Paul L. Caron
Dean




Friday, April 30, 2021

ITPF Hosts Conference Today On A New International Tax Architecture Based On The OECD Blueprints

The International Tax Policy Forum hosts a conference today on "Whither International Taxation: A New International Tax Architecture Based on the OECD Blueprints?" (program):

ITPFThe architecture for international tax relations among developed economies was established almost 100 years ago by the League of Nations. Over the last few years, however, historic concepts regarding jurisdiction to tax, attribution of profits to permanent establishments, and arm’s-length pricing have come under pressure. Notable developments include: the UK diverted profits tax, digital services taxes and levies enacted or proposed in over 40 countries, and the US Base Erosion and Anti-abuse Tax (BEAT).

In October of last year, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting released two Blueprints proposing new guidelines for the taxation of multinational enterprises (MNEs). The Pillar One Blueprint reallocates the right to tax certain high-margin income of MNEs on the basis of sales or users. Pillar Two sets forth a model minimum tax on the income of foreign subsidiaries along with rules for denying deductions (or imposing withholding tax) on payments not subject to a minimum rate of tax in the payee jurisdiction. The Biden Administration has endorsed the OECD/G20 project and agreement on open issues is targeted for the middle of this year.

This conference brings together experts from academia, government, and private practice to share their views on challenges to the international tax architecture and the OECD Blueprints. 

Overview of the OECD Blueprints:

  • Mary Bennett (Baker McKenzie)

Are New Rules Needed for Taxing International Income?:

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April 30, 2021 in Conferences, Tax, Tax Conferences, Tax Scholarship | Permalink

Wednesday, April 21, 2021

Kentucky Law Journal Call For Papers: The Racial Wealth Gap

Call for Papers: Kentucky Law Journal Symposium: The Racial Wealth Gap:

Kentucky Law (2021)The Kentucky Law Journal is pleased to invite proposals for its annual symposium, which will be held in the Fall of 2021.  The KLJ symposium is entitled The Racial Wealth Gap, and will focus on the legal and historical factors that have contributed to the current state of the wealth disparity in the United States that falls largely along racial lines.  This disparity has been increasingly the focus of academic and policy research, and this Symposium aims to bring together practitioners, policy researchers, and scholars to explore this issue.  In particular, the KLJ encourages submissions that consider tax law, property law, and other legal systems that have created and reinforced the conditions that lead to White families having median wealth of approximately $188,000, while Black families have median wealth of only 15% of that amount, or approximately $24,000.  In addition to exploring the evolution of the problem, the KLJ especially encourages submissions that explore possible solutions or proposals that would ameliorate the disparity.

The KLJ expects to host this symposium in person in beautiful Lexington, Kentucky, on October 22, 2021 (date subject to change).

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April 21, 2021 in Conferences, Legal Education, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink

Friday, April 9, 2021

24th Annual Critical Tax Theory Conference At UC-Irvine

UC-Irvine hosts the 24th Annual Critical Tax Theory Conference (program):

UCI_Law_1lineblue_logoThe Critical Tax Theory Conference has a long history of fostering the work of both established and emerging scholars whose research challenges and enriches the tax law and policy literature. Critical tax scholars question assumptions of objectivity in tax, as their work explores how tax law and policy impact historically marginalized groups. At a time when tax policy is once again at the forefront of politics and public discourse, the work of these and other critical tax scholars supports a more robust discussion of the role for tax law in current and future social and economic policy.

Panel #1: 

  • Leslie Book (Villanova), Keith Fogg (Harvard) & Nina E. Olson (Center for Taxpayer Rights), Administrative Burdens, Sludge, and Individual Taxpayer Rights
  • Michelle Layser (Illinois), Subsidizing Gentrification: A Spatial Analysis Of Place-Based Tax Incentives
  • Nancy Shurtz (Oregon) & Esther Sherman, When We Breathe: Reinventing the EITC for a More Just and Caring World
  • Moderator:  Mirit Eyal-Cohen (Alabama) 
  • Commentators:   Joshua Blank (UC-Irvine) & Christine Kim (Utah) 

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April 9, 2021 in Conferences, Scholarship, Tax, Tax Conferences, Tax Workshops | Permalink

Wednesday, March 31, 2021

National Tax Association 114th Annual Conference Call for Papers: Improving The Safety Net

NTA

114th Annual National Tax Association Conference Call for Papers: Improving the Safety Net:

November 18-20, 2021
Detroit Marriott at the Renaissance Center
Detroit, Michigan

We are planning to hold the 114th Annual Conference in person should health guidelines permit.  The NTA staff will continually monitor the health and government mandates and will abide by their recommendations regarding in-person events.

The 114th 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, as well as research from other fields that bears on these topics.

Motivated by the important role of public assistance programs during the COVID-19 pandemic and by the discussions of policy reform occurring during the early days of the Biden administration, the theme of this year’s conference is “Improving the U.S. Safety Net.” Keynote speakers and plenary panels will be oriented towards analysis of U.S. safety-net policies. We especially encourage submissions in line with this topic.

This year’s conference also includes a new submission category, Inequality and Disparities, for papers that investigate disparities by characteristics such as race or gender as well as the effects of tax or non-tax policies that are intended to alleviate them. We particularly encourage submissions to this topic area as well.

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March 31, 2021 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink

Tuesday, March 30, 2021

Fifth International Conference On Taxpayer Rights

5th Annual

Nina Olson (Executive Director and Founder, Center for Taxpayer Rights):

Registration is now open for the 5th International Conference on Taxpayer Rights, which will be held over three days, on May 26 to 28, 2021. The theme of the conference is Quality Tax Audits and the Protection of Fundamental Rights. You can access the agenda here. Our host for this year’s conference is the National and Kapodistrian University of Athens School of Law.

