Paul L. Caron
Dean
Pepperdine Caruso
School of Law
2013
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McCaffery Presents Bifurcation Blues: The Problems of Leaving Redistribution Aside Today at NYU
Edward McCaffery (USC) presents Bifurcation Blues: The Problems of Leaving Redistribution Aside at NYU today as part of its Colloquium Series on Tax Policy and Public Finance convened by Daniel Shaviro (NYU) and William Gale (Tax Policy Center; visiting at NYU): In short and in sum, the strategy of bifurcation, so elegant and attractive in theory, has…
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Washington & Lee Is the Biggest Legal Education Story of 2013
The Legal Whiteboard: Washington & Lee is Biggest Legal Education Story of 2013 (pdf here): Here it is in a nutshell. There is empirical evidence that Washington & Lee’s experiential 3L curriculum is delivering a significantly better education to 3L students—significantly better than prior graduating classes at W&L, and significantly better than W&L’s primary competitors.…
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Epstein: President Obama’s Proposed Charitable Deduction Limits Will Hurt the Poor
Defining Ideas op-ed: The End of Charity?, by Richard A. Epstein (NYU): The received progressive consensus mistakenly pushes hard on limiting charitable deductions and increasing the progressivity of the tax code. …What is doubly ironic in this situation is that the champions of redistribution seek to neuter the single most effective device for redistribution that…
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Monroe: Rethinking Partnership Tax
Andrea Monroe (Temple), Integrity in Taxation: Rethinking Partnership Tax, 64 Ala. L. Rev. 289 (2012): Partnerships play an increasingly vital role in the federal income tax. Yet partnership taxation is deeply flawed, with enormously complicated provisions that strain the voluntary compliance mechanism on which the federal income tax relies. This article takes some early steps…
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Kahn: Tax Expenditures and Accelerated Depreciation
Douglas A. Kahn (Michigan), A Proposed Replacement of the Tax Expenditure Concept and a Different Perspective on Accelerated Depreciation, 40 Fla. St. L. Rev. ___ (2013): The thesis of this article is that the tax expenditure concept is grounded on an erroneous vision of the structure of an income tax system. The tax expenditure concept…
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Gerzog: Wimmer Wins FLP Annual Exclusions
Wendy C. Gerzog (Baltimore), Wimmer Wins FLP Annual Exclusions, 138 Tax Notes 489 (Jan. 28, 2013): In Wimmer [T.C. Memo. 2012-157], the Tax Court held that the income stream from a taxpayer’s gifts of family limited partnership interests was eligible for the annual exclusion. By comparing the income interest in the partnership’s dividend paying marketable securities…
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USC Tax Institute
The USC Gould School of Law Tax Institute continues today with its Partnerships, Individual, and Ethics session. Kathryn Keneally (Assistant Attorney General, Tax Division, U.S. Department of Justice) delivers the keynote address on Tax Issues of Interest to the Department of Justice. Among the other speakers today are: Michael D. Fernhoff (Proskauer, New York) David…
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Reynolds: Tax the Revolving Door
USA Today op-ed: Tax the Revolving Door, by Glenn Harlan Reynolds (Tennessee): When President Obama ran for president in 2008, he promised to “close the revolving door” and clean up both ends of Pennsylvania Avenue, but that hasn’t happened. Which isn’t to say that it shouldn’t happen now. But I don’t think the usual ethics-rules…
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Northeastern Seeks to Hire Lead Tax Faculty
The Northeastern University Masters of Science in Taxation Program is inviting applications for three Lead Faculty Positions: Tax Accounting for Income Taxes Income Taxation of Trusts and Estates Planning for Estate Tax Issues As the Lead Faculty, your primary role is to coordinate and guide the section instructors, who have primary responsibility for day-to-day interaction…
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Diamond Reviews Tamanaha’s Failing Law Schools
Stephen F. Diamond (Santa Clara), The Future of the American Law School or, How the ‘Crits’ Led Brian Tamanaha Astray and His Failing Law Schools Fails (reviewing Brian Tamanaha (Washington U.), Failing Law Schools (University of Chicago Press, 2012)): Debate over the impact of the economic crisis on the future of the American law school…
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Call for Contributions: Controversies in Tax Law
Call for Contributions to Controversies in Tax Law: A Matter of Perspective (Anthony C. Infanti, Editor): The Centre for American Legal Studies at Birmingham City University School of Law in Birmingham, England, has established a “Controversies in …” series of volumes with Ashgate Publishing. The series currently has five books in the pipeline—on equal protection,…
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NLJ: Applicants Are Avoiding Law School in Droves (Especially Those With 170+ LSATs)
National Law Journal: Avoiding Law School in Droves: The Numbers of Applicants May Slump by 20 Percent: Nearly everyone in legal education expected the number of law school applicants to fall off this academic year. But they weren't prepared for this. As of mid-January, 27,891 people had applied for seats in American Bar Association-accredited law…
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Phil Mickelson and the Sports Star Tax Migration to Florida and Texas
