Taxation & Estate Planning

Dees: Profits Interests Gifts Under § 2701

Posted on May 17, 2009
Richard L. Dees (McDermott, Will & Emery, Chicago) has posted Profits Interests Gifts Under Section 2701: "I Am Not a Monster", 123 Tax Notes 707 (May 11, 2009), on SSRN. Here is the abstract: Section 2701 provides special gift tax...

CTJ Report: President Obama's Tax Proposals

Posted on May 16, 2009
Citizens for Tax Justice has published President Obama?s Proposals to Raise Revenue: On May 11, the Treasury Department released new details on President Obama?s proposed changes to the tax code. In addition to extending the Bush tax cuts for all...

The State and Local Tax Contributions Made by Undocumented Immigrants

Posted on May 16, 2009
Jacqueline Wolfert (J.D. 2009, Pittsburgh) has published Note, Reality vs. Rhetoric: Lozano v. Hazleton and the State and Local Tax Contributions Made by Undocumented Immigrants, 6 Pitt. Tax Rev. 83 (2008). Here is part of the Conclusion: The recent controversy...

OECD: High Taxes Make People Happy

Posted on May 16, 2009
MarketWatch: The Happiest Taxes on Earth: More People Are Satisfied in Heavily Tariffed Nations, by Thomas Kostigen: The Organization for Economic Cooperation and Development says people in Denmark, Finland and the Netherlands are the most content with their lives...

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5th Circuit: BLIPS Tax Shelter Lacks Economic Substance

Posted on May 16, 2009
The Fifth Circuit yesterday decided the issue it had reserved in Compaq Computer Corp. v. Commissioner, 277 F.3d 778 (5th Cir. 2001) -- the contours of the economic substance doctrine -- in the contect of a BLIPS (Bond Linked Issue...

113 Law School Commencement Speakers

Posted on May 15, 2009
Akron: Betty Sutton (Member, U.S. House of Representatives) Alabama: Richard Shelby (Member, U.S. Senate) Albany: Jonathan Lippman (Chief Judge. New York Court of Appeals) American: Seth Waxman (Partner, Wilmer Hale) Arkansas-Fayetteville: William Sutton (Partner, Friday, Eldredge & Clark) Ave Maria:...

Is Obama Ineligible to Work for the IRS?

Posted on May 15, 2009
From President Obama's Arizona State commencement address (at the 3:10 mark): President Crowe and the Board of Regents will soon learn all about being audited by the IRS See Pub. L. No. 105-206, § 1203, 112 Stat. 685 (1998); Boris...

John Marshall Hosts Conference Today on Ethics of Tax Law Practice

Posted on May 15, 2009
The John Marshall Law School Center for Tax Law and Employee Benefits hosts the Second Annual Institute on the Ethics of Tax Law Practice, co-sponsored by the ABA Tax Section. Here are the speakers and their topics: Myriad Judgment Calls:...

Kelly: Tax Foreclosure and Due Process in the Internet Age

Posted on May 15, 2009
James J. Kelly Jr. (Baltimore) has published Bringing Clarity to Title Clearing: Tax Foreclosure and Due Process in the Internet Age, 77 U. Cin. L. Rev. 63 (2008). Here is the abstract: The foreclosure of property tax liens performs an...

Holcomb: Taxing Commuters

Posted on May 15, 2009
Morgan Holcomb (Minnesota) has published Tax My Ride: Taxing Commuters in Our National Economy, 8 Fla. Tax Rev. 885 (2008). Here is the abstract: States constitutionally impose individual income taxes on two bases: (1) Residency: a state of residence can...

The "Chutes and Ladders" of the U.S. News Law School Rankings

Posted on May 15, 2009
Check out the Bitter Lawyer's take on the 2010 U.S. News Law School Rankings (featuring, among others, Tax Prof (and "rankings guru") Ted Seto (Loyola-L.A.)):

Challenging Gender Inequality in Tax Policy Making

Posted on May 15, 2009
The two-day workshop on Challenging Gender Inequality in Tax Policy Making sponsored by the International Institute for the Sociology of Law concludes today in Oņati, Spain: Panel 5 ? Labour Markets and Saving Choices Moderator: Lisa Philipps Taxation of the...

IRS Initiates Law Student Internship Program

Posted on May 15, 2009
National Law Journal: IRS Division Initiates Internship Program for Law Students: The IRS's employee plans division, which handles review of employee pension plans, is hiring two law student interns for the first time this summer and may expand the program...

Philippon: Financiers v. Engineers: Should the Financial Sector Be Taxed or Subsidized?

Posted on May 15, 2009
Thomas Philippon (NYU) has posted Financiers v. Engineers: Should the Financial Sector Be Taxed or Subsidized? on SSRN. Here is the abstract: I study the allocation of human capital in an economy with production externalities, financial constraints and career choices...

