U.S. Tax Prof Presentations At The 2023 Tax Research Network Conference

U.S. Tax Prof presentations at the two-day Tax Research Network Conference at the Faculty of Law, University of Cambridge:

Wednesday, September 6: 

Darien Shanske (UC-Davis; Google Scholar) & David Gamage (Indiana-Maurer; Google Scholar), Taxpayer Mobility and the Goal of Inclusive Prosperity:

Taxpayer mobility is often cited as a primary obstacle to progressive tax policies. However, this Article argues that mobility responses to taxation are often overemphasized. The empirical literature on taxpayer mobility sometimes characterizes responses as “large” merely because the responses are substantial enough to be measured with statistical significance. Yet, from a tax policy perspective, what should be considered “large” is partially a normative philosophical question. Applying a normative philosophical lens to the empirical literatures on taxpayer mobility, this Article concludes that there is no convincing evidence supporting the commonly held notion that taxpayer mobility should be considered a primary obstacle to enacting progressive tax policies—either for national-level governments or for subnational state and local governments. This does not imply that mobility responses are unimportant, however. This Article suggests policy responses to concerns related to taxpayer mobility for national governments and the international tax regime, for fiscal federalism and the interrelationship between national governments and subnational governments, and for subnational state and local governments acting on their own.

Michael Hatfield (Washington; Google Scholar), Safeguarding Taxpayer Data:

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Duke Symposium: Tax Evasion, Corruption, And The Distortion Of Justice

Symposium, Tax Evasion, Corruption and the Distortion of Justice, 84 Law & Contemp. Probs. 1-298 (2022): 

• Diane Ring (Boston College; Google Scholar) & Costantino Grasso (Manchester; Google Scholar), Foreword: Tax Evasion, Corruption and the Distortion of Justice, 84 Law & Contemp. Probs. i (2022)
• Diane Ring (Boston College; Google Scholar) & Costantino Grasso (Manchester; Google Scholar), Beyond Bribery: Exploring the Intimate Interconnections Between Corruption and Tax Crimes, 84 Law & Contemp. Probs. 1 (2022) (reviewed by Mirit Eyal-Cohen (Alabama; Google Scholar) here) 
• Daniel Ostas (Oklahoma), Endogenous Tax Law: Regulatory Capture and the Ethics of Political Obligation, 84 Law & Contemp. Probs. 49 (2022)

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Two Zoom Programs Next Week On The Impact Of The Affirmative Action Decisions On Law Schools

Following up on my previous posts:

• Legal Education's Reaction To The Supreme Court's Affirmative Action Decisions (June 30, 2023)
• Stephen Miller Sends Letter To 200 Law School Deans: I'll Sue If You Consider Race In Student Admissions, Faculty Hiring, Or Law Review Membership (July 1, 2023)
• More Legal Education Reaction To The Supreme Court's Affirmative Action Decisions (July 5, 2023)

Monday, July 10  11:00 AM ET|8:00 AM PT (registration) (program) (speakers)
AALS, Conference on Affirmative Action 

How can law schools achieve diversity in admissions without being able to engage in affirmative action? This issue is of enormous importance due to the Supreme Court’s decision of ending affirmative action in Students for Fair Admissions v. University of North Carolina and Students for Fair Admissions v. Harvard College. The program will focus on what is likely to be allowed and what is likely to be forbidden from these decisions. Several states — including California, Michigan, and Washington — already have eliminated affirmative action by voter initiatives. What can be learned from their experience about how to achieve diversity without affirmative action? Experts who have been dealing with this for many years will offer their practical suggestions.

Tuesday July 11  7:00 PM ET|4:00 PM PT (registration)
George Mason, Scalia­–Ginsburg Colloquy: A Balanced Discussion of Both Sides of the Affirmative Action Decision

Two distinguished constitutional law scholars will present opposing viewpoints in the historic case: Harry G. Hutchison, senior counsel and director of policy for the American Center for Law and Justice and a former Scalia Law professor, and Theodore M. Shaw, the Julius L. Chambers Distinguished Professor of Law and director of the Center for Civil Rights at the University of North Carolina School of Law.

David E. Bernstein, University Professor of Law and executive director of Scalia Law’s Liberty & Law Center, will moderate the colloquy. Bernstein is an expert on affirmative action and author of the recent book, Classified: The Untold Story of Racial Classification in America. Eugene Scalia and James Ginsburg will deliver introductory remarks on behalf of their families.

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University Of Cambridge Hosts Conference Today On Tax, Public Finance, And The Rule Of Law

The two-day 6th Annual Tax Policy Conference on Tax, Public Finance and the Rule of Law concludes today at the Centre for Tax Law at the University of Cambridge Faculty of Law. U.S. Tax Prof presentations include:

Alex Raskolnikov (Columbia), Distributional Limits of Legal Rules: 

The estate tax applies only to the rich, and so did the income tax for the first three decades of its existence. Many new taxes recently proposed by academics and politicians target only the rich as well. And any progressive tax takes more from the rich than from others. Yet no one has suggested that property law, contract law, antitrust or corporate law, to take just some examples, should have special, less favorable rules applicable only to the wealthy. This paper asks: why not? What is the problem with a separate law for the rich, especially given the long history of progressive taxation and the widespread academic support for the idea that legal rules should reflect distributional considerations as a general matter?

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Oxford Centre For Business Taxation Hosts 17th Annual Academic Symposium

The three-day Oxford University Centre for Business Taxation's 17th Annual Academic Symposium kicksoff today: 

Monday, June 26

Session 1: 

Chair: Michael Devereux (Oxford; Google Scholar)

Juan Carlos Suarez-Serrato (Stanford; Google Scholar), Does Tax Planning by US Multinationals Impact their Economic Activity? (with Rosanne Altshuler (Rutgers; Google Scholar) & Lysle Boller (Duke))
Discussant: Naomi Feldman (Hebrew University; Google Scholar) 

Annette Alstadsæter (Norwegian; Google Scholar), Pennies from Haven: Wages and Profit Shifting (with Julie Brun Bjørkheim (Norwegian; Google Scholar), Ronald Davies (University College Dublin) & Johannes Scheuerer (University College Dublin))
Discussant: Sarah Clifford (Oxford; Google Scholar)

Session 2: 

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Alan Turing Institute Hosts Workshop Today On AI In Tax, Audit, And Fintech At The University Of Surrey

The Alan Turing Institute hosts a workshop today on AI in Tax, Audit, and Fintech at the University of Surrey (program):

The use of digital technologies in tax and financial services has come far over the last ten years while there has been little attention on how it empowers and impacts a diverse society. The workshop aims to match digital innovation in tax administration with principles and mechanisms to protect both users and the reliability of outputs. The workshop will bring together experts in tax administration, fintech, economic policy design, machine learning, AI, early career researchers and PhD students. The co-sponsors are It is co-organized by Queen Mary University of London, University of Exeter, and University of Surrey.

