TaxProf Blog

Editor: Paul L. Caron
Pepperdine University School of Law

Wednesday, August 3, 2016

Walker:  The Practice And Tax Consequences Of Nonqualified Deferred Compensation

David I. Walker (Boston University), The Practice and Tax Consequences of Nonqualified Deferred Compensation:

Although nonqualified deferred compensation plans lack explicit tax preferences afforded qualified plans, it is well understood that nonqualified deferred compensation results in a joint tax advantage when employers earn a higher after‐tax return on deferred sums than employees could do on their own. Several commentators have proposed tax reform aimed at leveling the playing field between cash and nonqualified deferred compensation, but reform would not be easy or straightforward. This Article investigates nonqualified deferred compensation practices and shows that joint tax minimization often takes a backseat to accounting priorities and participant diversification concerns.

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

Schumer Decries 'Victory Tax,' Urges House To Pass Senate Bill Exempting Olympic Medals From Tax

Olympic RingsPress Release, Schumer Urges House of Representatives to Immediately Pass Bipartisan Legislation That Will Block IRS From Taxing Olympic Medals; Senator Says Olympic and Paralympic Athletes Should Not Have To Pay a Victory Tax:

During a visit to the Olympic Training Center in Lake Placid, U.S. Senator Charles E. Schumer joined with Olympic athletes and launched a major push to urge the U.S. House of Representatives to pass legislation that would prevent the Internal Revenue Service (IRS) from taxing Olympic and Paralympic athletes on medals or other prizes awarded to them in future Olympic games.

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August 3, 2016 in Congressional News, Tax | Permalink | Comments (5)

Professional Ethics For The Tax Lawyer To The Holmesian Bad Man

Bret N. Bogenschneider (Vienna), Professional Ethics for the Tax Lawyer to the Holmesian Bad Man, 49 Creighton L. Rev. 775 (2016):

The “manufacture” of factual indeterminacy in furtherance of tax avoidance activity constitutes potentially unethical attorney conduct. The structuring of facts toward tax avoidance is not merely the rendering of legal advice as contemplated by the Model Code of Professional Conduct, and instead may assist the Holmesian “bad man” client toward conduct which is normatively prohibited under the tax laws. As such, only tax planning via factual structuring, which results in determinative tax avoidance, is ethical attorney conduct.

Since a purely formalistic method of legal interpretation is not applied in the United States, the circumstance of determinative tax avoidance is extraordinarily rare in the modern era. The moral aspects of legal representation in furtherance of tax evasion are also re-evaluated from both the parochial and postmodern perspectives.

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

Utah Seeks To Hire A Tax Prof

Utah Logo (2016)The University of Utah S.J. Quinney College of Law invites applications for faculty positions at the rank of associate professor (tenure track), professor (with tenure), or career line (long-term clinical or other non-tenure track, rank consistent with experience) beginning academic year 2017-2018:

Qualifications include a record of excellence in academics or practice, successful teaching experience or potential as a teacher, and strong scholarly distinction or promise for tenure track or tenured positions. The College is particularly interested in candidates in the area of tax law. Interested persons should submit an application to the University of Utah Human Resources website.

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August 3, 2016 in Legal Education, Tax, Tax Prof Jobs | Permalink | Comments (0)

Trump Wants To Repeal The Johnson Amendment And Make Churches The New Super PACs

Following up on my previous posts (here and here):  The Atlantic, Trump Wants to Make Churches the New Super PACs: His Promise to Repeal the 1954 Johnson Amendment Isn’t About Free Speech—It’s About Cash:

Why have some religious conservatives decided to support Donald Trump for United States president? Leaders have named their reasons: He’s promised toappoint pro-life Supreme Court justices; he’s allegedly good at business. But they have also consistently cited something else, perhaps more unexpected: the tax code.

Trump has promised to repeal the so-called Johnson Amendment, a 1954 provision that prohibits tax-exempt organizations from participating in political activities. Proposed by then-Senator Lyndon B. Johnson and later revised by Congress, it keeps churches and other non-profits from lobbying for specific causes, campaigning on behalf of politicians, and supporting or opposing candidates for office.

While opponents of the Johnson Amendment often frame their objections in terms of free speech, the provision’s primary impact may be financial. Right now, the IRS makes a clear distinction between non-profit groups—from charities and universities to certain private schools and houses of worship—and political organizations.

If the Johnson Amendment were repealed, pastors would be able to endorse candidates from the pulpit, which they’re currently not allowed to do by law. But it’s also true that a lot more money could possibly flow into politics via donations to churches and other religious organizations. That could mean religious groups would become much more powerful political forces in American politics—and it would almost certainly tee up future court battles. ...

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August 3, 2016 in Political News, Tax | Permalink | Comments (9)

The IRS Scandal, Day 1182

IRS Logo 2Politico, Morning Tax: Sounds About Right:

A new document release from Judicial Watch shows that then-interim IRS chief Steven Miller was none too pleased when first informed about the tea party controversy that would eventually lead to his ouster. As Joseph Lawler of the Washington Examiner put it: “Miller threw his pencil across the room and yelled, ‘Oh, s — t,’” when told in the spring of 2012 that the agency had been improperly scrutinizing conservative organizations. Full Examiner story.

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August 3, 2016 in IRS News, IRS Scandal, Tax | Permalink | Comments (0)

Tuesday, August 2, 2016

Does Vic Fleischer's Appointment As Senate Finance Committee Co-Chief Tax Counsel Imperil Tax Reform, Or Give It A Shot In The Arm?

Fleischer (2016)Following up on my recent posts:

Forbes:  Senator Ron Wyden Endangers Tax Reform With Hire of Radical Partisan Victor Fleischer, by Ryan Ellis:

While most Americans over the past two weeks were consumed with the drama and intrigue of the two party conventions, a major hire was made in Washington, D.C. which could have devastating negative implications for fundamental tax reform prospects in 2017.

Senate Finance Committee Ranking Member Ron Wyden (D-Ore.) has hired University of San Diego law professor Victor Fleischer as co-chief tax counsel. Should the Democrats gain a majority in the Senate this fall, Fleischer would have a key role in shaping the direction of tax reform discussions next year with the new president and with a presumably Republican House of Representatives. Wyden called Fleischer a “true outside thought leader in this space.”

