Paul L. Caron
Dean




Monday, September 20, 2021

ABA Tax Section Virtual 2021 Fall Meeting

This week's ABA Tax Section virtual 2021 Fall Meeting (program) kicks off today. The highlight is:

ABA Fall Meeting CoverTeaching Taxation: Promoting Diversity, Equity, and Inclusion in Tax: Ideas and Resources for Mentoring Diverse Students and Leading Discussions of DEI in Tax (Wednesday, 12:30 - 2:00 PM ET):

This panel will document the need for greater diversity in the field of tax law − in practice and in Academia – and share ideas to promote this goal, with a focus on law students and recent law school graduates. The panelists will (1) provide information about existing programs to promote DEI in the tax profession, (2) discuss ways to build the tax profession pipeline, to recruit and retain diverse tax attorneys, and to provide strong platforms for professional success, and (3) solicit audience participation and ideas for new initiatives. 

  • Alice Abreu (Temple)
  • Caroline Ciraolo (Kostelanetz & Fink; Inaugural Vice Chair, Membership, Diversity, and Inclusion, Tax Section Council, ABA)
  • Steven Dean (Brooklyn)
  • Katie Pratt (Loyola-L.A.) (moderator)
  • Juan Vasquez (Judge, U.S. Tax Court)
  • Lany Villalobos (Kirkland & Ellis; Assistant Secretary, Tax Section Council, ABA; Immediate Past-Chair, ABA Tax Section Diversity Committee

Other Tax Profs with speaking roles include:

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September 20, 2021 in ABA Tax Section, Conferences, Tax, Tax Conferences | Permalink

Tuesday, September 7, 2021

ABA Tax Section Releases 21st Annual Law Student Tax Challenge Problem

The ABA Tax Section has released the J.D. Problem (rules; entry form) and LL.M. Problem (rules; entry form) for the 21st Annual Law Student Tax Challenge:

ABA Tax Section Law Student Tax Challenge (2021-22)An alternative to traditional moot court competitions, the Law Student Tax Challenge (LSTC) is organized by the Section’s Young Lawyers Form. The LSTC asks two-person teams of students to solve a complex business problem that might arise in everyday tax practice. Teams are initially evaluated on two criteria: a memorandum to a senior partner and a letter to a client explaining the result. Based on the written work product, six teams from the J.D. Division and four teams from the LL.M. Division receive a free trip to the Section’s Midyear Meeting, where each team presents its submission before a panel of judges consisting of the country’s top tax practitioners and government officials, including tax court judges. The competition is a great way for law students to showcase their knowledge in a real-world setting and gain valuable exposure to the tax law community.

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September 7, 2021 in ABA Tax Section, Legal Education, Tax, Teaching | Permalink

Wednesday, August 18, 2021

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 74, No. 4 (Summer 2021):

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August 18, 2021 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink

Friday, July 16, 2021

ABA Tax Section Women's Tax Forum Hosts Zoom Tea Today With Patricia Gimbel Lewis

The ABA Tax Section Women's Tax Forum is hosting a Zoom Tea today with Patricia Gimbel Lewis (Caplin & Drysdale) at 4:30 PM ET:

Aba-tax-section-women-in-tax-forumYou're invited to join the next Women in Tax Forum Zoom Tea! Take a 45-minute tea break with us as we chat on Zoom video with leading women tax lawyers from a variety of fields who share stories of success and struggle as we explore individual paths to professional and personal fulfillment.

We're honored to announce that Pat Lewis is joining us in July! With 50 years of experience as a tax attorney, Pat is a true pioneer for women in tax. Pat's practice at Caplin & Drysdale has long focused on transfer pricing issues, competent authority matters, and other aspects of international tax planning and controversy. She has been an advocate for transfer pricing "safe harbors" and other tax simplification approaches. 

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July 16, 2021 in ABA Tax Section, Legal Education, Tax | Permalink

Tuesday, July 6, 2021

Call For Articles: The Tax Lawyer

ABA Tax Lawyer (2021)Why Publish in The Tax Lawyer?:

“As an author, I always welcome the opportunity to publish with The Tax Lawyer, the outstanding peer-reviewed tax journal that reaches the widest possible audience of academics, practitioners, and government officials. The Tax Lawyer editors and staff are dedicated to ensuring publication in a timely manner of the highest quality articles, consistent with the publication’s commitment to serve the wider tax community and deepen understanding of significant tax issues.” —Karen Burke, University of Florida Levin College of Law

The Tax Lawyer is unique among tax journals for its focus on cutting-edge practical long-form scholarship. It is the only publication whose editorial board consists both of deeply experienced practitioners and academics, and whose audience reflects the diversity of practice one finds in the ABA Tax Section.” —Bryan Camp, Texas Tech University School of Law

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July 6, 2021 in ABA Tax Section, Legal Education, Scholarship, Tax, Tax Scholarship | Permalink

Wednesday, June 30, 2021

U.S. Tax Court's Tax Trailblazers: Judges Joseph Gale And Albert Lauber

U.S. Tax Court's Diversity & Inclusion Series, Tax Trailblazers: Mentoring the Next Generation:

Judges-gale-and-lauberPlease join the United States Tax Court for the next in its series of monthly programs celebrating diversity and inclusion in tax law.

Moderated by Judge Tamara W. Ashford, June’s webinar celebrates LGBTQ+ Pride Month with its focus on Tax Court Judges Joseph H. Gale and Albert G. Lauber. Today at 7:00-8:15 PM EST (register here).

Judge Joseph H. Gale holds an A.B. in Philosophy from Princeton University and a J.D from the University of Virginia School of Law. He practiced law as an Associate Attorney with Dewey Ballantine and with Dickstein, Shapiro and Morin before working on Capitol Hill. He served as Tax Legislative Counsel for Senator Daniel Patrick Moynihan, and in several positions, including Chief Tax Counsel and minority Staff Director and Chief Counsel for the Senate Finance Committee, before being appointed to the Tax Court for his initial term by President Clinton. Judge Gale was reappointed by President Obama for a term ending in 2026.

