top 5 Tax Paper Downloads

SSRN LogoThere is quite a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with a new #1 paper and new papers debuting on the list at #4 and #5:

  1. [215 Downloads]  The Historical Origins of the Debt-Equity Distinction, by Camden Hutchison (Wisconsin)
  2. [213 Downloads]  Using the 'Smart Return' to Reduce Tax Evasion, by Joseph Bankman (Stanford), Clifford Nass (Stanford) & Joel Slemrod (Michigan)
  3. [179 Downloads]  Scholarship Against Desire, by Shari Motro (Richmond)
  4. [129 Downloads]  Tax Compliance as a Wicked System, by J. T. Manhire (U.S Treasury Department)
  5. [121 Downloads]  Tax Account Misstatements and the PCAOB's Restrictions on Auditors’ Tax Services, by Clive Lennox (Nanyang Technological University)

May 10, 2015 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

Tacha: Just Mom

Tacha 4TaxProf Blog op-ed:  Just Mom, by Deanell Tacha (Dean, Pepperdine):

As I drove down the street recently, I jerked to attention when I noticed the vanity license plate on the car in front of me. It said simply "Just Mom". My lifelong fascination with the written word went into high gear. I wondered what message the woman driving could be hoping to convey. Those two words carried all the ambiguities that have haunted my generation of mothers. One possible interpretation is that of the boasting stay-at-home Mom who somehow managed to inoculate those of us who chose not to be "just Mom" with a healthy dose of guilt and questioning about what mortal deprivations we had visited upon our children by making the choice to combine motherhood with other professional and economic endeavors. Another possible interpretation is the counterposition. It is the mother who deprecates her other talents, interests, and aspirations by an apologetic admission that she resigns herself to being "just Mom". Neither of these opposing messages resonates with me. The first denigrates and belittles women who have combined motherhood with other occupations. The second diminishes the rich array of talents beyond those required to be a mother that an individual woman possesses. I reject both interpretations.

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May 10, 2015 in Legal Education, Tax | Permalink | Comments (5)

The IRS Scandal, Day 731

IRS Logo 2National Review, America’s Politicized Tax Enforcement Is a Harbinger of Decline, by Victor Davis Hanson (Stanford University, Hoover Institution):

Why did Rome and Byzantium fall apart after centuries of success? What causes civilizations to collapse, from a dysfunctional fourth-century-B.C. Athens to contemporary bankrupt Greece?

The answer is usually not enemies at the gates, but the pathologies inside them.

What ruins societies is well known: too much consumption and not enough production, a debased currency, and endemic corruption.

Americans currently deal with all those symptoms. But two more fundamental causes for decline are even more frightening: an unwillingness to pay taxes and the end of the rule of law. ...

The Clinton Foundation is expected to refile its tax returns for 2010, 2011, and 2012 after failing to separate government grants from donations. If an average citizen tried to amend his taxes for such huge sums and from that long ago, he would probably be under indictment. News reports of undocumented donations from foreign governments caught the foundation underreporting its income. The well-connected Clinton clan apparently had assumed that their political status ensured them immunity. ...

Who will police the tax police?

Former IRS official Lois Lerner and her subordinates were found to have targeted conservative nonprofit groups for excessive federal scrutiny. While testifying before Congress, Lerner invoked her Fifth Amendment right against self-incrimination, and investigators later found that two years of her e-mails had gone missing in a mysterious computer crash. Lerner has not been charged. ...

Our laws are becoming as politicized as our tax system. ...  In the last six years, the enforcement of federal laws has depended on their apparent political utility.  ... Increasingly in the United States, the degree to which a law is enforced — or whether a person is indicted — depends on political considerations. But when citizens do not pay any income taxes, or choose not to pay taxes that they owe and expect impunity, a complex society unwinds.

And when the law has becomes negotiable, civilization utterly collapses.