This year we are holding the conference entirely online. Although we will miss seeing everyone in person, we view this live online conference as an opportunity to expand the conference’s reach. So please share this information with others!

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March 30, 2021 in Conferences, Tax, Tax Conferences | Permalink

Saturday, March 27, 2021

2021 Boston College-Tulane Tax Roundtable

The 2021 Boston College-Tulane Tax Roundtable took place virtually yesterday:

BC Tulane (2021)Brian Galle (Georgetown) & Stephen Shay (Boston College), Administrative Law and the Crisis of Tax Administration
Discussant: Reuven Avi-Yonah (Michigan)

Susie Morse (Texas), Emergency Money: Lessons from the Paycheck Protection Program
Discussant: Andrew Hayashi (Virginia)

Shu-Yi Oei (Boston College) Who Joins BEPS? Understanding the Proliferation of International Tax Consensus
Discussant: Steve Shay (Boston College)

Steve Sheffrin (Tulane) & Koray Caglayan (American Institutes for Research), Giver and Taker States over the Business Cycle
Discussant: David Walker (Boston University)

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March 27, 2021 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink

Friday, March 26, 2021

Houston Hosts Energy Tax Conference Today

Houston (2017)The University of Houston Law Center hosts the 3rd Annual Denney L. Wright International Energy Tax Conference and the Houston Business and Tax Law Journal 21th Annual Symposium today on Exploring International Energy Investments During/Post Pandemic virtually today from 9:00 AM – 3:00 PM CDT:

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March 26, 2021 in Conferences, Scholarship, Tax, Tax Conferences | Permalink

Wednesday, March 17, 2021

Pittsburgh Tax Review Symposium: Tribute To Nina Olson

Pittsburgh Tax Review (2017)Symposium, Tribute to National Taxpayer Advocate Nina Olson, 18 Pitt. Tax Rev. 1-189 (2020):

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March 17, 2021 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink

Tuesday, March 16, 2021

Center For Taxpayer Rights Hosts A Tax Chat! Today On Artificial Intelligence And Taxpayer Rights

The Center for Taxpayer Rights hosts a free Tax Chat! on Artificial Intelligence and Taxpayer Rights today at noon ET:

Center for Taxpayer RightsOur guests for this conversation are:

  • Toon Calders, Department of Mathematics and Computer Science, University of Antwerp
  • Sylvie De Raedt, Research Manager, DigiTax, University of Antwerp
  • David Martens, Department of Engineering Management, University of Antwerp, and
  • Anne Van de Vijver, Associate Professor of Tax Law, University of Antwerp

All of our guests are members from DigiTax, a Centre of Excellence within the University of Antwerp.  DigiTax is an interdisciplinary team of about 25 researchers, including lawyers, economists, psychologists, and computer scientists, who explore the challenges and opportunities that digitalization brings to tax.

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March 16, 2021 in Conferences, Tax, Tax Conferences | Permalink

Wednesday, March 10, 2021

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

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

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

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

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

Thursday, March 4, 2021

Call For Proposals: Association For Mid-Career Tax Law Professors

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

Mid-CareerThe unvaccinated but optimistic 2021 AMT organizing committee—Jennifer Bird-Pollan, Emily Cauble, Brian Galle, Ben Leff, and Leigh Osofsky—welcomes proposals for our annual conference.

AMT is a recurring conference intended to bring together relatively recently tenured professors of tax law for frank and free-wheeling scholarly discussion. Our sixth (*: not counting last year’s summer Zoom series) annual meeting will be held virtually over two to three dates this summer: June 9, June 30, and July 21. We expect to convene for about 4 hours each day, not including the cocktail hours that Shu-Yi will inevitably organize. Presenters are asked to commit to attending at least 2/3 of the session hours; non-presenting guests (in addition to pets, inquisitive children, and in-home contractors) are welcome.

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March 4, 2021 in Legal Education, Tax, Tax Conferences, Tax Scholarship | Permalink

Wednesday, March 3, 2021

Tax Prof Presentations At Next Week's Florida Tax Institute

Tax Prof presentations at next week's Florida Tax Institute (March 10-12):

Cassady V. Brewer (Georgia State) & Bruce A. McGovern (South Texas), Recent Developments in Federal Income Taxation:

This session will review the most significant statutory enactments, judicial decisions, IRS rulings, and Treasury regulations promulgated during the last twelve months that affect general domestic income taxation, corporate taxation, partnership taxation, and tax procedure.

Samuel A. Donaldson (Georgia State), Transfer Tax Update:

Stay up to date with this informative and entertaining recap of the important cases, rulings, regulations, and legislation from the past 12 months related to federal income, estate, and gift taxes.

Charlene Luke (Florida), Proposed Partnership Regulation Projects: Where Do They Stand? How Should They Be Handled?:

This presentation will provide an overview of the current state of U.S. Treasury partnership regulation projects and consider potential future approaches in light of a new tax administration.

