TaxProf Blog

ABA Tax Section Fall CLE Meeting

The ABA Tax Section continues its three-day joint Fall CLE meeting with the ABA Real Property, Trust and Estate Law Section today in Austin, TX.  The full program is here.  Today's highlight is the Teaching Taxation program on Best Practices in Drafting and Interpreting IRS Guidance:

Tax regulators communicate with taxpayers and their advisors through various means including regulations, notices, rulings, publications, and the IRS website. Not surprisingly, taxpayers and their advisors parse these communications in order to understand the applicable law and conduct their affairs accordingly. This panel will critically analyze two high profile modes of communication: examples in Treasury regulations and IRS public pronouncements. One key question taxpayers and their advisors face is how regulation examples should be interpreted, and how new legal content in examples should be reconciled with the broader regulatory and statutory scheme. Another major debate regarding IRS guidance concerns the trend and pressure for the IRS to use plain language in written communications with the public. Although “plain language” sounds compelling, there are downsides to this drafting approach. Panelists will discuss the benefits and risks associated with plain language explanations of tax law in these communications.

• Terri Helge (Texas A&M) (moderator)
• Joshua Blank (NYU)
• Nina E. Olson (National Taxpayer Advocate)
• Susan Morse (Texas)
• Kerry Ryan (St. Louis)
• Eric Solomon (EY, Washington, D.C.)

Other Tax Profs with speaking roles include:

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ABA Tax Section Fall CLE Meeting

The ABA Tax Section kicks off its three-day joint Fall CLE meeting with the ABA Real Property, Trust and Estate Law Section today in Austin, TX.  The full program is here.  Tax Profs with speaking roles include:

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Privatizing Tax Collection: The Idiocy Continues

Congress seems to be on an unceasing quest to undermine effective tax collection (for why I choose those words see my rant here).  In what can only be described as yet another boneheaded move,  Congress included a provision in the Fixing America’s Surface Transportation (FAST) Act in 2015 that required the Service to out-source collection work to private collection agencies (PCA's).

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Reforming Tax Administration

The current discussion about tax reform is focused on reforming substantive tax law and not tax administration.  Last April, however, a group of tax practitioner organizations put out a paper calling for tax administration reform.  You can find the proposal on the AICPA website here.

The nine practitioner organizations include the AICPA, the National Association of Enrolled Agents, and the National Association of Tax Professionals.  Notably absent from the list of practitioner groups are the main tax lawyer organization, the ABA Section on Taxation.

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ABA Tax Section Releases 17th 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 17th Annual Law Student Tax Challenge:

An 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 2018 Midyear Meeting, February 8-10, 2018 in San Diego, CA, where each team will defend 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. On average, more than 50 teams compete in the J.D. Division and more than 30 teams compete in the LL .M. Division.

IMPORTANT DATES

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Karen Hawkins Named Chair Of ABA Tax Section

News Release, Former IRS Official Karen L. Hawkins to Chair ABA Section of Taxation:

Karen L. Hawkins of Yachats, Ore., has been selected to chair the American Bar Association’s Section of Taxation, the nation’s largest organization of tax lawyers. Hawkins will serve a one-year term, to be succeeded by Eric Solomon, of Washington, D.C., who will serve this year as chair-elect.

Hawkins served as the director of the IRS Office of Professional Responsibility (OPR), where she oversaw the standards of practice for tax professionals. Prior to government service, she was a partner in the San Francisco law firm of Taggart & Hawkins PC, where she specialized in civil and criminal tax controversy. ...

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ABA Tax Section Publishes New Issue Of Tax Times

The ABA Tax Section has published 36 Tax Times No. 4 (Aug. 2017):

FROM THE CHAIR
It Was a Very Good Year
By William H. Caudill, Norton Rose Fulbright LLP, Houston, TX
It has been my honor to serve as Chair of the Tax Section for 2016-2017. The year seems to have passed too quickly. There were many good times and some disappointments, but I am proud to have had the opportunity to lead and carry out the best job in the Section.

