UC-San Francisco Hosts Conference On U.S. International Tax Rules: Options For Change

UC-San Francisco hosts a conference on Complexities, Discontinuities, and Unintended Consequences of U.S. International Tax Rules: Options for Change today (registration): 

An east coast version of this conference was organized by the American Enterprise Institute and the University of Florida and was held in June 17-18, 2024 in Washington, D.C. More information about that conference can be found here. This west coast version of the conference will focus on the international tax provisions most relevant to technology- and intangibles-based enterprises.

Welcome 

• Mindy Herzfeld (Florida) 
• Heather Field (UC-San Francisco; Google Scholar) 

Session #1: Taxing of CFC Earnings – GILTI and Subpart F

The panelists will explore design issues of Subpart F income and GILTI, their differences, and opportunities for harmonization post TCJA.

• Kara Mungovan (Davis Polk), Subpart F and GILTI Recommendations, 115 Tax Notes Int'l 729 (July 29, 2024) 
• Gretchen Sierra (Deloitte) (commentator)
• Brian Jenn (McDermott) (commentator) 

Session #2: Foreign Tax Credit

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Fellowship Opportunities For The 117th National Tax Association Conference

The National Tax Association offers three fellowship opportunities for the 117th Annual Conference:

The NTA is pleased to offer three fellowship/funding opportunities for the 117th Annual Conference, the NTA Equity and Inclusion Travel Fellowship, the NTA Pre-Conference Mentoring Dinner for Women/Non-Binary Persons, and the NTA Climate Tax Fellowship. See below for the specifics for each fellowship.

NTA Equity and Inclusion Travel Fellowship

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Oxford Hosts Conference Today On Reimagining Global Tax Governance

The Oxford University Centre for Business Taxation hosts a conference on Reimagining Global Tax Governance today: 

Session #1: Goals of Global Tax Organisations 

• John Vella (Oxford) (chair)
• Mindy Herzfeld (Florida), Global Tax Governance: Models for International Tax Coordination
• Alice Pirlot (Geneva Graduate Institute), International Organisations & Tax Law Making
• Ivan Ozai (York University; Google Scholar) (discussant)

Session #2: Decision Making in Global Tax Organization

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Tax Presentations At Society Of Legal Scholars Annual Conference

U.S. Tax Prof presentations at the Society of Legal Scholars' Annual Conference at the University of Bristol:

Alex Zhang (Emory; Google Scholar), Fiscal Autonomy and the Legacy of Imperialism:

Within the United States, two subnational governments have distinctive powers to tax: Native tribes and U.S. territories. Native tribes can tax their own members and the commercial activities of non-Indian actors on reservations. The Supreme Court has grounded this power in both tribal sovereignty and the federal objective of fostering tribal self-governance. But its jurisprudence—in the form of preemption, plenary power, and tax doctrine—has hollowed out the Native tax base, forcing tribes to compete fiercely with Congress, states, and localities for revenue. By contrast, the U.S. territories face no tax competition. Their residents are generally exempt from federal income and estate taxes, and Congress has even delegated to some territories the authority to deviate from federal income-tax rules. Pursuant to this delegation, Puerto Rico has enacted a host of tax incentives to attract the ultra-wealthy to migrate from the mainland, fueling accusations of tax shelter and settler colonialism. The divergent tax treatment of Native and territorial communities paradoxically rests on the same rationale: fiscal autonomy.

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

Neil Buchanan has issued his annual call for tax papers and panels for next year's annual meeting of the Law & Society Association in Chicago, Illinois (May 22 - 25, 2025):

The Law & Society Association (LSA) will host its next annual meeting from May 22 - 25, 2025, in Chicago, Illinois.  For the 21st year in a row (so we're now of legal drinking age in the US), I am organizing sessions for the "Law, Society, and Taxation" group (Collaborative Research Network 31).  And for what is now the ninth year in a row, I am delighted to be working with Professors Jennifer Bird-Pollan and Mirit Eyal-Cohen as co-organizers of our conference-within-a-conference.

Under our signatures below, I've copied the Call for Papers email that LSA sent earlier this week.  Note that all sessions in Chicago will again be entirely live.

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Update: Florida Tax Review Symposium On Moore v. United States

Following up on my previous post, Florida Tax Review Call For Papers: Symposium On Moore v. United States:  From David Hasen (Florida; Google Scholar):

I bring you a brief update on our upcoming symposium on Moore v. U.S.

The symposium will take place on Friday, Nov. 1, and Saturday, Nov. 2, 2024. We will also have an informal conference dinner on Thursday, Oct. 31. Kindly note the following:

1. The deadline for paper submissions has been extended to September 15.
2. We have expanded the scope of the symposium to include papers on Loper Bright and Corner Post, two decisions also handed down last term that have significant implications for the federal tax system. Papers focusing on either (or both) of these cases may be on any topic as long as it bears on some aspect of the federal tax system.

Submissions need not be in final form, but they should be well developed. They should not exceed 20,000 words in length (though we may make exceptions); 12,000 to 15,000 words preferred.

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Call For Papers: Conference On Tax Law, The Environment, And Climate Change

The American Tax Policy Institute (ATPI) and the Pace Environmental Law Review (PELR) are pleased to announce a Call for Contributions for a Conference on Tax Law, the Environment, and Climate Change. The conference is co-sponsored by the Elisabeth Haub School of Law and its Sustainable Business Law Hub, as well as Pace | Haub Environmental Law. The event will take place on March 21-22, 2025, at Pace University’s Downtown Campus in Lower Manhattan.

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Netanya Hosts 8th International Roundtable On Taxation And Tax Policy

Netanya hosts the 8th International Roundtable on Taxation and Tax Policy (program) today:

Session I: Jurisprudence and Enforcement 

Chair: Assaf Harpaz (Georgia; Google Scholar) 

Viva Hammer (Australian National University), Tax Law as Political Gesture: U.S. Internal Revenue Service Through the Lens of Walter Benjamin’s Readings of Franz Kafka’s Allegories:

The Internal Revenue Code of the United States is known for its length and complexity, and virtually every change in the law has made it longer and more complex. Scholars continue to evaluate and propose changes to the law based on norms of equity, efficiency, simplicity and administrability, from which successive legislative changes consistently depart. This paper proposes that enacted laws are not failed attempts to implement good policies. Rather, each enacted tax law is a record of the outcome of conflict and cooperation between individuals with diverse motivations coming together in the lawmaking process. Every tax law contains the imprint from an individual’s political “gesture,” a term adapted here from Walter Benjamin's readings of Franz Kafka’s political allegories.

