Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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Fall 2006 ABA Tax Section News Quarterly
The Fall 2006 ABA Tax Section News Quarterly is now available. Tax Profs appearing in the issue include: Interview Charles I. Kingson (NYU & Penn) (pp.5-8) Points to Remember David Brennen (Georgia), Congress Finally Adopts New UBIT Standard in 512(b)(13) for Controlled Entities (pp.9-10) Toni Robinson (Quinnipiac), Problems with the Uniform Definition of a Qualifying…
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ABA Tax Section Offers Teleconference & Webcast Today on The New Tax Shelter Disclosure Rules
The ABA Tax Section offers a teleconference and webcast today on The New Tax Shelter Disclosure Rules: What You Need to Know Now from 1:00 – 2:30 p.m. EST: On November 1, 2006, the Treasury Department and the IRS issued proposed amendments to the tax shelter disclosure regulations for taxpayers and material advisors. The current…
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ABA Tax Section Submits Comments on Proposed Regulations under § 7216
The ABA Tax Section has submitted comments to the IRS on Proposed Regulations under § 7216 (12/11/06). Here is the Executive Summary: These Comments address Proposed Regulations relating to the rules regarding the disclosure and use of tax return information by tax return preparers. The Proposed Regulations provide guidelines for tax return preparers using or…
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ABA Tax Section Submits Comments on Proposed Regs For Cost Sharing Arrangements
The ABA Tax Section has submitted comments to the IRS on Proposed Regulations For Cost Sharing Arrangements (12/4/06) . Here is the Executive Summary: These comments address proposed amendments to Reg. § 1.482-7 governing cost sharing arrangements (“CSAs”). … The Proposed Regs would revise the existing Treasury Regulations under § 482 that govern qualified cost…
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National Institute on Criminal Tax Fraud Kicks Off Today in San Francisco
The 23rd Annual National Institute on Criminal Tax Fraud kicks off today in San Francisco: As it has throughout its tenure, the Institute will offer expert panelists from the defense bar, the government and the judiciary. The Institute is regularly attended by judges, federal, state and local prosecutors, other law enforcement officials, defense attorneys, corporate…
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ABA Tax Section Offers Teleconference & Webcast Today on FIN 48—Uncertain Accounting for Tax Uncertainties
The ABA Tax Section offers a teleconference and webcast today on FIN 48—Uncertain Accounting for Tax Uncertainties from 1:00 – 2:30 p.m. EST: The new rules of the Financial Accounting Standards Board (FASB) Interpretation No. 48 (FIN 48) may have a significant impact, particularly on when tax benefits for uncertain tax positions may be reported…
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ABA Offers Teleconference & Webcast Today on Charitable Planning in the New Tax Environment
The ABA Real Property, Probate & Trust Section is offering a teleconference and webcast today on Charitable Planning in the New Tax Environment from 1:00 p.m. – 2:30 p.m. EST: The Pension Protection Act of 2006 included many changes that affect charitable giving, including incentives for lifetime gifts from IRAs (“Charitable IRA Rollover”), gifts from…
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ABA Tax Section: Proposed S Corp Bank Regs Are Inconsistent with Section 1363(b)
The ABA Tax Section has submitted comments to the IRS on Proposed Regulations under Section 1363(b) Concerning S Corporation Banks. Here is the Executive Summary: The IRS has proposed to amend the section 1363 regulations with respect to the application of certain banking provisions to banks that are either S corporations or qualified subchapter S…
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Scott on The Impact of the Section 409A Proposed Regulations on Stock Appreciation Rights
Vanessa A. Scott (Legislative Counsel and Corporate Secretary, The ERISA Industry Committee, Washington, D.C.) has published Fallacies of Presumption: Unpacking the Impact of the Section 409A Proposed Regulations on Stock Appreciation Rights Issued by Privately-Held Companies, 59 Tax Law. 867 (2006). Here is the Introduction:
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Lipman on Taxing Undocumented Immigrants: Separate, Unequal and Without Representation
Francine J. Lipman (Chapman) has published Taxing Undocumented Immigrants: Separate, Unequal and Without Representation, 59 Tax Law. 813 (2006). Here is the abstract: Americans believe that undocumented immigrants are exploiting the United States’ economy. The widespread belief is that “illegal aliens” cost more in government services than they contribute to the economy. This belief is…
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Written Submissions Due Today in Law Student Tax Challenge
Written submissions are due today in the 6th Annual Law Student Tax Challenge ("LSTC") sponsored by the ABA Section of Taxation Young Lawyers Forum. Based on this written work product, 6 teams from the J.D. Division and 4 teams from the LL.M. Division will receive a free trip (including airfare and accommodations for two nights)…
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ABA Tax Section Submits Comments on Dual Consolidated Losses & Tax Court Rule 173
The ABA Tax Section has submitted comments on: Proposed Regulations Relating to Dual Consolidated Losses (Prop. Reg. §§1.1503(d)-1-1.1503(d)-(6) to the IRS (11/14/06) Proposed Amendment to Tax Court Rule 173 to the Tax Court (11/13/06)
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ABA Task Force on International Tax Reform Issues 200-Page White Paper
The ABA Tax Section Task Force on International Tax Reform (Peter H. Blessing; Mark van Casteren; Robert E. Culbertson; Jasper L. Cummings, Jr.; William S. Dixon; Alan F. Fischl; Robert J. Peroni; Elinore J. Richardson; Leonard Schneidman (Co-Chairman); Stephen E. Shay (Co-Chairman); Carol P. Tello; Joni L. Walser; Philip R. West; and Lowell D. Yoder)…
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ABA Tax Section Task Force on Patenting Tax Advice
The ABA Tax Section has formed a task force to study patenting of tax-related advice: Tax strategy patents are a part of business method patents, which have been growing in number since 1998, when the concept was approved by a federal circuit court. Since that time, more than 40 patents have been issued for tax-related…
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ABA Offers Teleconference & Webcast Today on Florida Estate Planning
The ABA Real Property, Probate & Trust Section is offering a teleconference and webcast today on What Every Estate Planning Attorney Should Know About Florida from 1:00 p.m. – 2:30 p.m. EST: With many retirees spending some or all of their golden years in Florida, estate planning attorneys around the country frequently confront Florida estate…
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ABA Tax Section Submits Comments on Tax Technical Corrections Act of 2006
The ABA Tax Section has submitted comments to the House Ways & Means Committee and Senate Finance Committee on H.R. 6264 and S. 4026: The Tax Technical Corrections Act of 2006 (10/31/06).
