Paul L. Caron
Dean




Friday, May 27, 2022

Weekly SSRN Tax Article Review And Roundup: Kim Reviews Dean's The Casual Racism Of The Tax Law

This week, Young Ran (Christine) Kim (Utah, moving to Cardozo; Google Scholar) reviews a new work by Steven A. Dean (Brooklyn), Filing While Black: The Casual Racism of the Tax Law, 2022 Utah L. Rev. __.

Kim

In response to a growing recognition of the absence of demographic data in federal datasets, including tax data, President Biden signed Executive Order 13985 in 2021, which, inter alia, established an Interagency Working Group on Equitable Data. The Treasury Department is also undertaking a comprehensive research initiative to study the relationship between the U.S. tax code and racial inequities. Senate Finance Committee Chair Ron Wyden (D-OR) has called for the IRS to collect and disclose more information relating to the tax code’s effect on different demographics because it makes no sense to blind lawmakers to the key data that would illuminate injustice in our tax laws. Those recent developments are the results of hard work by dedicated scholars like Alice Abreu, Jeremy Bearer-Friend, Dorothy Brown, Wei Cui, Steven Dean, Francine Lipman, and Goldburn Maynard. In this review, I would like to recognize Steven Dean's recent essay, Filing While Black: The Casual Racism of the Tax Law, 2022 Utah L. Rev. ___. Dean's essay is adapted from his testimony given before the Committee on Ways and Means of the U.S. House of Representatives on June 10, 2021, and was presented at the 2021 Utah Law Review Symposium, entitled #includetheirstories: Rethinking, Reimagining, and Reshaping Legal Education, for which I was an organizer. (Video clips are available here.)

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May 27, 2022 in Christine Kim, Scholarship, Tax, Tax Scholarship, Weekly SSRN Roundup, Weekly Tax Roundup | Permalink

Tax Policy In The Biden Administration

Avi-Yonah Posts International Tax Papers On SSRN

Thursday, May 26, 2022

No New Tax Cuts? Examining The Rescue Plan's New State Tax Limits

Conor Clarke (DOJ; Google Scholar) & Edward G. Fox (Michigan; Google Scholar), No New Tax Cuts? Examining the Rescue Plan's New State Tax Limits, 103 Tax Notes St. 1361 (Mar. 28, 2022):

Tax-notes-stateIn this article, Clarke and Fox examine the American Rescue Plan Act’s restrictions on state tax cuts, arguing that the restrictions are a variation on more familiar maintenance-of-effort provisions. These provisions are common, and are designed to help ensure that federal grants supplement rather than supplant state spending by requiring the state to maintain its level of spending on a program. Clarke and Fox conclude that the Rescue Plan’s requirements create similar incentives, and argue that the similarity makes it more likely that the act’s tax provisions are consonant with the Constitution’s spending clause.

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May 26, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Cooper: Section 2058 And The Decline Of State Death Taxes

Jeffrey A. Cooper (Quinnipiac; Google Scholar), Death by Deduction: Section 2058 and the Decline of State Death Taxes, 48 ACTEC L.J. __ (2023):

This article illustrates how, and seeks to explain why, the deduction for state estate taxes (Internal Revenue Code Section 2058) seems to have had no meaningful effect on state tax policy.

Since the deduction for state estate taxes reduces the amount of federal estate taxes paid, the net effect is to shift to the federal government some of the cost of these state death taxes. Prevailing theories of tax policy suggest that state governments will structure their tax systems to maximize this type of available deduction. But theory has not borne out in practice. To the contrary, most states have responded to enactment of Section 2058 not by restructuring their existing state estate taxes to maximize this federal deduction but rather by entirely abandoning state estate taxes. While a remaining group continue to impose those taxes, they have failed to structure those taxes in a manner that would optimize the deduction. In short, the 2058 deduction seems to have had extremely little, or perhaps entirely no, effect on state estate tax policy.

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May 26, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

SSRN Tax Professor Rankings

SSRN Logo (2018)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, 2022) 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)  208,581 1 Reuven Avi-Yonah (Michigan) 8,882
2 Daniel Hemel (Chicago) 125,410 2 Daniel Hemel (Chicago) 5,468
3 Dan Shaviro (NYU) 124,776 3 Bridget Crawford (Pace) 4,128
4 Lily Batchelder (NYU) 124,345 4 Lily Batchelder (NYU) 2,986
5 David Gamage (Indiana-Bloom.) 121,615 5 D. Dharmapala (Chicago) 2,930
6 Darien Shanske (UC-Davis) 114,651 6 Ruth Mason (Virginia) 2,808
7 David Kamin (NYU) 111,916 7 David Gamage (Indiana-Bloom.) 2,733
8 Cliff Fleming (BYU)    106,965 8 Kim Clausing (UCLA)     2,727
9 Manoj Viswanathan (UC-Hastings) 103,722 9 Zachary Liscow (Yale) 2,667
10 Rebecca Kysar (Fordham) 102,810 10 Darien Shanske (UC-Davis) 2,655
11 Ari Glogower (Ohio State) 102,491 11 Kyle Rozema (Washington University) 2,625
12 D. Dharmapala (Chicago) 47,270 12 David Kamin (NYU) 2,623
13 Michael Simkovic (USC) 46,688 13 Robert Sitkoff (Harvard) 2,590
14 Paul Caron (Pepperdine) 39,472 14 Richard Ainsworth (Boston Univ.) 2,584
15 Louis Kaplow (Harvard) 36,790 15 Dan Shaviro (NYU) 2,008
16 Richard Ainsworth (Boston Univ.) 34,965 16 Margaret Ryznar (Indiana-Indy)   2,000
17 Bridget Crawford (Pace) 31,815 17 Louis Kaplow (Harvard) 1,735
18 Robert Sitkoff (Harvard) 28,956 18 Ari Glogower (Ohio State) 1,711
19 Ed Kleinbard (USC) 28,526 19 Brad Borden (Brooklyn) 1,658
20 Vic Fleischer (UC-Irvine) 28,431 20 Francine Lipman (UNLV) 1,609
21 Brad Borden (Brooklyn) 27,961 21 Hugh Ault (Boston College) 1,558
22 Jim Hines (Michigan) 26,573 22 Vic Fleischer (UC-Irvine) 1,512
23 Ruth Mason (Virginia) 26,272 22 Gregg Polsky (Georgia) 1,435
24 Ted Seto (Loyola-L.A.) 25,559 24 Michael Simkovic (USC) 1,313
25 Katie Pratt (Loyola-L.A.) 25,408 25 Omri Marian (UC-Irvine) 1,246