Nancy A. McLaughlin (Utah), Trying Times: Conservation Easements and Federal Tax Law (207 pages):

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March 3, 2021 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink

Thursday, February 25, 2021

Free Webinar Today On #BlackEconomistsMatter: Economic Justice Recommendations For The Biden Administration

#BlackEconomicrsMatter

Following up on my previous posts:

The ABA Section of Civil Rights and Social Justice hosts a free webinar today at 3:00 PM ET on #BlackEconomistsMatter: Economic Justice Recommendations for the Biden Administration:

For over 100 years, Black economists have been erased by the profession and media. Occupational segregation in economics not only results in loss of opportunities and wage gaps for qualifying women, candidates of color, and others who are discriminated against, but undermines and narrows access to innovative solutions, diverse strategies, broad-based data collection, targeted recommendations, and practical remedies for societal inequities.

In 2017, seven Black women received a Ph.D. in economics in the U.S. In 2018, the number dropped to four out of over 1,000 economic doctoral degree graduates. A 2018 AEA report found that Black, Latinx, and Native American students were less likely to complete degrees in economics compared to any other subject. In 2017, only 16% of all economics degrees were awarded to these students of color.

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February 25, 2021 in Legal Ed Scholarship, Legal Education, Tax, Tax Conferences, Tax Scholarship | Permalink

Monday, February 22, 2021

UC-Irvine Hosts Virtual Symposium Today On Taxation In A Time Of Crisis

UC-Irvine hosts a virtual symposium today on Taxation in a Time of Crisis (program):

UC Irvine (20192)Panel #1: Tax Relief During the COVID-19 Pandemic:

Panel #2: Equitable Tax Administration During the COVID-19 Pandemic

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February 22, 2021 in Conferences, Legal Education, Tax, Tax Conferences, Tax Scholarship | Permalink

Friday, February 19, 2021

South Carolina Hosts Virtual Symposium Today On Taxation, Finance, And Racial (in)Justice

The South Carolina Law Review hosts a virtual symposium today on Taxation, Finance, and Racial (in)Justice (agenda):

SC SymposiumKeynote Speaker: Dorothy A. Brown (Emory)
Professor Brown will discuss the recent change outside of the legal academy when it comes to linking race and tax policy. She will also address the disconnect between the legal academy, federal government, and the public at large while suggesting ways in which the profession can expose and eliminate racial inequality in the application of modern federal tax laws.

Speaker: Danielle Holley-Walker (Dean, Howard)
Dean Holley-Walker will discuss the importance of having diverse lawyers in all areas of the legal profession, including tax law. She will also address how law schools and the profession can create pipelines for minority lawyers into tax law.

Panel#1: Property Tax's Lasting Control on Racial Inequities
This panel will concentrate on how local control over property tax assessment and distribution of property tax revenues contributes to racial segregation of housing markets as well as racial inequities in housing, schools, and public services. Additionally, the panel will discuss methods for the profession to address these inequalities through alternative assessment approaches.

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February 19, 2021 in Conferences, Legal Education, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink

Kentucky Hosts Virtual Panel Today On Tax And Tech

There is a panel on Taxation and Tech at 11:15 am–12:45 pm ET today at the Inframarginalism and Internet virtual conference at Kentucky: 

Kentucky Law (2021)Taxation is an underexplored remedy for Big Tech and tech is an underexplored remedy for tax. Consider first concerns about Big Tech. Many tech firms barter with their customers, supplying services to customers in exchange for their data—or attention—instead of their cash. That has stymied antitrust, which has traditionally viewed monopoly power as the power profitably to increase a cash price. But tax knows barter, and can more clearly see the bartering of personal data for services as a regulable transaction. What is more, taxation would seem to address more directly than antitrust the root of concerns regarding Big Tech—concerns that Big Tech’s ability to extract rents contributes to inequality of wealth—while at the same avoiding the cost and inefficiencies associated with antitrust remedies like breakup. Or does it? And what do the first civilizations, which arose to govern networks in a barter economy, have to teach us about the answer to this question? On the other side of the ledger, tech is swiftly making possible modes of taxation that were once merely theoretical abstractions. It is a small step from a world in which private firms know everything about you and use that information to impose private taxes on your every purchase to a world in which the government knows enough about your every purchase to replace (or supplement) the income tax system with a personalized consumption tax system. But should we do it?

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February 19, 2021 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink

Wednesday, February 17, 2021

Copenhagen Hosts Colloquium Today On Tax, Gender Equality, And The Pandemic

The Copenhagen Business School Tax Group hosts a Tax Colloquium today on Gender Equality Aspects Amid a Pandemic: Discussions on Tax Measures and Fiscal Policy:

CBS TaxThe impact of COVID-19 is at the moment undeniably extensive as the world faces the most severe recession in nearly a century. Economic emergency programs, the design and implementation of COVID-19 tax policies and subsequent state aid actions have been launched in many countries to mitigate the impact of the pandemic. Unlike previous economic recessions or financial crises, feminized sectors of the labor market, such as healthcare, education, care, retail, and client-facing services, which all are characterized by low-paid and multiple part-time jobs, seems to be hit the hardest by the pandemic. These sectors have, supported by emerging data, experienced higher job losses than traditionally male-dominated sectors and appears to be inadequately covered, by most financial state aid schemes at the moment.

Women have, in comparison to men, also reduced their hours of work to care for, and home school, children. Aggregating already existing problems associated to both the loss of paid work hours and to the gender-segregated allocation of unpaid hours for household work and caring. The sudden closure of childcare programs and schools in many countries has had a crucial impact for women whose labour force participation depends on these institutions.[1] The possibility of several waves of the virus that could trigger additional childcare closures make it extremely likely that married women (in general when considering the current norm of heterosexual couples) in particular may be slower to re-enter the work force in the hope of protecting the (single-breadwinner) family income. 

