Four Tax Questions For ChatGPT And Other Language Models

Libin Zhang (Fried Frank, New York), Four Tax Questions for ChatGPT and Other Language Models, 179 Tax Notes Fed. 969 (May 8, 2023):

Since ChatGPT was released to the public in late 2022, it and other language models have rapidly gained recognition for their ability to respond to queries with natural language text. This article tests the usefulness of three language models, ChatGPT, Bing Chat, and Google Bard, by asking each four tax-related questions:

1. Can I engage in a section 1031 like-kind exchange if I sell my Picasso painting?
2. Does a decedent recognize gain if she dies with assets that have debt in excess of tax basis?
3. Why should the federal government tax stock buybacks?
4. Can you tell me six original jokes about tax lawyers?

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Haneman: 529 Plans And School Choice

Victoria J. Haneman (Creighton; Google Scholar), 529 Plans and School Choice, 21 Pitt. Tax Rev. __ (2023):

Some politicians believe that market-based approaches to education will meaningfully reshape public education in the United States. Advocates of school choice insist that competition for students will improve academic outcomes, drive innovation and improvement, and reduce political interference in the education system. Critics believe that there is little empirical support for any of these claims, and fear that school choice policies worsen the problem of educational inequality. The purpose of this essay is not to rehash the topic of school choice, which has been exhaustively considered and debated by academia, think tanks, media and government. 

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Aprill: For-Profit Philanthropy And The 1969 Tax Reform Act

Ellen P. Aprill (Loyola-L.A.; Google Scholar), Reviewing For-Profit Philanthropy And the 1969 Tax Reform Act, 179 Tax Notes Fed. 825 (May 1, 2023):

For-Profit Philanthropy criticizes recent developments in philanthropy, arguing that they demonstrate “the unraveling of a pact between elites and the public that fueled half a century of philanthropic achievement.” My review recognizes the achievement of this book, in particular the breadth of its examination, but, of course, also critiques it. The authors argue that recent philanthropic activity by wealthy elites betrays the grand bargain of the 1969 Tax Reform Act that set out the rules for private foundations. I believe this thesis claims somewhat too much. In my view, it does not sufficiently weigh the value of donor privacy and by ignoring other philanthropic vehicles blessed by tax law, both before and after the 1969 Tax Reform Act.

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Tax Classification Of Cryptocurrency, NFTs, DAOs, And Other Digital Assets

Billy Abbott (O'Melveny & Myers, Silicon Valley), The Anything Asset: The Tax Classification of Cryptocurrency, NFTs, DAOs and Other Digital Assets, 26 Chap. L. Rev. 459 (2023):

The first question for any tax practitioner looking at a digital asset will be this: What is it? Given the flexibility of digital assets as evidenced by their already varied use, in a sense, a digital asset can be almost anything. Although tax advisors are used to applying old rules to classify new assets, the versatility of digital assets will stretch that approach and change the practice of tax law. This Article explores the interesting and challenging issue of classifying digital assets: first, through specifically considering the tax classification of common categories of digital assets--cryptocurrency, DAOs and NFTS--and second, by asking whether any or all of those assets can be classified as "securities" or "commodities" under a few key provisions of the Code.

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Jonathan Choi Leaves Minnesota For USC

Jonathan Choi (Minnesota; Google Scholar) has accepted a later offer from USC effective Fall 2023:

Professor Jonathan H. Choi specializes in law and artificial intelligence (applying natural language processing to study legal issues), statutory interpretation, and tax law.

Professor Choi earned his B.A. from Dartmouth College, summa cum laude, with a triple major in Computer Science, Economics, and Philosophy and high honors for his Computer Science thesis. He received a J.D. from the Yale Law School, where he was Executive Bluebook Editor of the Yale Law Journal. Before entering the academy, he practiced tax law at Wachtell, Lipton, Rosen & Katz.

Professor Choi has published articles in the New York University Law Review, Stanford Law Review, Yale Journal on Regulation, and Yale Law Journal, among others. His work has been covered by a wide variety of news outlets, including ABC News, Bloomberg, CBS News, CNN, the Daily Mail, Fox News, NBC Nightly News, the New Yorker, Reuters, the Star Tribune, and the Washington Post.

His recent publications include:

• Measuring Clarity in Legal Text, 91 U. Chi. L. Rev. __ (2024) 
• Subjective Costs of Tax Compliance, 108 Minn. L. Rev. __(2024) (with Ariel Jurow Kleiman (Loyola-LA; Google Scholar))
• ChatGPT Goes to Law School, 72 J. Legal Educ. __ (2023) (with Kristin Hickman (Minnesota; Google Scholar), Amy Monahan (Minnesota) & Daniel Schwarcz (Minnesota; Google Scholar)) 

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Taxing Zero

Hillel Nadler (Wayne State), Taxing Zero, 26 Fla. Tax Rev. __ (2023):

“Zero-price” transactions—in which goods or services are provided at a cash price of zero—are an increasingly important feature of economic life. Consumers can search the web, use email, listen to music, and even trade stocks, all without paying anything out of pocket. But zero-price transactions are not free: for-profit businesses provide products at zero-price because they get something valuable from consumers in return. Consumers pay with their time, attention, or private information. Zero-price transactions are not giveaways; they are a form of barter exchange.

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The Unacknowledged Realities Of Extraterritorial Taxation

Laura Snyder (AARO, SEAT), The Unacknowledged Realities of Extraterritorial Taxation, 47 S. Ill. U. L.J. 243 (2023):

The U.S. extraterritorial tax system has evolved such that today it is more consequential than one century ago. The system, conceived in the stigmatization of overseas Americans, consists of highly penalizing taxation and banking policies that make it difficult for overseas Americans to live normally. The IRS is also a victim: it is unable to administer the system.

Many have sought to educate policymakers and the public. Detailed survey reports have been issued, documenting how overseas Americans experience the system. Research articles have been published, exposing certain problems of the system and, in some cases, proposing solutions.