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May 26, 2022 in Legal Education, Tax, Tax Prof Rankings | Permalink

Wednesday, May 25, 2022

8th Annual Mid-Career Tax Professors Workshop At North Carolina

UNC Law School Logo

Tuesday, May 24:

Panel #1:

Ari Glogower (Ohio State; Google Scholar), Means-Adjusted Tax Rules
Commentator:  Philip Hackney (Pittsburgh)

Susan Morse (Texas; Google Scholar), APA Statute of Limitations
Commentator:  Clint Wallace (South Carolina)

Andrew Hayashi (Virginia; Google Scholar), Income Tax Enforcement & Redistribution: A Survey
Commentator:  Shu-Yi Oei (Boston College; Google Scholar

Brian Galle (Georgetown; Google Scholar), Solving the Valuation Challenge: A Feasible Method for Taxing Extreme Wealth (with David Gamage (Indiana-Maurer; Google Scholar) & Darien Shanske (UC-Davis; Google Scholar))
Commentator:  Andrew Hayashi (Virginia; Google Scholar)

Panel #2:

Yariv Brauner (Florida; Google Scholar), What Should Developing Countries do about the Recent Global Minimum Tax "Agreement"?
Commentator:  Young Ran (Christine) Kim (Utah, moving to Cardozo; Google Scholar)

Shuyi Oei (Boston College; Google Scholar), What Determines Treaty Favorability to Developing Countries?
Commentator: Susan Morse (Texas; Google Scholar)

Doron Narotzki (Akron; Google Scholar), Tax Planning and Pillar Two
Commentator: Yariv Brauner (Florida; Google Scholar)

Panel #3:

Jordan Barry (USC), Tax & the Boundaries of the Firm (with Victor Fleischer (UC-Irvine; Google Scholar))
Commentator: Doron Narotzki (Akron; Google Scholar)

Manoj Viswanathan (UC-Hastings), Hybrid Tax Bases & the Constitution
Commentator: Ari Glogower (Ohio State; Google Scholar)

Emily Cauble (DePaul), Testing Intuitions About Partnership Tax Intuitions
Commentator: Leigh Osofsky (North Carolina; Google Scholar)

Panel #4:

Stephanie Hoffer (Indiana-McKinney; Google Scholar), Language of Disability in the Tax Code
Commentator: Kathleen DeLaney Thomas (North Carolina; Google Scholar)

Kathleen DeLaney Thomas (North Carolina; Google Scholar), Fake News & the Tax Law
Commentator: Emily Cauble (DePaul)

Leigh Osofsky (North Carolina; Google Scholar), Implicit Leg Bias & the HMID
Commentator: David Gamage (Indiana-Maurer; Google Scholar)

Wednesday, May 25:

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May 25, 2022 in Conferences, Scholarship, Tax, Tax Conferences, Tax Scholarship | Permalink

CIC Services: The Supreme Court Hands The IRS A Major Loss

Beckett Cantley (Northeastern) & Geoffrey Dietrich (Cantley Dietrich), CIC Services v. IRS: the Supreme Court Hands the IRS a Major Loss, 5 Bus. Entrepreneurship & Tax L. Rev. __ (2021):

The Anti-Injunction Act (“AIA”) is an important part of administrative procedure law and a crucial piece of the United States tax system. Enacted to help expedite the tax revenue process, the Act works to invalidate any lawsuit to restrict the assessment or collection of taxes. Nonetheless, having the power to bar standing and having the right to do so are two completely different things. For instance, while the AIA gives the power to bar suits brought against administrative rulemaking processes, the Act does not give this right unless the suit was brought with the purpose of restraining the assessment of a tax.

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May 25, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Google's Cost Sharing Arrangement: Bride Of Frankenstein

Stephen Curtis (Cross Border Analytics), Google's Cost Sharing Arrangement: Bride of Frankenstein:

Google (2022)This paper performs a forensic analysis of Google's transfer pricing cost sharing arrangement based on forensic economic analysis of public information, including tax litigation in France, tax hearings conducted in the United Kingdom, information from a related U.S. tax court case, documents disclosed in a European data privacy investigation, published materials containing insider accounts of Google’s operations, books, periodicals and other sources. The paper finds that Google appears to have violated U.S. transfer pricing laws in 2009 and later years, in ways that appear to have invalidated its cost sharing arrangement but which were not detected by the IRS. These tax violations appear to have led to the potential of tax assessments by the IRS of more than $38 billion and up to $50 billion. Google is now a subsidiary of Alphabet Inc., and the company's reserves for Uncertain Tax Positions were $3.8 billion as of December 31, 2020 – reserves that are about 90% less than this tax adjustment risk. The ability of the IRS to apply periodic adjustments is not limited by any statute of limitations.

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May 25, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Tuesday, May 24, 2022

Saito: Tax Allyship

Blaine G. Saito (Northeastern; Google Scholar), Tax Allyship, 1 LSU L.J. for Soc. Just. & Pol'y 49 (2022):

Tax has a race problem. The tax system’s traditional color-blind approach only ossifies our existing structures of racial hierarchy. The solution, then, is to abandon the color-blind approach and introduce reform to explicitly help combat the inequities in wealth and income that fall along racial lines. 

This essay calls on young lawyers and racial-justice activists to pressure the tax field—scholars, legislators, practitioners, and judges—to do better. I hope, especially, to inspire law students to consider taking tax courses and becoming tax lawyers with an eye toward promoting racial justice both within and outside the field.