• Panel #1: The Role of Digital Technology in Tax Administration
• Panel #2: Principles and Standards
• Panel #3: Using AI to Advance Administration and Policy
• Panel #4: Using AI to Advance Administration and Policy
• Panel #5: The Impact of AI Tools on Practice
• Panel #6: Using AI to Advance Administration and Policy
• Panel #7: Taxing AI and Cryptocurrencies

Michael Hatfield (University of Washington; Google Scholar) presents Professionally Responsible Artificial Intelligence, 51 Ariz St. L.J. 1057 (2019), today on Panel #5:

As artificial intelligence (AI) developers produce more applications for professional use, how will we determine when the use is professionally responsible? One way to answer the question is to determine whether the AI augments the professional’s intelligence or whether it is used as a substitute for it. To augment the professional’s intelligence would be to make it greater, that is, to increase and improve the professional’s expertise. But a professional who substitutes artificial intelligence for his or her own puts both the professional role and the client at risk. The problem is developing guidance that encourages professionals to use AI when it can reliably improve expertise but discourages substitution that undermines expertise.

This Article proposes a solution, using tax professionals as a case study.

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Today's 13th Annual IRS/TPC Joint Research Conference On Tax Administration

13th Annual IRS/TPC Joint Research Conference on Tax Administration:

The Internal Revenue Service (IRS) and the Urban-Brookings Tax Policy Center invite you to attend virtually or in-person the only annual conference focused exclusively on tax administration research. Researchers from the IRS, other government agencies, academia, and private organizations will discuss some of the latest analyses seeking to make tax administration as effective as possible.

• Agenda
• Abstracts of Papers

Opening

• Wendy Edelberg (Director, Hamilton Project, Brookings Institution)
• Eric Toder (Institute Fellow, Tax Policy Center)
• Barry Johnson (Deputy Chief Data and Analytics Officer, Research, Applied Analytics and Statistics, IRS)

Session 1: Service is Our Surname

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Northwestern Hosts Annual State And Local Tax Symposium: Projecting The Future Of SALT

Northwestern hosts the 2023 State And Local Tax Symposium today (program):

• Hayes Holderness (Richmond), Self-Policing Through Retaliatory Taxation (with Matt Schnall (WilmerHale)
• Michelle Layser (San Diego; Google Scholar), Help Wanted: Better Formulas for Apportioning Income, Residence and Intangibles (with Matt Schnall (WilmerHale)_
• Francine Lipman (UNLV; Google Scholar), Not Taxing Puerto Rico? Whitewashing Impoverishment in U.S. v. Vaello-MaderoNot Taxing Puerto Rico? (with Aubrey Griffin (PwC))

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Tax Presentations At Today's National Business Law Scholars Conference

Tax presentations at the National Business Law Scholars Conference today at Tennessee (schedule): 

Jordan Barry (USC; Google Scholar), Tax and the Boundaries of the Firm (with Victor Fleischer (UC-Irvine; Google Scholar)): 

We analyze how income taxes distort firms’ decisions regarding what to produce themselves ("make") or purchase from others ("buy") along a number of dimensions. Many of these provisions expand the boundary of the firm; others contract it. Importantly, the expansions and contractions generally operate on different points, and thus do not offset each other, making each distortion problematic.

Our framework provides insight into a number of key tax policy questions, including the merits of worldwide versus territorial tax systems, the economic cost of the corporate tax, and the effects of the Tax Cuts and Jobs Act of 2017.

Assaf Harpaz (Drexel; Google Scholar), International Tax Reform: Who Gets a Seat at the Table?:

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Columbia Hosts 2023 Tax Policy Workshop

Columbia hosts the two-day 2023 Tax Policy Workshop (program):

Monday, June 12:

Steve Hamilton (George Washington), Hundreds and Thousands: Bunching at Positive, Salient Tax Balances and the Cost of Reducing Tax Liabilities (with Robert Breunig (Australian National University; Google Scholar) & Nathan Deutscher (Australian National University; Google Scholar))
Discussant: Michael Best (Massachusetts; Google Scholar)

Rebecca Kysar (Fordham; Google Scholar), Towards Global Taxation
Discussant: Emily Satterthwaite (Georgetown; Google Scholar)

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Today's Law, Society, And Taxation Panels

Today's Law, Society, and Taxation panels at the 2023 Law & Society Association Annual Meeting in San Juan, Puerto Rico:

Taxation & Social Impact (Tessa Davis (South Carolina), Chair/Discussant):

The tax code is used in a vareity of ways to enact or support social goals that are not necessarily explicitly tied to economic ends. The papers in this session will think about how tax and spending programs are used to achieve particular ends. Papers in the session will consider both intended and unintended consequences of the relevant provisions on the social outcomes of the individual taxpayers affected by the rules.

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Today's Law, Society, And Taxation Panels

Today's Law, Society, and Taxation panels at the 2023 Law & Society Association Annual Meeting:

Tax Advocacy & Tax Justice (Mirit Eyal-Cohen (Alabama; Google Scholar), Chair/Discussant):

Tax lawyers operate inside a system that often challenges traditional notions of zealous advocacy in lawyering. Further, decisions around tax law, tax policy, and tax lawyering must be made in the larger context of goals around social policy and desired social outcomes. The papers in this session examine both particular tax lawyers but also the larger issues faced by tax lawyers as a whole. Also considered is the role the tax law plays in affecting lawyers' actions and infuencing their decisions.

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Today's Law, Society, And Taxation Panel

Today's Law, Society, and Taxation panel at the 2023 Law & Society Association Annual Meeting in San Juan, Puerto Rico:

Taxation of Labor and Business 

• Session Organizer: Neil Buchanan (Florida; Google Scholar) 
• Chair/Discussant: Orly Mazur (SMU; Google Scholar) 

The imposition of a tax has an impact on the social and economic responses of taxpayers, whether individuals or corporations. The papers in this session contemplate the effects of a variety of tax rules on the business decisions of workers and employers, and think through what improvements might be available as a matter of tax policy and tax design.

