TaxProf Blog

The Columbia Journal of Tax Law has published a new issue (Vol. 16, No. 1 (Winter 2024)):

• Sloan G. Speck (Colorado; Google Scholar), The Realization Rule as a Legal Standard, 16 Colum. J. Tax L. 1 (2024) (reviewed by David Elkins (Netanya, Google Scholar) here)

• Reuven S. Avi-Yonah (Michigan; Google Scholar) & Ariel Siman (Michigan), Taxation and Corporate Governance, 16 Colum. J. Tax L. 51 (2024)

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https://taxprof.typepad.com/taxprof_blog/2025/05/columbia-journal-of-tax-law-publishes-a-new-issue-1.html

Update: Eugene Volokh (UCLA), Court Dismisses Palestinian Muslim Student Activist’s Harassment Complaint Against Northwestern Law School, But Discrimination Claim Can Go Forward

Reuters, Northwestern University Must Face Palestinian Law Grad’s Discrimination Suit:

A former Northwestern law student can proceed with a discrimination lawsuit that claims the school failed to protect her from being harassed over her pro-Palestine activism, a federal judge ruled on Tuesday [Elagha v. Northwestern University, No. 24-C-12066 (N.D. Ill. May 13, 2025)].

Plaintiff Yasmeen Elagha in November sued Northwestern and several law school officials, including law dean Hari Osofsky, alleging she was discriminated against and subjected to a hostile educational environment.

Elagha, who is a Palestinian Muslim, said university officials failed to intervene after fellow students falsely claimed she attacked them during a campus protest. She also alleged that students released her personal information online and got her job offer at a major law firm rescinded.

U.S. District Judge Charles Kocoras in Chicago dismissed Elagha’s claim of a hostile educational environment, but allowed her claim of intentional discrimination to proceed after Northwestern filed a motion to dismiss the case. …

Law firm DLA Piper rescinded her job offer after a fellow law student falsely claimed Elagha assaulted her during a protest, according to the suit. Subsequent internal university review concluded that no assault took place, according to the lawsuit.

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https://taxprof.typepad.com/taxprof_blog/2025/05/northwestern-must-face-palestinian-law-grads-discrimination-lawsuit.html

Following up on my previous post, Yeshiva University Agrees To Recognize LGBTQ Student Group After Five-Year Battle: New York Times, Yeshiva University Reverses Itself and Bans L.G.B.T.Q. Club:

Two months after Yeshiva University said it would recognize an L.G.B.T.Q. student club on campus, bringing a yearslong legal battle to an end, the school has reversed course and banned the organization.

The school said the club, called Hareni, had violated both Jewish principles and the legal settlement. But lawyers for the students said it was leaders at the school, a Modern Orthodox Jewish institution with campuses in Manhattan and the Bronx, who had violated the agreement with hostile religious rhetoric.

In a letter to the community on Friday, the university repeated an argument it made unsuccessfully in state court in 2022, saying its undergraduate programs are “fundamentally religious.”

The school said that “recent actions and statements” from Hareni, which was formed after a legal battle with an unofficial club called the Pride Alliance, had led administrators to believe that it was “operating as a pride club under a different name and as such is antithetical to the Torah values of our yeshiva, as well as in violation of the approved guidelines and of the terms of the settlement agreement.”

“There is no place for such a club in yeshiva,” the letter continued, using the general term for an Orthodox Jewish educational institution. It said: “We remain fully committed to guiding our students in their challenges” in a manner consistent with Jewish religious law.

Yeshiva’s decision in March to recognize the club had seemed to end the legal dispute, which had plunged a university in one of the country’s most liberal cities into a nationwide debate over religious freedom, civil rights and whether houses of worship, religiously affiliated organizations or even pious individuals could be compelled to provide public accommodations to people with differing views.

The litigation had been closely watched by religious organizations and religious freedom groups. While many Jewish congregations support L.G.B.T.Q. rights, many Orthodox leaders interpret the Torah as promoting traditional ideas of gender and sexuality.

Throughout years of legal wrangling, Yeshiva went to great lengths to deny the Pride Alliance official recognition, including briefly banning all on-campus clubs. As the case worked its way through the courts, it also drew the attention of state lawmakers, who criticized the university’s position and suggested it might have imperiled its ability to access public funds.

