Taxation & Estate Planning

ABA Tax Section Midyear Meeting

Posted on January 21, 2011
The ABA Tax Section midyear meeting continues today in Boca Raton. The full program is here; Tax Profs with speaking roles today include: Exempt Organization Committee Luncheon -- Frances R. Hill (Miami) Foreign Activities of US Taxpayers: Foreign Tax Credit Panel -- Robert J...

Crowdsourced Law School Rankings

Posted on January 21, 2011
The Conglomerate's crowdsourced law school rankings have received over 92,000 votes -- here are the current Top 10 (with their corresponding u.s. News rank): Chicago (5) Columbia (4) NYU (6) UC-Berkeley (7) Michigan (9) Virginia (10) Pennsylvania (7) Northwestern (11) Duke (11) Georgetown (14)

Vann: Travellers, Tax Policy and Permanent Establishments

Posted on January 21, 2011
Richard J. Vann (Sydney Law School) has published Travellers, Tax Policy and Agency Permanent Establishments, 6 British Tax Rev. 538 (2010). Here is the abstract: This article analyses the policy, historical development and current application of permanent establishment rules for travellers...

Law Profs Kiss a Pig for Charity

Posted on January 21, 2011
Thomas Cooley Law Profs Ronald Bretz and Michael Molitor kiss a pig to raise $200 for charity:

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Ainsworth: The Empirical Evidence -- Will Cutting the Payroll Tax Increase Jobs?

Posted on January 21, 2011
Richard Thompson Ainsworth (Boston University) has posted Will Cutting the Payroll Tax Increase Jobs? (Empirical Evidence from the EU VAT) on SSRN. Here is part of the abstract: Empirical evidence from the EU suggests that [the 2% employee payroll tax cut in the Tax Relief, Unemployment Insurance Reauthorization, and Jobs...

Kuo: Global Tax Competition and the Crisis of Constitutional Democracy

Posted on January 21, 2011
Ming-Sung Kuo (Warwick Law School) has published (Dis)embodiments of Constitutional Authorship: Global Tax Competition and the Crisis of Constitutional Democracy, 41 Geo. Wash. Int'l L. Rev. 181 (2009). Here is the abstract: The initial onset of globalization generated optimism regarding the possible creation of a global legal universe capable of...

Boise: Optimal Tax Treaty Administrative Guidance

Posted on January 21, 2011
Craig M. Boise (DePaul) has published Optimal Tax Treaty Administrative Guidance, 88 Tex. L. Rev. See Also 175 (2010), responding to Michael S. Kirsch (Notre Dame), The Limits of Administrative Guidance in the Interpretation of Tax Treaties, 87 Tex. L...

Illinois Tax Hikes Claim First Victim: Jimmy John's to Leave State

Posted on January 21, 2011
Following up on my recent posts (here and here) on the gigantic individual (67%) and business (45%) income tax hikes just approved in Illinois: Jimmy John Liautaud, the founder of Jimmy John's Gourmet Subs, has announced that he is pulling the company out of Champaign because of the tax increases...

Johnson Presents Fifty Ways to Raise a Trillion Today at SMU

Posted on January 21, 2011
Calvin H. Johnson (Texas) presents Fifty Ways to Raise a Trillion at SMU today as part of its Tax Policy Colloquium Series: The presentation focuses on contingency planning for ways to raise revenue in the impending budget crisis. The Shelf Project is a collaboration to create and develop proposals to...

Joint Tax Committee Releases List of Expiring Federal Tax Provisions, 2010-2020

Posted on January 21, 2011
The Joint Committee on Taxation today released List of Expiring Federal Tax Provisions 2010-2020 (JCX-2-11): This document ... provides a listing of Federal tax provisions (other than those providing time-limited transition relief after the repeal of an underlying rule) that are currently scheduled to expire in 2010-2020 (with references to...

Tax Policy Center Wins $1 Million MacArthur Award

Posted on January 20, 2011
Congratulations to the Tax Policy Center, recipient of a $1 million 2010 MacArthur Award for Creative & Effective Institutions: Analyzing how tax policy impacts people. The Urban-Brookings Tax Policy Center, a joint venture of the Urban Institute and the Brookings Institution, provides non-partisan, credible information on tax policy and the...

ABA Tax Section Midyear Meeting

Posted on January 20, 2011
The ABA Tax Section midyear meeting kicks off today in Boca Raton. The full program is here; Tax Profs with speaking roles today include: Low Income Taxpayers Representation Workshop -- Keith Blair (District of Columbia), Sandy Freund (Rutgers-Newark), Michelle Kwon (Texas Tech), Jan Pierce (Lewis & Clark), Kathryn J...

House Holds Tax Reform Hearing Today

Posted on January 20, 2011
The House Ways & Means Committee holds the first in a series of tax reform hearings today at 9:00 a.m.: The hearing will examine the economic and administrative burdens imposed by the current structure of the Federal income tax. It will explore the cost of complexity borne by American families,...

Joint Tax Committee Releases Report on Federal Excise Taxes

Posted on January 20, 2011
The Joint Committee on Taxation yesterday released Present Law and Background Information on Federal Excise Taxes (JCS-1-11). Here is the Introduction: The Internal Revenue Code imposes numerous excise taxes on goods and services. In addition to excise taxes the primary purpose of which is revenue production, excise taxes also are...

Delaware's Role as a Tax Haven

Posted on January 20, 2011
Scott D. Dyreng (Duke University, Fuqua School of Business), Bradley P. Lindsey (College of William and Mary, Mason School of Business) & Jacob R. Thornock (University of Washington, Michael G. Foster School of Business) have posted Exploring the Role Delaware Plays as a Domestic Tax Haven on SSRN...

