Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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ABA Tax Section Fall Meeting
The three-day fall meeting of the ABA Tax Section kicks off today in Toronto. Tax Profs with speaking roles include: Court Procedure & Practice: Litigating The Application of Anti-Tax Avoidance Statutes – Learning From The Canada Experience — Martin J. McMahon, Jr.) Employee Benefits: Distributions Update — Kathryn Kennedy (John Marshall) Employee Benefits: Litigation Update — Joshua Erlich (Georgetown) Exempt…
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ABA Releases Law Student Tax Challenge Problem
The ABA Tax Section has released the problem (J.D.; LL.M.) and updated rules (J.D.;LL.M.) for the 10th Annual Law Student Tax Challenge: An alternative to traditional moot court competitions, the Law Student Tax Challenge asks two-person teams of students to solve a cutting-edge and complex business problem that might arise in everyday tax practice. J.D.: This…
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ABA Tax Section Hosts Webcast Today on Tax Strategy Patents After Bilski
The ABA Tax Section offers a teleconference and webcast today on Is This the Beginning or Is It the End? — Implications of Bilski on Patenting Tax Strategies from 1:00 – 2:30 p.m. EST: Are tax planning methods patentable? This question has concerned tax practitioners for years. Tax patents are part of a broader group known…
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Charles Egerton Named ABA Tax Section Chair
The ABA announced today that Charles H. Egerton (Mead, Egerton, Bloodworth, Capouano & Bozarth, Orlando, FL) has been selected to chair the 22,000-menber ABA Tax Section. He will serve a one-year term, to be succeeded by William M. Paul of Covington & Burling (Washington, D.C.), who was chosen to serve as chair-elect. From the ABA press…
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ABA Tax Section Hosts Webcast Today on The Coming Regulation of Federal Tax Return Preparers
The ABA Tax Section offers a teleconference and webcast today on Be Prepared: A [Scout’s] Guide to the Coming Regulation of Federal Tax Return Preparers from 1:30 – 3:00 p.m. EST: The IRS has completed its study of Federal tax return preparers and has concluded that Federal regulation is warranted. As the IRS and Department of Treasury…
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ABA Tax Section Publishes Summer 2010 Issue of News Quarterly
The ABA Tax Section has published 29 News Quarterly No. 4 (Summer 2010): Opinion Point: The Ethereal Angel List, by Thomas Greenaway (KPMG, Boston), pp. 1, 21-22 Section Meeting Calendar, p. 2 From the Chair (Stuart M. Lewis) (Buchanan Ingersoll & Rooney, Washington, D.C.), pp. 3, From the Chair-Elect (Charles H. Egerton) (Dean, Mead, Egerton, Bloodworth, Capouano…
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted these comment letters: Notice 2009-93 and the Pilot Program to Truncate Taxpayer ID Numbers on Payee Statements (July 22, 2010) Qualification of S Corporation Debt to Shareholders (July 26, 2010) Recommendations for the 2010-11 Treasury-IRS Guidance Priority List (July 28, 2010)
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ABA Tax Section Hosts Webcast Today on Tax Strategy Patents After Bilski
The ABA Tax Section offers a teleconference and webcast today on Is This the Beginning or Is It the End? — Implications of Bilski on Patenting Tax Strategies from 1:30 – 3:00 p.m. EST: Are tax planning methods patentable? This question has concerned tax practitioners for years. Tax patents are part of a broader group known…
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ABA Tax Section Submits Comment Letter on Contingent Fees in Circular 230
The ABA Tax Section has submitted a comment letter on Contingent Fees in Section 10.37 of Circular 230 (July 15, 2010): Section 10.27 of Circular 230 regulates fees charged by tax practitioners concerning matters before the IRS and restricts the use of unconscionable or contingent fees in tax-related representations. In general, these Comments discuss the provisions in §…
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The Tax Lawyer Publishes New Issue
The Tax Lawyer has published Vol. 63, No. 3 (Spring 2010): In Memoriam: Steven C. Salch, 63 Tax Law. 223 (2010) Nina E. Olson (National Taxpayer Advocate), 2010 Erwin N. Griswold Lecture Before the American College of Tax Counsel: Taking the Bull by Its Horns: Some Thoughts on Constitutional Due Process in Tax Collection, 63 Tax Law.…
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted comment letters on: Disclosure of Uncertain Tax Positions Proposed § 355 Regs on Active Trade or Business Requirement The Taxation of Carried Interests Proposed § 901 Regs on Compulsory Tax Payments
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Cummings: The Supreme Court’s Federal Tax Jurisprudence, 1801-2010
Jasper L. Cummings, Jr. (Alston & Bird, Raleigh, NC) has published The Supreme Court's Federal Tax Jurisprudence: An Analysis of Fact Finding Methods and Statutory Interpretation from the Court's Tax Opinions, 1801-Present (ABA, 2010), the first book in the ABA Tax Section's new "Studies in Taxation" series. The Supreme Court's Federal Tax Jurisprudence occupies an original space…
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ABA Tax Section Accepting Nominations for 2011-2013 Public Service Fellowships
The ABA Tax Section is accepting applications for Public Service Fellowships for 2011-2013: Applications must be received by October 4, 2010 to be considered. Applicants selected for interviews will be invited to attend the Section’s meeting in Boca Raton on January 20-22, 2011, and asked to participate in interviews on January 22, 2011.
