Taxation & Estate Planning

Call for Papers: Global Conference on Environmental Taxation

Posted on June 17, 2010
The 11th Global Conference on Environmental Taxation on Using Environmental Taxation Strategies to Support Climate Change Resilience to be held November 3-5, 2010, in Bangkok, Thailand, has issued a call for papers: Abstracts of papers should be submitted by June 21, 2010, on the conference website...

Brunson: Taxing Investment Fund Managers Using a Simplified Mark-to-Market Approach

Posted on June 17, 2010
Samuel D. Brunson (Loyola-Chicago) has published Taxing Investment Fund Managers Using a Simplified Mark-to-Market Approach, 45 Wake Forest L. Rev. 79 (2010). Here is the abstract: For several years, a debate has swirled around the taxation of hedge fund managers? compensation...

The Senate's Vote to Eliminate the Deduction for Punitive Damages

Posted on June 17, 2010
The Senate voted yesterday to pay for a 90-day extension of the home buyer's tax credit by adopting the Obama Administration's proposal to eliminate the deduction for punitive damages. Linda Beale (Wayne State) applauds the move. In their forthcoming article, Taxing Punitive Damages, 96 Va...

W&L Colloquium on the Business Activity Tax Simplification Act

Posted on June 16, 2010
The Washington & Lee Law Review has published a Student Notes Colloquium on the Business Activity Tax Simplification Act: Quinn T. Ryan (J.D. 2010, Washington & Lee), Beyond BATSA: Getting Serious About State Corporate Tax Reform, 67 Wash. & Lee L. Rev...

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Infanti: The Legal Landscape for Pennsylvania Same-Sex Couples

Posted on June 16, 2010
Anthony C. Infanti (Pittsburgh) has published Surveying the Legal Landscape for Pennsylvania Same-Sex Couples, 71 U. Pitt. L. Rev. 187 (2009). Here is the abstract: Recently, national attention has been riveted on California and Connecticut. In those states, same-sex couples who could already obtain legal recognition for their relationships by...

Tamanaha: Wake Up, Law Professors, to the Failure of the Law School Model

Posted on June 16, 2010
Brian Tamanaha (Washington University), Wake Up, Fellow Law Professors, to the Casualties of Our Enterprise: It?s grim reading. The observations are raw, bitter, and filled with despair. It is easier to avert our eyes and carry on with our pursuits. But please, take a few moments and force yourself to...

69 Law School Deans Support Kagan Nomination

Posted on June 16, 2010
The White House yesterday released this letter signed by 69 law school deans supporting Elena Kagan's Supreme Court nomination: We are writing in support of Solicitor General Elena Kagan?s nomination to become an Associate Justice of the United States Supreme Court...

More on Tax Court Decision Permitting Nurse to Deduct University of Phoenix MBA

Posted on June 16, 2010
Following up on my prior posts: Tax Court Allows Nurse to Deduct Cost of University of Phoenix MBA (Dec. 3, 2009) WSJ: Decision May Open Floodgates on Deductibility of M.B.A. Expenses (Jan. 11, 2010) Nurse Wins Favorable Ruling on Deducting MBA Educational Expenses, CPA Journal, June 2010, at 56: Lori...

Cincinnati Landmark Struck by Lightning

Posted on June 16, 2010

Oregon Attorney Convicted of Tax Fraud After Filing $1 Trillion Lien Against IRS

Posted on June 16, 2010
WebCPA, Couple Convicted in Tax Shelter Scheme: A married couple was convicted of running an elaborate tax shelter scheme for over a decade in which they marketed tax trusts to clients, filed lawsuits against IRS employees, and prepared a $108 million tax lien against former Treasury Secretary John Snow...

Cooper: Ghosts of 1932 -- The Lost History of Estate and Gift Taxation

Posted on June 16, 2010
Jeffrey A. Cooper (Quinnipiac) has published Ghosts of 1932: The Lost History of Estate and Gift Taxation, 9 Fla Tax Rev. 875 (2010). Here is the abstract: In 1932, the United States confronted a bleak economic landscape. Amid the financial carnage caused by the 1929 stock market crash and the...

Textron: Tax Cases Make Bad Work Product Law

Posted on June 16, 2010
Jacob A. Kling (J.D. 2010, Yale) has published Comment, Tax Cases Make Bad Work Product Law: The Discoverability of Litigation Risk Assessments After United States v. Textron, 119 Yale L.J. 1715 (2010). Here is the Conclusion: The decision in Textron denies work product protection to litigation risk analyses prepared for...

Nijenhuis: Tax Issues in Financial Derivatives Reform

Posted on June 16, 2010
Erika W. Nijenhuis (Cleary Gottlieb Steen & Hamilton, New York) has posted New Tax Issues Arising From Derivatives Regulatory Reform, 127 Tax Notes 1235 (June 14, 2010), on SSRN. Here is the abstract: This article examines an array of new tax questions that have arisen, or are about to arise,...

Tax Law Review Publishes Wealth Transfer Taxation Symposium

Posted on June 15, 2010
The Tax Law Review has published a Symposium on Wealth Transfer Taxation (Vol. 63, No. 1): Foreword, 63 Tax L. Rev. vii (2009) Lily L. Batchelder (NYU), What Should Society Expect From Heirs? The Case for a Comprehensive Inheritance Tax, 63 Tax L. Rev...

Powell: Tax and Islamic Jurisprudence

Posted on June 15, 2010
Russell Powell (Seattle) has published Zakat: Drawing Insights for Legal Theory and Economic Policy from Islamic Jurisprudence, 7 Pitt. Tax Rev. 43 (2009). Here is the abstract: The rapid development of complex income taxation and welfare systems in the 20th century may give the impression that progressive wealth redistribution systems...