Tamir Shanan (College of Management; Google Scholar), Reevaluating Tax Amnesty Programs (Voluntary Disclosure Programs) in the 21st Century (with Doron Narotzki (Akron; Google Scholar)):

The current income tax rules for taxing cross-border income were largely shaped a century ago, a time when the income tax was itself a “work in progress,” when the economic reality was very different, and when capital (both human and physical) was relatively static. Over the years, it has become clear that physical capital is becoming more mobile than ever, and every year, governments from all over the world forgo considerable sums in lost revenues. Following Becker’s seminal research, the literature on the public enforcement of law acknowledged that information about violations could only be obtained by investing significant resources in improving policing power and in obtaining information on such violations. Over the years, more and more countries realized the advantages of obtaining information mainly on offshore tax violations from the violators themselves using voluntary compliance/disclosure programs (VDPs). Generally, VDPs offer non-compliant taxpayers an opportunity to declare unpaid income and wealth that were concealed in the past in return for defined concessions over civil or criminal penalties, while some countries even offered concessions over the amount of tax or interest payable. In 2010 and 2015, the OECD issued two comparative, analysis, and policy reports on VDPs, and proposed a recommended general VDP framework for countries. Our paper critically examines the OECD general framework for VDPs, its impact on compliant taxpayers, and governments’ tax revenues and questions to what extent such programs are still relevant or effective following the recent collapse of bank secrecy, the ratification of over 130 countries of the multilateral instrument and the integration of AI and data mining technologies in sophisticated tax audits that turn concealed information instantly more transparent in a feasible manner. 

Mirit Eyal-Cohen (Alabama; Google Scholar) & David Elkins (Netanya), Taxing Artificial Entrepreneurs:

 

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Harpaz Presents Global Tax Wars And The Shift To Cross-Border Taxation At UC-Davis

Assaf Harpaz (Georgia; Google Scholar) presented Global Tax Wars in the New Era of Cross-Border Taxation at UC-Davis last week as part of the 2024 National Business Law Scholars Conference: 

International taxation is at a crossroads. In a rapidly evolving digital economy, intergovernmental organizations are competing to shape the cross-border tax agenda. Global North economies have dominated this regime through the Organisation for Economic Co-operation and Development (OECD), which has drawn backlash due to its undemocratic procedure and unfavorable outcomes for developing countries. Meanwhile, the United Nations has occupied a relatively peripheral role in global tax governance. Nonetheless, in 2023, developing countries overwhelmingly supported the establishment of a new Framework Convention on International Tax Cooperation within the UN. The unprecedented initiative marks a novel challenge to the Global North’s hegemony in international tax policymaking.

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19th Annual Junior Tax Scholars Workshop Concludes Today At Wisconsin

• Luis Calderon Gomez (Cardozo; Google Scholar), Charity's Limits
  Discussant: Nyamagaga Gondwe
• Conor Clarke (Washington University; Google Scholar), The Practice of Apportioned Direct Taxation
  Discussant: Alex Zhang
• Jon Endean (Brooklyn; Google Scholar), Rethinking Valuation
  Discussant: Conor Clarke
• Hilary Escajeda (Mississippi College; Google Scholar), Generative AI as Property
  Discussant: Luke Maher
• Nyamagaga Gondwe (Wisconsin;* Google Scholar), Tax-Based Welfare Policy & Feminized Poverty in the U.S.
  Discussant: Jeesoo Nam 
• Assaf Harpaz (Georgia; Google Scholar), Global Tax Wars and the Shift to Source-Based Taxation
  Discussant: Hilary Escajeda
• Michael Love (Columbia), How Much Wealth Is Held in U.S. Trusts?
  Discussant: Daniel Schaffa

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Florida Tax Review Call For Papers: Symposium On Moore v. United States

The University of Florida Levin College of Law (UF) and the Florida Tax Review (FTR) are excited to announce a call for papers and for attendance at a symposium to be held at the University of Florida this coming fall on Moore v. United States. Accepted papers will be published in the Spring 2025 issue of the FTR devoted to the symposium. The symposium is tentatively scheduled for a Friday and Saturday in early November of 2024. Details on dates will be provided shortly.

Attendance is open to all interested persons. UF can cover the costs of conference meals for attendees whose papers are accepted. UF may also be able to offer a reduced hotel rate to these individuals. We are not able to cover travel expenses.

If you would like to submit a draft for consideration, kindly do so by August 15, 2024. Drafts should be not more than 20,000 words in length (12,000 to 15,000 words preferred). Drafts must not have been submitted to, published in, or accepted for publication with any other journal, and authors must agree that if their submission is accepted for the symposium, their paper will be published exclusively in the FTR as described above.

A (non-exclusive) list of potential topics includes:

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Law, Society, And Taxation Panels

Law, Society, and Taxation panels at last week's 2024 Law & Society Association Annual Meeting in Denver:

Thursday:  

Tax, Ethics, and Charity (Neil Buchanan (Florida; Google Scholar), Chair/Discussant):

While tax law often seems to operate in something like a vacuum, occasionally front page news stories draw attention to questions about the law, its enforcement, and the effects of the law on taxpayers. When the affected taxpayers are notable public figures like Supreme Court Justices or the beneficiaries of tax exemptions like public charities, then the response is often more outraged. The papers on this panel explore some of the questions around the ethical bounds of tax law, with a particular focus on charitable entities and their expectations.

