Wednesday, April 2, 2014
Michael S. Knoll (Pennsylvania) presents Tax Discrimination in the European Union and Beyond (with Ruth Mason (Virginia)) at Washington University today as part of its International Tax Speakers Series hosted by Adam H. Rosenzweig:
Yin Delivers Lecture on Reforming (and Saving) the IRS by Respecting the Public’s Right to Know at Temple
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The Heritage Foundation: IRS Targeting: Is the Obama Administration Conducting a Serious Investigation?, by Hans A. von Spakovsky:
- American Thinker: The IRS Digs in its Heels
- MSNBC: Issa Takes Heat for Feeble Witch Hunt
- Statesman Journal: The Silence of the Tax Lamb
Tuesday, April 1, 2014
The Permanent Subcommittee on Investigations Subcommittee of the Senate Homeland Security and Governmental Affairs Committee holds a hearing today on Caterpillar's Offshore Tax Strategy (webcast):
- Thomas F. Quinn (PricewaterhouseCoopers, Chicago)
- Steven R. Williams (PricewaterhouseCoopers, McLean, VA)
- James G. Bowers (PricewaterhouseCoopers, Dallas)
- Julie A. Lagacy (Finance Services Division, Caterpillar)
- Robin D. Beran (Chief Tax Officer, Caterpillar)
- Rodney Perkins (Former Senior International Tax Manager, Caterpillar)
Press and blogosphere:
- Bloomberg, Caterpillar Dodged $2.4 Billion Tax in Swiss Move, Inquiry Finds
- Bloomberg, Caterpillar Says Legal Swiss Tax Move Eliminated Unneeded Costs
- Los Angeles Times, Today in Corporate Tax Avoidance: Caterpillar's 'Pink Elephant'
- New York Times, Senate Report Says Caterpillar Used Swiss Subsidiary to Reduce Taxes
- Wall Street Journal, The $2.4 Billion Tax Question for Caterpillar; Senate Panel Says Company's Strategy Allowed It to Defer or Avoid Paying Some U.S. Taxes
- Wall Street Journal, Caterpillar's Senate Show Trial; An American Company Stands Accused of Paying All the Taxes It Owes
- Wall Street Journal, Levin: Caterpillar Shifted Profits Overseas to Lower U.S. Tax Liabilities; McCain Blames High U.S. Corporate-Tax Rate
- Washington Post, Caterpillar Skirted $2.4 Billion in Taxes, Senate Report Says
In a stunning bipartisan agreement, President Barack Obama, Attorney General Eric Holder, IRS Commissioner John Koskinen, House Committee on Oversight and Government Reform Chair Darrell Issa and Ranking Member Elijah Cummings committed to aggressively pursue investigations into the IRS's targeting of conservative groups in advance of the 2012 presidential election.
Attorney General Holder: I understand why the American public might question the impartiality of the DOJ's investigation headed by Barbara Bosserman in light of her political contributions to both of President Obama's campaigns. I have thus rescinded her appointment and appointed one of the few DOJ attorneys who did not donate to President Obama's campaigns to lead the investigation.
IRS Commissioner Koskinen: Inspired by the example of my predecessor Randolph Thrower who died on March 8, I commit to complying fully and completely with the investigation by the House Committee on Oversight and Government Reform. As the first step, the IRS will not take "years" to supply Lois Lerner's emails to the committee but instead will turn them over by April 15.
Chairman Issa: I deeply regret cutting off the microphone of my dear friend Elijah Cummings at our last hearing and I promise to include him as a full and equal partner in all future committee actions in this matter.
Ranking Member Cummings: This is one of the most alarming abuses of government power that I have ever seen. I’m very concerned about it, we gotta get to the bottom of it, and by the way … we gotta do it in a bipartisan way.
For details of the agreement, see here.
