Taxation & Estate Planning

The VAT Reader: What a Federal Consumption Tax Would Mean for America

Posted on February 28, 2011
Tax Analysts today published The VAT Reader: What a Federal Consumption Tax Would Mean for America. The 352-page book is free, avaialable in both pdf and hard copy. The contributors are: Martin A. Sullivan, Introduction: Getting Acquainted With VAT (p...

Luke Presents Partnership Tax Restraints on Tax Attribute Markets at Georgia

Posted on February 28, 2011
Charlene Luke (Florida) presents Partnership Tax Restraints on Tax Attribute Markets: Time for an Entity-level Solution? at Georgia today as part of its Faculty Colloquium Series. Here is the abstract: This Article considers partnership tax law in terms of two long-standing doctrinal standards: the owner of an income-producing asset pays...

Death of Duke Snider: Baseball Great, Tax Scofflaw

Posted on February 28, 2011
From the New York Times obituary of Brooklyn and Los Angeles Dodger Hall of Famer Duke Snider, who died yesterday at the age of 84: Snider returned to Brooklyn on a sad note on July 20, 1995, when he appeared in federal court, a couple of miles from where Ebbets...

Law School Rankings by BigLaw Jobs

Posted on February 28, 2011
The National Law Journal reports today that 27.3% of the law school class of 2010 landed jobs at the 250 largest law firms, down from 30.3% last year. The NLJ ranks the Top 50 law schools by the percentage of the graduating class landing jobs at BigLaw firms...

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Fleischer Presents Taxing Founders' Stock Today at Stanford

Posted on February 28, 2011
Victor Fleischer (Colorado) presents Taxing Founders' Stock today at Stanford Law School's Rock Center for Corporate Governance, co-sponsored by the Northern California Tax Roundtable. Joe Bankman (Stanford) and Heather Field (UC-Hastings) will be the commentators...

CTJ: Tax

Posted on February 28, 2011
Citizens for Tax Justice, Tax Proposals in President Obama?s Fiscal Year 2012 Budget: While the President's budget does include many laudable proposals to raise revenue, these don't come close to offsetting the revenue losses from the tax cuts that he proposes...

A-Rod Uses Loophole to Pay $1,200 Property Tax on $6 Million Condo

Posted on February 27, 2011
From the New York Daily News: Yankees star Alex Rodriguez will pay virtually no property tax for a $6 million apartment he is buying on the upper West Side. Rodriguez will be billed around $1,200 this year in real estate tax for his 3,000-square-foot, five-bedroom penthouse with spectacular views of...

Taxes and Asteroids

Posted on February 27, 2011
A blogosphere kerfuffle has erupted over this Volokh Conspiracy post: I think there?s a good case to be made that taxing people to protect the Earth from an asteroid... is an illegitimate function of government from a moral perspective.... [I]t?s O.K...

Oscar Swag Bags to Result in $100k Income to Celebrity Presenters

Posted on February 27, 2011
Tonight's Oscars have lost a bit of their buzz because of the tax consequences of the swag bags received by the celebrity presenters -- worth a record $100,000 this year. From IRS and Hollywood Reach Accord on Gift Bags: The IRS [has] launched an outreach campaign to the entertainment industry...

Top 5 Tax Paper Downloads

Posted on February 27, 2011
This week's list of the Top 5 Recent Tax Paper Downloads is the same as last week's list, with some minor reshuffling within the Top 5: 1. [569 Downloads] The Fundamentals of Wealth Transfer Tax Planning: 2011 and Beyond, by John A. Milller (Idaho) & Jeffrey A...

What Lawyers Earn (by County)

Posted on February 26, 2011
Bill Henderson (Indiana-Bloomington) and the ABA provide a database on What Lawyer's Earn: In this, the first installment of a periodic series, we look at the geography of lawyer salaries, showing where the jobs are and what they pay. Using actual salary data reported to the U...

WSJ: Governors Get a Jump on Corporate Tax Reform

Posted on February 26, 2011
Wall Street Journal editorial, The State Business Tax Revolt: Governors Get a Jump on Corporate Tax Reform: President Obama says he wants corporate tax reform but hasn't proposed how to do it. Maybe he should take a look at the states, where as many as 10 new Governors are moving...

Taxability of Former Duke Lacrosse Players' $60m (?) Settlement

Posted on February 26, 2011
Detroit News, Ex-Duke Lacrosse Star Insists Tax Bill a 'Mistake': Nearly four years after receiving an undisclosed settlement from Duke University, Reade Seligmann, one of three lacrosse players exonerated in a racially-charged rape case, owes the IRS almost $6...

More on Tax Lawyers Who Make $1,000/Hour

Posted on February 26, 2011
Following up on Thursday's post, G-Men -- Tax Lawyers Who Charge $1,000 Per Hour: some thoughts on Tax Lawyers Who Make $1000/Hour or More by Tom Smith (San Diego): I always tell my students that if they are smart enough to be tax lawyers and if they find it at...

Tax Court Denies Deduction for TV Anchor's Clothing Expenses

Posted on February 25, 2011
The Tax Court yesterday denied business expense deductions claimed by a TV new anchor for her wardrobe expenses and sustained accuracy-related penalties. Hamper v. Commissioner, T.C. Summ. Op. 2011-17 (Feb. 25, 2011) (citations omitted): On Schedules A of her Federal income tax returns for the years at issue, petitioner claimed...

