Taxation & Estate Planning

Law & Zaring: The Use of Legislative History in Tax Cases

Posted on August 21, 2009
David S. Law (Washington University) & David T. Zaring (Pennsylvania) have posted Why Supreme Court Justices Cite Legislative History: An Empirical Investigation on SSRN. Here is the abstract: Much of the social science literature on judicial behavior has focused on the impact of ideology on how judges vote...

College Rigor Rankings

Posted on August 21, 2009
Following up on yesterday's post on the 2010 U.S. News & World Report College Rankings; the American Council of Trustees and Alumni has rated over 100 colleges according to the rigor of their course requirements for undergraduates based on seven core subjects: Composition, Literature, Foreign Language, U...

BNA Tax Management Meets on Foreign Income & Transfer Pricing

Posted on August 21, 2009
The BNA Tax Management Advisory Board met yesterday and discussed three Foreign Income & Transfer Pricing papers: Check-the-Box Reform: Technical Issues Relating to Tax Residency Based Entity Classification, by Robert Stack, Danielle Rolfes & John Bates President Obama's Tax Enforcement Proposals -- An Analysis and Critique, by Edward Tanenbaum Xilinx...

TIGTA: IRS Needs to Better Evaluate Tax Research Programs

Posted on August 21, 2009
The Treasury Inspector General for Tax Administration has released An Improved Project Management Process Is Needed to Measure the Impact of Research Efforts on Tax Administration: The IRS does not have a systemic process to measure research outcomes against intended results...

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No Accounting for the Holidays

Posted on August 21, 2009
I previously blogged The Singing CPA CD by Steven Zelin. Check out these tracks from his latest CD, No Accounting for the Holidays: Deck the Halls (With Calculators) Most Deductible Time of the Year We Wish You a Great Big Refund Joy to the World (The Clients Paid) IRS Jingle...

2010 U.S. News College Rankings

Posted on August 20, 2009
At 12:01 this morning, U.S. News & World Report released its 2010 College Rankings. Here are the Top 25 National Universities (along with their 2008 and 2009 rankings): 2010 Rank 2009 Rank 2008 Rank School 1 1 2 Harvard 1 2 1 Princeton 3 3 3 Yale 4 6 6...

Court Rejects $1.1b Tax Losses Claimed by Andrew Beal in DAD Tax Shelter

Posted on August 20, 2009
In the first distressed asset/debt (DAD) tax shelter case to go to trial, the U.S. District Court for the Northern District of Texas on Tuesday rejected $1.1 billion in losses claimed by D. Andrew Beal, #329 on Forbes list of the 400 Richest Americans...

The Incentives for Tax Planning

Posted on August 20, 2009
Chris Armstrong (University of Pennsylvania, Accounting Department), Jennifer L. Blouin (University of Pennsylvania, The Wharton School) & David F. Larcker (Stanford University, Graduate School of Business) have posted The Incentives for Tax Planning on SSRN...

WSJ: Textron Work Papers

Posted on August 20, 2009
Following up on last week's post, En Banc First Circuit Reverses Panel, Gives IRS Access to Textron's Work Papers: in today's Wall Street Journal, Ruling in Tax-Auditing Case Puts Corporations on Edge, by Amir Efrati:

Death and Taxes: A Visual Look at Where Your Tax Dollars Go (2010)

Posted on August 20, 2009
Check out new edition of the cool 24" x 36" poster, Death and Taxes: A Visual Look at Where Your Tax Dollars Go: Death and Taxes is a large representational graph and poster of the federal budget. It contains over 500 programs and departments and almost every program that receives...

More Celebrity Tax Woes

Posted on August 20, 2009
The Detroit News has two new additions to its list of celebrities with tax woes: Earl Cureton (former basktball player): IRS $217,776 tax lien, Michigan $2,212 tax lien Teri Polo (actress): IRS $341,988 tax lien, California $91,748 tax lien

Barker & O'Brien: Correcting § 409A Failures

Posted on August 20, 2009
Rosina B. Barker & Kevin P. O?Brien (both of Ivins, Phillips & Barker, Washington, D.C.) have published 409A Failures: Correcting With and Without Notice 2008-113, 124 Tax Notes 557 (Aug. 10, 2009). Here is the abstract: Deferred compensation plans under § 409A are minefields of potential mistakes...

Tax Profs Criticize UBS Settlement

Posted on August 20, 2009
Following up on yesterday's post, UBS Agrees to Release 4,450 Names to IRS in Tax Evasion Case: Chris Bergin, President and Publisher of Tax Analysts, characterizes the settlement as Justice for All ? Well, At Least for the Rich and the Swiss: Three law professors from American University?s law school...

Is Obama's Tax Reform Panel Fizzling Out?

Posted on August 19, 2009
BNA, Lawmakers Dismiss Prospects for Obama's Tax Reform Panel: The Tax Reform Task Force President Obama created in March has yet to schedule any public meetings but does not plan on asking for an extension of its early-December deadline for filing a report, according to an administration official...

Vault Releases 2009 Law Firm Rankings

Posted on August 19, 2009
Vault yesterday released its annual ranking of the Top 100 Law Firms, based on prestige as voted on by associates. Here are the Top 25: (Hat Tip: Above the Law and Legal Blog Watch.)

