Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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ABA Tax Section Submits Comment Letters
Treatment of Interests in Money Market Mutual Funds Under § 856(c)(4)(A) Reform of Federal Civil Tax Penalties Funding of the IRS
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Student Comments & Notes in ABA Tax Lawyer
Here are the four student comments and notes in the latest issue of The Tax Lawyer (Vol. 62, No. 1): Christopher W. Livingston, Comment, Finding the Right Balance: A Critical Analysis of the Major Proposals to Reform the Taxation of Carried Interests in Private Equity, 62 Tax Law. 241 (2008) Hanna M. Chouest, Note, Dot All…
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Zotos: The Standard of Review in Collection Due Process Appeals
Nick A. Zotos (Satterlee Stephens Burke & Burke, New York) has published Service Collection Abuse of Discretion: What is the Appropriate Standard of Review and Scope of the Record in Collection Due Process Appeals?, 62 Tax Law. 223 (2008). Here is part of the Introduction: In 1998, Congress significantly altered the landscape of Service collection…
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Occhuizzo: Taxing Tenure
Nicole Occhuizzo (Ivins, Phillips & Barker, Washington, D.C) has published Taxing Tenure: An Examination of How the Federal Insurance Contribution Act (FICA) Has Been Applied to Tenure Buyouts, 62 Tax Law. 189 (2008). Here is part of the Introduction: In recent years, three federal courts of appeals have considered the question of whether early retirement payments…
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Gesikohas: Protection of Taxpayer Information in the Internet Age
Agnes Gesikohas (Foley & Lardner, San Diego) has published The Protection of Taxpayer's Federal Tax Return Information in the Internet Age—Is Tax Return Information Being Afforded Proper Confidentiality and Privacy Protections, 62 Tax Law. 175 (2008). Here is part of the Introduction: The Service and taxpayers disclose federal tax return information (FTI) in a variety…
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Brown: The Character of § 357(c) Gain
Fred B. Brown (Baltimore) has published Determining the Character of Section 357(c) Gain, 62 Tax Law. 117 (2008). Here is the abstract: Under § 351, a person transferring property to a controlled corporation generally recognizes no gain or loss on the transaction. An exception to tax-free treatment is contained in § 357(c), which generally provides…
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Elkins & Hanna: Taxation of Supernormal Returns
David Elkins (SMU & Netanya School of Law) & Christopher H. Hanna (SMU) have published Taxation of Supernormal Returns, 62 Tax Law. 93 (2008). Here is part of the Introduction: In the last ten to fifteen years, a number of articles have been written on the differences between a normative income tax system and a…
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Burke & McCouch: COBRA Strikes Back: Anatomy of a Tax Shelter
Karen C. Burke (San Diego) & Grayson M.P. McCouch (San Diego) have published COBRA Strikes Back: Anatomy of a Tax Shelter, 62 Tax Law. 59 (2008). Here is the abstract: Paul Daugerdas gained notoriety for himself and his erstwhile firm, Jenkens & Gilchrist, as the designer of a tax shelter that uses contingent liabilities to generate…
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Kahn: The Transfer of a Compensatory Partnership Interest
Douglas A. Kahn (Michigan) has published The Proper Tax Treatment of the Transfer of a Compensatory Partnership Interest, 62 Tax Law. 1 (2008). Here is the Introduction: If a person receives property as payment for services, whether for past or future services, the receipt typically constitutes gross income to the recipient. If a person performs…
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ABA Tax Section Offers Webcast Today on Tax Issues of the Madoff Scandal
The ABA Tax Section offers a teleconference and webcast today on Tax Issues of the Madoff Scandal: Advising Victims of Investment Fraud from 1:00 – 2:30 p.m. EST: Fraudulent schemes by supposedly reputable investment advisors have left their investor-victims trying to determine what to do. These victims need guidance on the tax and other implications of their…
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Careers in Tax Law for Chicago Area Tax Students
The ABA Tax Section hosts Careers in Tax Law today for Chicago area tax students at John Marshall: The Section of Taxation co-hosts Careers in Tax Law panels at various law schools around the country to introduce J.D. and LL.M. students to careers available in the tax practice area. The career panels typically include three to…
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ABA Tax Section Accepting Nominations for 2010-2012 Public Service Fellowships
The ABA Tax Section is accepting applications for Public Service Fellowships for 2010-2012: Applications must be received by August 1, 2009 to be considered. Applicants selected for interviews will be invited to attend the Section’s meeting in Chicago on September 25-26, 2009, and asked to participate in interviews on September 26, 2009. The Section will…
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Careers in Tax Law Today for Washington, D.C. Area Tax Students