That is very bad news if you were hoping to see fundamental tax reform finally become a reality next year.

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August 2, 2016 in Congressional News, Legal Education, Tax | Permalink | Comments (4)

Treasury Issues Proposed Regs To Limit Valuation Discounts For Fractional Interests

DiscountsWall Street Journal, U.S. Aims to Clamp Down on Tactic to Avoid Estate Tax:

The U.S. government on Tuesday proposed making it harder for wealthy business owners to transfer assets to heirs without paying estate and gift taxes.

The Treasury Department and Internal Revenue Service plan would place new limits on a common technique used to transfer interests in illiquid businesses.

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August 2, 2016 in Tax | Permalink | Comments (2)

San Francisco ‘Tech Tax’ Is Dead

Tech TaxFollowing up on my previous post, NY Times: San Francisco Considers 'Tech Tax' To Pay For Boom’s Downside:  Time, The San Francisco ‘Tech Tax’ Is Dead:

In a committee meeting on Monday, one of the more controversial proposals to bubble up in San Francisco in recent years was effectively killed. But the angst that the proposed “tech tax” exposed was left in its wake, after being put on display during an afternoon of commentary from lawmakers and members of the public.

The measure, intended for the November ballot, would have levied a 1.5% payroll tax solely on the booming tech sector, and the estimated $140 million in annual revenue from that special tax would have been earmarked for projects like housing the homeless and building affordable housing. While supporters argued that there was a Robin Hood-esque justice this would bring to the city — well-paid tech workers have flowed in and lower-income residents have been pushed out — critics like Supervisor Mark Farrell described the proposal as simplistic “scapegoating” that threatened to drive economic powerhouses to other places.

One of the city’s 11 lawmakers and the chair of the committee that stopped the measure from moving forward, Farrell opened by comparing the spirit of the tax to “the politics of Donald Trump,” describing him as one of “those who divide us.” The allusion did not sit well in a city where lawmakers are often distinguished by being progressive or moderate Democrats, leading at least one supporter of the measure to hold back tears of anger. While everyone agreed that rising rents and limited housing stock have reached crisis levels, there was not agreement on how much the tech boom is to blame, nor on what the true character of the tech industry is. ...

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August 2, 2016 in Tax | Permalink | Comments (0)

NY Times:  Donald Trump Ducks Tax Disclosure

Trump (2016)New York Times editorial, Donald Trump Ducks Tax Disclosure:

As Donald Trump’s tweets pile one atop another, generating sensational headlines, issues of true substance are tending to get lost in the shuffle. None is more important for voters to keep in mind than the failure of Mr. Trump to disclose his full income tax returns, something he is not likely to do by Election Day.

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August 2, 2016 in Political News, Tax | Permalink | Comments (1)

Richmond Seeks To Hire An Entry-Level Tax Prof

Richmond LogoThe University of Richmond School of Law seeks to fill two entry-level tenure-track positions for the 2017-2018 academic year, including one in tax law:

Candidates should have outstanding academic credentials and show superb promise for top-notch scholarship and teaching. The University of Richmond, an equal opportunity employer, is committed to developing a diverse workforce and student body and to supporting an inclusive campus community. Applications from candidates who will contribute to these goals are strongly encouraged.

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August 2, 2016 in Legal Education, Tax, Tax Prof Jobs | Permalink | Comments (0)

Law Profs Debate Solo Practitioner Earnings, Usefulness Of IRS Data

ABA Journal, How Much Do Solo Lawyers Make? More Than IRS Data Suggests, Law Profs Assert:

How much do solo lawyers make? According to a University of Tennessee law professor who examined IRS data, the answer was an average of about $49,000 a year in 2012. But can the IRS data be trusted?

The question is being debated by two blogging law professors who are challenging the figure by University of Tennessee law professor and book author [Glass Half Full The Decline and Rebirth of the Legal Profession (Oxford University Press, 2015) (blogged here, here, and here)] Benjamin Barton. In an article published by Business Insider last year, Barton said the average income for all solos fell 34 percent since 1967, when figures adjusted for inflation showed solos earned a little less than $74,000.

Two law professors who think the $49,000 is too low are Seton Hall University law professor Michael Simkovic, writing at Brian Leiter’s Law School Reports [How Much Do Lawyers Working in Solo Practice Actually Earn?], and Santa Clara University law professor Stephen Diamond, writing at his own blog [Flying Solo: Data Show Lawyers Can Earn a Decent Living on Their Own]. They both rely on Census data that suggests the number could be higher.

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August 2, 2016 in Legal Education, Tax | Permalink | Comments (17)

The IRS Scandal, Day 1181

IRS Logo 2Judicial Watch Press Release, FBI Interviews with Cincinnati IRS Employees Reveal DC Headquarters Delayed Tea Party Applications:

Judicial Watch today released 105 pages of newly obtained Federal Bureau of Investigation (FBI) “302” documents revealing that, beginning in 2010 and lasting through the Obama reelection campaign in 2012, the Obama IRS orchestrated a deliberate policy of burying conservative groups’ tax exemption applications in bureaucratic delays. Interviews with numerous Cincinnati IRS employees in mid-2013 reveal that “Tea Party” group applications were automatically denied approval and assigned to a special “Group 7822” for an extended “inventory” process while waiting for decisions from IRS headquarters in Washington, DC.  One IRS manager “asked why progressive cases were not segregated similar to the Tea Party cases, but she did not get any satisfactory answers.”  FBI “302” documents are detailed narratives of FBI investigation interviews. The Obama Justice Department and FBI investigations into the Obama IRS scandal resulted in no criminal charges.

According to a Cincinnati “Group Manager” interview in July of 2013:

Group 7822 was composed of 12 to 15 people and was simply a place for the Tea Party cases to be held in inventory while the agent waited to receive guidance from the Washington office. There had been no precedence previously on these issues. If the case said it supports politics and political activity, it would be put into Group 7822. [Redacted] and then [Redacted] held the cases in inventory.

A second Cincinnati Group Manager interviewed in July 2013 told the FBI 302 interviewers a similar story, pinning the blame directly on the IRS Washington headquarters:

In the 14-month period when [Redacted] had the cases, he would ask for updates on guidance and was told they were still waiting on DC. He recalls receiving emails with contradictory guidance on whether the 501-c-3 or 501-c-4 cases should be denied. It was his understanding that a team would come and work the Tea Party cases when the guidance was provided … Nobody told him directly where the delay was in resolving the Tea Party issue. DC is like a black hole.