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Pop & Perjury: The IRS Valuation War With The Estate Of Michael Jackson

Beckett Cantley (Northeastern) & Geoffrey Dietrich (Cantley Dietrich), Pop & Perjury: The IRS Valuation War with the Estate of Michael Jackson, 21 New Hampshire L. Rev. 93 (2022):

When Michael Jackson died unexpectedly in Los Angeles, California, on June 25, 2009, his career and earnings were nearing an all-time low. Plagued by past sexual abuse allegations, scandals, and questionable health, Michael Jackson’s personal finances were purported to be in complete disarray. However, following his unexpected death, the value of his estate, which was reported to be near to nothing, swelled as the world remembered his beloved contributions to the world and began to purchase accordingly. Sales of Michael Jackson’s music began to soar high. The estate’s value soared even higher as it signed licensing agreements and released new feature films and theatrical material of Michael Jackson.

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Apple v. European Commission: Losing The War On Corporate International Transfer Pricing

Beckett Cantley (Northeastern) & Geoffrey Dietrich (Cantley Dietrich), Apple v. European Commission: Losing the War on Corporate International Transfer Pricing, 45 Loy. L.A. Int'l & Comp. L. Rev. 1 (2022):

For the last several years, Apple has been defending tax strategies utilized in Ireland before the European Union (EU) General Court. The European Commission, using Article 107 of the Treaty on the Functioning of the European Union, argues that Ireland provides state aid to Apple regarding several tax rulings, and that Apple owes a substantial tax liability. Although Apple was able to secure a favorable ruling before the EU General Court, the European Commission has appealed the General Court’s decision, and the final resolution to this case could be several years away. 

The outcome of this case has the potential to cause changes to the corporate tax structure within the EU and could either strengthen or weaken the Commission’s success in challenging the lack of arm’s length principles in transfer pricing methods through state aid concerns. If the European Commission is unsuccessful in this case, there may be a push for the EU to harmonize the corporate tax system in the hopes of limiting corporations’ ability to reduce tax liabilities by shifting profits between countries in the EU. 

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Thomas & Scharff: Fake News And The Tax Law

Kathleen DeLaney Thomas (North Carolina; Google Scholar) & Erin Scharff (Arizona State), Fake News and the Tax Law, 80 Wash. & Lee L. Rev. 803 (2023):

The public misunderstands many aspects of the tax system. For example, people frequently misunderstand how marginal tax rates work, misperceive their own average tax rates, and believe they benefit from tax deductions for which they are ineligible. Such confusion is understandable given the complexity of our tax laws. Unfortunately, research suggests these misconceptions shape voter preferences about tax policy which, in turn, impact the policies themselves.

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Tax Policy And COVID-19: An Argument For Targeted Crisis Relief

Assaf Harpaz (Drexel), Tax Policy and COVID-19: An Argument for Targeted Crisis Relief, 31 Cornell J.L. & Pub. Pol'y 235 (2021):

The COVID-19 pandemic caused a sharp global economic decline. By the end of 2021, the U.S. government responded to the downturn with record fiscal legislation totaling over $5 trillion, which includes considerable tax relief. Most notably, the U.S. government distributed over $800 billion in three rounds of advanced refundable tax credits (known as recovery rebates, or stimulus checks) to most households. Tax relief has been unprecedented in scale but has often been the product of political circumstances rather than principled policy design. Tax relief thus remains largely undertheorized and politically motivated.

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The Top Five New Tax Papers

There is quite a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with new papers debuting on the list at #1 and #5:

1. [340 Downloads]  The Unacknowledged Realities of Extraterritorial Taxation, by Laura Snyder (Association of Americans Resident Overseas)
2. [311 Downloads]  Taxation of Information and the Data Revolution, by Yariv Brauner (Florida; Google Scholar)
3. [238 Downloads]  Capital Taxation and Market Power, by Kimberly Clausing (UCLA; Google Scholar)
4. [231 Downloads]  The Employment Effects of Tax Subsidies for the Construction of Amazon Facilities, by Ike Brannon (Jack Kemp Foundation) & Matthew Winden (University of Wisconsin (Whitewater); Google Scholar)
5. [196 Downloads]  The Inflation Reduction Act's Impact On Tax Compliance—And Fiscal Sustainability, by Natasha Sarin (Yale; Google Scholar; Former Counselor on Tax Policy, U.S. Treasury Department) & Mark J. Mazur (Former Assistant Secretary for Tax Policy, U.S. Treasury Department),

This Week's Ten Most Popular TaxProf Blog Posts

Legal Education:

1. New York Times, Here’s What Happens When A Lawyer Uses ChatGPT
2. U.S. News, 2024 Omnibus Law School Specialty Rankings
3. U.S. News, 2024 Omnibus Law School Specialty Rankings v. Overall Rankings
4. Paul Caron (Dean, Pepperdine), Preview Of The 2024 U.S. News Law School Rankings: Admissions
5. Law.com, Duquesne, FIU, Kansas, Oklahoma, And Texas A&M Are Among The Biggest U.S. News Law School Rankings Winners
6. ABA Journal, Some Law Schools Already Are Using ChatGPT To Teach Legal Research And Writing
7. Inside Higher Education, 17 Universities And Law Schools Have Full Satellite Campuses In Washington, D.C.
8. John Bliss (Denver) & David Sandomierski (Western), Learning Without Grade Anxiety: Lessons From The Pass/Fail Experiment In North American J.D. Programs
9. Law.com, Tenured Law Professor Pulled From His Classroom Faces Termination. He Wants To Know Why?
10. U.S. News 2024 Law School Specialty Rankings:

• Legal Writing
• Tax Law
• Trial Advocacy

Tax:

