Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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Katz on The Art of Taxation
Farley P. Katz (Partner, Strasburger & Price, San Antonio) has published The Art of Taxation: Joseph Hemard’s Illustrated Tax Code, 60 Tax Law. 163 (2006). Here is the Introduction: Tax codes are notoriously dull reading. They are devoid of interest to anyone but professionals trained in the arcane language of the tax laws who, even…
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ABA Tax Section Offers Teleconference & Webcast Today on New Transfer Pricing Regs
The ABA Tax Section offers a teleconference and webcast today on New Transfer Pricing Regulations on Services and Intangibles from 1:00 – 2:30 p.m. EST: In recent years, two of the most critical issues in international taxation have involved the transfer pricing treatment of related party services and intangibles transactions. This program will focus on…
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Peters & Miller on Apportionability in State Income Taxation
James H. Peters (Adjunct Professor, NYU Law School & Pace Business School) & Benjamin F. Miller (Counsel, Multistate Tax Affairs, California Franchise Tax Board) have published Apportionability in State Income Taxation: The Uniform Division of Income for Tax Purposes Act and Allied-Signal, 60 Tax Law. 57 (2006). Here is the Introduction: In 1954 the National…
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Kratzke on The (Im)Balance of Externalities in Employment-Based Exclusions from Gross Income
William P. Kratzke (Memphis) has published The (Im)Balance of Externalities in Employment-Based Exclusions from Gross Income, 60 Tax Law. 1 (2006). Here is the Introduction: Through the Internal Revenue Code, Congress implicitly defines, by design or by accident, what the nature of the employment relationship is, or can be. Through a pattern of employer deductions…
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ABA Tax Section Submits Comments on Proposed Amendments to U.S. Court of Federal Claims Rules
The ABA Tax Section has submitted comments to Edward J. Damich, Chief Judge of the U.S. Court of Federal Claims, on Proposed Amendments to the Rules of the U.S. Court of Federal Claims Concerning Assignment and Processing of Indirectly Related Tax Cases.
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ABA Tax Section Submits Comments on Options to Close the Tax Gap
The ABA Tax Section has submitted comments to the Senate Finance Committee on Additional Options to Improve Tax Compliance Prepared by the Staff of the Joint Committee on Taxation: Joint Committee on Taxation, Additional Options to Improve Tax Compliance (8/3/06) TaxProf Blog coverage
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Beale on Davis and the Constitutionality of Tax Exemptions for Home State Bonds
The ABA Tax Section has published the 2007 Winter issue of the NewsQuarterly. It features an interesting Point & Counterpoint on The Constitutionality of Tax Exemptions for Home State Bonds under the Dormant Commerce Clause, introduced by Christopher M. Pietruszkiewicz (LSU): The income tax system in Kentucky exempted interest on bonds issued by the Commonwealth…
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ABA Tax Section Comments
The ABA Tax Section has submitted a number of comments to Congress and the IRS recently, including: Proposed Regulations Under Sections 6011, 6111, and 6112 (3/5/07) Procedures for Requesting Accounting Method Changes (2/27/07) Proposed Increases in Civil and Criminal Penalties in S. 349, The Small Business and Work Opportunity Act of 2007 House Version (2/23/07)…
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ABA Tax Section Offers Teleconference & Webcast Today on Zero Basis
The ABA Tax Section offers a teleconference and webcast today on Zero Basis – Alive or Dead? from 1:00 – 2:30 p.m. EST: This teleconference will address the recent revocation of Rev. Rul. 74-503 [in Rev. Rul. 2006-2] and whether an issuing corporation does or should have a zero basis in its stock or debt.…
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ABA Tax Section Names 2007 Nolan Fellows
The ABA Tax Section has named its 2007 Nolan Fellows: Jennifer Alexander (Deloitte Tax, Washington, D.C.) Adam Cohen (Sutherland Asbill & Brennan, Washington, D.C.) Christopher D’Amico (Dean, Mead, Egerton, Bloodworth, Capouano & Bozarth, Orlando, FL) Thomas Greenaway (IRS Office of Chief Counsel, Boston, MA) Pete Lowy (Shell Oil, Houston TX) Brandee Tilman (Disney Corp., Glendale…
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ABA Tax Section Comments
The ABA Tax Section has submitted a number of comments to Congress and the IRS recently, including: Comments on Proposed Regs under § 1221(a)(4) (2/22/07) Comments on Patented Tax Strategies (2/21/07) Letter to Senate Finance Committee on New Revenue Provisions in Minimum Wage Bill (2/6/07) Comments on § 4965 (2/5/07) Letter on Legislative Process (2/2/07)…
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ABA Tax Section Urges IRS to Make Taxpayers Disclose Use of Patented Tax Strategies
The ABA Tax Section yesterday requested in an 8-page letter that the IRS require taxpayers to list the use of a patented tax strategy as a reportable transaction on their tax returns: These Comments were prepared by members of the Section’s Task Force on Patenting of Tax Strategies (the “Task Force”). Principal responsibility was exercised…
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ABA Tax Section Offers Teleconference & Webcast Today on Can Patents Restrict Our Advice To Our Clients?