This seminar will discuss existing gender gaps within various domestic tax systems and national tax policies.

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February 17, 2021 in Conferences, Legal Education, Tax, Tax Conferences | Permalink

Thursday, February 11, 2021

Call For Papers: ACTEC Law Journal Symposium On Modernizing Trusts And Estates

The American College of Trust and Estate Counsel announces a Call For Papers on the following topic:

ACTECAs trusts and estates academics and practitioners look forward into the remainder of the 21st century, we acknowledge the aspects of law and practice that are changing, that should change, and that should resist change.

A special issue of the ACTEC Law Journal will be devoted to a discussion of the topic of Modernizing Trusts and Estates and will be comprised of shorter articles (2,500-5,000 words).  The issue will focus on what matters are of most importance to the forward-looking trusts and estates professional.  Topics may include developments in tax law, adaptations in legal technology, racial justice and diversity, new or impending statutory reform, remote or electronic estate planning documents, the funeral and death industry, and other topics that demonstrate the way in which the trusts and estates landscape is shifting.

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February 11, 2021 in Conferences, Legal Education, Tax, Tax Conferences, Tax Scholarship | Permalink

Tuesday, February 9, 2021

Call For Papers: Australian Tax Review Symposium On New Voices In Tax Reform

Monash University (Australia), Critical Junctures/Critical Perspectives – A Call For New Voices in Tax Reform:

Monash[T]he impact of COVID-19 on fiscal systems worldwide is exactly the type of crisis often thought necessary to precipitate major tax reform.

At such a critical juncture, it is essential to open the discussion of tax reform to new voices and new perspectives. The technical subject matter of taxation (and the general public apathy towards this perceived technical detail) means that certain groups and epistemic communities can dominate tax policy formation, development and implementation. This is despite the stakes being so high – taxation is one of the primary means to address wealth and income inequality in a political system that is tied to a market-based economy.

This symposium seeks to open the debate on reform to new voices and new perspectives that are able to challenge the status quo. It invites papers from scholars from all disciplines (for example, law, politics, economics, sociology) to offer critical perspectives on taxation. Topics might include (but are not limited to):

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February 9, 2021 in Conferences, Legal Education, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink

Friday, February 5, 2021

Free ABA Webinar Today On #BlackTaxpayersMatter: The Intersection Of Race, Tax Systems, Laws, And Enforcement

BlackTaxpayersMatterFollowing up on my previous posts:

The ABA Section of Civil Rights and Social Justice hosts a free webinar today at 3:30 PM ET on #BlackTaxpayersMatter: Intersection of Race, Tax Systems, Laws and Enforcement:

The United States exhibits wider disparities of wealth than any other major developed nation. Over the past five decades, wealth has concentrated among the highest-income households, which are disproportionately white and male. In 2018, three white men held aggregate wealth greater than the aggregate wealth of one-half of all Americans. The median white household has 41 times more wealth than the median Black household and 22 times more wealth than the median Latinx household. On average women earn less than men in all industries. At the intersection of race and gender the gaps are even more shocking. Women of color are disproportionately poor suffering poverty rates of 21.4% Black women, 18.7% Latinas, and 22.8% Native American women, as compared to 7% for white men. Moreover, education, work, and marriage and other attributes that fall under the rubric of “personal responsibility” do not remedy these disparities.

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February 5, 2021 in Legal Education, Tax, Tax Conferences | Permalink

Duke Law Journal Hosts Virtual Symposium Today On The Future of Chevron Deference

The Duke Law Journal hosts its annual Administrative Law Symposium today on The Future of Chevron Deference:

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February 5, 2021 in Conferences, Legal Ed Scholarship, Legal Education, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink

Tuesday, January 26, 2021

ABA Tax Section Virtual 2021 Midyear Meeting

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

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

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

Other Tax Profs with speaking roles include:

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

Saturday, January 9, 2021

AALS Hosts Virtual Panel Today On New Voices In Taxation

The AALS Tax Section hosts a Zoom panel today on New Voices in Taxation at 4:15 pm ET:

AALS (2018)This program gives junior tax scholars an opportunity to receive useful feedback on their work from senior reviewers before submitting the work for publication.

Kathleen DeLaney Thomas (North Carolina) (moderator)

Jeremy Bearer-Friend (George Washington), Taxation and the Law-and-Political-Economy Project (with Ari Glogower (Ohio State), Ariel Jurow Kleiman (San Diego) & Clinton Wallace (South Carolina)
Commentator:  Ajay Mehrotra (American Bar Foundation & Northwestern)

Jonathan Choi (Minnesota), Legal Analysis, Policy Analysis, and the Price of Deference: An Empirical Study of Mayo and Chevron
Commentator, Leigh Osofsky (North Carolina)

Hayes Holderness (Richmond), Insidious Regulatory Taxes
Commentator:  Beth Colgan (UCLA)

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January 9, 2021 in Conferences, Legal Education, Tax, Tax Conferences, Tax Scholarship | Permalink

Friday, January 8, 2021

AALS Hosts Virtual Panel Today On Tax Law In An Age Of COVID

The AALS Tax Section hosts a Zoom panel today on Tax Law in an Age of COVID at 1:15 pm ET:

AALS (2018)In the wake of COVID-19, Congress rushed to use the tax policy and the administrative resources of the IRS to deliver economic benefits to individuals and firms, but it also used this must-pass legislation to enact long-sought tax measures. This panel will consider federal tax policy's role in this unprecedented economic contraction and in the fiscal crisis confronting state and local governments.

