Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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ABA Tax Section Offers Teleconference & Webcast Today on State and Local Tax Traps for the Unwary
The ABA Tax Section offers a a teleconference and webcast today on State and Local Tax Traps for the Unwary from 1:00–2:30 pm EST: For multistate taxpayers, navigating the shifting complexities of state and local audit and appeals systems is achallenging and thankless task. This teleconference will discuss a number of state tax traps —…
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Papers Due Monday for ABA Law Student Tax Challenge
Written submissions are due Monday for the 5th Annual Law Student Tax Challenge ("LSTC"), sponsored by the ABA Section of Taxation Young Lawyers Forum. This year for the first time, both J.D.s and LL.M.s attending ABA-accredited law schools are invited to participate in the one of the country’s largest and most prestigious tax competitions. The…
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ABA RPP&T Section Submits S Corp Comments
The ABA Section on Real Property, Probate & Trust Law has sent comments to the IRS (3 pages) and to the Senate Finance Committee (6 pages) on the S Corporation family attribution rules under § 1361(c)(1).
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ABA Tax Section Offers Teleconference & Webcast Today on Splitting Up a Family Business
The ABA Tax Section offers a a teleconference and webcast today on Splitting Up a Family Business from 1:00–2:30 pm EST: Based on a program that was presented recently at the 2005 Joint Fall CLE Meeting co-sponsored by the Section of Taxation and Section of Real Property, Probate & Trust Law, this teleconference will discuss…
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ABA Tax Section Sponsors Pro Bono Help for Hurricane Victims
The ABA Tax Section is encouraging those with experience in tax law to participate in a 2-hour telephone training to help those affected by Hurricanes Katrina and Rita. The workshop, on Wednesday, November 9, 2005 from 2:00 – 4:00 p.m. EST, is presented by the IRS through its Taxpayer Advocate Service, and will explain new…
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ABA Tax Section Offers Teleconference & Webcast Today on Dealing With the New IRS Form 1023
The ABA Tax Section offers a teleconference and webcast today on Dealing With the New IRS Form 1023 (Application for Section 501(c)(3) Charitable Status) — Tips and Traps as part of its "Last Wednesday" CLE series from 1:00–2:30 pm EST: An organization seeking qualification as a tax exempt charity under IRC section 501(c)(3) must complete…
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ABA RPP&T Section Posts 2005 Symposia Materials
The ABA Section on Real Property, Probate & Trust Law has posted program materials from the Spring 2005 Symposia on its web site: An Introduction to Trusts and Estates (Bekerman, Featherston, Reddy, & TaBois) 2004 – 2005 Developments on Family Limited Partnerships, S Corporations Reform, and Closely Held Businesses (Akers, Dietrich, Paris, Spratt, Worthington, &…
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ABA RPP&T Section Publishes Issue 2005.2 of E-STATE
The ABA Section on Real Property, Probate & Trust Law has posted several artricles in Issue 2005.2 of E-STATE, the RPPT Section Electronic Resource for Estate Planners: IRS Guidance Regarding Circular 230 – Effect on Estate Planning Practitioners, by Steve R. Akers Solutions for the Payment of Life Insurance Premiums, by Joseph Maier, Jason Handal…
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Philadelphia Tax Conference Kicks Off Today
The two-day 2005 Philadelphia Tax Conference kicks off today, co-chaired by Alice G. Abreau (Temple) & Joan C. Arnold (Pepper Hamilton, Philadelphia) The conference is designed for corporate tax professionals—both in-house and outside advisors—and will provide an in-depth discussion and explanation of the latest federal, state, and international legal developments and planning opportunities. Business operations…
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NYSBA Submits Letters and Reports to IRS
The New York State Bar Association Tax Section has submitted several letters and reports to the IRS on a variety of tax issues: JCT Proposal on SECA Taxation (No. 1097) Letter Report U.S. Branch Allocation of Interest Expense (No. 1096) Letter Credit Default Swaps (No. 1095) Letter Report Proposed Regulations Regarding Cross-Border Mergers (No. 1094)…
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ABA Tax Section Submits Documents to IRS on Tax Implications of Hurricane Katrina
The ABA Tax Section has submitted two documents to the IRS in connection with Hurricane Katrina: Letter to IRS Commissioner and Acting Deputy Assistant Trwasury Secretary Regarding Hurricane Katrina (9/21) Suggested IRS and Treasury Guidance Relating to the Impact of Hurricane Katrina (9/15)
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ABA Tax Section Offers Teleconference & Webcast Today on Splitting Up a Family Business
The ABA Tax Section offers a teleconference and webcast today on Splitting Up a Family Business as part of its "Last Wednesday" CLE series from 3:30–5:00 pm EST: Based on a program that was presented recently at the 2005 Joint Fall CLE Meeting co-sponsored by the Section of Taxation and Section of Real Property, Probate…
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ABA Tax Section Submits Comments on Tax Technical Corrections Act
The ABA Tax Section has submitted comments to the House Ways & Means Committee and the Senate Finance Committee on the proposed Tax Technical Corrections Act of 2005.