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June 30, 2021 in ABA Tax Section, Tax, Tax News | Permalink

Thursday, June 17, 2021

The Tax Lawyer Transitions Editorial Leadership

ABA, The Tax Lawyer Transitions Editorial Leadership:

ABA Tax Lawyer (2019)Longtime member of The Tax Lawyer editorial team William H. Lyons ends his service as Associate Editor-in-Chief with the journal’s summer 2021 issue. As an editor for the journal since 2007, Lyons has reviewed submissions and edited articles accepted for publication other than the articles reviewed and edited by the journal’s State and Local Tax team. Lyons is the Richard H. Larson Professor of Tax Law Emeritus at the University of Nebraska College of Law. ...

The incoming Associate Editor-in-Chief is Gil Rothenberg, who currently serves as Adjunct Professor of Law at American University’s Washington College of Law. Rothenberg was a long-time attorney in the Justice Department Tax Division’s Appellate Section. He served 15 years as Chief of the Appellate Section overseeing a staff of about 50 attorneys and support personnel. Rothenberg began his Tax Lawyer work in May. ...

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June 17, 2021 in ABA Tax Section, Tax, Tax Scholarship | Permalink

Wednesday, June 16, 2021

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 74, No. 3 (Spring 2021):

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June 16, 2021 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink

Friday, June 11, 2021

ABA Tax Section Women's Tax Forum Hosts Zoom Tea Today With Angela Spencer-James

The ABA Tax Section Women In Tax Forum is hosting a Zoom Tea today with Angela Spencer-James (C-Suite Advisor, Global DEI Leader, and former EY Partner/Principal) at 4:30 PM ET:

ABAYou're invited to join the next Women in Tax Forum Zoom Tea! Take a 45-minute tea break with us as we chat on Zoom video with leading women tax lawyers from a variety of fields who share stories of success and struggle as we explore individual paths to professional and personal fulfillment.

We're thrilled to announce Angela Spencer-James is joining us in June! Angela is a senior business executive with a track record of success in leadership roles directing client and internal firm initiatives. Angela recently capped a 27-year career with EY (1991-1993, 1997-2020), including as Partner for more than 16 years using her technical tax expertise advising clients. As a Principal and leader in U.S. Federal Tax Consulting, she was also responsible for creating a successful tax business platform, including all aspects of general management, marketing, sales, product development, employee management, and P&L management.

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June 11, 2021 in ABA Tax Section, Legal Education, Tax | Permalink

Wednesday, June 9, 2021

Meet The Authors Today On Zoom: From The Texas Cotton Fields To The U.S. Tax Court

Thursday, May 13, 2021

ABA Tax Section Virtual 2021 May Meeting

The ABA Tax Section virtual 2021 May Meeting continues today (program). Today's highlight:

ABA TaxTeaching Taxation: Law Schools and Access to Tax Justice 12:30 PM ET:
How can law schools help improve access to tax justice? Panelists will present models of law school courses through which students provide tax services or representation to taxpayers, or for which access to justice is the primary subject of the course. The panel will engage a variety of perspectives including different areas of tax law, different pedagogical approaches, and different institutional commitments by the law schools. Topics will include Volunteer Income Tax Assistance, Low-Income Taxpayer Clinics, a seminar on Taxes and Social Justice, a Business Tax Practicum, and the Adopt-a-Base program.

  • Alice Abreu (Temple)
  • Michelle Lyon Drumbl (Washington & Lee) (moderator)
  • C. Wells Hall III (Nelson Mullins, Charlotte, NC)
  • Matthew T. James (Temple)
  • Francine Lipman (UNLV)
  • Manoj Viswanathan (UC-Hastings)

Other Tax Profs with speaking roles include:

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May 13, 2021 in ABA Tax Section, Conferences, Tax, Tax Conferences | Permalink

Monday, May 10, 2021

ABA Tax Section May Meeting Kicks Off Today With The Emergence Of Analytics For Tax Positions

The ABA Tax Section virtual 2021 May Meeting kicks off today (program). Today's highlight:

ABA TaxBenjamin Alarie (Osler Chair in Business Law, University of Toronto Faculty of Law; Co-Founder & CEO, Blue J Legal), The Emergence of Analytics for Tax Positions at 2:30 PM ET:

When defending a client’s position to the IRS or a judge, it can be hard to ensure you are making the strongest possible argument for the client’s position, mitigating the risk of the position being successfully challenged and providing time- and cost-effective service for your client. Join us as we discuss how leading tax professionals are using advanced analytics tools to strengthen client positions and gain an advantage in settlement discussions by:

  • Using artificial intelligence to identify the strength of a position with greater than 90% accuracy;
  • Testing the effect of various changes to the facts on the strength of the position;
  • Gaining a comprehensive view of the law by identifying authorities and guidance that may pose a risk to the position or can be used to support it;
  • Providing independent, 3rd party reports to foster favorable resolutions

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May 10, 2021 in ABA Tax Section, Conferences, Legal Education, Tax | Permalink

Wednesday, March 10, 2021

ABA Tax Section Webinar Today On State Tax And Economic Policy Responses To COVID-19

The ABA Tax Section hosts a CLE webinar today on State Tax and Economic Policy Responses to the Ongoing COVID Pandemic at 1:00 PM - 2:35 PM EST (registration):

ABA TaxIn March, 2020, Congress enacted the Coronavirus Aid, Relief, and Economic Security (CARES) Act to ameliorate economic shocks to U.S. households from the COVID pandemic and lockdowns. Although the CARES Act provided $150 billion in funds to states and local governments, those funds are not enough to stem the tide of the challenges states and local governments are facing today. State and local governments must therefore raise revenue themselves, and do so with a smaller fiscal toolbox than that available to the federal government. Panelists, including experts in tax, economics, and public policy will discuss state tax and related policy responses to COVID economic relief going forward. What policy tools do state and local governments have to manage this enormous shock? How can they raise revenue while also protecting vulnerable businesses and households harmed by the pandemic?