1. Bryan Camp (Texas Tech), Lesson From The Tax Court: Substantiating Gambling Losses On Per-Casino Basis
2. Daniel Shaviro (NYU), Two New Tax Papers on SSRN
3. Bryan Camp (Texas Tech), Lesson From The Tax Court: On Time Is Late
4. Reuven Avi-Yonah (Michigan), Three New International Tax Papers On SSRN
5. Law, Society, And Taxation, Thursday's Panel
6. Law, Society, And Taxation, Friday's Panels
7. Law, Society, And Taxation, Saturday's Panels
8. SSRN, The Top Five New Tax Papers
9. David Elkins (Netanya), Review Of Ancillary Benefits And Income Versus Consumption Taxation in Liam Murphy’s And Thomas Nagel’s 'The Myth of Ownership,' by Daniel Shaviro (NYU)
10. Roundup, Tax Policy In The Biden Administration

Faith: 

1. Tim Keller, Growing My Faith In The Face Of Death
2. Roundup, The Life, Death, And Legacy Of Tim Keller
3. Roundup, More On The Life, Death, And Legacy Of Tim Keller
4. New York Times Op-Ed (Ross Douthat), Pro-Trump Christians, Never-Trump Christians, And Tim Keller
5. New York Times Op-Ed (Tish Harrison Warren), How a Cancer Diagnosis Makes Jesus’ Death and Resurrection Mean More: An Interview With Tim Keller

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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Tax Policy In The Biden Administration

• Bloomberg, Clean Energy Companies Race to Prepare Tax Credit Applications
• Bloomberg, Hedge Funds Cash In on Covid-Era Tax Credit With IRS Backlog
• Bloomberg, Summers Sees Higher Fed Interest Rates, Increased Taxes
• Law360, Pressure For Corporate Tax Transparency May Just Be Beginning
• Los Angeles Times, Celebs Dodged Millions in L.A.’s ‘Mansion Tax.’ Meet the Industry Guarding Their Wealth

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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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Grewal: Billionaire Taxes And The Constitution

Andy Grewal (Iowa; Google Scholar), Billionaire Taxes and the Constitution, 57 Ga. L. Rev. ___ (2023):

The United States now has ten times as many billionaires as it had just a few decades ago. This ever-growing class has sparked congressional interest in “billionaire tax” proposals. These proposals would generally require that billionaires recognize income when their asset values increase, even if they have not sold their assets.

Under existing doctrine, billionaire taxes likely violate the realization requirement embedded in the Sixteenth Amendment of the Constitution. However, this Article argues that existing Sixteenth Amendment doctrine suffers from deep infirmities and theoretical inconsistencies. With the conceptually sound interpretive approach advanced in this Article, a billionaire tax would pass constitutional muster.

Wallace: A Democratic Perspective On Tax Law

Clint Wallace (South Carolina), A Democratic Perspective on Tax Law, 98 Wash. L. Rev. ___ (2023):

As democracies around the world have faltered, legal scholars in fields as diverse as election law, labor law, and administrative law have turned to tax law to repair and support democratic governments. Taxation offers a toolset well equipped to address concerns raised by democratic theorists focused on the conditions that shape a democratic community and help it to flourish. Tax laws can rectify social dynamics characterized by economic inequality and can help establish and strengthen civic institutions, among many possible interventions. But legal scholars evaluating and designing tax policies generally focus on the standard normative criteria of efficiency, equity, and administrability, with little specific regard for democratic concerns. This separation from democratic theory has left tax law scholars ill-equipped to respond to calls for help from more democracy-focused fields of law. Thus, tax scholarship mostly has not engaged with the increasingly important project of strengthening democratic governance.

This Article argues that democracy should be a more central consideration in designing and evaluating tax laws in a democratic system of government, exploring a set of democracy criteria that can bolster the standard normative criteria used to evaluate tax policy.

The democracy criteria considered here ask: does a change in tax rules strengthen or undermine democratic governance? This Article draws on democratic theory to identify pressure points where taxation might shape democracy, building on work by tax scholars who have tried to integrate democratic values into the standard criteria. I make the case that democratic considerations should not be subordinated to other criteria, but rather should stand on their own. I apply the democracy criteria to wealth tax proposals, showing how a democratic perspective illuminates a contemporary debate in U.S. tax policy.

Approached in this way, a democratic perspective on tax law and policy can facilitate tax responses—in scholarly discourse and in policy prescriptions—to current challenges facing democracies around the world, answering the calls of scholars in other fields who (appropriately) view tax rules as sites of important potential interventions to shore up democracy.

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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The Welfare Effects Of Nudges Versus Taxes

John A. List (Chicago; Google Scholar), Matthias Rodemeier (Bocconi; Google Scholar), Sutanuka Roy (Australian National; Google Scholar) & Gregory Sun (Chicago), Judging Nudging: Understanding the Welfare Effects of Nudges Versus Taxes:

While behavioral non-price interventions (“nudges”) have grown from academic curiosity to a bona fide policy tool, their relative economic efficiency remains under-researched. We develop a unified framework to estimate welfare effects of both nudges and taxes. We showcase our approach by creating a database of more than 300 carefully hand-coded point estimates of nonprice and price interventions in the markets for cigarettes, influenza vaccinations, and household energy. While nudges are effective in changing behavior in all three markets, they are not necessarily the most efficient policy. 

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Kemker: When Gender-Affirming Healthcare Becomes Illegal, Will It (Still) Be Tax-Deductible?

Diane Kemker (Southern, DePaul), When Gender-Affirming Healthcare Becomes Illegal, Will It (Still) Be Tax-Deductible?:

In the absence of universal health care, which itself exacts a deadly toll on Americans, all too many people face unmanageable medical costs. Even those with insurance may find themselves with large, uninsured expenses. The Internal Revenue Code acknowledges these realities by permitting taxpayers to take a deduction for unusually large medical expenses incurred in a taxable year, whether for the taxpayer or their dependents. Although the statutory provision that creates this deduction does not condition deductibility on the legality of the medical treatment, the Regulations do.