Wood: Taxing Prisoners Freed From Wrongful Convictions

Posted on February 25, 2011
Robert W. Wood (Wood & Porter, San Francisco) has published Tax-Free Wrongful Imprisonment Recoveries,130 Tax Notes 961 (Feb. 21, 2011): Although wrongful incarceration and similar recoveries are becoming common and can proceed under several different legal theories, their tax treatment has received relatively little attention...

Iowa Law Review Symposium Today on The Future of Legal Education

Posted on February 25, 2011
The Iowa Law Review hosts a symposium today on The Future of Legal Education: Keynote Speech: Dean Erwin Chemerinsky (UC-Irvine) Panel 1: Creating and Recreating the Ideal Law School: A Response to Dean Chemerinsky?s Keynote Speech Moderator: Professor Thomas P...

U.S. Effective Corporate Tax Rate Among Highest in World

Posted on February 25, 2011
Cato Institute, New Estimates of Effective Corporate Tax Rates on Business Investment: This bulletin presents estimates of effective corporate tax rates on new capital investment for 83 countries. ?Effective? tax rates take into account statutory rates plus tax-base items that affect taxes paid on new investment, such as depreciation deductions,...

CNN: GM's Sweetheart Tax Deal

Posted on February 25, 2011
Following up on my prior post, Rasmusen Presents The Lawlessness of the GM NOL Ruling (Feb. 14, 2011): CNN, GM's Sweetheart Tax Deal: The U.S. Treasury is giving up $14 billion in tax revenue because of a sweetheart deal it's giving General Motors. The automaker is expected to post its...

George Washington Law Revue 2011: F*** You

Posted on February 25, 2011
George Washington law student parody of Cee Lo Green's music video, F*** You (language warning):

CTJ: Boeing Gets $35 Billion Federal Contract, Pays Zero Federal Income Taxes

Posted on February 25, 2011
Citizens for Tax Justice, Boeing?s Reward for Paying No Federal Taxes Over Last Three Years? A $35 Billion Federal Contract: Despite reporting nearly $10 billion in domestic pre-tax profits between 2008 and 2010, the Boeing Corporation, which was granted a contract worth as much as $35 billion to build airplanes...

Tom Campbell Named Dean at Chapman

Posted on February 25, 2011
Chapman University School of Law today named Tom Campbell as its new dean. He is a former Stanford law professor (1983-89), member of the U.S. Congress (1989-93, 1995-2001) and California state senate (1993-95), and UC-Berkeley business school dean (2002-08) and professor (2009-)...

Geithner: End Pass-Through Treatment of LLCs, Partnerships & S Corps

Posted on February 25, 2011
Bloomberg News, Geithner Seeks to Broaden U.S. Corporate Tax Overhaul Debate: The Obama administration is seeking to widen the scope of its proposal to overhaul the corporate tax code, urging Congress to also change rules that allow some businesses to take advantage of tax laws governing individuals...

The Ides of March: U.S. News to Release New Law School Rankings on March 15

Posted on February 25, 2011
Robert Morse (Director of Data Research, U.S. News & World Report) has announced that the new law school rankings will be released online on March 15 (last year's price: $19.95) and in hard copy at newstands on April 5 (last year's price: $9.99) (both for $24...

G-Men: Tax Lawyers Who Charge $1,000 Per Hour

Posted on February 24, 2011
Wall Street Journal, Big Law's $1,000-Plus an Hour Club: Leading attorneys in the U.S. are asking as much as $1,250 an hour, significantly more than in previous years, taking advantage of big clients' willingness to pay top dollar for certain types of services...

State & Local Tax Burden: Highest in NJ & NY, Lowest in AK & NV

Posted on February 24, 2011
The Tax Foundation yesterday released State-Local Tax Burdens Fall in 2009 as Tax Revenues Shrink Faster than Income: Combined state and local tax burdens fell slightly in fiscal year 2009, as taxes shrank faster than income due largely to a slower economy, according to a new study by the Tax...

Galle: Congressional Control of State Taxation

Posted on February 24, 2011
Brian D. Galle (Boston College) has posted The Politics of Federalism: Self-Interest or Safeguards? Evidence from Congressional Control of State Taxation on SSRN. Here is the abstract: We present for the first time in the literature a quantitative analysis of the efficacy of the "political safeguards of federalism...

CRS: Tax Policy Options for Deficit Reduction

Posted on February 24, 2011
Congressional Research Service, Tax Policy Options for Deficit Reduction (R41641) (Feb. 18, 2011): This report analyzes various revenue options for deficit reduction, highlighting proposals made by the President's Fiscal Commission and the Debt Reduction Task Force.

Miller & Bertrand: The Tax Treatment of Hedge Funds

Posted on February 24, 2011
David S. Miller & Jean Marie Bertrand (both of Cadwalader, Wickersham & Taft, New York) have posted The U.S. Federal Income Tax Treatment of Hedge Funds, Their Investors and the Managers on SSRN. Here is the abstract: This paper describes various hedge fund structures, and discusses the federal income tax...

Three Law Schools Freeze Tuition

Posted on February 24, 2011
National Law Journal, Three Law Schools Freeze Tuition Rates: Annual law school tuition increases of between 3% and 10% are usually a given, but at least three schools have announced tuition freezes for the coming academic year. Ave Maria ($35,948) Maryland ($23,744 in-state; $35,023 out-of-state) New Hampshire ($39,900) The University...

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