The FBI 302 interviews with Cincinnati IRS employees reveal that the agency adopted a series of policies assuring that Tea Party and other conservative group tax exempt applications would not be approved before the November 2012 presidential election. The strategy relied upon the IRS’ multi-tier “bucketing” system that determined from the time an application was received whether it would be quickly approved or indefinitely delayed.

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August 2, 2016 in IRS News, IRS Scandal, Tax | Permalink | Comments (17)

Monday, August 1, 2016

Stiglitz:  Apple's Tax Strategy Is A 'Fraud'

Bloomberg, Stiglitz Calls Apple’s Profit Reporting in Ireland ‘a Fraud’:

Nobel economist Joseph Stiglitz said U.S. tax law that allows Apple Inc. to hold a large amount of cash abroad is “obviously deficient” and called the company’s attribution of significant earnings to a comparatively small overseas unit a “fraud.”

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August 1, 2016 in Tax | Permalink | Comments (9)

ABA Tax Section Accepting Nominations For 2017-2019 Public Service Fellowships


ABA Tax Section Logo (2012)The ABA Tax Section is accepting applications for Public Service Fellowships for 2017-2019:

The American Bar Association Section of Taxation is pleased to announce that it is now accepting applications for its Christine A. Brunswick Public Service Fellowship program class of 2017-2019. ...

The Christine A. Brunswick Public Service Fellowships provide funding for the Fellows’ salaries and benefits, as well as law school debt assistance, by means of charitable contributions to the Fellow's Sponsoring Organization. ... The Section plans to award up to two fellowships each year.

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August 1, 2016 in ABA Tax Section, Legal Education, Tax | Permalink | Comments (0)

Hemel & Ouellette:  Knowledge Goods And Nation-States

Daniel Hemel (Chicago) & Lisa Larrimore Ouellette (Stanford), Knowledge Goods and Nation-States, 101 Minn. L. Rev. ___ (2016):

The conventional economic justification for global IP treaties begins from the premise that nation-states, if left to their own devices, will rationally underinvest in innovation incentives such as IP laws, grants, tax credits, and prizes (the “underinvestment hypothesis”). Under this account, nation-states will free-ride on each other’s knowledge production unless they find some solution to their collective-action problem. The solution that nation-states have struck upon is international IP law: IP treaties harmonize domestic laws and thus ensure a baseline level of investment in knowledge production (the “harmonization hypothesis”). Moreover, IP is the only such solution available to nation-states because a global regime of grants, tax credits, or prizes would require a global public finance system — and no such system exists. IP is thus unique among innovation policy options in that it can be implemented at the international level (the “uniqueness hypothesis”). Previous authors have adopted this logic while lamenting its implications: IP appears to be a necessary evil in an interconnected world — necessary to solve the free-rider problem; lamentable because it results in sizeable deadweight losses.

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

Changes To TaxProf Blog

Over the past two weeks, I have received several emails like the following:

Thank you so much for your TaxProf blog. I've been a reader for at least a dozen years. Your blog has the most informative tax information available.

The last two weeks, however, you've interrupted my long-time late Friday night routine! You see, with the cares of my week behind me, and with at least one day of respite ahead of me, each Friday I look forward to reading your blog's four weekly "roundups." To my dismay, though, today is the second Friday in a row that no roundup has appeared. And no explanation has been given for the absence of this rewarding end-of-week treat.

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August 1, 2016 in About This Blog, Legal Education, Tax | Permalink | Comments (6)

IRS Acquiesces In Ninth Circuit Decision Giving Unmarried Couples Double The Mortgage Interest Deduction Available To Married Couples

The IRS has issued AOD 2016-02, 2016-31 IRB 193 (Aug. 1, 2016), acquiescing in the Ninth Circuit's decision in Voss v. Commissioner, 796 F.3d 1051 (9th Cir. 2015), which held that the § 163(h)(3) limitations on the deductibility of mortgage interest ($1 million of acquisition indebtedness plus $100,000 of home equity indebtedness) are applied on a per-taxpayer basis (for a total of $2.2 of mortgage debt for unmarried couples), rather than on a per-residence basis (and thus limited to $1.1 of mortgage debt for married couples), as previously argued by the IRS and decided by the Tax Court (138 T.C. 204 (2012)).

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August 1, 2016 in IRS News, New Cases, Tax | Permalink | Comments (2)

Harrison, Alum Debate State Of Florida Grad Tax Program: Is 80% Acceptance Rate A Sign Of Trouble, 45% Yield A Sign Of Strength?

Florida Logo (GIF)Following up on Thursday's post, Harrison: Florida Is 'Modernizing,' Not 'Dismantling,' Its Graduate Tax Program, which has generated 18 comments (thus far):  Jeff Harrison (Florida), So Many Questions:

Here is what I believe to be a reasonable comment over on the tax prof blog about the tax (non) "issues" at UF and my responses [in italics].  Two comments:

First, I think I have never seen any instances in which people who claim to have the best interests of a program at heart have done so much to communicate that it is declining. What are they thinking?

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August 1, 2016 in Legal Education, Tax | Permalink | Comments (2)

Subscribing To TaxProf Blog

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August 1, 2016 in About This Blog, Legal Education, Tax | Permalink | Comments (0)

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August 1, 2016 in About This Blog, Legal Education, Tax | Permalink | Comments (0)

TaxProf Blog Weekend Roundup

Sunday, July 31, 2016

Buckles:  Religious Colleges That Embrace Heterosexual Monogamy Should Retain Their Tax Exemption Under Bob Jones, Despite Obergefell

Johnny Rex Buckles (Houston), The Sexual Integrity of Religious Schools and Tax Exemption:

Many private universities and other schools adhere to religiously grounded codes of conduct that embrace heterosexual monogamy as the sole moral context for sexual relationships. The federal income tax exemption of these schools has been questioned following the recent Supreme Court opinion of Obergefell v. Hodges. In Obergefell, the Supreme Court held that the right to marry is a fundamental constitutional right that same-sex couples may exercise. The relevance of this decision to the federal tax status of private religious schools arises from another Supreme Court decision, Bob Jones University v. United States. The Court in Bob Jones held that two schools with racially discriminatory policies as to students were not entitled to exemption from federal income tax because the policies violate established public policy. The issue now is whether the sexual conduct policies of private religious schools violate the established public policy of the United States following Obergefell.