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May 10, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (1)

Saturday, May 9, 2015

Why Some Men Pretend To Work 80-Hour Weeks

80 HourNew York Times, How Some Men Fake an 80-Hour Workweek, and Why It Matters, by Neil Irwin:

Imagine an elite professional services firm with a high-performing, workaholic culture. Everyone is expected to turn on a dime to serve a client, travel at a moment’s notice, and be available pretty much every evening and weekend. It can make for a grueling work life, but at the highest levels of accounting, law, investment banking and consulting firms, it is just the way things are.

Except for one dirty little secret: Some of the people ostensibly turning in those 80- or 90-hour workweeks, particularly men, may just be faking it.

Many of them were, at least, at one elite consulting firm studied by Erin Reid, a professor at Boston University’s Questrom School of Business. It’s impossible to know if what she learned at that unidentified consulting firm applies across the world of work more broadly. But her research, published in the academic journal Organization Science [Embracing, Passing, Revealing, and the Ideal Worker Image: How People Navigate Expected and Experienced Professional Identities], offers a way to understand how the professional world differs between men and women, and some of the ways a hard-charging culture that emphasizes long hours above all can make some companies worse off.

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May 9, 2015 in Legal Education, Tax | Permalink | Comments (0)

WSJ: How To Vet A Charity

Wall Street Journal, How To Vet A Charity:

Do you scrutinize your charities the way you do your stocks or mutual funds? You should. ...

The good news for careful givers is that in return for their tax-free status, nonprofit groups other than churches typically must make extensive public disclosures about their finances and governance. Some state authorities require useful disclosures as well.

The result is a wealth of information and analysis available to prospective donors, much of it free and easy to find online. Within minutes you can get data on an organization’s program expenses, fundraising, assets and executive compensation.

Guides for Giving:

Databases:

Rating Sites:

Wall Street Journal Law Blog, What to Scrutinize on a Charity’s Tax Form:

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May 9, 2015 in Tax | Permalink | Comments (0)

ABA Tax Section May Meeting

ABA Tax Section Logo (2012)The ABA Tax Section May meeting concludes today in Washington, D.C. The full program is here. Tax Profs with speaking roles today include:

  • Employee Benefits:  Kathryn Kennedy (John Marshall)
  • Pro Bono & Tax Clinics:  Scott Schumaker (U. Washington)
  • Sales, Exchanges & Basis:  Brad Borden (Brooklyn), Danshera Cords (Albany), Erik Jensen (Case Western), Calvin Johnson (Texas), Roberta Mann (Oregon)

May 9, 2015 in ABA Tax Section, Tax | Permalink | Comments (0)

The IRS Scandal, Two Years And Counting

IRS Logo 2The American Spectator, Making Sense of the IRS Scandal: Is Sympathy for the Devil Still Possible?:

Two years ago this month, former IRS official Lois Lerner revealed that the agency had discriminated against scores of right-leaning nonprofits on the basis of their political beliefs. The public called for accountability and got something vaguely resembling it in the form of resignations, investigations, and congressional debates. But despite the flurry of activity, the underlying issues that contributed to the IRS scandal remain unresolved, and the agency is still firmly embroiled in the messy business of policing political speech.

It’s enough to make one wonder: two years later, have things really changed? Or could it happen again?

Starting in 2010, IRS agents were instructed to apply extra scrutiny to applications for nonprofit status from conservative and tea-party organizations, culminating in those applications being sent to a special office where they were subjected to lengthy delays and invasive questioning. This was the agency’s inept response to the Citizens United decision, which freed all organizations to speak about elections, so long as they do so independently of candidates and parties. Critics of the decision, including several U.S. Senators, pressured the IRS to do anything in its power to stop groups from exercising their newfound freedom. Lerner herself remarked to a Duke University panel that “everybody is screaming at [the IRS] right now.”

But the IRS is a revenue collection agency, not a campaign finance regulator, so it was hopelessly ill-equipped for the task. It failed to treat groups equally or fairly, instead singling out conservative and tea party groups for an incredible level of scrutiny. The IRS demanded the personal information of groups’ supporters, copies of minutes from board meetings, résumés of current and former individuals involved with the organization, and even past intern history, copies of social media postings, and print outs of every page of an organization’s website.