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Avi-Yonah: Should U.S. Tax Law Be Constitutionalized? Centennial Reflections On Eisner v. Macomber (1920)

Reuven Avi-Yonah (Michigan; Google Scholar), Should U.S. Tax Law Be Constitutionalized? Centennial Reflections on Eisner v. Macomber (1920), 16 Duke J. Const. L. & Pub. Pol'y 65 (2021)

The United States Supreme Court last decided a federal income tax case on constitutional grounds in 1920—a century ago. The case was Eisner v. Macomber, and the issue was whether Congress had the power under the Sixteenth Amendment to include stock dividends in the tax base. The Court answered “no” because “income” in the Sixteenth Amendment meant “the gain derived from capital, from labor, or from both combined.” A stock dividend was not “income” because it did not increase the wealth of the shareholder.

Macomber was never formally overruled, and it is sometimes still cited by academics and practitioners for the proposition that the Constitution requires that income be “realized” to be subject to tax. 

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Shaviro Posts Two Tax Papers On SSRN

Daniel Shaviro (NYU; Google Scholar) has posted two tax papers on SSRN:

Time Is, Time Was: Evaluating the Use of the Life Cycle Model as a Fiscal Policy Tool:

What time periods should we use in tax and other fiscal policy to evaluate people’s circumstances, and thus to determine either how they are being treated, or how they ought to be? This question is both fundamental and pervasive.

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Avi-Yonah Posts Three International Tax Papers On SSRN

Reuven S. Avi-Yonah (Michigan; Google Scholar) has posted three international tax papers on SSRN:

Unitary Taxation After Pillar One:

Pillar One of the G20/OECD/IF BEPS 2.0 effort is unlikely to succeed for three reasons. First, it requires a multilateral tax convention (MTC) to be implemented because Amount A requires overriding Articles 5 (Permanent Establishment, PE), 7 (Business Profits) and 9 (Associated Enterprises) of every tax treaty to abolish the PE and Arm’s Length Principle (ALP) limits enshrined therein. 

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Lesson From The Tax Court: Substantiating Gambling Losses On Per-Casino Basis

The old saying “you win some, you lose some” is not true for most recreational gamblers.  For them, the saying is more like “you win some, you lose more.”  But proving that proves a problem.  In Jacob Bright v. Commissioner, Docket No. 10095-22 (May 4, 2023), Judge Buch teaches us how taxpayers can use their player cards to substantiate their wagering losses.  There, Mr. Bright reported some $241,000 of wagering gains on his 2019 return, and an equal amount of losses.  However, he apparently did not follow best practices—as very nicely explained in this article—of keeping daily contemporaneous records.  When audited, the IRS accepted his self-reported income (natch!) but disallowed all the losses for lack of substantiation (double natch!).

In Tax Court, Judge Buch allowed Mr. Bright to introduce reports of his player card activity, from each of the three Casinos he gambled at in 2019.  That created a sufficient basis for the Court to use the Cohan rule, albeit differently for each Casino.  The Court used this method to estimate $191,000 of losses.  In taking this approach for calculating wagering losses, Judge Buch gives us a new idea of “per session” netting worth considering, not only for proving up wagering losses, but also for calculating wagering gains.  I would call it a “per establishment” approach.  It makes a good bit of sense.  Details below the fold.

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TaxProf Blog Holiday Weekend Roundup

Saturday:

• This Week's Ten Most Popular TaxProf Blog Posts
• Duquesne, FIU, Kansas, Oklahoma, And Texas A&M Are Among The Biggest U.S. News Law School Rankings Winners
• Innovation Funding And The Valley Of Death
• Applying Universal Design In The Legal Academy

Sunday:

• More On The Life, Death, And Legacy Of Tim Keller
• NY Times Op-Ed: Pro-Trump Christians, Never-Trump Christians, And Tim Keller
• NY Times: A Christian University Fired Two Employees For Including Pronouns In Their Email Signatures
• The Top Five New Tax Papers

Memorial Day:

• Brooks Reviews Cui's Administrative Foundations Of The Chinese Fiscal State
• 17 Universities And Law Schools Have Full Satellite Campuses In Washington, D.C.
• Brunson: Tax Entity Status And Decentralized Autonomous Organizations
• Assessing Heinonline As A Source Of Scholarly Impact Metrics

Brooks Reviews Cui's Administrative Foundations Of The Chinese Fiscal State

Kim Brooks (Dalhousie University, Schulich School of Law; Google Scholar), Where Tax Law Canno Be Found, You Will Find a Robustly-Tasked Tax Administrator (JOTWELL) (reviewing Wei Cui (British Columbia; Google Scholar), The Administrative Foundations of the Chinese Fiscal State (Cambridge University Press (2022) (reviewed by David Elkins (Netanya; Google Scholar) here)):

The hard work that went into authoring The Administrative Foundations of the Chinese Fiscal State is palpable from the first page. Cui seeks to achieve two aims: (1) to tease out aspects of Chinese taxation of general interest to policy makers and social scientists in other countries (P. 3) and (2) to offer a new framework for understanding the policies and politics of taxation in China (P. 4). Both aims are accomplished handily.

Particularly fun for those of us who like tax administration, Cui claims that ground-level tax administration is essential to understanding the Chinese tax system. Focusing on tax administration, tax collection and revenue mobilization, allows Cui to show us something new about our own tax systems. He offers us the opportunity to see more clearly our own paradigmatic orientation: one that centres the importance of rule of law.

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Brunson: Tax Entity Status And Decentralized Autonomous Organizations

Samuel D. Brunson (Loyola-Chicago; Google Scholar), Standing on the Shoulders of LLCs: Tax Entity Status and Decentralized Autonomous Organizations, 57 Ga. L. Rev. 603 (2023):

Since the formation of the first decentralized autonomous organization in 2016, their use has exploded. Thousands of DAOs now try to take advantage of smart contracts to solve a problem that plagues business entities: the gulf between ownership and management. Armed with smart contracts and requiring token-holders to vote on any change in strategy, DAOs dispense with the management layer so necessary in traditional business entities.