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

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. [304 Downloads]  Dark Pools, High-Frequency Trading, and the Financial Transaction Tax: A Solution or Complication?, by Doron Narotzki (Akron)
  2. [264 Downloads]  Fiduciary Financial Advice to Retirement Savers: Don't Overlook the Prudent Investor Rule , by Max M. Schanzenbach (Northwestern) & Robert H. Sitkoff (Harvard)
  3. [211 Downloads]  Wealth Management, Tax Evasion and Money Laundering: The Panama Papers Case Study, by Ehi Esoimeme (Cardiff)
  4. [187 Downloads]  The U.S. Response to OECD-BEPS and the EU State Aid Cases, by Daniel Shaviro (NYU)
  5. [167 Downloads]  The Trojan Horse of Corporate Integration , by Edward D. Kleinbard (USC)

July 31, 2016 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)

The IRS Scandal, Day 1179

IRS Logo 2Breitbart op-ed:  Congress Must Impeach the IRS Commissioner, by Reps. Jim Jordan (OH-4), Tim Huelskamp (KS-1) & John Fleming (LA-4):

Today Americans see two sets of rules: one for the powerful and politically connected and another for

ordinary Americans. They view the system as rigged — and they’re not wrong.

There’s a roster of Obama administration officials that have abused their offices and not been held accountable.

Former Director of the Exempt Organizations unit of the IRS Lois Lerner engaged in systematic targeting of conservative individuals and organizations for their political views. When it came to light, she first lied when she falsely blamed agents in Cincinnati. She then refused to answer questions in a Congressional hearing. And as a result, she was held in contempt of Congress.

Although held in contempt by the House of Representatives, no grand jury was ever convened and no charges were filed by the Department of Justice. Lois Lerner was able to retire quietly with full government benefits despite having abused Americans’ most fundamental liberties. ...

Perhaps the most egregious example is John Koskinen — Commissioner of one of the most powerful government agencies — the Internal Revenue Service.

John Koskinen’s Chief Counsel knew in February of 2014 that there were problems with Lois Lerner’s hard-drive. He waited four months before he told Congress. During that four month timeframe, with two congressional-subpoenas and three preservation orders in place, the IRS destroyed 422 back-up tapes containing as many as 24,000 emails.

Any American who has ever dealt with the IRS knows how important document preservation, full disclosure, and transparency is. A wrong move could get you fined — or worse, land you in jail. No private citizen

being audited by the IRS could get away with such behavior. Why should John Koskinen?

In Federalist No. 65, Alexander Hamilton wrote that the power to impeach a civil servant should protect the public against “the abuse or violation of some public trust.” Time and time again, Koskinen both abused his power and violated the public’s trust in the IRS.

The primary — perhaps the only — argument against impeachment of the IRS Commissioner is that it hasn’t been done before. To date, no head of a government agency has been impeached by Congress — and that might be part of the problem.

It is clear Congress should be doing more to hold agencies accountable, not less. The facts show that impeachment is appropriate, but the House has to show the American people that it has the fortitude to do the right thing and finally hold this administration accountable.

Unless Congress acts, IRS Commissioner Koskinen – like Lerner, Holder, and Clinton– will be able to get away with abuse of his office as well.

Earlier this month, the House Freedom Caucus made a privileged motion on the House floor calling up articles of impeachment of Commissioner John Koskinen. The House of Representatives should immediately bring this to the floor for a vote. The American people deserve nothing less.

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July 31, 2016 in IRS News, IRS Scandal, Tax | Permalink | Comments (0)

Saturday, July 30, 2016

This Week's Ten Most Popular TaxProf Blog Posts

Tennessee Seeks To Hire A Tax Clinician

Tennessee LogoThe University of Tennessee College of Law invites applications from both entry-level and lateral candidates for two full-time, tenure-track faculty positions to commence in the 2017 Fall Semester:

Candidates should have a particular interest in either business law teaching, including business associations and contracts, or transactional clinical teaching in business, taxation, intellectual property, community economic development, or health care that offers students transferable legal skills.

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July 30, 2016 in Legal Education, Tax, Tax Prof Jobs | Permalink | Comments (0)

Hillary Clinton Moves Left On Taxes

ATRPolitico, Morning Tax: Corporate Tax Left in the Lurch?:

Hillary and Corporate Taxes, Cont'd:
Is that sound you hear the Democratic Party moving left on taxes?

Neera Tanden, a key adviser to Democratic nominee Hillary Clinton, scoffed in Philadelphia at the idea that the corporate tax rate needs a cut — noting that companies’ bottom lines seem to be doing just fine, even with the top rate of 35 percent, and suggesting that average Americans aren’t concerned over whether corporations get a lower rate.

Republicans have knocked President Barack Obama for not really having his heart in tax reform, but this White House did release a framework to reduce the corporate rate to 28 percent. (Manufacturers would have the chance to get down to 25 percent.)

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July 30, 2016 in Political News, Tax | Permalink | Comments (0)

The IRS Scandal, Day 1178

IRS Logo 2Salt Lake City Tribune, IRS Chief Says Chaffetz’s Drive to Oust Him Will Leave Few Wanting Top Federal Jobs:

IRS Commissioner John Koskinen says Utah Rep. Jason Chaffetz's relentless drive to impeach him will scare good people away from entering government service and is damaging his agency.

"If this is the signal we are sending to people thinking about coming to take a senior position in government, it's going to make it harder for good people to come in," Koskinen told reporters during a visit Wednesday to the Ogden IRS service center.

He adds that Republicans have slashed the IRS budget to punish him and the agency. With that, the Ogden center has lost 1,300 employees through attrition over the past five years — leaving about 5,000 there — and customer service is suffering.

Chaffetz, a Republican, fired back that if Koskinen wants to stop such perceived damage, "He can solve this himself by doing the right thing for the nation and stepping aside. He is so egotistical that he can't bear to do that." ...

