Author: Paul Caron
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Call for Participants: 5th Annual Junior Tax Scholars’ Workshop
The fifth annual Junior Tax Scholars' Workshop will be held this year at Notre Dame Law School from the evening of Thursday, June 10th through Saturday, June 12th. The workshop is an opportunity for junior tax faculty to meet each other and to present works-in-progress in a supportive environment. All participants present a work-in-progress, are
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Private Colleges Give 53.5% Discount Off Advertised Tuition Rate
Inside Higher Ed, Slashing Prices: Tuition discounting reached record high levels at private colleges and universities in 2008, and the largest share of that aid was awarded without consideration of students’ financial need, according to a report released Tuesday the National Association of College and University Business Officers (NACUBO). The average discount rate for full-time
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Polsky: Deterring Tax-Driven Partnership Allocations
Gregg Polsky (Florida State; moving to North Carolina) has posted Deterring Tax-Driven Partnership Allocations on SSRN. Here is the abstract: How to allocate a partnership’s tax items is the most fundamental issue in subchapter K of the Internal Revenue Code, which governs the taxation of limited liability companies, limited liability partnerships, limited partnerships, general partnerships,
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ABA Tax Section Webcast Today on The Economic Substance Doctrine
The ABA Tax Section offers a teleconference and webcast today on The Economic Substance Doctrine from 1:00 – 2:30 p.m. EST: The new health care legislation contains a codification or "clarification" of the economic substance doctrine. This teleconference will examine what the new statutory language says and how it came about. The panelists will also review recent case law,
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Former Arnold & Porter Tax Partner Gets Three Years Probation in Tax Shelter Case
Former Arnold & Porter tax partner Peter Cinquegrani was sentenced Tuesday to three years probation following his guilty plea to marketing fraudulent tax shelters. He was disbarred last year. ABA Journal Bloomberg JD Journal New York Law Journal Reuters
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TaxProf – Tax Analysts Partnership
I am delighted to announce that Tax Analysts has agreed to partner with TaxProf Blog in making some of its wonderful content available to the broader tax community. In particular, each week I will post three full-text items from Tax Notes Today, State Tax Today, and Worldwide Tax Daily. And of course, all Tax Analysts content is available through the LexisNexis®
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The IRS Has Sufficient Administrative Authority to Enforce ObamaCare’s Individual Mandate
Following up on this morning's post, Joint Tax Committee: IRS Lacks Authority to Enforce ObamaCare's Individual Mandate: Tax Profs Ted Seto and Bryan Camp argue that the Joint Committee on Taxation overstated the limitations on the IRS's ability to enforce ObamaCare's individual mandate: Theodore Seto (Loyola-L.A.): In its Technical Explanation of the Revenue Provisions of the Reconciliaton
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“The GAAP Conspiracy Against ObamaCare”
The Atlantic, Henry Waxman's War on Accounting: Accounting basics: when a company experiences what accountants call "a material adverse impact" on its expected future earnings, and those changes affect an item that is already on the balance sheet, the company is required to record the negative impact–"to take the charge against earnings"–as soon as it
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The World’s Strangest Tax Laws
Foreign Policy, The World’s Strangest Tax Laws — my favorite: World Cup Tax Exemption Countries: World cup hosts Who‘s affected: South African residents, nonresidents The bottom line: South Africa is understandably thrilled to be hosting the 2010 World Cup, which opens June 11. A financial boost is expected as infrastructure improvements reach a massive scale and
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Tax Freedom Day Is April 9 — Earlier in AK, LA & MS, Later in CT, NJ, NY
The Tax Foundation today announced that April 9 is Tax Freedom Day, the day on which Americans will have earned enough money to pay all federal, state, and local taxes for the year: Tax Freedom Day will arrive on April 9 this year, the 99th day of 2010, according to the Tax Foundation’s annual calculation using
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Avi-Yonah: Xilinx Revisited
Reuven S. Avi-Yonah (Michigan) has published Xilinx Revisited, 126 Tax Notes 1621 (Mar. 29, 2010). Here is the abstract: In this article, Avi-Yonah argues that the original Xilinx panel decision was correct and that the new one was the result of the government's refusal to accept the rationale of that decision. However, he also believes
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Farewell, Malibu
I am back in Cincinnati after spending spring break in Malibu, California, teaching a one-week course at Pepperdine University School of Law. It was a spectacular week in all respects. The course, Selected Advanced Topics in Federal Income Taxation, went very well. Although we designed our Tax Stories book to be used either as supplemental reading for the basic tax course or as the
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Joint Tax Committee: IRS Lacks Authority to Enforce ObamaCare’s Individual Mandate
Big Government, Joint Committee on Taxation Confirms that ObamaCare Does Not Enforce Individual Mandate: One of the more controversial elements of ObamaCare is the mandate for most individuals to purchase insurance beginning in 2014. There is really no precedent for a federal mandate of this scale requiring individuals to purchase a product or service. So
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Mason: Made in America for European Tax
Ruth Mason (UConn) presented Made in America for European Tax: The Internal Consistency Test, 49 B.C. L. Rev. 1277 (2008), as part of the Lisbon International and EC Tax Law Seminar:
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The Flat Tax: How it Works and Why it is Good for America
A new video released yesterday by the Center for Freedom and Prosperity Foundation (CF&P) explains "why a flat tax would be superior to the internal revenue code. Entitled "The Flat Tax: How it Works and Why it is Good for America," the mini-documentary includes a 20-second tutorial showing the simple postcard-sized tax forms that would replace
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Will a Tax LL.M. Cleanse a 4th Tier, Bottom of the Class J.D.?
