Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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LePree: The Application of the § 514 Debt-Financed Rules to Hedge Funds and Derivatives
Summer A. LePree (Holland & Knight, Miami) has published Taxation of United States Tax-Exempt Entities’ Offshore Hedge Fund Investments: Application of the Section 514 Debt-Financed Rules to Leveraged Hedge Funds and Derivatives and the Case for Equalization, 61 Tax Law. 807 (2008). Here is the abstract: Several tax issues involving hedge funds have been receiving…
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Todres: Tax Malpractice Damages
Jacob L. Todres (St. John’s) has published Tax Malpractice Damages: A Comprehensive Review of the Issues, 61 Tax Law. 705 (2008). Here is the abstract: Suits to redress instances of tax malpractice may be framed either in tort or in contract. While some ancillary aspects of the litigation may differ, a professional must exercise reasonable…
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Gibbs: 2008 Griswold Lecture: Constancy and Change in Our Federal Tax System
Lawrence B. Gibbs (Miller & Chevalier, Washington, D.C.) has published 2008 Erwin L. Griswold Lecture Before the American College of Tax Counsel: Constancy and Change in Our Federal Tax System, 61 Tax Law. 673 (2008). Here is the Introduction: The opportunity to deliver this year’s Griswold Lecture is an honor for which I thank the…
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ABA Tax Section Offers Teleconference & Webcast Today on Origination and Restructuring Activity Consequences Under § 864(b)
The ABA Tax Section offers a teleconference and webcast today on Origination and Restructuring Activity Consequences Under Section 864(b) from 1:00 – 2:30 p.m. EST: Section 864(b)(2) provides a safe harbor under which foreign corporations that limit their activities to trading in stocks and securities (and derivatives) are not subject to U.S. federal income tax,…
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ABA Tax Section Fall Meeting
The three-day ABA Tax Section Fall Meeting concludes today in San Francisco. A list of TaxProfs with speaking roles today, and their topics, is below the fold:
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ABA Tax Section Fall Meeting
The three-day ABA Tax Section Fall Meeting continues today in San Francisco. A list of TaxProfs with speaking roles today, and their topics, is below the fold:
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ABA Tax Section Fall Meeting
The three-day ABA Tax Section Fall Meeting kicks off today in San Francisco. A list of TaxProfs with speaking roles today, and their topics, is below the fold:
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted comment letters on: Proposed Regs Under §§ 6694 & 6695 Proposed Regs Under § 2032 Relating to the Alternate Valuation Date Election Proposed Regs Under § 6503(j) Relating to the Suspension of the Limitations Period for Corporations Facing Designated or Related Summonses
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ABA Law Student Tax Challenge Releases This Year’s Problem
The ABA Section of Taxation Young Lawyers Forum yesterday released the Problem, updated rules (J.D.; LL.M.), and entry forms (J.D.; LL.M.) for the 8th Annual Law Student Tax Challenge: For the eighth consecutive year, the Young Lawyers Forum of the ABA Section on Taxation will sponsor its Law Student Tax Challenge competition. An alternative to…
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ABA Tax Section Offers Teleconference & Webcast Today on Tax Treatment of “Carried” Interests
The ABA Tax Section offers a teleconference and webcast today on Carried Away: A Discussion of the Current Tax Treatment of “Carried” Interests and the Prospects for Change from 1:00 – 2:30 p.m. EST: This panel will discuss a wide array of issues regarding “carried” and other compensatory interests, including their tax treatment under current…
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ABA Tax Section Publishes Summer 2008 Issue of News Quarterly
The ABA Tax Section has published 27 News Quarterly No. 4 (Summer 2008): 2008 Joint Fall CLE Meeting (p. 2) From the Chair (Stanley L. Blend) (pp. 3, 18) From the Chair-Elect (William J. Wilkins) (p. 4) Interview with Dr. Eric Toder (pp. 6-9) Points to Remember: Swallows Holding: Chevron‘s Growing Traction in Tax Litigation,…
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William Wilkins Named New ABA Tax Section Chair
William J. Wilkins, a tax partner of WilmerHale (Washington, D.C.), is the new chair of the ABA Tax Section. From the press release: Prior to joining WilmerHale, Wilkins served on the staff of the U.S. Senate Committee on Finance (1981-1998), including as staff director and chief counsel of the committee (1987-1988). Wilkins has previously served…
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ABA Tax Section to Award Two Public Service Tax Fellowships
The ABA Tax Section has announced that it will award two pro bono fellowships to recent law school graduates or judicial clerks for their work in tax-related public service organizations: The section is now accepting applications for those interested in the two annual fellowships. Applicants must arrange employment with a tax-related § 501(c)(3) organization of…
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ABA Tax Section Offers Teleconference & Webcast Today on Using State Law LLCs as S Corps
