Taxation & Estate Planning

Deans' Leadership in Legal Education Symposium

Posted on June 02, 2009
The University of Toledo Law Review has published the ninth annual issue in its wonderful Deans' Leadership in Legal Education Series. Each issue contains essays written by Deans of various law schools on a wide array of legal education topics. The current issue contains fifteen essays written by these deans:...

Santa Clara to Host Women and the Law Stories Conference

Posted on June 02, 2009
Santa Clara is hosting a Women and the Law Stories Conference on The Power of Women?s Stories II: Examining Women?s Role in Law and the Legal System on April 16, 2010 in connection with the forthcoming publication of Women and the Law Stories, part of the Law Stories Series (for...

TPC Hosts Forum Today on Is There a Fair Way to Cap the Tax Exclusion of Employer-Sponsored Health Insurance?

Posted on June 02, 2009
The Tax Policy Center hosts a forum today on Is There a Fair Way to Cap the Tax Exclusion of Employer-Sponsored Health Insurance?: Health reform, the ?let?s do lunch? of public policy, is on everyone?s lips in Washington. But -- often the big question after long-postponed, obligatory meals -- who...

New World Tax Journal

Posted on June 02, 2009
The International Bureau of Fiscal Documentation has launched World Tax Journal, a new, peer-reviewed tax journal: The objective of the WTJ is to meet the perceived need of the international research community for a scientific journal in the area of international, comparative and regional (e...

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Goodwin: How the Rich Stay Rich: Using a Family Trust Company to Secure a Family Fortune

Posted on June 02, 2009
Iris J. Goodwin (Tennessee) has posted How the Rich Stay Rich: Using a Family Trust Company to Secure a Family Fortune on SSRN. Here is the abstract: This Article is about family trust companies and the role they play in preserving great fortunes. A family trust company is a corporation...

Today's En Banc 1st Circuit Oral Argument in Textron Tax Accrual Work Papers Case

Posted on June 02, 2009
The audio of today's oral argument before the en banc First Circuit in United States v. Textron, No. 07-2631, is available here. For prior TaxProf Blog coverage, see: Ventry: A Primer on Tax Work Product for Federal Courts (5/19/09) 1st Circuit Orders Rehearing En Banc in Textron Tax Accrual Work...

AIG Tries to Claw Back Contributions to Hank Greenberg's Foreign Foundation

Posted on June 02, 2009
Lloyd H. Mayer (Notre Dame) has some fascinating posts on AIG's attempt to claw back $490 million from former chairman Hank Greenberg's Swiss Foundation, including a response from AIG: AIG Tries to Claim $490 Million from Former Chairman's Swiss Foundation AIG Responds to Story About Former CEO's Swiss Foundation

Tax Law Review Publishes Symposium on Corporate Tax Policy in the EU

Posted on June 01, 2009
The Tax Law Review has published a Symposium on Corporate Tax Policy in the European Union: Walter Hellerstein, Georg Kofler & Ruth Mason, Constitutional Restraints on Corporate Tax Integration in the EU and the U.S., 62 Tax L. Rev. 1 (2008) Commentary: Pasquale Pistone, Taxation of Cross-Border Dividends in Europe:...

Illinois Bends Admissions Standards to Admit Politically Connected

Posted on June 01, 2009
Chicago Tribune, U. of I. Admissions: How politicians Pressured University to Admit Students: State Sen. Chris Lauzen believed a student deserved admission to the University of Illinois law school in 2005, and he let the university's lobbyists know. The school's dean thought otherwise...

NLJ: Recession Slows Plans for 8 of 11 New Law Schools

Posted on June 01, 2009
In this week's National Law Journal: Recession Crimps Plans for New Law Schools, by Amanda Bronstad: Chalk up the latest victims of the recession: new law schools. A slowdown in contributions, coupled with state budget cuts, has clipped the wings of fledging institutions nationwide...

Death of Dick Loengard

Posted on June 01, 2009
I am sorry to bring you new of the death on Sunday of Richard O. Loengard, Jr., the former head of Fried Frank's tax department. He was 77 years old. Dick joined Fried Frank in 1956 after graduating from Harvard Law School. He became a tax partner in 1967, and...

TaxProf Blog Weekend Roundup

Posted on June 01, 2009
Saturday: Galle Presents Hidden Taxes Today at Stanford/Yale Junior Faculty Forum Law, Society & Taxation Panel #13: Tax Policy Law, Society & Taxation Panel #12: Tax Agreements Law, Society & Taxation Panel #11: Tax-Exempt Organizations McMahon Presents Putting the "Community" in Community Property Today at Law & Society Sunday: NY...

Tax Court Video

Posted on June 01, 2009
The Tax Court has released an eight-part video series, An Introduction to the United States Tax Court: Welcome & Overview Part One: Understanding the Process Part Two: Introduction to the United States Tax Court Part Three: Filing the Petition Part Four: Pretrial Matters Part Five: Calendar Call and Trial Part...

Polsky & Hellwig: Taxing Structured Settlements

Posted on June 01, 2009
Gregg D. Polsky (Florida State) & Brant J. Hellwig (South Carolina) have posted Taxing Structured Settlements, 50 B.C. L. Rev. ___ (2009), on SSRN. Here is the abstract: Congress has granted a tax subsidy to physically injured tort plaintiffs who enter into structured settlements...

Accounting Program Rankings

Posted on June 01, 2009
Joshua G. Coyne, Scott L. Summers, Brady Williams & David A. Wood (all of BYU, School of Accountancy) have posted Accounting Program Research Rankings by Topical Area and Methodology on SSRN. Here is the abstract: Recognizing the diversity of accounting research, this paper provides separate rankings of accounting research programs...