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The Top Five New Tax Papers

This week's list of the Top 5 Recent Tax Paper Downloads is the same as last week's list:

1. [483 Downloads]  GILTI and the GloBE, by Heydon Wardell-Burrus (Oxford)
2. [405 Downloads]  Does the 'Initial Phase Relief' Make the EU’s Pillar Two Directive Invalid?, by Georg Kofler (Vienna University of Economics and Business; Google Scholar) & Arne Schnitger (Free University of Berlin)
3. [300 Downloads]  Taxation of Information and the Data Revolution, by Yariv Brauner (Florida; Google Scholar)
4. [229 Downloads]  The Employment Effects of Tax Subsidies for the Construction of Amazon Facilities, by Ike Brannon (Jack Kemp Foundation) & Matthew Winden (University of Wisconsin (Whitewater); Google Scholar)
5. [219 Downloads]  Capital Taxation and Market Power, by Kimberly Clausing (UCLA; Google Scholar),

This Week's Ten Most Popular TaxProf Blog Posts

Legal Education:

1. Law.com, Tenured Law Professor Pulled From His Classroom Faces Termination. He Wants To Know Why?
2. Derek Muller (Iowa), How Law Faculty Succeeded In Diminishing Their Importance In The U.S. News Rankings
3. Markus Funk (Colorado), Andrew Boutros (Chicago) & Eugene Volokh (UCLA), Time For Law Schools To Rethink Unsung Role Of Adjuncts
4. Stephanie Hunter McMahon (Cincinnati), What Law Schools Must Change To Train Transactional Lawyers
5. Paul Caron (Dean, Pepperdine), Preview Of The 2024 U.S. News Law School Rankings: Admissions
6. Wall Street Journal Op-Ed (Jay Mitchell, Alabama Supreme Court), The New Bar Exam Puts DEI Over Competence
7. Donald Tobin (Maryland), A Preliminary Analysis of the New 2024 U.S. News Law School Rankings
8. Paul Caron (Dean, Pepperdine), Projected 2025 U.S. News Law School Rankings: The Biggest Winners And Losers
9. Prentiss Cox (Minnesota), 1L Curricula in the United States: 2023 Data and Historical Comparison
10. U.S. News & World Report 2024 Specialty Rankings:

• Dispute Resolution Rankings
• Environmental Law Rankings
• Health Care Law Rankings
• Intellectual Property Law Rankings
• International Law Rankings

Tax:

1. Bryan Camp (Texas Tech), Lesson From The Tax Court: On Time Is Late
2. The Legal Watchdog, How The Accounting Profession Wrecked Itself And Made A Legal Career Preferable To A CPA
3. Bryan Camp (Texas Tech), Lesson From The Tax Court: Allocating Between Excludable Child Support and Includable Interest
4. Reuven Avi-Yonah (Michigan) & Yoseph Edrey (Haifa University), Constitutional Review Of Federal Tax Legislation
5. Bryan Camp (Texas Tech), Lesson From The Tax Court: Exclusion Rules For Disability Payments
6. U.S. News & World Report, 2024 Tax Rankings
7. San Diego Conference, Tax Profs Tenured 1-15 Years 
8. SSRN, The Top Five New Tax Papers
9. Sloan Speck (Colorado), Review Of A Critical Evaluation Of The Qualified Small Business Stock Exclusion, By Gregg Polsky (Georgia) & Ethan Yale (Virginia)
10. Roundup, Tax Policy In The Biden Administration

Faith: 

1. The Life, Death, And Legacy Of Tim Keller
2. Tim Keller: Growing My Faith In The Face Of Death

Innovation Funding And The Valley Of Death

Lital Helman (Ono Academic College), Innovation Funding and the Valley of Death, 76 S.M.U. L. Rev. __ (2023):

Innovation is a public good. As with other public goods, it is expected to be under-produced if only private incentives are present. Therefore, the law strives to encourage innovation via an array of stimuli mechanisms. The law offers three main such mechanisms: intellectual property (IP), cash transfers—mainly prizes and grants, and tax incentives.

Vast literature analyzes and compares these innovation stimuli in search for the optimal mix to boost innovation. Yet a key problem is largely overlooked: taken together, the existing stimuli do not cover the lion’s share of the innovation lifecycle. At the beginning of the innovation process, companies can win grants or prizes to cover research & development (R&D) expenses. When the company is already selling, it can enjoy IP payoffs and tax credits. In between, no targeted stimuli exist. This is an incongruity, because most innovative endeavors struggle neither in the R&D phase nor at the sales stage. In particular, for startups in the high-tech sector, it is precisely the phases between R&D and sales that prove fatal. This phenomenon is so well-known that the market has created a nickname for it—“the valley of death.”

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Weekly SSRN Tax Article Review And Roundup: Speck Reviews A Critical Evaluation Of The Qualified Small Business Stock Exclusion By Polsky & Yale

This week, Sloan Speck (Colorado; Google Scholar) reviews a new work by Gregg D. Polsky (Georgia; Google Scholar) & Ethan Yale (Virginia; Google Scholar), A Critical Evaluation of the Qualified Small Business Stock Exclusion, 42 Va. Tax Rev. 353 (2023).

After 2017’s Tax Cuts and Jobs Act, some commentators predicted a renaissance in taxpayers’ use of the statutory exclusion for gain from qualified small business stock under § 1202. In 2015, Congress made permanent the provision’s 100 percent exclusion that emerged in the wake of the Great Recession, and the TCJA’s fourteen-point reduction in corporate rates heralded new benefits to bucking longstanding conventional wisdom that taxpayers should operate nonpublic companies as passthroughs. These predictions didn’t really come to pass, as Polsky and Yale observe in their magisterial exegesis of § 1202, A Critical Evaluation of the Qualified Small Business Stock Exclusion. 

