Taxation & Estate Planning

Death of Alvin Storrs

Posted on April 30, 2010
Tax Prof Alvin Storrs (Michigan State) died Monday, April 26, 2010, after a lengthy illness. From the Michigan State press release: "This is a terrible loss for the Law College," said Joan Howarth, dean of MSU College of Law. "Al Storrs exemplified the highest values of our law school and...

2d Cir.: Rejects Firm's 'Bold Attempt' to Contest IRS Levy

Posted on April 30, 2010
New York Law Journal, 2nd Circuit Rejects Firm's 'Bold Attempt' to Contest IRS Levy: A law firm partner's advances on partnership profits are subject to administrative levies imposed by the IRS, the 2nd U.S. Circuit Court of Appeals ruled Thursday. The circuit found that the advances, or partner "draws," at...

Forbes: Can Tax Court Force IRS to Check Out Whistleblower's Claim?

Posted on April 30, 2010
Forbes, Can IRS Be Forced To Check Out Informant's Tip?: In related lawsuits with broad implications for the new tax whistleblower law, the U.S. Tax Court is set to rule on a bounty-seeking informant's request that the IRS be ordered to investigate his tips...

VanderWolk: Inversions Under § 7874

Posted on April 30, 2010
Jefferson P. VanderWolk (Faculty of Law, Chinese University of Hong Kong) has posted Inversions Under Section 7874 of the Internal Revenue Code: Flawed Legislation, Flawed Guidance, 30 Nw. J. Int'l L. & Bus. ___ (2010), on SSRN. Here is the abstract: The Obama Administration?s international corporate tax proposals would, if...

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Prof. Rotunda's Sexual Harasment Case Against George Mason Goes to Trial in June

Posted on April 30, 2010
Following up on my prior post, Prof. Rotunda Sues George Mason for Sexual Harassment: the Washington Times reports that the case is going to trial in June: An ex-assistant secretary of the Air Force who has become a George Mason University Law School professor has asked a federal court to...

Caron, Kowal, Pratt & Seto: Pursuing a Tax LLM Degree -- Where?

Posted on April 29, 2010
Jennifer M. Kowal (Loyola-L.A.), Katherine Pratt (Loyola-L.A.), Theodore P. Seto (Loyola-L.A.) and I have posted Pursuing a Tax LLM Degree: Where? on SSRN. Here is the abstract: This Article and a related article, Pursuing a Tax LLM Degree: Why and When?, provide information and advice about Tax LLM programs to...

2010 Tannenwald Tax Writing Competition

Posted on April 29, 2010
For students writing tax seminar papers this semester: the Theodore Tannenwald, Jr. Foundation for Excellence in Tax Scholarship and American College of Tax Counsel are sponsoring the 2010 Tannenwald Writing Competition: Named for the late Tax Court Judge Theodore Tannenwald, Jr...

ABA Tax Section Publishes Spring 2010 Issue of News Quarterly

Posted on April 29, 2010
The ABA Tax Section has published 29 News Quarterly No. 3 (Spring 2010): Hot Topics and Current Developments in Circular 230, by Christine L. Weingart (Dean, Mead, Egerton, Bloodworth, Capouano & Bozarth, Orlando, FL), pp. 1, 12-13 Section Meeting Calendar, p...

Hellerstein & Gillis: The VAT in the European Union

Posted on April 29, 2010
Walter Hellerstein (Georgia) & Timothy H. Gillis (KPMG) have published The VAT in the European Union, 127 Tax Notes 461 (Apr. 26, 2010): One of the key issues to be addressed in the United States would be coordinating a federal VAT with state and local retail sales taxes...

Lee: The Role of Danielson in the Taxation of Credit Card Securitizations

Posted on April 29, 2010
Grace Soyon Lee (Alabama) has published What's in a Name?: The Role of Danielson in the Taxation of Credit Card Securitizations, 62 Baylor L. Rev. 110 (2010). Here is the abstract: While the doctrine of substance over form has been a part of tax law for over seventy years, courts...

Wisconsin Hosts Conference Today on The Transnationalization of Tax Lawmaking

Posted on April 29, 2010
Wisconsin hosts a conference today on Networks, Norms, and the Transnationalization of Tax Lawmaking: Panel I: Case Study of Brazil -- Luis Eduardo Schoueri (University of Sao Paulo Law School, Brazil), Andre Mendes Moreira (Milton Campos School of Law, Brazil) Panel II: Case Studies of China and Turkey -- Ruiqing...

WSJ: Dividend Tax to Increase From 15% to 43.4%

Posted on April 29, 2010
Wall Street Journal editorial, The Dividend Tax Bill Arrives: Democrats Would Nearly Triple the Top Rate: As the big tax increase day of January 1, 2011 approaches, the Democrats running Congress are beginning to lay out their priorities. Get ready for bigger rate increases than previously advertised...

Idaho Seeks to Hire a Tax Visitor

Posted on April 29, 2010
The University of Idaho College of Law seeks to hire a tax visitor for the 2010-11 academic year: Anticipated curricular needs include Basic Income Taxation, Business Entities Taxation, Estate Tax and Planning, and Elder Law. ... Interested persons should send a letter of application and resume listing three references to...

New Issue of Journal of Taxation of Investments

Posted on April 29, 2010
The Journal of Taxation of Investments has published its Spring 2010 issue (Vol. 27, No. 3), with these articles: Todd D. Keator, Basis in a Life Insurance Contract: The Janus Face of Revenue Ruling 2009-13, 27 J. Tax'n Inv. 5 (2010) Matthew Gelfand, Pay Now or Pay Later? Capital Gains...