The official dissolution of Hareni comes at a time when the rights of L.G.B.T.Q. Americans appear under threat from the Trump administration, which has attacked elite universities and mounted a campaign against the participation of transgender people, in particular, in public life.

In a statement, the club said its members were “deeply disappointed by the announcement of Hareni’s cancellation,” which it said came one day after their lawyers sent a letter to the university objecting to “ongoing displays of animus and hostility” from university leadership.

• Forward, Rabbis Revolt Over LGBTQ+ Club, Exposing Fight Over Queer Acceptance at Yeshiva University
• Inside Higher Ed, Yeshiva University Ends New LGBTQ+ Club
• NY Jewish Week, Yeshiva University Rescinds Approval for LGBTQ+ Student Club

Prior TaxProf Blog coverage:

• Letter from 48 Cardozo Law Professors, Yeshiva University Should Reverse Its ‘Wrong And Unlawful’ Ban On LGBTQ+ Student Group (May 2, 2021)
• New York Times, State Judge Rules Yeshiva University Must Recognize LGBTQ Student Club (June 19, 2022)
• Michael Helfand (Pepperdine; Google Scholar), Illegal Discrimination Or Religious Freedom? Understanding Yeshiva University’s Case Against The YU Pride Alliance (Sept. 4, 2022)
• New York Times, Justice Sotomayor Says Yeshiva University Can Bar LGBT Student Club — For Now (Sept. 11, 2022)
• Wall Street Journal, Supreme Court (5-4) Denies Yeshiva University Request To Block State Ruling On Recognition Of LGBTQ Club; Yeshiva Responds By Canceling All Student Groups (Sept. 18, 2022)
• Reuters, Cardozo Law School Fights Fallout From Yeshiva University LGBT Club Case (Sept. 25, 2022)
• Christianity Today, What Christian Colleges Can Glean From The Supreme Court’s ‘Yeshiva’ Case (Oct. 2, 2022)
• Chronicle of Higher Education, ‘Alternative’ or ‘Sham’? Yeshiva U. Created A New LGBTQ Club — But Won’t Recognize The One That Sued (Oct. 30, 2022)
• Inside Higher Ed, Yeshiva University Announces New LGBTQ Club While Continuing Its Legal Battle With The Existing One (Nov. 13, 2022)
• Yeshiva University Commentator, NY Appellate Court Orders Yeshiva University To Recognize LGBTQ Student Group (Jan. 1, 2023)
• New York Times, Yeshiva University Agrees To Recognize LGBTQ Student Group After Five-Year Battle (Mar. 30, 2025)

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https://taxprof.typepad.com/taxprof_blog/2025/05/ny-times-yeshiva-university-reverses-itself-and-bans-lgbtq-club.html

Following up on Tuesday’s post, ABA Legal Ed Council Proposes To Double Experiential Learning Accreditation Requirement To 12 Credits:

Daniel B. Rodriguez (Northwestern; Google Scholar), ABA Accreditation Once More: Are They Making Me Eat My Words?:

Less than a week after a short post urging the ABA Section on Legal Education to keep up its generally good work and encouraging external folks to avoid major changes that could well throw out the baby with the bathwater, the Section has announced its intention to consider a very bad idea from the Standards Committee (previously the “Standards Review Committee”). This “very bad idea” is the doubling of the required number of credits of so-called “experiential learning” for students to graduate. While I associate myself squarely with those who value the curricular programs, run mainly through law school clinics, and who encourage students to pursue opportunities for experiential learning during my time in law school, the insistence on this once-size-fits all requirement is a bad idea coming at a bad time. …

[T]he imposition of curricular mandates is to be usually disfavored, and especially disfavored in our current times of turmoil. Such mandates are expensive, clinical programs being especially so, given how the labor-intensive work that typically goes into such courses. Given the pressures faced by legal education and, more to the point, by students embarking on their legal careers with the prospects of high levels of debt to meet the tuition demands of law schools, adding to the costs of legal education seems, in a word, foolish. …

On top of all these potentially bad results of the ABA’s quest to revamp law school curriculum and pedagogy in the direction of experiential learning, there is the spectacularly bad odor which emerges from this top-down micro-management of law school curriculum, this is an era in which innovation and experimentation in higher education is being championed and in which the ABA already has a target on its back from external forces who might swap out this accreditor for another. …

Take a beat; take some time for considered reflection on the values and purposes of accreditation; and look for creative ways to work with diverse stakeholders. And in this time, give heavy-handed mandates for what some constituencies insist its The Only and Best Way Forward a rest.

