Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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ABA Tax Section Submits Comments to the IRS on Transfers of Assets and Stock Following a Reorganization
The ABA Tax Section has submitted comments to the IRS on Transfers of Assets and Stock Following a Reorganization. Here are the Executive Summary and Summary of Recommendations: On August 18, 2004, the Treasury and the Service published Proposed Regulations that relate to the effect of asset and stock transfers on the status of certain…
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ABA Tax Section Submits Comments to IRS on Notice 2004-80
The ABA Tax Section has submitted comments to the IRS on Notice 2004-80 (Interim Guidance Under §§ 6111, 6112 and 6708). Here are the Executive Summary and Major Recommendations: In Notice 2004-801, the Service and Treasury requested public comment “regarding the requirements of §§ 6111, 6112, and 6708, including comments on the definition of material…
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ABA Tax Section Submits Comments to IRS on Interim Guidance Regarding Disclosures by Material Advisors
The ABA Tax Section last week submitted to the IRS Interim Guidance Regarding Disclosures by Material Advisors (Notice 2004-80). Here is the Executive Summary: These comments address the Interim Guidance governing required disclosures by “material advisors” pursuant to § 6111, as amended by the American Jobs Creation Act of 2004. The comments are in response…
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Winners of 2004 Law Students Tax Challenge
Congratulations to the winners of the 2004 Law Students Tax Challenge sponsored by the ABA Tax Section: 1st Place Team: Brian Judkins & Dan McCall, Georgetown (right). See the Georgetown press release here. 2nd Place Team: Kevin Morriss & Jason Rednour, Chapman 3rd Place Team: Atim Nsunwaaq & Soyun Park, Georgetown Other semi-finalists: Jason Dutil…
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Leyden, Hellwig Honored by ABA Tax Section
Tax Profs received two prestigious awards at the just-concluded ABA Mid-Year Meeting in San Diego: Diana L. Leyden (Connecticut) received the ABA Tax Section Pro Bono Award. According to the press release (also available on the Tax Analysts web site as Doc 2005-1736, 2005 TNT 18-41): The ABA Tax Section Pro Bono Award is presented…
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Tax Profs at ABA Tax Section Mid-Year Meeting
Tax Profs are playing a prominent role in the mid-year meeting of the ABA Tax Section in San Diego. Tax Profs on today’s panels include: 7:00 a.m.- 9:00 a.m.: Low Income Taxpayers: Chair: Diana Leyden (Connecticut) Ethics and "Offer Mills": Moderator: Gwen Thayer Handelman (Nova) 8:30 a.m.- 11:45 a.m.: Sales, Exchanges, and Basis Current Developments…
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Tax Profs at ABA Tax Section Mid-Year Meeting
Tax Profs are playing a prominent role in the mid-year meeting of the ABA Tax Section in San Diego. Tax Profs on today’s panels include: 7:30 a.m.- 8:30 a.m.: Exempt Organizations Subcommittee on Political & Lobbying Organizations and Activities: Co-Chair: Miriam Galston (George Washington) 7:30 a.m.- 9:00 a.m.: Teaching Taxation: Advising on Foreign Tax Systems:…
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Leyden Wins ABA Tax Section Pro Bono Award
Diana Leyden (Connecticut) has been chosen to receive the ABA Tax Section’s Pro Bono Award at the mid-year meeting of the ABA in February, 2005 in Salt Lake City, Utah.
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ABA Tax Section Comments on Worker Classification Settlement Program
The ABA Tax Section has submitted to the IRS Comments on the IRS’s Classification Settlement Program to resolve worker classification cases. The comments were prepared by the Committee on Employment Taxes. Here is the Executive Summary: The issue of worker classification – i.e., whether a worker retained by a service recipient to perform services…
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ABA Tax Section Needs Editors for Annual Report on Important Developments
Tax Profs are invited to contact Bill Lyons (Nebraska) to volunteer to edit a portion of the Annual Report on Important Developments to be published in the Summer 2005 issue of The Tax Lawyer: List of ABA Tax Section Committees submitting annual reports Copies of the 2004 Annual Report Guidelines for Annual Reports on Important…
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Hymel, Mann, and Richmond Offer ABA Teleconference Today on Individual Tax Aspects of Jobs Act
The ABA Tax Section is offering today the third of three CLE teleconferences on the American Jobs Creation Act of 2004 on Hummer Write-Offs, Car Donations and Other Highlights of the American Jobs Creation Act of 2004 That Affect Individual Taxpayers from 1:00 – 2:30 pm EST: The American Jobs Creation Act of 2004 contains…
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Chief Judge Wells’ Musings on Tax Court Traditions
Tax Court Chief Judge Thomas B. Wells delivered remarks on Musings on Tax Court Traditions to the Court Procedure Committee at the ABA Tax Section’s Midyear Meeting on January 30, 2004, recently published at 57 Tax Law. 857 (2004). Here is the abstract: Thank you for inviting me here today. I thought I would deviate…
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ABA Teleconference Today on International Tax Aspects of Jobs Act
The ABA Tax Section is offering the second of three CLE teleconferences on the American Jobs Creation Act of 2004 on International Tax After the Jobs Act: What You Need to Know today from 1:00 – 2:30 pm EST: The American Jobs Creation Act of 2004 contains revolutionary changes to the international tax provisions of…
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In Memoriam: John S. Pennell
Senior Tax Court Judge Lapsley W. Hamblen, Jr. published a memorial tribute for John S. Pennell, who died on March 27, 2004, in 57 Tax Law. 855 (2004). Here is the concluding paragraph of Judge Hamblen’s moving tribute: We who have been fortunate to know and work with John Pennell are enriched and made better…
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ABA Teleconference Today on Impact of Jobs Act on Circular 230
The ABA Tax Section is offering today the first of three CLE teleconferences on the American Jobs Creation Act of 2004 on Circular 230 and the IRS Office of Professional Responsibility: Highlights, New Developments, and the Impact of the American Jobs Creation Act of 2004 from 1:00 – 2:30 pm EST: Circular 230 provides rules…
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ABA Teleconference and Web Cast Today on Current Tax Developments
The ABA Tax Section’s "Connection" Teleconference and Webcast will be held today from 1:00 – 2:30 pm EST on Current Developments in the Tax Law: Increase your knowledge of current Tax Law issues facing older taxpayers, including transferring business ownership, retirement, and estate planning.