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May 24, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Spivack: The Happy Families Of Tax Law

Carla Spivack (Oklahoma City), The Happy Families of Tax Law, 100 N.C. L. Rev. 601 (2022): 

This Article points to the difference between the treatment of wealthy families and poor families who apply for tax benefits and argues that the same treatment should apply to both. I show that tax breaks for the wealthy and benefits for the poor are both government expenditures that deplete the public fisc; indeed, some have called tax benefits for the rich “hidden” or “submerged” forms of welfare. Yet, as I discuss, the law treats wealthy applicants for tax breaks quite differently from the way it treats poor people applying for similar benefits. The wealthy receive tax breaks based on assumptions about their family dynamics, without any inquiry into the dynamics in a particular family. By contrast, poor people applying for benefits face scrutiny of their intimate lives, relationships, and spaces to establish eligibility. In essence, this Article argues that what’s sauce for the goose is sauce for the gander.

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May 24, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

San Diego Law School Names Paul Yong Director Of Graduate Tax Programs

Paul Yong Named Director of Graduate Tax Programs and a Professor of Practice at San Diego

Unnamed (1)University of San Diego (USD) School of Law is pleased to announce that Paul Yong will join the School of Law as the new Director of Graduate Tax Programs and a Professor of Practice as of June 2022. The USD School of Law Tax program has been consistently ranked a top Tax Program by U.S. News.

As the Director, Yong will provide strategic leadership for the law school graduate tax programs. He will also oversee the LLM in Tax and other tax education programs and conferences designed to complement the School of Law's Juris Doctor program.

In addition to his new role at the School of Law, Yong remains Vice President, Chief Tax Counsel for Sempra Energy. He is an innovative, results-oriented tax executive with over 30 years of experience with Sempra Energy, Arthur Anderson, and Unocal Corporation. Yong will be a Professor of Practice for the law school, and developed the School of Law Tax Planning Lab, a unique "hands-on" simulation course. He enjoys mentoring students and preparing them to be practice-ready from day one in their tax careers.

"Paul Yong is going to be an inspirational and a strong leader for the graduate Tax Program. He will be an exceptional mentor for our students and brings a practitioner's perspective to the role coupled with great enthusiasm for teaching," said Miranda Fleischer, Professor of Law and outgoing Director of Graduate Tax programs.

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May 24, 2022 in Legal Education, Tax | Permalink

Monday, May 23, 2022

Is Bitcoin Prudent? Is Art Diversified? Offering Alternative Investments To 401(k) Participants

Edward Zelinsky (Cardozo), Is Bitcoin Prudent? Is Art Diversified? Offering Alternative Investments to 401(k) Participants, 54 Conn. L. Rev. 509 (2022):

Whether 401(k) plans’ investment menus should feature “alternative” investments is a fact-driven inquiry applying ERISA’s fiduciary standards of prudence, loyalty, and diversification. Central to this fact-driven inquiry is whether the alternative investment class in question is broadly accepted by investors in general and by professional defined benefit trustees in particular. A similarly salient concern when making this inquiry is the financial unsophistication of many, perhaps most, 401(k) participants. Accounting for these considerations, this Article concludes that REITs, private equity funds, and hedge funds can, with limits, today be offered as investment choices to 401(k) participants, but that cryptocurrencies (including Bitcoin), art, and environmental-social-governance (ESG) funds cannot. These latter investment categories have yet to achieve acceptance among professional defined benefit trustees and thus are not yet prudent to offer to 401(k) participants—if they ever will be. 

This Article explores each of these five categories as a class. Even if 401(k) participants should be offered choices within any (or all) of these classes of alternative investments, particular investments within each class must still be scrutinized individually for their compliance with ERISA’s fiduciary standards. The threshold, fact-intensive question that this Article addresses is whether, before considering specific investments, any generic category of alternative investments ought to be considered for the menu of choices offered to 401(k) participants. 

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May 23, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

GAO: Lack Of Data Limits Research On Tax Equity

GAO, Tax Equity: Lack of Data Limits Ability to Analyze Effects of Tax Policies on Households by Demographic Characteristics:

GAO (2022)The U.S. has a large and increasing gap in income and wealth by race, ethnicity, and sex. However, little is known about the effects of tax policies across demographic characteristics. The tax code does not tax individuals differentially based on certain demographics. However, some researchers have noted how it could result in potential unintended disparate tax outcomes. 

The CARES Act includes a provision for GAO to report on its ongoing COVID-19 monitoring and oversight efforts. GAO was also asked to review how selected tax policies affected households by race, ethnicity, and sex as part of this oversight.

This report (1) examines approaches for analyzing the effect of tax policies, including some in the CARES Act and related legislation, on households by race, ethnicity, and sex, and (2) estimates how households use selected tax provisions by race, ethnicity, and sex. 

May 23, 2022 in Gov't Reports, IRS News, Tax | Permalink

Lesson From The Tax Court: Counting The Days

Most people know that the IRS generally has three years to audit a return. Calculating the proper three-year period, however, requires close attention to both the start date and the end date.  You need to count those days properly.  I tried to drill into my students the practice of always consulting a calendar when attempting to calculate the proper dates.  Christian Renee Evert v. Commissioner, T.C. Memo. 2022-48 (May 9, 2022) (Judge Marshall), reinforces that teaching: to calculate the period in which the IRS can assess a tax, you need to properly count the days in the three year period.

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May 23, 2022 in Bryan Camp, New Cases, Scholarship, Tax, Tax Practice And Procedure, Tax Scholarship | Permalink | Comments (1)

TaxProf Blog Weekend Roundup

Sunday, May 22, 2022

Tax Experts Say Section 107 Housing Allowance For Clergy Remains Safe Despite Recent Cases And Greedy Abuses

Christianity Today, Churches Still Depend on Clergy Housing Allowance:

Despite recent legal cases and reports of greedy abuses, experts say the longstanding benefit remains safe.

Wth the federal tax filing deadline looming, a Virginia court case may have some ministers wondering whether their ministerial housing allowance is secure.

The case isn’t about the housing allowance. But to some, including Supreme Court Justice Neil Gorsuch, it suggests courts may be willing to meddle increasingly in clergy affairs, including housing.