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ABA Tax Section Hosts Webcast Today on Current Developments in Circular 230
The ABA Tax Section offers a teleconference and webcast today on Hot Topics and Current Developments in Circular 230 from 1:30 – 3:00 p.m. EST: The Office of Professional Responsibility (“OPR”) has been expanded recently in light of the Service’s interest in upgrading the quality of tax practice and as part of an aggressive effort to…
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ABA Asks IRS to Withdraw Proposal Requiring Taxpayers to Report Uncertain Tax Positions
The ABA Committee on Government Affairs on Friday sent this letter to the IRS expressing its opposition to the proposals to require taxpayers to disclose uncertain tax positions to the IRS: On behalf of the ABA, I write to express our concerns regarding the proposals contained in IRS Announcement 2010-9, 2010-7 I.R.B. 408, Announcement 2010-17, 2010-13 I.R.B. 515,…
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ABA Tax Section May Meeting
The ABA Tax Section May Meeting concludes today in Washington, D.C. The full program is here. Highlights of the meeting were: The Laurence Neal Woodworth Memorial Lecture in United States Tax Law and Policy on Tax Policy in the 21st Century: Challenges and Changes from the Time of Larry Woodworth by Thomas Barthold (Chief of Staff of the Joint Committee…
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted comment letters on: Corrections of Failures of Nonqualified Deferred Compensation Plans to Comply with § 409A(a) Proposed Regs on Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Corporate Stock or Securities Proposed § 509(a)(3) Regs on Type III Supporting Organizations Notice 2008-115 Reporting and Wage Withholding Requirements with Respect to Amounts…
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ABA Tax Section Publishes Spring 2010 Issue of News Quarterly
The ABA Tax Section has published 29 News Quarterly No. 3 (Spring 2010): Hot Topics and Current Developments in Circular 230, by Christine L. Weingart (Dean, Mead, Egerton, Bloodworth, Capouano & Bozarth, Orlando, FL), pp. 1, 12-13 Section Meeting Calendar, p. 2 From the Chair (Stuart M. Lewis) (Buchanan Ingersoll & Rooney, Washington, D.C.), pp. 3, 17 Tax…
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The Tax Lawyer Publishes New Issue
The Tax Lawyer has published Vol. 63, No. 2 (Winter 2010): J. Ross Macdonald (Baker & McKenzie, New York), "Songs of Innocence and Experience": Changes to the Scope and Interpretation of the Permanent Establishment Article in U.S. Income Tax Treaties, 1950-2010, 63 Tax Law. 285 (2010) Martin J. McMahon, Jr. (Florida) & Daniel L. Simmons (UC-Davis), A…
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted comment letters on: Hearings on Federal Wealth Transfer Taxes Technical Correction to ARRA Change in § 1374 Built-In Gain Tax Reform of Federal Wealth Transfer Taxes IRS Funding and Proposed Funding for Assistance to Low-Income Taxpayers Proposed § 706 Partnership Taxable Year Regulations Proposed Additional Examples on Program-Related Investments by Exempt Organizations Temporary…
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Thomas Barthold to Deliver Woodworth Memorial Lecture in U.S. Tax Law and Policy
Thomas Barthold, Chief of Staff of the Joint Committee on Taxation, will deliver the Laurence Neal Woodworth Memorial Lecture in United States Tax Law and Policy on May 6, 2010, at the ABA Tax Section Midyear Meeting. The title of the lecture is Tax Policy in the 21st Century: Challenges and Changes from the Time of…
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ABA Tax Section Accepting Nominations for 2011-2013 Public Service Fellowships
The ABA Tax Section is accepting applications for Public Service Fellowships for 2011-2013: Applications must be received by October 4, 2010 to be considered. Applicants selected for interviews will be invited to attend the Section’s meeting in Boca Raton on January 20-22, 2011, and asked to participate in interviews on January 22, 2011.
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ABA Tax Section Seeks to Hire a Pro Bono Staff Counsel
The ABA Tax Section is looking to hire a Pro Bono Staff Counsel to work in the Washington, D.C. staff office: The Tax Section’s Pro Bono Staff Counsel works with the Section’s Pro Bono Committee to coordinate efforts to provide service to the pro bono tax assistance community and individual taxpayers. As such, he/she assists in providing…
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ABA Tax Section Webcast Today on The Economic Substance Doctrine
The ABA Tax Section offers a teleconference and webcast today on The Economic Substance Doctrine from 1:00 – 2:30 p.m. EST: The new health care legislation contains a codification or "clarification" of the economic substance doctrine. This teleconference will examine what the new statutory language says and how it came about. The panelists will also review recent case law,…
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ABA Tax Section Webcast Today on The Prosecution and Defense of Offshore Bank Accounts
The ABA Tax Section offers a teleconference and webcast today on The Prosecution and Defense of Offshore Bank Accounts from 1:00 – 2:30 p.m. EST: Thousands came forward in connection with the voluntary disclosure program, but many more did not. This program will discuss the government’s efforts to prosecute these cases, and the defenses that are available.…