President Obama called the IRS’s conduct “outrageous” and promised “I will not tolerate it. And we will make sure that we find out exactly what happened.” Lerner and IRS Commissioner Steven T. Miller resigned, countless congressional hearings were held to rail against the violation of taxpayers’ First Amendment rights, and multiple investigations — some of which are still ongoing — commenced to shed bits of light on the matter. ...

Lois Lerner may be gone, but the IRS is still threating to infringe upon First Amendment rights. In the same vein, a new TIGTA report issued on April 30 praised the IRS for reducing its backload of applications and making some changes to its screening process, such as standardizing the questions asked of groups, but noted that the IRS still “does not have a clearly defined test for determining whether an organization’s request for exemption as a social welfare organization should be approved.”

Things might be a little better, but they’re still not good, and there’s nothing to stop the IRS from deciding to target groups again in the future. The failure to secure the rights of nonprofits in the aftermath of the scandal is a sobering reminder that passion for accountability is not enough. We also have to be wise, and address policy problems where they exist instead of merely searching for individuals to blame.

Disputes over the language of the 501(c)(4) statute, combined with a lack of clear guidance from the Federal Election Commission and gridlock in Congress, left the IRS to regulate in an area where it lacked sufficient expertise to act responsibly. The IRS deserves more than its fair share of rebuke for targeting groups with views it didn’t like, for being dishonest about its activities, and for responding to criticism by proposing even more restrictive regulations. But whether its errors were committed in good faith or not, whether they were catastrophic or mere blunders, the IRS simply should never have been put in position to make them.

As the agency works on its new proposal, it should rely on the feedback it received last time. That means recognizing that nonprofit advocacy groups have a valuable role to play in civic life, protecting that role, and clarifying the rules so that small and volunteer-run organizations can be assured their activities are legal and their supporters’ private information is secure.

That’s the best we can hope for, but it shouldn’t be up to the IRS to make these decisions. That job belongs to Congress. Clarifying the language of the 501(c)(4) statute to explicitly protect the political speech of nonprofit groups would finally chart a path forward out of this regulatory morass. It would be a blessing both to nonprofit groups and the IRS.

On the two-year anniversary of revelations of the IRS scandal, perhaps it is time to leave behind the search for a villain and instead solve the problem. Until advocacy nonprofits have their First Amendment rights secured, the threat of future targeting lingers, no matter who is in charge

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May 9, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (4)

Friday, May 8, 2015

The Tax Lawyer Publishes New Issue

The Tax Lawyer (2013)The Tax Lawyer has published Vol. 68, No. 2 (Winter 2015):

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May 8, 2015 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0)

Weekly Tax Roundup

Weekly SSRN Tax Roundup

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May 8, 2015 in Scholarship, Tax | Permalink | Comments (0)

Weekly Student Tax Note Roundup

University College London Hosts Conference Today on The Philosophical Foundations of Tax Law

UCLUniversity College London Faculty of Laws hosts a two-day conference beginning today on The Philosophical Foundations of Tax Law:

There is currently very little literature considering the philosophical aspect of tax law. Yet given the controversy that surrounds tax, particularly in a turbulent economic environment, it is an excellent time to explore tax from a philosophical perspective. It is essential that we have a complete understanding of the answers to some of the seemingly basic questions which surround tax, before we can begin to think about what a tax system should look like. Questions such as what in fact is a tax? Why should we tax? How much should we tax and on whom should tax be levied? What should taxes be used for? How do ideas of fairness and justice tie in with the tax system?  The consideration of all these questions is crucial to a complete understanding of the tax system and the future of the tax system.