The ABA Tax Section offers a teleconference and webcast today on Using State Law Limited Liability Companies as S Corporations from 1:00 – 2:30 p.m. EST: Although LLCs have gained increasing popularity over the last decade, the number of entities taxed as S corporations still exceeds the number of entities taxed as partnerships for federal…
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Student Notes in ABA Tax Lawyer
There are four student notes in the latest issue of the ABA Tax Lawyer: Jonathan M. Burke, Note, A Critical Analysis of Glass v. Commissioner: Why Size Should Matter for Conservation Easements, 61 Tax Law. 599 (2008) Andrew Golodny, Note, Lawyers Versus Auditors: Disclosure to Auditors and Potential Waiver of Work-Product Privilege in United States…
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted comment letters on: Proposed Regulations Relating to Extensions of the Time Under § 2642(g)(1) Instructions for the Redesigned Form 990 for Tax-Exempt Organizations Notice 2007-88: Proposed Procedural Changes for Obtaining the Commissioner’s Consent to Change a Method of Accounting Proposed Regulations Under §§ 6011 & 6111 Relating to Patented…
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Jenn: The Case for Tax Credits
Brian H. Jenn (Skadden, Washington, D.C.) has published The Case for Tax Credits, 61 Tax Law. 549 (2008). Here is the Conclusion: Over the last few decades, Congress has increasingly relied on tax credits as an alternative to deductions and exclusions in the implementation of tax expenditures, particularly those meant to create incentives for certain…
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Berg: Judicial Deference to Tax Regulations
Mark E. Berg (Feingold & Alpert, New York,) has published Judicial Deference to Tax Regulations: A Reconsideration in Light of National Cable, Swallows Holding, and Other Developments, 61 Tax Law. 481 (2008). Here is part of the Conclusion: Although (or perhaps because) much ink has been spilled by courts and commentators regarding the standards to…
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Bamberg: A Different Point of Venue: The Plainer Meaning of Section 7482(b)(1)
James Bamberg has published A Different Point of Venue: The Plainer Meaning of Section 7482(b)(1), 61 Tax Law. 445 (2008). (The Article won first prize in the 2007 Tannenwald Tax Writing Competition sponsored by the American College of Tax Counsel.) Here is the Conclusion: Although the language of section 7482(b)(1), establishing venue in the D.C.…
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Infanti: Unfettering Zealous Advocacy on Behalf of Lesbian and Gay Taxpayers
Anthony C. Infanti (Pittsburgh) has published Deconstructing the Duty to the Tax System: Unfettering Zealous Advocacy on Behalf of Lesbian and Gay Taxpayers, 61 Tax Law. 407 (2008). Here is the abstract: In this article, I consider how the tax lawyer’s generally-acknowledged duty to the tax system should be applied in the representation of lesbian…
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IRS’s 2008 Nationwide Tax Forum Rolls Into Chicago Today
The IRS’s 2008 Nationwide Tax Forum rolls into Chicago today: The Tax Forums offer three full days of seminars with the latest word from the IRS leadership and experts in the fields of tax law, compliance and ethics. Attendees can earn up to 18 continuing professional education (CPE) credits, learn about the latest IRS e-Services…
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Ventry: Whistleblowers and Qui Tam for Tax
Dennis J. Ventry, Jr. (UC-Davis) has published Whistleblowers and Qui Tam for Tax, 61 Tax Law. 357 (2008). Here is the abtstract: This Article examines the underexplored IRS whistleblower program, which Congress revamped in December 2006 by, among other things, significantly expanding the size of rewards paid to informants. Increased monetary incentives for exposing tax…
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ABA Tax Section Offers Teleconference & Webcast Today on Review of Regs on Capitalization of Tangible Assets
The ABA Tax Section offers a teleconference and webcast today on Review of Regulations on Capitalization of Tangible Assets from 1:00 – 2:30 p.m. EST: In 2006, proposed regulations under § 263(a) were issued relating to amounts paid to acquire, produce, or improve tangible property and clarifying what amounts must be capitalized rather than deducted…
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ABA Tax Section Makes Recommendations on IRS’s Guidance Priority Plan
The ABA Tax Section has issued recommendations of guidance for inclusion in the 2008-2009 Treasury-IRS Guidance Priority List in the following areas: Capital Recovery and Leasing Corporate Tax Employee Benefits Energy and Environmental Taxes Exempt Organizations Low Income Taxpayers Partnerships and LLCs Tax Accounting
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ABA Tax Section Offers Teleconference & Webcast Today on Ethics for Tax Lawyers
The ABA Tax Section offers a teleconference and webcast today on Ethics for Tax Lawyers: Test Your Knowledge of the ABA Model Rules from 1:00 – 2:30 p.m. EST: The ABA’s Model Rules of Professional Responsibility have been adopted, with some modification, in the vast majority of states and, therefore, provide useful baseline guidance to…