"It goes beyond me. My concern is that no appointed official has been impeached for 140 years. So if we are suddenly, on relatively poorly supported facts, going to start attacking senior officials, people in the private sector" will have second thoughts about public service.

They will think, "It doesn't look like much fun," he said. "You get yelled at a lot in a hearing," and Congress may try "to impeach you." House Republicans even sought, he said, to reduce his salary to zero or take away his pension.

Future presidents may discover that it is "harder to find people who want to be Cabinet secretaries, deputy secretaries, agency heads," he said. "It's going to be interesting to see who wants to take this seat next." ...

Chaffetz responded in a telephone interview. "He may say it has been fixed, but the GAO [Government Accountability Office, a research arm of Congress] begs to differ."

Chaffetz said Koskinen "has not solved this problem. He has exacerbated it." Also, "I think he provided false testimony to Congress. There should be a consequence."

Koskinen said he plans to serve until his term ends in November 2017. "I have no intention of being hounded out of office." ...

Chaffetz added, "We're not going to have productive interactions with the IRS as long as he's the commissioner. ... I do think it's affecting tens of thousands of workers in a very negative way. That's his choice, not mine."

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July 30, 2016 in IRS News, IRS Scandal, Tax | Permalink | Comments (5)

Friday, July 29, 2016

Tennessee To Become Income-Tax-Free State No. 8

TennesseeForbes:  Tennessee To Become Income-Tax-Free State No. 8, by Ashlea Ebeling:

You retire to an income-tax-free state and you don’t expect to pay any income tax. So imagine the surprise a former California couple in their 60s got when they went to a tax preparer in Tennessee for help with their 2015 federal tax return, and she gave them the news that they owed $1,200 in taxes to Tennessee on their capital gains, interest and dividend income, thanks to the 6% state “Hall Tax.”

“A lot of seniors come to Tennessee, and they get a surprise: We have a tax on people who have done things correctly by saving for retirement,” says Friday Burke, an enrolled agent in Brentwood, Tenn. The retired California couple had $125,000 in overall taxable income, including $28,000 in interest, dividends and capital gains, $20,000 of which was subject to the Hall Tax. “That’s $1,200 they hadn’t budgeted,” says Burke.

The good news she was able to deliver to the couple is that the Hall Tax is on its way out. It was one of a trifecta of taxes that kept Tennessee on the list of states unfriendly to business owners and retirees. The state’s gift tax was repealed effective Jan. 1, 2012. The state’s estate tax was repealed effective Jan. 1, 2016. And now the Hall Tax is repealed—as of Jan. 1, 2022. In the meantime, the tax rate was cut from 6% to 5% retroactive to Jan. 1, 2016, and the legislature is meant to decrease the rate one percentage point a year, assuming the state meets certain revenue targets. ...

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July 29, 2016 in Tax | Permalink | Comments (1)

Federal Government To Expand Tracking Of Luxury Home Buyers To LA, San Diego, San Francisco & San Antonio

SothebyFollowing up on my previous post, Federal Government To Start Tracking Luxury Home Buyers, Beginning In Miami (>$1m), NYC (>$3m):  New York Times, U.S. to Expand Tracking of Home Purchases by Shell Companies:

More than a quarter of the all-cash luxury home purchases made using shell companies in Manhattan and Miami were flagged as suspicious in a new effort to unearth money laundering in real estate, the Treasury Department said Wednesday. As a result, officials said they would expand the program to other areas across the country.

The expansion of the effort to identify and track the people behind shell companies, begun in March, means that there will now be increased scrutiny of luxury real estate purchases made in cash in all five boroughs of New York City, counties north of Miami, Los Angeles County, San Diego County, the three counties around San Francisco and the county that includes San Antonio.

The examination, known as a geographic targeting order, is part of a broad effort by the federal government to crack down on money laundering and secretive shell companies.

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July 29, 2016 in Tax | Permalink | Comments (0)

Customers Flock To Ride-Sharing Companies Like Uber/Lyft As Higher Taxes Penalize Car-Sharing Companies Like Zipcar/Car2Go

ULZCWall Street Journal, Car-Sharing Industry Carries Heavy Tax Burden:

Local taxes put Zipcar and Car2Go at a disadvantage in competing with ride-hailing services Uber and Lyft, research by DePaul University shows.

For the millions of Americans without cars, daily errands often require a quick calculation: Is it cheaper and quicker to hail a ride, via apps such as Uber or Lyft, or to use a car-sharing service, such as Zipcar or Car2Go?

Local governments around the country are tipping the scales and helping to shape the industry’s winners and losers. In recent years, cities have increased taxes on the car-sharing industry but not ride-hailing, according to new research into the competitive landscape of the fledgling industries.

Of the 40 largest U.S. cities, 29 apply taxes of more than 10% on one-hour car-sharing trips, including nine cities with effective tax rates above 30%, according to an analysis of car-sharing taxes by Joseph Schwieterman and Heather Spray of DePaul University’s Chaddick Institute for Metropolitan Development [When Sharing Is Taxing: Comparing the Tax Burden on Carsharing Services in Major U.S. Cities] ...

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July 29, 2016 in Tax | Permalink | Comments (0)

Herzig:  Elective Taxation On Inbound Real Estate Investment

David J. Herzig (Valparaiso), Elective Taxation on Inbound Real Estate Investment, 2016 U. Ill. L. Rev. 1025:

Since 1980, the United States has taxed U.S. real property gains of foreign investors. A nonresident must pay tax on the capital gain from the sale of U.S. real property or rights in U.S. real property, as well as on the sale of shares in non-publicly held domestic corporations that hold significant U.S. real property assets. The United States imposes a withholding liability on the purchaser based on a percentage of the purchase price. Moreover, by owning U.S. real property, foreign investors are subject to Internal Revenue Service (‘‘IRS’’) investigatory powers. Because of these rules, foreign investors spend significant resources to structure investment in U.S. real property assets to avoid being deemed an owner of the underlying real property for taxation purposes. This has rendered the underlying statute, the Foreign Investment in Real Property Act of 1980 (‘‘FIRPTA’’), elective. This electivity results in the United States exhibiting tax haven characteristics for inbound real estate investments. Rather than tightening the rules to eliminate this friction, Congress has recently proposed even looser requirements. The resulting narrative by practitioners and policy makers is that FIRPTA should be eliminated. The United States currently needs more, not less, collection of taxation. The fact that FIRPTA is either easily arbitraged or not properly collected should not result in the repeal.