Following up on my prior posts (links below): Wall Street Journel op-ed, Mickelson and the Sports Star Tax Migration, by Allysia Finley: If Lefty moves to a state with no income tax like Florida, he’ll find he has plenty of elite athlete company. … The benefit of living in a state without an income tax can…
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Bucknell Joins Rankings Hall of Shame
Inside Higher Ed: How Much Admission Misreporting?: Bucknell University [has come] forward to admit that it had misreported SAT averages from 2006 through 2012, and ACT averages during some of those years. … [T]he inaccurate data resulted from the college leaving some students’ scores out of test averages. In a few cases, the omitted students…
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NY Times: Italians Have a New Tool to Unearth Tax Cheats
New York Times: Italians Have a New Tool to Unearth Tax Cheats: Despite the government’s best efforts, tax evasion remains something of a pastime in Italy, where, famously, more than a few of the Ferrari-driving set claim impoverishment when it comes to declaring their incomes. So this month, not without controversy, the National Revenue Agency…
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Goulder: The Pepperdine Papers: International Tax Advice for Obama’s Second Term
Robert Goulder (Tax Analysts), The Pepperdine Papers: Advice for Obama's Second Term: Last week, the Pepperdine Law Review hosted a unique policy forum: Tax Advice for the Second Obama Administration. The event was organized by Professor Paul Caron and cosponsored by Tax Analysts. Three of the featured papers addressed international reforms and are highlighted below.…
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USC Tax Institute
The three-day USC Gould School of Law Tax Institute kicks off today with its Business Tax Planning session. Pamela F. Olson (Former Assistant Secretary for Tax Policy, U.S. Department of Treasury; U.S. Deputy Tax Leader and Washington National Tax Services Leader, PricewaterhouseCoppers, Washington, D.C.) delivers the keynote address on The Impact of Transparency on Corporate…
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Anderson: Plastic Grocery Bag Bans and the $87,500 Seagull
Rob Anderson (Pepperdine), Law Profs Bag $87,500 Seagull: Law professors Jonathan Klick (U Penn Law) and Joshua D. Wright (George Mason Law) have posted a paper, Grocery Bag Bans and Foodborne Illness, that has been making the rounds in the news and blogs in the last few days. The paper argues that the bans on plastic bags in…
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Historic Preservation Tax Credit Rules to be Reviewed
Detroit Free Press: Historic Preservation Tax Credit Rules to be Reviewed: U.S. Interior Secretary Ken Salazar said in Detroit Friday that he has ordered a review of rules governing the use of historic preservation tax credits with a view to making the credits easier to use in cities like Detroit. He made the remarks following…
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TaxProf Blog Weekend Roundup
Saturday: What's FATCA Got To Do With It? Tina Turner Renounces U.S. Citizenship Financial Times: U.S. Taxes: Certain as Death, Complicated as Hell 2013 Undergraduate Accounting Program Rankings by Tax Hiring Authorities Bloomberg Law: Should Deans be Disciplined for Deceitful Marketing to Students? Sunday: ABA Tax Section Midyear Meeting Top 5 Tax Paper Downloads Tax…
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ABA Tax Section Midyear Meeting
The ABA Tax Section midyear meeting concluded yesterday in Orlando. The full program is here. Tax Profs with speaking roles included: Diversity: Lily Kahng (Seattle) Employee Benefits: Kathryn Kennedy (John Marshall) Foreign Activities of U.S. Taxpayers: Robert Peroni (Texas) Individual & Family Taxation and Pro Bono & Tax Clinics: Stephen Black (Texas Tech), Keith Fogg (Villanova),…
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Top 5 Tax Paper Downloads
There is quite a bit of movement in this week’s list of the Top 5 Recent Tax Paper Downloads on SSRN, with new papers debuting on the list at #2 and #5: 1. [343 Downloads] The End of Taxation without End: A New Tax Regime for U.S. Expatriates, by Bernard Schneider (Queen Mary, University of London School…
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Tax Prof Amicus Brief in PPL Corp. v. Commissioner
The U.S. Supreme Court will hear oral argument in PPL Corp. v. Commissioner, Docket No. 12-43, on February 20. The issue presented is: Whether, in determining the creditability of a foreign tax, courts should employ a formalistic approach that looks solely at the form of the foreign tax statute and ignores how the tax actually…
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Tax Strategy Patents After the America Invents Act
Nichelle Closson (J.D. 2013, Iowa), Note, Tax Strategy Patents After the America Invents Act: The Need for Judicial Action, 38 Iowa J. Corp. L. 159 (2012): With the passage of the Leahy-Smith America Invents Act (the Act) in September of 2011, tax strategy patents became one of only three types of business methods that Congress…
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What’s FATCA Got To Do With It? Tina Turner Renounces U.S. Citizenship
The Daily Mail: Let's Stay Together? Tina Turner Renounces Her U.S. Citizenship to Become Swiss (So How Much Tax Will She Now Pay?): Tina Turner is renouncing her American citizenship to become Swiss, it was revealed today. The American rock diva has lived in the Zurich suburb of Kuesnacht since the mid-1990s and speaks fluent…