Richard Schmalbeck (Duke), Defining Charity: Declaratory Judgments of Exempt Status:

Until 1976, it was very difficult for an organization whose application for recognition of exempt status had been denied (or revoked) by the IRS to obtain judicial review of that determination. In most cases, such organizations would have no net income, and hence no income tax liability. Without such liability, they could not generate a case or controversy that would be ripe for adjudication. In addition, the anti-injunction act generally precluded an action for a declaratory judgment to the effect that the organization was entitled to exempt status. The only means routinely available would be to have a donor make a donation, and seek to deduct it. The validity of the deduction would depend on the exempt status of the recipient organization, which would then become an issue ripe for adjudication. But that route was usually unattractive. The IRS might not audit the donor's return. If it did audit the return, every issue that might be raised by that return would be on the table, and few donors would welcome that sort of scrutiny.

 

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Conference For Tax Profs Tenured 1-15 Years At Northwestern

The two-day 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) conferences concludes today at Northwestern:

Panel #1: 

• Zachary Liscow (Yale; Google Scholar), Is the Realization Rule the Achilles Heel of the Income Tax? and The Income Tax and Taxation of the Top 1%
• Edward Fox (Michigan; Google Scholar), Buy, Borrow, Die? Understanding the Role of Borrowing and Consumption in How the Rich Are Taxed
• Clint Wallace (South Carolina; Google Scholar), Moore, “Incomes,” and the Limits of Time

Panel #2: 

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9th Annual Texas Tax Faculty Workshop

SMU hosted the 9th Annual Texas Tax Faculty Workshop on Monday:

Christopher Hanna (SMU), Taxing Carried Interest: A Reappraisal (with David Elkins (Netanya; Google Scholar)
Commenter: Susan Morse (Texas; Google Scholar)

Gary Lucas (Texas A&M; Google Scholar), Shaping Preferences with Pigouvian Taxes
Commenter: Johnny Buckles (Houston; Google Scholar)

Orly Mazur (SMU; Google Scholar), Beyond ChatGPT: Responsible AI and Government Innovation, 92 Tenn. L. Rev. __ (2025) (with Adam Thimmesch (Nebraska; Google Scholar))
Commenter: William Byrnes (Texas A&M; Google Scholar) 

Susan Morse (Texas; Google Scholar), The Truth About Safe Harbors, 92 Tenn. L. Rev. __ (2025)
Commenter: Dennis Drapkin (SMU)

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27th Annual Critical Tax Conference At Florida

Florida hosts the 27th Annual Critical Tax Conference today and tomorrow. If you would like to attend via Zoom, contact David Hasen. 

Friday 

9:00 AM: Welcome 

9:10 AM: First Morning Session 

• Ted Afield (Georgia State), A Catholic Social Teaching Approach to Tax Administration and Enforcement 
• Emily Cauble (Wisconsin; Google Scholar), The Impact of Informal Tax Guidance

10:25 AM: Second Morning Session  

• Rebecca Morrow (Wake Forest; Google Scholar), The Income Tax As a Market Correction 
• Daniel Schaffa (Richmond; Google Scholar), The Regressivity of Complexity 

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Columbia Tax Workshop (Day 2)

Today's Columbia Tax Workshop is being held at its Manhattanville Campus: 

Katarzyna Bilicka (Utah State; Google Scholar), The Role of Intellectual Property in Tax Planning (with Paul Organ (U.S. Treasury Department; Google Scholar) & İrem Güçeri (Oxford; Google Scholar)) 
Discussant: Michael Love (Columbia)

Multinational enterprises (MNEs) that invest in research and development (R&D) and innovation find it easier to shift profits between their subsidiaries located in jurisdictions with different tax rates. While MNEs invest in R&D and develop intellectual property (IP) across multiple jurisdictions, they can also strategically move profits arising from that IP from high- to low-tax jurisdictions to reduce their overall tax bill. In this paper, we analyze and quantify the importance of two different strategies that MNEs use to move their IP to low-tax jurisdictions: selling a patent developed in a high-tax jurisdiction to a low-tax jurisdiction directly, or signing a cost-sharing arrangement (CSA) between those two jurisdictions to cover the costs of developing further IP. Combining administrative data on CSAs, patent applications and transactions, and US tax returns, we provide novel stylized facts on the use of both those strategies by MNEs. We then show that CSAs increase jurisdiction-level patenting activity, royalty payments, profits, and profitability, especially the CSAs signed with low-tax jurisdictions. At the MNE level, a new CSA significantly increases firm sales, profitability, and R&D investment, without affecting the MNE’s effective tax rates. Private firms are the only ones that experience the significant MNE-level effects on sales, profitability, and intangible assets after they sign their first CSA.

Ari Glogower (Northwestern; Google Scholar), Closing the Life Insurance Tax Loophole (with Andrew Granato (J.D.-Ph.D. Candidate, Yale))
Discussant: John Vella (Oxford) 

Permanent life insurance contracts enjoy an unparalleled combination of tax benefits. In a permanent or “cash value” contract, a portion of the premium paid is allocated to an internal savings account or “cash value reserve,” which over time reduces the amount of insured risk in the contract. The cash value reserve enables the policyholder’s beneficiary to ultimately receive a guaranteed “death benefit” that includes the policyholder’s accumulated savings upon the death of the insured person, resulting in an arrangement that resembles an investment account, rather than financial protection in the event of an untimely death.

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Columbia Tax Workshop (Day 1)

Today's Columbia Tax Workshop is being held at its Manhattanville Campus: 

Kimberly Clausing (UCLA; Google Scholar), Capital Taxation and Market Power
Discussant: Wojciech Kopczuk (Columbia; Google Scholar)

In recent decades, market power has increased substantially, according to multiple measures that describe industry concentration, mark-ups, and business profitability. While market power can generate benefits, it also raises vexing policy concerns, including the potential for adverse effects on labor markets, income inequality, and the dynamism of market competition. The concept of market power also has implications for how we conceptualize capital income, making it important to distinguish between normal and above-normal returns to capital. The tax system taxes both types of returns to capital, but often imperfectly and incompletely. Full consideration of the relationship between market power and capital income suggests important implications for optimal capital taxation design, including the role of entity taxation, the use of graduated business tax rates, and international tax reform.