Ohio Federal Judge Bars Columbia Law Grad From Using 'J.D.' After His Name

Posted on January 20, 2011
National Law Journal, Federal Judge Bars Law Grad From Using 'J.D.' After His Name: A federal judge in Ohio has prohibited a Columbia Law School graduate from using the initials "J.D." after his name. U.S. District Judge Patricia Gaughan on Jan. 14 denied a motion to reconsider filed by Bruce...

Wood: Why Tax Opinions Are Valuable

Posted on January 20, 2011
Forbes, Why Tax Opinions Are Valuable, by Robert W. Wood (Wood & Porter, San Francisco): What taxpayers really want is to have their tax position upheld. That makes the best reason to get a tax opinion to help secure your position. An opinion?especially one prepared not at tax return time...

3d Cir. Joins 7th Cir. in Reversing Tax Court and Upholding Innocent Spouse Reg

Posted on January 20, 2011
A divided Third Circuit yesterday followed the Seventh Circuit (Lantz v. Commissioner, No. 09-3345 (7th Cir. June 8, 2010)), and rejected the Tax Court (Manella v. Commissioner, 132 T.C. No. 10 (Apr. 13, 2009)), in upholding the requirement in Reg § 1...

Bankman Presents The Tax Preference for Employer Health Insurance at NYU

Posted on January 20, 2011
Joseph Bankman (Stanford Law School) presents Reforming the Tax Preference for Employer Health Insurance (with John Cogan (Stanford University, Hoover Institution), R. Glenn Hubbard (Dean, Columbia Business School) & Daniel Kessler (Stanford University, Graduate School of Business)) at NYU today as part of its Colloquium Series on Tax Policy and...

Hickman: Dismayed by Mayo? Check Out the Mannella Dissent

Posted on January 20, 2011
Following up on my prior posts (links below) on Mayo Foundation for Medical Education & Research v. United States, No. 09-837 (U.S. Jan. 11, 2011); and . Mannella v. Commissioner, No. 10-1308 (3d Cir. Jan. 19, 2011): Kristin Hickman (Minnesota), Dismayed by Mayo? Check Out the Mannella Dissent: The majority...

Tax Analysts Conversations: Loyola-L.A.'s Tax LL.M. Faculty

Posted on January 19, 2011
Jeremiah Coder, Conversations: Loyola Law School's Tax LLM Faculty,130 Tax Notes 286 (Jan. 17, 2011): As Loyola Law School in Los Angeles celebrates 10-plus years since beginning its graduate tax program, it is taking bold steps to offer educational programs it believes are responsive to changes in the legal market...

University of Colorado Student Pays Tuition Bill in $1 Bills

Posted on January 19, 2011
To protest the rising cost of tuition at the University of Colorado, economics major Nik Ramos paid his $14,309.51 charge in $1 bills (and a 50-cent piece, and a penny). Three university employees spent three hours counting the money. ABC News BBC CBS News L...

23rd Australasian Tax Teachers Association Conference: Tax - It's More Than Numbers

Posted on January 19, 2011
The 23rd Annual Conference of the Australasian Tax Teachers Association kicks off today at Melbourne Law School with the theme "Tax - It's More Than Numbers"

Why You Shouldn't Text While Walking

Posted on January 19, 2011

U.S.: The New Swedish Tax Haven

Posted on January 19, 2011
The Local, U.S. Emerges as New Swedish 'Tax Haven': Swedish taxpayers looking to shield earnings from the country's tax authorities may have an unlikely tax haven at their disposal across the Atlantic: the United States. While Sweden and the United States have a tax treaty obligating the tax agencies in...

ABA Submits Comments on Codification of Economic Substance Doctrine

Posted on January 19, 2011
The ABA Tax Section yesterday submitted this 65-page comment letter on Notice 2010-62 and Implementation of the Economic Substance Legislation: In Notice 2010-62, the Treasury and the IRS requested comments on certain aspects of the economic substance legislation contained in the Health Care and Education Reconciliation Act of 2010...

De Broe Presents The Cross-Border Rendition of Services Today at Northwestern

Posted on January 19, 2011
Luc De Broe (Katholieke Universiteit Leuven, Belgium) presents Article 15 and the Cross-Border Rendition of Services at Northwestern today as part of its Tax Program Speaker?s Series: Professor De Broe will discuss interpretation issues arising under Article 15 of the OECD Model Tax Convention involving the taxation of income from...

Greenaway: Mayo Foundation Cures Tax Myopia

Posted on January 18, 2011
Following up on last week's commentary on the Supreme Court's unanimous opinion in Mayo Foundation for Medical Education & Research v. United States, No. 09-837 (Jan. 11, 2011): Kristin Hickman (Minnesota), Goodbye National Muffler! Hello Administrative Law? (Jan...

State Law Schools Struggle

Posted on January 18, 2011
In the January 2011 issue of National Jurist: When Public Funding is No Longer Available: The nation's economic recession has found one more victim -- the state-funded law school. As state governments struggle, many have slashed their high-education allocations...

2011 Tannenwald Tax Writing Competition

Posted on January 18, 2011
For students writing tax seminar papers this semester (or having completed a tax paper last semester): the Theodore Tannenwald, Jr. Foundation for Excellence in Tax Scholarship and American College of Tax Counsel are sponsoring the 2011 Tannenwald Writing Competition: Named for the late Tax Court Judge Theodore Tannenwald, Jr...

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