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May 8, 2015 in Conferences, Scholarship, Tax | Permalink | Comments (0)

ABA Tax Section May Meeting

ABA Tax Section Logo (2012)The ABA Tax Section May meeting continues today in Washington, D.C. The full program is here. Tax Profs with speaking roles today include:

  • Bankruptcy & Workouts:  Don Leatherman (Tennessee)
  • Diversity:  Allen Madison (South Dakota)
  • Foreign Activities of U.S. Taxpayers:  Robert Peroni (Texas)
  • Foreign Activities of U.S. Taxpayers, Foreign Lawyers Forum, Transfer Pricing & U.S. Activities of Foreigners and Tax Treaties:  Karen Brown (George Washington)

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May 8, 2015 in ABA Tax Section, Legal Education, Tax | Permalink | Comments (0)

Kahn & Kahn: The Agency Exception to the Anticipatory Assignment of Income Doctrine

Douglas A. Kahn (Michigan) & Jeffrey H. Kahn (Florida State), The Agency Exception to the Anticipatory Assignment of Income Doctrine, 147 Tax Notes 555 (May 4, 2015):

One consequence of having graduated income tax rates is that it becomes advantageous to shift income from a high bracket taxpayer to a person in a lower tax bracket. A number of different vehicles have been tried to shift the incidence of the income tax to another person, and the courts and Congress have adopted a number of rules to prevent that from occurring. As early as 1930, the Supreme Court adopted the anticipatory assignment of income doctrine to prevent a person who anticipates earning income from his services from shifting that income to another person in a lower tax bracket. Income is taxed to the person whose services produced it rather than to the person who has the beneficial right to possess the income once it is earned.

This article discusses the tax treatment of an employee whose services create income for his employer. The anticipatory assignment of income doctrine does not apply in these circumstances under the so-called agency exception. This article explains the policy justification of the agency exception and uses examples to help illustrate when and when not the agency exception should apply.

May 8, 2015 in Scholarship, Tax | Permalink | Comments (0)

The IRS Scandal, Day 729

IRS Logo 2Orange County Register editorial, Emails Keep IRS Scandal Probe Afloat:

John Koskinen has some ’splaining to do. Last June, Mr. Koskinen, the IRS commissioner, told Senate Finance Committee Chairman Ron Wyden and ranking member Orrin Hatch that a computer malfunction somehow zapped thousands of emails to and from Lois Lerner, the scandalized IRS official whose office targeted conservative groups for special scrutiny when applying for tax-exempt status.

Last week, those potentially incriminating emails were recovered – not because Mr. Koskinen was determined to get to the bottom of the IRS targeting scandal, but because of the diligence of J. Russell George, Treasury Inspector General for Tax Administration.

Mr. George is in the process of turning over some 6,400 emails to the Senate Finance Committee, which last year tasked the inspector general’s office with figuring out what emails had been lost, if someone at IRS intentionally destroyed them and if the emails could possibly be retrieved.

That seemed to us at the time a project Mr. Koskinen’s staff could have undertaken. Instead, it appeared that Mr. Koskinen – and, perhaps, Obama administration officials further up the food chain – were hoping the scandal would just fade away.

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May 8, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (2)

Thursday, May 7, 2015

Virginia Tax Review Publishes New Issue

Virginia Tax Review (2014)The Virginia Tax Review has published Vol. 34, No. 2 (Fall 2014):

May 7, 2015 in Scholarship, Tax | Permalink | Comments (0)

Journal of Tax Administration Publishes Inaugural Issue

JOTA LogoThe Chartered Institute of Taxation and the University of Exeter Business School have launched the Journal of Tax Administration:

This open access, peer reviewed and on-line journal provides an interdisciplinary forum for scholars and practitioners to share knowledge and research on issues of concern to tax administrations, governments, the tax practitioner community and wider society. An international editorial board includes leading academics in the field.