Burke& McCouch: Carlisle -- A "Hollow Victory"

Posted on June 01, 2009
Karen C. Burke (San Diego) & Grayson M.P. McCouch (San Diego) have posted Carlisle: A "Hollow Victory" on SSRN. Here is the abstract: Arthur Andersen LLP v. Carlisle [No. 08?146, May 4, 2009)] is the first investor suit involving a failed Son-of-BOSS tax shelter to reach the Supreme Court...

Law, Society & Taxation Panel #14: Designing Taxes to Change Behavior

Posted on May 31, 2009
Today's fourteenth Law, Society, and Taxation panel at the Law & Society Association Annual Meeting in Denver is on Designing Taxes to Change Behavior: Taxes can be used to change specific behavior as well as to raise revenue. The scholars on this panel will discuss the uses of tax policy...

SOI Releases Spring 2009 SOI Bulletin

Posted on May 31, 2009
The IRS's Statistics of Income Division has released the Spring 2009 SOI Bulletin with these six articles: High-Income Tax Returns for 2006, by Justin Bryan Individual Foreign-Earned Income and Foreign Tax Credit, 2006, by Scott Hollenbeck & Maureen Keenan Kahr International Boycott Reports, 2005 and 2006, by Melissa Costa U...

NY Times: Will BOA Deal Usher in New "Synthetic Consolidation" Tax Shelter?

Posted on May 31, 2009
New York Times: A Shelter That Could Start a Stampede, by Gretchen Morgenson: If the Treasury is ever to replenish its coffers, increased tax receipts will be sorely needed. But these inflows could be reduced if an unusual tax-avoidance transaction ? set up to allow losses at one company to...

Top 5 Tax Paper Downloads

Posted on May 31, 2009
There is a lot of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with a new #1 paper and new papers debuting on the list at #4 and #5: 1. [234 Downloads]: Measuring Rates of Return for Lobbying Expenditures: An Empirical Analysis Under the American...

Law, Society & Taxation Panel #12: Tax Agreements

Posted on May 30, 2009
Today's twelfth Law, Society, and Taxation panel at the Law & Society Association Annual Meeting in Denver is on Agreements, Negotiation, and Tax Laws: The scholars on this panel will discuss the impact of agreements large and small on the tax systems and economic welfare of nations, discussing agreements from...

Law, Society & Taxation Panel #11: Tax-Exempt Organizations

Posted on May 30, 2009
Today's eleventh Law, Society, and Taxation panel at the Law & Society Association Annual Meeting in Denver is on Charity and Nonprofit Organizations: Exemption from taxation for nonprofit organizations is a cornerstone of the tax system in the United States...

McMahon Presents Putting the "Community" in Community Property at Law & Society

Posted on May 30, 2009
My colleague Stephanie McMahon (Cincinnati) presents California Women: Putting the "Community" in Community Property today at the Gender and Justice in Courts and Families panel at the Law & Society Association Annual Meeting in Denver: Community property is currently thought of as a more equitable marital property regime than the...

Galle Presents Hidden Taxes Today at Stanford/Yale Junior Faculty Forum

Posted on May 30, 2009
Brian D. Galle (Florida State) presents Hidden Taxes, 86 Wash. U. L. Rev. ___ (2009), today at the 2009 Stanford/Yale Junior Faculty Forum at Stanford. Here is the abstract: The idea of hidden taxes is as old as John Stuart Mill, but convincing evidence of their existence is new...

Law, Society & Taxation Panel #13: Tax Policy

Posted on May 30, 2009
Today's thirteenth Law, Society, and Taxation panel at the Law & Society Association Annual Meeting in Denver is on Thinking Big About Tax Policy: While much tax policy analysis deals with narrow issues of doctrine and statutory interpretation, this panel will address issues of much broader political and social consequence...

Law, Society & Taxation Panel #8: Business Tax

Posted on May 29, 2009
Today's eighth Law, Society, and Taxation panel at the Law & Society Association Annual Meeting in Denver is on The Thrills and Chills of Business Taxation: Like all acquired tastes, scholarship in the area of business taxation is all the more satisfying as we learn to savor the nuances...

Law, Society & Taxation Panel #7: Normative Analyses of Tax Doctrines

Posted on May 29, 2009
Today's seventh Law, Society, and Taxation panel at the Law & Society Association Annual Meeting in Denver is on Normative Analyses of Tax Doctrines: What constitutes an unacceptable tax position? Scholars on this panel will discuss the general problem of tax shelters, some doctrines to fix it, and some specific...

Law, Society & Taxation Panel #6: Tax Rules and Social Outcomes

Posted on May 29, 2009
Today's sixth Law, Society, and Taxation panel at the Law & Society Association Annual Meeting in Denver is on Tax Rules and Social Outcomes: Several classic doctrines in tax law respond to recurring problems in the lives of taxpayers. Interactions between accidents, insurance, unexpected reversals, and tax consequences have created...

Court Rejects G-I Holdings' Request to Reopen Case to Hear Congressional Staff Testimony on Meaning of Transition Rule

Posted on May 29, 2009
I previously blogged the taxpayer's attempt to have the district court reconsider its decision in In re G-I Holdings, Inc., 369 B.R. 832 (D.N.J. 2007), based on affidavits to be supplied by Senate Finance Committee staffers on the meaning of a tax transition rule: Can Congressional Staff Testify on Meaning...

Law, Society & Taxation Panel #10: Tax Expenditures

Posted on May 29, 2009
Today's tenth Law, Society, and Taxation panel at the Law & Society Association Annual Meeting in Denver is on Conferring Valuable Social Benefits through the Tax System: The government can spend money directly on an activity, or it can indirectly subsidize an activity by giving advantageous tax treatment to those...

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