At issue was denial of a property tax exemption for a church parsonage in Fredericksburg, Virginia. New Life in Christ Church sought the tax exemption for a church-owned home inhabited by two youth ministers, married couple Josh and Anacari Storms. The city denied the exemption because it claimed the church’s denomination, the Presbyterian Church in America (PCA), does not allow women to be considered ministers.

New Life in Christ said the city misunderstood its doctrine. Ordination and certain duties, like preaching, are limited to men in the PCA, according to the church, but the denomination’s governing documents permit congregations latitude in hiring nonordained persons like the Stormses for various ministry jobs. Yet a trial court sided with Fredericksburg, as did the Virginia Supreme Court.

The US Supreme Court declined to hear the church’s appeal in January. Now the church must continue paying the annual property tax bill of $4,589.15. The Supreme Court’s action provoked a dissent from Gorsuch.

“The City continues to insist that a church’s religious rules are ‘subject to verification’ by government officials,” Gorsuch wrote. “I would grant the [church’s] petition and summarily reverse. The First Amendment does not permit bureaucrats or judges to ‘subject’ religious beliefs ‘to verification.’”

Is the case a harbinger of increased willingness to scrutinize ministerial housing in court? Pastors across America hope not. While fewer churches own traditional parsonages, the majority take advantage of the federal clergy housing allowance and say it benefits both their families and their churches. ...

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May 22, 2022 in Faith, New Cases, Tax, Tax News | Permalink

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 paper debuting on the list at #5:

  1. SSRN Logo (2018) [521 Downloads]  How Treasury and the IRS Have Allowed High-Net-Worth Taxpayers to Exploit Stepped-Up Basis on Intergenerational Wealth Transfers, and How They Can Stop It: Answers to Question for the Record, by Daniel Hemel (Chicago; moving to NYU; Google Scholar)
  2. [397 Downloads]  Taxing Robots, by Rita de la Feria (Leeds; Google Scholar) & Maria Amparo Grau Ruiz (Universidad Complutense de Madrid; Google Scholar)
  3. [370 Downloads]  A Matter of High Interest: How a Quiet Change to an Actuarial Assumption Turbocharges the Life Insurance Tax Shelter, by Andrew Granato (J.D.|Ph.D., Yale; Google Scholar)
  4. [358 Downloads]  Permanent Establishment and Fixed Establishment in the Context of the Subsidiary and the Digital Economy, by Stoycho Dulevski (University of National and World Economy; Google Scholar)
  5. [320 Downloads]  Where Nonprofits Incorporate and Why It Matters, by Peter Molk (Florida; Google Scholar)

May 22, 2022 in Scholarship, Tax, Tax Scholarship, Top 5 Downloads | Permalink

Saturday, May 21, 2022

This Week's Ten Most Popular TaxProf Blog Posts

GAO: IRS Audit Rates Plummet For The Rich

GAO, Tax Compliance: IRS Audit Trends for Individual Taxpayers Vary by Income:

From tax years 2010 to 2019, audit rates of individual tax returns decreased for all income levels. On average, individual tax returns were audited over three times more often for tax year 2010 (about 0.9 percent) than for tax year 2019 (0.25 percent). Audit rates for taxpayers with incomes of $200,000 and above decreased the most, largely because higher-income audits tend to be more complicated and require auditors to manually review multiple issues, according to IRS officials. Because audit staffing has decreased, IRS cannot conduct as many of these audits, compared to lower-income audits, which are generally less complex and involve more automated processes. In addition, IRS officials stated that the number of returns filed by higher-income populations is growing, meaning more audits are needed to achieve the same audit rate.

Although audit rates decreased the most for higher-income taxpayers during this time period, IRS continued to audit higher-income taxpayers at higher rates than lower-income taxpayers, in general. However, IRS audited taxpayers claiming the Earned Income Tax Credit (EITC) at a higher rate than average (see fig. 1, using tax year 2019 as an example). IRS officials explained that EITC audits are limited in scope and historically have high rates of improper payments and therefore require a greater enforcement presence.

GAO 2

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May 21, 2022 in Tax, Tax News | Permalink

Friday, May 20, 2022

Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews AI, Taxation, And Valuation By Soled And Thomas

This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews Jay Soled (Rutgers; Google Scholar) & Kathleen DeLaney Thomas (North Carolina; Google Scholar), AI, Taxation, and Valuation, 108 Iowa L. Rev. __ (2023).

Mirit-Cohen (2018)

Artificial intelligence (AI) is improving our lives by utilizing technology and machine learning to accomplish tasks that require considerable human labor. It can deliver similar and often better outcomes in a cost-effective manner. I have written here that calculative actions do not require much creativity thus are the most obvious fields in which machines are superior to humans. It is very fitting to ask, then, how can AI improve tax enforcement and compliance? Valuation is one of the most calculative and arduous areas in tax administration that automation can greatly improve. 

Valuation often requires many efforts determining fair market value (FMV) when there is no willing buyer and seller that negotiate the asset’s purchase price. Because of the essential role that asset valuations play in determining tax liabilities, there is a high sensitivity by the IRS and taxpayers to their accuracy. Transactions between related parties or not at arm’s length such as transfer of bequests, nonfungible real estate, or closely held business interests present complex valuation issues as there is no clear FMV. Congress uses a traditional carrot-and-stick approach to valuation by encouraging taxpayers to comply through clarifying and simplifying reporting obligations, along with imposing penalties for misstating the value of assets.

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May 20, 2022 in Scholarship, Tax, Tax Scholarship, Weekly SSRN Roundup | Permalink

Tax Policy In The Biden Administration

Tax Now Or Tax Never: Political Optionality And The Case For Current-Assessment Tax Reform

David Gamage (Indiana-Maurer; Google Scholar) & John R. Brooks (Georgetown; moving to Fordham; Google Scholar), Tax Now or Tax Never: Political Optionality and the Case for Current-Assessment Tax Reform, 100 N.C. L. Rev. 487 (2022):

The U.S. income tax system is broken. Due to the realization doctrine and taxpayers’ consequent ability to defer taxation of gains, taxpayers can easily minimize or avoid the taxation of investment income, a failure that is magnified many times over when considering the ultra-wealthy. As a result, this small group of taxpayers commands an enormous share of national wealth yet pays paltry taxes relative to the economic income their wealth produces—a predicament that this Article condemns as being economically, politically, and socially harmful. 