  • Gladriel Shobe (BYU) (moderator)
  • Ariel Jurow Kleiman (San Diego; moving to Loyola-L.A.)
  • Erin Scharff (Arizona State)

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March 10, 2021 in ABA Tax Section, Conferences, Tax, Tax Conferences | Permalink

Tuesday, March 9, 2021

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 74, No. 2 (Winter 2021):

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March 9, 2021 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink

Tuesday, January 26, 2021

ABA Tax Section Virtual 2021 Midyear Meeting

The ABA Tax Section Virtual 2021 Fall Midyear Meeting continues today. The full program is here. The highlight is State Tax and Economic Policy Responses to the Ongoing COVID Pandemic (Teaching Taxation Committee (Wednesday, 12:30 − 2:00 PM ET)):

ABA Tax Section Virtual Meeting 2In March, 2020, Congress enacted the Coronavirus Aid, Relief, and Economic Security (CARES) Act to ameliorate economic shocks to U.S. households from the COVID pandemic and lockdowns. Although the CARES Act provided $150 billion in funds to states and local governments, those funds are not enough to stem the tide of the challenges states and local governments are facing today. State and local governments must therefore raise revenue themselves, and do so with a smaller fiscal toolbox than that available to the federal government. Panelists, including experts in tax, economics, and public policy will discuss state tax and related policy responses to COVID economic relief going forward. What policy tools do state and local governments have to manage this enormous shock? How can they raise revenue while also protecting vulnerable businesses and households harmed by the pandemic?

  • Chris Hoene (Executive Director, California Budget & Policy Center)
  • Ariel Jurow Kleiman (San Diego)
  • Erin Scharff (Arizona State)
  • Darien Shanske (UC-Davis)
  • Gladriel Shobe (BYU) (moderator)

Other Tax Profs with speaking roles include:

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January 26, 2021 in ABA Tax Section, Conferences, Tax, Tax Conferences | Permalink

Friday, January 15, 2021

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 74, No. 1 (Fall 2020):

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January 15, 2021 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink

Friday, January 8, 2021

ABA Tax Section Women's Tax Forum Hosts Zoom Tea Today With Alice Abreu

The ABA Tax Section Women's Tax Forum is hosting a Zoom Tea today with Alice Abreu (Temple) at 4:30 PM ET:

ABA Tax Section Women in TaxTake a 30-minute tea break with us as we chat on Zoom video with leading women tax lawyers from a variety of fields who share stories of success and struggle as we explore individual paths to professional and personal fulfillment.

We're thrilled to announce Alice Abreu is joining us this Friday! Alice is a Professor of Law at Temple University's Beasley School of Law, where she teaches courses in Taxation, Corporate Taxation, International Taxation, and Low Income Taxpayer Policy and Practice and is serving as the inaugural Director of Temple's Center for Tax Law and Public Policy.

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January 8, 2021 in ABA Tax Section, Legal Education, Tax | Permalink

Wednesday, December 23, 2020

ABA Tax Section Military VITA Pro Bono Project Seeks Writers For State Tax Guide

From James Steele (Morgan, Lewis & Bockius, Washington, D.C.):

Military VITA 3As part of the ABA Tax Section's Military VITA pro bono effort, we have recently taken over an important, ongoing resource for Military VITA sites. We will be updating and maintaining, on a go-forward basis, a State Tax Guide that compiles relevant state income tax topics and issues that are specific to members of the Military. For reference, and as a way to provide a sense of the volunteer commitment, I have attached a sample state from the current version of the Guide. The state-specific guides range from one to four pages, and the volunteer's job is simply to review and make any relevant updates to ensure accuracy and repeat this task each December in preparation for tax season.

We are looking for one or more volunteers to adopt each state with a state income tax, plus Washington, DC, to help review and update the Guide. By dividing the document by state, the time commitment of each volunteer should be very minimal. If you are interested in signing up for more than just your state, we welcome that too. The audience for the Guide is Military members (often with no prior tax background), so we are trying to keep it very readable and limit it to the most common issues. This volunteer opportunity is ideal for new attorneys, retired attorneys, non-attorneys, and anyone in between. It also could be a group effort at a firm. No prior experience is necessary, and the information is easily attainable by researching online.

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December 23, 2020 in ABA Tax Section, Tax, Tax News | Permalink | Comments (0)

Thursday, December 17, 2020

Johnson & Johnson Debate Gitlitz

Point: Calvin H. Johnson (Texas), The Supreme Court’s Statutory Interpretation in Gitlitz: A Failed Approach to Interpretation and a Bad Decision, 40 ABA Tax Times (Fall 2020):

ABA Tax TimesThe Supreme Court’s decision in Gitlitz v. Commissioner is an irresponsible decision disrupting the logic of tax for the benefit only of abuse. In Gitlitz the Supreme Court gave the equivalent of a double deduction, both an appropriate exclusion of cancellation of indebtedness income for an insolvent Subchapter S corporation and also an inappropriate increase in shareholder basis. The combination of the exclusion and shareholder basis generated a tax loss that had no economic substance, a loss that in Judge Posner’s wonderful phrase “did not impinge on the world.” ...

The approach in Gitlitz allowing an absurd tax deduction shows a hostility to the tax system that is inappropriate for a court in its role as a faithful servant. There are fundamental principles underlying the tax law, including antagonism to double deductions and deduction of phantom losses. The Supreme Court has a duty to interpret tax law in favor of coherent principle, and Gitlitz violates fundamental principle.

Counterpoint: Steve Johnson (Florida State), The Constitution Is More Important than a Few Tax Dollars Squandered by Congress: Gitlitz Was Correctly Decided, 40 ABA Tax Times (Fall 2020):

Gitlitz was decided two decades ago, and its practical import was rapidly nullified when Congress amended the statute to remove the glitch in the statute Congress originally enacted. That being so, is Gitlitz worth our time and thought today? Yes, it is. In Gitlitz, the Supreme Court reminded us that the constitutional separation of powers principle is for the long term and should not be eroded by yielding to temptations of the moment.