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

IRS Hits Facebook With $5 Billion Tax Bill

Facebook (2016)Following up on yesterday's post, Facebook Ignores Seven Summonses From The IRS Demanding Documents On Its Offshore Tax Strategies:  Bloomberg, Facebook Tax Bill Over Ireland Move Could Cost $5 Billion:

Facebook Inc.’s future cash flows and results could suffer a major blow if it loses a battle over new U.S. tax liabilities related to the transfer of its global operations to Ireland in 2010.

The Internal Revenue Service delivered a notice of deficiency to the social media giant Wednesday for $3 billion to $5 billion, plus interest and penalties, based on the agency’s audit of Facebook’s transfer pricing, the company said in a regulatory filing Thursday. Facebook, which plans to challenge the notice in federal tax court, said its balance sheet could suffer if it’s held liable.

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July 29, 2016 in Tax | Permalink | Comments (0)

The IRS Scandal, Day 1177

IRS Logo 2The Daily Signal, Justice Department Knew of IRS Scandal 2 Years Before Congress but Did Nothing:

Recently unearthed documents reveal that the FBI knew the IRS was unfairly targeting groups because of their conservative politics two years before Congress even heard about the agency’s misconduct.

The revelation has already added fodder to the conservative case to impeach the current IRS Commissioner John Koskinen.

Almost 300 pages of documents released Thursday and obtained by Judicial Watch through the Freedom of Information Act confirm that the IRS subjected conservative groups to increased scrutiny beginning in 2011.

Even though the FBI uncovered the scandal in 2011, the documents show, the Department of Justice chose not to act.

Legal Insurrection, Top IRS Officials Knew Agency Targeted Conservative Groups:

What a shock. Judicial Watch discovered that top IRS officials, including Lois Lerner and Holly Paz, knew that the agency targeted conservative groups before they told Congress.

Washington Examiner, IRS Chief's Reaction After Learning About Tea Party Targeting: 'Oh, S--t':

Then-IRS chief Steven Miller threw his pencil across the room and yelled, "Oh, s—t" when he was told in the spring of 2012 that his agency had been targeting Tea Party groups for heightened security, according to newly released documents.

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July 29, 2016 in IRS News, IRS Scandal, Tax | Permalink | Comments (3)

Thursday, July 28, 2016

Harrison:  Florida Is 'Modernizing,' Not 'Dismantling,' Its Graduate Tax Program

Florida Logo (GIF)Jeff Harrison (Florida), Please Don't Dismantle Tax!!:

In my previous post (more here) I praised the new Dean at UF. Someone, perhaps disingenuously, perhaps sincerely, wrote a comment (anonymously) asking me to list what her accomplishments are. ...  I responded with a list. ...

[O]ne of my answers was "modernize the LLM in tax."  To that I got this — yes, anonymous —  comment: "By modernizing the LLM program, do you mean by dismantling it and not hiring outstanding faculty to replace those that are retiring?"

This particular  phrasing has been used repeatedly by people who are being manipulated, in my opinion, to fight self-interested battles of those  terrified of changing a 50s style LLM program into a 21st Century LLM program to the benefit of all. Some of this has occurred evidently in a mass mailing. In fact, I expect to see  T shirts that say "Don't dismantle tax." The ANONYMOUS commentator is parroting a rumor possibly spread, encouraged, and, hatched by people at UF who are afraid of moving forward. ... Riling up students and alums to advance personal ends is pretty desperate.

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July 28, 2016 in Grad Tax Faculty Rankings, Legal Education, Tax | Permalink | Comments (18)

Law Firm Partner Sentenced To Jail For Pretending To Be A Tax Lawyer Also Claimed To Be A Columbia Tax Prof

KitchenForbes: Woman Sentenced To Jail For Pretending To Be A Tax Attorney, by Kelly Phillips Erb:

Kimberly Kitchen ... worked as an attorney in Huntingdon County, Pennsylvania, for ten years. There was just one problem: Kitchen was never actually licensed to practice law.

Kitchen lied about her background, claiming to have received a law degree, first in her class, from Duquesne University School of Law in Pittsburgh, Pennsylvania. She claimed to have passed the bar exam and received her attorney license. She even claimed to have taught trust and taxation law at the Columbia University School of Law. Kitchen had documents to back her claims up – only all of those documents were fake. Kitchen never went to law school, never passed the bar exam, and was never a licensed attorney. There is no evidence that she ever taught trust and taxation law at law school.

Nonetheless, Kitchen was able to trick her employers, as well as her colleagues, for years. At the BMZ Law Firm, she made partner. She was even appointed president of the Huntingdon County Bar Association.

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July 28, 2016 in Legal Education, Tax | Permalink | Comments (6)

Leff:  How Churches Can Vindicate Their Right to Endorse Political Candidates

Following up on yesterday's post, Chodorow & Johnston: Trump's Wrong-Headed Call For Tax-Subsidized Politicization Of The Pulpit:  Benjamin Leff (American), If Churches Really Want to Vindicate Their Right to Endorse a Candidate, It’s Easy for Them to Get into Court:

Last week, attendees at the Republican National Convention applauded loudly when Donald Trump repeated his promise that if he’s elected president, he’ll work to end the ban on political-campaign activity by tax-exempt churches.  All 501(c)(3) organizations (including churches) have been prohibited from “intervening” in a campaign for public office for over half a century, and the arguments for and against the prohibition have remained remarkably consistent for decades.  Activists on one side call for an end to the ban, which they believe is an infringement on free exercise of religion or free speech.  Activists on the other side call for the IRS to actually enforce the ban, which they argue is being flouted by (mainly) churches who thereby distort the electoral process.  A long list of academics has written articles from a wide range of perspectives, proposing a wide range of solutions (including my contribution way back in 2009).  (I also spoke about this issue a few weeks ago in Australia, at a fabulous round-table at the University of Melbourne.)  As Sam Brunson pointed out on this blog in May, the IRS is “stuck in the middle.”