The inaugural issue (Vol. 1, No. 1) contains these articles:

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May 7, 2015 in Scholarship, Tax | Permalink | Comments (0)

Maynard: Reimagining Wealth Taxation As A Tool For Building Wealth

Goldburn P. Maynard Jr. (Louisville), Addressing Wealth Disparities: Reimagining Wealth Taxation as a Tool for Building Wealth, 92 Denv. U. L. Rev. 145 (2014):

In the past three decades, research has indicated that the building of assets can have a sustainable impact on well-being. Yet to the extent that the tax system has incorporated this insight, it has been done in a piecemeal, ad hoc fashion, disproportionately benefiting those with wealth and further reinforcing wealth inequality. This paper argues that while reducing wealth concentrations is important, there should be an increased emphasis on how our tax system can build wealth or, put differently, level up. While the problem of wealth disparities may be too large for any one part of the federal policy toolkit to solve, I argue that the tax system can and should play a vital role.

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May 7, 2015 in Scholarship, Tax | Permalink | Comments (0)

Number of Americans Renouncing Their U.S. Citizenship Hits Yet Another All-Time High

International Tax Blog, The Exodus Continues (2015 1st Quarter Published Expatriates):

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the first quarter of 2015. The number of published expatriates for the quarter was 1,335. This is the highest quarterly number of published expatriates ever.

Expat

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May 7, 2015 in Tax | Permalink | Comments (8)

Tax Prof Moves, 2015-16

Moves VAP Hire

  • Hayes Holderness (McDermott, Will & Emery, New York) to Illinois

Entry Level Hires

Lateral Moves

Promotions, Tenures, Chairs, and Professorships

  • Steve Arsenault (Charlotte) to Professor of Law With Tenure
  • Craig Boise (Dean, Cleveland-Marshall) to Baker & Hostetler Chair
  • David Herzig (Valparaiso) to Professor of Law With Tenure
  • Benjamin Leff (American) to Professor of Law With Tenure
  • John Plecnik (Cleveland-Marshall) to Associate Professor With Tenure
  • Susannah Tahk (Wisconsin) to Associate Professor With Tenure
  • Robert Wooten (Northwestern) to Professor of Practice

Administrative Appointments

Visits

  • Jennifer Bird-Pollan (Kentucky) to Indiana-Bloomington (Fall 2015)
  • Danshera Cords (Albany) to Pittsburgh (2015-16)
  • Cliff Fleming (BYU) to Vienna University (Oct. 2015), Central European University (May 2016)
  • Keith Fogg (Villanova) to Harvard (2015-16)
  • David Gamage (UC-Berkeley) to Dule (Fall 2015), Georgetown (Spring 2016)
  • Myron Grauer (Capital) to Ohio State (Fall 2015)
  • Edward Kleinbard (USC) to Stanford (Fall 2015)
  • Sarah Lawsky (UC-Irvine) to Northwestern (Fall 2015)
  • Leandra Lederman (Indiana-Bloomington) to Chicago (Fall 2015)
  • Charlene Luke (Florida) to Boston College (Spring 2016)
  • Gail Richmond (Nova) to Stetson (Fall 2015)
  • Tracey Roberts to UC-Hastings (2015-16)
  • David Schizer (Columbia) to Harvard (Fall 2015), Yale (2016)

Retirements

For prior years' Tax Prof Moves, see:

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May 7, 2015 in Legal Education, Tax, Tax Prof Moves | Permalink | Comments (1)

ABA Tax Section May Meeting

LectureThe ABA Tax Section May meeting kicks off today in Washington, D.C. The full program is here. Today's highlight is the annual Laurence Neal Woodworth Memorial Lecture in Federal Tax Law and Policy on Prospects for Tax Reform delivered by Dave Camp (Senior Policy Advisor, PricewaterhouseCoopers; Former Chair, House Ways & Means Committee).  Tax Profs with speaking roles today include:

  • Low Income Taxpayers Representation Workshop:  Keith Fogg (Villanova), Robert Nassau (Syracuse)

May 7, 2015 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0)

The IRS Scandal, Day 728

IRS Logo 2Wall Street Journal editorial, The IRS Goes to Court:

The agency suggests it can discriminate for 270 days. Judges gasp.

It isn’t every day that judges on the D.C. Circuit Court of Appeals declare themselves “shocked.” But that happened on Monday when an animated three-judge panel eviscerated the IRS and Justice Department during oral argument in a case alleging the agency delayed the tax-exempt application of a pro-Israel group due to its policy views.

