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

Neil Buchanan (Florida) has issued his annual call for tax papers and panels for next year's annual meeting of the Law & Society Association in Denver, Colorado (June 6 - 9, 2024):

The Law & Society Association (LSA) will host its next annual meeting from June 6 - 9, 2024, in Denver, Colorado. For the twentieth year in a row (wow), I am organizing sessions for the "Law, Society, and Taxation" group (Collaborative Research Network 31). And for what is now the eighth year in a row, I have the good fortune of 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 last week. Note that all sessions in Denver will be entirely live. Like it or not (and I personally like it very much), everything is in-person again.

This year's official conference theme, "Unsettling Territories: Tradition and Revolution in Law and Society," is interesting and might encompass the work that you'd like to present.  Even so, please remember that you are not bound by the official theme of the conference,   We will give full consideration to proposals in any area of tax law, tax policy, distributive justice, interdisciplinary scholarship, and so on.

The deadline for submissions is October 24, 2023 at 5:00pm Eastern Standard Time (USA and Canada, where the "and Canada" part is personally meaningful to me this year, as my signature line below indicates, eh?).

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European Law Institute Hosts A Webinar Today On Taxation And Digital Assets

The ELI Business and Financial Law SIG hosts a webinar on Taxation and Digital Assets today at 9:00 A.M. EST (registration) (agenda):

We would like to invite you to the webinar on Taxation and Digital Assets on 22 September at 16:00 CEST. The webinar will address the taxation of digital assets including crypto, the metaverse, and NFTs. Topics covered will include the tax treatment of acquiring, holding and selling such assets. Panelists will include experts from the IMF, the US and Europe.

• Reuven S. Avi-Yonah (Michigan; Google Scholar) & Yuri Biondi (CNRS) (moderator)
• Michael Keen (IMF), What are Digital Assets?
• Christine Kim (Cardozo; Google Scholar), Enforcement Issues and Taxing the Metaverse
• Amanda Parsons (Colorado; Google Scholar), US Taxation of Cryptocurrencies: Acquiring Crypto

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National Tax Journal Hosts Forum Today On Gender And Public Policy

The National Tax Association hosts a National Tax Journal forum on Gender and Public Policy today at 12:30 PM ET (registration):

The Editors of the National Tax Journal (NTJ) are excited to continue our webinar series that periodically features some of the NTJ’s recently published articles.

Our next webinar will comprise four papers from the Forum of the September 2023 issue. Despite decades of progress, the path to gender equality in the U.S. remains long. The gender wage gap persists across the entire workforce, and women spend more time on average on unpaid household work and caretaking. There are also clear gender gaps in a wide array of economic, educational, and health outcomes. Recently, it has become increasingly recognized that public policies that are applied uniformly can mitigate or exacerbate these existing gender inequalities because of the different economic circumstances and family structures experienced by women and those in the LGBTQ+ community. The papers in this Forum explore several issues in gender and public policy.

Webinar Panelists:

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Fellowship Opportunities For The 116th National Tax Association Conference

The National Tax Association offers three fellowship opportunities for the 116th Annual Conference:

There are three fellowship/funding opportunities for the 116th Annual Conference, the NTA DEI Travel Fellowship, the the NTA Tax Climate Fellowship and the the NTA/CSWEP Mentoring Dinner for Women/Non-Binary Persons.  Read on for specifics for each fellowship. The deadline for all opportunities below is September 22nd. Recipients will be notified no later than October 6th. Questions? Email us: [email protected].

NTA Equity and Inclusion Travel Fellowship

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

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

Wednesday, September 6: 

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

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

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

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IBFD Opens Applications For 2024 Doctoral Meeting Of International Tax Researchers And Post-Doc International Tax Forum

Applications are open for the 2024 IBFD Academic Doctoral Meeting of Researchers in International Taxation (DocMIT) and Postdoctoral International Tax Forum (PITF): 

Applications are open until 31 December 2023! Check out the brochure for more information regarding the procedure and requirements.