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ABA Tax Section Submits Comments to IRS
The ABA Tax Section has submitted these comments to the IRS: Comments in Response to Notice 2006-68, Requirement of Partial Payment with Submission of Offer in Compromise (10/27/06) Comments in Response to Notice 2006-68 Regarding Definition of “Low-Income” and Waiver Authority Under Section 7122(c)(2)(C) (10/16/06)
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ABA Tax Section Fall Meeting Concludes Today in Denver
The ABA Tax Section Fall Meeting concludes today in Denver. Tax Profs presenting include: 7:20 a.m.: Low Income Taxpayers and Administrative Practice — Collection Due Process Smorgasbord Keith Blair (Baltimore) 8:00 a.m.: Common Interest Developments in the Law Reviews Paula Franzese (Seton Hall) Susan French (UCLA) 8:30 a.m.: Sales, Exchanges and Basis — Current Developments…
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ABA Tax Section Fall Meeting Continues Today in Denver
The ABA Tax Section Fall Meeting continues today in Denver. Tax Profs presenting today include: 7:30 a.m.: Exempt Organizations Subcommittee on Political and Lobbying Organizations and Activities Miriam Galston (George Washington) 7:30 a.m.: Joint Session/Plenary Breakfast — Can Patents Restrict Our Advice To Our Clients? Ellen Aprill (Loyola-L.A.) (moderator) Richard Gruner (Whittier) 8:30 a.m.: Affiliated…
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ABA Tax Section Fall Meeting Kicks Off Today in Denver
The 3-day ABA Tax Section Fall Meeting kicks off today in Denver. Tax Profs presenting today include: 1:00 – 6:15 p.m.: Low Income Taxpayer Clinic Workshop – Refund Claim Litigation Filing Suits for Refund in US Tax Court, US District Court and the US Court of Federal Claims Danshera Cords (Capital) Claims for Damages Against…
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ABA Tax Section Offers Teleconference & Webcast Today on Tax Tips for Real Estate Lawyers
The ABA Tax Section is offering a teleconference and webcast today on Practical Tax Considerations for the Real Estate Practitioner from 1:00 – 2:30 p.m. EST: Join our expert faculty for a primer on tax issues that attorneys must identify in a typical real estate practice. After the program, you will be able to: Explain…
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ABA Tax Section Offers Teleconference & Webcast Today on Building Blocks of Hedge Fund Taxation
The ABA Tax Section is offering a teleconference and webcast today on Building Blocks of Hedge Fund Taxation from 1:00 – 2:30 p.m. EST: Tax issues for hedge funds and their investors can be extremely complex.This teleconference and live audio webcast will provide tax professionals who work with hedge funds and their investors the building…
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ABA Tax Section Submits Comments to IRS
The ABA Tax Section has submitted these comments to the IRS: Letter to IRS Oversight Board Measuring IRS Progress in Meeting Long Term Goals (09/15/06) Letter Concerning Reconsideration of Section 409A of the IRC (09/15/06) Comments in Response to Notice 2006-68 Regarding Requirement of Partial Payment with Submission of Offers in Compromise
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ABA Law Student Tax Challenge Releases This Year’s Problem
The ABA Section of Taxation Young Lawyers Forum has released the Problem and updated rules (J.D. rules; LL.M. rules) for the 6th Annual Law Student Tax Challenge ("LSTC"): Teams are initially evaluated on two criteria: a memorandum to a senior partner and a letter to the client explaining the result. Based on this written work…
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ABA Tax Section Offers Teleconference & Webcast Today on Ethical Issues in Property Taxes
The ABA Tax Section is offering a teleconference and webcast today on Ethical Issues in Property Taxes from 1:00 – 2:30 p.m. EST: This program, presented at the ABA/IPT Advanced Property Tax Seminar in March 2006, will discuss particular applications of the ABA Rules of Professional Conduct. The teleconference will also address the Institute for…