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ABA Tax Section Publishes New Issue Of Tax Times

The ABA Tax Section has published 36 Tax Times No. 3 (June 2017):

FROM THE CHAIR
Tax Reform Discussions and Other Developments
By William H. Caudill, Norton Rose Fulbright LLP, Houston, TX
We are now heading into the last part of this 2016-2017 Tax Section year, having most recently completed the Section’s May Meeting in Washington—the third and largest meeting in our annual cycle of Section meetings. We have made good progress on many tasks, not least of which is the vital role of educating and informing our members and the public at large about tax reform.

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The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 70, No. 3 (Spring 2017):

• Karen L. Hawkins (Hawkins Law, Yachats OR; Former Director, IRS Office of Professional Responsibility), 2017 Erwin N. Griswold Lecture Before the American College of Tax Counsel: A (Not So) Modest Proposal, 70 Tax Law. 647 (2017)
• ABA Section of Taxation, Comments on Proposed Regulations Under Section 751(b), 70 Tax Law. 661 (2017)
• Karen C. Burke (San Diego), Hot Asset Exchanges: Integrating Sections 704(c), 734(b), and 751(b), 70 Tax Law. 711 (2017)

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ABA Tax Section May Meeting

The ABA Tax Section May Meeting kicks off today in Washington, D.C. The full program is here. Tax Profs with speaking roles include:

• Diversity: Anthony Infanti (Pittsburgh),  Jacqueline Lainez (UDC), Francine Lipman (UNLV)
• Employee Benefits:  Jon Forman (Oklahoma), Kathryn Kennedy (John Marshall)
• Fiduciary Income Tax:  Jerome Hesch (Miami)
• Financial Transactions:  Itai Grinberg (Georgetown)

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The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 70, No. 2 (Winter 2017):

• Paul J. Sax (Orrick, Herrington & Sutcliffe, San Francisco) , In Memoriam: M. Bernard Aidinoff, 70 Tax Law. 441 (2017)
• John P. Steines (NYU), Subsidized Foreign Tax Credits and the Economic Substance Doctrine, 70 Tax Law. 443 (2017)
• Allen D. Madison (South Dakota), The Legal Framework for Tax Compliance,  70 Tax Law. 497 (2017)

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ABA Tax Section Publishes New Issue Of Tax Times

The ABA Tax Section has published 36 Tax Times No. 2 (Feb. 2017):

FROM THE CHAIR
Interesting Times
By William H. Caudill, Norton Rose Fulbright LLP, Houston, TX
As I write this column, we are well into the Tax Section’s 2016–2017 year. I am pleased that we have made good progress on many tasks, but there is much that remains to be accomplished, not least of which is how we as tax lawyers will prepare for the tax reforms that will likely come our way as a result of this last election cycle and how the Section can contribute to the process.

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The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 70, No. 1 (Fall 2016):

• Paul J. Sax (Orrick, Herrington & Sutcliffe, San Francisco) & Lawrence B. Gibbs (Miller & Chevalier, Washington, D.C.), In Memoriam: Phillip L. Mann, 70 Tax Law. 1 (2016)
• J. Ross Macdonald (Baker & McKenzie, New York), “Time Present and Time Past:” U.S. Anti-Treaty Shopping History, Policy, and Rules, 70 Tax Law. 5 (2016)
• Allen D. Madison (South Dakota), The Legal Consequences of Noncompliance with Federal Tax Laws, 70 Tax Law. 367 (2016)

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Winners Of The 16th Annual Law Student Tax Challenge

ABA Tax Section, Winners in J.D. and LL.M. Divisions of Law Student Tax Challenge Chosen:

J.D. Division
1st Place:  Tyler Johnson & Anna Peckjian (Northwestern)
2nd Place:  Joshua Jacobson & George Gray (Florida)
3rd Place:  Nicholas Bjornson & Brian Lynn (Kansas)
Best Written Submission:  Joshua Jacobson & George Gray (Florida)

LL.M. Division

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ABA Tax Section Names 2017 Nolan Fellows

The ABA Tax Section announced the recipients of its 2017 Nolan Fellowships at its midyear meeting in Orlando:

• Elizabeth K. Blickley (Washington, D.C.)
• Matthew Cooper (Ernst & Young, Washington, D.C.)
• Nikki J. Hasselbarth (Venable, Baltimore)
• Vanessa C. Lafleur (Louisiana Department of Revenue, Baton Rouge)
• Rafi W. Mottahedeh (Jenner & Block, Chicago)
• Susanna W. Ratner (SeniorLAW Center, Philadelphia)

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2017 ABA Tax Section Janet Spragens Pro Bono Award

Press Release,  Wells Hall Receives 2017 ABA Section of Taxation Janet Spragens Pro Bono Award:

The American Bar Association Section of Taxation presented its annual Janet Spragens Pro Bono Award to C. Wells Hall III of Nelson Mullins Riley & Scarborough, during the Section’s Plenary Luncheon on January 21, 2017. ...

Wells served as Section Vice-Chair, Pro Bono and Outreach, from 2013 to 2016. During his tenure in that position, Wells championed programs to increase pro bono participation among Section membership and to increase access to tax assistance for low-income and underserved populations.

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ABA Tax Section Midyear Meeting

The ABA Tax Section Midyear meeting concludes today in Orlando. The full program is here.  Tax Profs with speaking roles include:

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ABA Tax Section Publishes November 2016 Issue Of Tax Times

The ABA Tax Section has published 36 Tax Times No. 1 (Nov. 2016):

FROM THE CHAIR
Boston Meeting Successes, and More to ComeBy William H. Caudill, Norton Rose Fulbright LLP, Houston, TX
We had a great joint meeting in Boston with the Real Property, Trust and Estate Law Section at the end of September. There were approximately 1,100 in attendance, and I was inspired by the enthusiasm about the activities of the Tax Section for the coming year. We have a lot of work to do, and we are going to have a good time doing it.

PEOPLE IN TAX
Interview with Anne-Marie Rábago
By Tom Greenaway, KPMG LLP, Boston, MA
Anne-Marie Rábago recently joined the State Bar of Texas as Director of the Texas Opportunity & Justice Incubator in Austin. We interviewed her at the Joint Fall Meeting in Boston to talk about the incubator movement and the access to justice gap.

AT COURT
Implications of Bitcoin Not Being Actual Currency: The Espinoza Case
By Joni Larson, Professor, Indiana Tech Law School, Fort Wayne, IN
Bitcoin is not the first virtual currency. It has, however, garnered significant attention by being embroiled in several scandals. Through the lens of the Espinoza case, this article examinations the tax implications of selling bitcoin.

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The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 69, No. 4 (Summer 2016):

• ABA Tax Section, Comments on the Multistate Tax Commission’s Proposed Draft Amendments to Its Model General Allocation and Apportionment Regulations, 69 Tax Law. 769 (2016)
• Bruce J. Squillante (General Ellectric), Temple-Inland—Revealing How the States Moved From Jackrabbits to Predators in Taking Unclaimed Property, 69 Tax Law. 773 (2016)
• Moon J. Koo (Korea Institute of Public Finance), Is the Investment Tax Credit Really More Coercive Than the Personal Property Tax Exemption in the Cuno Controversy?, 69 Tax Law. 817 (2016)

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ABA Tax Section Fall CLE Meeting

The ABA Tax Section concludes its three-day joint Fall CLE Meeting with the ABA Real Property, Trust and Estate Law Section today in Boston. The full program is here.  Tax Profs with speaking roles today include:

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ABA Tax Section Fall CLE Meeting

The ABA Tax Section continues its three-day joint Fall CLE Meeting with the ABA Real Property, Trust and Estate Law Section today in Boston. The full program is here.  Today's highlight is the joint program of the Teaching Taxation and State & Local Taxes sections on Out of Ferguson: Misdemeanors as Taxes and Municipal Courts as Tax Collectors:

The 2014 events in Ferguson, Missouri brought the operation of the municipal justice system in St. Louis County, Missouri into the public eye. Most of the 91 municipalities in St. Louis County have their own police force and municipal court. Increasingly, the police and municipal courts have been charged with a revenue raising function. City administrators have encouraged police to issue misdemeanor citations, primarily for traffic offenses including driving without insurance and failure to renew vehicle registration or the operator’s license. According to a Department of Justice Report on Ferguson, policing in Ferguson had come to serve primarily a revenue function, so that the police and courts became relatively little concerned with public safety in enforcing laws and more in generating revenue. This joint program will consider the impact of reclassifying these fines and penalties as taxes.