The ABA Tax Section offers a teleconference and webcast today on Can Patents Restrict Our Advice To Our Clients? from 1:00 – 2:30 p.m. EST: Patents involving legal products and methods have the potential to reshape how we practice law. Today, tax, probate, and real property lawyers need to consider doing patent searches before offering…
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In Memoriam: Sherwin Palmer Simmons
Roberta Casper Watson (Trenam, Kemker, Scharf, Barkin, Frye, O’Neill & Mullis, St. Petersburg, FL) has published In Memoriam: Sherwin Palmer Simmons, 59 Tax Law. 937 (2007): On May 24, 2006, the Tax Section, the ABA, and the legal profession lost a legend. Sherwin Palmer Simmons, who dedicated much of his life to the ABA, ALI,…
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ABA Tax Section Offers Teleconference & Webcast Today on Tax Practitioner Penalties
The ABA Tax Section offers a teleconference and webcast today on Tax Practitioner Penalties: A Primer from 1:00 – 2:30 p.m. EST: The last several years of tax enforcement have focused unprecedented attention on tax professionals and the standards under which they provide their services. As a result of this push toward greater accountability, tax…
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2006 Law Student Tax Challenge Results
Last Wednesday, we blogged the results of the the ABA Tax Section’s 2006 Law Student Tax Challenge. The ABA Tax Section has now put the results on its web site, along with a full listing of the 42 teams that entered the competition and their coaches. (For more details, see the ABA press release.) The…
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ABA Offers Teleconference & Webcast Today on Tax Issues in Divorce
The ABA Section of Family Law offers a teleconference and webcast today on Tax Issues Relating to Asset Divisions in Divorce from 1:00 – 2:30 p.m. EST: During a divorce, the marital assets are divided between the parties. There are tax issues relating to the division of assets. This session will cover the following: Valuation…
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2006 Law Student Tax Challenge Results
Congratulations to the winners of the ABA Tax Section’s 2006 Law Student Tax Challenge: J.D. Division: 1st Place: Michigan State Students: Jason Frederick Maus & Julie Ann Camden Faculty Coach: Michele LaForest Halloran 2nd Place: Virginia Students: Sarah L. Pendergraft & Jason McIntosh Faculty Coach: Michael Doran 3rd Place: Northern Illinois Students: Jody Beilke &…
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ABA Offers Teleconference & Webcast Today on Conservation Easements
The ABA Section of Real Property, Probate and Trust Law offers a teleconference and webcast today on Conservation Easements and the Pension Protection Act of 2006 from 1:00 – 2:30 p.m. EST: Conservation easements have long been a powerful but overlooked tool that virtually all estate planners can use to expand their practice and better…
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2006 Law Student Tax Challenge Results
Jack Bogdanski reports on the winners of the 2006 Law Student Tax Challenge announced at the ABA Tax Section Mid-Year Meeting: Overall Winners: J.D. Division: Michigan State LL.M. Division: Loyola-L.A. Best Written Submissions: J.D. Division: Santa Clara LL.M. Division: TBA We will provide more details as they become available.
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ABA Tax Section Mid-Year Meeting Concludes Today in Florida
The ABA Tax Section Mid-Year Meeting concludes today in Hollywood, Florida. Tax Profs presenting today include: Sales, Echanges, and Basis 8:35 a.m.: Sales and Exchanges: Current Developments Erik Jensen (Case Western) (moderator) Brad Borden (Washburn) 9:00 a.m.: Sales and Exchanges of Leasehold Interests Brad Borden (Washburn) (moderator) VAT and Other Consumption Taxes 8:45 a.m.: VAT…
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Final Rounds Today in ABA Law Student Tax Challenge
The semi-final and final rounds of the Law Student Tax Challenge take place today at the ABA Tax Section Mid-Year Meeting in Hollywood, Florida. 9:00 a.m. – 11:30 a.m.: J.D. Semifinals – Judges: John Colvin (Tax Court Chief Judge) Deborah A. Butler (Associate Chief Counsel (Procedure & Administration), IRS Office of Chief Counsel) Juan F.…
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ABA Tax Section Mid-Year Meeting Continues Today in Florida
The ABA Tax Section Mid-Year Meeting continues today in Hollywood, Florida. Leslie M. Book, Director of the Federal Tax Clinic at Villanova, receives the Sixth Annual Pro Bono Award at this morning’s plenary session at 7:15 a.m. Tax Profs presenting today include: 8:30 a.m.: Partnerships and LLCs — Patenting Tax Advice: Potential Ramifications on Subchapter…
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ABA Tax Section Mid-Year Meeting Kicks Off Today in Florida
The three-day ABA Tax Section Mid-Year Meeting kicks off today in Hollywood, Florida. Tax Profs presenting today include: Low Income Taxpayer Clinic Workshop — Refund Claim Litigation 1:00 p.m.: Filing Claims for Refund in US Tax Court, US District Court and the US Court of Federal Claims Danshera Cords (Capital) 2:10 p.m.: Choice of Forum…
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ABA Tax Section Submits Comments on Proposed Partnership Allocation Regs
The ABA Tax Section has submitted comments to the IRS on Proposed Regulations Concerning Substantiality of Partnership Allocations Made to “Look-Through” Partners.