Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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ABA Tax Section Offers Teleconference & Webcast Today on Recent State Tax Reforms: Ohio, Texas and Michigan
The ABA Tax Section offers a teleconference and webcast today on Update on Recent State Tax System Reforms (Case Studies: Ohio, Texas and Michigan) from 1:00 – 2:30 p.m. EST: This presentation will involve overviews and insights about Ohio’s Commercial Activities Tax (the "CAT"); the reformed Texas franchise tax (the "Margin Tax") and Michigan’s new…
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted comment letters on: Example 4 of Reg. § 1.367(b)-4(b)(1)(iii) Guidance under § 529 Funding of the Joint Committee on Taxation Correction Program for Nonqualified Deferred Compensation Plan Failures under § 409A Final Regs under § 337(d) Relating to Conversion Transactions
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ABA Tax Section Publishes Spring 2008 Issue of News Quarterly
The ABA Tax Section has published 27 News Quarterly No. 3 (Spring 2008): From the Chair (Stanley L. Blend) (pp. 3, 16) "Interview" with Ernest J. Brown (pp. 4-5) Ethics for the Tax Lawyer: Test Your Knowledge of the ABA’s Model Rules (pp. 6-10) Points to Remember: Antibribery Laws and the Tax Treatment of a…
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ABA Tax Section May Meeting
The ABA Tax Section’s three-day May Meeting concludes today at the Grand Hyatt in Washington, D.C. A list of Tax Profs with speaking roles today, and their topics, is below the fold.
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Student Notes in ABA Tax Lawyer
There are three student notes in the latest issue of the ABA Tax Lawyer: Natanyah Ganz, Note, Please Hang Up and Try Again: The Missouri Supreme Court Speed Dials Telephone Services into the Manufacturing Exemption Too Quickly in Southwestern Bell Telephone Co. v. Director of Revenue, 60 Tax Law. 1103 (2007) Christopher Klimmek, Note, Challenging…
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ABA Tax Section May Meeting
The ABA Tax Section’s three-day May Meeting continues today at the Grand Hyatt in Washington, D.C. A list of Tax Profs with speaking roles today, and their topics, is below the fold.
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Burns: ANR Pipeline: Beware of the Relief Sought
John B. Burns (Baker, Donelson, Bearman, Caldwell & Berkowitz, Memphis) has published ANR Pipeline: Beware of the Relief Sought, 60 Tax Law. 1087 (2007). Here is the Introduction: Recently, Louisiana’s courts were called upon to address the state’s disparate methods of assessing intrastate and interstate pipeline property for ad valorem tax purposes. On appeal, the…
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Graetz Delivers Woodworth Lecture on Tax Policy Today in D.C.
In keeping with tradition, the annual Laurence Neal Woodworth Lecture on Federal Tax Law and Policy will be given today at 5:00 p.m. at the first day of the May Meeting of the ABA Tax Section at the Grand Hyatt in Washington, D.C. Michael J. Gratez, Justus S. Hotchkiss Professor of Law at Yale Law…
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ABA Tax Section May Meeting
The ABA Tax Section’s three-day May Meeting kicks off today at the Grand Hyatt in Washington, D.C. Today’s highlight is the Laurence Neal Woodworth Lecture on Federal Tax Law and Policy at 5:00 p.m. (I will have more to say about this later today.) A list of Tax Profs with speaking roles today, and their…
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McKim: The Sometimes Dubious Efficacy of Michigan Department of Treasury Guidance
Samuel J., McKim, III (Miller, Canfield, Paddock & Stone, Detroit; Adjunct Professor, Wayne State) has published The Sometimes Dubious Efficacy of Michigan Department of Treasury "Rules," "Revenue Administrative Bulletins," "Letter Rulings," "Questions and Answers," and Other Publications, 60 Tax Law. 1019 (2007). Here is the Introduction: The Michigan Department of Treasury (Department) speaks with many…
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Herman: Options for Allocating Stock Option Income: New York’s New Allocation Rules
Debra Silverman Herman (Roberts & Holland, New York) has published Options for Allocating Stock Option Income: New York’s New Allocation Rules and Their Effect on Taxpayers, Multistate Employers, and Other States, 60 Tax Law. 991 (2007). Here is the Introduction: Determining the allocation of income from stock options for nonresidents is inherently challenging, given the…
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Ohlenforst: The New Texas Margin Tax
Cynthia M. Ohlenforst (K & L Gates, Dallas) has published The New Texas Margin Tax: More Than a Marginal Change to Texas Taxation, 60 Tax Law. 959 (2007). Here is part of the Introduction: The new law, effective for reports filed on or after January 1, 2008, imposes an entirely new “margin tax” on taxpayers,…
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Tatarowicz: Federalism, the Commerce Clause, and Discriminatory State Tax Incentives
Philip M. Tatarowicz (Ernst & Young, Washington, D.C.; Adjunct Professor, Georgetown) has published Federalism, the Commerce Clause, and Discriminatory State Tax Incentives: A Defense of Unconditional Business Tax Incentives Limited to In-State Activities of the Taxpayer, 60 Tax Law. 835 (2007). Here is part of the Introduction: When a state or local tax incentive rewards…