Tax Panels at Today's ALEA Annual Meeting

Posted on May 15, 2009
The two-day American Law and Economics Association Annual Meeting kicks off today at the University of San Diego School of Law. Here is today's tax-releated panel: Behavioral Public Finance: Panel Chair: Dhammika Dharmapala (Illinois) Brian Galle (Florida State), Do Hidden...

9th Circuit Reverses Tax Court: TP Can Recover Attorneys' Fees Advanced by Third Party

Posted on May 14, 2009
In a 2006 case, the Tax Court denied a taxpayer's attorneys' fees request under § 7430 on the ground that the taxpayer had not "paid or incurred" the fees because they were advanced by his employer. Morrison v. Commissioner, T.C....

Feldstein: Obama's Tax Increases Could Kill the Recovery

Posted on May 14, 2009
Wall Street Journal op-ed: Tax Increases Could Kill the Recovery, by Martin Feldstein (Harvard University, Department of Economics): The barrage of tax increases proposed in President Barack Obama's budget could, if enacted by Congress, kill any chance of an early...

This Won't Help Arizona State in the U.S. News Rankings

Posted on May 14, 2009
The Daily Show With Jon Stewart M - Th 11p / 10c Arizona State Snubs Obama thedailyshow.com Daily Show Full Episodes Economic Crisis Political Humor

Negotiating Your Law Review Publishing Agreement

Posted on May 14, 2009
My friend and colleague Tim Armstrong gave a great talk to our faculty yesterday on An Introduction to Publication Agreements for Authors. He provides some great advice for negotiating the publication agreement with law reviews and book publishers in his...

HeinOnline Releases Archive of Tax Materials (1781-2009)

Posted on May 14, 2009
HeinOnline has announced a new online resource, Taxation & Economic Reform in America, A Historical Archive, 1781-2009: This library will allow researchers for the first time to search across tax regulations, laws, and hundreds of legislative histories dating back to...

Turn Off Your Cell Phone

Posted on May 14, 2009

Bank Secrecy, Tax Havens and International Tax Competition

Posted on May 14, 2009
The Tax Foundation has published a 12-page special report, Bank Secrecy, Tax Havens and International Tax Competition, by Robert Carroll: Carroll acknowledges the need to target tax evasion, as the proposal does, but he argues that ending tax deferral is...

Hawaii Becomes Fifth State to Impose Special Income Tax Rate on "The Rich" -- 11% Rate Is Highest in Country

Posted on May 14, 2009
The Tax Foundation reports that Hawaii is the fifth state to adopt new income tax brackets on the "rich," and now imposes the highest marginal income tax rate in the country: 11% Hawaii: 11% on > $200,000 income California: 10.55%...

Challenging Gender Inequality in Tax Policy Making Workshop

Posted on May 14, 2009
The two-day workshop on Challenging Gender Inequality in Tax Policy Making sponsored by the International Institute for the Sociology of Law kicks off today in Oņati, Spain: Panel 1 ? Tax Reform and Fundamental Theories Moderator: Lisa Philipps Challenging Gender...

CB&PP: Raise Taxes to Combat State Revenue Shortfalls

Posted on May 14, 2009
Following up on yesterday's post: State Tax Revenues Fall 12.6%: the Center on Budget and Policy Priorities says in a new 10-page report that the answer is to raise taxes: Raising taxes reflects sound policy judgment. Tax increases can be...

Is the Recession Sucking the Joy Out of Faculty Life?

Posted on May 14, 2009
Inside Higher Ed: Next Budget Victim? Joy: Step away from that copy machine, and don?t even think about serving lunch at that next faculty meeting. Oh, and that class you love with 20 students? Double it. On second thought, couldn?t...

Gerzog: Negron and the 2-2 Circuit Split on Lottery Payments

Posted on May 13, 2009
Wendy C. Gerzog (Baltimore) has posted Negron: Circuits Now Split 2-2, 123 Tax Notes 767 (May 11, 2009), on SSRN. Here is the abstract: The article discusses Negron [v. United States, 553 F.3d 1013 (6th Cir. 2009),] and the circuit...

Top Universities Cut Their Ph.D. Programs

Posted on May 13, 2009
Inside Higher Ed reports today that many top universities -- Chicago, Columbia, Emory, Harvard, MIT, Northwestern, Princeton -- are shrinking their Ph.D. programs because of economic pressures: [T]he shifts could be significant, as they involve doctoral programs that are influential...

Georgetown Tax Conference

Posted on May 13, 2009
The 32nd Annual Advanced State & Local Tax Institute and the 5th Annual Symposium on Sourcing the Operations & Transaction of Multijurisdictional Enterprises: A Guide for Tax Planning, Compliance, Policy Making & Enforcement Professionals kick off today at Georgetown...

Kovach: A 1963 Perspective on the Tax Gap

Posted on May 13, 2009
Richard J. Kovach (Akron) has published Taxes, Loopholes and Morals Revisited: A 1963 Perspective on the Tax Gap, 30 Whittier L. Rev. 247 (2008). Here is the Introduction: Jerome R. Hellerstein was a professor of law at NYU who specialized...

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