Monday, March 31, 2014
The New Yorker, Piketty’s Inequality Story in Six Charts:
New York Times: Q&A: Thomas Piketty on the Wealth Divide, by Eduardo Porter:
Financial Times op-ed: Save Capitalism From the Capitalists by Taxing Wealth, by Thomas Piketty
- Alex Brill, AEI
- John Samuels, General Electric
Panel #1: Base Erosion and Profit Shifting Under Worldwide and Territorial Taxation
- Dhammika Dharmapala (Illinois)
- Kevin Markle (University of Waterloo)
- Alan D. Viard (American Enterprise Institute) (commentator)
- Michael Graetz (Columbia) (moderator)
Panel II: Repatriation of Foreign Profits in Japan, the U.K., and the U.S.
- Sebastien Bradley (Drexel)
- Peter Egger (ETH Zurich)
- Fritz Foley (Harvard)
- Rosanne Altshuler (Rutgers) (commentator)
- Alan Auerbach (UC-Berkeley) (moderator)
Panel #3: Home-Country Tax Effects on Mergers, Inversions, and Headquarters Location
- Susan Morse (Texas)
- Paul Oosterhuis (Skadden)
- Johannes Voget (University of Mannheim)
- James Hines (Michigan) (commentator)
- Mihir Desai (Harvard) (moderator)
Luncheon Address: Jason Furman (Council of Economic Advisers)
Wall Street Daily: Renegade Government Agency Silences Political Opponents, by Floyd Brown (President, Western Center for Journalism):
- Raw Story: Documents Reveal Secretive Hollywood Group’s Shady Donations to Conservative Politicians
- Tribune Review: Another IRS Crock: The Anti-Speech Thugs
- Crane Presents When Is a Tax on Value (Not) a Tax on Income? at Washington University
- Legal Education's Moment of Impact: How to Design Strategic Conversations That Accelerate Change
- Krugman and Mankiw Debate Optimal Tax Theory, Economic Models, and Civility
- The IRS Scandal, Day 324
- How Law Schools Goose Their U.S. News Ranking by Hiring Their Graduates
- Top 5 Tax Paper Downloads
- Wall Street Journal Tax Tips
- The IRS Scandal, Day 325
Sunday, March 30, 2014
- Check Your Marriage Penalty—or Bonus: How to figure out whether you're paying more—or less—online.
- The Great Property (and Tax) Comeback: How the prices of luxury homes—but also estate taxes—are rapidly rising
- Last-Minute Tax Tips: What taxpayers can do to lower their bill, decide whether an extension makes sense and track down a missing refund.
- A New Reason to Hoard Assets: The wealthy may be putting the brakes on the gifting bonanza of the past few years.
- Tax Strategy Shifts from Gifting to Inheritance: Clients use a tax break known as the step-up in basis.
- What to Do if Your Tax Refund Goes AWOL: About three-quarters of all individual tax returns request a refund. Here's what to do if yours goes missing.
Saturday, March 29, 2014
Charlotte Crane (Northwestern) presented When Is a Tax on Value (Not) a Tax on Income? An Exploration of the Puzzles in PPL v. Commissioner at Washington University yesterday as part of its International Tax Speakers Series hosted by Adam H. Rosenzweig:
New York Times: Wealth Over Work, by Paul Krugman (Princeton):
Not Class Warfare, Optimal Taxation, by Greg Mankiw (Harvard):
New York Times: Too Much Faith In Models, Capital Taxation Edition, by Paul Krugman (Princeton):
Too Little Faith in People, Tax Policy Edition, by Greg Mankiw (Harvard):
- Daily Mail: IRS Chief: Producing Documents Could Take Years
- Fox News: Christie and IRS: A Tale of Two Scandals and Liberal Hypocrisy at Its Worst
- News Busters: Big Three Blackout: No Mention of Issa Threatening Contempt Charges for IRS Chief
- News Max: Rep. Chaffetz: Hold IRS Commissioner in Contempt of Congress
- Orlando Sun-Sentinel: Deal With IRS Official, and Get It Out of the Way
Friday, March 28, 2014
The John F. Kennedy Presidential Library and Museum today named Former President George H. W. Bush this year’s recipient of the John F. Kennedy Profile in Courage Award "in recognition of the political courage he demonstrated as President when he agreed to a 1990 budget compromise which reversed his 1988 campaign pledge not to raise taxes and put his re-election prospects at risk."