Chronicle: Law School Should Be More Like Medical School

Posted on April 29, 2010
Chronicle of Higher Education, Law Schools Could Take a Hint From Medical Schools on Curriculum Reform, Experts Advise: The nation's legal-education system needs a major overhaul so that students graduating with more than $100,000 in debt can find jobs in a shrinking market and graduate ready to practice...

USA Today: 'Defanged' IRS Won't Be Able to Enforce ObamaCare Insurance Mandate

Posted on April 29, 2010
USA Today, IRS Lacks Clout to Enforce Mandatory Health Insurance, by Sandra Block: The IRS processed more than 230 million tax returns last year, paid 127 million refunds and received about 68 million phone calls. The agency is responsible for enforcing a tax code that, at 71,000 pages, makes Anna...

Students at Private Colleges Get 0.30 Higher GPAs, Improving Their Chances for Law School Admission

Posted on April 28, 2010
Teachers College Record, Grading in American Colleges and Universities GradeInflation.com New York Times Economix, Want a Higher G.P.A.? Go to a Private College The Faculty Lounge, The Advantage of Sending Your Child to a Private College or University The Daily Princetonian, Average GPA Is 3...

Forthcoming Tax Regulations

Posted on April 28, 2010
Here.

The Law School Tuition Bubble

Posted on April 28, 2010
Conglomerate, Minding Our Own Business Forum: Bubbles, Student Loans and Sub-Prime Debt, by Christine Hurt (Illinois) ABA Journal, Law Prof Sees Parallels Between Tuition Hikes and Subprime Mortgage Bubble, by Debra Cassens Weiss Above the Law, The Next Bubble: Law School Tuition, by Elie Mystal Chicago Tribune, Law School Tuition...

Best Law Revue Video

Posted on April 28, 2010
Above the Law is asking readers to vote on the best law revue video from seven law schools. My favorite is from Northwestern:

Florida Tax Review Publishes New Issue

Posted on April 28, 2010
The Florida Tax Review has published Vol. 10, No. 1: John F. Avery Jones (Judge, Upper Tribunal (Tax and Chancery Chamber), UK), Understanding the OECD Model Tax Convention: The Lesson of History, 10 Fla. Tax Rev. 1 (2009) Irene J.J. Burgers (University of Groningen, The Netherlands), The New OECD Approach...

The U.S. News Rankings, Employment Statistics, and Consumer Protection

Posted on April 28, 2010
Consumer Law & Policy Blog, The US News Rankings, Employment Statistics, and Consumer Protection, by Jeff Sovern (St. John's): In ranking law schools, US News takes into account the percentage of students who are employed at graduation and nine months after graduation...

Houston Business & Tax Law Journal Publishes New Issue

Posted on April 28, 2010
The Houston Business & Tax Law Journal has published Vol. 9, Part 2 (2009): Geraldine Szott Moohr, Introduction: Tax Evasion as White Collar Fraud, 9 Hous. Bus. & Tax J. 207 (2009) Stuart P. Green,What Is Wrong with Tax Evasion?, 9 Hous. Bus. & Tax J...

Charlotte Seeks to Hire Associate Dean for Faculty Development

Posted on April 28, 2010
The Charlotte School of Law seeks to hire an Associate Dean for Faculty Development: Primary Duties & Responsibilities: Support and manage faculty recruitment, development, mentoring, retention and promotion; Exemplify and promote excellence in teaching, scholarship, and skills development; develop faculty recognition process which will include both internal and external recognition;...

District Court Rejects Merck's Request for New Trial in $690m Assignment of Future Income Tax Shelter

Posted on April 28, 2010
I previously blogged the district court's rejection of a $690 million assignment of future income tax shelter in Schering-Plough v. United States, 651 F.Supp.2d 219 (D.N.J. 2009). The district court today rejected the taxpayer's motion for a new trial...

Tax Prof Moves, 2010-2011

Posted on April 27, 2010
VAP Hires Anders Christiansen (Deloitte, New York) to Loyola L.A. James Puckett (Alabama VAP) to Seattle (2010-12) Entry Level Hires Jennifer Bird-Pollan (Ropes & Gray, Boston) to Kentucky Susannah Carnic (Skadden, Washington, D.C.) to Wisconsin Elizabeth R...

Professors Without Borders

Posted on April 27, 2010
A group of professors announced on Monday that it has launched a new charity, Professors Beyond Borders, modeled after the highly successful Doctors Without Borders (which won the 1999 Nobel Peace Prize for its humanitarian efforts): Our Mission: Professors Beyond Borders are dedicated to public health and a secure global...

Textron Files Reply Brief in Tax Work Papers Case

Posted on April 27, 2010
I previously blogged the eleven amicus briefs filed in January in the U.S. Supreme Court (No. 09-750), supporting Textron's certiorari petition seeking review of the First Circuit's 3-2 en banc decision in United States v. Textron, Inc., No. 07-2631 (1st Cir...

Chronicle: Faculty, Like Students, Can be Led Astray by Rankings

Posted on April 27, 2010
Chronicle of Higher Education, Academics, Too, Can Be Led Astray by College Rankings, Study Finds, by Peter Schmidt: Prospective students are hardly the only ones who can be overly fixated on college rankings and make poor judgments of the institutions as a result...

More on the 47% Who Pay No Income Tax

Posted on April 27, 2010
Following up on my prior post, More on the 47% Who Pay No Income Tax: Neil H. Buchanan (George Washington), Do Some Americans Pay No Taxes? The Contrived Claims That Everyone Must Help Pay for the Government (FindLaw) Neil H. Buchanan (George Washington), Freeloaders and Taxpayers (Dorf on Law) VAT...

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