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July 28, 2016 in Tax | Permalink | Comments (1)

Visualizing How Fortune 500 Companies Use Offshore Tax Havens

HowMuch.net, This Interactive Calculator Shows How Much Tax Havens Are Costing America:

Many multinational corporations use their global reach, and a fair degree of high-tech accounting, to shift their assets, profits—and taxes due—to so-called offshore tax havens. These countries have minimal corporation tax rates, drastically reducing the amount of tax these multinationals have to pay. Below is a list of the 30 U.S. companies with the biggest offshore holdings. Our calculator gives you an idea of how much more money Uncle Sam would make if all that income were declared in the U.S. 

Tax-havens-2 (2)

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July 28, 2016 in Tax | Permalink | Comments (7)

Johnson:  Paul Ryan's Republican Tax Wish List

Calvin H. Johnson (Texas), Where's the Rest of Me?: Ryan's Republican Wish List, 152 Tax Notes 105 (July 4, 2016):

House Speaker Paul D. Ryan, R-Wis., has released a wish list of what Republican House members would like to see in a tax system in the form of a plan that moves toward a cash flow consumption tax. A cash flow consumption tax is a terrific idea if it is used to raise revenue and to shift the tax burden from those without resources to those who have them, but it increases the harm that taxes do if it is used to give away revenue or shift the tax burden the other way. A cash flow consumption tax exempts from tax the return from capital, an exemption that obviously benefits those who have capital, called rich people. A cash flow consumption tax should make up for the revenue loss given over to the wealthy with higher taxes on their consumption, but Ryan’s plan would not. One of the great virtues of a cash flow consumption tax is that it would end the tax bias in favor of owner-occupied housing — selfish and wasteful investments instead of productive investments — but this plan would not.

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

IRS Launches Investigation Of Clinton Foundation

CLinton Foundation (2017)Daily Caller, IRS Launches Investigation Of Clinton Foundation:

IRS Commissioner John Koskinen referred congressional charges of corrupt Clinton Foundation “pay-to-play” activities to his tax agency’s exempt operations office for investigation, The Daily Caller News Foundation has learned.

The request to investigate the Bill, Hillary and Chelsea Clinton Foundation on charges of “public corruption” was made in a July 15 letter by 64 House Republicans to the IRS, FBI and Federal Trade Commission (FTC). They charged the foundation is “lawless.” ...

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July 28, 2016 in IRS News, Tax | Permalink | Comments (9)

Facebook Ignores Seven Summonses From The IRS Demanding Documents On Its Offshore Tax Strategies

Facebook (2016)Following up on my previous post, IRS Sues Facebook For Billions In Undervalued IP Assets In 2010 Irish Transfers: Bloomberg, Facebook Fails to Show Up for Seventh Tax Summons From IRS:

Facebook officials failed to show up after getting seven summonses from the Internal Revenue Service demanding internal corporate records on one of its offshore tax strategies, according to an IRS court filing.

U.S. authorities are examining Facebook’s federal income tax liability for the period ending Dec. 31, 2010 and are looking at whether the company understated the value of global rights for many of its intangible assets outside the U.S. and Canada that it transferred to a subsidiary in low-tax Ireland.

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July 28, 2016 in IRS News, Tax | Permalink | Comments (3)

The IRS Scandal, Day 1176

IRS Logo 2Legal Insurrection, Hillary: As President, Trump Could Use IRS to Target His Enemies:

Have you noticed that many of Trump’s critics accuse him of things he hasn’t done yet but which other people have actually done already? The latest example comes from the presumptive Democratic nominee who warns President Trump could use the IRS to target his enemies.

Imagine that.

Watch Hillary Clinton paint a picture of this potential travesty which already unfolded under President Obama.

Hillary has one thing going for her here. The media has pretty much abandoned all reportage of the IRS targeting scandal. How many average Americans even know Obama used the IRS to silence tax paying Americans in the run up to the 2012 election and got away with it?

David Reaboi made the point well on Twitter:

Tweet

If we had an honest media, Hillary would have been laughed off the stage for saying this.

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July 28, 2016 in IRS News, IRS Scandal, Tax | Permalink | Comments (2)

Wednesday, July 27, 2016

Tax Infinity And Beyond

InfinityGalya Savir (Michigan), Tax Infinity & Beyond:

Commercial activities in space are going to expand thanks to new game-changing technologies being developed by Space Entrepreneurs. These entrepreneurs have pledged to reduce the cost of accessing space, and plan to unlock new horizons for innovative space markets, such as mining space-based resources and space tourism. Signs are showing in Congress of the impact that the space technology phenomenon is having on the U.S. legal system and on other governments’ policy decisions worldwide. Realizing the promise of expanding the United States' aerospace economy has raised myriad legal challenges, one of which is the issue of taxation. Thus, there is no time like the present to review the tax rules, at both the federal and the international levels, to ensure the sustainability of a policy that is clearly in the public interest.

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

Chodorow & Johnston:  Trump's Wrong-Headed Call For Tax-Subsidized Politicization Of The Pulpit

Trump (2016)Following up on Sunday's post, Trump's Call To Repeal The Johnson Amendment And Allow Churches To Endorse Political Candidates:  

Adam Chodorow (Arizona State), Donald Trump Wants to Politicize the Pulpit:

One of the biggest applause lines of the Republican convention was Donald Trump’s call to repeal the so-called Johnson Amendment, which, among other things, conditions churches’ tax-exempt status on ministers refraining from political speech at their pulpits. Critics such as Trump argue that ministers have First Amendment speech rights, which they say the government is infringing by restricting religious organizations in this manner. ...

In truth, it’s a lot more complicated than that. With Trump, it always is. Because on closer inspection, it’s clear that the Johnson Amendment, made law in 1954, serves an important function: preventing the government from subsidizing political speech. And repealing the law could lead to more entanglement of church and state—not less. ...

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July 27, 2016 in Political News, Tax | Permalink | Comments (1)

The Top 10 Washington, D.C. Tax Law Firms

Following up on my previous post, 2017 Vault Law Firm Tax Rankings:  Above the Law, Tax Firm Power Rankings:

Over the next few months, we going to be hear A LOT about the presidential candidates' tax plans. But who is actually going to turn all of these proposals into actual laws? These people, that's who, the tax attorneys and lobbyists (who are often lawyers) in Washington, DC. While tax lawyers in, say, NYC help clients navigate the Tax Code, it is their peers in DC who exert influence on the *writing” of the laws themselves.

