Friday, July 8, 2016
NY Times Op-Ed: EITC Is Better Tool To Raise Incomes Than 'Economic Russian Roulette' Of $15/Hour Minimum Wage
- The Atlantic, How to Force Donald Trump to Release His Tax Returns
- American Enterprise Institute, Is Corporate Integration a Good Idea?, by Alan Viard
- Bloomberg, Messi’s 21 Months in Prison Is Another Penalty He May Miss
- Bloomberg, Wells Fargo’s Partial Tax Victory May Spur Billions in Refunds, by Lynnley Browning
- Dan French (Missouri) & McKay Price (Lehigh), Depreciation-Related Capital Gains, Differential Tax Rates, and the Market Value of Real Estate Investment Trusts
- Fabio Gaertner, Stacie Laplante & Dan Lynch (Wisconsin), Trends in the Sources of Permanent and Temporary Book-Tax Differences During the Schedule M-3 Era
- Carlo Garbarino (Università Bocconi, Milan), The Development of the Comparability Analysis by the Court of Justice of the European Union in the Context of Capital Income Taxation, 21 Colum. J. Eur. L. 451 (2015)
- Philip Manns (Liberty) & Timothy Todd (Liberty), Issues Arising Upon the Death of the Sole Member of a Single-Member LLC, 99 Marq. L. Rev. 725 (2016)
Bloomberg: IRS Takes Facebook to Court, Signaling Start of Tougher Approach, by Lynnley Browning & Kartikay Mehrotra:
TIGTA: IRS May Have Allowed 60% Of Former Employees (Including Those Subject To Disciplinary Proceedings) Access To Buildings, Computers
Thursday, July 7, 2016
17 Tax Profs Submit Comments To Treasury Department On Earnings Stripping, Serial Inversion Proposed Regs
FROM THE CHAIR
Assisting the IRS
The IRS now more than ever needs the help of the Section and its members. This column describes some of the ways that the Section is providing assistance to the IRS.
PEOPLE IN TAX
The Tax Ghosts of Christmas Past, Christmas Present, and Christmas Yet to Come
In this issue of ATT, People in Tax deviates from its traditional interview format to present the remarks of Terence F. (Terry) Cuff, which he delivered at the Real Estate and Partnerships & LLCs Luncheon on January 29 at the 2016 Midyear Meeting in Los Angeles.
Speculation abounds on the impact on pending cases and major issues, such as abortion and the Second Amendment, of Justice Scalia’s departure from the Supreme Court. Some have tried to focus that speculation on tax issues, but that effort faces two hurdles.
DNC Lacks 501(c)(3) Exemption For Philadelphia Convention, Putting Donors' Charitable Deductions At Risk
Wednesday, July 6, 2016
Following up on my previous posts on Altera Corp. & Subs. v. Commissioner, 145 T.C. No. 3 (July 27, 2015), in which the Tax Court unanimously (15-0) invalidated the Section 482 stock-based compensation cost sharing regulations:
- TaxProf Blog op-ed: Altera Corp. & Subs. v. Commissioner: The Tax Court Delivers An APA-Based Smackdown, by Kristin Hickman (Minnesota)
- Alphabet Could Be Big Winner If Intel Wins Altera Appeal In 9th Circuit
Two groups of tax professors have filed amicus briefs with the 9th Circuit on behalf of the IRS:
Natelson: The Meaning Of The Constitution's Financial Terms, Including 'Tax,' 'Direct Tax' And 'Apportionment'
Tuesday, July 5, 2016
Harry Grubert (U.S. Treasury Department) & Rosanne Altshuler (Rutgers), Shifting the Burden of Taxation from the Corporate to the Personal Level and Getting the Corporate Tax Rate Down to 15 Percent, 69 Nat'l Tax J. ___ (2016):
Updated Emmanuel Saez Inequality Data: Bottom 99% Had Income Party Like It's 1999, But Top 1% Did Twice As Well
Emmanuel Saez (UC-Berkeley), U.S. Top One Percent of Income Earners Hit New High in 2015 Amid Strong Economic Growth (July 1, 2016):
Emmanuel Saez (UC-Berkeley), Striking it Richer: The Evolution of Top Incomes in the United States (Updated with 2015 Preliminary Estimates) (June 30, 2016):
GAO: IRS's 30% Error Rate With Refundable Tax Credits Results In $30 Billion In Annual Erroneous Payments
- This Week's Ten Most Popular TaxProf Blog Posts
- Chronicle: Highly Ranked Law Schools Like Minnesota, Washington & Lee Cut Enrollments, Costs To Survive
- Did Trump Violate IRS Rules By Using His Foundation's Money To Purchase Tebow-Signed Helmet (Now Worth $415) For $12,000?