Mirit Eyal-Cohen (Alabama; Google Scholar), Taxing Innovation Inventiveness:

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Conference For Tax Profs Tenured 1-15 Years At San Diego

San Diego hosted a combined AMT (Association of Mid-Level Tax Scholars Conference, for those tenured for 1-10 years) and EITC (Experienced in Tax Conference, for those tenured for 11-15 years) earlier this week:

Panel #1:

Ari Glogower (Ohio State; Google Scholar), Restoring Substance to the Taxing Power
Discussant: Omri Marian (UC-Irvine; Google Scholar)

Jake Brooks (Fordham; Google Scholar), The Constitutional Meaning of “Income”: Moore v. United States and the Movement to Revive Eisner v. Macomber
Discussant: Michael Doran (Virginia; Google Scholar)

Brian Galle (Georgetown; Google Scholar), Unreserved: Central Banks Have Powerful New Tools for Controlling the Economy but They’re Still Playing by the Old Rules
Discussant: Steven Dean (Brooklyn)

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Tax Papers At Junior Faculty Forum At Richmond

Tax presentations at this week's Junior Faculty Forum at Richmond (program):

Assaf Harpaz (Drexel; Google Scholar), International Tax Reform: Challenges to Multilateral Cooperation, 44 U. Pa. J. Int'l L. __ (2023):

In 2021, the OECD proposed new rules for the cross-border taxation of multinational corporations. The proposed rules set forth the most significant reform to international tax rules in several decades. They follow approximately a decade of multilateral negotiation led by the OECD and drafted by a broader Inclusive Framework of over 140 countries. The goal of this Article is to highlight the importance of multilateral cooperation and illuminate the obstacles to implementing international tax reform. It argues that the new international tax framework requires unprecedented multilateral cooperation to reallocate taxing rights and limit profit shifting. But such ambitious cooperation may be more than countries can accomplish. The new rules are largely an outcome of political compromises rather than a principled approach to tax policy. They infringe on tax sovereignty, limit tax competition, and undermine the economic interests of the world’s developing countries.

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ABA Tax Section May Meeting Kicks Off Today In Washington, D.C.

This week's ABA Tax Section 2023 May Tax Meeting (program) kicks off today. A highlight is the Teaching Taxation program on Friday on Taxing the Metaverse:

The buzz surrounding the Metaverse—a digital space featuring virtual reality, augmented reality, and other advanced internet technology—has been growing steadily for the past couple of years, but the tax implications of this novel ecosystem remain fuzzy to most tax scholars. Such uncertainty is concerning, given the potential and momentum of this emerging technology. Although the Metaverse evolved from online video games focused only on user consumption, it now allows users to produce income and accumulate wealth entirely within the Metaverse. Current law seems to defer taxation of such until a realization or cash-out event. This panel will examine the tax implications of various economic activity in the Metaverse, such as self-created virtual assets (like NFTs), loot drops, intra-Metaverse exchanges, inter-Metaverse exchanges, and cash-for-virtual goods exchanges. Furthermore, this panel will discuss whether Metaverse taxation should be deferred until cash-out or immediate taxation, such as mark-to market, is possible. Finally, the panel will explore potential compliance issues posed by Metaverse activity.

• Young Ran (Christine) Kim (Cardozo; Google Scholar) (moderator)
• Eric Chason (William & Mary) 
• David Gamage (Indiana-Maurer; Google Scholar) 
• Omri Marian (UC-Irvine; Google Scholar)
• Caitlin Tharp (Steptoe & Johnson, Washington, D.C.) 

Other Tax Profs with speaking roles include:

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26th Annual Critical Tax Conference At Loyola

Loyola-L.A. hosts the 26th Annual Critical Tax Conference (program) today and tomorrow:

Friday

9:00 AM: Welcome 

• Jennifer Kowal (Loyola-L.A.)

9:10 AM: What is Critical Tax? 

• Diane Klein Kemker (DePaul), Teaching Critical Tax: What, Why, & How?, 19 Pitt. Tax Rev. 143 (2022)
• Ariel Jurow Kleiman (Loyola-L.A.; Google Scholar), Taxation and Law and Political Economy, 83 Ohio St. L. J. 471 (2022) (with Jeremy Bearer-Friend (George Washington; Google Scholar), Ari Glogower (Northwestern; Google Scholar) & Clinton Wallace (South Carolina; Google Scholar)) (reviewed by Hayes Holderness (Richmond) here and Neil Buchanan (George Washington) here)
• Katie Pratt (Loyola-L.A.; Google Scholar) (moderator)

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Colloquium On Taxing Income And Consumption Today At Queensland (Australia)

Queensland University of Technology Hosts a Colloquium today on Taxing Income and Consumption: Past, Present and Future. Highliughts include:

Addressing Some Tax Fundamentals

• Victor Thuronyi (International Monetary Fund), Should We Tax Income or Consumption? 

International Tax: BEPS and Beyond

• Cliff Fleming (BYU; Google Scholar), Robert Peroni (Texas) & Stephen Shay (Boston College; Google Scholar), What's the Problem That Prompted Pillar 2 and is there a Better Solution?

Tax Reform: Lessons for the Future

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Virginia Hosts Tax Study Group Meeting

The Virginia Center for Tax Law hosts a Virginia Tax Study Group Meeting today from 9:30 AM - 4:45 PM EST (registration): 

9:30 AM - 10:45 AM:  D.C. Panel

• Tiffany Smith (Senate Finance Committee) 
• Krishna Vallabhaneni (U.S. Treasury) 
• Kashi Way (U.S. Congress Joint Committee on Taxation) 
• Mark Warren (Brownstein Hyatt Farber Schreck)
• Cecily Rock (U.S. Congress Joint Committee on Taxation) (moderator)

11:00 AM - 12:15 PM: The Corporate Alternative Minimum Tax

• Mindy Herzfeld (Florida)
• Marie Milnes-Vasquez (IRS)
• Michael Schler (Retired, Cravath, Swaine & Moore) 
• Jeri K. Seidman (Virginia-McIntire; Google Scholar)
• Eric Solomon (Steptoe & Johnson) (moderator)

12:30 PM - 1:45 PM: Keynote Address 

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Call For Papers: Tax Research Network Conference At Cambridge

Call for Papers:

The conference will be held at the University of Cambridge from 5-7 September 2023 and will run as an in-person conference with some virtual provision for those who are unable to travel to Cambridge. As usual, the first two days will be research focused, while the Tax Education Day will run on the 7th September. Further details of the conference are at TRN Conference 2023 – Cambridge. Both research and teaching focused papers are welcomed in this call for papers.