Brian Leiter (Chicago; Google Scholar), Law Schools Should Oppose an ABA Proposal to Double the Experiential Learning Credits From 6 to 12:

The ABA is up to mischief again, which needs to be opposed for the sake of law students. Here’s what I wrote the last time this awful idea was being floated: …

A reader calls my attention to this apt observation in a letter from dozens of law school Deans concerning another bit of unwarranted ABA meddling:

We believe that these proposals are part of a recent trend of the ABA Council to try and exercise greater regulatory control over law schools. As deans, we urge greater restraint in this regard and urge that there be new regulation only if needed to solve a demonstrated problem supported by evidence and only if it is clear that any changes would not have adverse consequences on legal education.

If this continues–and the proposed doubling of experiential credits will be the straw that breaks the camel’s back–then law schools will, en masse, have to pressure the federal government to allow other accreditors for U.S. law schools.

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https://taxprof.typepad.com/taxprof_blog/2025/05/opposition-grows-to-abas-proposal-to-double-the-experiential-learning-accreditation-requirement.html

NYU Law Announces 2025 Teaching Award Recipients:

Richard Brooks, Brant Hellwig LLM ’00, and Daniel Hemel have been named this year’s recipients of the NYU Law Teaching Award, which recognizes faculty members who have made outstanding contributions to student learning and engagement.

Each year, NYU Law solicits nominations from students and faculty for the award based on criteria that include extraordinary commitment to teaching, inclusive pedagogical approaches, student engagement in critical thinking, mentorship, curriculum development, and length of service. These awards represent the highest recognition of teaching excellence at NYU Law. …

Hellwig, who is professor of tax law and directs NYU Law’s Graduate Tax Program, earned recognition for his dedication to bringing real-world applications into the classroom. Students highlighted his willingness to adapt curriculum based on their interests, including developing entirely new classes to address student requests. His commitment has also extended beyond scheduled courses, including supervising summer directed writing projects and taking on additional classes to offer a wider range of opportunities for students. According to one nominator, “the fact that he has said yes so often shows his extraordinary commitment to teaching and learning.”

Hemel, professor of law, was recognized for generating “considerable interest and enthusiasm in the tax field”—an area of study that many of his students said they hadn’t previously considered pursuing. His courses consistently reach maximum enrollment capacity, with numbers “virtually unheard of” for specialized legal topics. Colleagues praised Hemel as “widely loved by our students” and “a core member of our 1L curriculum,” noting his lively, engaging teaching style that challenges while entertaining students. Many first-year students report that Hemel was their favorite teacher of the year.

“It is my honor to recognize my extraordinary colleagues—Rick, Brant, and Daniel—for the tremendous service they provide to our students and our institution,” says Dean Troy McKenzie ’00. “Their innovative approaches, student-centered teaching philosophies, and dedication exemplify NYU Law’s commitment to excellence in legal education.”

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https://taxprof.typepad.com/taxprof_blog/2025/05/hellwig-and-hemel-receive-the-2025-nyu-law-teaching-award.html

Following up on Friday’s post, Opposition Grows To ABA’s Proposal To Double The Experiential Learning Accreditation Requirement: David Yellen (former Dean, Miami), The ABA Standards and Regulatory Modesty:

I’d like to add a few thoughts to Dan Rodriguez’s recent posts about the accreditation work of the Council of the ABA Section on Legal Education. Like Dan, I have viewed calls for the replacement of the Council as law school accreditor as misguided. As Barry Currier argues compellingly, having a national “approver” for bar licensing purposes is essential. Despite what I view as a very mixed record by the Council, I have no reason to think that a newly constituted entity would represent a significant improvement, to say nothing of the enormous transition costs involved. And I certainly have no confidence in the Trump Administration’s approach to accreditation “reform”.