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ABA Tax Section Publishes Fall 2016 Issue Of Tax Times

The ABA Tax Section has published 35 Tax Times No. 4 (Fall 2016):

FROM THE CHAIR
Hail and Farewell
By George C. Howell, III, Hunton & Williams LLP, Richmond, VA
It has been an honor and a privilege to serve as Chair of the Tax Section over the past year. With the devotion of our volunteer members and the help of our dedicated staff, much has been accomplished.

FROM THE CHAIR-ELECT
Providing a Valuable Benefit
By William H. Caudill, Norton Rose Fulbright LLP, Houston TX
It is both exciting and humbling to be presented with the opportunity to serve as Chair of the Tax Section for 2016-2017. I have three objectives for the coming year: (1) focusing on the high quality output of our Committees in the areas of CLE programming and government submissions: (2) continuing the promotion of the Section’s pro bono and public service efforts—a longstanding priority for the Section; and (3) attracting new members, particularly younger and diverse tax lawyers, to the Section, and identifying new opportunities to meet their needs.

POINT & COUNTERPOINT
Perspectives on Two Proposals for Tax Filing Simplification
By Joseph Bankman, Ralph Parsons Professor of Law and Business, Stanford Law School, Stanford, CA, and James E. Maule, Professor of Law, Villanova University Charles Widger School of Law, Villanova, PA
In this Point and Counterpoint, Stanford Professor Joseph Bankman and Villanova Professor James Edward Maule debate two related tax-filing simplification proposals: data-retrieval system and pro forma return system.

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William Caudill Named Chair of ABA Tax Section

ABA Tax Section Press Release:

William H. Caudill, a partner in the Houston, TX, office of Norton Rose Fulbright, has been selected to chair the American Bar Association’s Section of Taxation, the nation’s largest organization of tax lawyers. Mr. Caudill will serve a one-year term, to be succeeded by Karen L. Hawkins, of Yachats, OR, who will serve as chair-elect.

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ABA Tax Section Accepting Nominations For 2017-2019 Public Service Fellowships

The ABA Tax Section is accepting applications for Public Service Fellowships for 2017-2019:

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 2017-2019. ...

The Christine A. Brunswick Public Service Fellowships provide funding for the Fellows’ salaries and benefits, as well as law school debt assistance, by means of charitable contributions to the Fellow's Sponsoring Organization. ... The Section plans to award up to two fellowships each year.

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ABA Tax Section Publishes Spring 2016 Issue Of Tax Times

The ABA Tax Section has published 35 Tax Times No. 3 (Spring 2016):

FROM THE CHAIR
Assisting the IRS
By George C. Howell, III, Hunton & Williams LLP, Richmond, VA:  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
By Terence Floyd Cuff, Loeb & Loeb LLP, Los Angeles, CA 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.

AT COURT
Missing Scalia?
By Jasper L. Cummings, Jr., Alston & Bird, LLP, Charlotte, NC
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.

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The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 69, No. 3 (Spring 2016):

2016 Erwin N. Griswold Lecture Before the American College of Tax Counsel

• Emily A. Parker (Thompson & Knight, Dallas), Stroke of the Scrivener’s Pen: Role of a Tax Planner and Litigator, 69 Tax Law. 477 (2016)

Selected Papers From the Inaugural International Taxpayer Rights Conference

• Nina E. Olson (National Taxpayer Advocate, IRS), Introduction, 69 Tax Law. 491 (2016)
• Alice G. Abreu (Temple) & Richard K. Greenstein (Temple), Tax as Everylaw: Interpretation, Enforcement, and the Legitimacy of the IRS, 69 Tax Law. 493 (2016)

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Death Of Phil Mann

Phillip L. Mann (Miller & Chevalier, Washington, D.C.) passed away over the weekend at the age of 76.  From his 2012 ABA Tax Section Distinguished Service Award:

This year’s tribute is made to honor the extraordinary contribution of Phil Mann through his commitment to sound tax law and policy, to fair and effective administration of the tax system, and to the importance of the role of the Tax Section.