New York Law Journal, Advice for the Lawlorn: Question: I graduated from law school last summer. I went to a fourth tier school and graduated near the bottom of my class. … When I came back to my hometown, I took a few LLM classes as a non-degree student at a top tier school and got
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NLJ: The 40 Most Influential Lawyers, 2000-2009
National Law Journal, The Decade’s Most Influential Lawyers: These are the lawyers who’ve defined a decade. For our annual Most Influential Lawyers special report, the editors of The National Law Journal have selected 40 attorneys in a dozen key legal areas whose work between Jan. 1, 2000, and Dec. 31, 2009, was so consequential that
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NY Times: States Seeking Cash Hope to Expand Taxes to Services
New York Times, States Seeking Cash Hope to Expand Taxes to Services: In the scramble to find something, anything, to generate more revenue, states are considering new taxes on virtually everything: garbage pickup, dating services, bowling night, haircuts, even clowns. … Opponents of imposing taxes on services like funerals, legal advice, helicopter rides and dry
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Tax Profs on Chapman’s Dean Search Committee
Tax Profs Bobby L. Dexter and Francine J. Lipman are serving on Chapman University School of Law's Dean Search Committee.
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Hellerstein & Swain: State & Local Tax Commentary
Walter Hellerstein (Georgia) & John A. Swain (Arizona) have published State & Local Tax Commentary (March 2010): Professors Hellerstein and Swain examine (1) the proper measure of receipts from intangibles for sales factor computation purposes; (2) the proper attribution of receipts from yellow page advertising for apportionment purposes; (3) a Texas case applying the sale-for-resale
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Chutzpah: Rep. Rangel Offers Tax Advice to His Constituents
Charlie Rangel, who has taken a leave of asbsence from chairing the House Ways & Means Committee while the House Ethics Committee investigates reports that he dodged his taxes, has sent a tax advice flyer to his constituents. DNAinfo, Harlem Rep. Charlie Rangel Offers Tax Advice Despite His Own Tax Woes Going Concern, The Irony of
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Law Library Rankings
What Makes a Great Library (National Jurist (March 2010)): Many thought that the digital age would render brick-and-mortar libraries obsolete. But the modern-day law library has emerged as a vital center for learning and research that’s busier than ever. We rank 198 law libraries for resources, services, and space. 25%: volumes 25%: titles 20%: library seats per student
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Welcome to the Tax Blogosphere: Tax Blawg
Chamberlain, Hrdlicka, White, Williams & Martin (West Conshohocken, PA) has launched Tax Blawg, describe das "Tax Talk for Tax Pros": A resource for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20 blawgs related to taxation and estate planning, the needs of tax professionals have received
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IFA International Tax Student Writing Competition
The International Fiscal Association is sponsoring the 2010 International Tax Student Writing Competition: Subject: Any topic relating to U.S. taxation of income from international activities, including taxation under U.S. tax treaties. Open to: All students during the 2009-10 academic year pursuing a graduate degree with a tax specialty. Submission Deadline: September 30, 2010. Prize: $2,000 cash, plus
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TaxProf Blog Weekend Roundup
Saturday: Tax Lawyer Staged Suicide to Look Like Murder Saturday at the IRS Tax Articles in The Urban Lawyer Court Rejects NYLS Grade Complaint New York's Amazon Tax and the Battle Over Affiliate Nexus Sunday: Top 5 Tax Paper Downloads President Obama Makes Two Tax Recess Appointments Students Who Visit College on a Cloudy Day