That said, some of the Council’s recent actions makes defending it difficult. Derek Muller has explored some of the Council’s overreach. Most notably, the Council has sent out for notice and comment two proposals that, taken together, would represent the most radical intrusion into the operation of law schools that I can recall. One is a proposal to double the number of required experiential learning credits from 6 to 12. The other is to mandate tenure or tenure-like protections for all full time law faculty, including clinical faculty, legal writing faculty and academic support/bar preparation instructors. …

[I]n my view, the Council too often seems to disregard the limited nature of the accreditation function. As someone who serves on another accrediting body and who has worked with a handful of other accreditors at the university level, I urge the Council to adopt a posture of regulatory modesty and restraint. The Standards should be limited to rules that are reasonably necessary to ensure a quality legal education experience. They should not be a formalization of what some believe to be best practices. Judged on that basis, the Standards are dramatically more detailed and intrusive than the rules governing any other professional education field. The ABA Task Force on the Future of Legal Education, on which I served, had it right over a decade ago when it urged that “a number of the Standards be repealed or dramatically changed.” The Standards too often burden law schools in ways that raise costs and inhibit innovation. They need to change direction before it is too late.

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https://taxprof.typepad.com/taxprof_blog/2025/05/yellen-the-aba-standards-and-regulatory-modesty.html

Today’s Law, Society, and Taxation panels at the 2025 Law & Society Association Annual Meeting in Chicago:

Local Governments and Tax Benefits

As state governments think about imposing tax within their own borders they are faced with the additional challenges of balancing their state-level taxes with the U.S. federal tax. This same balance also arises in other contexts, such as the balance between national and EU tax law. The papers in this panel explore what this balancing process looks like in various contexts, and attempts to address some of the significant challenges that can arise as a result.

• Assaf Harpaz (Georgia; Google Scholar) (chair/discussant)
• Heather Field (UC Law-SF; Google Scholar), Selling Tax Benefits
• Borbala Kolozs, Taxation and Animals
• Richard Winchester (Brooklyn), A Tax Policing Paradox
• Alex Zhang (Emory; Google Scholar), Fiscal Autonomy in Subnational Taxation

The Black Tax: 150 Years of Theft, Exploitation, and Dispossession in America

This will be an Author Meets Reader session on Andrew Kahrl’s book The Black Tax: 150 Years of Theft, Exploitation, and Dispossession in America, published by the University of Chicago Press in 2024. Kahrl’s book tells the long history of racial discrimination and inequity in local tax systems and African Americans’ struggle for tax justice in America. It re-examines the entire sweep of African American and American history since 1865 through a fiscal lens, showing how local tax administration and enforcement became (and remains) a powerful force of inequality in housing, education, public health, and wealth in America and a key arena of struggle. Kahrl’s book makes interventions into several areas of scholarship of particular interest to legal scholars. This panel brings together top scholars in those fields to assess Kahrl’s book.

• Andrew Kahrl (Virginia) (author)
• Robert Manduca (Michigan; Google Scholar)
• Thomas Mitchell (Boston College; Google Scholar)
• Beryl Satter (Rutgers; Google Scholar)

Technology, Data, and Tax Law

Just like all other areas of law, the tax law faces new and different challenges in contemplating how best to respond to the worlds of artificial intelligence, crypto-currencies, and other technologies. The papers in this panel investigate these challenges and others and propose solutions that solve some of the most intractable elements of the problems. At the same time, additional potentially as yet unconsidered difficulties are also identified.

• Emily Cauble (Wisconsin; Google Scholar) (chair/discussant)
• Joshua Blank (UC-Irvine; Google Scholar), Chapter 10: The Future of Agency Communications (with Leigh Osofsky (North Carolina; Google Scholar))
• Mirit Eyal (Alabama; Google Scholar), Tax Levers For A Safer AI Future (with Yonathan A. Arbel (Alabama; Google Scholar))
• Amanda Parsons (Colorado; Google Scholar), Digitalization, Inequality, and the New Political Economy of Wealth and Capital Income Taxes
• Limor Riza (Carmel Academic Center), Proposal For A Subsidy Law – The Solution For “Probably None Of Us Will Have A Job”

Political Economy and Tax Theory

At the heart of many discussions of tax policy is a question of whether the tax law achieves the right end, for all people affected by it, and how best to design the tax to achieve the desired ends. The papers in this session tackle these essential, and difficult, questions from a variety of angles, contemplating theories of tax and tax policy design. While each paper contemplates a different aspect of tax system design, the papers in this session are concerned with asking about both the theoretical justifications and the effects of particular tax decisions.