Phil was born and raised in the town of Alva, a dot on Oklahoma’s western panhandle. Phil initially attended the University of Oklahoma and upon transferring to the University of Texas after a year, he proceeded to graduate in five years, obtaining both a Bachelor of Business Administration degree and his LL.B. in 1962, at the age of 22. At UT, Phil converted to become a lifelong Texan, especially relishing the successes of the Darrell Royal football teams during his college days.

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Book: Bureaucratic Oppression And The Tax System

Leslie Book (Villanova), Bureaucratic Oppression and the Tax System, 69 Tax Law. ___ (2016):

Observers of the Internal Revenue Service’s administration of the earned income tax credit (EITC) have leveled one main criticism, that the Service has been unable to reduce stubbornly high error rates. Congress has generally focused attention on this problem with many legislative initiatives, including unprecedented (for the tax system) penalties for improper claims, special due diligence rules for preparers submitting returns with EITC claims, and a lessening of pre-assessment right to judicial review of Service rejections of EITC claims.

In this Article I wish to shift attention to the Service’s poor service to EITC claimants. In particular, I wish to broaden the inquiry to reflect the insights of nontax scholars who have looked at the ways that administrative agencies interact with low-income individuals who rely on benefits that agencies administer.

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ABA Tax Section May Meeting

The ABA Tax Section May meeting concludes today in Washington, D.C.  The full program is here.  Today's highlights are:

Pro Bono & Tax Clinics, Reflecting on Low Income Tax Clinics and Celebrating Professor Kathryn Sedo

This program will look back at low income tax clinics since their inception with a particular focus on retiring clinic Professor Kathryn Sedo of the University of Minnesota. Professor Sedo has been a part of the low income taxpayer community as one of the founders of one of the oldest clinics in the country. As she retires from her current position, we have the opportunity to look at the changes in the tax system as it relates to low income taxpayers over the course of her career and to look forward.

• Frank DiPietro (Minnesota) (moderator)
• Leslie Book (Villanova)
• Keith Fogg (Harvard)
• Peter Panuthos (Chief Special Trial Judge, U.S. Tax Court)

Posthumous Presentation, 2016 Distinguished Service Award Recipient Ken Gideon

The Section of Taxation is pleased to honor Kenneth W. (“Ken”) Gideon as the recipient of its 2016 Distinguished Service Award in recognition for his distinguished career in recognition of his service to the profession, service to the government, and service to the Section. 

The Distinguished Service Award is the highest honor awarded by the Section of Taxation. The Award is given to individuals who have had a distinguished career in taxation and “who have provided an aspirational standard for all tax lawyers to emulate.” In the fall of last year, the Distinguished Service Award Committee unanimously selected Ken to be this year’s recipient. As is the custom of the Committee, the plan was to inform Ken of the Award at the Council Dinner during the January meeting in Los Angeles. Ken passed away unexpectedly on January 10, 2016, two weeks before the Los Angeles meeting. [See Michael Graetz, Farewell To Ken Gideon.]

Other Tax Profs with speaking roles today include:

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ABA Tax Section May Meeting

The ABA Tax Section May meeting continues today in Washington, D.C.  The full program is here.  Yesterday's highlight was the annual Laurence Neal Woodworth Memorial Lecture in Federal Tax Law and Policy on What Has the Tax Court Been Doing? An Update delivered by Senior Tax Court Judge James S. Halpern. Today's highlights are the two Teaching Taxation programs:

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ABA Teleconference Today On The Tax Code And Income Inequality

The ABA Section of Civil Rights and Social Justice and the ABA Tax Section are offering a free teleconference today at 3:30 - 5:00 EST on The Tax Code and Income Inequality: Limitations and Political Opportunities:

“Welfare” has become “workfare,” delivered through the Tax Code, e.g., the Earned Income Tax Credit and Child Tax Credit. How well is that really working for low and middle income Americans, much less those in poverty? At the same time, tax deductions, credits—and avoidance/evasion schemes—are increasingly benefitting wealthy individuals and big corporations, which increasingly pay a smaller portion of federal tax revenue—revenue that could fund government programs, bolster economic growth and benefit the bottom 99% by providing jobs and increase skills of lower income American. Panelists will discuss how changes to the Tax Code can address income inequality in the U.S. and political opportunities for reform.