My respect for Professor Calvin Johnson is great, but so is my conviction that, in this instance, his view is unwise.

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December 17, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (1)

Thursday, December 10, 2020

Kahn & Kahn: Recovery For Causing Tax Overpayment — Lyeth v. Hoey And Clark Revisited

Douglas A. Kahn (Michigan) & Jeffrey H. Kahn (Florida State), Recovery for Causing Tax Overpayment - Lyeth v. Hoey and Clark Revisited, 74 Tax Law. ___ (2021):

ABA Tax Lawyer (2019)The question has arisen in numerous cases as to the extent to which a settlement between arms’ length parties is dispositive in tax cases of the claims on which the settlement is based. Another issue that often arises is whether the receipt of compensation for a tax payment that was incurred because of the negligence of the payor is excluded from gross income. While those two issues were central to the proper resolution of a recent case in the United States Court of Appeals for the Eleventh Circuit, McKenny v. United States [No. 18-10810 (11th Cir. Sept. 30, 2020)], the court failed even to note one of those issues and did not resolve the other. The court’s failure to deal with those two issues led it to reach an incorrect result.

The two landmark cases establishing the doctrines that should have been applied in McKenny are the Supreme Court’s decision in Lyeth v, Hoey [305 U.S. 188 (1938)] and the decision of the Board of Tax Appeals (now known as the Tax Court) in Clark v. Commissioner [40 B.T.A. 333 (1939)]. Using McKenny as a springboard, this article reviews the continued misapplication and sometimes disparagement of the Lyeth v. Hoey and Clark v. Commissioner reasonings.

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December 10, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

2020 Tannenwald Tax Writing Competition Winners

Tannenwald (2016)The Theodore Tannenwald, Jr. Foundation for Excellence in Tax Scholarship has announced the winners of the 2020 tax writing competition:

First Prize ($5,000):
Ryan Bullard (North Carolina), I Am “QOZ,” The Great and Terrible: A Policy Analysis of the Qualified Opportunity Zone Nominations Process
Faculty Sponsor:  Leigh Osofsky

Second Prize ($2,500):
Heydon Wardell-Burrus (Harvard), Blending Under A Global Minimum Tax
Faculty Sponsor:  Alvin C. Warren, Jr.

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December 10, 2020 in ABA Tax Section, Legal Education, Scholarship, Tax, Tax Scholarship, Teaching | Permalink | Comments (0)

Monday, December 7, 2020

Afield: Moving Tax Disputes Online Without Leaving Taxpayer Rights Behind

W. Edward Afield (Georgia State), Moving Tax Disputes Online Without Leaving Taxpayer Rights Behind, 74 Tax Law. ___ (2020):

ABA Tax Lawyer (2019)As the Service’s technological infrastructure continues to show its age, both the Service and Congress appear to be recognizing the importance of the Ser-vice having technological infrastructure that allows it to take advantage of the capabilities of modern computing systems to improve both its enforcement and service efforts. The National Taxpayer Advocate has entered this conversation as well, encouraging Congress and the Service to prioritize improvements to the Service’s technological infrastructure but simultaneously raising legitimate concerns about the impact that an overreliance on technology might have on taxpayer rights, particularly rights of vulnerable population groups who may not be able to utilize technology.

Fortunately, increasing technological deployment as part of taxpayer service is not a zero sum game that requires sacrificing taxpayer rights in the name of efficiency. The Service can accomplish the goal of deploying technology in a pro-taxpayer rights manner if it brings considerations of affirming taxpayer rights to the forefront of its deliberations about how best to utilize technology. Both the academic literature and Service strategic documents have focused on a wide variety of taxpayer interactions with the Service in proposing how this can be done. There is one type of interaction, however, that has thus far been underexplored both in the academic literature and in the Service’s strategic efforts to move more of its taxpayer interactions online: taxpayer controversy resolution.

This Article argues that the Service has insufficiently considered whether it can increase its use of technology-based interactions with taxpayers in the controversy-resolution process in a manner that both achieves efficiency gains and affirms taxpayer rights. Specifically, three areas in controversy resolution could lend themselves to such rights-affirming technological implementation.

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December 7, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (1)

Saturday, October 24, 2020

This Week's Ten Most Popular TaxProf Blog Posts

Wednesday, October 21, 2020

ABA Tax Section Hosts Free Webinar Today On The Tax System and Social Policy

The ABA Tax Section hosts a free webinar today on The Tax System and Social Policy at 1:00 ET:

ABA TaxThe tax system has been used with increasing frequency as a social policy tool to administer social programs. From the Earned Income Tax Credit to the recent Economic Impact Payments, the IRS has been asked to do more with an ever decreasing budget. While the tax system may be an attractive vehicle to administer certain payments or benefits, it can also pose challenges. Panelists will examine the history of the tax code as a way to administer social programs. Panelists will then evaluate certain programs and discuss some advantages and disadvantages of administering these programs through the tax code. In particular, panelists will discuss the recent Economic Impact Payments and some of the challenges with administering these payments successfully. Lastly, panelists will propose some changes and alternatives to the way programs are administered to better serve the communities that are most in need of these benefits.

Speakers:

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October 21, 2020 in ABA Tax Section, Conferences, Tax, Tax Conferences, Tax News | Permalink | Comments (0)

Wednesday, October 7, 2020

ABA Tax Section Accepting Nominations for 2021-2023 Public Service Fellowships

The ABA Tax Section is accepting applications for Christine A. Brunswick Public Service Fellowships for 2021-2023:

ABA Tax Section (2017)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 2021-2023. Developed in 2008, the Fellowship program seeks to address the growing need for tax legal assistance and to foster a greater interest in tax-focused public service through funding and other support to young lawyers engaged in tax work for underserved communities.

Other important aspects of the fellowship program:

  • The fellowship award includes student loan assistance;
  • Fellows have incredible access to ABA Tax Section meetings and the tax community; and
  • The positive career trajectories of the prior fellowship recipients (see list here). They are great resources on the fellowship for interested parties.

The deadline for applications is November 2, 2020.