• Elaine Wilson (West Virginia; Google Scholar) (chair/discussant)
• Jennifer Bird-Pollan (Wayne State; Google Scholar), The State and Local Tax Deduction Cap and the Marriage Penalty
• Luis Calderon Gomez (Cardozo; Google Scholar), Charity’s Limits
• Rory Gillis (Western University; Google Scholar), Distributive Purposes in Tax Case Law
• Christine Speidel (Villanova; Google Scholar), Building a Trauma Informed Tax System

Editor’s Note: If you would like to receive a daily email with links to tax posts on TaxProf Blog, email me here.

https://taxprof.typepad.com/taxprof_blog/2025/05/todays-law-society-and-taxation-panels.html

The Recorder, State Bar Acknowledges Scoring Errors, Including Swapped Essays, on February Exam:

California’s state bar on Wednesday acknowledged scoring problems on the February 2025 exam that led to four applicants being told incorrectly that they had failed the test.

In an email to February test-takers, a statement attributed to the bar’s office of admission said that a manual review of thousands of exams revealed that three applicants were graded on essays submitted by other people. …

Wednesday’s revelations are just the latest troubles for a test marked by planning foul-ups, technical meltdowns and a surprise announcement that some of the questions were crafted using artificial intelligence.

“We understand how frustrating the past several months have been for many of you, and we apologize,” the statement said. “In recognition of both the need for greater transparency around and confidence in the scoring process, as well as the significant demands on staff who are necessarily focusing on planning for a successful July bar exam administration, the State Bar will engage an independent third party to manage a comprehensive review of all concerns expressed about scoring and grading.”

Reuters, California Bar Exam-Takers Were Told They Failed. Oops, They Passed.:

The State Bar of California said on Wednesday that a number of scoring errors had occurred on its February bar exam — the latest black eye for the disastrous test plagued by logistical and technical issues.

A review of the February exam’s scoring revealed three separate categories of mistakes, which resulted in four examinees going from failing to passing after those problems were corrected, the bar said in an email to test takers that Reuters reviewed.

• Bloomberg Law, Three California Bar Exam Takers Were Scored on Others’ Work
• The Recorder, From Distress to Gratitude: How a Bar Exam Scoring Snafu Put One Applicant on Emotional Roller Coaster

Prior TaxProf Blog coverage:

• California Bar Exam Suffers Catastrophic Meltdown: ‘I’ve Never Had This Much Despair And Hopelessness’ (Feb. 27, 2025)
• The California Bar Exam Fiasco: Is Provisional Licensure The Appropriate Remedy? (Mar. 1, 2025)
• New York Times: California Bar Exam Fiasco Enrages Test Takers And Clouds Their Futures; Chemerinsky Calls For Provisional Licensure (Mar. 3, 2025)
• 17 Deans Ask California High Court To Provisionally License Grads Who Fail February Exam And Scrap New Kaplan-Written Questions And Revert Back To In-Person Exams In July (Mar. 4, 2025)
• California Supreme Court Reverts Back To In-Person Bar Exam In July (Mar. 5, 2025)
• Law Profs: California State Bar Must Be Held Accountable For Its Catastrophic Failures (Mar. 6, 2025)
• California Bar Orders Investigation Of February Exam Disaster As Beleaguered Test-Takers Fume (Mar. 9, 2025)
• California Bar Blocked Law School Deans And Professors From Vetting Troubled Bar Exam (Mar. 15, 2025)
• California Bar Recommends Provisional Licensure For All Who Failed And Withdrew From The February Bar Exam (Mar. 16, 2025)
• State Bar Of California Announces Remediation Actions For The February Bar Exam And Plans For The July Bar Exam (Mar. 18, 2025)
• California Bar Still Can’t Decide How To Make Applicants Whole After Botched February Bar Exam (Apr. 8, 2025)
• California Bar Allowed Non-Lawyers To Use AI To Draft February Exam Questions, Will Ask Supreme Court To Lower Cut Score (Apr. 23, 2025)
• California Supreme Court Demands Answers From State Bar On Its Use Of AI In Preparing Bar Exam Questions (Apr. 26, 2025)
• Pressure Grows On California Bar To Switch To NCBE For July Exam Following February Exam Debacle (Apr. 28, 2025)
• California Bar Delays Release Of Results Of Catastrophic February Exam, Further Punishing Applicants (Apr. 30, 2025)
• California Supreme Court Lowers Passing Score on February Bar Exam, Orders Return to Multistate Exam in July (May 5, 2025)
• Pass Rate On February 2025 California Bar Exam Hits All-Time High, Due To Lowered Passing Score And Bonus For Taking Experimental Test (May 6, 2025)
• California Bar Backs Provisional Licensure For Those Who Withdrew From Or Failed Botched February Exam (May 13, 2025)