The conventional view among tax law experts has assumed that the problems created by the realization doctrine can be fixed on the back end by adjusting the rules that govern taxation at the time of realization. Specifically, most tax scholars have favored reform proposals that would retain the realization doctrine while aiming to impose taxes in a way that would erase or reduce the financial benefits of deferral. Examples include retrospective capital gains tax reforms, progressive consumption tax reforms, and more incremental reforms such as ending stepped-up basis. 

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May 20, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Thursday, May 19, 2022

Raskolnikov Presents Should Only The Richest Pay More? Today At The OMG Transatlantic Tax Talks

Alex Raskolnikov (Columbia) presents Should Only the Richest Pay More? today as part of the OMG Transatlantic Tax Talks Series (OMG = Oxford-Michigan-MIT-Munich-Georgetown):

Alex_raskolnikov_0This paper challenges the leading academic, political, and cultural narrative supporting greater redistribution. This narrative holds that redistribution should come at the expense of the very restricted group of the highest earners: the one percent, the super-rich, the billionaire class. I argue that the very 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, economic mobility, government capture, political polarization, or the rise of populism, the affluent are as great or greater contributors to these problems as those in the top one percent. Remarkably, the contemporary U.S. legal and economic scholarship has ignored the affluent almost completely, greatly limiting the magnitude of possible economic transfers as well the form that these transfers may take.

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May 19, 2022 in Scholarship, Tax, Tax Scholarship, Tax Workshops | Permalink

Who Gives A Trump? Evidence Of Framing Effects In Tax Policy

Mark McKnight (Southern Indiana; Google Scholar), Curtis Price (Southern Indiana; Google Scholar), Andrew Dill (Southern Indiana), Timothy Bryan (Marshall; Google Scholar) & Brett Bueltel (Southern Indiana; Google Scholar), Who Gives a Trump? Evidence of Framing Effects in Tax Policy, 23 J. Acct., Ethics & Pub. Pol'y 149 (2022):

We use a framed survey to measure how associating the name “Trump” with the Tax Cuts and Jobs Act (TCJA) affects people’s satisfaction of said Act. Our research included 72 participant clients from a Volunteer Income Tax Assistants (VITA) program, who were asked to provide baseline data regarding political affiliation and attitudes prior to having tax returns completed. We find that using the name “Trump” with people who self-identify as Republican results in more satisfaction with the Act, whereas, for people with who do not self-identify as Republican, association with the name “Trump” does not precipitate stronger or weaker satisfaction with the Act.

Trump

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May 19, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Wednesday, May 18, 2022

Innovations In IPO Deal Structure: Do Up-C IPOs Harm Public Shareholders?

Mary Brooke Billings (NYU), Kevin Hsueh (NYU), Melissa F. Lewis-Western (BYU; Google Scholar) & Gladriel Shobe (BYU; Google Scholar), Innovations in IPO Deal Structure: Do Up-C IPOs Harm Public Shareholders? (additional write-up here):

This paper examines an innovation in capital formation that has spurred contentious debate: the Umbrella Partnership Corporation (“Up-C”) IPO. Advisors and underwriters argue that the Up-C deal structure is a driver of post-IPO value and, thus, is a value-enhancing means of raising capital that may be one solution to concerns regarding the drop in the number of publicly traded companies. Consistent with these claims, recent research suggests that organizing soon-to-be public businesses as pass-through entities (as is the case for UpCs) leads to superior future performance. Yet, broadening the analysis to consider abnormal stock performance and post-IPO litigation of a larger and more recent sample of exclusively Up-C IPOs, we conclude just the opposite. While the Up-C deal structure increases IPO valuations and predicts positive post-IPO operating performance, the return performance of Up-C IPOs indicates that Up-C deals harm public shareholders.

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May 18, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Soled & Morris: The Strange And Curious Tax Treatment Of Investment Expenses

Jay A. Soled (Rutgers; Google Scholar) & Mallory A. Morris (Dechert), The Strange And Curious Tax Treatment Of Investment Expenses, 67 Vill. L. Rev. 101 (2022):

To secure income, taxpayers often incur a wide range of expenses. At least theoretically, one might think that the Internal Revenue Code (“Code”) would accord all such expenses similar tax treatment, but (i) trade or business expenses and (ii) investment expenses endure the exact opposite tax treatment: the former are generally allowed, whereas the latter are commonly disallowed. The obvious question is why there is a difference in treatment between the two.

This Article explores possible answers to that important question. It first traces the evolution of the Code’s dichotomous tax treatment of trade or business versus investment expenses. It then investigates possible justifications and their associated merits for the different handling of these two expense categories. 

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May 18, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Using The Internal Revenue Code To Limit Coaching Salaries: A Proposal To Bring Amateurism Back Into College Football

Blaire Mikesell (J.D. 2022, Indiana-Maurer), Note, Using the Internal Revenue Code to Limit Coaching Salaries: A Proposal to Bring Amateurism Back into College Football, 97 Ind. L.J. 393 (2022):

Since formal collegiate athletic competitions began in 1852, they have gained popularity and become a mainstay in American culture. This rise in popularity coupled with increased media coverage allowed college athletics, and particularly college football, to grow into a successful business that generates billions of dollars in revenue each year. Colleges and institutions earn this athletic revenue as tax-free income due to their tax-exempt status under the Internal Revenue Code § 501(c)(3) tax-exemption statute. The basic policy underlying this statute is as follows: colleges and universities provide an important benefit to the public by providing education, and in exchange for that provided benefit, the IRS does not tax educationally related income. Currently, income generated by college athletics is educationally related and thus is earned under the tax-exempt status of the university.