There will be concurrent sessions over the conference to accommodate the papers submitted. The virtual sessions will be conducted via Microsoft Teams with links to be provided prior to the conference.

The conference will offer a limited number of fee scholarships and travel bursaries for PhD students and Early Career Research/Teaching colleagues. We will also hope to have limited funding for supporting childcare costs. Further details will be available once registration opens.

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Yale Hosts Symposium On The Legal Treatise: Past, Present, And Future

Yale hosts a symposium today on The Legal Treatise: Past, Present, And Future (registration):

The Lillian Goldman Law Library, with the generous support of the Oscar M. Ruebhausen Fund at Yale Law School, is pleased to announce its second legal information symposium: “The Legal Treatise: Past, Present, and Future,” scheduled to take place at Yale Law School on Friday, March 24, 2023. The papers presented at this event will be published as a special symposium issue of Law Library Journal. This symposium will examine the legal treatise as a source and genre through the lenses of history, authorship, identity, and transition. 

Welcome Remarks 

• Femi Cadmus (Librarian, Yale; Google Scholar) 
• Heather Gerken (Dean, Yale) 

Keynote Address 

• John Langbein (Yale), The Rise and Fall of Legal Academic Treatise Writing in the United States

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UCLA|NYU|Berkeley Host Conference Today On Five Years After TCJA: New Directions In Tax Policy Research

UCLA|NYU|Berkeley host a symposium today on Five Years After TCJA: New Directions in Tax Policy Research today:

Tax Evasion|Non-Compliance|IRS Money and the Future of Tax Enforcement

• Natasha Sarin (Penn; Google Scholar)
• Daniel Reck (Maryland)
• Day Manoli (Georgetown; Google Scholar)

Taxing the Rich After TCJA

• Danny Yagan (UC-Berkeley; Google Scholar)
• Wojciech Kopczuk (Columbia; Google Scholar)
• Daniel Hemel (NYU; Google Scholar)
• David Kamin (NYU) (discussant)

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Stetson Hosts 2nd Annual Tax Law Symposium Today

The Stetson Business Law Review hosts a Tax Law Symposium today at  9:00 AM (registration): 

State and Local Tax Law Panel

• George Thurlow, America’s Most Hated Tax?: Why Property Taxes Are Unfair and Regressive Taxation
• Omar Hussein, Stock Transfer Taxes in the Modern Age

Embracing Tax Avoidance

• David Elkins (Netanya, visiting NYU; Google Scholar) 

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American Tax Policy Institute Hosts Symposium This Friday On The Federal Income Tax: Racially Blind but Not Racially Neutral

The American Tax Policy Institute hosts a symposium on The Federal Income Tax: Racially Blind but Not Racially Neutral at Skadden, Washington, D.C., on Friday, February 24 (free registration):

Introduction and Opening Remarks

• Alice Abreu (Temple)

Panel I: Race, History, Taxation and Behavior

Race and taxation have always been intertwined in the United States. Tax law is deeply implicated in slavery, as colonies and then states sought to impose taxes on both land and the human beings who were treated as property. The United States Constitution famously counted enslaved persons as three-fifths of the white persons in the jurisdiction, and did not count “Indians” at all, for purposes of determining political representation. How, over time, did how subordinated racial groups, particularly African Americans, Native Americans, and others, rely on tax rhetoric and reality, including their roles as taxpayers, to demand greater political and social rights? In what way has the tax system continued to prop up the systematic exclusion of Blacks and other groups from ownership of homes and other property? What are the racial and gendered dimensions of choices taxpayers have made over time, including choices about the provision of services to family members? Who benefits from the tax-free treatment of imputed income? Given the tax system’s role in racial subordination, is there a way that the tax laws might be deployed to remedy race-based harms of enslavement, forced dispossession, centuries of race-based discrimination, or raced and gendered patterns of behavior?

• Alice Thomas (Howard) (moderator)
• Jeremy Bearer-Friend (George Washington; Google Scholar), Poll Taxes, Revisited
• Nyamagaga Gondwe (Wisconsin; Google Scholar), Economic Precarity and Tax Invisibility of Uncompensated Kin-Group Service Providers
• Anthony Infanti (Pittsburgh; Google Scholar), Taxation and Slavery in Colonial America: The Case for Reparations
• Richard Winchester (Seton Hall; Google Scholar), The Pontchartrain Park Case: Privilege Joins Prejudice in Tax Court 

Panel II: Tax Systems and Privileged Choices

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Hofstra Hosts Symposium Today On Freedom Of Expression At American Law Schools

Hofstra hosts a symposium today on Freedom of Expression at American Law Schools (registration): 

Commitments to principles supporting the freedom of expression are found in statements of policy at public and private institutions of higher education throughout the United States. American law schools, either as parts of larger universities or standing alone, have embraced similar policies adhering to the principle that free intellectual inquiry is at the core of a law school’s educational and research mission.

General statements about free expression, however, do not always resolve actual controversies. When does expression "go too far?" Are controversies over free expression at law schools different from those elsewhere on campuses? There have been powerful reminders, in recent years, that law school free expression has limits — that at some point it can collide with other values and interests of concern to deans, faculty, and students.

Agenda:

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ABA Tax Section Mid-Year Meeting Kicks Off Today In San Diego

This week's ABA Tax Section Midyear Tax Meeting (program) kicks off today. A highlight is the Teaching Taxation program on Friday on New Directions in Tax Information Reporting and Withholding:

Tax information reporting and withholding rules play critically important roles in the United States tax system. When income is subject to mandatory tax information reporting—where third parties and/or taxpayers disclose information regarding certain transactions and activities to the IRS—the individual tax compliance rate is very high. When income is subject to both tax information reporting and withholding, it is even higher. While tax information reporting and withholding rules are among the government’s essential tax enforcement and administration tools, under current law, these rules do not apply equally to all taxpayers and transactions. Gaps in these rules lead not only to the potential spread of tax noncompliance, but they also raise important fairness concerns. Further, these rules often receive less attention from tax policymakers and tax law scholars than other aspects of the substantive tax law. This panel will consider new policy directions for tax information reporting and withholding rules in a variety of contexts, including taxpayers engaged in the gig economy, incarcerated taxpayers, and high-income and wealthy taxpayers.