In December 2009, Pennsylvania-based Z Street applied for 501(c)(3) status to pursue its pro-Israel educational mission. In July 2010, when the group called to check on what was taking so long, an IRS agent said that auditors had been instructed to give special attention to groups connected with Israel, and that they had sent some of those applications to a special IRS unit for additional review.

Z Street sued the IRS for viewpoint discrimination (Z Street v. Koskinen), and in May 2014 a federal district judge rejected the IRS’s motion to dismiss. The IRS appealed, a maneuver that halted discovery that could prove to be highly embarrassing. Justice says Z Street’s case should be dismissed because the Anti-Injunction Act bars litigation about “the assessment or collection of tax.” Problem is, Z Street isn’t suing for its tax-exempt status. It’s suing on grounds that the IRS can’t discriminate based on point of view.

The three judges—Chief Judge Merrick Garland,David Tatel and David Sentelle—were incredulous. You say they want a tax exemption, but that’s not the complaint, Judge Sentelle admonished government lawyer Teresa McLaughlin: “They are not in court seeking to restrain the assessment or collection of a tax, they are in court seeking a constitutionally fair process.”

The suit should also be foreclosed, the government argued, because under Section 7428(b)(2) of the Internal Revenue Code groups may sue to obtain their tax-exempt status if no action has been taken for 270 days, and that should be an alternative to Z Street’s approach.

“You don’t really mean that, right? Because the next couple words would be the IRS is free to discriminate on the basis of viewpoint, religion, race [for 270 days]. You don’t actually think that?” Judge Garland said. “Imagine the IRS announces today a policy that says as follows: No application by a Jewish group or an African-American group will be considered until one day short of the period under the statute . . . Is it your view that that cannot be challenged?”

The judges also asked why the government had buried the key precedent in a footnote in its brief. In Direct Marketing Association v. Brohl, the Supreme Court decided that the language of the Anti-Injunction Act did not preclude cases like Z Street’s. In a previous case before the D.C. Circuit, Judge Garland noted, the court also “rejected” the exact arguments the government was making, “so in a way we have already decided every issue before us today, against you.” ...

The Beltway media may be bored, but the IRS scandal is a long way from over.

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May 7, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (5)

Wednesday, May 6, 2015

Oei & Ring: Human Equity? Regulating The New Income Share Agreements

Shu-Yi Oei (Tulane) & Diane M. Ring (Boston College), Human Equity? Regulating the New Income Share Agreements, 68 Vand. L. Rev. 681 (2015):

A controversial new financing phenomenon has recently emerged. New “income share agreements” (“ISAs”) enable an individual to raise funds by pledging a percentage of her future earnings to investors for a certain number of years. These contracts, which are offered by entities such as Fantex, Upstart, Pave, and Lumni, raise important questions for the legal system: Are they a form of modern-day indentured servitude or an innovative breakthrough in human financing? How should they be treated under the law?

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May 6, 2015 in Scholarship, Tax | Permalink | Comments (0)

Fleischer: Libertarianism And The Charitable Tax Subsidies

Miranda Perry Fleischer (San Diego), Libertarianism and the Charitable Tax Subsidies, 56 B.C. L. Rev. ___ (2016):

Tax scholarship is largely silent about the interaction between libertarian principles and the structure of our tax system. If all taxation is indeed slavery, as Nozick suggested, why bother analyzing libertarianism for insights into our tax system? This dismissal, however, ignores the diversity of libertarian thought. To that end, this Article mines the nuances of libertarian theory for insights into one feature of our tax system: the charitable tax subsidies.