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https://taxprof.typepad.com/taxprof_blog/2025/05/california-bar-cops-to-multiple-scoring-errors-on-disastrous-february-bar-exam-third-party-will-do-a.html

Reid Kress Weisbord (Rutgers) & Naomi Cahn (Virginia), Repealing the Estate Tax Could Create Headaches For the Rich – As Well As Worsen Inequality:

Nothing is more certain than death and taxes, Benjamin Franklin famously declared. And, since 1916, the federal government has imposed an estate tax on the transfer of property owned at death.

But the Trump administration and Republican lawmakers may be on the verge of changing all that. GOP legislators are now considering a massive bill that includes major tax law changes and could pass by June or July 2025. Among the measures under consideration in both the House and Senate is the Death Tax Repeal Act, which would end the federal estate tax and reduce the tax rate on lifetime gifts. …

As law professors who specialize in trusts and estates, we’re interested in what might happen next. Interestingly, while the long-term impact to the federal budget would be significant, repealing the estate tax would complicate estate planning for the wealthy taxpayers who might not save all that much money. …

The bottom line is that repealing the estate tax may hurt both taxpayers and the government. People with sufficient wealth to exhaust the high exemption are likely to have established estate plans that can’t be changed to benefit from estate tax repeal. Meanwhile, for new estate plans that seek to retain property ownership until death, the government will lose an important source of tax revenue – $22.5 billion in 2022 – collected from a tiny number of very wealthy estates that can afford to pay the tax.

And, of course, repeal would also abandon the original purpose of the estate tax, which sought to reduce extreme concentrations of wealth.

Editor’s Note: If you would like to receive a daily email with links to tax posts on TaxProf Blog, email me here.

https://taxprof.typepad.com/taxprof_blog/2025/05/repealing-the-estate-tax-could-create-headaches-for-the-rich-and-worsen-inequality.html

Hilary G. Escajeda (Mississippi College; Google Scholar), Taylor Swift, Tortured Poets, and the Tax Code’s Frankenstein, 125 Colum. L. Rev. F. 75 (2025):

Taylor Swift’s songs inspire generations of fans to sing and dance about love and to “shake . . . off” heartbreak. Swift’s hard-earned “reputation” for being a savvy music mogul inspires other creative spirits to be “fearless” in their artistic endeavors. But unless these artists are songwriters and musicians, they should keep their “eyes open” when selling their works, as they may see “red” when they discover their tax rates.

The simple fact is that a taxpayer’s financial ability to live out their “wildest dreams” may turn on their chosen artistic medium. Notably, the Internal Revenue Code taxes the sale of poems differently than the sale of songs. As a result, in most cases, poets will be subject to ordinary income tax rates, while songwriters may be eligible for preferential capital gains treatment.

This Piece explores how U.S. tax laws breed “bad blood” between poets and songwriters who sell their creative work products. It then argues that sound public policy requires Congress to take responsibility for the “tax Frankenstein” it has created by articulating consistent policies for taxpayers who sell or dispose of their artistic works.

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https://taxprof.typepad.com/taxprof_blog/2025/05/taylor-swift-tortured-poets-and-the-tax-codes-frankenstein.html