Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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Serota Begins Term as Chair of ABA Tax Section
Susan P. Serota (Pillsbury Winthrop Shaw Pittman, New York) began her one-year term yesterday as Chair of the ABA Tax Section: Serota chairs the executive compensation and employee benefits practice at her firm. Prior to becoming chair of the Tax Section, Serota chaired both the Section’s Employee Benefits Committee and the ABA Joint Committee on…
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ABA Tax Section Survey on IRS Appeals Office
ABA Tax Section members are invited to take this Survey of Satisfaction and Experience with the IRS Appeals Office: The Tax Section has recently engaged in extensive discussion concerning the independence of the IRS Office of Appeals and its usefulness in resolving tax controversies. Consequently, the Section decided to survey its members regarding their experiences…
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ABA Offers Teleconference & Webcast Today on Estate and Gift Tax Implications of FLPs
The ABA Real Property, Probate & Trust Section is offering a teleconference and webcast today on Estate and Gift Tax Implications of FLPs from 1:00 p.m. – 2:30 p.m. EST: Family limited partnerships are often a major component of a client’s gift and estate plan. However, compliance with the shifting rules makes the use of…
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ABA Offers Teleconference & Webcast Today on Income Tax Implications of FLPs
The ABA Real Property, Probate & Trust Section is offering a teleconference and webcast today on Income Tax Implications of FLPs from 1:00 p.m. – 2:30 p.m. EST: Learn about the federal income tax traps and opportunities presented at each stage of a family limited partnership’s existence from formation and operation through liquidation. Attend this…
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ABA Tax Section Offers Teleconference & Webcast Today on Redemptions and Purchases of S Corp Stock
The ABA Tax Section is offering a teleconference and webcast today on Redemptions and Purchases of S Corporation Stock from 1:00 – 2:30 p.m. EST: A discussion of the tax consequences of redemptions and purchases of S corporation stock to the redeemed or selling shareholder, the Corporation or buying shareholder and the remaining shareholders, with…
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ABA Tax Section Calls on Sen. Baucus to End Block of Solomon’s Appointment as Assistant Secretary for Tax Policy
The ABA Tax Section has joined the NYSBA Tax Section (blogged here) in sending a letter to Senate Finance Committee Ranking Minority Member Max Baucus asking that he drop his attempt to block the confirmation of Eric Solomon as Assistant Secretary for Tax Policy unless the Treasury adopts a specific timetable for closing the tax…
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ABA Tax Section Submits Comments to the IRS & Congress
The ABA Tax Section has submitted comments to the IRS and Congress on: Regulations Permitting the Revaluation of Partnership Capital Accounts Upon Sales of Partnership Interests (7/24/06) The Uniform Definition of Qualifying Child (7/24/06) Proposed Amendments to Section 10.39 of Circular 230 (7/21/06)
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Gamino on Tax Controversy Overburdened: A Critique of Heightened Standards of Proof
John Gamino has published Tax Controversy Overburdened: A Critique of Heightened Standards of Proof, 59 Tax Law. 497 (2006). Here is the Introduction: Tax controversy exhibits certain distinguishing features, one of which is the odd but persistent balance of power. Taxpayers come to the table or to the courtroom with superior access to the pertinent…
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Schickli on Equipment Fee Clauses in U.S. Tax Treaties
Wright Schickli (Executive Director, Ernst & Young International Tax Services, San Jose, CA) has published The Unmolded Progeny of Madame Tussaud?, 59 Tax Law. 419 (2006). Here is the Introduction: Technological developments, especially those fueled by the Internet, have significantly extended the international reach of small and large businesses alike. Accompanying these opportunities are potential…
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ABA Tax Section Recommends Projects for 2006-2007 Guidance Priority Plan
The ABA Tax Section has submitted Recommendations for 2006-2007 Guidance Priority List to the Treasury Department and IRS: As requested in Notice 2006-36, ABA Tax Section members have identified the following tax issues that should be addressed through regulations, rulings or other published guidance in 2006-2007. The issues are grouped in these categories: Banking and…
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Idrees on When Do Tax Deficiencies Actually Accrue? Resolving the Recent Circuit Split over the Accumulated Earnings Tax
Kamran Idrees (International Tax Group, Deloitte Tax, Chicago) has published When Do Tax Deficiencies Actually Accrue? Resolving the Recent Circuit Split over the Accumulated Earnings Tax, 59 Tax Law. 541 (2006). Here is the Introduction: Generally, the Internal Revenue Code treats corporations as independent taxpaying entities, regardless of the personal characteristics of their shareholders. Thus,…
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ABA Tax Section Offers Teleconference & Webcast Today on Grantor Trusts