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May 6, 2015 in Scholarship, Tax | Permalink | Comments (0)

TIGTA: IRS Allowed $5.6 Billion In Erroneous Education Tax Credits

TIGTAThe Treasury Inspector General for Tax Administration yesterday released Billions of Dollars in Potentially Erroneous Education Credits Continue to Be Claimed for Ineligible Students and Institutions (2015-40-027):

The IRS still does not have effective processes to identify erroneous claims for education credits.  Although the IRS has taken steps to address some of our recommendations, many of the deficiencies TIGTA previously identified still exist.  As a result, taxpayers continue to receive billions of dollars in potentially erroneous education credits.  Based on our analysis of education credits claimed and received on Tax Year 2012 tax returns, TIGTA estimates that more than 3.6 million taxpayers (claiming more than 3.8 million students) received more than $5.6 billion in potentially erroneous education credits ($2.5 billion in refundable credits and $3.1 billion in nonrefundable credits).  Specifically, TIGTA estimates:

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May 6, 2015 in Gov't Reports, IRS News, Tax | Permalink | Comments (1)

The IRS Scandal, Day 727

IRS Logo 2Fox News op-ed:  IRS Scandal: I Was Targeted and I've Got Proof it Was a Democratically-led Conspiracy, by Wayne Allyn Root:

I was targeted by the IRS in a coordinated attack at the highest levels of government...and we now have the proof.

My IRS files, obtained under the Freedom of Information Act by Judicial Watch, clearly implicate the IRS and a Democratic U.S. senator.

Per Tom Fitton, president of Judicial Watch: 

“The Obama IRS obstructed the release of Wayne Root’s tax documents. The abuse of process Judicial Watch and Wayne suffered through to get these documents is scandalous. Now we know why the Obama IRS was hesitant to give Wayne his own IRS files. These documents show the Obama IRS scandal was more than just suppressing the Tea Party, it was also about auditing critics of President Obama. Richard Nixon had to resign from office for less. The first order of business for AG Loretta Lynch should be to appoint a special counsel who can convene a grand jury to look into the Obama IRS outrages.”

As you’ll read below, the fingerprints of the Obama administration and the Democratic Party are all over my case. Until now, no one could prove the IRS was using politics as a basis for vicious attacks against critics of the president. That just changed.

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May 6, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (2)

Tuesday, May 5, 2015

Polsky Presents Private Equity Tax Games Today At NYU

Polsky (2015)Gregg D. Polsky (North Carolina) presents A Compendium of Private Equity Tax Games at NYU today as part of its Tax Policy Colloquium Series hosted by Daniel Shaviro and Alan Viard:

This paper will describe and analyze tax strategies, lawful and unlawful, used by private equity firms to minimize taxes. While one strategy — the use of “carried interest” — should by now be well understood by tax practitioners and academics, the others remain far more obscure. In combination, these strategies allow private equity managers to pay preferential tax rates on all of their risky pay (through carried interest), pay preferential tax rates on much of their non-risky pay (through management fee waivers and misallocations of their expense deductions), and push much of the residual non-risky pay down to their funds’ portfolio companies who, unlike the fund, can derive significant tax benefits from the resulting deductions (through monitoring fees and management fee offsets).

May 5, 2015 in Colloquia, Scholarship, Tax | Permalink | Comments (0)

Soled Reviews Zelenak's Learning To Love Form 1040

Learning to Love 1040Jay A. Soled (Rutgers), Book Review, 87 Temp. L. Rev. 111 (2014) (reviewing Lawrence Zelenak (Duke), Learning to Love Form 1040: Two Cheers for the Return-Based Mass Income Tax (University of Chicago Press, 2013)): 

For the last several decades, a few days immediately before and on April 15 itself, our country has experienced an annual ritual as taxpayers nationwide form long lines at their local post offices to file their income tax returns. Akin to military service, undoubtedly few relish this obligation but recognize it as their civic obligation worthy of fulfillment. In a fascinating new book, Learning to Love Form 1040, published by the University of Chicago Press, Duke University School of Law professor Lawrence Zelenak details the origins of this obligation, traces its history, and explores how it has fostered what he terms fiscal citizenship, or “the important civic purpose of recognizing and formalizing the financial responsibilities of citizenship.”

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May 5, 2015 in Book Club, Scholarship, Tax | Permalink | Comments (2)