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ABA Tax Section Announces 2016-18 Public Service Fellows

The 2016-2018 Christine A. Brunswick Public Service Fellowship Class:

• Laura LaPrade, a recent graduate of the University of the District of Columbia David A. Clarke School of Law, will be working with Community Tax Aid, Inc., in Washington, DC.
• Catherine Strouse, who earned her J.D. from Gonzaga University School of Law and an LL.M. in Taxation from the University of San Diego School of Law, will be working with the Legal Aid Society of San Diego.

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The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 69, No. 2 (Winter 2016):

• Armando Gomez (Skadden, Washington, D.C.) & Pamela F. Olson (PricewaterhouseCoopers, Washington, D.C.), In Memoriam: Kenneth W. Gideon, 69 Tax Law. 231 (2016)
• ABA Section of Taxation, Comments on Regulations Enabling Elections for Certain Transactions Under Section 336(e), 69 Tax Law. 237 (2016)
• ABA Section of Taxation, Comments on the Definition of Political Subdivison for Tax-Exempt Bonds and Other Tax-Advantaged Bonds, 69 Tax Law. 313 (2016)
• Martin J. McMahon, Jr. (Florida), Rethinking Taxation of Privately Held Businesses, 69 Tax Law.  345 (2016)

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ABA Tax Section Publishes Winter 2016 Issue Of Tax Times

The ABA Tax Section has published 35 Tax Times No. 2 (Feb. 2016):

• From the Chair: A Midyear Report, by George C. Howell, III (Hunton & Williams, Richmond, VA)
• People in Tax: An Interview With Kevin Sullivan (Connecticut Commissioner of Revenue Services), by Tom Greenaway (KPMG, Boston)
• At Court: Carpenter Says Individuals Cannot Discharge Vicarious Tax Liabilities in Bankruptcy, by Gregory Germain (Syracuse)

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ABA Tax Section Publishes Fall 2015 Issue Of Tax Times

The ABA Tax Section has published 35 Tax Times No. 1 (Oct. 2015):

• From the Chair: A Good Start, by George C. Howell, III (Hunton & Williams, Richmond, VA)
• Interview: Karen L. Hawkins (Former Director, IRS Office of Professional Responsibility), by Thomas D. Greenaway (KPMG, Boston) & Jasper L. Cummings, Jr. (Alston & Bird, Raleigh, NC & Washington, D.C.)
• Points to Remember: ‘Just Add SaLT!’ When and How to Consider State Tax Ethical Issues in Advising Clients, by Michael B. Lang (Chapman) & Rachel L. Partain (Caplin & Drysdale, New York)

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Winners Of The 15th Annual Law Student Tax Challenge

ABA Tax Section, Winners of the 15th Annual Law Student Tax Challenge:

The Section is pleased to announce the winners of the 15th Annual Law Student Tax Challenge, a contest designed to give students an opportunity to research, write about, and present their analyses of a real-life tax planning problem. The competition is open to both J.D. and LL.M. law students. The teams presented oral arguments before a panel of distinguished tax lawyers and tax court judges attending the Section of Taxation 2016 Midyear Meeting in Los Angeles, CA, with the winners honored at a reception during the meeting.

The awardees from this year's competition include:

J.D. Division

1st Place:
Scott Woody and Frank Cardoza
University of New Mexico School of Law
Coach: Mary Pareja

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The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 69, No. 1 (Fall 2015):

• Lawrence B. Gibbs (Miller & Chevalier, Washington, D.C.), Stanley L. Blend (Strasburger & Price, San Antonio, TX) & William H. Caudill (Norton Rose Fulbright, Houston, TX), In Memorium: B. Harvie Branscomb, Jr., 69 Tax Law. 1 (2015)
• ABA Tax Section, Comments on Proposed Regulations on Certain Partnership Provisions of the American Jobs Creation Act of 2004, 69 Tax Law. 5 (2015)
• George K. Yin (Virginia), Preventing Congressional Violations of Taxpayer Privacy, 69 Tax Law. 103 (2015)