• Michelle Layser (San Diego; Google Scholar) (moderator)
• Joshua Blank (UC-Irvine)
• Jessica Jeane (Vice President for Tax Policy, Western CPE)
• Katherine Pratt (Loyola-L.A.)

Other Tax Profs with speaking roles include:

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Call For Presentations: UC-Irvine Symposium On Taxation Of Crypto-Assets

The UC-Irvine Graduate Tax Program has issued a call for papers for its fifth annual Taylor Nelson Amitrano LLP Tax Symposium on Taxation of Crypto Assets on April 17, 2023:

We are interested in submissions for proposed presentations on current issues relating to taxation of crypto-assets in the United States and abroad.

This one-day virtual symposium will be attended by tax industry professionals, government officials, and academic researchers from all over the world. Presenters of accepted submissions will be invited to present at the event.

We accept submissions from:

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Brooklyn Hosts A Book Talk And Discussion Today On For-Profit Philanthropy

Brooklyn hosts a hybrid Book Talk and Discussion with Dana Brakman Reiser (Brooklyn; Google Scholar) and Steven A. Dean (Brooklyn), featuring Anne-Marie Slaughter (CEO, New America; Professor Emerita, Princeton University) on For-Profit Philanthropy: Elite Power & the Threat of Limited Liability Companies, Donor-Advised Funds, & Strategic Corporate Giving (Oxford University Press 2023) today at 6:00 PM ET:

About the Book

Please join Professors Dana Brakman Reiser and Steven A. Dean for a discussion of their new book For-Profit Philanthropy (Oxford University Press, Jan. 3, 2023).

In For-Profit Philanthropy, the authors reveal that philanthropy law has long operated as strategic compromise, binding ordinary Americans and elites together in a common purpose. At its center stands the private foundation. Prophylactic restrictions separate foundations from their funders' business and political interests. And foundations must disclose more about the sources and uses of their assets than any other business or charity. The philanthropic innovations increasingly espoused by America's most privileged individuals and powerful companies prioritize donor autonomy and privacy, casting aside the foundation and the tools it provides elites to demonstrate their good faith. By threatening to displace impactful charity with hollow virtue signaling, these actions also jeopardize the public's faith in the generosity of those at the top.

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Call For Papers: BI Norwegian Business School Workshop On Taxation, Citizenship, And Democracy

Call For Papers:

We invite submissions from scholars in from law, politics, economics, and history to jointly discuss the interlinking between taxation, citizenship, and democracy. The workshop and publication strive for a multidisciplinary approach and thought-provoking ideas on the theme. In contrast to general legal scholarship, formal citizenship has not been of particular interest to tax scholarship. 

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New York Law School Symposium: Race, Bias, And Advocacy

Symposium, Race, Bias, and Advocacy, 66 N.Y. L. Sch. L. Rev. 121-413 (2021-2022):

• Deborah N. Archer (NYU; Google Scholar), Preface, 66 N.Y. L. Sch. L. Rev. 121 (2021-2022)
• Edward A. Purcell, Jr. (New York Law School; Google Scholar), Race Across the Curriculum: A Team-Taught Course on Law and Race in America, 66 N.Y. L. Sch. L. Rev. 125 (2021-2022)
• Edward A. Purcell, Jr. (New York Law School; Google Scholar), Race and the Law: The Visible and the Invisible, 66 N.Y. L. Sch. L. Rev. 141 (2021-2022)

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Santa Clara Symposium: Lawyers, Leadership, And Change

Symposium, Lawyers, Leadership, and Change: Addressing Challenges and Opportunities in Unprecedented Times, 62 Santa Clara L. Rev. 1-244 (2022):

• Donald J. Polden (Dean Emeritus, Santa Clara), Introduction, 62 Santa Clara L. Rev. i (2022)
• Lindsey P. Gustafson (Arkansas-Little Rock), Aric K. Short (Texas A&M; Google Scholar) & Neil W. Hamilton (St.  Thomas-MN; Google Scholar), Teaching and Assessing Active Listening as a Foundational Skill for Lawyers as Leaders, Counselors, Negotiators, and Advocates, 62 Santa Clara L. Rev. 1 (2022)
• Joan MacLeod Heminway (Tennessee; Google Scholar), Change Leadership and the Law School Curriculum, 62 Santa Clara L. Rev. 43 (2022)

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Call For Papers: Cambridge Tax Policy Conference On Tax, Public Finance And The Rule of Law

Call For Papers: 

The Centre for Tax Law at the University of Cambridge is delighted to invite proposals for papers to be presented at our sixth Tax Policy Conference on Monday 3 and Tuesday 4 July 2023.

The topic of the conference is ‘Tax, public finance and the rule of law’. We have prepared a brief paper explaining this theme and setting out possible areas in which proposals could be made.

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Louisville Law Review Symposium: Mental Health And The Legal Profession

Mental Health and the Legal Profession, 60 U. Louisville L. Rev. 423- 519 (2022):

• Timothy S. Hall (Louisville), "We Don't Talk about Bruno:" Of Mental Health, Honesty and Openness, and the Legal Profession, 60 U. Louisville L. Rev. 423 (2022)
• David Jaffe (American), Reflections on Law Student Mental Health by a Dean of Students after 25 Years, 60 U. Louisville L. Rev. 429 (2022)
• David Jaffe (American), Katherine Bender (Bridgewater State) & Jerome Organ (St. Thomas-MN), "It Is Okay to Not Be Okay": The 2021 Survey of Law Student Well-Being, 60 U. Louisville L. Rev. 441 (2022)

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Drake Legal Education Symposium

Symposium on Legal Education, 70 Drake L. Rev. 1- 247 (2022): 