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May 18, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Tuesday, May 17, 2022

A Half-Century With The Internal Revenue Code: The Memoirs Of Stanley Surrey

A Half-Century with the Internal Revenue Code: The Memoirs of Stanley S. Surrey (Lawrence Zelenak (Duke) & Ajay Mehrotra (Northwestern; Google Scholar) eds. Carolina Academic Press 2022):

SurreyStanley S. Surrey was the most prominent mid-twentieth-century American tax law academic, and the federal government official with the greatest influence on tax policy over that same period (aside from politicians). His professional life with the federal tax system spanned half a century, ending only with his death at the age of 73 in 1984. As Surrey writes in his memoirs, he had good reason to "doubt that any person alive today has had as close and as varied a relationship with the Internal Revenue Code as I have had."

He divided the five decades of his professional life between academia (three early years at the University of California, Berkeley, followed by many years at Harvard Law School), and two lengthy tours of duty in the service of the U.S. Treasury Department. In his second Treasury stint he served as the Assistant Secretary of the Treasury for Tax Policy, the highest executive branch position exclusively focused on taxation. Surrey's influence on the federal tax system was deep and pervasive and continues to this day; perhaps his most enduring accomplishment has been his development of tax expenditure analysis, which since the 1970s has played a central role in a wide range of tax policy discussions.

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May 17, 2022 in Book Club, Scholarship, Tax, Tax Scholarship | Permalink

Socialism, Progressive Taxation, And The Fiscal State

Sol Picciotto (ICTD, Lancaster, London; Google Scholar), Socialism, Progressive Taxation, and the Fiscal State:

This paper traces the philosophical, political, sociological and economic underpinning for the advocacy by socialists of progressive taxation, from the Communist Manifesto to recent supporters of tax justice campaigns. Socialists’ attitudes to taxation have been tied to their primary aim of socialisation of the ownership of the means of production, reflecting the view that inequality and exploitation are inherent in capitalism, which rests on private property enforced by state power. Communism, as developed particularly by Marx and Engels, aimed to transcend capitalism and end the separation of the state from civil society, by the socialisation of property, including through progressive taxation. Marx’s view in Capital volume 3 that the emergence of large scale enterprises already entailed the ‘abolition of capital as private property within the framework of capitalist production itself’, when it was published in 1894 became central to the debates among German socialists (Liebknecht, Kautsky, Bernstein and Luxemburg), and the Austro-Marxists (Renner, Hilferding), but socialists split when graduated direct taxes were introduced to help fund the welfare-warfare state. Goldscheid’s outline for a social science of the state centred on fiscality underpinned his radical and influential wartime proposals to finance the socialisation of large corporations through taxes on capital.

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May 17, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Colella: Crispino Upholds IRS Mailbox Rule Reg

Frank G. Colella (Pace), ‘But I Mailed It’ — Crispino Upholds IRS Mailbox Rule Regulation, 173 Tax Notes Fed. 1479 (Dec. 13, 2021):

Tax Notes Federal (2020)In Crispino, the U.S. District Court for the District of New Jersey held that taxpayers cannot introduce extrinsic evidence under the common law mailbox rule to establish timely filing of their claim for refund and, accordingly, dismissed the refund action for lack of jurisdiction. Crispino, a decision appealable to the Third Circuit, upheld the IRS’s position that the only means to satisfy section 7502, the statutory “mailbox rule,” is by proper compliance with reg. section 301.7502- 1(e)(2), which requires proof of certified or registered mailing when the IRS alleges that it has not received a document.

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May 17, 2022 in Scholarship, Tax, Tax Analysts, Tax Scholarship | Permalink

Monday, May 16, 2022

Lipman: How To Design An Antiracist State And Local Tax System

Francine Lipman (UNLV; Google Scholar), How to Design An Antiracist State and Local Tax System, 53 Seton Hall L. Rev. ___ (2022):

Since the first ship of enslaved African people landed in Virginia in 1619, racist policies in institutions, systems, structures, practices, and laws have ensured inequity for people of color. These racist policies include every imaginable variant of injustice from slavery to lynching, to segregation, and to economic injustices, including those delivered through tax systems today. Although facially color-blind, tax systems have long empowered the explosion of white wealth and undermined wealth accumulation for Black families and communities of color. State and local tax systems, especially in the South, have deeply-rooted racist fiscal policies, including Jim Crow laws that continue to sustain and bolster racial inequality today. These injustices have become even more obvious during the global pandemic.

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May 16, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Two Tax Court Paid Internship Programs: Diversity, Case Processing

The U.S. Tax Court offers two paid internship programs:  

ABA Tax Section (2021)Diversity in Government Internship Program
The DiG Tax program is separate from the Court’s legal internship program, and you need not be a law student to apply.  DiG Tax interns may assist on projects with departments throughout the Court, including Case Services, Facilities, Finance, Human Resources, Library, Information Technology, and Public Affairs.  For more information, see here.

Case Processing Legal Student Intern

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May 16, 2022 in ABA Tax Section, Legal Education, Tax | Permalink

Lesson From The Tax Court: Only One Exclusion For Military Retiree Disability Payments

Camp (2021)My dad served as a doctor in the military for 30 years, 23 days. Starting this week, he will have been retired for longer than he served. When he first retired, he received a monthly pension check from the Defense Finance and Accounting Service (DFAS) and that was all.  A few years later he learned that his hearing loss, likely from his time in Vietnam, qualified him for disability payments from the Department of Veterans Affairs (VA).  He applied for, and received, a 30% disability rating.  He then started receiving two checks each month, one from DFAS and one from the VA.

My dad’s DFAS check is included in gross income but his VA check is not, thanks to §104(a)(4).  If he had never applied for the disability rating, however, §104 would still permit him to exclude part of his DFAS check to the extent he would have be entitled to a disability check from the VA.  Confused?  Today’s lesson will help! 

In Tracy Renee Valentine v. Commissioner, T.C. Memo. 2022-42 (Apr. 28, 2022) (Judge Gustafson), the taxpayer was a veteran and received two checks per month, one from DFAS and one from VA for disability compensation.  She wanted to exclude not only the VA disability check, but she also wanted to exclude part of her DFAS check.  But she mis-read §104(a)(4)’s interplay with §104(b).  Judge Gustafson teaches us the proper way to read the rules.  Basically, veterans get only one exclusion for their disability payments.  Details below the fold.