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January 8, 2021 in Conferences, Legal Education, Tax, Tax Conferences | Permalink

Tuesday, December 15, 2020

Call For Tax Papers And Panels: Law & Society Annual Meeting On Crisis, Healing, Re-Imagining

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 Chicago (May 27 - 30, 2020):

Law & SocietyFor the seventeenth year in a row, I will organize sessions for the "Law, Society, and Taxation" group (Collaborative Research Network 31).  For the fifth year in a row, I am pleased to be carried along in these organizational efforts by Professors Jennifer Bird-Pollan and Mirit Eyal-Cohen.

The conference will mostly be held online, but LSA does hope to hold some events in person in Chicago for those who are willing and able to travel.  They are also indicating that they will take account of time zone differences in their scheduling. ...

Although there is an official call for papers, please remember that you are not bound by the official theme of the conference ("Crisis, Healing, Re-Imagining").  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 11:59 p.m. ET (USA) on Thursday, January 7, 2021.

Please be aware that the online submission system has been changed significantly since last year.  (For what it's worth, I think the changes are all for the better.)  Please follow these instructions carefully:

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December 15, 2020 in Conferences, Legal Education, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Tuesday, December 8, 2020

Tax Analysts Hosts Webinar Today On Artificial Intelligence And The Future Of Tax

Tax Analysts hosts a webinar today (2:00 p.m. ET) on Artificial Intelligence and the Future of Tax (registration):

Tax Analysys Logo (2013)AI systems process massive amounts of data, identify patterns, spot anomalies, and even generate predictions to guide action. This enables all aspects of businesses – including tax planning and preparation — to improve efficiency, identify critical information, and innovate faster than ever. But does it also bring risks?

Tax Analysts

  • Benjamin Alarie (Professor & Osler Chair in Business Law, University of Toronto Faculty of Law; Co-founder & CEO, Blue J Legal)
  • Cara Griffith (President & CEO, Tax Analysts) (moderator)
  • Sarah Lawsky (Professor of Law, Northwestern Pritzker School of Law; author, Teaching Algorithms and Algorithms for Teaching, 25 Fla. Tax Rev. ___ (2021))

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December 8, 2020 in Tax, Tax Analysts, Tax Conferences | Permalink | Comments (1)

Thursday, November 19, 2020

NTA 113th Annual Conference On Taxation

Highlights of the first two days of the National Tax Association's virtual 113th Annual Conference on Taxation (full program here):

National Tax Association (2016)

COVID-19 and Business Tax & Credit Policies
Session Chair: Yilin Hou (Syracuse)

Electricity Sector: Policy Design and Outcomes
Session Chair: Agustin Leon-Moreta (New Mexico)

Legal Issues in International Taxation
Session Chair: Lilian Faulhaber (Georgetown)

Nonprofit Organizations
Chair: Jeremy Bearer-Friend (George Washington)

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November 19, 2020 in Conferences, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Friday, November 13, 2020

Tax Innovators Exchange Today At Stetson

New Tax Innovators Exchange Brings National Tax Experts to Stetson Law:

STIX 3The Tax Law Society at Stetson University College of Law will present the Stetson Tax Innovators Exchange (S.T.I.X.) on Nov. 13, 2020, featuring nationally renowned experts in environmental taxation and tax technology.

S.T.I.X. is a new and forward-thinking tax law collaboration event focused almost exclusively on tax practitioners – those working in the trenches every day.  The nation’s top tax attorneys will dive into bleeding edge approaches to the practice of tax law and lead group discussions where practitioners can share challenges they face…and have a platform full of the greatest tax minds in the country work the problem out with them.

This interactive seminar will feature topics that run the gamut, but the overall goal is to ensure attendees leave armed with useful new techniques to advance not only their practice, but the field itself.

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November 13, 2020 in Legal Ed News, Legal Education, Tax, Tax Conferences | Permalink | Comments (0)

Thursday, November 12, 2020

Leff Presents Cannabis Taxation: Theory And Practice Today At Boston University

Benjamin M. Leff (American) presents Cannabis Taxation: Theory and Practice at the Virtual Boston University Law Review Conference today on Marijuana Law 2020: Lessons from the Past, Ideas for the Future:

Leff (2020)My goal in my presentation is to make two primary points: (1) In designing a tax instrument to tax cannabis at the state level, it is misguided to get distracted by any theory of Pigouvian taxes, since the most important market substitute for legal cannabis is illegal cannabis, and so (except for some special cases) taxation of legal cannabis is not Pigouvian.  (2) In designing a tax instrument to tax cannabis at the federal level, the most important issue is the degree to which any federal tax crowds out state-level taxation, not the purported incoherence (or injustice?) of section 280E.  In fact, section 280E has some plausible benefits as compared to federal excise taxes.