What is it about?
The purpose of the DocMIT and PITF is to provide researchers with an opportunity to discuss their current research projects with leading academics and a select circle of colleagues. Participants benefit from tailored coaching provided by our panel of international tax professors, as well as from feedback provided by peers from around the world.

For the first time after the restrictions due to the pandemic, the seminar will take place at the IBFD HQ in Amsterdam, returning to its traditional in-person format.

You can find more information on the event at this link and, of course, spreading the word through your network will be much appreciated!

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IBFD Call For Abstracts: Individual Tax Reform In A Globalized World

IBFD, Inaugural Academic Tax Conference:

We invite you to submit your abstracts for our inaugural Academic Tax Conference (ATC), to be held in Amsterdam on 16-17 May 2024.

The Academic Tax Conference (ATC) kicks off with a Call for Abstracts and focuses on the topic “Blueprint for Individual Taxation Reform in a Globalized World”.

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Netanya Hosts 7th International Roundtable On Taxation And Tax Policy

Netanya hosts the 7th International Roundtable on Taxation and Tax Policy (program) today:

Session I: Business Taxation 

Chair: Noam Noked (Chinese University of Hong Kong; Google Scholar)
Mirit Eyal-Cohen (Alabama; Google Scholar), Taxing Artificial Inventiveness
Israel Klein (Ariel University; Google Scholar), The Corporate Tax Paradox

Session II: Enactment, Assessment, and Adjudication 

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

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

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

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

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

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

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

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Oxford Centre For Business Taxation Hosts 17th Annual Academic Symposium

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

Monday, June 26

Session 1: 

Chair: Michael Devereux (Oxford; Google Scholar)

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

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

Session 2: 

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

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

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

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

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

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

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

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

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

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

• Agenda
• Abstracts of Papers

Opening

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

Session 1: Service is Our Surname

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18th Annual Junior Tax Scholars Workshop Concludes Today At Northeastern

• Jeremy Bearer-Friend (George Washington; Google Scholar), How to Capitalize a Multi-Trillion Reparations Fund
• Luis Calderon-Gomez (Cardozo; Google Scholar), Taxation’s Limits
• Charles Delmotte (Michigan State; Google Scholar), Liberalism and Wealth Taxation
• Gaga Gondwe (Wisconsin), No Exit: Intimate Partner Violence and Tax-Based Social Support
• Jeesoo Nam (USC), Taxing the Innocent
• Amanda Parsons (Colorado; Google Scholar), Taxing Data in a Cash-Based Tax System
• Blaine Saito (Northeastern; Google Scholar), Tax Contrarians
• Daniel Schaffa (Richmond), Measuring Tax Complexity
• Christine Speidel (Villanova; Google Scholar), Reinforcing the Backstop

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

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

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

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Tax Presentations At Today's National Business Law Scholars Conference

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

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

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

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

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

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Columbia Hosts 2023 Tax Policy Workshop

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

Monday, June 12:

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

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

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Today's Law, Society, And Taxation Panels

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

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

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

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Today's Law, Society, And Taxation Panels

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

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

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

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Today's Law, Society, And Taxation Panel

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

Taxation of Labor and Business 

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

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

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

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8th Annual Texas Tax Faculty Workshop

Houston hosted the 8th Annual Texas Tax Faculty Workshop (program):

Johnny Buckles (Houston), Constitutional Law and Tax Expenditures: A Prelude, 76 Ark. L. Rev. 1 (2023)
Commenter: Susan Morse (Texas; Google Scholar)

Orly Mazur (SMU; Google Scholar), Cooperative Federalism and the Digital Tax Impasse, 51 Fla. St. U. L. Rev. __ (2023) (with Adam B. Thimmesch (Nebraska; Google Scholar))
Commenter: Khrista McCarden (Tulane)

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Tax Papers At Junior Faculty Forum At Richmond

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

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

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

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

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

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

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

Other Tax Profs with speaking roles include:

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26th Annual Critical Tax Conference At Loyola

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

Friday

9:00 AM: Welcome 

• Jennifer Kowal (Loyola-L.A.)