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October 7, 2020 in ABA Tax Section, Legal Ed News, Legal Education, Tax, Tax News | Permalink | Comments (0)

Thursday, October 1, 2020

Infanti: Hegemonic Marriage — The Collision Of 'Transformative' Same-Sex Marriage With Reactionary Tax Law

Anthony C. Infanti (Pittsburgh), Hegemonic Marriage: The Collision of 'Transformative' Same-Sex Marriage with Reactionary Tax Law, 74 Tax Law. ___ (2021):

ABA Tax Lawyer (2019)Before there was a culture war in the United States over same-sex marriage, there was a battle between opponents and proponents of same-sex marriage within the LGBTQ+ community. Some within the LGBTQ+ community opposed same-sex marriage because of the long patriarchal history of marriage and the more consequential need to bridge the economic and privilege gap between the married and the unmarried. On the other hand, LGBTQ+ proponents of same-sex marriage saw marriage as a civil rights issue because of the central importance of marriage in American society. They sensed a profound wrong in the denial of the benefits of marriage to same-sex couples when those couples carried on lives no different from their heterosexual counterparts, save for the legal recognition of their relationships as a “marriage.” Proponents also lauded the transformative potential of same-sex marriage, contending that it could upset the patriarchal nature of marriage and help to refashion marriage into something new and better. Opponents, of course, feared the hegemony of heterosexual marriage in the United States and argued that same-sex marriage would not transform American society at all.

This essay looks back at that debate through the lens of the federal tax definition of “marriage” before and after the U.S. Supreme Court’s decisions in United States v. Windsor and Obergefell v. Hodges.

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October 1, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

Wednesday, September 30, 2020

ABA Tax Section Virtual Meeting

The ABA Tax Section Virtual 2020 Fall Meeting kicks off today. The full program is here. Today's highlight is Beyond CARES: Tax and Economic Policy Responses to the Ongoing COVID Pandemic (Teaching Taxation Committee (10:00 − 11:30 AM ET)):

ABA Virtual TaxIn March, 2020, Congress enacted the Coronavirus Aid, Relief, and Economic Security (CARES) Act to ameliorate economic shocks to U.S. households from the COVID pandemic and lockdowns. The CARES Act included temporary: (1) Economic Impact Payments to individuals and families of up to $1,200 per adult (subject to income limitations) and $500 per child under 17 years old; (2) Paycheck Protection Program (PPP) forgivable loans to businesses, including independent contractors, to cover up to eight weeks of payroll costs or to pay interest on mortgages, rent, and utilities; and (3) supplemental Federal Pandemic Unemployment Compensation (FPUC) of $600 per week. Following expiration of CARES Act relief, the question is: what new COVID economic relief package is advisable? Members of Congress and policymakers disagree about the best approaches to counteract the continuing economic shocks to households from the pandemic. Panelists, including experts in tax, economics, and public policy will discuss tax and related policy responses to COVID economic relief going forward. Panel topics include proposals: to expand and increase the Earned Income Tax Credit; to expand and increase the Child Tax Credit; to reduce payroll taxes; to extend FPUC benefits; to increase federal subsidies to states; and to enact a federal VAT or Carbon Tax, which could fund an expanded EITC or Child Tax Credit or a lump sum Basic Income for Americans. Panelists will consider potential gender, racial, and socio-economic disparities in the economic impact of (1) the COVID pandemic and (2) pandemic relief proposals.

Speakers:

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September 30, 2020 in ABA Tax Section, Conferences, Tax, Tax Conferences | Permalink | Comments (1)

Saturday, September 26, 2020

Tax Consequences On The Sale Of Encumbered Property: Recourse v. Nonrecourse Debt

Kenneth Weil, Recourse and Nonrecourse Debt: What Are the Federal Income Tax Consequences When the Character of Debt Changes, 74 Tax Law. ___ (2020):

ABA Tax Lawyer (2019)When encumbered property is sold, the taxation of that sale is different if the sale involves recourse debt as opposed to non-recourse debt. This difference raises an intriguing question: when debt changes from recourse debt to non-recourse debt or vice versa, which rules will control? Examples of when debt changes from recourse to non-recourse or vice versa include bankruptcy discharges, foreclosures in a state with anti-deficiency statutes, some short sales in deficiency states, and the operation of Bankruptcy Code section 1111(b).

The Cottage Savings regulations, Regulation section 1.1001-3, have specific provisions designed to answer the question what happens when debt changes from recourse to non-recourse or vice versa.

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September 26, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

Wednesday, September 9, 2020

ABA Tax Section Releases 20th Annual Law Student Tax Challenge Problem

The ABA Tax Section has released the J.D. Problem (rules; entry form) and LL.M. Problem (rules; entry form) for the 20th Annual Law Student Tax Challenge (infographic):

LSTCAn alternative to traditional moot court competitions, the Law Student Tax Challenge (LSTC) is organized by the Section’s Young Lawyers Form. The LSTC asks two-person teams of students to solve a complex business problem that might arise in everyday tax practice. Teams are initially evaluated on two criteria: a memorandum to a senior partner and a letter to a client explaining the result. Based on the written work product, six teams from the J.D. Division and four teams from the LL.M. Division receive a free trip to the Section’s Midyear Meeting, where each team presents its submission before a panel of judges consisting of the country’s top tax practitioners and government officials, including tax court judges. The competition is a great way for law students to showcase their knowledge in a real-world setting and gain valuable exposure to the tax law community.

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September 9, 2020 in ABA Tax Section, Legal Ed News, Legal Education, Tax, Tax News, Teaching | Permalink | Comments (0)

Thursday, September 3, 2020

Field: Tax MACs — A Study of M&A Termination Rights Triggered By Material Adverse Changes In Tax Law

Heather M. Field (UC-Hastings), Tax MACs: A Study of M&A Termination Rights Triggered by Material Adverse Changes in Tax Law, 73 Tax Law. 823 (2020):

ABA Tax Lawyer (2019)A “Tax MAC” provision—one that triggers termination or other rights upon a material adverse change in tax law—can be crucial to a business deal if a change in tax law would change a party’s interest in consummating the deal, particularly at the specified price and on the articulated terms. Tax MAC provisions may be particularly important when taxpayers make business decisions in a political climate like today’s, when tax laws could change again, perhaps dramatically, if control of Congress and the White House changes. Yet little has been written about Tax MAC provisions. In response, I studied Tax MAC provisions included in publicly filed M&A agreements from the past five years, focusing on provisions that could trigger termination of the deal if tax laws change adversely. This Article details the findings of that study.