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November 12, 2020 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Friday, October 30, 2020

Florida Hosts 16th Annual International Tax Symposium

Florida Logo (2017)The University of Florida Graduate Tax Program hosts its Sixteenth International Taxation Symposium virtually today:

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October 30, 2020 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

15th Annual Junior Tax Scholars Workshop Concludes Virtually Today At Utah

Utah Logo (2016)Jon Choi (Minnesota), Implied-Utility Tax Analysis
Commentators: Ariel Jurow Kleiman (San Diego), Daniel Schaffa (Richmond)

Hayes Holderness (Richmond), Hate the Sin, Tax the Sinner
Commentators: Shelley Layser (Illinois), Blaine Saito (Northeastern)

Ariel Jurow Kleiman (San Diego) & Emily Satterthwaite (Toronto), Trading a Safety Net for a Living Wage?
Commentators: Ed Fox (Michigan), Goldburn Maynard (Indiana Business School)

Sloan Speck (Colorado), Double Tax Benefits and Targeted Tax Benefits Under the CARES Act
Commentators: Andrew Appleby (Stetson), Ed Fox (Michigan)

Clint Wallace (presenting, South Carolina), Jeremy Bearer-Friend (George Washington), Ari Glogower (Ohio State), & Ariel Jurow Kleiman (San Diego), Tax and the Law-and-Political-Economy Project
Commentators: Jon Choi (Minnesota), Hayes Holderness (Richmond)

Eleanor Wilking (Cornell, presenting) & Jacob Goldin (Stanford), What Are the Distributional Consequences of Federal Income Tax Penalties?
Commentators: Andrew Appleby (Stetson), Christine Kim (Utah)

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October 30, 2020 in Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Wednesday, October 21, 2020

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

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

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

Speakers:

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

Friday, October 16, 2020

15th Annual Junior Tax Scholars Workshop Continues Virtually Today At Utah

Utah Logo (2016)Andrew Appleby (Stetson), Subnational Digital Services Taxes
Commentators: Christine Kim (Utah), Shelly Layser (Illinois)

Ed Fox (Michigan, presenting) & Zach Liscow (Yale), When the Taxman Pays Taxpayers: Understanding the Psychology of Negative Tax Liability
Commentators: Jeremy Bearer-Friend (George Washington), Clint Wallace (South Carolina)

Jacob Goldin (Stanford, presenting) & Ariel Jurow Kleiman (San Diego), Whose Child Is This?
Commentators: Jeremy Bearer-Friend (George Washington), Daniel Schaffa (Richmond)

Christine Kim (Utah), Taxing Teleworks in the Wake of COVID-19
Commentators: Goldburn Maynard (Indiana Business School), Ariel Jurow Kleiman (San Diego)

Shelley Layser (Illinois), Magnet Zones
Commentators: Zach Liscow (Yale), Tracey Roberts (Cumberland)

Daniel Schaffa (Richmond), Payroll Subsidies as a Policy Tool
Commentators: Tracey Roberts (Cumberland), Eleanor Wilking (Cornell) 

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October 16, 2020 in Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Tuesday, October 13, 2020

15th Annual Junior Tax Scholars Workshop Kicked Off Oct. 2 Virtually At Utah

Utah Logo (2016)Zach Liscow (Yale, presenting) & Ed Fox (Michigan), The Psychology of Taxing Capital Income: Evidence from a Survey Experiment on the Realization Rule
Commentators: Jon Choi (Minnesota), Sloan Speck (Colorado)

Goldburn Maynard (Indiana Business School), Enjoying Luxury while Black
Commentators: Jacob Goldin (Stanford), Blain Seto (Norteastern)

Tracey Roberts (Cumberland), Regulatory Taxation (Revisited)
Commentators: Hayes Holderness (Richmond), Eleanor Wilking (Cornell)

Blaine Saito (Northeastern), Tax Coordination
Commentators: Jacob Goldin (Stanford), Clint Wallace (South Carolina)

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October 13, 2020 in Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Wednesday, September 30, 2020

ABA Tax Section Virtual Meeting

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

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

Speakers:

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

Monday, September 14, 2020

Copenhagen Business School Hosts Virtual Conference Today On Inequality Within International Taxation

Inequality Int'l Tax'n

Copenhagen Business School hosts a two-day virtual conference beginning today on Inequality Within International Taxation (program):

How should concerns about inequality influence the choices that countries make in the design of their international tax laws and regulations? What role do international tax rules play in reducing (or exacerbating) inequalities of income and wealth, and how do concerns such as gender and racial inequalities inform and intersect with economic and political concerns? Can tax rules, for example, allow wealthier countries to help pull poorer countries out of poverty? Will political systems be willing to use tax policy to address the effects of continuing discrimination in employment, housing, and other areas of people’s live?

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September 14, 2020 in Conferences, Tax, Tax Conferences | Permalink | Comments (0)

Monday, August 31, 2020

International Tax Symposium In Honor Of Tim Edgar

Symposium, Re-Imagining Tax for the 21st Century: Inspired by the Scholarship of Tim Edgar (York University, Osgoode Hall Law School) (Vol. 67, No. 3; Vol. 67, No. 4; Vol. 68, No. 1; and Vol. 68, No. 2):

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August 31, 2020 in Conferences, Legal Education, Scholarship, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Wednesday, August 26, 2020

Call For Papers: UC-Irvine Symposium On Taxation In Times Of Crisis

The UC-Irvine Graduate Tax Program has issued a call for papers for its third annual UCI/Lavar Taylor Tax Symposium on Taxation in Times of Crisis on February 22, 2021:

UC Irvine (20192)The purposes of this full-day symposium is to launch an in-depth discussion on the effects of local, national, and global crises on tax administration, tax policymaking, and tax compliance. We are interested in submissions for proposed presentations related to taxation in times of (or in response to) social unrest, racial tensions, pandemics, natural and man-made disasters, wars, climate and geological emergencies, financial crises, and other types of large-scale social challenges.

This one-day symposium will be attended by tax industry professionals, government officials, and academic researchers. We expect about 150 attendees this year. Presenters of accepted submissions will be invited to present at the symposium. If the symposium is held on campus, the Graduate Tax Program will cover the presenters’ reasonable travel and lodging expenses.