• Russell E. Lovell (Drake), Celebrating the Drake Legal Clinic at 50! Drake Law Experiential Education at 157! 157–50! A Proud Tradition since 1865, 70 Drake L. Rev. 1 (2022)
• Melissa L. Kidder (Ohio Northern; Google Scholar), The Future of Rural Lawyering: How Law Schools Should Embrace a General Practice Legal Clinic Model to Address the Current and Future Legal Needs of Rural and Smaller Communities, 70 Drake L. Rev. 83 (2022)
• Carolyn Young Larmore (Chapman; Google Scholar), Just Compensation: An Empirical Examination of the Success of Legal Externships for Pay and Credit, 70 Drake L. Rev. 145 (2022)

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Call For Papers: Stetson Tax Law Symposium

The Stetson Business Law Review has issued a call for papers for its Tax Law Symposium:

Stetson Business Law Review (SBLR) is seeking articles and presenters for the 2023 edition of its Tax Law Symposium. The SBLR was founded in the 2019-20 academic year by ambitious students with strong interests in business law following the establishment of the Stetson Business Law Concentration. Earlier this year, SBLR successfully hosted its inaugural Symposium focused on white collar crime. The second annual Symposium will take place virtually on Friday, February 24, 2023, with an opportunity for hybrid in-person presentations. Following the virtual event, SBLR will be hosting a networking reception at the Tampa Law Center.

We invite you to submit an article for publication in the next edition of the Symposium paired with a presentation, or to join as a presenter without an article submission. We are hopeful that you take advantage of this unique opportunity to share your specialized knowledge for the benefit of the profession, while showcasing your expertise nationally. Each submission should be related to tax law, and satisfy the following:

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Tax Policy Center Hosts Virtual Event Today On The Future Of Business Taxes Post-Inflation Reduction Act

The Tax Policy Center hosts a virtual event on The Future Of Business Taxes Post-Inflation Reduction Act today at 12:30 PM ET (registration):

The recently enacted Inflation Reduction Act (IRA) put in place some significant changes to business taxation, including incentives for clean energy and a minimum tax on large corporations’ book incomes. But how effective will those measures be in achieving their goals? And what should Congress do next, with so many unanswered questions about the future of corporate taxation and climate change?

Join the Urban-Brookings Tax Policy Center for an event examining the IRA and the short-term future of corporate taxation. The event will feature keynote remarks by Treasury Assistant Secretary for Tax Policy Lily Batchelder and two expert panels. The first panel will examine the new corporate tax provisions, and the second panel will examine expanded green-energy incentives.

Keynote Speaker: 

• Lily Batchelder (Assistant Secretary for Tax Policy, U.S. Treasury)

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Stanford Hosts Forum Today On Tax Policies For A Freer And Fairer Country

The Stanford Institute for Economic Policy Research (SIEPR) hosts a forum today from 11:30 AM - 7:00 PM PT (register here). 

12:00 PM: Welcome Remarks

• Mark Duggan (Stanford; Google Scholar), the Trione Director of SIEPR, the Wayne and Jodi Cooperman Professor of Economics

12:15 PM: Tax on Individuals—Equity and Efficiency

• Kimberly Clausing (UCLA; Google Scholar)
• Kevin Hassett (Hoover Institution; Google Scholar)
• Scott Hodge (Tax Foundation)
• Mark Wolfson (Stanford) (moderator)

 

 

 

 

 

1:30 PM: Corporate Tax—Tax-induced Distortions, Profit Shifting, and Location and Investment Decisions

• Alan Auerbach (UC-Berkeley; Google Scholar)
• Michelle Hanlon (MIT; Google Scholar)
• Marcus Heyland (KPMG)
• Juan Carlos Suarez Serrato (Duke; Google Scholar)
• Rebecca Lester (Stanford; Google Scholar) (moderator)

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Brooklyn Hosts Discussion Today On A Global UN Tax Convention And Human Rights

Brooklyn hosts a Discussion on a Global UN Tax Convention and Human Rights today from 5:00 PM - 6:30 PM EST. 

Objectives
On the margins of the UN General Assembly, the UN Independent Expert on foreign debt and human rights is convening a side event with the general aim of deepening discussions around the content of her thematic report, including the recommendations therein. More specifically, this side event will focus on:

• Further discussing the current issues plaguing the international tax architecture;
• Examining in detail the recommendations of creating a global UN led tax convention and a global tax body using a human rights lens.

Moderator: 

• Attiya Waris (UN Independent Expert; Google Scholar)

Speakers: 

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Pittsburgh Hosts Symposium Today On Protecting Dynastic Wealth

Pittsburgh hosts a symposium on Protecting Dynastic Wealth: Perspectives on the Role of Estate and Gift Tax in Perpetuating Inequality today at 8:00 AM -2:00 PM ET (live stream here): 

Opening Keynote:  Jonathan Blattmachr, The 200-Year Life and the Future of Wealth Transfer Taxation

Panel #1: Protecting Dynastic Wealth

The estate and gift tax law has been critiqued as ineffective in curbing the growth of dynastic wealth. What goals are well served by the current law of wealth transfer taxation? Who benefits the most from the current tax structure? How might estate and gift tax laws be more effective as a backstop for the income tax? What role do lawyers play in the tax system, and how does that uniquely manifest in the wealth transfer tax context?

• Bridget Crawford (Pace; Google Scholar)
• Mitchell Gans (Hofstra) 
• David Herzig (Ernst & Young) (moderator)
• Carlyn McCaffrey (McDermott Will & Emery, New York)

Panel #2: Critical Perspectives on Wealth

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ABA Tax Section 2022 Fall Meeting

The ABA Tax Section held an in person 2022 Fall Tax Meeting in Dallas last week (program). A highlight was the Teaching Taxation program on Classification of Tax Regulations and the APA:

For many administrative agencies, external sources of law, such as the Administrative Procedure Act, have played a key role in rulemaking. The APA has had an increasingly important role in tax administration. One key aspect is its relationship to tax regulations. Most tax regulations that interpret statutory text have historically been viewed by the tax community as interpretive rules under the APA, thus not requiring notice and comment (although tax regulations have historically been issued with notice and comment). One panelist reads some recent Tax Court and circuit court cases to have implicitly or explicitly held that regulations interpreting statutory text are considered legislative for APA purposes; another panelist does not read those cases as authoritative or persuasive on the issue. The current state of this issue will be discussed to inform the audience as to the issues involved. In addition, regulatory practices have changed significantly over time, yet litigants have raised procedural challenges to older regulations. This panel will consider the historical approach to tax regulations, review the arguments concerning the proper classification of those regulations, and address cases that have struggled to situate tax regulations under the APA. In addition, the panel will address the significance for tax administration of West Virginia v EPA, where the Supreme Court struck down emission caps and relied on the “major questions” doctrine, which requires agencies to demonstrate “clear congressional authorization” when taking actions of political or economic significance.