And I'm the one who will not raise taxes. My opponent now says he'll raise them as a last resort, or a third resort. But when a politician talks like that, you know that's one resort he'll be checking into. My opponent won't rule out raising taxes. But I will. And the Congress will push me to raise taxes and I'll say no. And they'll push, and I'll say no, and they'll push again, and I'll say, to them, ‘Read my lips: no new taxes.’
New York Times, A Profile in Courage Prize for George Bush (the Other One), by Andrew Rosnethal:
The Tax Lawyer has published Vol. 67, No. 2 (Winter 2014):
- Martin J. McMahon Jr. (Florida) & Daniel L. Simmons (UC-Davis), When Subchapter S Meets Subchapter C, 67 Tax Law. 232 (2014)
- Sheldon D. Pollack, The First National Income Tax, 1861–1872, 67 Tax Law. 311 (2014)
- ABA Section of Taxation Report, Options for Tax Reform in the Inbound International Tax Provisions of the Internal Revenue Code, 67 Tax Law. 331 (2014)
- Mona Shin (J.D. 2013, Georgetown), Note, Lightened Taxpayer Burdens in the Sale of Personal Goodwill After H&M, Inc. v. Commissioner, 67 Tax Law. 363 (2014)
- Robert D. Stewart (J.D. 2013, Georgetown), Note, I Am the Master(s) of My Fate: Owen v. Commissioner and the Assignment of Income Doctrine in the Context of Personal Service Corporations, 67 Tax Law. 379 (2014)
- Bloomberg, Caterpillar Previews Tax Defense for April Senate Hearing, by Richard Rubin
- Bloomberg, IRS to Make Limited Use of Offshore Bank Data, Koskinen Says, by Richard Rubin
- Forbes, Gotcha! Tax Court Penalizes IRA Rollover That IRS Publication Says Is Allowed, by Janet Novack
- Forbes, The Home Office Deduction: What You Need To Know, by Deborah Jacobs
- Forbes, Twitter File: Will IRS Accept Your Taxes Via Tweet?, by Robert W. Wood
- Going Concern, The More Money Your Parents Made, the Less Likely You Are to Become an Accountant, by Adrienne Gonzalez
- National Affairs, Rethinking Tax Benefits for Home Owners, by Andrew Hanson, Ike Brannon & Zackary Hawley
- New York Times Dealbook, Deducting the Costs of a Government Settlement, by Peter J. Henning (Wayne State)
- New York Times, Disabled Borrowers Trade Loan Debt for a Tax Bill From the I.R.S., by Tara Siegel Bernard
- Procedurally Taxing, Does Equity Have a Role in Offers in Compromise?, by Scott Schumacher (University of Washington)
- Procedurally Taxing, When Can Concentrating Enforcement Resources Increase Compliance?, by Leigh Osofsky (Miami)
- Sacramento Bee op-ed: A Better Direction for California’s Climate Change Policy, by Mark Gergen (UC-Berkeley) & David Gamage (UC-Berkeley)
- Tax Analysts Blog, Good Grief! Tax Analysts v. Internal Revenue Service, by Christopher Bergin
- Tax Analysts Blog, Hang On to Your Wallets, by David Brunori
- Tax Analysts Blog, Portman’s Disappointing Tax Reform Plan, by Jeremy Scott
- Tax Analysts Blog, Raising Taxes on the Rich Won't Balance the Budget -- But It's Still Important, by Joseph J. Thorndike
- Tax Update Blog, Tax Court Decision Cuts 3.8% Obamacare Net Investment Income Tax for Many Trusts, by Joe Kristan
- Tax Vox Blog, Dave Camp’s Plan for the Expired Tax Provisions: An Almost-Good Idea, Howard Gleckman
- USA Today, Six Reasons to Give Your Tax Prep a Technology Boost
- Washington Examiner op-ed: Time to Scrap the Mortgage Interest Deduction, by Philip Klein
- Cheryl Boudreau (UC-Davis) & Scott MacKenzie (UC-Davis), Wanting What Is Fair: How Party Cues and Information About Income Inequality Affect Public Support for Taxes
- James Chyz (Tennessee), Fabio B. Gaertner (Wisconsin) & Asad Kausar (Nanyang), Overconfidence and Aggressive Corporate Tax Policy
- Harvey Gilmore (Monroe Collegem), New York's Taxable Lap Dancing … At a Strip Club Near You!