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August 26, 2020 in Conferences, Tax, Tax Conferences | Permalink | Comments (0)

Tuesday, August 18, 2020

AALS Call For Papers Due Thursday: New Voices In Taxation

AALS (2018)

Call For Papers: New Voices in Taxation Panel
AALS Section on Taxation/2021 Annual Meeting

The AALS Section on Taxation is pleased to announce the following Call for Papers. Selected papers will be presented at a works-in-progress session at the 2021 AALS Annual Meeting from January 5 through 9. While AALS has not made a decision about whether the conference will be held in person, selected presenters will have the opportunity to present remotely. This program will provide panelists the opportunity to present their work and receive feedback from senior colleagues in the field.

Eligibility: Scholars teaching at AALS member schools or non-member fee-paid schools with seven or fewer years of full-time teaching experience as of the submission deadline are eligible to submit papers. (Non-tenure track teaching fellowships count for this deadline.). For co-authored papers, all authors must satisfy the eligibility criteria. While we welcome submissions from previous panelists, we will give a preference to scholars whose work has not been selected for a previous new voices panel.

Due date: 5 p.m. PDT, Thursday, August 20, 2020.

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August 18, 2020 in Conferences, Legal Education, Scholarship, Tax, Tax Conferences | Permalink | Comments (0)

Monday, August 17, 2020

Webinar Today On Taxation And Social Contract In A Post-Pandemic Era

AfronomicsLaw Webinar IV: Taxation and Social Contract in a Post-pandemic Era today at 10:00 A.M. ET/7:00 A.M. PT (registration):

Afronomics LawThe responses of countries to the coronavirus pandemic have been limited by the strength of their revenue collection, especially through taxation. On the other hand, the expectations of citizens from their governments have been high, notwithstanding the strength or otherwise of the social contract between the sovereigns and the governed. In many developing countries, it is argued that the social contract has failed or is failing, calling for its review, if citizens will be obliged, whether legally or morally, to keep funding the social contract. As Alexander Ezenagu, the symposium convener argues, this conversation is applicable at the international level, as well as to domestic tax conversations.

This webinar is a follow-up to the recently concluded Taxation and the Social Contract in a Post-Pandemic Era: Domestic and International Dimensions Symposium which had 20 blog submissions.

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August 17, 2020 in Conferences, Tax, Tax Conferences | Permalink | Comments (0)

Wednesday, August 5, 2020

Taxation And Gender Equality Conference: Postponed

Following up on my previous post, Conference Announcement And Call For Contributions: Taxation And Gender Equality

Taxation and Gender Equality Conference: Postponed:

As the Organizers and members of the Academic Advisory Committee we regret to confirm what you probably assumed:  The Taxation and Gender Equality Conference and Research Roundtable that were to be held on September 14 and 15, 2020, in Washington, DC, have been postponed due to the travel and other risks brought on by the COVID-19 pandemic.  The Conference and Research Roundtable were to have explored the interaction between tax law and gender equality with the objective of shining a spotlight on gender issues in taxation and bringing consideration of gender impacts into mainstream discussions surrounding the enactment and administration of tax laws.  With the continued support of our sponsors, the Tax Policy Center, the American Tax Policy Institute, the American Bar Foundation, the Tax Section of the American Bar Association and the American College of Tax Counsel, we expect to hold the Conference in Fall 2021.  We will announce a date and venue once the public health crisis brought on by the pandemic has abated sufficiently to allow for safe travel and large in-person gatherings, and we will issue another Call for Papers at that time.

We thank all who submitted papers in response to our original Call for Papers and are endeavoring to provide virtual outlets for at least some of them. Please be on the lookout for further developments and thank you for your continuing support of this important project.

Organizers
Julie Divola (Pillsbury Winthrop Shaw Pittman and American Tax Policy Institute), Elaine Maag (Tax Policy Center), and Alice Abreu (Temple Center for Tax Law and Public Policy and American Tax Policy Institute)

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August 5, 2020 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Friday, July 24, 2020

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

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

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

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

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

Friday, July 10, 2020

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

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

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

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

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

Thursday, July 9, 2020

AALS Hosts Virtual Panel Today On Inclusion And Addressing Racism In The Federal Income Tax Course

The AALS Tax Section hosts a Zoom panel today on Inclusion and Addressing Racism in the Federal Income Tax Course at 1:00 pm ET:

AALS (2020)The AALS Tax Section will convene a panel discussion on classroom inclusion and how to identify and address policies with racist implications in the Federal Income Tax Law course. It may also discuss issues relating to who takes tax courses in law school. Many colleagues have been spurred by Jeremy Bearer-Friend’s post to the TaxProf email list about inclusive course design, and this panel seeks to connect course design choices to the specific context of tax classes.

The session will have two parts. The first (about forty minutes) will provide an overview that touches on casebook selection and syllabus goals. Each panelist will speak briefly about what they have done in their classrooms, with a focus on specific examples. The second part (about thirty minutes) will feature a moderator-panelist exchange during which the moderator will pose questions that have been submitted to panelists in advance of the panel.

Speakers:

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July 9, 2020 in Conferences, Legal Ed Conferences, Legal Education, Tax, Tax Conferences | Permalink | Comments (0)

Wednesday, July 8, 2020

South Carolina Law Review Call For Papers: Taxation, Finance, And Racial Justice

South Carolina (2019)The South Carolina Law Review will host its 2021 Virtual Symposium on February 19, 2021, at the University of South Carolina School of Law, hosted on Blackboard Collaborate Ultra. The symposium will specifically examine the intersection of tax law and policy and racial (in)justice at the local, state, and federal levels.