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September 3, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

Thursday, July 30, 2020

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 73, No. 4 (Summer 2020):

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July 30, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

Friday, July 24, 2020

ABA Tax Section Hosts Free Webinar Today On Careers In Tax Law

The ABA Tax Section hosts a free virtual program on Careers in Tax Law today at 12:00 - 1:15 pm ET (9:00 - 10:15 am PT):

ABA Tax SectionThe program is intended for summer associates, law clerks, law students, and young lawyers who may be considering a career in tax law. Panelists will discuss their own career paths, provide advice, and give their perspective on the practice of federal tax law.

  • Michael J. Desmond (Chief Counsel, IRS)
  • Diana L. Erbsen (Partner, DLA Piper)
  • Maurice B. Foley (Chief Judge, U.S. Tax Court)

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July 24, 2020 in ABA Tax Section, Legal Ed Conferences, Legal Education, Tax, Tax Conferences | Permalink | Comments (0)

Tuesday, July 14, 2020

2020-22 ABA Tax Section Public Service Fellows

The 2020-2022 Christine A. Brunswick Public Service Fellowship Class:

  • ABA Tax Section (2017)Shailana Dunn-Wall, a graduate of University of Nebraska College of Law, will work with Legal Aid of Nebraska to educate residents throughout Nebraska on the benefits of the Earned Income Tax Credit in an effort to increase the percentage of eligible taxpayers who claim the credit by filing a tax return.
  • Terri Morris, a graduate of University of Richmond School of Law, will work with the Community Tax Law Project of Richmond, Virginia, on their Fight Against Financial Abuse project. Through this initiative, Terri will advocate, educate and engage local domestic violence survivors on tax issues surrounding financial abuse.

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July 14, 2020 in ABA Tax Section, Legal Ed News, Legal Education, Tax, Tax News | Permalink | Comments (0)

Friday, July 10, 2020

ABA Tax Section Hosts Free CLE Webinar Today On Race And The Internal Revenue Code

The ABA Tax Section hosts a free CLE webinar on Race and the Internal Revenue Code today at 1:00 pm to 2:35 pm ET:

ABA Race And The Tax CoceAs the nation focuses on the many racial inequities that permeate society, this free webinar will explore how the federal tax code, state and local taxes and international taxation impact racial inequality.

The panel will feature a demonstration of a recently released interactive feature that traces IRS Form 1040 line by line to examine the impact of the federal tax code on racial and economic inequality. The panel will further explore the impact of colorblind tax data on social policy. Panelists will also discuss the racial inequities perpetuated through taxable treatment of employment discrimination damages and how race intersects with international tax law and policy.

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July 10, 2020 in ABA Tax Section, Conferences, Legal Ed News, Legal Education, Tax, Tax Conferences | Permalink | Comments (0)

Saturday, May 30, 2020

ABA Tax Section Names 2020-2021 John Nolan Fellows

ABA Tax Section Recognizes Outstanding Young Tax Lawyers, Names Six 2020-2021 John S. Nolan Fellows:

ABA Tax Section (2017)The American Bar Association Section of Taxation is pleased to announce the recipients of the 2020-2021 John S. Nolan Fellowships.

  • Carina Federico (Crowell & Moring, Washington, D.C.)
  • Morgan Klinzing (Pepper Hamilton, Philadelphia, PA)
  • Galina “Allie” Petrova (Petrova Law, Greensboro, NC)
  • Nancy Rossner (The Community Tax Law Project, Richmond, VA)
  • Monisha Santamaria (Joint Committee on Taxation, Washington, D.C.)
  • Timothy Todd (Liberty University School of Law, Richmond, VA)

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May 30, 2020 in ABA Tax Section, Tax, Tax News | Permalink | Comments (0)

Monday, May 11, 2020

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 73, No. 3 (Spring 2020):

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May 11, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

Saturday, March 21, 2020

Book & Ames: The Morass Of The Anti-Injunction Act

Leslie Book (Villanova) & Marilyn Ames (IRS Office of Chief Counsel (retired)), The Morass of the Anti-Injunction Act: a Review of the Cases and Major Issues, 73 Tax Law. ___ (2020):

ABA Tax Lawyer (2019)As Congress gives the Internal Revenue Service more tasks to perform beyond its function of assessing and collecting taxes, courts, practitioners, and academics are struggling to apply the Anti-Injunction Act (AIA) as the IRS promulgates procedures in the course of fulfilling new mandates. The AIA has its origins in the post-Civil War era when the federal government established new procedures ensuring the assessment and collection of taxes. It may seem odd an over 150-year old provision is fueling a growing number of contested and controversial disputes. Yet, the AIA has taken on renewed importance as courts consider challenges to tax regulations and guidance, fueled in part by the increasing importance of administrative law in issues of tax procedure and administration.

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March 21, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

Monday, March 16, 2020

McGovern, Brewer & Delaney: 2019 Federal Income Tax Developments

Bruce A. McGovern (South Texas), Cassady V. Brewer (Georgia State) & James M. Delaney (Wyoming), Recent Developments in Federal Income Taxation: The Year 2019, 73 Tax Law. ___ (2020):

ABA Tax Lawyer (2019)This article summarizes and provides context to understand the most important developments in federal income taxation for the year 2019. The items discussed primarily consist of the following: (i) significant amendments to the Internal Revenue Code; (ii) important judicial decisions; and (iii) noteworthy administrative rulings and regulations promulgated by the Service and the Treasury Department. This article primarily focuses on subjects of broad general interest — tax accounting rules, determination of gross income, allowable deductions, treatment of capital gains and losses, corporate and partnership taxation, exempt organizations, and procedure and penalties.