House Holds Hearing Today on Mututal Fund Tax Simplification

Posted on June 15, 2010
The Select Revenue Measures Subcommittee of the House Ways and Means Committee holds a hearing today on Tax Simplification Proposals Impacting Regulated Investment Companies: H.R. 4337 was introduced late last year as the "Regulated Investment Company Modernization Act of 2009...

Tax Alliance Conference Begins Today in Texas

Posted on June 15, 2010
The three-day Tax Alliance Conference 2010 kicks off today in Plano, Texas. See the list speakers and their topics.

Tribute to Regis Campfield

Posted on June 15, 2010
The SMU Law Review has published a tribute to Regis Campfield upon his retirement after 32 years on the faculty (63 SMU L. Rev. 3-14 (2010)): John Attanasio, Tribute for Regis Campfield, 63 SMU L. Rev. 3 (2010) Charles O. Galvin, Tribute to Regis W. Campfield, 63 SMU L...

AALS Call for Presentations: Gender and Tax

Posted on June 15, 2010
The AALS Planning Committee for the 2011 Mid-Year Workshop on Women Rethinking Equality has issed a Call for Presentations, Papers and Posters: We are seeking proposals for presentations, papers and posters for the 2011 Mid-Year Meeting Workshop on Women Rethinking Equality...

Crawford & Gans: Estate & Gift Tax Treatment of Copyright Termination Rights

Posted on June 15, 2010
Bridget J. Crawford (Pace) & Mitchell Gans (Hofstra) have published Sticky Copyrights: Discriminatory Tax Restraints on the Transfer of Intellectual Property, 66 Wash. & Lee L. Rev. 25 (2010). Here is the abstract: The focus of this article is the federal estate and gift tax treatment of copyright termination rights...

BC Dean John Garvey Named President of Catholic University

Posted on June 15, 2010
Boston College Law School Dean (and former AALS President) John H. Garvey has been named President of Catholic University, effective July 1, 2010. From the Washington Post: Garvey, dean of the Boston College Law School since 1999, will replace David M...

Coder: Living With GAAR

Posted on June 15, 2010
Jeremiah Coder (Contributing Editor, Tax Analysts), Living With GAAR Lite?, 127 Tax Notes 1187 (June 14, 2010): Following codification of the economic substance doctrine earlier this year, practitioners and government officials have debated just how extensively the new statutory provision applies the common-law test to tax planning...

Tax Profs Take Charge at Boston College

Posted on June 15, 2010
Following up on this morning's post, BC Dean John Garvey Named President of Catholic University -- Boston College Law School is in capable hands, as newly-minted Associate Deans of Academic Affairs (and Tax Profs) James R. Repetti (left) and Diane Ring (right) mind the store, pending the appointment of an...

Transocean: Better at Tax Planning Than Oil Drilling

Posted on June 14, 2010
Martin A. Sullivan (Tax Analysts), Oil Drillers Gain Billions From 'Immoral' Tax Break, 127 Tax Notes 1183 (June 14, 2010): There is something else not working well in the gulf: the tax system. No, we are not talking about those cash-only Cajun-country fishermen who never pay income tax and now...

Call for Papers: Pittsburgh Tax Review

Posted on June 14, 2010
The Pittsburgh Tax Review has issued a call for papers: The Pittsburgh Tax Review invites submissions from faculty, judges, and practitioners for inclusion in a syrnposium issue on Pennsylvania tax reform. Papers should explore aspects of the Pennsylvania state and/or local tax systems and suggest potential reforms or improvements...

McMahon: The Codified Economic Substance Doctrine and an 'Angel List'

Posted on June 14, 2010
Martin J. McMahon, Jr. (Florida) has posted Living with (and Dying by) the Codified Economic Substance Doctrine on SSRN. Here is the abstract: This article examines recently enacted § 7701(o), codifying clarifications to the judicial economic substance doctrine, and the associated new strict liability penalty regime applicable to transactions that...

A Tale of Two Faculties: Rutgers, Florida

Posted on June 14, 2010
Chronicle of Higher Education, Rutgers U. Cancels Raises and Freezes Pay, Citing 'Extreme Fiscal Crisis': Rutgers University announced on Thursday that it will cancel scheduled pay raises and freeze salaries across the board to deal with an "extreme fiscal crisis" brought on by state budget cuts, according to news reports...

TaxProf Blog Weekend Roundup

Posted on June 14, 2010
Saturday: 5th Annual Junior Tax Scholars' Workshop Concludes Today at Notre Dame Pennsylvania?s Inheritance Tax Pennsylvania's Taxpayer Relief Act Sunday: Top 5 Tax Paper Downloads ABA Podcast: Law School Tuition Structured Settlements and Single-Claimant Qualified Settlement Funds

New IRS-Mandated Disclosure of FMV of University Presidents' Housing

Posted on June 14, 2010
The Boston Globe, Light Shed on Housing for College Presidents; New IRS Guidelines Require Estimate on Compensation Deals: For the first time, the IRS this year is requiring private colleges and universities and other nonprofits to factor in the value of certain nontaxable perks ? such as the estimated fair-market...

Faculty Karaoke

Posted on June 14, 2010
The Benefits of Karaoke for Lawyers (The Legal Intelligencer): I always thought karaoke was lame and I never, ever, ever, ever, ever believed I would write a column about karaoke, let alone about karaoke and the law. ... I always rejected karaoke and begged off of events featuring amateur singing...

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