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“Tax on the Beach”: Today is Deadline for ABA Student Tax Challenge
The ABA Tax Section’s Young Lawyers Forum is sponsoring the Fourth Annual Law Student Tax Challenge. Two-person student teams will analyze and present the tax consequences of a complex business planning problem. Teams are intially evaluated on two criteria: a memorandum to a senior partner and a letter to the client explaining the result. Based…
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ABA Teleconference and Webcast Today on State Taxation of Pass-Through Entities
The ABA Tax Section’s "Last Wednesday of the Month" Teleconference and Webcast will be held today from 1:00 – 2:30 pm EST on State Taxation of Pass-Through Entities and their Owners: An Overview of the Issues and the Opportunities: The program will address various state and local tax issues, and potential opportunities, raised by the…
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ABA Tax Section Task Force on Judicial Deference Publishes Its Report
The ABA Tax Section Task Force on Judicial Deference (comprised of 6 tax practitioners (including Irving Salem (Latham & Watkins LLP), Chair) and two tax professors (Ellen Aprill (Loyola-L.A.) & Linda Galler (Hofstra)) has published its 61-page report. Here are its two conclusions: • The Task Force believes that this set of recommendations reasonably accommodates…
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ABA Tax Section Recommendations on Executive Compensation Paid by Tax-Exempt Organizations
Wednesday, October 6, 2004 In a 5-page letter to the Senate Finance Committee, the ABA Tax Section has made a number of recommendations regarding exempt organization executive compensation and intermediate sanctions (§ 4958). Specifically, the Tax Section recommends: • Requiring increased disclosure by exempt organizations of executive compensation arrangements• Retaining in modified form existing rules…
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Tax Profs at ABA Tax Section Meeting
Saturday, October 2, 2004 Once again, tax professors have prominent roles in the ABA Tax Section Fall Meeting which winds up today at the Sheraton in Boston. For the complete program schedule, see here. Here is today’s line-up of Tax Profs: • 7:00 am – 9:00 am: Low Income Taxpayers (Diane Leyden (Connecticut), Chair)• 8:30…
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Tax Profs at ABA Tax Section Meeting; Guest Bloggers Needed
Friday, October 1, 2004 Once again, tax professors have prominent roles in the ABA Tax Section Fall Meeting beginning today at the Sheraton in Boston. For the complete program schedule, see here. Here is today’s line-up of Tax Profs: • 7:15 am – 8:00 am: Young Lawyers Orientation Breakfast (Barry Kozak (John Marshall), Chair)• 7:30…
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ABA Teleconference and Webcast Today on Criminal Employment Tax Matters
Wednesday, September 29, 2004 The ABA Tax Section’s "Last Wednesday of the Month" Teleconference and Webcast will be held today from 1:00 – 2:30 pm EST on Strategies for Avoiding and Handling Criminal Employment Tax Matters. The program will examine fact patterns that may give rise to criminal tax controversies and discuss avoidance and defense…
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ABA Task Force Report on Federal Wealth Transfer Taxes
Sunday, September 19, 2004 The ABA Tax Section and Real Property, Probate and Trust Section have released the 228-page Report on Reform of Federal Wealth Transfer Taxes by the 34-person Task Force on Federal Wealth Transfer Taxes (which included four Tax Profs: Mary Louise Fellows (Minnesota) (the Reporter), Joseph Dodge (Florida State), Jeffrey Pennell (Emory),…
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“Tax on the Beach”: Law Student Tax Challenge in San Diego
Friday, September 17, 2004 The ABA Tax Section’s Young Lawyers Forum is sponsoring the Fourth Annual Law Student Tax Challenge. Two-person student teams will analyze and present the tax consequences of a complex business planning problem. Teams are intially evaluated on two criteria: a memorandum to a senior partner and a letter to the client…