Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted these comment letters: Permission For Late Filing (Jan 20, 2011) Requirements For Tax- Exempt Hospitals (Jan. 20, 2011) Codification of Economic Substance (Jan. 18, 2011) Grandfathering Rules In The HIRE Act (Jan. 10, 2011) Bond-Financed Grants (Jan. 5, 2011) PBGC Proposed Rule on Reportable Events (Dec. 22, 2010) Circular 230 (Dec. 7, 2010) The Effective Date of § 909 (Nov. 15,…
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ABA Tax Section Hosts Webcast Today With Lindy Paull, Eric Solomon
The ABA Tax Section offers a teleconference and webcast today on Legislative and Tax Policy Discussion with Lindy Paull and Eric Solomon from 1:00 – 2:30 p.m. EST: Please join Lindy Paull, former Chief of Staff of the Joint Committee on Taxation, and Eric Solomon, former Assistant Secretary for Tax Policy, as they discuss the latest legislative…
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Samford, Northwestern Win 2010 ABA Law Student Tax Challenge
The ABA Tax Section has released the list of winners of the 2010 Law Student Tax Challenge: The contest features J.D. and LL.M. divisions, both of which compete in two person teams that research the tax issues involved, and then submit technical memoranda and client letters with their solutions. The teams’ written submissions are judged by tax…
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ABA Tax Section Hosts Webcast Today on Recent Tax Developments
The ABA Tax Section offers a teleconference and webcast today on Current Developments in Individual, Corporate, and Partnership Taxation from 1:00 – 2:30 p.m. EST: Please join Professors Martin J. McMahon, Jr. and Ira B. Shepard as they review the most significant statutory enactments, judicial decisions, IRS rulings, and Treasury regulations promulgated during the last twelve…
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ABA Tax Section Names 2011 Nolan Fellows
The ABA Tax Section today announced the recipients of its 2011 Nolan Fellowships on the final day of its midyear meeting in Boca Raton: Chad R. DeGroot (Bryan Cave, St. Louis) Stacey Delich-Gould (Cahill Gordon & Reindel, New York) Melissa L. Galetto (Skadden, Arps, Slate, Meagher & Flom, Washington, D.C.) Vanessa A. Scott (Southerland Asbill & Brennan, Washington, D.C.) Lisa M. Stern…
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Fulbright & Jaworski Receives Janet Spragens Pro Bono Award
The ABA Tax Section today presented Fulbright & Jaworski with the annual Janet Spragens Pro Bono Award on the final day of its midyear meeting in Boca Raton. From the press release: The Janet Spragens Pro Bono Award, named after the late American University Law professor who greatly contributed to ensuring representation for low-income taxpayers, is presented each year…
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ABA Tax Section Midyear Meeting
The ABA Tax Section midyear meeting concludes today in Boca Raton. The full program is here; Tax Profs with speaking roles today include: Low Income Taxpayers — Leslie Book (Villanova), Kathryn J. Sedo (Minnesota), William N. Timm, Jr. (Georgia State) Pro Bono: Tax Counseling for the Exploding Population of Elderly — Francine J. Lipman (Chapman) Sales, Exchanges &…
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ABA Tax Section Midyear Meeting
The ABA Tax Section midyear meeting continues today in Boca Raton. The full program is here; Tax Profs with speaking roles today include: Exempt Organization Committee Luncheon — Frances R. Hill (Miami) Foreign Activities of US Taxpayers: Foreign Tax Credit Panel — Robert J. Peroni (Texas) Individual and Family Taxation: Elder Law Taxation — David Rice (Pomona) State & Local…
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ABA Tax Section Midyear Meeting
The ABA Tax Section midyear meeting kicks off today in Boca Raton. The full program is here; Tax Profs with speaking roles today include: Low Income Taxpayers Representation Workshop — Keith Blair (District of Columbia), Sandy Freund (Rutgers-Newark), Michelle Kwon (Texas Tech), Jan Pierce (Lewis & Clark), Kathryn J. Sedo (Minnesota)
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ABA Submits Comments on Codification of Economic Substance Doctrine
The ABA Tax Section yesterday submitted this 65-page comment letter on Notice 2010-62 and Implementation of the Economic Substance Legislation: In Notice 2010-62, the Treasury and the IRS requested comments on certain aspects of the economic substance legislation contained in the Health Care and Education Reconciliation Act of 2010. These comments, which have been prepared by members of the ABA Section of…
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ABA Hosts Webcast Today on Planning Under the New Estate Tax Law
The ABA Real Property, Trust and Estate Law Section offers a teleconference and webcast today on Planning with the TRA 2010 Transfer Tax Rules: The Sun Has Risen from 1:00 – 2:30 p.m. EST: The dust is settling on the flurry of year-end estate planning activity resulting from the Tax Relief Act of 2010. For…
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ABA Tax Section Hosts Webcast Today on Estate Planning Under the 2010 Act
The ABA Tax Section offers a teleconference and webcast today on Moving Forward (2 Years at a Time) With Estate Planning Under the 2010 Act from 1:00 – 2:30 p.m. EST: With the wonderland year of 2010 behind us and all last-minute gifts to grandchildren safely protected from GST tax, we can now settle back and…
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The Tax Lawyer Publishes New Issue