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May 16, 2022 in Bryan Camp, New Cases, Scholarship, Tax, Tax Scholarship | Permalink | Comments (1)

TaxProf Blog Weekend Roundup

Sunday, May 15, 2022

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 paper debuting on the list at #4:

  1. SSRN Logo (2018)[940 Downloads]  Amazon and the State Aid Tax Saga, by Leopoldo Parada (Leeds; Google Scholar)
  2. [521 Downloads]  How Treasury and the IRS Have Allowed High-Net-Worth Taxpayers to Exploit Stepped-Up Basis on Intergenerational Wealth Transfers, and How They Can Stop It: Answers to Question for the Record, by Daniel Hemel (Chicago; moving to NYU; Google Scholar)
  3. [385 Downloads]  Taxing Robots, by Rita de la Feria (Leeds; Google Scholar) & Maria Amparo Grau Ruiz (Universidad Complutense de Madrid; Google Scholar)
  4. [350 Downloads]  A Matter of High Interest: How a Quiet Change to an Actuarial Assumption Turbocharges the Life Insurance Tax Shelter, by Andrew Granato (J.D.|Ph.D., Yale; Google Scholar)
  5. [346 Downloads]  Permanent Establishment and Fixed Establishment in the Context of the Subsidiary and the Digital Economy, by Stoycho Dulevski (University of National and World Economy; Google Scholar)

May 15, 2022 in Scholarship, Tax, Tax Scholarship, Top 5 Downloads | Permalink

Saturday, May 14, 2022

This Week's Ten Most Popular TaxProf Blog Posts

Azam: Online Taxation Post Wayfair

Rifat Azam (Radzyner School of Law, Israel; Google Scholar), Online Taxation Post Wayfair, 51 N.M. L. Rev. 116 (2021):

WayfairThe United States Supreme Court saved the states’ sales tax base in the landmark case of South Dakota v. Wayfair in 2018. This revolutionary decision ended the long ban on states imposing sales tax collection duties on out-of-state retailers without a physical presence in the state, as established in Bellas Hess v. Department of Revenue of Illinois in 1967 and Quill Corp. v. North Dakota in 1992. Wayfair now allows states to impose sales taxation on out-of-state retailers in the era of digitalization. In this article, I provide valuable guidelines and suggestions to aid states on this critical journey toward taxing remote online transactions fairly and efficiently.

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May 14, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Friday, May 13, 2022

Tax Policy In The Biden Administration

Next Week’s Tax Workshop

Thursday, May 19: Alex Raskolnikov (Columbia) will present Should Only the Richest Pay More? as part of the OMG Transatlantic Tax Talks Series. This event does not require registration. 

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May 13, 2022 in Legal Education, Scholarship, Tax, Tax Scholarship, Tax Workshops | Permalink

Brookings: Rethinking The Corporate Income Tax — The Role Of Rent Sharing

William G. Gale (Brookings Institution; Google Scholar) & Samuel I. Thorpe (Brookings Institution), Rethinking the Incidence of the Corporate Income Tax:

TPCDebates about corporate income tax cuts follow a familiar script. Republicans claim that rank-and-file workers benefit. Democrats argue that affluent shareholders reap the gains.

In a new project [Rethinking the Corporate Income Tax: The Role of Rent Sharing], we find that, workers do benefit, but it is the most affluent employees — managers and executives — who receive the lion’s share of benefits, not rank-and-file staff.

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May 13, 2022 in Tax, Tax Scholarship, Think Tank Reports | Permalink

Thursday, May 12, 2022

The Tax Lawyer Publishes New Issue

The Tax Lawyer has published Vol. 75, No. 3 (Spring 2022):

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May 12, 2022 in ABA Tax Section, Scholarship, Tax, Tax Scholarship | Permalink

Parsons: Cryptocurrency, Legibility, And Taxation

Amanda Parsons (Academic Fellow, Columbia; moving to Colorado), Cryptocurrency, Legibility, and Taxation:

In Jarrett v. United States, a taxpayer in Tennessee is arguing that staking cryptocurrency did not result in him earning “income” under federal income tax law. This case illustrates the fundamental challenge that cryptocurrency and blockchain technology present for tax law. Wealth creation in the crypto space is not readily legible to the state. This absence of legibility threatens tax law’s reliance on placing economic activities into categories to determine how they should be taxed. Furthermore, this case highlights the harms Congress and Treasury are risking by not taking action on cryptocurrency taxation. The uncertainty and lack of guidance on the appropriate taxation of cryptocurrency is opening the door for a critical juncture in tax law to be decided via strategic litigation. This threatens a jurisprudential evasion of the democratic and administrative process in a high-stakes moment for tax law.

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May 12, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

ABA Tax Section Hybrid 2022 May Meeting

This week's ABA Tax Section hybrid 2022 May Meeting (program) kicks off today. One of the highlight of the meeting is Saturday's luncheon and plenary session:

ABA Tax SectionKeynote Speaker: Lily Batchelder, Assistant Secretary for Tax Policy, U.S. Department of the Treasury
Roundtable: Tax Data Transparency: Changes Coming to a Post-Pandemic Tax Code? On January 20, 2021, President Biden signed Executive Order 13985, which, inter alia, established an Interagency Working Group on Equitable Data prompted by a growing recognition that the absence of demographic data in federal datasets, including tax data, results in inequities across federal programs. In addition, Treasury is undertaking a comprehensive research initiative to study the relationship between the U.S. tax code and racial inequities, in response to research identifying inequities in tax enforcement. Congress, too, is making demands for more transparency in tax data, with Senate Finance Chair Ron Wyden (D-OR) calling for the IRS to “collect and disclose more information relating to the effect of the tax code on different demographics [because] it makes no sense to blind lawmakers to the key data that would illuminate injustice in our tax laws.” This roundtable will provide new insight on the tax policy implications of greater tax data transparency in a post-Pandemic tax code. Discussion will focus on the role of tax data transparency in tax expenditure oversight; the implications of the absence of demographic data on current tax administration and policy; and how tax expenditures included in Pandemic- related legislation have created an opportunities for new data.