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Tax Prof Tour And Dinner At ABA Tax Section Midyear Meeting In Los Angeles

Here is a photo of Tax Profs at the Frank Gehry Tour of Loyola-L.A. Law School and Dinner on January 29 (during the  ABA Tax Section Midyear meeting in Los Angeles):

(Photo credit: Brian Costello)

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ABA Tax Section Midyear Meeting

The ABA Tax Section Midyear meeting concludes today in Los Angeles. The full program is here. Today's highlight is the Keynote Address by Edward Kleinbard (USC), Fiscal Policy in an Age of Inequality:

Politicians of all persuasions are fixated on tax policy during this primary season, but this is the wrong question to debate. What we should care about is fiscal policy -- the net economic and social impacts of government taxing and spending, taken together. Government is not in the business of taxing us for sport, but rather of spending our money on public goods. Taxation is just how we finance the government we want.

A more muscular U.S. fiscal policy — not a further retrenchment — in fact responds to America's three great economic quandaries: (1) the surge in top-end inequality, where the income and wealth of the most affluent Americans have grown at rates that far outstrip the gains of the rest of America; (2) the stagnant incomes of the middle class; and (3) long-term growth. But we cannot see why this is true or how we can do better unless we look at the entirety of the opportunities for welfare-enhancing government investment and insurance, net of the cost of financing those programs through taxation. This outline presentation draws in part on my book, We Are Better Than This, to suggest why more government investment and insurance programs would lead to a happier and wealthier society. As in the book, the outline presentation benchmarks the United States against other countries to remind readers that we are unique in the world, and not always in a good way: we are a low-tax, small government, large and rich country that tolerates more poverty and much greater income inequality within our midst than do our peers.

Other Tax Profs with speaking roles today include:

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ABA Tax Section Midyear Meeting

The ABA Tax Section Midyear meeting continues today in Los Angeles. The full program is here. Today's highlight is the Teaching Taxation Program:

Inequality and Taxation. The debate over the nature of inequality and social mobility in the United States, and the corresponding role of taxation, continues to be at the center of public discourse. Potential tax reform will remain a major topic in political conversations in the coming year. Panelists will debate and discuss both the underlying issues and possible responses from the tax system, including redistribution and taxation, wealth concentration and estate and gift taxation, creative tax reform, and the legal and practical limits on a tax response to inequality.

• Chair:  Anthony Infanti (Pittsburgh)
• Moderator:  Kerry Ryan (St. Louis)
• Panelists:  Neil Buchanan (George Washington), Goldburn Maynard, Jr. (Louisville), Miranda Fleischer (San Diego)

Other Tax Profs with speaking roles today include:

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SoCal Law Students Invited To ABA Tax Section Careers In Tax Law Dinner On Jan. 28

The ABA Tax Section invites all Southern California area law students to attend a Careers in Tax Law Dinner this Thursday, Jan. 28, at the J.W. Marriott L.A. Live at 7:00 p.m.:

The ABA Section of Taxation cordially invites you to the Careers in Tax Law Dinner at the 2016 Midyear Meeting. A dynamic panel of tax practitioners will speak about the nature of their jobs, what they do, and how students might best prepare for and pursue careers in this field. Dinner will be provided.

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Loyola To Host Tax Prof Dinner At ABA Tax Section Midyear Meeting In Los Angeles

Tax Professors attending the ABA Tax Section Midyear Meeting in Los Angeles are invited to a dinner at Loyola Law School on Friday, Jan. 29 from 6:00-8:00 p.m.  If you would like to attend, please RSVP to Jennifer Kowal.