Chair: Michelle Drumbl (Washington & Lee)
Moderator: Leslie Book (Villanova; Google Scholar)
Panelists:

• Kristin Hickman (Minnesota; Google Scholar)
• Gilbert Rothenberg (American)
• Jack Townsend (Houston)

Other Tax Profs with speaking roles included:

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Texas A&M Conference For Associate Deans

Five years ago, on my first day as dean, I presented Faculty Scholarship Assessment: A (Very) New Dean's Perspective at the 2017 Texas A&M Associate Deans Conference.  I am delighted to be back at the 2022 Texas A&M Associate Deans Conference today as part of a Panel of Deans:

This panel features current law deans with diverse backgrounds and experiences. They will discuss issues relevant to associate deans, including the relationship between the dean and associate dean, as well as advice for prospective law deans.

• Robert Ahdieh (Texas A&M)
• Paul Caron (Pepperdine)
• Tamara Lawson (University of Washington)
• Moderator: Gary Lucas (Texas A&M) 

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Call For Tax Papers And Panels: Law & Society Annual Meeting

Neil Buchanan (Florida) has issued his annual call for tax papers and panels for next year's annual meeting of the Law & Society Association in San Juan (June 1 - 4, 2023):

The Law & Society Association (LSA) will host its next annual meeting from June 1 - 4, 2023, in San Juan, Puerto Rico.  For the nineteenth year in a row, I am organizing sessions for the "Law, Society, and Taxation" group (Collaborative Research Network 31).  For the seventh year in a row, Professors Jennifer Bird-Pollan and Mirit Eyal-Cohen are willing to work tirelessly as co-organizers to make our conference-within-a-conference a continuing success.

Under our signatures below, I've copied the Call for Papers email that LSA sent last week.  Note that all sessions in San Juan will be entirely live -- that is, there will be no online sessions or virtual participation of any kind at next year's conference.  Law & Society goes old school!

This year's official conference theme, "Separate and Unequal," happens to overlap with much of the work that you all have been presenting at Law & Society conferences over the years.  Even so, please remember that you are not bound by the official theme of the conference,   We will give full consideration to proposals in any area of tax law, tax policy, distributive justice, interdisciplinary scholarship, and so on.

The deadline for submissions is November 8, 2022 at 12 noon Eastern Standard Time (United States and Canada).  That is barely more than six weeks from today!

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U.S. Tax Prof Presentations At Today's Tax Research Network Conference

U.S. Tax Prof presentations at today's Tax Research Network Conference in Edinburgh Law School at the University of Edinburgh:

Jeremy Bearer-Friend (George Washington; Google Scholar), Poll Taxes, Revisited:

The introduction of the Community Charge in Scotland in 1989 was one of the defining moments of modern UK politics. Famously defended by Nicholas Ridley, Conservative Secretary of State for the Environment, on the grounds that a Duke would pay no more than a dustman, the arrival of the unpopular form of tax in Scotland a year before its introduction in England and Wales inspired a mass non-payment campaign and helped to bring about the end of Margaret Thatcher’s career as Prime Minister. But it was not the first time a 'poll tax' had been introduced by a British or US government during the twentieth century.

Using the political ephemera and archive collections of the National Library of Scotland, Jeremy Bearer-Friend puts the Scottish anti-Poll Tax campaign into global perspective, exploring how the everyday act of tax filing can become both a tool of discrimination and a powerful forum for political expression. Looking at the introduction of the Community Charge in comparison with other poll taxes applied by Anglophone governments during the twentieth century, he examines the ways in which neutrality in statutory language can cloak the use of tax as a political and economic weapon, and argues for an enriched understanding of the relationship between taxpaying and citizenship that goes beyond voting rights.

Michael Hatfield (University of Washington; Google Scholar) & Michelle Kwon (Tennessee), A Study of Tax Lawyers Discussing Duties, 75 Tax Law. ___ (2022):

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Virtual Roundtable Tomorrow On Starving The Beast: Ronald Reagan And The Tax Cut Revolution

On behalf of the Ronald Reagan Institute, the Washington, D.C. Office of the Ronald Reagan Presidential Foundation and Library, we invite you to attend the next iteration of the Reagan Scholars Virtual Roundtable Series from 1:00 pm to 3:00 pm Eastern Time on Tuesday, August 2, 2022. Ronald Reagan Institute will host a virtual roundtable on August 2 from 1:00 p.m. - 2:00 p.m. ET. If you would like to attend, please contact Anthony Eames. 

For this session, we welcome Professor Monica Prasad of Northwestern University. She is the author of Starving the Beast: Ronald Reagan and the Tax Cut Revolution - winner of the best book award in economic sociology. Dr. Brian Domitrovic, Richard S. Strong Scholar at the Laffer Center for Supply-Side Economics, will offer his own comments in response. He is a leading authority on the history of on supply-side economics. See his recent book The Emergence of Arthur Laffer: The Foundations of Supply-Side Economics in Chicago and Washington, 1966-1976.  

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Today's Law, Society, And Taxation Panels

Today's Law, Society, and Taxation panels at the virtual 2022 Law & Society Association Annual Meeting:

Session #18:  Teaching Taxation: A Pittsburgh Tax Review Symposium (Diane Klein (Southern), Chair/Discussantl Author, Teaching Critical Tax: What, Why, & How, 19 Pitt. Tax Rev. 143 (2022)):
In its Spring 2022 issue, the Pittsburgh Tax Review published a symposium issue dedicated to teaching taxation. The idea behind the special issue is to collect in one place the insights of leading tax teachers as a service for all who are interested in and devoted to educating current law students and future tax lawyers. This roundtable session includes several of the contributors to this special issue who will describe their contributions and lead a discussion regarding tax teaching in an interactive format with the audience. The contributions featured here include using a VITA program to put a face on tax policy, incorporating critical perspectives in the tax classroom, teaching tax through film, and lessons from teaching tax during the pandemic.