- David A. Guenther (Oregon), Linda K. Krull (Oregon) & Brian M. Williams (Oregon), Are 'Tax Aggressive' Firms Just Inflating Earnings?
- Jeffrey Hoopes (Ohio State), Jacob Thornock (U. Washington) & Braden Williams (U. Washington), Is Sales Tax Avoidance a Competitive Advantage?
- Ilya Lipin (Villanova), Discovery of Tax Accrual Workpapers after Textron and Deloitte
- Carla Marchese (University of Eastern Piedmont), Tax Amnesties
- Robert McGee (Fayetteville State) & Adriana Ross (Florida International), Education Level and Ethical Attitude Toward Tax Evasion: A Six-Country Study
- Jon P. Nelson (Penn State), Binge Drinking, Alcohol Prices, and Alcohol Taxes: A Systematic Review of Results for Youth, Young Adults, and Adults from Economic Studies, Natural Experiments, and Field Studies
- Laura E. Erdman (J.D. 2014, Washington & Lee), Note, Reinterpreting the Limited Partner Exclusion to Maximize Labor Income in the Self-Employment Tax Base, 70 Wash. & Lee L. Rev. 2389 (2013)
- Amanda Stein (J.D. 2014, Washington University), Note, FICA Taxation of Post-Employment Benefits: A Statutory Puzzle and Sociopolitical Conundrum, 91 Wash. U. L. Rev. 203 (2013)
- Undergraduate Accounting
- MS Tax
- MAcc Tax
- MBA Tax
- JD Tax
- LL.M. Tax
For the LL.M. Tax Survey, respondents were asked to select up to five schools (out of 31) with LL.M. Tax programs that they hold in highest regard when hiring candidates. Respondent Profile: 144 currently employed heads of corporate in-house tax departments.
For the J.D. Tax Survey, respondents were asked to select up to five schools (out of 20) with JD Tax programs that they hold in highest regard when hiring candidates. It is a bizarre list of 20 law schools, as it omits 14 of the 15 schools ranked in tax by U.S. News (Georgetown is the only school ranked by both U.S. News and Tax Talent.)
Feds Partner With TurboTax to Push Income-Based Repayment on Student Loan Borrowers, Despite Potential Hefty Back-End Tax Bite
- Accounting Web: Koskinen Gets an Earful from GOP
- Biz Pac Review: Trey Gowdy Hammers IRS Commissioner Over Missing Lois Lerner Emails
- Chronicle of Philanthropy: House Lawyers Say Panel Can Pursue Lerner Contempt Case
- Huffington Post: Darrell Issa Hearing Reveals IRS-Targeted Groups Prefer To Be Political
- The Kelly File: Years to Produce Lois Lerner's IRS Emails?
- National Review: Lois Lerner’s New Lawyer
- Politico: Darrell Issa Rankles Some Republicans in Handling IRS Tea Party Probe
- Politico: Republicans Hammer New IRS Chief John Koskinen Over Tea Party Melee
- Power Line: Trey Gowdy on the Case
- Washington Examiner: Do Darrell Issa and Jim Jordan Have Another Trick Up Their Sleeve to Make Lois Lerner Talk?
- Washington Times: Congress Must Bully the IRS by Cutting Off its Money Until It Cooperates
Thursday, March 27, 2014
Following up on Wedmesday's TaxProf Blog op-ed, Omri Marian (Florida): Bitcoin and Notice 2014-21: New York Times DealBook: Taxes Won’t Kill Bitcoin, but Tax Reporting Might, by Victor Fleischer (San Diego):
Update: Tax Vox Blog, You Could Owe Capital Gains Taxes When You Spend Bitcoin, by Steven Rosenthal
Suffolk University Law School is launching a new Tax LL.M. Program in May 2015 that will permit Suffolk students to earn J.D. and Tax LL.M. degrees in three years:
The National Jurist quotes Associate Dean Anthony Polito, Faculty Director of the Tax LL.M. Program: "Compared to the J.D. program, the only additional classes would be those in the summer session, so law students could graduate with J.D. and LL.M. degrees for about half the cost of attending a separate LL.M. program."
