Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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ABA Tax Section Offers Teleconference & Webcast Today on Net Worth Tax Pitfalls
The ABA Tax Section is offering a teleconference and webcast today on Net Worth Tax Pitfalls and Techniques to Avoid Them or What You Don’t Know Can Hurt You from 1:00 – 2:30 p.m. EST: States including Illinois, Louisiana, and Pennsylvania, among others, impose significant franchise taxes based on a company’s net worth. Business advisors…
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ABA Tax Section Offers Teleconference & Webcast Today on Ethical Considerations for a U.S. Practitioner in Planning for a U.S. Multinational Client
The ABA Tax Section is offering a teleconference and webcast today on Ethical Considerations for a U.S. Practitioner in Planning for a U.S. Multinational Client from 1:00 – 2:30 p.m. EST: Ethical considerations in representing cross border clients can no longer be ignored by U.S. practitioners: In the U.S., tax plans that result in fraudulent…
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4th Annual International Tax Institute Begins Today at Georgetown
The 4th Annual International Tax Institute, Planning for U.S. Multinationals in Today’s Global Tax Environment, kicks off today at Georgetown. For more information, see: General Information Program Speakers Prior Institutes The Institute is sponsored by the ABA Tax Section, Georgetown University Law Center and International Fiscal Association.
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Peter on U.S. Cross-Border Discovery in International Tax Proceedings
Alexander F. Peter (Norton Rose, Frankfurt, Germany) has published U.S. Cross-Border Discovery in International Tax Proceedings: An Overview from a European Comparative Law Perspective, 58 Tax Law. 881 (2005). Here is the abstract: In the mid-1980s, the Service determined that a significant portion of collectible tax deficiencies resided in the largest cases, many of which…
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Dunn on Structural Tax Considerations in Cross-Border Joint Ventures
Daniel M. Dunn (O’Melveny & Myers, New York) has published Venturing Afar: Structural Tax Considerations in Cross-Border Joint Ventures, 58 Tax Law. 849 (2005). Here is the abstract: This paper sets forth the principal U.S. federal income tax considerations for entering into a joint venture (JV) in a non-U.S. jurisdiction. Unless otherwise specified, this paper…
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Kestenbaum & Ponikvar on Aspects of the Consolidated Group in Bankruptcy: Tax Sharing and Tax Sharing Agreements
Russell J. Kestenbaum & Dale L. Ponikvar (both of Milbank, Tweed, Hadley & McCloy, New York) have published Aspects of the Consolidated Group in Bankruptcy: Tax Sharing and Tax Sharing Agreements, 58 Tax Law. 803 (2005). Here is the abstract: This article takes note of numerous difficult fact patterns bankruptcy tax attorneys face today in…
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ABA Submits Comments to IRS on Proposed § 199 Regs
The ABA Tax Section has submitted comments to the IRS on the proposed § 199 regs. Here is the opening of the Executive Summary: On October 19, 2005, the IRS issued a Notice of Proposed Rule Making (Reg-105847-05) proposing regulations (the “Proposed Regulations”) under Section 199 of the Internal Revenue Code. Section 199 was enacted…
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Can Estate Planning Lawyers Provide Financial Planning Advice?
The February 2006 Your ABA e-newsletter has an interesting Eye on Ethics column, Would You Like a Financial Plan With That?: A lawyer who has an estate planning practice frequently advises his clients to get financial planning advice. Over the years, he has become very familiar with financial planning practices and he realizes that he…
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ABA Tax Section Offers Teleconference & Webcast Today on Cuno Update
The ABA Tax Section is offering a teleconference and webcast today on Cuno Update from 1:00 – 2:30 p.m. EST: In the current economic landscape, state governments have become increasingly innovative in their attempts to spur economic development in their states. This has contributed to fierce competition between the states to attract and retain large…
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ABA Tax Section Offers Teleconference & Webcast Today on The ECJ Decision in Marks & Spencer
The ABA Tax Section is offering a teleconference and webcast today on The ECJ Decision in Marks & Spencer: Impact and Opportunities from 1:00 – 2:30 p.m. EST:: Marks & Spencer has been billed as perhaps the most significant tax decision handed down by the European Court of Justice thus far. This teleconference will analyze…
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ABA Tax Section Names 2006 Nolan Fellows
The ABA Tax Section has announced the recipients of its 2006 Nolan Fellows awards. Nolan Fellows are young tax lawyers who are actively involved in the section and have demonstrated leadership qualities. The six 2006 Nolan Fellows are: Christopher Condeluci (Groom Law Group, Washington, D.C.) Jessica Hough (Skadden, Arps, Slate, Meagher & Flom, Washington, D.C.)…
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2005 Law Student Tax Challenge Results
Congratulations to the winners of the ABA Tax Section’s 2005 Law Student Tax Challenge: J.D. Division: 1st Place: Tonita Northington & Teri Ellison (LSU) (pictured)(winning paper here) 2nd Place: Mary Riley & Cathryn Streeter (Northern Illinois) 3rd Place: Gainey Johnson & Travis Combs (Houston) Best Written Submission: Jed Tomkins & Luke Jones (Lewis & Clark)…
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Tax Profs at ABA Tax Section Midyear Meeting