Tax law and policy plays an essential role in defining the ways in which individuals relate to and support one another. Revenue needs and spending policy are inextricably entwined and reflect and reinforce a society’s understanding of what each individual owes to and is owed by the society in which she lives. How tax defines income, whom it taxes, their relative contributions, and the activities that our tax system chooses to subsidize or not create countless points of overlap between tax and racial justice. The goal of this symposium is to critically examine the intersection of tax law and policy, finance, and racial justice through both a chronicling of the past and detailing pathways to reform. Topics may include (but are not limited to): the past and current impact of federal tax law and policy on historically-marginalized groups, the role of state tax systems in exacerbating and/or perpetuating racial injustice, and how tax law may be reimagined to advance racial justice at the state and federal levels.

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July 8, 2020 in Conferences, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Thursday, June 25, 2020

Avi-Yonah Delivers Keynote Address On Taxation After The Pandemic Today At Copenhagen Virtual Workshop On Corporate Tax Practice And Inequality

Copenhagen Business School, Three Day Virtual Workshop on Corporate Tax Practice and Inequality:

ReuvenScholars from the variety of fields that tackle either corporate sustainability or corporate tax practices do not ‘naturally’ meet for conversations, yet there are links between the various fields that could benefit from further dedicated exploration. Meanwhile, given the intensive media coverage of corporate tax practices and wider societal interest in the topic, much interesting research is underway to explore the linkages and other aspects of corporate tax practice that is relevant for the business in society agenda.

With this background in mind, this workshop will gather together speakers (and workshop participants) who are already involved in, planning or have a keen interest in research on the linkages between corporate tax and sustainability issues. The workshop will include presentation of innovative proposals as well as space for more general conversations about potential future research streams, key concepts that could inform work at this intersection, and theoretical themes or methodological approaches that are relevant to this work. It is our hope that the engagement between researchers from a variety of disciplines and with a variety of perspectives will generate new insights and add value to ongoing research that will enter the literature in the years to come.

The public key note speech by Professor Reuven Avi-Yonah from University of Michigan will be on Taxation after the Pandemic and followed by a Q&A:

If there is one thing that is relatively clear about the Covid-19 pandemic, it is that governments will need new sources of revenue to offset its costs and build a better social safety net. All over the world, governments are borrowing and spending at a pace not seen since World War II, and at the same time revenues from both income and consumption taxes are falling because of pandemic related slowdowns in economic activity. The result is unprecedented levels of debt that even with low interest rates mean inevitable needs for more revenue down the road. Even a country that borrows in its own currency like the US or Japan cannot debt well in excess of GDP forever without risking either inflation (if it creates money to pay off the debt) or a sharp increase in borrowing costs that crowds out other government expenditures at a time when they are most needed to bolster the social safety net, which the pandemic revealed to be quite fragile in many countries including the US.

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June 25, 2020 in Conferences, Scholarship, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Wednesday, June 17, 2020

Symposium: The Impact And Future Of The Tax Cuts And Jobs Act

Symposium, The Impact and Future of the Tax Cuts and Jobs Act, 45 Ohio N.U. L. Rev. 501-560 (2019):

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June 17, 2020 in Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Tuesday, June 2, 2020

Roin: Changing Places, Changing Taxes — Exploiting Tax Discontinuities

Julie Roin (Chicago), Changing Places, Changing Taxes: Exploiting Tax Discontinuities, Symposium on Legal Discontinuities (Cegla Center for Interdisciplinary Research, Tel Aviv University), 22 Theoretical Inquiries in Law ___ (2020):

Legal DiscontinuityPresident Trump’s decision to move his official state of residence from high-tax New York to no (income)–tax Florida has brought public attention to an issue that has long troubled scholars, as well as designers and administrators of income tax systems: how the interaction of tax rules deferring the taxation of income and tax rules based on residency allows taxpayers to reduce and even avoid taxation of their deferred income. These discontinuities in tax treatment may lead to excessive migration, as well as reductions in state income tax revenues.

Although trans-national moves of this sort are increasingly treated as “realization events” for tax purposes, triggering the immediate taxation of accrued but untaxed gains in the taxpayer’s country of original residence, the states of the United States have not tried to impose similar rules on residents moving to other states. This reluctance may stem in part from concerns that any attempt to do so would be struck down as a violation of the federal constitution’s Commerce Clause or its Right to Travel. But it may also stem from the fact that such a forced realization rule creates a different discontinuity; a tax rule accelerating the taxation of accrued gain penalize interstate movers (relative to those who stay put and continue to benefit from tax deferrals), disincentivizing such moves. Instead of too much interstate migration, there may be too little, interfering with both economic efficiency and what could be a valuable feedback mechanism about the performance of state governments. The same discontinuity problem arises in the international realm, of course, but there the difference in institutional structures and political sensibilities—not to mention larger revenue concerns due to higher tax rates—has led to a different policy outcome.

My paper analyses legal mechanisms or rules that might reduce both positive incentives and negative disincentives for interstate moves.

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June 2, 2020 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Monday, June 1, 2020

Washington University Symposium: Current Issues In State Tax

Symposium, Current Issues in State Tax, 58 Wash. U. J.L. & Pol'y 1-296 (2019):

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June 1, 2020 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)

Wednesday, May 27, 2020

Temple Symposium: Taxpayer Rights — All The Angles

Symposium, Taxpayer Rights: All the Angles, 91 Temp. L. Rev. 679-830 (2019):

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May 27, 2020 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink | Comments (0)