9:10 AM: What is Critical Tax? 

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

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Florida Hosts 13th Annual Tax Policy Symposium Today

Florida hosts the 13th Annual Ellen Bellet Gelberg Tax Policy Symposium today (Zoom link here):

Keynote #1 (9:30 AM ET): Diane Lim (Virginia), Bridging the Divide

• William Gale (Brookings Institution; Google Scholar) (moderator)
• Leonard Burman (Syracuse) 
• Bradley Hardy (Georgetown; Google Scholar)
• Elaine Maag (Urban Institute; Google Scholar) 
• Amy Matsui (National Women's Law Center) 

Keynote #2 (12:10 PM ET): William Gale (Brookings Institution; Google Scholar), Racial Disparities in the Income Tax Treatment of Marriage (with Janet Holtzblatt, Swati Joshi & Nora Cahill (Tax Policy Center):

Although it is generally blind with respect to race, the tax code can create racial disparities when factors that affect tax liability are correlated with race. In this working paper, we provide new evidence on racial differences in marriage penalties and bonuses in the income tax, using data from the Survey of Consumer Finances. Our results support Brown’s (2021) hypothesis that, controlling for income, penalties are more frequent and larger for Black couples than white couples. We link these results to racial differences in income, relative spousal earnings, and the presence of dependents, and examine two policy reforms.

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

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

Addressing Some Tax Fundamentals

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

International Tax: BEPS and Beyond

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

Tax Reform: Lessons for the Future

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Virginia Hosts Tax Study Group Meeting

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

9:30 AM - 10:45 AM:  D.C. Panel

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

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

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

12:30 PM - 1:45 PM: Keynote Address 

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Call For Papers: Tax Research Network Conference At Cambridge

Call for Papers:

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

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

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

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Loyola-L.A. Hosts Festschrift, Symposium, And Celebration To Honor Ellen Aprill

Loyola-L.A. hosted a festschrift, live symposium, and celebration to honor Ellen Aprill (Loyola-L.A.; Google Scholar) yesterday:

Lloyd Hitoshi Mayer (Notre Dame; Google Scholar), Nonprofits, Taxes, and Speech, 56 Loy. L.A. L. Rev. __ (2023):

Federal tax law is of two minds when it comes to speech by nonprofits. The tax benefits provided to nonprofits are justified in significant part because they provide nonprofits great discretion in choosing the specific ends and means to pursue, thereby promoting diversity and pluralism. But current law withholds some of these tax benefits if a nonprofit engages in certain types of political speech. Legislators have also repeatedly, if unsuccessfully, sought to expand these political speech restrictions in various ways. And some commentators have proposed denying tax benefits to groups engaged in other types of disfavored speech, including hate speech and fake news. These latter proposals have recently become more prominent as additional facts come to light about the role of nonprofits in supporting white supremacy and in disseminating misleading information about COVID-19 treatments.

This Article explores the existing and proposed limitations on speech by tax-exempt nonprofits given the constitutional restrictions on such limitations and the policy justifications for existing nonprofit tax benefits. It explains why the existing limits on political campaign intervention and lobbying by charities are both justified given the subsidy provided to charities and their supporters under existing federal tax law and constitutional given existing and longstanding case law. It further concludes that any expansion of these limits on charities to cover other types of speech, including hate speech and fake news, would be inconsistent with the existing broad definitions of the purposes that charities can pursue as well as, in some circumstances, constitutionally suspect. It also concludes that limits on speech by non-charitable tax-exempt nonprofits, including the existing limit on political campaign intervention for some of these nonprofits, is both unwise as a policy matter and, in some circumstances, constitutionally suspect given the lack of a subsidy for such speech by these nonprofits.