The ABA Tax Section concludes its three-day Midyear Meeting today in San Diego. Tax Profs speaking on panels today include: 7:00 a.m. – 9:00 a.m.: Low Income Taxpayers 7:55 a.m.: What You Need to Know About Collection Due Process Panelist: Diana Leyden (Connecticut) 8:30 a.m. – 11:30 a.m.: Fiduciary Income Tax 11:00 a.m.: Repercussions of…
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Tax Profs at ABA Tax Section Midyear Meeting
The ABA Tax Section continues its three-day Midyear Meeting today in San Diego. Tax Profs speaking on panels today include: 7:30 a.m. – 8:30 a.m.: Section Breakfast — Plenary Session 2006 Pro Bono Award Recipient: Janet Spragens (Washington) Speaker: George K. Yin (Virginia): The Evolving Legislative Process and What it May Portend for Budget Control…
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Tax Profs at ABA Tax Section Midyear Meeting
The ABA Tax Section kicks off its three-day Midyear Meeting today in San Diego. Tax Profs speaking on panels today include: 1:00 p.m. – 6:00 p.m.: Low Income Taxpayer Clinic Workshop 2:40 p.m.: The ABCs of Liens and Levie Panelists: George Willis (Chapman) & Diana Leyden (Connecticut) 2:40 p.m.: Bankruptcy v. OIC Panelist: Jerome Borison…
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Spragens Wins ABA Tax Section’s Pro Bono Award
Janet R. Spragens (American) will receive the ABA Tax Section’s annual Pro Bono Award on Friday at the 2006 Midyear Meeting in San Diego. From the press release: Spragens founded one of the earliest and most successful low-income taxpayer clinics in the country in 1990 — the Federal Tax Clinic at American University’s Washington College…
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ABA Tax Section Offers Teleconference & Webcast Today on Fundamentals of Partnership Proceedings
The ABA Tax Section is sponsoring a teleconference and webcast today on Fundamentals of Partnership Proceedings: Avoiding Common Procedural Pitfalls from 1:30–3:00 p.m. EST: The past five years has seen a dramatic increase in partnership-level tax litigation. For most tax practitioners, the unified audit and litigation procedures that apply to most partnership proceedings are a…
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ABA Tax Section Submits Comments on Sections 501 (c)(3) & 4958 Proposed Regs
The ABA Tax Section has submitted comments to the IRS on the Proposed Regulations Under Sections 501 (c)(3) and 4958 (1/9/06) (9 pages): The 2005 proposed regulations add a number of examples intended to illustrate whether an organization serves a public rather than a private interest within the meaning of section 1.501(c)(3)-1(d)(1)(ii) of the regulations.…
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ABA Tax Section Submits Comments on S. 2020: Tax Relief Act of 2005
The ABA Tax Section has submitted comments to the Senate Finance Committee and House Ways & Means Committee on S.2020: Tax Relief Act of 2005 (1/4/06) (3 pages): I write with respect to three revenue offset provisions in S. 2020 (the “Bill”) that have also been contained in previous legislation passed by the Senate, including…
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ABA Tax Section Submits Comments on Disciplinary Procedures of the Office of Professional Responsibility
The ABA Tax Section has submitted comments to the IRS on Disciplinary Procedures of the Office of Professional Responsibility (12/8/05) (17 pages). Here is the Executive Summary: During the May 2004 Section of Taxation Meeting in Washington, D.C., the Director, IRS Office of Professional Responsibility (“OPR”), discussed significant changes being made in OPR and asked…
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ABA Tax Section Submits Comments on Changes to Collection Due Process Procedures
The ABA Tax Section has submitted comments to the IRS on Changes to Collection Due Process Procedures Under Sections 6230 and 6330 (12/27/05) (21 pages). Here is the Executive Summary: Collection Due Process (“CDP”) hearings are relatively new procedures enacted into law as part of the Internal Revenue Service Restructuring and Reform Act of 1998…
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ABA Tax Section Submits Comments on Partnership Equity for Services
The ABA Tax Section has submitted comments to the IRS on Partnership Equity for Services (12/29/05) (41 pages). Here is the Executive Summary: In Notice 2000-29 (the “Notice”), the IRS and the Treasury requested public comment on “the tax consequences to the recipient of the partnership interest as well as to the partnership upon the…
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ABA Tax Section Urges Broader § 475 Valuation Safe Harbor
The ABA Tax Section has submitted comments to the Treasury Department and IRS on Proposed Safe Harbor Regulations under Section 475. Here is the Executive Summary: Our comments address two concerns. The first is the relationship of the scope of the proposed safe harbor for determining fair market value to the underlying policy goal. The…
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ABA Tax Section Criticizes Circular 230 Regs
The ABA Tax Section has submitted comments to the Treasury Department and IRS on Final Circular 230 Regulations Governing Written Tax Advice: I am writing on behalf of the Section of Taxation of the American Bar Association to express our concern about the adverse impact that the final Circular 230 regulations governing written tax advice…
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ABA Tax Section Offers Teleconference & Webcast Today on Nonprofits Under Scrutiny Brace for Reform
The ABA Tax Section is co-sponsoring a teleconference and webcast today on The New Stewardship: Nonprofits Under Scrutiny Brace for Reform from 1:30–3:00 pm EST: Tax exempt organizations are under intense review concerning their transparency, governance and accountability. This program addresses initiatives and legislative changes affecting all tax exempt organizations and should be of great…