- Law Prof Network Blogger's Work Helps Get New Trial For Serial's Adnan Syed
- The IRS Scandal, Day 1150
- Charlene Luke Succeeds Marty McMahon As Editor-In-Chief Of The Florida Tax Review
- Update On Murder-For-Hire Investigation Into Dan Markel's Death: Charlie Adelson Denies 'Any Involvement'
- The Top 5 Tax Paper Downloads
- Hundreds Of Churches Offer 90-Day Money-Back Tithing Guarantees
- The IRS Scandal, Day 1151
- Tax Like It Is July 4, 1776
- Pittsburgh Seeks To Hire An Entry-Level Or Junior Lateral Tax Prof
- Amidst 26% Enrollment Decline, West Virginia Law School Accelerates Faculty And Staff Downsizing With Buyouts
- Exploring American Taxes: Then & Now
- The IRS Scandal, Day 1152
Monday, July 4, 2016
Tax Policy Blog: Independence Day: Taxes Then and Now, by John Olson:
Sunday, July 3, 2016
Charlene D. Luke has been named Editor-in-Chief of the Florida Tax Review, succeeding Martin J. McMahon, Jr. Prof. McMahon and the other tax faculty at the University of Florida Levin College of Law will continue as members of the editorial board, and the Florida Tax Review will continue to draw on the talent of several graduate tax student editors. A board of advisors comprising tax faculty at other institutions provides additional support and guidance. The Florida Tax Review will begin reviewing new submissions on August 1, 2016.
There 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 news papers debuting on the list at #4 and #5:
- [349 Downloads] Following the Money: Lessons from the Panama Papers, Part 1: Tip of the Iceberg, by Lawrence Trautman (American)
- [264 Downloads] Why Does Inequality Matter? Reflections on the Political Morality of Piketty's Capital in the Twenty-First Century, by Liam Murphy (NYU)
- [224 Downloads] 'Death Tax' Politics, by Michael J. Graetz (Columbia)
- [197 Downloads] Fiduciary Financial Advice to Retirement Savers: Don't Overlook the Prudent Investor Rule , by Max M. Schanzenbach (Northwestern) & Robert H. Sitkoff (Harvard)
- [159 Downloads] The President's Power To Tax, by Daniel Hemel (Chicago)
Saturday, July 2, 2016
- Temperature Rises In Debate Over NY Times Coverage Of The Law School Crisis
- Update On Murder-For-Hire Investigation Into Dan Markel's Death: Hit Men Thwarted In Previous Attempt To Kill FSU Law Prof
- Department Of Education Panel Recommends Suspension Of ABA's Power To Accredit Law Schools Due To Its 'Lack Of Attention To Student Achievement'
- More On The Possible Suspension Of The ABA's Power To Accredit Law Schools
- CBO: The 2016 Budget Outlook
- Amidst 57% Enrollment Decline At Valparaiso Law School, 10 Tenured Faculty Accept Buyouts And 3 Junior Faculty Will Be Terminated
- California Law School To Close Unless A Buyer Is Found
- Law Students May Use Department Of Education's New Fraud Defense To Loan Repayment Aimed At For-Profit Colleges To Discharge Law School Loans
- Hoffman: The Futility Of The Law School Crisis Debate
- The Tax Consequences Of Brexit
Did Trump Violate IRS Rules By Using His Foundation's Money To Purchase Tebow-Signed Helmet (Now Worth $415) For $12,000?
Friday, July 1, 2016
- Bloomberg, Hedge Funds Still Can't Figure Out a Way to Avoid a $25 Billion Tax Bill
- Bloomberg, Hong Kong’s Richest Man Calls for Higher Tax Amid Wealth Gap
- Bloomberg, Oil Investor Zukerman Pleads Guilty in Tax Evasion Case
- Bloomberg, Paul Ryan's Tax Blueprint Looks A Lot Like Trump's
- John Gallemore (Chicago), Brandon Gipper (Chicago) & Edward Maydew (North Carolina), Banks As Tax Planning Intermediaries
- Erik Jensen (Case Western), Direct Taxes – Article I, Section 9, Clause 4
- Erik Jensen (Case Western), Income Tax – Amendment XVI
- Richard Krever (Monash) & Borbala Kolozs (Corvinus), Hungary, GAARs – An Emerging Trend in the Tax Landscape
NBA free agency kicked off at midnight. How important are state tax considerations to players in choosing which team to join? Kevin Durant reportedly is courting six suitors, two of whom are in states without an income tax: Miami and San Antonio (the others are Boston, Golden State, Los Angeles (Clippers) and Oklahoma City.) Given his recent tax troubles, Durant may be particularly sensitive to tax considerations in making his free agency decision. See Slam Online, The Influence of State Taxes on NBA Free Agency:
Allison Christians (McGill University), Not So Soft Law: The OECD BEPS Regime
Discussant: John Vella (Oxford University)
Dominika Langenmayr (KU Eichstatt-Ingolstadt & CESifo), Why The Current Tax Rate Tells You Little: Competing for Mobile and Immobile Firms
Discussant: Johannes Voget (University of Mannheim)
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Investor's Business Daily editorial, IRS Scandal: No End To Lois Lerner's Lawlessness:
- American Thinker, New Docs Show IRS's Lois Lerner Broke the Law
- PJ Media, New Docs Show That IRS's Lois Lerner Broke the Law
- WND, New Finding Suggests IRS' Lerner Likely Broke Law
Thursday, June 30, 2016
As Pepperdine's summer session winds down, my wife and I hosted our third and final lunch today with my small but plucky tax class. This summer has marked several firsts for me: my first summer teaching at Pepperdine (after 11 summers teaching at San Diego); my first time teaching such a small (7 students) class; and my first time switching to a new casebook in 25 years of law teaching.