Conor Clarke (Washington University; Google Scholar) & Wojciech Kopczuk (Columbia; Google Scholar), Income Inequality and the Corporate Sector
Discussant: Yair Listokin (Yale; Google Scholar)

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Akron Hosts International Tax Symposium

Akron hosted an International Tax Symposium yesterday: 

• Federico Bertocchi (Ph.D. Candidate, University of Bergamo), Tax Arbitration and the Rule of Law: Issues in International and EU Tax Law
• Yariv Brauner (Florida; Google Scholar), The Foundation of International Taxation: Knocked from Post to Pillars 
• Henry Ordower (St. Louis; Google Scholar), Tax Hybridity and the Globalization of Taxation: Convergence, Borrowing, Culture 
• Tamir Shanan (College of Management, Israel; Google Scholar), Reevaluating Tax Amnesty Programs In The 21st Century

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Pittsburgh Tax Review Call For Papers: Combatting Poverty Through Federal Tax Policy

Pittsburgh Tax Review Call for Papers: Combatting Poverty Through Federal Tax Policy

According to the U.S. Census, in 2022 there were over 37 million people in the United States in poverty. Though, at one time, perhaps the tax code had little to do with relieving poverty, at least since 1975, with the enactment of the Earned Income Tax Credit, Congress has increasingly used tax law as a means of relieving poverty. In light of the important role that tax law and policy now plays in addressing poverty as well as income and wealth inequality in the United States, the Pittsburgh Tax Review invites contributions to a curated issue on the theme of “Combatting Poverty Through Federal Tax Policy.” Contributions will be published in the Fall 2024 issue of the journal’s twenty-second volume.

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UC-Irvine Hosts Symposium Today On Moore And The Future Of The Realization Doctrine

UC-Irvine hosts a symposium today on The Moore Case and the Future of the Realization Doctrine today (program): 

The Graduate Tax Program at the University of California, Irvine School of Law will host its sixth annual UCI Law|Taylor Nelson Amitrano LLP Tax Symposium on April 18, 2024. Sponsored by the Law Offices of Taylor Nelson Amitrano LLP, the theme of this year’s symposium is The Moore Case and the Future of the Realization Doctrine.

This virtual event will feature keynote speaker, David Kamin. Kamin’s scholarship focuses on tax and budget policy, and he served in the White House under President Biden and President Obama. 

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Roosevelt Institute Hosts Tax Policy As Competition Policy Today

The Roosevelt Institute hosts Tax Policy as Competition Policy: Reimagining How the US Tax Code Can Foster a More Equitable and Participatory Economy today at 12:00 PM EST (RSVP): 

Excessive market power by dominant corporations is widely decried across the political divide. Federal and state antitrust agencies have begun to reclaim their rightful roles in checking the power of a few firms to control so much of the economy. Historically, tax policy complemented these antitrust enforcers by leveling the economic playing field. Yet today, taxation remains overlooked both as a driver of current levels of market concentration and as a tool to remedy the problem.

Roosevelt’s Taxing Monopolies series explores how a rewriting of the tax code can work alongside other antimonopoly tools to curb the excessive economic and political power of large corporations and their owners.

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Symposium: The Federal Income Tax—Racially Blind But Not Racially Neutral

Symposium, The Federal Income Tax: Racially Blind but Not Racially Neutral, 21 Pitt. Tax Rev. 1-151 (2023):

• Alice G. Abreu (Temple), Foreword, Ilusion of Neutrality: There's More Than Math and Money in Tax, 21 Pitt. Tax Rev. 1 (2023)
• Leo P. Martinez (UC-San Francisco), You’ve Got to Speak Out Against the Madness: The Myth of Tax Neutrality, 21 Pitt. Tax Rev. 11 (2023)
• Alice Martin Thomas (Howard), The HBCU Tax Pipeline Creating Charles Hamilton Houston Social Justice Tax Warriors: How to Build, Maintain, and Sustain an HBCU Tax Pipeline, 21 Pitt. Tax Rev. 21 (2023)
• Richard Winchester (Seton Hall; Google Scholar), A Simple Tax Case Complicated by Race, 21 Pitt. Tax Rev. 37 (2023)
• David A. Brennen (Kentucky), Race Conscious Affirmative Action by Tax Exempt 501(c)(3) Institutions After Students for Fair Admissions v. Harvard and UNC, 21 Pitt. Tax Rev. 49 (2023) 
• Samuel D. Brunson (Loyola- Chicago; Google Scholar), Black Charity: Rethinking the Subsidy of Black Charitable Donations, 21 Pitt. Tax Rev. 61 (2023)

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National Tax Association 117th Annual Conference Call for Papers: April 19th Deadline

National Tax Association 117th Annual Conference Call for Papers: 

The 117th Annual Conference on Taxation will cover a broad range of topics in tax policy and public finance. We welcome submissions from the fields of accounting, economics, law, and public policy and administration, as well as research from other fields or by practitioners that relates to these topics.

We especially welcome submissions that can speak to current challenges facing policymakers such as the effect of digitalization/e-commerce/remote work on public finances, minimum taxes and international tax law, the child tax credit and other family policies, and global challenges to government finances.

You are invited to submit the following: individual papers to be integrated into sessions, proposals for complete sessions of papers, and proposals for panel discussions (roundtable format, just speakers, no papers). Please note that full session proposals are mere suggestions of groupings. The conference committee reserves the right to consider and accept individual papers from a complete session rather than accepting the complete session, break apart complete sessions or otherwise change the full session.

