Monday, December 17, 2018
FROM THE CHAIR
The Tax Section Serving the Tax System
By Eric Solomon (Ernst & Young, Washington, D.C.)
The Tax Section held its Fall Tax Meeting with the Trust & Estate Division of the Real Property, Trust & Estate Law Section in Atlanta on October 4-6. Over 950 people attended. There was much to discuss, especially the recent regulatory guidance relating to the 2017 Tax Act.
PEOPLE IN TAX
Interview with Patricia A. Cain
By Thomas D. Greenaway (KPMG, Boston, MA)
The Tax Times interviewed Professor Patricia Cain from Santa Clara University. Professor Cain writes frequently about taxation and estate planning for same-sex couples and has co-authored one of the leading texts used in Sexuality and the Law courses.
AT COURT IN BRIEF
Update on U.S. Tax Court’s Opinion in Altera
On July 27, 2015, the Tax Court decided Altera Corp, ruling for Intel (Altera’s parent company) on the basis that the government had failed to engage in “reasoned decisionmaking” in issuing the cost-sharing regulations.
Hotel Valuation: Deduction for the Return on FF&E
By Gauri S. Samant (Fredrikson & Byron P.A., Minneapolis, MN)
An operating hotel is an amalgamation of distinct but essential components that contribute to its value: real property (land and improvements) as well as non-realty items including: (1) personal property (furniture, fixtures, and equipment or FF&E) and (2) intangible property (such as franchise brand or flag, goodwill, contracts, and reputation). As many jurisdictions tax only real property, valuing a hotel for property tax purposes involves distinguishing the real property components from the personal property components and the intangible property components.
States Work to Avoid Impact of TCJA Limitation on State and Local Tax Deduction and IRS Weighs in on Attempted Workarounds
By Jaye Calhoun (Kean Miller, New Orleans, LA)
Since the amendment of Internal Revenue Code section 164(b)(6) to limit joint filing taxpayers' deduction for state and local taxes to $10,000 annually (pursuant to the 2017 tax legislation, frequently called the Tax Cuts and Jobs Act or TCJA, P.L. 115-97), a number of states have considered or enacted various workaround measures to avoid or mitigate the effect of the new limitation on their residents.
PRO BONO MATTERS
Georgia on My Mind
By Francine J. Lipman (William S. Boyd School of Law, UNLV)
Pecans, peaches, peanuts, a possum named Pogo, and a progressive state income tax made Georgia the perfect place for the Section’s October 2018 meeting.
An Interview with 2017-2019 Christine A. Brunswick Public Service Fellow Catherine Martin
Throughout the country, cities have taken steps to revitalize urban neighborhoods to attract young upwardly mobile residents who prefer to live in dense urban areas. As these neighborhoods increase in attractiveness, property tax values also increase. ATT recently contacted Catherine Martin to discuss the important work she is doing through her fellowship.
Choose the TAPS Endowment for Your Year-End Giving and Supporting our Public Service Fellows
Through the Tax Assistance Public Service (TAPS) endowment fund, the Section of Taxation seeks to provide stable, long-term funding for its tax-related public service programs.
PATHS IN TAX
A Conversation with Drita Tonuzi
The following is a lightly edited and abridged version of the May 2018 Tax Bridge to Practice conversation between Kelley C. Miller, Reed Smith, Washington, DC, and Drita Tonuzi, Deputy Chief Counsel for Operations at the Internal Revenue Service.
IN THE STACKS
Review of Concrete Economics
By Bree Ermentrout (U.S. Department of Defense, Springfield, VA)
Politicians, economists and policymakers hotly debate the means to economic growth. These debates often focus on the size of government or the scale of government regulation. Berkeley’s Cohen and Delong argue that today’s ideological debates run counter to the economic history of the United States.
There Is No Place Like the House
By Robert S. Steinberg (Law Offices of Robert S. Steinberg, Palmetto Bay, FL)
To tune of “There is Nothing Like a Dame,” by Rodgers and Hammerstein from the Broadway show and movie, “South Pacific.”
NEWS & ANNOUNCEMENTS
Government Submissions Boxscore
Government submissions are a key component of the Section's government relations activities. The full archive is available to the public on our website.
Accepting Nominations for the 2019 Janet Spragens Pro Bono Award
The Section of Taxation Pro Bono Award Committee is seeking nominations for the 2019 Janet Spragens Pro Bono Award. This award was established in 2002 to recognize one or more individuals or law firms for outstanding and sustained achievements in pro bono activities in tax law.
Accepting Nominations for the 2019 Nolan Fellowships
Named for the late Jack Nolan, a dedicated and respected Tax Section member, the Nolan Fellow distinction is awarded to young lawyers who are actively involved in the Section and have shown leadership qualities.
ABA-Wide Cyber Monday 2018 Sale
Save the date for this year's Cyber Monday sale!
TaxIQ: 2018 Fall Tax Meeting Materials Available
Did you know that Tax Section members have access to thousands of pages of cutting-edge committee program materials presented at Section of Taxation Meetings?
The Tax Lawyer - Summer 2018 Issue Is Available
The Tax Lawyer, the nation’s premier tax law journal, is published quarterly as a service to members of the Tax Section.
Call for Content: The Tax Lawyer, State and Local Tax Edition
The editors of the summer edition welcome inquiries, proposals and submissions of content for the 2019 edition.
The Practical Tax Lawyer - November 2018 Issue Is Available
Produced in cooperation with the Tax Section and published by ALI-CLE, The Practical Tax Lawyer offers concise, practice-oriented articles to assist lawyers with all aspects of tax law.
Get Involved in ATT
ABA Tax Times (ATT) is looking for volunteers to join its ranks as associate editors to assist in writing and acquiring articles for publication.
ABA Tax Times Community
The ABA Tax Times Community is an online platform for Section of Taxation members to join and interact with fellow ATT readers.