Moderator: Caroline Bruckner, Sr. Professorial Lecturer & Managing Director of the Kogod Tax Policy Center, American University Kogod School of Business

Panelists: Steven Dean, Professor of Law, Co-Director of the Dennis J. Block Center for the Study of International Business Law, Brooklyn Law School; Mark Mazur; Danny Yagan

Other Tax Profs with speaking roles include:

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May 12, 2022 in ABA Tax Section, Conferences, Tax | Permalink

Wednesday, May 11, 2022

Brooks: The International Tax System Is There To Achieve Justice

Kim Brooks (Dalhousie University, Schulich School of Law; Google Scholar), The International Tax System Is There to Achieve Justice (JOTWELL) (reviewing Allison Christians (McGill; Google Scholar) & Laurens van Apeldoorn (Open University, the Netherlands), Tax Cooperation in an Unjust World (2021)):

Jotwell (2019)I love everything about this book book, Tax Cooperation in an Unjust World, by Allison Christians and Laurens van Apeldoorn. It’s short, it’s readable, there’s no mystery about the point (and the authors don’t belabour it), and it’s important.

The main claim: our international tax system has justice at its heart. And when we fail to attend to its justice consequences, we enable states with great wealth to “facilitate[] and feed[] off continued human suffering.” (P. 1.)

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May 11, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Wiedenbeck & Stein: The Executive Compensation Threat To Retirement

Peter J. Wiedenbeck (Washington University; Google Scholar) & Norman P. Stein (Drexel), The Executive Compensation Threat to Retirement:

In recent years a new phenomenon has appeared on the retirement savings landscape: the expansion into middle management ranks of a traditional tool of executive compensation, the so-called “top hat” pension plan. Top hat plans are unfunded deferred compensation programs for a “select group of management or highly compensated employees.” Properly structured, top hat plans amass retirement resources that are taxed to employee-participants only when distributed. From the participant’s viewpoint, that delayed inclusion appears comparable to the tax deferral accorded qualified retirement plan savings, yet top hat plans are exempt from all of the Code’s qualification conditions. They are likewise excused from virtually all of ERISA’s pension plan participant protections, including vesting, funding, and fiduciary responsibilities.

This regulatory immunity licenses three interconnected pathologies that undermine core retirement policy objectives. The inapplicability of ERISA’s worker protections, combined with preemption of state law, relegates top hat plan participants to a uniquely precarious position: their retirement savings are more exposed to depredation and vulnerable to loss than if ERISA had never been enacted. The inapplicability of the Code’s qualified plan nondiscrimination requirements allows employers to offer additional retirement savings to highly-paid managerial, technical, and professional employees without having to pay comparable benefits to rank-and-file workers. And the dramatic disparity, post-2017, between income tax rates applicable to corporations and high-income individuals incentivizes that favoritism with a substantial tax subsidy that’s unmeasured and generally overlooked.

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May 11, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Hasen: Interest Deductibility

David Hasen (Florida; Google Scholar), Interest Deductibility:

The proper tax treatment of interest expense has been a subject of disagreement since the inception of the modern income tax in the early twentieth century. On one view, the purpose of the financing transaction dictates the tax treatment of interest so that interest paid on borrowing used to finance consumption should be nondeductible, whereas business interest should be deductible. On another view, interest paid does not finance a consumption item but rather a mere shift in resources and therefore should be deductible at all events, assuming the recipient includes the interest received in income.

Both of these views lead to conundrums that cannot be resolved without considering the broader question of why some expenses are deductible at all. Focusing on that question, it turns out that business interest, like any other business expense, should generally be deductible as a timing or an accounting principle under an income tax. That principle does not apply to personal interest expense. Nevertheless, there may be an independent basis to permit a deduction for personal interest expense that is grounded in considerations of vertical equity.

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May 11, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Tuesday, May 10, 2022

Tax Law Review Publishes New Issue

The Tax Law Review has published a new issue (Vol. 74, No. 2 (Spring 2021)):

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May 10, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

Hasen: Legal Standards And Incomplete Monitoring

David Hasen (Florida; Google Scholar), Legal Standards and Incomplete Monitoring, 30 Res. in L. & Econ. 109 (2022):

Regulators can adjust penalties to compensate for incomplete monitoring of regulated parties that are subject to legal rules, but compensating penalty adjustments often are unavailable when regulated parties are subject to legal standards. Incomplete monitoring consequently invites greater noncompliance under standards than under rules. This chapter develops a model that quantifies some of the specific tradeoffs that regulators face in designing standards regimes under incomplete monitoring. 

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May 10, 2022 in Scholarship, Tax, Tax Scholarship | Permalink

A Critical Review Of Tax The Rich! And The Patriotic Millionaires

Michael Conklin (Angelo State; Google Scholar), We Must Raise Taxes on the Rich: A Critical Review of Tax the Rich! and the Patriotic Millionaires:

Tax the RichAt the 2021 Met Gala, Alexandria Ocasio-Cortez sparked controversy by wearing a “Tax the Rich” dress. Afterward, AOC championed the race of the dress designer and accused her critics of being sexist, while her critics pointed to the irony of such a message at a $30,000-a-ticket event designed to support the interests of the ultra-rich. But these points are largely irrelevant when considering if taxes on the rich should be increased. This is unfortunately also the level of discourse present in the book Tax the Rich! How Lies, Loopholes, and Lobbyists Make the Rich Even Richer. Anyone reading this book in an effort to better understand the arguments for and against raising taxes on the rich will be disappointed, as it largely provides neither. This review critiques the book for selectively omitted information, ignoring incentivization effects, and the appeal to emotion by villainizing the rich. These critiques provide a better understanding of the legitimate arguments for and against raising taxes on the rich and point to potential hypocrisy in groups such as the Patriotic Millionaires.

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May 10, 2022 in Book Club, Scholarship, Tax, Tax Scholarship | Permalink