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Festschrift To Honor Ellen Aprill

Festschrift to Honor Ellen Aprill, 56 Loy. L.A. L. Rev. 1135-1354 (2023):

• Samuel D. Brunson (Loyola-Chicago; Google Scholar) & Philip Hackney (Pittsburgh; Google Scholar), A More Capacious Conception of Church, 56 Loy. L.A. L. Rev. 1135 (2023) (Commentator: Michael Helfand (Pepperdine; Google Scholar))
• Roger Paul Colinvaux (Catholic), Strings Are Attached: Placing a Spotlight on the Hidden Subsidy for Gift Restrictions, 56 Loy. L.A. L. Rev. 1169 (2023) (Commentator: Edward J. McCaffery (USC; Google Scholar))
• Richard L. Hasen (UCLA; Google Scholar), Nonprofit Law as the Tool to Kill What Remains of Campaign Finance Law: Reluctant Lessons from Ellen Aprill, 56 Loy. L.A. L. Rev. 1233 (2023) (Commentator: Justin Levitt (Loyola-L.A.))
• Michelle D. Layser (San Diego; Google Scholar), The Uncertain Equity Impacts of Place-Based Tax Incentives, 56 Loy. L.A. L. Rev. 1261 (2023) (Commentator: Deanna Newton (Pepperdine))

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Florida Hosts 14th Annual Tax Policy Symposium Today: AI, Tax, And Society

Florida hosts the 2024 Ellen Bellet Gelberg Tax Policy Symposium on AI, Tax, and Society today at 9:30 AM EST (registration): 

Speakers: 

• William G. Gale (Brookings Institution; Google Scholar) 
• Jacob Goldin (Chicago; Google Scholar) 
• Omri Marian (UC-Irvine; Google Scholar) 
• Nicol E. Turner-Lee (Brookings Institution) 

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Committee For A Responsible Federal Budget Hosts A Tax Policy Summit Today

The Committee for a Responsible Federal Budget hosts When the TCJA Expires: A Tax Policy Summit today at 2:30 PM EST (RSVP): 

Please join the Committee for a Responsible Federal Budget on March 28 for a summit focusing on the 2025 tax cut expirations and future tax policy.

With large parts of the 2017 Tax Cuts and Jobs Act set to expire, policymakers will soon face important decisions regarding the tax code’s future. These choices could add trillions of dollars to the national debt, or they could put us on a path toward genuine tax reform.

We are pleased to invite you to a gathering of the tax and budget communities to discuss how best to handle the challenges and opportunities offered by this moment.

Agenda

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Virginia Hosts Tax Study Group Meeting Today

Update: Virginia Tax Study Group To Convene in Three-Decade Tradition

The Virginia Center for Tax Law hosts a Virginia Tax Study Group Meeting today (registration): 

D.C. Panel 

• Jamie Cummins (Senior Tax Counsel, Senate Finance Committee) 
• Kathleen Kerrigan (Chief Judge, U.S. Tax Court)
• Ji Prichard (Tax Counsel, House Ways & Means Committee) 
• Cecily Rock (Senior Legislation Counsel, Joint Committee on Taxation) (moderator) 
• Mark Warren (former Chief Tax Counsel, Senate Finance Committee) 

Moore and Beyond 

• Alice Abreu (Temple) 
• Harry Franks (Virginia) 
• Itai Grinberg (Georgetown)
• Gil Rothenberg (Former Chief, Appellate Section, Tax Division, U.S. Department of Justice) 
• Eric Solomon (Former Assistant Secretary for Tax Policy, U.S. Treasury Department) (moderator) 
• Isaac Wood (Attorney-Adviser, Office of Tax Policy, U.S. Treasury Department)

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Houston Hosts Energy Tax Conference Today

The University of Houston Law Center hosts the 6th Annual Denney L. Wright International Energy Tax Conference and 24th Annual Houston Business and Tax Law Journal Symposium today on Lessons Learned from International Energy Investments:

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Blank & Osofsky Present Democratizing Administrative Law Today At Duke

Joshua D. Blank (UC-Irvine; Google Scholar) & Leigh Osofsky (North Carolina; Google Scholar) present Democratizing Administrative Law at Duke today as part of its 54th Annual Administrative Law Symposium: 

When agencies make statements about the law, people listen. This insight yields a fundamental tension. According to one set of views, such agency statements, and their ability to influence public behavior, are critical not only for a well-functioning bureaucracy, but also for our entire system of government. According to another set of views, this agency power, if left unchecked, could border on tyranny.

Administrative law responds to this tension through an extensive, purportedly comprehensive, framework that attempts to police agency statements. The framework places different types of agency statements into different legal categories. 

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Panel Discussion Today On Bearer-Friend's Paying For Reparations

Jeremy Bearer-Friend (George Washington; Google Scholar) joins a panel on Reparations: How To Fund Them & Avoid A Wall Street Takeover hosted by Take On Wall Street and Americans for Financial Reform Education Fund today at 2:00 PM ET (registration): 

Reparations: How to Fund Them & Avoid a Wall Street Takeover is a fireside chat with Jeremy Bearer-Friend (George Washington University Law) and Alvin Velazquez, (SEIU) moderated by Ericka Taylor (Take On Wall Street and Americans for Financial Reform). Bearer-Friend authored a novel proposal for how to pay for reparations [Paying for Reparations: How to Capitalize a Multi-Trillion Reparations Fund, 67 How. L.J. __ (2024) (reviewed by Blaine Saito (Ohio State) here)]. His approach proposes capitalizing a multi-trillion dollar reparations fund with corporate equity in lieu of cash payments.

Join us as we explore the important questions Bearer-Friend’s proposal raises about how to actually design the governance of the proposed reparations fund to maximize its benefits to its intended beneficiaries and prevent the fund from being co-opted by the financial industry to further its own interests. Velazquez will discuss experiences labor unions have had with pension funds, and what lessons can be drawn from them to inform the design of a reparations fund’s governance.

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Call For Proposals: Association For Mid-Career Tax Law Professors Annual Conference At Northwestern

The Association for Mid-Career Tax Law Professors (“AMT”) has issued a Call for Proposals:

The 2024 Association of Mid-Career Tax Scholars/Experienced in Tax Scholars Conference will be held on Thursday, May 30 and Friday, May 31 at Northwestern University Pritzker School of Law in Chicago, IL. This is a recurring conference intended to bring together relatively recently and not-so-recently tenured professors of tax law from around the country to discuss ideas and works-in-progress in an informal setting.