Common Corporate Tax Base (CCTB) and Effective Tax Burdens in the EU Member States

Posted on August 19, 2009
Timo Reister (Centre for European Economic Research), Christoph Spengel (Centre for European Economic Research) & Andreas Oestreicher (University of Goettingen) have posted Common Corporate Tax Base (CCTB) and Effective Tax Burdens in the EU Member States on SSRN...

Death of

Posted on August 19, 2009
Arent Fox (Washington, D.C.) today announced the death of Edwin L. Kahn, one of the founders of the firm, at the age of 91: Edwin L. Kahn joined the firm in 1955 after serving in high-level positions with the Internal Revenue Service, where he played a prominent role in drafting...

California Announces New $5k Penalty for "Frivolous Submissions"

Posted on August 19, 2009
The California Franchise Tax Board has announced a new $5,000 penalty for "frivolous submissions." For more, see Web CPA.

Reputation Without Rigor

Posted on August 19, 2009
In today's Inside Higher Ed, Reputation Without Rigor: The form submitted by the provost at the University of Wisconsin at Madison deemed 260 of its 262 peer institutions to be of ?adequate? quality. A survey from the University of Vermont?s president listed ?don?t know? for about half of the universities...

Golombek: Planning with Registered Disability Savings Plans

Posted on August 19, 2009
Jamie Golombek (CIBC Private Wealth Management) has published Planning with Registered Disability Savings Plans, 57 Can Tax J. 338 (2009). Here is the abstract: The introduction of the registered disability savings plan (rdsp ) represents a significant development in facilitating the financial security of persons with disabilities...

UBS Agrees to Release 4,450 Names to IRS in Tax Evasion Case

Posted on August 19, 2009
IRS Announcement IRS's UBS Web Page U.S.-Swiss Government Agreement U.S.-Swiss Government Declarations U.S.-UBS Agreement New York Times Wall Street Journal Washington Post

2009 Legal Educator Blog Census

Posted on August 19, 2009
Colin Miller (John Marshall (Chicago)) of our sister EvidenceProf Blog has released 2009 Legal Educator Blog Census (A-M, N-Z) The purpose of this legal educator blog census is [to tell] us which legal educators are blogging and where the blogosphere is headed...

Are Young Lawyers Slackers?

Posted on August 18, 2009
Legal Blog Watch asks Are Generation Y Lawyers a Bunch of Slackers?: Over at Idealawg, Stephanie West Allen plays host to a robust debate over whether Generation Y lawyers -- or "millennials," lawyers under 30 -- who seek work/life balance to the exclusion of focusing on client needs are unrealistic...

Kirsch: The Limits of Administrative Guidance in the Interpretation of Tax Treaties

Posted on August 18, 2009
Michael S. Kirsch (Notre Dame) has published The Limits of Administrative Guidance in the Interpretation of Tax Treaties, 87 Tex. L. Rev. 1063 (2009). Here is the abstract: This Article addresses the increasingly important role of administrative guidance in interpreting the United States' international treaty obligations...

Peer Reputation: Size Matters

Posted on August 18, 2009
Kyle Sweitzer (Michigan State) & J. Fredericks Volkwein (Penn State) have published Prestige Among Graduate and Professional Schools: Comparing the U.S. News? Graduate School Reputation Ratings Between Disciplines, Res. Higher Educ. (July 2009). Here is the abstract: Using a conceptual model, this study examines the variables associated with the U...

A Structural Critique of Trader Taxation

Posted on August 18, 2009
Shu-Yi Oei (Bingham McCutchen, Boston) has published A Structural Critique of Trader Taxation, 8 Fla. Tax Rev. 1013 (2008). Here is the abstract: This article scrutinizes the structural elements underlying the unusual tax treatment of securities traders under current law...

Treasury Department Seeks to Hire International Tax Counsel

Posted on August 18, 2009
The Treasury Department is looking to fill the International Tax Counsel position: The International Tax Counsel serves as the principal legal adviser to the Assistant Secretary (Tax Policy) and the Secretary of the Treasury with regard to all aspects of international taxation, including legislation, the development and promulgation of administrative...

Deducting the Cost of an M.B.A. Degree

Posted on August 18, 2009
John J. DeBoy (J.D. 2010, Georgetown) has published Solving the B-School Tax Riddle: A Proposal to Clarify the Confusion Surrounding Deductions for MBA-Related Educational Expenditures Under Section 162 of the Internal Revenue Code, 97 Geo. L.J. 1689 (2009)...

NY Uncovers Fraud at 30% of Tax Preparers

Posted on August 18, 2009
From an Albany Times Union profile of William Comiskey, Deputy Commissioner for Enforcement in the New York State Tax Department: [W]e've done a little project on tax preparers. We go out pretending to be tax payers ... we've done it at 170 different tax preparers...

IRS Commissioner Named Chair of OECD Tax Forum

Posted on August 17, 2009
IRS Commissioner Douglas Shulman has been named Chair of the OECD Tax Forum. From the OECD press release: The Forum, or FTA, allows Tax Commissioners from 41 advanced economies to confer and develop new ideas to enhance tax administration around the world...

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