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Tax Policy In The Biden Administration

• Bloomberg, Biden Pressed to Limit Hydrogen Credits Key to New Industry
• Bloomberg, Flight of Affluent Taxpayers Catches Up With New York
• Bloomberg, IRS's $80 Billion Budget Boost Targeted for Cuts in Debt Talks
• Common Dreams, 'We Are Not Taxing the Very Wealthy Enough': Runaway Inequality About to Get Worse
• Financial Times, IRS Sets Its Sights on Tax Avoidance by the Super-Rich and Corporations

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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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The Inflation Reduction Act's Impact On Tax Compliance—And Fiscal Sustainability

Natasha Sarin (Yale; Google Scholar; Former Counselor on Tax Policy, U.S. Treasury Department) & Mark J. Mazur (Former Assistant Secretary for Tax Policy, U.S. Treasury Department), The Inflation Reduction Act's Impact on Tax Compliance—and Fiscal Sustainability:

The Inflation Reduction Act (IRA) includes a once-in-a-generation investment in the Internal Revenue Service (IRS) to modernize America’s tax administration and, by doing so, meaningfully increase compliance with the nation’s tax laws. We consider the impact of this investment on new tax revenue that the agency will be able to collect. Our rough estimate suggests that IRS funding will raise at least $560 billion ($480 billion, net) over the course of the next ten years—and, depending on the extent of taxpayer’s behavioral response to greater enforcement presence, could easily raise closer to $1 trillion. This is much larger than official government estimates.

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Clausing: The International Tax Agreement Of 2021—Why It's Needed, What It Does, And What Comes Next?

Kimberly A. Clausing (UCLA; Google Scholar), The International Tax Agreement of 2021: Why It's Needed, What it Does, and What Comes Next?:

In 2021, more than 135 jurisdictions agreed on transformative new international tax rules that would establish a minimum tax rate of 15 percent on multinational corporate income regardless of where it was reported. In December 2022, the European Union unanimously moved forward to implement this minimum tax, and other countries, including South Korea, Japan, Australia, Canada, and the United Kingdom, are also either implementing the tax or taking substantial steps toward implementation.

In tandem, the United States should also reform its international tax system and adopt a stronger minimum tax. While the future of the international agreement is uncertain, it has important implications for the ability of governments worldwide to create tax systems that are administrable, fair, and efficient.

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SSRN Tax Professor Rankings

SSRN has updated its monthly ranking of 750 American and international law school faculties and 3,000 law professors by (among other things) the number of paper downloads from the SSRN database.  Here is the new list (through May 1, 2023) of the Top 25 U.S. Tax Professors in two of the SSRN categories: all-time downloads and recent downloads (within the past 12 months):

		All-Time			Recent
1	Reuven Avi-Yonah (Michigan)	220,463	1	Jonathan Choi (Minnesota)	13,150
2	Daniel Hemel (NYU)	129,887	2	Reuven Avi-Yonah (Michigan)	11,859
3	Dan Shaviro (NYU)	126,539	3	Kristin Hickman (Minnesota)	10,601
4	Lily Batchelder (NYU)	126,365	4	Amy Monahan (Minnesota)	9,666
5	David Gamage (Indiana-Maurer)	124,060	5	Daniel Hemel (NYU)	4,465
6	Darien Shanske (UC-Davis)	117,196	6	Bridget Crawford (Pace)	4,090
7	David Kamin (NYU)	113,586	7	Ruth Mason (Virginia)	3,333
8	Cliff Fleming (BYU)	107,956	8	Margaret Ryznar (Indiana-McKinney)	3,073
9	Manoj Viswanathan (UC-San Francisco)	104,514	9	Louis Kaplow (Harvard)	3,034
10	Ari Glogower (Northwestern)	103,801	10	Robert Sitkoff (Harvard)	3,014
11	Rebecca Kysar (Fordham)	103,614	11	D. Dharmapala (Chicago)	2,892
12	D. Dharmapala (Chicago)	50,137	12	Kyle Rozema (Washington University)	2,870
13	Michael Simkovic (USC)	47,611	13	Richard Ainsworth (Boston University)	2,545
14	Paul Caron (Pepperdine)	40,941	14	Darien Shanske (UC-Davis)	2,544
15	Louis Kaplow (Harvard)	39,839	15	David Gamage (Indiana-Maurer)	2,441
16	Richard Ainsworth (Boston University)	37,513	16	Kim Clausing (UCLA)	2,427
17	Bridget Crawford (Pace)	35,907	17	Brad Borden (Brooklyn)	2,266
18	Robert Sitkoff (Harvard)	31,977	18	Zachary Liscow (Yale)	2,260
19	Brad Borden (Brooklyn)	30,229	19	Dan Shaviro (NYU)	2,065
20	Vic Fleischer (UC-Irvine)	29,751	20	Young Ran (Christine) Kim (Cardozo)	2,044
21	Ruth Mason (Virginia)	29,608	21	Lily Batchelder (NYU)	2,017
22	Ed Kleinbard (USC)	29,359	22	Richard Kaplan (Illinois)	1,887
23	Jim Hines (Michigan)	27,844	23	Brian Galle (Georgetown)	1,780
24	Richard Kaplan (Illinois)	27,059	24	Victoria Haneman (Creighton)	1,727
25	Katie Pratt (Loyola-L.A.)	26,221	25	David Kamin (NYU)	1,670

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

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

Panel #1:

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

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

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

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Taxing Creativity

Xuan-Thao Nguyen (Washington) & Jeffrey A. Maine (Maine), Taxing Creativity, 89 Tenn. L. Rev. 523 (2022):

The recent sell offs of song catalogs by Bob Dylan, Stevie Nicks, Neil Young, and Mick Fleetwood for extraordinarily large sums of money raise questions about the law on creativity. While patent and copyright laws encourage a wide array of creative endeavors, tax laws governing monetization of creative works do not. 

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How The Accounting Profession Wrecked Itself And Made A Legal Career Preferable To A CPA

The Legal Watchdog, Accounting: How to Wreck (and Rescue) a Profession:

In my earlier life, becoming a CPA was, in a sense, easy.  To be sure, the two-day exam itself was very tough.  Unlike state bar exams which sometimes have an 80% first-time pass rate, the November 1996 CPA exam, for example, had a 17% pass rate for first-time test takers.  But the process of becoming a CPA was very simple.  Just get a B.S. or B.B.A. in accounting, sign up for and pass the CPA exam, and then wait for your certificate to arrive in the U.S. mail. ...

