Monday, September 18, 2006
The University of Minnesota Law School is hosting a symposium on October 27, 2006 on The Future of Tax Shelters:
Tax shelter activity has been widespread for decades. IRS attempts to curtail that activity have met with mixed results. For a time, it seemed that the IRS might have succeeded as never before, as Congress held hearings, the Treasury Department substantially expanded tax shelter disclosure requirements, and the Department of Justice brought criminal prosecutions against several KPMG tax professionals. Recently, however, there has been pushback from the courts, the tax profession, and even Congress. Did the government overreach and target legitimate business activity? Was the KPMG-prompted decline merely a cyclical downturn, to be followed by a return to previous levels of tax shelter activity? What will the future hold for tax shelters?
This conference will bring together top tax scholars and professionals as well as scholars from other disciplines who are thinking about tax shelters from different perspectives to evaluate the present and future of tax shelters.
Keynote Speaker: Pamela Olson (Skadden, Arps, Slate, Meagher & Flom; former Assistant Secretary of the Treasury (Tax Policy))
Papers (to be published in the Virginia Tax Review):
- Tax Investment Strategies, Business Method Patents, and the Firm, by Dan L. Burk (Minnesota) & Brett H. McDonnell (Minnesota)
- Legal Evolution and Gaming the System, by Philip Curry (Simon Fraser University) & Claire A. Hill (Minnesota)
- Tax Shelters: Intentionalism’s Greatest Challenge, by Lawrence M. Solan (Brooklyn)
- In Defense of Tax Shelters, by Leo Katz (Penn)
- Of Lenity, Chevron, and KPMG, by Kristin E. Hickman (Minnesota)
- Options Backdating and Corporate Culture, by Victor Fleischer (Colorado)
- State Tax Shelters and State Taxation of Capital, by Joseph Bankman (Stanford)