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March 16, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

Thursday, March 12, 2020

Winners Of The 19th Annual Law Student Tax Challenge

ABA Tax Section, Winners of the 19th Annual Law Student Tax Challenge:

J.D. Division

ABA JD1st Place:
Amanda Krugler and Scott Sullivan [right, with ABA Tax Section Chair Thomas Callahan] [more here]
University of Kentucky College of Law
Coach:  Jennifer Bird-Pollan

2nd Place (Tie):
Matthew Foran and Harry Gao
Seton Hall Law School
Brian Krastev and Matthew Marcellino
Syracuse University College of Law

Best Written Submission:
Ryan Hartnett and Mitchell Renfrew
Western New England University School of Law

Semi-Finalists:
Anita Alanko and Jennifer Galstad
Catholic University of America, Columbus School of Law

Mark Watterson and Taylor Monroe
UNT Dallas College of Law

Ryan Hartnett and Mitchell Renfrew
Western New England University School of Law

LL.M. Division

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March 12, 2020 in ABA Tax Section, Legal Education, Tax, Tax News, Teaching | Permalink | Comments (0)

Sunday, March 8, 2020

Crawford & Blattmachr: Basis And Bargain Sales

Bridget J. Crawford (Pace) & Jonathan G. Blattmachr (Milbank, New York), Basis and Bargain Sales: Income Tax and Other Concerns, 73 Tax Law. ___ (2020):

ABA Tax Lawyer (2019)This article explores the income tax consequences of the sale during lifetime and at death of property for less than fair market value. The analysis focuses in particular on the tax consequences of a bargain sale by a transferor who wishes to confer some financial benefit on a family member, but leave the rest of her estate to charity. Generally speaking, death-time bargain sales may be preferable to similar transactions during lifetime, if the assets have a low basis pre-death, because of the step up in income tax basis under section 1014.

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March 8, 2020 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

Wednesday, March 4, 2020

2020 ABA Tax Section Janet Spragens Pro Bono Award

Press Release, ABA Section of Taxation Awards 2020 Janet Spragens Pro Bono Award to Hardin Matthews, Kelley Miller and Larry Sannicandro:

MatthewsHardin Matthews spent an exceptional career embodying the very characteristics this award seeks to acknowledge. His dedication to low-income taxpayers is noteworthy not only for the years of service, but also for the breadth of service. After retiring from Ropes & Gray, where he performed pro bono services for clients over the many years of his career, he dedicated himself to finding ways to help low-income taxpayers. He completed a year-long fellowship with the Access to Justice Program at Greater Boston Legal Services (GBLS) and continued to volunteer after the fellowship dedicating over 3,700 hours of volunteer attorney time in just five years. He goes above and beyond in his service to taxpayers, linking them to other needed resources. In addition to achieving life-changing victories for low-income taxpayers, he is a steady source of legal research and mentorship for other attorneys both at GBLS and Harvard’s Low-Income Taxpayer Clinic (LITC). Hardin volunteers for the Volunteer Income Tax Assistance (VITA) program in Chelsea and Revere, Massachusetts. He also led a statewide advocacy project to improve the interactions of low-income taxpayers with the state revenue agency in Massachusetts.

ABA AwardKelley Miller [Reed Smith, Washington, D.C.] and Larry Sannicandro [McCarter & English, Newark ] were jointly selected to receive the Janet Spragens Pro Bono Award because in designing and implementing the Exonerees’ Tax Assistance Network, they created an entirely new form of low-income taxpayer assistance that is nothing short of extraordinary. For years, wrongfully incarcerated individuals who received compensation for their time behind bars were required to pay income taxes on the settlements they received from government organizations responsible for their wrongful incarceration. Congress changed the law in 2015 to exempt exonerees from paying income taxes on civil damages, restitution or other monetary awards received as compensation for their wrongful incarceration. Despite the passage of the Wrongful Conviction Tax Relief Act of 2015, many exonerated individuals remain unaware of their right to a refund of tax paid on their compensation, much less the applicable filing deadlines. Kelley Miller and Larry Sannicandro saw an opportunity to help people who have been significantly disenfranchised and would not otherwise have the ability to claim what is rightfully theirs.

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March 4, 2020 in ABA Tax Section, Tax, Tax News | Permalink | Comments (0)

Tuesday, February 25, 2020

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 73, No. 2 (Winter 2020):

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February 25, 2020 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0)

Saturday, February 1, 2020

ABA Tax Section Mid-Year Meeting

The ABA Tax Section Midyear Meeting concludes today in Boca Raton, Florida. The full program is here. The highlight of the program is:

ABATeaching Taxation: Opportunity Zones – Two Years In
The Tax Cuts and Jobs Act enacted in December 2017 included a new provision intended to direct investment into low-income communities through a combination of tax benefits for investors (deferral, partial reductions in gains, and exclusions of future appreciation). Though the enactment of such targeted tax incentives is not entirely new, the design of this provision has raised significant questions for investing taxpayers seeking to secure the tax benefits and for public policy advocates assessing whether the Opportunity Zone provisions achieve their stated goals. To explore all of these issues, this panel will discuss the design of the new incentive, who is making the investments, where, in what projects, how much is being invested, who is securing the benefits, and what will be the likely community impact. The panel also considers the current data reporting requirements and what/whether data should be made public to facilitate assessment of the program’s success in promoting economic growth in low-income areas.