Here is our take on the most active and influential law firms and lobbying shops in the area of tax practice and policymaking. The law firm portion of our list comprises both elite specialist boutiques as well as top-tier full-service Biglaw firms that place a relatively outsized emphasis on tax practice in our nation’s capital. ...

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July 27, 2016 in Tax | Permalink | Comments (1)

Beyer:  Estate Planning Ramifications Of Obergefell

Gerry W. Beyer (Texas Tech), Estate Planning Ramifications of Obergefell v. Hodges:

One year ago, the Supreme Court of the United States handed down its landmark ruling in Obergefell v. Hodges holding that “same-sex couples may exercise the fundamental right to marry.” Since then, an estimated 123,000 same-sex marriages have occurred bringing the total number of same-sex marriages in the United States to almost one-half million. The number of Texas same-sex marriages will be difficult to track because the government does not plan on keeping a separate count of same-sex marriage licenses. Nonetheless, with over three percent of Texans identifying themselves as gay or lesbian, it is of vital importance for estate planners to understand the current and potential future impact of same-sex marriage on estate planning in Texas.

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

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 July 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.)

57,604

Reuven Avi-Yonah (Mich.)

10,365

2

Michael Simkovic (S. Hall)

32,823

Michael Simkovic (S. Hall)

4681

3

Paul Caron (Pepperdine)

31,655

D. Dharmapala (Chicago)

3272

4

D. Dharmapala (Chicago)

27,217

Paul Caron (Pepperdine)

2747

5

Louis Kaplow (Harvard)

26,223

Richard Ainsworth (BU)

2437

6

Vic Fleischer (San Diego)

22,473

Robert Sitkoff (Harvard)

1975

7

James Hines (Michigan)

21,901

Jeff Kwall (Loyola-Chicago)

1926

8

Ted Seto (Loyola-L.A.)

21,161

Nancy McLaughlin (Utah)

1913

9

Richard Kaplan (Illinois)

21,156

Chris Hoyt (UMKC)

1778

10

Ed Kleinbard (USC)

19,974

Omri Marian (UC-Irvine)

1744

11

Katie Pratt (Loyola-L.A.)

19,005

David Weisbach (Chicago)

1738

12

Richard Ainsworth (BU)

18,197

Louis Kaplow (Harvard)

1736

13

Robert Sitkoff (Harvard)

17,362

William Byrnes (Texas A&M)

1731

14

Carter Bishop (Suffolk)

17,080

Dan Shaviro (NYU)

1681

15

Brad Borden (Brooklyn)

17,036

Ed Kleinbard (USC)

1520

16

David Weisbach (Chicago)

16,971

Vic Fleischer (San Diego)

1493

17

Jen Kowal (Loyola-L.A.)

16,675

Yariv Brauner (Florida)

1445

18

Chris Sanchirico (Penn)

16,513

Brad Borden (Brooklyn)

1441

19

Francine Lipman (UNLV)

16,147

Katie Pratt (Loyola-L.A.)

1417

20

Dennis Ventry (UC-Davis)

16,110

Jack Manhire (Texas A&M)

1390

21

Bridget Crawford (Pace)

15,673

Francine Lipman (UNLV)

1360

22

Dan Shaviro (NYU)

15,105

Richard Kaplan (Illinois)

1330

23

David Walker (Boston Univ.)

15,071

Steven Bank (UCLA)

1265

24

Steven Bank (UCLA)

13,410

Jordan Barry (San Diego)

1255

25

Herwig Schlunk (Vanderbilt)

13,175

Gregg Polsky (N. Carolina)

1223

Note that this ranking includes full-time tax professors with at least one tax paper on SSRN, and all papers (including non-tax papers) by these tax professors are included in the SSRN data.

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July 27, 2016 in Scholarship, Tax, Tax Prof Rankings | Permalink | Comments (0)

AALS Call For Participation: Discussion Group On The Future Of Tax Administration And Enforcement

AALS (2018)AALS, Call for Participation in a Discussion Group on The Future of Tax Administration and Enforcement:

The Annual Meeting Program Committee introduced a new program format, Discussion Groups, at the 2016 Annual Meeting to facilitate scholarly discussion and engagement. Discussion Groups provide a small group of faculty an opportunity to engage in a sustained conversation about a topic of interest. The objective is to facilitate a lively and engaging real-time discussion among participants. Discussion Group participants will typically be expected to write and share a short presentation summary (3-5 pages) as part of their participation. The Discussion Group sessions, however, will not feature formal presentations. Instead, the written summaries are intended to facilitate a lively and engaging real-time discussion among the participants. Participants in this Discussion Group will consist of a mix of the people identified in the original proposal along with additional individuals selected on the basis of this call for participation. There will be limited audience seating for those not selected in advance to be discussion participants.

The following is a Call for Participation in a Discussion Group on The Future of Tax Administration and Enforcement, to be held at the AALS Annual Meeting, Saturday, January 7, 2017 from 8:30–10:15 am, in San Francisco.

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July 27, 2016 in Conferences, Legal Education, Scholarship, Tax | Permalink | Comments (0)

The IRS Scandal, Day 1175

IRS Logo 2Hot Air, Hillary: Can You Imagine Electing a Vindictive Man Who Might … Send the IRS After His Critics?:

You know what? I can imagine it. Pretty vividly, actually. Right down to the names of the “hypothetical” IRS officers involved.

Of all the examples she could have cited to make the point that Trump is a loose cannon, how did she and her speechwriters conclude that this was one worth floating? I understand calling him out for wanting to issue illegal orders to the military; that’s the most alarming thing he’s said since he got in the race. But attacking Trump over a potential IRS gone rogue is like attacking him for potentially wanting to intervene in foreign civil wars without Congress’s approval. We’ve seen that movie already. In fact, Hillary Clinton produced that movie.

Even lamer, if the IRS decides to start taking down political enemies, it’s more likely they’d focus on taking down President Trump himself than his adversaries. Judging by their political donations, IRS employees lean in exactly the partisan direction you’d expect the taxman to lean. Obama didn’t need to tell Lois Lerner to target tea partiers. That sort of thing would occur to her naturally given the agency’s institutional lean.

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July 27, 2016 in IRS News, IRS Scandal, Tax | Permalink | Comments (3)