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted comment letters on: IRS Funding Proposed § 125 Regulations Proposed Regulations Concerning Mergers Under § 704(c)(1)(B) and 737 Proposed and Temporary § 368(a)(1)(D) Regsulations 2007 Amendment to the § 6694 Preparer Penalty New Service Provider Exemption Under § 408(b)(17) of ERISA
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Student Notes in ABA Tax Lawyer
There are four student notes in the latest issue of the ABA Tax Lawyer: Note, Stefanie Benyard, The Comprehensive Interpretation of Section 7463(f) in Schwartz v. Commissioner, 61 Tax Law. 287 (2007) Note, Gregory W. Carey, Turn Off the Tape Recorder at Telephonic Collection Due Process Hearings: Why the District Court Was Wrong in Simien…
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Reilly & Rotkowski: The Discount for Lack of Marketability
Robert Reilly (Willamette Management Associates, Portland, OR) & Aaron Rotkowski (Obsidian Finance Group, Portland, OR) have published The Discount for Lack of Marketability: Update on Current Studies and Analysis of Current Controversies, 61 Tax Law. 241 (2007). Here is the Introduction: The difference in price an investor will pay for a liquid asset compared to…
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State & Local Tax Lawyer Publishes Tax Shelter Symposium
The ABA Tax Section has published its final edition of the State & Local Tax Lawyer, Vol. 11, No. 2 (Summer 2006), a tax shelter symposium issue. (As blogged here, there will now be an annual State & Local Tax Edition of The Tax Lawyer, beginning with the current issue (Vol. 60, No. 4 (Summer…
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Rothman: Translating Corporate Concepts into the Language of LLCs
Robert P. Rothman (Akin Gump Strauss Hauer & Feld, New York) has published Translating Corporate Concepts into the Language of LLCs, 61 Tax Law. 161 (2007). Here is the Introduction: As anyone who has ever tried to decipher an English-language instruction manual for a product made in China can attest, a literal translation of words…
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Keinan: Federal Taxation of Derivatives
Yoram Keinan (Michigan) has published United States Federal Taxation of Derivatives: One Way or Many?, 61 Tax Law. 81 (2007). Here is the Introduction: While derivatives have been utilized for almost a century, the use of derivatives has been exploding in the last two decades. The development of the tax rules, however, could not keep…
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ABA Tax Section Offers Teleconference & Webcast Today on New Return Preparer Standards and Proposed Regs
The ABA Tax Section offers a teleconference and webcast today on You May Be a Tax Return Preparer and Not Know It: The Latest on the New Return Preparer Standards and Proposed Regulations from 1:00 – 2:30 p.m. EST: Under new § 6694, effective for federal tax returns prepared after May 25, 2007, a tax…
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Shores: Textualism and Intentionalism in Tax Litigation
David F. Shores (Wake Forest) has published Textualism and Intentionalism in Tax Litigation, 61 Tax Law. 53 (2007). Here is the Introduction: Tax cases frequently turn on issues of statutory construction. The statute might be general in nature, such as section 162, which allows a deduction for “all the ordinary and necessary expenses paid or…
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Smith: The Deliberative Stylings of Leading Tax Law Scholars
Andre L. Smith (Florida International) has published The Deliberative Stylings of Leading Tax Law Scholars, 61 Tax Law. 1 (2007). Here is the Introduction: This Article examines the deliberative techniques of leading tax scholars as gleaned from articles they have written. It compares their deliberative or interpretative prescriptions to the nine Supreme Court tax cases…
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State & Local Tax Edition of The Tax Lawyer
The ABA Tax Section has ceased publication the State & Local Tax Lawyer and instead will have an annual State & Local Tax Edition of The Tax Lawyer, beginning with the current issue (Vol. 60, No. 4 (Summer 2007)) with these pieces: Articles Federalism, The Commerce Clause, and Discriminatory State Tax Incentives: A Defense of…
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ABA Tax Section Offers Teleconference and Webcast Today on Report of National Taxpayer Advocate Nina Olson
The ABA Tax Section offers a teleconference and webcast today on Report of National Taxpayer Advocate Nina Olson from 1:00 – 2:30 p.m. EST: The Tax Section 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 Taxpayer Advocate’s…
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ABA Tax Section Publishes Winter 2008 Issue of News Quarterly
The ABA Tax Section has published 27 News Quarterly No. 2 (Winter 2008): From the Chair (Stanley L. Blend) (pp. 3, 18) Interview with Karen Gilbreath-Sowell (Deputy Assistant Secretary for Tax Policy) (pp. 4-7) News Briefs (pp. 7, 23) Points to Remember: Are Type III Supporting Organizations the New Private Foundations?, by Jocelyne C. Miller…