Today, there are many articles about the declining number of CPAs and, especially, of accounting majors in the CPA pipeline.  The latest such article is here, in today’s WSJ (subscription required).  That article’s title indicates its proposed solution to the problem: How can we make accounting cool?  And there are many articles like this one, angsting about how to replenish the numbers within the profession.  But I doubt people are now avoiding accounting because it’s un-cool.  It has always been un-cool (which, in some circles, can be cool).

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Lesson From The Tax Court: On Time Is Late

In law, even more than in comedy, timing can be critical.  In comedy you just lose a laugh.  In law, you lose a case.  In Roy A. Nutt and Bonnie W. Nutt v. Commissioner, 160 T.C. No. 10 (May 2, 2023) (Judge Buch), we learn why a petition seemingly submitted on time will be rejected as late.  There, the Nutts electronically submitted their Petition to the Tax Court on the last day they could file.  Now we all know you really don't want to ever do that.  But sometimes it just happens.  And the last day to file is just as timely as the first day to file.  The Nutts submitted their Petition at 11:05 p.m.  So they seemed to be on time.

The problem was that they were filing from Alabama (Central Time) and the Tax Court’s Clerk’s office is in Washington D.C. (Eastern Time).  Thus, even though they submitted on time, Judge Buch holds that their Petition was filed late, because 11:05 p.m. in Alabama was five minutes after midnight in Washington D.C.  Thus, sticking to its increasingly archaic view that the timing rules for filing a Petition are jurisdictional, the Tax Court dismissed the Petition.

Note this is another precedential opinion issued in a case with unrepresented taxpayers.  Here, the IRS moved to dismiss and briefed the issue, but there was no responding brief to counter the government’s view.  These pro-se taxpayers probably did not know about all the Tax Court precedent applying equitable principles to rescue seemingly late-filed petitions.  I give a close review of those cases in Bryan Camp, Equitable Doctrines and Jurisdictional Time Periods, Part 2, 159 Tax Notes 1581 (June 11, 2018).

To his great credit, Judge Buch has, in a similar case, asked for amicus briefs on the issue.  I hope the Tax Court there comes to a different conclusion.  It’s always a balancing act: weighing the need for taxpayer access to judicial review with the need to obey statutory limits. Perhaps the Tax Court might reconsider how that balance should work for electronically filed documents.  However, as Professor Book puts it in this post over at Procedurally Taxing, after this case taxpayers now have a steeper hill to climb. You will find the sad details below the fold, along with my modest thoughts on how to strike a better balance. 

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The Top Five New Tax Papers

There is a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with a new #1 paper and a new paper debuting on the list at #4:

1. [470 Downloads]  GILTI and the GloBE, by Heydon Wardell-Burrus (Oxford)
2. [396 Downloads]  Does the 'Initial Phase Relief' Make the EU’s Pillar Two Directive Invalid?, by Georg Kofler (Vienna University of Economics and Business; Google Scholar) & Arne Schnitger (Free University of Berlin)
3. [293 Downloads]  Taxation of Information and the Data Revolution, by Yariv Brauner (Florida; Google Scholar)
4. [220 Downloads]  The Employment Effects of Tax Subsidies for the Construction of Amazon Facilities, by Ike Brannon (Jack Kemp Foundation) & Matthew Winden (University of Wisconsin (Whitewater); Google Scholar)
5. [202 Downloads]  Capital Taxation and Market Power, by Kimberly Clausing (UCLA; Google Scholar),

This Week's Ten Most Popular TaxProf Blog Posts

Legal Education:

1. ABA Journal, ABA Pauses Move To Eliminate LSAT Requirement For Admission To Law School
2. Paul Caron (Dean, Pepperdine), Projected 2025 U.S. News Law School Rankings: The Biggest Winners And Losers
3. Donald Tobin (Maryland), A Preliminary Analysis of the New 2024 U.S. News Law School Rankings
4. Paul Caron (Dean, Pepperdine), 2024 U.S. News Law School Peer Reputation Rankings (And Overall Rankings)
5. ABA Journal, ABA Increases Law School Online Course Cap From 33% To 50%
6. Paul Caron (Dean, Pepperdine), More Commentary On The 2024 U.S. News Law School Rankings
7. Stephen Embry (TechLaw Crossroads), Should ChatGPT Be In Law School?
8. Paul Caron (Dean, Pepperdine), The Law Schools Most Impacted By The Methodology Changes In The 2024 U.S. News Rankings
9. Paul Caron (Dean, Pepperdine), The Impact Of The U.S. News Law School Rankings Boycott On Peer Reputation
10. U.S. News & World Report Specialty Rankings:

• Business/Corporate Law Rankings
• Clinical Training Rankings
• Constitutional Law Rankings
• Contracts/Commercial Law Rankings
• Criminal Law Rankings

Tax:

1. Bryan Camp (Texas Tech), Lesson From The Tax Court: Allocating Between Excludable Child Support and Includable Interest
2. Wall Street Journal, IRS Weighs Creating A Government-Run Tax-Prep Option; Americans Don't Want It
3. U.S. News & World Report, 2024 Tax Rankings
4. NYU Law News, Over 50+ Years, The NYU Tax VAP Program Has Launched Dozens Of Tax Prof Careers
5. Bryan Camp (Texas Tech), Lesson From The Tax Court: Exclusion Rules For Disability Payments
6. Jay Soled (Rutgers) & Kathleen DeLaney Thomas (North Carolina), AI, Taxation, and Valuation
7. Ruth Mason (Virginia), Legal Problems With Digital Taxes In The United States And Europe
8. SSRN, The Top Five New Tax Papers
9. Blaine Saito (Northeastern), Review Of Automated Agencies, By Joshua Blank (UC-Irvine) & Leigh Osofsky (North Carolina)
10. Roundup, Tax Policy In The Biden Administration

