Richard C. Pugh, a long-time tax professor at San Diego, passed away on December 5 after a battle with cancer. From Dean Stephen Ferruolo:
Dick taught and wrote in the areas of corporate tax, international tax, international law, international criminal law and human rights. He joined our law faculty in 1989 after a prestigious career at Columbia University School of Law. Dick was instrumental in building USD's tax program. He not only set a standard of excellence that helped build the reputation of the law school, he was a paragon of the civility and collegiality that has endured among our distinguished faculty.
From Ed Kleinbard:
Richard Pugh, one of the leading international tax law scholars of his generation, and a mentor to hundreds of practicing lawyers and younger scholars, passed away Sunday.
Dick was a Rhodes Scholar. He joined Cleary Gottlieb Steen and Hamilton as an associate in 1958. He left for a time to become a Professor of Law at Columbia Law School, and in 1966-1968 served as Deputy Assistant Attorney General in the Tax Division of the Department of Justice. Dick returned to Cleary Gottlieb as a partner in July 1969.
In 1989, Dick joined the faculty of the University of San Diego School of Law, where he was instrumental in building USD's tax program. At USD, Dick taught and wrote in the areas of corporate tax, international tax, international law, international criminal law and human rights.
Dick set a standard of excellence that helped build the reputation of every institution with which he was affiliated. He was a paragon of the civility and collegiality that made one proud to be his colleague, and his calming presence and mentoring talents made a very significant contribution to the lives of all who were fortunate enough to work with him.
A memorial service will be held on December 23 at 11:00 AM at the Church of the Epiphany at 5450 Churchwood Dr, Oak Park, CA 91377, with a lunch reception to follow at his son Rich’s home in Westlake Village, California.
Dick's work at San Diego is remembered in the annual Richard C. Pugh Lecture in Tax Law & Policy:
- 2010: Eric Solomon (Director of National Tax Practice, Ernst & Young)
- 2011: Carr Ferguson (San Diego/Davis Polk & Wardwell)
- 2013: Stephen Shay (Harvard)
- 2014: Ed Kleinbard (USC)
- 2015: Michael Graetz (Columbia/Yale)
I was honored to get to know Dick during my eleven summers teaching at San Diego and to participate in the tribute to Dick published at the 2010 dedication of his lecture series. I am reprinting below the spotlight profile of Dick I published in June 2004:
Richard Pugh has led the consummate tax life, with high powered positions in private practice, public service, and legal education.
After graduating from Dartmouth in 1951, Professor Pugh studied at Oxford as a Rhodes Scholar and spent three years as a naval officer before returning to the U.S. to earn his J.D. from Columbia Law School (where he was an editor of the Law Review). After 3 years as a tax associate at Cleary, Gottlieb, Steen & Hamilton in New York City, he returned to Columbia in 1961 as a Professor of Law teaching courses in tax and international law.
Professor Pugh remained on the Columbia faculty for 8 years, interrupted by 2 years of public service as Deputy Assistant Attorney General in the Tax Division of the U.S. Department of Justice. In 1969, he returned to private practice as a tax partner at Cleary, Gottlieb where he enjoyed an extraordinary 20-year career representing some of the leading national and international corporations in tax matters. He also continued to teach 1 tax course per year as an Adjunct Professor at Columbia.
Professor Pugh began the final chapter of his tax career in 1989 when he returned to academia and accepted a position as Distinguished Professor of Law at the University of San Diego, joining an already strong tax faculty of Bert Lazerow, Virginia Shue, and Lester Snyder. Over the past 15 years, Professor Pugh has been a productive scholar, perhaps best known as the co-author of three leading casebooks: Taxation of Business Enterprises (West Group, 2d ed. 2002), Taxation of International Transactions (West Group, 2d ed. 2001), and International Law (West Group, 4th ed. 2001), as well as coordinating editor of the annual International Income Taxation: Code and Regulations–Selected Sections (CCH). His most recent law review article was published as the lead article in the inaugural issue of the San Diego International Law Journal: Policy Issues Relating to the U.S. Taxation of Foreign Persons Engaged in Business in the United States Through Agents: Some Proposals for Reform, 1 San Diego Int’l L.J. 1 (2000).
Although Professor Pugh is in phased retirement at USD, he continues to teach a full load in the spring term and remains an active scholar, with revised editions of his casebooks and code and regulations volume in the works.
Throughout his long tax career, Professor Pugh has held various leadership posts within the academy and profession. He is a fellow of the American College of Tax Counsel and a member of the American Law Institute. He is the former chair of The Tax Forum and past president of the U.S.A. Branch of the International Fiscal Association.
Professor Pugh’s tenure at the University of San Diego has coincided with the schools’s meteoric rise into the top echelons of American law schools, both generally and with respect to its tax program. In recent years, USD has made a number of noteworthy lateral hires of top scholars from other law schools, including tax stars Karen Burke (from Minnesota) and Grayson McCouch (from Miami).
In his most recent survey of law school faculty quality, Texas law professor (and rankings guru) Brian Leiter rates USD as having the 22nd best faculty among the 180 law schools (and thus confirming his earlier observations that USD was on a "steep upward trajectory" and was "on the verge of cracking the 'big leagues' of the great law school hierarchy").
In the most recent U.S. News & World Report tax rankings, USD is 11th overall and 6th among law schools with graduate tax programs. Indeed, USD’s tax program is the highest ranked program west of the Mississippi River. USD's program is strengthened by the involvement of several national tax figures, including M. Carr Ferguson (Senior Counsel at Davis Polk & Wardwell) as Executive Advisor; Richard Shaw (Chair of the ABA Tax Section) as Distinguished Adjunct Professor; and the Honorable David Laro (U.S. Tax Court Judge) as Visiting Professor.
By his own account, Professor Pugh is an avid tennis player and inept golfer. His legions of San Diego students have enjoyed his sense of humor – he has summered in Vermont for over 25 years and collected various examples of Vermont lore that he deploys in class to provide much-needed relief from the rigors of tax law.
Professor Pugh is off this summer to celebrate his 50th anniversary and 75th birthday with his wife, three children and their spouses, and seven grandchildren – his greatest legacy.
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