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Tax Profs at ABA Tax Section Fall Meeting
Tax Profs once again have prominent speaking roles at the ABA Tax Section’s Fall Meeting in San Francisco. The keynote speaker at the meeting is Joseph Bankman (Stanford), who gave a speech on Tax Shelters at yesterday’s Joint Section Breakfast Plenary Session. Thursday, Sept. 15: 1:00 pm – 6:00 pm: Low Income Taxpayer…
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ABA Tax Section Releases Problem for 2005 Law Student Tax Challenge
The ABA Section of Taxation Young Lawyers Forum has released the Problem (html or pdf) for the 5th Annual Law Student Tax Challenge ("LSTC"). This year for the first time, both J.D.s and LL.M.s attending ABA-accredited law schools are invited to participate in the one of the country’s largest and most prestigious tax competitions. The…
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ABA Tax Section Presents 2005 Law Student Tax Challenge
The ABA Section of Taxation Young Lawyers Forum presents the 5th Annual Law Student Tax Challenge ("LSTC"). This year for the first time, both J.D.s and LL.M.s attending ABA-accredited law schools are invited to participate in the one of the country’s largest and most prestigious tax competitions. The LSTC is designed to reflect everyday tax…
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Drapkin New ABA Tax Section Chair
Dennis B. Drapkin (Jones Day, Dallas) has assumed his duties as the new chair of the ABA Tax Section. From the ABA press release: Drapkin helps direct Jones Day’s executive compensation practice, and also advises on a wide range of general tax matters. In addition to private practice, Drapkin previously served as Attorney-Advisor to the…
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Walker on The Tax Regime for Individual Expatriates
Andrew Walker (Milbank, Tweed, Hadley & McCloy, New York) has published The Tax Regime for Individual Expatriates: Whom to Impress?, 58 Tax Law. 555 (2005). Here is the abstract: The American Jobs Creation Act of 2004 (the “2004 Act”) includes provisions to amend the tax regime for individual expatriates. This salvo is the latest in…
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Scarborough on Partnerships as an Alternative to Secured Loans
Robert H. Scarborough (Freshfields Bruckhaus Deringer, New York) has published Partnerships as an Alternative to Secured Loans, 58 Tax Law. 509 (2005). Here is the abstract: This Article considers financing structures that resemble nonrecourse debt but are intended to be treated for tax purposes as partnerships. If respected, they have quite different tax consequences from…
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Reynolds on Patronage-Sourced Income
Clayton S. Reynolds (Orrick, Herrington & Sutcliffe, New York) has published Patronage-Sourced Income: An Expanding Universe, 58 Tax Law. 479 (2005). Here is the abstract: For taxable cooperatives, the distinction between patronage and nonpatronage-sourced income is critical. Subsequent to the publication of Revenue Ruling 69-576, there has been a notable expansion of the types of…
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Coughlan on Section 174 R&E Deduction Upon Statutory Stock Option Exercise
J. Anthony Coughlan (PriceWaterhouseCoopers) has published Section 174 R&E Deduction Upon Statutory Stock Option Exercise, 58 Tax Law. 435 (2005). Here is the abstract: This article critiques some half-century-old orthodoxies regarding the tax treatment to an employer corporation when its employees exercise compensatory stock options. When an employee exercises a nonstatutory stock option, the employee…
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McMahon & Shepard on Privilege and the Work Product Doctrine in Tax Cases
Martin J. McMahon, Jr. (Florida) & Ira B. Shepard (Houston) have published Privilege and the Work Product Doctrine in Tax Cases, 58 Tax Law. 405 (2005). Here is the abstract: Over the past few years, the applicability of the attorney-client privilege, the related section 7525 tax practitioner-client privilege, and the work product doctrine have emerged…
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Smith on Deferential Review of Tax Court Decisions of Law
Andre L. Smith (Florida International) has published Deferential Review of Tax Court Decisions of Law: Promoting Expertise, Uniformity, and Impartiality, 58 Tax Law. 361 (2005). Here is the abstract: This Article continues the debate over whether the federal circuit courts of appeal should deferentially review U. S. Tax Court decisions of law. Some fault this…
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Mosley on Assessing State and Local Taxes Under the Negative Commerce Clause
Mark L. Mosley (Mosley & Gearinger, San Francisco) has published The Path Out of the Quagmire: A Better Standard for Assessing State and Local Taxes Under the Negative Commerce Clause, 58 Tax Law. 729 (2005). Here is the abstract: In the 1980s the Supreme Court created the “internal consistency test” to help evaluate the constitutionality…
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Land on Bearer or Registered Debt
Stephen B. Land (Linklaters, New York) has published Bearer or Registered? Lingering Issues Under TEFRA, 58 Tax Law. 667 (2005). Here is the abstract: Federal tax law imposes sanctions on U.S. persons who hold bearer debt securities and on issuers of bearer debt to U.S. persons. Sanctions on the holder include disallowance of deductions for…