Faith: 

1. Tim Keller: Growing My Faith In The Face Of Death

The Borrower's Dilemma And A Tax-Based Solution To The Student Debt Problem

Kate Souza (J.D. 2022, UC-San Francisco), Note, How Can I Ever Repay You? The Borrower’s Dilemma and a Tax-Based Solution to the Student Debt Problem, 73 Hastings L.J. 129 (2022):

The growing cost of higher education relative to wage growth means that college is no longer the sure path to financial security it once was. While the cost of tuition ballooned over the past several decades, government funding for higher education diminished. Students have made up the difference by borrowing more. For many borrowers, large student loans result in unmanageable debt that makes their financial futures less secure. Student debt also harms society and the economy. If the government wants Americans to continue to have access to higher education, it must find ways to make higher education more affordable

Politicians recognize the problems posed by the current historic levels of student loan debt. They recently proposed to cancel large swaths of student loan debt. However, debt cancellation is not a good solution. It is expensive, unfair, and offers mere temporary relief from a problem that will continue to plague future borrowers. A better solution would offer lasting relief

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Weekly SSRN Tax Article Review And Roundup: Saito Reviews Automated Agencies By Blank & Osofsky

This week, Blaine Saito (Northeastern; Google Scholar) reviews a new work by Joshua D. Blank (UC-Irvine; Google Scholar) & Leigh Osofsky (North Carolina; Google Scholar), Automated Agencies, 107 Minn. L. Rev. 2114 (2023). 

A lot of the news these days are around the rise of AI like ChatGPT. But already, we have weaker forms of virtual assistants. These days, I can often “chat” with an airline’s chatbot when my flight is delayed. Federal agencies, like the IRS, have implemented similar tools to present people with user friendly answers to their questions. But in their new article, Automated Agencies, 104 Minn. L. Rev. 2115 (2023), Joshua D. Blank and Leigh Osofsky raise some concerns. Building on their work on Simplexity, a term the authors coined for government pronouncements to the general public that tend to oversimplify the actual underlying complicated and nuanced law, they note that automated legal guidance tools may actually exacerbate the problems of Simplexity to a frightening extent. And often agency officials are unaware of these problems.

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Narotzki Posts Five Tax Papers On SSRN

Doron Narotzki (Akron; Google Scholar) has posted five tax papers on SSRN:

Tax Implications of Contributing Appreciated Property Overseas, 179 Tax Notes Fed. 431 (April 17, 2023) (with Tamir Shanan (College of Management)): 

In this article, Narotzki and Shanan examine the application of section 367 to section 351 exchanges and the income inclusion issues that may arise upon a U.S. person’s contribution of property to a foreign entity. 

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Winners Of The 22nd Annual Law Student Tax Challenge

ABA Tax Section, Winners Of The 22nd Annual Law Student Tax Challenge:

J.D. Division 

1st Place: 

Tracy Costanzo and Amanda Hepinger
Syracuse University College of Law

2nd Place and Best Written: 

Ivan Rudd and Isaac Fuhrman Borgman
University of Miami School of Law

3rd Place: 

Justin Sung and Judd Baguioro 
University of California College of the Law, San Francisco

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Hemel Presents The Realization Doctrine And The Optimal Taxation Of Capital Income Today At The OMG Transatlantic Tax Talks

Daniel Hemel (NYU; Google Scholar) presents The Realization Doctrine and the Optimal Taxation of Capital Income (with Dhammika Dharmapala (Chicago; Google Scholar)) at the OMG Transatlantic Tax Talks Series (OMG = Oxford-Michigan-MIT-Munich-Georgetown) today: 

The realization requirement—a common feature of real-world capital income tax systems—defers the taxation of gains until the sale or other disposition of assets. As implemented, it generally imposes effective capital income tax rates that decline over a taxpayer’s holding period. Scholars of tax law and public finance have long appreciated that the realization requirement generates a deferral benefit and an associated allocative inefficiency (the “lock-in effect”). However, they have largely overlooked the relationship between realization and the optimal taxation of capital over the lifecycle. In this paper, we connect the realization requirement to canonical results in the optimal tax literature—in particular, the Atkinson-Stiglitz argument for the nontaxation of retirement savings and the Diamond-Mirrlees argument for high tax rates on savings withdrawn in midlife. First, we reconcile these results in a simple three-period framework with stochastic skill shocks in the middle period, demonstrating that the optimal tax rate on savings withdrawn in the middle period is high while the optimal tax rate on savings withdrawn in the final period is zero. We next show how the realization requirement partially implements the optimal age-dependent capital income tax schedule. 

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Foster: Reckoning With Tax Risk

William E. Foster (Arkansas; Google Scholar), Reckoning with Tax Risk, 42 Va. Tax Rev. 473 (2023):

Whether a business is engaging in a major transaction or simply conducting day-to-day operations, it must address tax questions and take positions based on available authority and its appetite for risk. With enough research, most tax questions are answerable at a high level of comfort, but many are not. This article looks at how businesses deal with the latter scenario. 

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Senate Hearing: The Rich Get Richer, Deficits Get Bigger — How Tax Cuts For The Wealthy And Corporations Drive The National Debt

The Senate Budget Committee held a hearing yesterday on The Rich Get Richer, Deficits Get Bigger: How Tax Cuts for the Wealthy and Corporations Drive the National Debt (video):

• Bruce Bartlett (Former Deputy Assistant Secretary, U.S. Treasury), Testimony
• Scott Hodge (Tax Foundation), Testimony
• Samantha Jacoby (Center on Budget and Policy Priorities), After Decades of Costly, Regressive, and Ineffective Tax Cuts, a New Course Is Needed 
• Bobby Kogan (Center for American Progress), Testimony
• Adam Michel (Cato Institute), Protecting American Families from Higher Taxes

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