The ABA Tax Section is offering a teleconference and webcast today on Grantor Trusts – Rulings, Rules and Practical Applications from 1:00 – 2:30 p.m. EST: Our expert panel will discuss Grantor Trust Rules under Subchapter J, including recent IRS rulings, favorite techniques for “triggering” grantor trust status, and rules on EINs and tax reporting.…
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Germain on Income Tax Claims in the Year of Bankruptcy
Gregory L. Germain (Syracuse) has published Income Tax Claims in the Year of Bankruptcy: A Congressionally Created Quagmire, 59 Tax Law. 329 (2006). Here is the Introduction: Whenever a debtor files bankruptcy on a date other than the first or last day of the tax year, the debtor will potentially owe some taxes on income…
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ABA Tax Section Submits Comments to IRS on § 409
The ABA Tax Section has submitted comments to the IRS on: Section Comments on Code Section 409A Proposed Regulations Regarding Distribution Issues (6/15) Modification of Stock Rights under Proposed Treasury Regulations under Section 409A (6/7)
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ABA Tax Section Submits Comments to IRS on Circular 230 & § 409
The ABA Tax Section has submitted two comment letters to the IRS on: Proposed Amendments to Circular 230 Stock Rights under Proposed Treasury Regulations under § 409A
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ABA Tax Section Offers Teleconference & Webcast Today on Bankruptcy Act: Tax and Non-Tax Issues for Closely-Held Businesses
The ABA Tax Section is offering a teleconference and webcast today on New Bankruptcy Act: Tax and Non-Tax Issues Relating to the Closely Held Business and Its Owners from 1:00 – 2:30 p.m. EST: This program will address the tax provisions of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 that impact closely…
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ABA Tax Section Submits Comments to IRS on § 7874
The ABA Tax Section has submitted comments to the IRS on the proposed regulations under § 7874. Here is the opening of the Executive Summary: The American Jobs Creation Act of 2004 added § 7874 to curtail inversion transactions. In December of 2005, the Treasury Department issued proposed and temporary regulations setting forth rules for…
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LaRue on LIFO Recapture on C-to-S Conversions
David W. LaRue (Associate Professor and Director, Graduate Tax Program, McIntire School of Commerce, University of Virginia) has published LIFO Recapture on C-to-S Conversions: Filling the Gaps and Ameliorating the Deficiencies of Section 1363(d), 59 Tax Law. 1 (2005). Here is the abstract: Prior to the enactment of section 1363(d) in 1987, the conversion of…
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Yablon on Assessing the Surprising Resilience of State Death Taxes
Robert Yablon (Yale J.D. 2006; winner of 2004 Tannenwald Writing Competition) has published Defying Expectations: Assessing the Surprising Resilience of State Death Taxes, 59 Tax Law. 241 (2006). Here is the part of the abstract: The prevailing view among observers was that the many states levying only a pick-up tax would have no choice but…
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Hartt & Blacker on Judicial Application of Issue Preclusion in Tax Litigation
Gover Hartt, III (Assistant Chief, Civil Trial Section, Southwestern Region, Department of Justice – Tax Division) & Jonathan L. Blacker (Trial Attorney, Civil Trial Section, Southwestern Region, Department of Justice – Tax Division) have published Judicial Application of Issue Preclusion in Tax Litigation: Illusion or Illumination?, 59 Tax Law. 205 (2005). Here is the abstract:…
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Blanchard, Hooker & Vogel on Underwater Assets and Insolvent Corporations
Jerred G. Blanchard, Jr., Kenneth L. Hooker & Gary R. Vogel (all of Ernst & Young) have published Underwater Assets and Insolvent Corporations: Reflections on Treasury’s Recently Proposed Regulations and Related Matters, 59 Tax Law. 107 (2005). Here is the abstract: Over the last few years there has been a significant interest on the part…
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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. Today’s highlight is the ceremony honoring Martin D. Ginsburg (Georgetown) as this year’s recipient of the Distinguished Service Award during the Section breakfast (7:30 – 8:45 a.m.): The Section of Taxation is proud to present the Distinguished Service…
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ABA Tax Section May Meeting Kicks Off Today with Woodworth Lecture by Oosterhuis
The ABA Tax Section’s three-day May Meeting kicks off today at the Grand Hyatt in Washington, 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. in the Constitution Ballroom. The speaker is Paul W. Oosterhuis, the head of Skadden’s international…
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ABA Tax Section Task Force on International Tax Reform Completes Report
The ABA Tax Section convened a Task Force on International Tax Reform to provide policymakers with objective criteria by which to evaluate reform proposals and to identify and analyze possible modifications to the U.S. international tax rules. The Task Force recently completed a 200-page Report, which will be published in 59 Tax. Law. 649 (2006). …
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ABA Tax Section Releases Several Comments and Reports
The ABA Tax Section has released several comments and reports: Section Comments on Internal Revenue Service Funding (4/17) Testimony to Oversight Subcommittee Regarding Simplification of Federal Tax Laws (4/6) Section Comments on Anti-Terrorist Financial Guidelines (4/5)