On a related note, please let me know if would like to break away and see the many wonders of Malibu (a 35 minute drive from the conference hotel).  I'd be happy to get together for breakfast, lunch, dinner, or drinks at one of the many beachfront spots here, or show you around America's most beautiful campus:

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The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 68, No. 4 (Summer 2015) (State and Local Tax Edition):

• 75th Anniversary Compendium—Evolution of SALT Practice and the SALT Committee, 68 Tax Law. 537-593 (2015)
• R. Bruce Johnson (Taxometry), State Tax Administrators and the Tax Section, 68 Tax Law. (2015)
• David R. Cassidy (Breazeale, Sachse & Wilson, Baton Rouge, LA), Reflections on the Past 15 Years, 68 Tax Law.  543 v(2015)
• Reflections on the SALT Committee: An Interview with Arthur R. Rosen (McDermott Will & Emery, Miami, FL), 68 Tax Law. 547 (2015)

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ABA Tax Section Fall CLE Meeting

The ABA Tax Section concluded its three-day joint Fall CLE Meeting with the ABA Real Property, Trust and Estate Law Section yesterday in Chicago.  The full program is here.  Tax Profs with speaking roles included:

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ABA Tax Section Accepting Nominations For 2016-2018 Public Service Fellowships

The ABA Tax Section is accepting applications for Public Service Fellowships for 2016-2018:

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 2016-2018. ...

The Christine A. Brunswick Public Service Fellowships provide funding for the Fellows’ salaries and benefits, as well as law school debt assistance, by means of charitable contributions to the sponsoring organization. The Section plans to award two fellowships each year.

Applications must be received by November 13, 2015, to be considered. Interviews will be conducted during the Section’s Midyear Meeting in Los Angeles, CA, on January 28-30, 2016. The Section will cover the cost of travel and accommodations for applicants selected for interviews.

To apply for the Christine A. Brunswick Public Service Fellowships, see here

ABA Tax Section Publishes Summer 2015 Issue Of News Quarterly

The ABA Tax Section has published 34 News Quarterly No. 4 (Summer 2015):

• Opinion Point, The ACA, the Service, and the Indian Health Care Delivery System, by Heather Erb & Christine Speidel, pp. 1, 20-21

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The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 68, No. 3 (Spring 2015):

• 75th Anniversary Compendium—Role of the Tax Section in Representing Underserved Taxpayers, 68 Tax Law. 421-62 (2015):
• Alice G. Abreu (Temple), For Good (Foreword), 68 Tax Law. 421 (2015)
• Nina E. Olson (National Taxpayer Advocate), The Tax Section’s Role as an Advocate for Equal Access to Justice: A Personal History, 68 Tax Law. 427 (2015)
• Michael Hirschfield (Dechert, New York), The Tax Section’s Role in Assisting Those Affected by Disasters and Other Tragedies, 68 Tax Law. 433 (2015)

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Call For Review Essays: ABA Tax Section NewsQuarterly

From Linda Beale (Wayne State):

The ABA Tax Section’s NewsQuarterly is transitioning to an all-digital format. One new feature to be introduced in connection with the move to digital is reviews of books and articles on topics of interest to tax practitioners. Reviews serve the purpose of informing readers of recent publications pertaining to tax policy and emerging issues, as well as broader concerns about the interrelationship between tax policies and economic growth. Reviews may be of single books or articles or they may be review essays that discuss and compare two or more books and articles addressing the same topic, similar to such review essays in the New York Review of Books. Reviews will be considered for publication in each quarterly issue, with the first review appearing in the Winter 2016 issue.

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ABA Tax Section May Meeting

The ABA Tax Section May meeting concludes today in Washington, D.C. The full program is here. Tax Profs with speaking roles today include:

• Employee Benefits:  Kathryn Kennedy (John Marshall)
• Pro Bono & Tax Clinics:  Scott Schumaker (U. Washington)
• Sales, Exchanges & Basis:  Brad Borden (Brooklyn), Danshera Cords (Albany), Erik Jensen (Case Western), Calvin Johnson (Texas), Roberta Mann (Oregon)

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 68, No. 2 (Winter 2015):

• 75th Anniversary Compendium—Evolution of Tax Practice, 68 Tax Law. 275-320 (2015):
• George C. Howell, III (Hunton & Williams, New York), A Tax Section Looks at 75 (Foreword), 68 Tax Law. 276 (2015)
• Stefan F. Tucker (Venable, Washington, D.C.), The Future of Our Profession, 68 Tax Law. 279 (2015)
• Kathryn Keneally (DLA Piper, New York), From Clique to Community: The Power of Inclusion, 68 Tax Law. 283 (2015)

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