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Call For Papers: 115th Annual Society Of Legal Scholars Conference

Call for Papers for the Tax Section of the 115th Annual Society of Legal Scholars Conference (Sept. 3-5, 2024): 

The theme of the conference is “Learning from Others: Lessons for Legal Scholars?”
As scholars, we interact with others – students; fellow academics; legal practitioners; the wider public – and the 2024 conference will reflect on the gains we can achieve from such interaction in a global academic environment. The conference will examine this theme in two ways. First, as scholars attending the SLS conference, we benefit greatly from meeting colleagues from different backgrounds and disciplines and, notably, from other legal jurisdictions (both within and outside the common law world). What can we gain from taking an international or comparative perspective to our work? To what extent do different perspectives, such as socio-legal, interdisciplinary or historical viewpoints, assist our research? Secondly, one of the significant elements of the conference is the inclusion of papers from both junior and senior scholars. What lessons can we gain from each other, both in terms of mentoring and in recognising the need to promote the interests of early career legal scholars and offering support for those entering the academy? No scholar is an island. The SLS provides a positive inclusive environment for legal academics at whatever stage of their career to engage with each other and learn valuable lessons from a diverse and inclusive community of legal scholars. Doctoral students are very welcome and are encouraged to submit papers for consideration in the Subject Sections Programme.

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Call For Presentations: UC-Irvine Symposium On Moore And The Future Of The Realization Doctrine

Call for Presentations: The Moore Case and the Future of the Realization Doctrine:

The Graduate Tax Program at the University of California, Irvine School of Law will host its 6th Annual UCI Law - Taylor Nelson Amitrano LLP Tax Symposium on April 18, 2024. The theme this year is The Moore Case and the Future of the Realization Doctrine.

We are interested in submissions for proposed presentations on potential effects of the Moore case on the realization doctrine, as well as any topics relating to the realization doctrine as they pertain to issues such as constitutional design, legal alternatives, behavioral effects, societal effects and disparities, tax planning, and political discourse.

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Call For International Tax Papers: Akron Law Review

Call for Papers: 

The Master of Taxation Program at the University of Akron College of Business will host on May 2nd the Akron Conference on International Tax and is proud to invite submissions from tax scholars to present and discuss articles and essays addressing any international tax issues, however we are especially interested in one or more of the following topics or related topics:

• International Tax Dispute Resolution
• International Tax Policy
• Tax Treaties
• International Tax of Human Capital
• Fairness in International Taxation
• Pillar I and Pillar II

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UC-San Francisco Hosts 2024 Northern California Tax Roundtable

UC-San Francisco hosts the 2024 Northern California Tax Roundtable today with these papers and commentary:

Brian Galle (Georgetown; Google Scholar), Though Money Moves: Taxing the Wealthy at the State Level (with David Gamage (Missouri-Columbia; Google Scholar) & Darien Shanske (UC-Davis; Google Scholar))
Commentator: Shayak Sarkar (UC-Davis; Google Scholar)

Darien Shanske (UC-Davis: Google Scholar), Help Wanted: Achieving Better Formulas for Apportioning Income, Residence and Intangibles

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Call For Papers: American Tax Policy Institute Research Roundtable And Symposium

Call For Papers: American Tax Policy Institute Research Roundtable and Symposium on It’s a Man’s World: Revealing and Addressing Hidden Gender Bias in Tax Law and Policy

Expressions of interest due March 31, 2024
Program October 17-18, 2024, Washington DC

The American Tax Policy Institute is pleased to issue this Announcement and Call for Contributions to an event on October 17 and 18, 2024, in Washington, DC, that will explore the intersections between and among gender, taxation, and public policy. Conference co-sponsors include Skadden Arps Meagher & Flom LLP, the Elisabeth Haub School of Law at Pace University, the Birnbaum Women’s Leadership Center at New York University School of Law, the Tax Law Center at New York University School of Law, the Pittsburgh Tax Review, the Loyola of Los Angeles Law Review, and several other organizations (list in formation). The goal of the event is to shine a spotlight on gender issues in taxation and to bring consideration of gender impacts into mainstream discussions surrounding the enactment and administration of tax law and policy. The intended scope of the Conference is broad, focusing not only on gender issues in U.S. tax law but also on gender issues in the tax laws of other countries. It will consider all taxes, including income, consumption, transfer, wealth-related, or other national-level taxes, as well as subnational taxes.

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Call For Tax (And Other) Papers: Harvard|Stanford|Yale Junior Faculty Forum

Request for Submissions
Harvard/Stanford/Yale Junior Faculty Forum
June 3-4, 2024, Stanford Law School

Harvard, Stanford, and Yale Law Schools are soliciting submissions for the 2024 Harvard/Stanford/Yale Junior Faculty Forum, to be held at Stanford Law School on June 3-4, 2024. Twelve to twenty junior scholars (with one to seven years in teaching) will be chosen, through a double-blind selection process, to present their work at the Forum. A senior scholar will comment on each paper. The audience will include the participating junior faculty, senior faculty from the host institutions, and invited guests. The goal of the Forum is to promote in-depth discussion on the selected papers and more general reflections on broader methodological issues, as well as to foster a stronger sense of community among American legal scholars, particularly by strengthening ties between new and veteran professors.

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

This week's ABA Tax Section Midyear Tax Meeting (program) kicks off today. A highlight is Friday's Teaching Taxation program on Reparations and Taxation:

To address the atrocities and enduring harms of slavery, legislators are considering proposals to provide reparations to Black Americans. For example, in 2023, a state-appointed task force in California issued a comprehensive report that explained why governments should provide such reparations and offered recommendations regarding how they should structure payments. According to the task force, reparations could address several specific harms, including the Black life expectancy gap, mass incarceration and excessive policing, discriminatory housing practices, lost business opportunities, and unjust property takings by eminent domain. Other federal, state, and local legislators are also actively considering reparations proposals. While legislators debate whether to adopt proposals to provide reparations, they must also consider several important related tax questions. What are the possible tax treatments of receipt of reparations under current law? Should governments introduce legislation to provide different tax treatment of the receipt of reparations, as compared to the tax treatment under current law? How should federal and state tax laws interact regarding the tax treatment of reparations? This panel will examine the topic of reparations and taxation by considering these and other questions.