  • Edward De Barbieri (Albany)
  • Michelle Layser (Illinois)
  • Ellen Aprill (Loyola-L.A.) (moderator)

Other Tax Profs with speaking roles include:

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February 1, 2020 in ABA Tax Section, Conferences, Tax, Tax Conferences | Permalink | Comments (0)

Tuesday, December 10, 2019

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 73, No. 1 (Fall 2019):

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December 10, 2019 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

2019 Tannenwald Tax Writing Competition Winners

Tannenwald (2016)The Theodore Tannenwald, Jr. Foundation for Excellence in Tax Scholarship has announced the winners of the  2019 tax writing competition:

First Prize ($5,000):
Christine Davis (Florida), More Anti-Simplification: PTI and GILTI After the Tax Cuts and Jobs Act
Faculty Sponsor:  Mindy Herzfeld

Second Prize ($2,000):
Alexandra Ferrera (NYU), Incentivizing the Care of Adult Family Members Through a Two-Part Tax Credit
Faculty Sponsor:  Lily Batchelder

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December 10, 2019 in ABA Tax Section, Legal Education, Scholarship, Tax, Tax Scholarship, Teaching | Permalink | Comments (0)

Thursday, October 3, 2019

ABA Tax Section Fall Meeting

The ABA Tax Section kicks off its three-day joint fall meeting with the ABA Real Property, Trust and Estate Law Section today in San Francisco. The full program is here. The highlight is:

ABA 2Teaching Taxation: Technology-Driven Trends in Tax Law Training
This panel explores the changing ways in which lawyers can, and are expected to, train themselves to excel in tax practice in an age of pervasive technology. Formal law firm training of associates is less common than before the Great Recession. Clients no longer are willing to subsidize the training of new associates. Tax associates must arrange to train themselves, outside their full-time, billable work obligations. The panel will discuss various training options (including residential and online LLM programs, online courses, webinars, podcasts, and mixed programs) by which tax lawyers can create a solid foundation for their tax practice and expand their knowledge into new tax subspecialties. These training options employ a range of pedagogical approaches, reflecting ongoing study and experimentation in online learning. The panel will highlight educational best practices, based on learning theory. In addition, the Panel will explore parameters by which lawyer-consumers of such training and employer-firms can assess the success of various training options.

  • Leslie Book (Villanova)
  • Steven Dean (NYU)
  • Mirit Eyal-Cohen (Alabama)
  • Heather Field (UC-Hastings) (moderator)
  • Samuel Greenberg (EY, Los Angeles)
  • Michael Hunter Schwartz (McGeorge)
  • Ryan Montgomery (Morgan Lewis, Boston)
  • Annette Nellen (San José)
  • Katherine Pratt (Loyola-L.A.)

Other Tax Profs with speaking roles include:

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October 3, 2019 in ABA Tax Section, Conferences, Tax, Tax Conferences | Permalink | Comments (1)

Wednesday, September 18, 2019

Cooper: Lessons From The State Death Tax Credit And The SALT Deduction

Jeffrey A. Cooper (Quinnipiac), Red States, Blue States: Lessons from the State Death Tax Credit and the 'SALT' Deduction, 73 Tax Law. ___ (2020):

ABA Tax Lawyer (2019)Since 1861, every version of the federal income tax has included a deduction for state and local taxes (often referred to by its popular acronym “SALT”). Since this provision, the “SALT deduction,” minimizes the effect of state and local taxes on taxpayers, it offers greater benefits to those living in states that impose the highest tax burden — the high-tax “blue” states. In 2017, the Tax Cuts and Jobs Act marked a major shift in this long-established federal policy toward state taxes. Among its many provisions, the Act capped the SALT deduction at $10,000 per married couple, providing no Federal tax offset for amounts paid in excess of that amount.

In this article, I attempt to address two questions raised by this turn of events. First, how will states respond to this change in federal law? Second, does the capping of the SALT deduction represent a major shift in federal-state relations, an unprecedented attack on blue states, or is it simply politics as usual?

My novel approach to the subject is to consider these questions by exploring the similarities and contrasts between the income tax SALT deduction and the estate tax state death tax credit, which was established in 1924 and repealed in 2001. Viewing the 2017 legislation within this broader historical context more reveals trends and patterns, providing greater insight than would a study of the SALT deduction in isolation.

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September 18, 2019 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

Wednesday, September 4, 2019

ABA Tax Section Releases 19th Annual Law Student Tax Challenge Problem

The ABA Tax Section has released the J.D. Problem (rules; entry form) and LL.M. Problem (rules; entry form) for the 19th Annual Law Student Tax Challenge:

LSTCAn alternative to traditional moot court competitions, the Law Student Tax Challenge asks two-person teams of students to solve a cutting-edge and complex business problem that might arise in everyday tax practice. Teams are initially evaluated on two criteria: a memorandum to a senior partner and a letter to a client explaining the result. Based on the written work product, six teams from the J.D. Division and four teams from the LL.M. Division receive a free trip (including airfare and accommodations for two nights) to the Section of Taxation 2020 Midyear Meeting, January 30-February 1, in Boca Raton, FL, where each team will defend its submission before a panel of judges representing the country’s top tax practitioners and government officials, including Tax Court judges.

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September 4, 2019 in ABA Tax Section, Legal Education, Tax, Tax News, Teaching | Permalink | Comments (0)

Wednesday, August 28, 2019

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 72, No. 4 (Summer 2019):

August 28, 2019 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink | Comments (0)

Tuesday, August 27, 2019

Tax Issues In Dr. Pepper's Acquisition Of Keurig

Jeffrey Sheffield (Senior Lecturer, Northwestern; Partner, Kirkland & Ellis), Whose Earnings and Profits? What Dividend? A Discussion Based on the Dr. Pepper - Keurig Transaction, 72 Tax Law. __ (2019):

KDP2In July 2018 Dr. Pepper Snapple Group, Inc. (“Dr. Pepper”) acquired all the stock of the Maple Parent Holdings Corp. (better known as “Keurig”) in exchange for Dr. Pepper common stock. The acquisition was unusual in two respects: Dr. Pepper paid its shareholders a pre-merger “special dividend” equal to approximately 87% of the stock’s value; and Dr. Pepper then issued to Keurig’s shareholders Dr. Pepper stock equal to approximately 87% of the combined companies’ stock. It is this combination of events that gives rise to the tax issues discussed in this article.

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August 27, 2019 in ABA Tax Section, Scholarship, Tax, Tax News, Tax Scholarship | Permalink | Comments (1)