The Tax Lawyer has published Vol. 63, No. 4 (Summer 2010), The State & Local Tax Edition: Richard D. Pomp (Connecticut), The Unfulfilled Promise of the Indian Commerce Clause and State Taxation, 63 Tax Law. 897 (2010) Anthony Ciolli (Suffolk), The Power of United States Territories to Tax Interstate and Foreign Commerce: Why the Commerce and Import-Export Clauses…
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ABA Tax Section Submits Comments on Circular 230
The ABA Tax Section has submitted this comment letter on Circular 230: Under the proposed amendments to Circular 230 the definition of “Practitioner” is expanded to include a new category of “Registered Tax Return Preparers,” defined by reference to § 7701(a)(3) and Reg. § 301.7701-15. This new category of practitioners is estimated to include 900,000 to 1.2 million individuals. We…
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ABA Hosts Webcast Today on Conservation Easement Donations
The ABA Real Property, Trust and Estate Law Section offers a teleconference and webcast today on Pleasing Mother Earth and the IRS: Conservation Easement Donations in the New Age of IRS Oversight Lessons from Recent Court Developments and Practical Drafting Advice from 1:00 – 2:30 p.m. EST: The IRS has been aggressively auditing taxpayers who…
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National Institute on Criminal Tax Fraud
The ABA Tax Section’s two-day 27th Annual National Institute on Criminal Tax Fraud kicks off today in San Francisco: [T]he Institute will offer the most knowledgeable panelists from the defense bar, the government, and the judiciary. The sessions are regularly attended by judges, federal, state and local prosecutors, other law enforcement officials, defense attorneys, corporate in-house…
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ABA Tax Section Hosts Webcast Today on Planning for Debt Discharge Income
The ABA Tax Section offers a teleconference and webcast today on Planning for Debt Discharge Income and Section 108 Relief: Part II from 1:00 – 2:30 p.m. EST: Using a unique problem format that continues the discussion from Part I of this presentation, this panel returns to further discuss the tax aspects of the realization of debt…
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ABA Submits Comments to Congress on Estate and GST Taxes
The ABA Section on Real Property, Trust & Estate Law and ABA Tax Section have submitted a letter to Congress requesting action on pending Estate & Generation-Skipping Transfer Tax legislation: We urge that Congress, before adjournment, address the limbo that legislative inaction has created for the nation’s taxpayers. Specially, we ask Congress to resolve the…
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted these comment letters: The Effective Date of § 909 (Nov. 15, 2010) Treaty Override Provisions of the Health Bill (Nov. 12, 2010) Issue Price Under Reg. § 1.148-1(b) (Nov. 11, 2010) Carried Interest Proposals in Senate Amendment 4386 to H.R. 4213 (Nov. 5, 2010) The Taxation of Dividend Equivalent Under § 871(l)…
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ABA Business Law Section Submits Comments on Form 990
Following up on last week’s post, Has the IRS Usurped the Business Judgment of Tax-Exempt Organizations?: the ABA Business Law Section and the Nonprofit Organizations Committee of the Business Law Section of the California State Bar have submitted comments to the IRS Draft Form 990: [A]s attorneys who work regularly with nonprofit organizations, especially in the…
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ABA Tax Section Publishes Fall 2010 Issue of News Quarterly
The ABA Tax Section has published 30 News Quarterly No. 1 (Fall 2010): Special Report: The Internal Revenue Code: Looking Ahead to 2010 Three Once and Future Issues, by Charlene Luke (Florida), pp. 1, 20 Wish-List for the Federal Tax System in the Year 2020, by Joseph M. Dodge (Florida State), pp. 20-21 Section Meeting Calendar, p.…
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ABA Tax Section Hosts Webcast Today on The Impact of Schedule UTP
The ABA Tax Section offers a teleconference and webcast today on The Rubber Meets the Road: Understanding the Impact of Schedule UTP from 1:00 – 2:30 p.m. EST: The IRS has finalized Schedule UTP for the 2010 tax year and set forth procedures for implementation, but there are still lurking questions about the schedule, its requirements,…
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ABA Tax Section Solicits Nominations for Janet Spragens Pro Bono Award
The ABA Tax Section is accepting nominations for the Janet Spragens Pro Bono Award to be presented at the Midyear Meeting in Boca Raton on January 20-22, 2011. The award is given to one or more individuals or law firms that have provided meritorious pro bono service in the representation to low-income taxpayers, based on these…
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ABA Tax Section Hosts Webcast Today on The Implications of Citizens United on Exempt Organizations
The ABA Tax Section offers a teleconference and webcast today on Citizens United — Implications of Corporate Political Free Speech for the EO Sector from 1:00 – 2:30 p.m. EST: Earlier this year, in the Citizens United case, the Supreme Court held that corporations (and, by extension, unions) cannot constitutionally be prevented from expressing support for…
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ABA Tax Section Hosts Webcast Today on Planning for Debt Discharge Income and § 108 Relief
The ABA Tax Section offers a teleconference and webcast today on Planning for Debt Discharge Income and § 108 Relief from 1:00 – 2:30 p.m. EST: Using a unique problem format, this panel will discuss the tax aspects of the realization of debt discharge for COD income and the planning opportunities available for exclusion or deferral under…