• Sonya C. Watson (Office of the Attorney General of Nevada) (moderator)
• Young Ran (Christine) Kim (Cardozo; Google Scholar) (chair) 
• Bobby Dexter (Chapman) 
• Anthony Infanti (Pittsburgh; Google Scholar) 
• Natalia A. Ventsko (Law Office of Natalia A. Ventsko) 

Other Tax Profs with speaking roles include: 

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Pepperdine Hosts Junior Tax Scholars Writing Retreat

Pepperdine Caruso Law was delighted to host a group of junior tax professors last week for a winter writing retreat:  Luis Calderon-Gomez (Cardozo), Conor Clarke (Washington University), Maynard Goldburn (Indiana-Kelley Business School), Nyamagaga Gondwe (Wisconsin), Luke Maher (Seattle), Jeesoo Nam (USC), Deanna Newton (Pepperdine), and Alex Zhang (Emory). The only bummer: I was at the AALS Annual Meeting all week and didn't have the opportunity to spend any time with these wonderful young tax scholars. Hopefully next year!

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Please Join Us: Pepperdine Caruso Law AALS Reception TODAY (6:00-8:00 PM)

Pepperdine Caruso Law School invites law professors and deans to a reception
hosted by Dean Paul Caron at the 2024 AALS Annual Meeting in Washington, D.C.

Friday, Jan. 5, 6:00 - 8:00 p.m.
Tulip Room (2nd Floor Mezzanine) | Marriott Marquis (Headquarter Hotel)
Please join us for local California wine & beer and hors d'oeuvres

Today's AALS Tax Highlights

Section on Taxation, Taxation and Democracy 
10-11:40 AM Independence Salon A, Level M4, Marriott Marquis 

Taxation plays a fundamental role in democratic societies. This panel will focus on the relationship between tax policy and democratic principles. It will explore the various roles that tax policy plays in shaping our democracy and consider innovative approaches to advancing tax policy that enhances democratic values.

• Steven A. Dean (Boston University) 
• Francine J. Lipman (UNLV) 
• Orly Mazur (SMU) (moderator) 
• Clinton G. Wallace (South Carolina) 

Section on European Law, Co-Sponsored by Comparative Law and Taxation, EU Fiscal Federalism and the U.S. Perspective
1-2:40 PM Mount Vernon Square, Level M3, Marriott Marquis 

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Please Join Us: Pepperdine Caruso Law AALS Reception (Friday, Jan. 5)

Pepperdine Caruso Law School invites law professors and deans to a reception
hosted by Dean Paul Caron at the 2024 AALS Annual Meeting in Washington, D.C.

Friday, Jan. 5, 6:00 - 8:00 p.m.
Tulip Room (2nd Floor Mezzanine) | Marriott Marquis (Headquarters Hotel)
Please join us for local California wine & beer and hors d'oeuvres

Center For Taxpayer Rights Hosts Conference On Transforming Tax Administration

The Center for Taxpayer Rights hosted a conference on Transforming Tax Administration: Toward an Effective, Trusted & Inclusive IRS: 

The Center for Taxpayer Rights is pleased to convene this conference on Transforming Tax Administration: Toward an Effective, Trusted & Inclusive IRS. In August 2022, Congress enacted the Inflation Reduction Act (IRA), Public Law 117-169, which provides for $80 billion in funding over a ten year period to enhance Internal Revenue Service (IRS) resources and improve taxpayer compliance. While some of this funding may be reduced in future appropriations bills, there is no doubt that the IRS needs a major investment in cash and expertise to transform itself from a mid-20th century tax administration to one that reflects and meets the needs of today’s taxpayers and the economy they operate in.

Panel 1: The IRS Budget: Exploring IRS Service & Enforcement Categories, and Re-Thinking Measuring Performance

• Jon-Yin Chong (Center for Taxpayer Rights)
• Michael J. Desmond (Gibson, Dunn & Crutcher; Los Angeles) (moderator)
• Fred Goldberg (Skadden, Arps, Slate, Meagher & Flom LLP; Washington, D.C.) 
• Chye-Ching Huang (NYU Tax Law Center), Access-Oriented Performance Measurement for Refundable Credits: Issues & Options 

Keynote Address: 

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The Hamilton Project: The Past, Present, And Future Of U.S. Tax Policy

The Hamilton Project, Taking on Tax: The Past, Present, and Future:

Tax law is scheduled to change significantly at the end of 2025, setting the stage for rigorous policy debates. If policymakers use the opportunity effectively, Congress can both improve tax policy and help to stabilize the fiscal trajectory. That will require maintaining focus on the priorities of raising additional revenue, making the tax system more progressive, and ensuring that tax policy is efficiently aligned with high-level fiscal policy goals.

On Wednesday, September 27, 2023, The Hamilton Project at the Brookings Institution convened leaders and experts to discuss the past and the future of tax policy in the United States. The event featured fireside chat between former Speaker Paul Ryan, Peter Orszag of Lazard, and moderator Catherine Rampell of The Washington Post. The forum also included two discussions featuring Kimberly Clausing (University of California, Los Angeles), Wendy Edelberg (The Hamilton Project), Ben Harris (Brookings), Kyle Pomerleau (American Enterprise Institute), Nirupama Rao (University of Michigan), and Natasha Sarin (Yale University).

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Raskolnikov Presents Two Papers Today At Canadian Law & Economics Conference

Alex Raskolnikov (Columbia) presents two papers as part of the 2023 Canadian Law & Economics (CLEA) conference: 

Should Only the Richest Pay More?:

This paper challenges the leading academic, political, and cultural narrative supporting greater redistribution. The narrative holds that redistribution should come at the expense of a very restricted group of the highest earners: the one percent, the super-rich, the billionaire class. I argue that many reasons offered in support of this view call for redistribution from a much broader group that includes the affluent—those with incomes in the ninetieth to ninety-ninth percentiles of the distribution. Whether one looks at the recent trends in income concentration, wealth concentration, social mobility, political representation, or the rise of populism, the affluent are as great—and sometimes greater—contributors to these problems as those in the top one percent. Remarkably, contemporary legal scholarship has ignored the affluent almost completely, greatly limiting the magnitude of possible economic transfers as well the forms that these transfers may take. This paper reveals the analytical weakness of the prevailing narrow view. Higher taxes on the affluent should fully enter distributional debates.