• Commentator: Eugene Volokh (UCLA; Google Scholar)

Roger Paul Colinvaux (Catholic University),  Strings Are Attached: Placing a Spotlight on the Hidden Subsidy for Gift Restrictions, 56 Loy. L.A. L. Rev. __ (2023):

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Tax Prof Presentations At Today's Poverty Law Conference

Tax Prof presentations at today's Poverty Law Conference at Berkeley (register here): 

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

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

Francine J. Lipman (UNLV; Google Scholar), Not Taxing Puerto Rico? Whitewashing Impoverishment in United States v. Vaello-Madero:

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

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

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

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

Taxing the Rich After TCJA

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

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Stetson Hosts 2nd Annual Tax Law Symposium Today

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

State and Local Tax Law Panel

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

Embracing Tax Avoidance

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

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

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

Introduction and Opening Remarks

• Alice Abreu (Temple)

Panel I: Race, History, Taxation and Behavior

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

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

Panel II: Tax Systems and Privileged Choices

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

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

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

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

Other Tax Profs with speaking roles include:

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

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

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

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

We accept submissions from:

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

Call For Papers:

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

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Georgetown|International Tax Policy Forum Conference: International Taxation in Flux

The Georgetown Law School Institute of International Economic Law (IIEL) and the International Tax Policy Forum (ITPF) host a conference today on International Taxation in Flux (program):

Panel #1: Primer: OECD/G20 Two-Pillar Project 

• Will Morris (PwC) (moderator)
• Mindy Herzfeld (Florida), Pillar One
• Lily Faulhaber (Georgetown; Google Scholar), Pillar Two

Panel #2: Assessment of Pillar One Amount A

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

Call For Papers: 

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

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

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Today's AALS Tax Highlight

Section on Taxation, Tax Reform at the Midterm: Reflections and Opportunities
3–4:40 pm Point Loma, First Floor, South Tower, Marriott

The Biden administration began in 2021 with significant attention being given to wealth and capital income tax reform as well as to the intersection of racial justice and the Tax Code. This panel will reflect on the resulting tax reform efforts that occurred during the first two years of the the Biden administration and the prospects for reform going forward.

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Today's Pepperdine And Tax AALS Highlights

Section on Associate Deans for Academic Affairs and Research, LLM (Law, Learning and Motivation): Transforming Legal Education via Learning and Motivation Principles
1–1:50 pm Marriott Grand Ballroom 9, Lobby Level, North Tower

Legal education and support are often described as entrenched in traditional methods of teaching and assessing student learning. Pedagogical considerations in law school classrooms and law school support systems rarely include a focus on how learning and motivation theory, and their practical applications, can positively impact the law student experience. In this session, participants will learn how to apply learning and motivation principles in the law school, with the overall goal of maximizing student learning and engagement, including a focus on self-regulation, goal setting, self-evaluation, cognitive load, emotions, and self-efficacy.

• Olympia Duhart (Nova) (moderator)
• Jeffrey Baker (Pepperdine)
• Chalak Richards (Pepperdine)
• Deepika Sharma (USC)
• Nickey Woods (USC)

Section on Taxation, Teaching Tax: Methods and Approaches for the Modern Student
3–4:40 pm Solana, First Floor, South Tower, Marriott

Experienced tax professors will share lessons that they have learned about teaching tax in the last few years of disruption in legal education. Topics will include utilizing technology, incorporating insights from practitioners, and covering issues of racial justice.

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Please Join Us: Pepperdine Caruso Law AALS Reception (Friday, Jan. 6)

Pepperdine Caruso Law School invites law professors and deans to a reception
hosted by Dean Paul Caron at the 2023 AALS Annual Meeting in San Diego

Friday, Jan. 6, 6:30 - 8:30 p.m.
Malibu Room | Marriott Marquis San Diego Marina (Headquarter Hotel)
Please join us for local California wine & beer and hors d'oeuvres

Call For Papers: Stetson Tax Law Symposium

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

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

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

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