Suffolk joins other law schools like Boston University, Loyola-L.A. Northwestern, and Washington University that offer three-year J.D./Tax LL.M. programs. Other law schools (like Georgetown, NYU, and San Diego) offer seven-semester J.D./Tax LL.M. programs.
Thomas J. Brennan (Northwestern) presented Smooth Retirement Accounts at Boston College yesterday as part of its Tax Policy Workshop Series hosted by James Repetti and Diane Ring and funded by the Paulus Endowment for Tax Programs:
- Amarillo Globe News editorial: IRS Should Stop Stonewalling
- CNN: IRS Agrees to Hand Over Emails to Issa
- Daily Caller: Trey Gowdy Threatens to Hold IRS Commissioner in Contempt for Withholding Lerner Emails
- Fox News: House Committee May Hold Lois Lerner in Contempt of Congress
- New York Times: House Oversight Leader Accuses I.R.S. Commissioner of Stonewalling Inquiry
- Legal Cafe: The IRS Targeted "Progressive" Nonprofits Too
- Los Angeles Times: IRS Chief, House Panel Clash Over Scandal-Related Documents
- NBC News: Former IRS Official May Be Held in Contempt of Congress
- Newsmax: Trey Gowdy: IRS' Lerner to be Held in Contempt of Congress Soon
- Newsmax: Issa Slams New IRS Chief: Agency Still Withholding Documents
- PJ Media: ‘A Wing of the FEC’: Issa Says Lerner Was on Mission Against 501(c)(4)s After Citizens United
- Politico: Republicans Hammer New IRS Chief John Koskinen Over Tea Party Melee
- Town Hall: Issa to IRS Commissioner: Release Lerner's Emails or Face Contempt
- USA Today: Turning Over Lerner E-mails Could Take Years, IRS Says
- Washington Examiner: IRS Commissioner: 'It's Going to Take Years' to Produce Documents About Tea Party Targeting
- Washington Post: House Lawyers Say Panel Can Pursue Contempt Charges Against Lois Lerner
- Washington Times: Conservative Group Hits Sen. Franken on Proposed IRS Rule Changes
- Washington Times: Lawmakers Told IRS Probe Will Take Years
- WND: IRS Stonewalls on Emails About Tea-Party Targets
Wednesday, March 26, 2014
Edgar Presents Corrective Taxation, Leverage, and Compensation in a Bloated Financial Sector Today at Toronto
The NYU Journal of Law & Business and the NYU Graduate Tax Program hosted a symposium yesterday on Tax and Corporate Social Responsibility:
Panel #1: Should Corporations Pay Tax?
- Moderator: Mitchell Kane (NYU)
- Presenter: Reuven Avi-Yonah (Michigan), Corporate Social Responsibility and the Business Enterprise
- Discussants: Peter Barnes (Duke), Michael Schler (Cravath), Helen Scott (NYU)
Panel #2: Should Corporate Tax Returns Be Public?
- Moderator: David Kamin (NYU)
- Presenter: Joshua Blank (NYU), Reconsidering Corporate Tax Privacy
- Discussants: Allison Christians (McGill), Reuven Avi-Yonah (Michigan), Peter Barnes (Duke)
- Howard Abrams (Emory) to San Diego
- Michael Doran (Georgetown) to Virginia
- Mirit Eyal-Cohen (Pittsburgh) to Alabama
- David Hasen (Santa Clara) to Colorado
- Michael Hatfield (Texas Tech) to University of Washington
- Xuan-Thao Nguyen (SMU) to Indiana-Indianapolis
I will update this list as part of my annual April compilation of tax moves.
Following up on my prior post, President Obama's Interview With Zach Galifianakis (Mar. 21, 2014):
- GOP USA: There Is Good Reason to Question Validity of IRS Investigation
- National Review: Democrats Not Budging on New IRS Rules
- New York Times: How the IRS Created a Campaign-Spending Mess
- Wall Street Journal: IRS Commissioner Headed to the Hill
- Washington Times: GOP Aide on White House: ‘They’ve Blown Off the Subpoenas’; IRS Faces Another Hearing