Poor ESG (with Zohar Goshen (Columbia) & Assaf Hamdani (Tel Aviv; Google Scholar)): 

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ABA Tax Section Virtual Fall Meeting Kicks Off Today

This week's ABA Tax Section 2023 Virtual Fall Meeting (program) kicks off today. A highlight is the Teaching Taxation program on Wednesday on Tax Justice in the Age of Artificial Intelligence: 

The recent and rapid rise of artificial intelligence (AI) technology is positioned to impact all aspects of tax law, including tax practice, administration, ethics, and the tax base itself. As tax law inevitably evolves in response to AI, there will be new opportunities to introduce laws, policies, and practices that make the tax system more equitable. Alternatively, these developments could further entrench inequities that exist under current law. This panel discusses ways that AI might affect tax equity and distributive justice; furthermore, in response to the emergence of this new technology, it will scrutinize the equity implications of proposals to improve tax administration and substantive tax law. In doing so, panelists will have the ambitious threefold agenda: (i) reflect upon tax equity under current law, (ii) consider what AI tells us about values embedded in the tax system, and (iii) explain how tax justice can be advanced in the age of AI.

• Michelle Layser (San Diego; Google Scholar) (moderator) 
• Stephanie Hoffer (Indiana-McKinney; Google Scholar) 
• Jay Soled (Rutgers; Google Scholar) 
• Hilary Escajeda (Mississippi College; Google Scholar) 

Other Tax Profs with speaking roles include:

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George Washington Hosts Symposium Today To Celebrate George Yin

George Washington hosts A Symposium in Celebration of the Career of Professor George K. Yin (J.D. 1977, George Washington; Edwin S. Cohen Distinguished Professor of Law and Taxation Emeritus, Virginia). The Zoom link is here. 

9:30 AM: Dayna Bowen Matthew (Dean, George Washington; Google Scholar), Opening Remarks

9:35 AM: Karen Brown (George Washington), A Perspective on the Career of George K. Yin

9:50 AM: Tom Barthold (Joint Committee on Taxation) 

10:15 AM: Larry Zelenak (Duke; Google Scholar)

10:40 AM: George K. Yin (Virginia) presents Textualism, the Role and Authoritativeness of Tax Legislative History, and Stanley Surrey, 86 Law & Contemp. Probs. __ (2023) (reviewed by Sloan Speck (Colorado; Google Scholar) here):

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Duke Symposium: The Legacy of Stanley S. Surrey

Symposium, The Legacy of Stanley S. Surrey, 86 Law & Contemp. Probs. i-269 (2023):

• Ajay K. Mehrotra (Northwestern; Google Scholar) & Lawrence Zelenak (Duke; Google Scholar), Foreword: The Legacy of Stanley S. Surrey, 86 Law & Contemp. Probs. i (2023)
• Catherine L. Fisk (UC-Berkeley; Google Scholar), When an Aspiring Tax Lawyer Considered Labor Unions Important to the Future of Capitalism, 86 Law & Contemp. Probs. 1 (2023)
• Joseph J. Thorndike (Tax Analysts), Stanley Surrey, The New Deal, and the Virtues of Incremental Tax Reform, 86 Law & Contemp. Probs. 15 (2023)
• Ajay K. Mehrotra (Northwestern; Google Scholar), The Surprising Surrey: Stanley S. Surrey as Educator, Mentor, and Institution Builder, 86 Law & Contemp. Probs. 37 (2023)
• Steven A. Dean (Boston University), Surrey’s Silence: Subpart F and the Swiss Subsidiary Tax that Never Was, 86 Law & Contemp. Probs. 73 (2023)
• W. Elliot Brownlee (UC-Santa Barbara) & Eisaku Ide (Keio University), Stanley Surrey, the Shoup Mission, and Tax Administration in Japan, 86 Law & Contemp. Probs. 89 (2023)
• George K. Yin (Virginia), Textualism, the Authoritativeness of Congressional Committee Reports, and Stanley Surrey, 86 Law & Contemp. Probs. 107 (2023)

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Michigan & Cardozo Host A Symposium Today On The International Tax Revolution

Update:  

Michigan and Cardozo host The International Tax Revolution: A Symposium today (program) (zoom link):

9:30 AM ET Keynote Address: The BEPS Project, 2013-2023

• Pascal Saint-Amans (Former Director, OECD Centre for Tax Policy and Administration)

10:45 AM ET Panel I: The US and BEPS

• Reuven Avi-Yonah (Michigan; Google Scholar) (moderator) 
• Kimberly Clausing (UCLA; Google Scholar) 
• Lilian Faulhaber (Georgetown; Google Scholar) 
• Christopher Hanna (SMU) 
• Lukas Hrdlicka (S.J.D. Candidate, Michigan) 
• Robert Stack (Deloitte, Washington, D.C.) 

1:30 PM ET Panel II: Commentary

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Tax Analysts Hosts A Virtual Panel Today On Debating The Global Minimum Tax

Tax Analysts hosts a panel on Debating the Global Minimum Tax as part of the Taxing Issues series on tax policy today at 2:00 P.M. ET (registration): 

As a global minimum tax attracts growing support around the world, discussion about it continues to unfold in the United States. Our panel will thoroughly examine this multifaceted and controversial issue -- discussing the pros and cons of such a tax and encompassing the perspectives of both legislators and industry leaders. 

Tax Analysts is offering this episode of Taxing Issues as a free service to the public, and all attendees can receive CPE credit. To do so, you must register for the webcast before it starts and log in no later than the scheduled start time. You also must request CPE credits before each webcast, and you must answer the polling questions that will be asked throughout the event. 

Speakers: 

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