• Alice Abreu (Temple), Tax on the Ground: How a VITA Course Enhances the Law School Curriculum, 19 Pitt. Tax Rev. 101 (2022)
• Katherine Pratt (Loyola-L.A.), Reflections on Law Teaching at the Post-Pandemic Crossroads, 19 Pitt. Tax Rev. 217 (2022)
• Margaret Ryznar (Indiana-McKinney), Lessons from Teaching Tax Online, 19 Pitt. Tax Rev. 295 (2022)
• Stephanie McMahon (Cincinnati), Teaching Tax Through Film: It’s Not as Crazy as it Sounds, 19 Pitt. Tax Rev. 183 (2022)

Session #14:  Directions and Strategies for Future Tax Reforms (in Europe) (Yvette Lind (Copenhagen; Google Scholar), Chair/Discussant & Patrik Emblad (Gothenburg), Discussant):

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Today's Law, Society, And Taxation Panels

Today's Law, Society, and Taxation panels at the 2022 Law & Society Association Annual Meeting:

Session #9:  Tax History (Manoj Viswanathan (UC-Hastings; Google Scholar), Chair/Discussant):
While there is no imposition of tax at the supranational level, the imposition of tax at the national level within a country's own borders introduces complexity at the international level that affects issues of tax policy and tax design. The papers on this panel consider many of these complex concerns, with special attention paid, in some of the papers to the way the United States has addressed matters of international taxation.

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Penn-Wharton Hosts Virtual Discussion Today On Minimum Corporate Income Taxes

Penn-Wharton hosts a virtual discussion on Minimum Corporate Income Taxes today at 12:00 p.m. - 1:00 p.m. EDT (registration):

Minimum corporate income taxes are currently being debated as a way to generate tax revenue while preventing highly profitable companies from using tax loopholes to reduce their tax bills. In particular, a minimum tax based on income that corporations report on financial statements has been included in both the House and Senate versions of Build Back Better. Minimum taxes, such as a minimum tax on multinational corporations, are also being considered as part of tax changes codified in international agreements. Questions that will be addressed in this webinar include: Are minimum corporate income taxes efficient in general? What are the challenges with different approaches to imposing a minimum tax, both domestically and internationally? What are potential minimum tax alternatives that do not use financial statement income but can raise similar levels of revenue?

Panelists:

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Today's Law, Society, And Taxation Panels

Today's Law, Society, and Taxation panels at the 2022 Law & Society Association Annual Meeting:

Session #4:  International Tax I (Lotta Björklund Larsen (Exeter; Google Scholar), Chair/Discussant):
While there is no imposition of tax at the supranational level, the imposition of tax at the national level within a country's own borders introduces complexity at the international level that affects issues of tax policy and tax design. The papers on this panel consider many of these complex concerns, with special attention paid, in some of the papers to the way the United States has addressed matters of international taxation.

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Today's Law, Society, And Taxation Panels

Today's Law, Society, and Taxation panels at the 2022 Law & Society Association Annual Meeting:

Session #1:  Critical Tax Theory  (Alice Abreu (Temple), Chair/Discussant):
The nominal application of tax rules to the taxpayers affected by them is often at odds with the affects of those rules in practice. In addition, the priorities and experiences of the actors participating in the drafting, interpreting, and enforcing of tax rules can impact the way those rules are created or operate. The papers on this panel employ a variety of approaches to think about the tax law in the real world, both in the lived experiences of those subject to the rules, and in the intentions of those who create and enforce the rules.

Nyamagaga Gondwe (Wisconsin), American Taxation and The Empty Promise of Black Capitalism:

The federal income tax system is more permissive in how it provides financial assistance to property owners than it is in its method of giving financial assistance to those who principally rely on labor income. Historically, the federal government has participated in expanding rights in property ownership to different historically excluded groups. Expanding those entitlements allows the government to tout individualist virtues of capitalism over collective social spending. But Professors Mehrsa Baradaran and Keeanga Yamatta-Taylor present the theories of “counterfeit capitalism” and “predatory inclusion” to show that systemic failures to regulate market racism against Black Americans have made historically significant tools for building wealth (e.g., stock ownership and homeownership) empty entitlements that drain Black resources instead. Baradaran and Yamatta-Taylor’s accounts are significant from the perspective of the tax distinction between capital and ordinary income because for the balance of American history Black American economic life has been confined to low-wage labor and low-value housing.

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Surrey Workshop On Fairness In International Taxation

The two-day University of Surrey Fairness in International Taxation Workshop (program) concludes today:

The nature of international tax policy has changed dramatically in recent years. Twentieth century international tax policy sought to prevent double taxation of income, to treat taxpayers doing business abroad fairly and to mitigate inefficiencies in the allocation of investment. Recently, the focus of international tax policymaking has shifted, aiming to prevent double non-taxation of corporate income and to achieve a fair division of the resulting tax revenue. This is illustrated most prominently by the recent agreement on a global minimum corporation tax rate. As international tax policy raises its ambitions, there is a need for normative theories adequate to the challenges of this new era.

Fairness in International Taxation brings together legal scholars, political theorists and political philosophers to consider both high-level theories of distributive justice and the normative underpinnings and implications of leading policy proposals. The workshop will cover questions such as how to divide tax revenue from multinationals between nations, how to strike a fair balance between combating profiting shifting and respecting national autonomy, and how to tax internationally mobile workers. By combining theoretical approaches to distributive justice with analysis of the political and institutional context of policymaking we aim to develop new accounts of fairness in international taxation.

U.S. presenters include:

Amanda Parsons (Colorado), The Economic Allegiance of Capital Gains:

How to ensure that multinational companies are paying their “fair share” of taxes in the countries in which they create value has been the subject of lively debate within the international tax community in recent years. These debates have led to significant and exciting reforms, namely the OECD/G20 Inclusive Framework. While these reforms represent an important step towards creating a more coherent and equitable international tax system, the current conversations have overlooked an essential fact. Value created by a company’s business activities manifests itself in two ways—as business income and as an increase in the overall market value of the company, which then translates into capital gains income when investors sell their shares. Thus far, the conversation has focused exclusively on how to divide taxing authority over company income, missing half the story. A truly comprehensive reform that ensures fairness and equity in international taxation must address the question of how taxing authority over income stemming from the growth in company value should be allocated amongst countries.

This paper fills this gap and assesses how taxing authority over this capital gains income should be divided amongst countries under the normative principles that have guided international tax law for the past 100 years.

Adam Kern (Law Clerk, Hon. Jed S. Rakoff, U.S. District Judge Court for the Southern District of New York), Optimal Taxation for the World:

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