The ABA Tax Section hosts Careers in Tax Law today for Washington, D.C. area tax students at Georgetown: The Section of Taxation co-hosts Careers in Tax Law panels at various law schools around the country to introduce J.D. and LL.M. students to careers available in the tax practice area. The career panels typically include three…
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Call for Tax Papers: ABA Tax Lawyer
The ABA Tax Section has issued a call for articles for the 2009 issue of The Tax Lawyer — The State and Local Tax Edition (SALTE): The SALTE features legal scholarship devoted to state and local taxation and is distributed to all members of the ABA Tax Section's membership, as well as other subscribers. As…
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ABA Tax Section Kicks Off 5-Day Tax CLE Program
The ABA Tax Section kicks off a five-day Advanced Tax CLE Program today in New Orleans: Advanced Income Tax Sales/Use Tax Advanced Property Tax
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ABA Tax Section Offers Webcast Today on Challenging the Validity of Treasury Regulations
The ABA Tax Section offers a teleconference and webcast today on This Treas. Reg. is Wrong! Substantive and Procedural Challenges and Standards of Review for Attacking Department of Treasury Tax Regulations from 1:00 – 2:30 p.m. EST: This panel will discuss the issues raised or settled by the recent Third Circuit decision in Swallows Holding v. Commissioner,…
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ABA Tax Section Submits Comment Letter on Proposed § 108 Regs
The ABA Tax Section has submitted a comment letter on the Proposed § 108 Regs on the Reduction of S Corporation Tax Attributes. Here is the Executive Summary:
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ABA Tax Section Publishes Winter 2009 Issue of News Quarterly
The ABA Tax Section has published 28 News Quarterly No. 2 (Winter 2009): Section Meeting Spotlight: Estate Planning for Boomers and Beyond Estate Planning for the Baby Boomers: Will They Have Estates to Plan?, by Amy Morris Hess (University of Tennessee College of Law) (pp. 1, 13-14) What a Difference a Generation Makes: Tax, Estate, and…
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Call for Editors: ABA Annual Reports on Important Tax Developments
The ABA Tax Section produces an Annual Reports on Important Developments, which tracks the key legislative changes, regulations, cases, and rulings over the past year, as well as forecasts upcoming developments, in over thirty substantive areas of the tax law. Steve Black (Franklin Pierce) is coordinating this year's effort and reports that editors are needed…
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ABA Tax Section Offers Webcast Today on Report of National Taxpayer Advocate Olson
The ABA Tax Section offers a teleconference and webcast today on Report of the National Taxpayer Advocate Nina Olson from 1:00 – 2:30 p.m. EST: The ABA Section of Taxation is pleased to present a special 90-minute teleconference featuring Nina Olson, IRS National Taxpayer Advocate, who will discuss the major findings and recommendations from the National…
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted comment letters on: Notice 2008-19 and Segregated Arrangements That Do Not Involve Insurance Transfer Pricing as Related to Enhancing Canada’s International Tax Advantage
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Student Comments & Notes in ABA Tax Lawyer
Here are the students comments and notes in the latest issue of The Tax Lawyer (Vol. 61, No. 4): Evan M. Stern, Comment, The Import-Export Clause and Territorial Taxation, 61 Tax Law. 1245 (2008) Matthew Harris, Note, Commissioner v. Dunkin: The Ninth Circuit’s Novel Tax Treatment of Deferred Compensation of Divorced Spouses, 61 Tax Law.…
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Stombock: Economic Nexus and Nonresident Corporate Taxpayers
Megan A. Stombock (Cadwalader, Wickersham & Taft, New York) has published Economic Nexus and Nonresident Corporate Taxpayers: How Far Will It Go?, 61 Tax Law. 1225 (2008). Here is the Introduction: Article I, Section 8, Clause 3 of the U.S. Constitution, known more commonly as the Commerce Clause, grants Congress the power to regulate interstate commerce. The U.S. Supreme Court held in…
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Glickman & Calhoun: The “States” of the Federal Common Law Tax Doctrines
Jeffrey C. Glickman & Clark R. Calhoun (both of Alston & Bird, Atlanta have published The "States" of the Federal Common Law Tax Doctrines, 61 Tax Law. 1181 (2008). Here is part of the Introduction: This Article focuses on states’ attempts to apply the federal anti-avoidance doctrines to state tax transactions. Since 2000, there has been considerably more activity…
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Wright: Using Retroactive Taxes to Cure Budget Shortfalls
Kathleen K. Wright (California State University-Fullerton, Mihaylo College of Business and Economics) has published Using Retroactive Taxes to Cure Budget Shortfalls, 61 Tax Law. 1153 (2008). Here is the Introduction: New legislation limiting the amount of refunds available for LLCs who have qualified to do business in California and have paid the fee based on unapportioned gross receipts is being…