Paul L. Caron
Dean
Pepperdine Caruso
School of Law
News
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Law Firm Corporate Tax Rankings
Chambers has ranked the top U.S. law firms by various specialities. The rankings are based on over 14,000 one-hour interviews with lawyers and clients (greater weight is given to the views of clients). Here are the top Top 28 law firms in the area of Tax: Corporate and Finance, grouped in five bands, with the
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Student Gets Two Points For Writing “F*** Off* on Exam
The Times: Markers Award Students for Writing Obscenities on GCSE Papers: Write ‘f*** Off’ on a GCSE Paper and You’ll Get 7.5%. Add an Exclamation Mark and It’ll Go Up to 11%, by Joanna Sugden: Pupils are being rewarded for writing obscenities in their GCSE English examinations even when it has nothing to do with
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Today’s WSJ Tax Editorials
Corporate Tax Cut Windfall: For those who still claim that tax rates don’t matter to economic decisions or U.S. competitiveness, we present Exhibit A: the 2004 American Jobs Creation Act. This law gave American companies a one-year window in 2005 to repatriate earnings from foreign subsidiaries to the United States at a 5.25% tax rate.
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Fear Factor: 30% of Lawyers Are Worried About Losing Their Jobs
ABA Journal, Nearly 30% of Lawyers Surveyed Fear Firing Above the Law, Associate Life Survey: Feeling Sluggish?
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Tax Profs Fault Amazon’s “Audacious” State Tax Strategy
Wall Street Journal: Will Amazon Get a Visit From the Tax Man?, by Lee Gomes: New questions are being raised about an audacious legal strategy Amazon.com has used to avoid collecting sales tax in eight states where it has warehouses or distribution centers, including populous ones such as Pennsylvania and Virginia. Texas has been examining
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Tax Treatment of Settlement Agreements with Confidentiality Provisions
Interesting discussion on the Drug and Device Law Blog on the tax treatment of settlement agreements with confidentiality provisions. Mark Herrmann (Jones Day) blogged the famous Amos case (T.C. Memo. 2003-329), which involved the tax treatment of damages paid by Dennis Rodman to a courtside camerman he kicked, and cited this piece in suggesting that
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WSJ: Obama’s Social Security Fine Print
Wall Street Journal: Obama’s Social Security Fine Print, by Donald L. Luskin: Last week, Barack Obama revealed his plan to shore up Social Security’s shaky finances by raising the income level on which the payroll tax is applied. Currently, incomes above $102,000 are exempt, with that threshold rising every year indexed to wage inflation. Mr.
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NY Times: One-Time Tax Break Saved 843 U.S. Corps $265 Billion
New York Times: A One-Time Tax Break Saved 843 U.S. Corporations $265 Billion, by Lynnley Browning: More than 840 of the largest American corporations reaped a $265 billion windfall thanks to a one-time tax break aimed at bringing home profits stashed overseas, according to recent government data. The windfall resulted from a temporary tax deduction
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Ventry: Gay Marriage and the Marriage Tax Penalty
I recently blogged four questions on Gay Marriage and the Marriage Penalty posed by Stephen Bainbridge (UCLA). Tax Prof Dennis Ventry (UC-Davis) provides thoughtful answers to the four questions: In states that recognize gay marriage, does state tax law likewise impose a marriage penalty? If so, will it be applied to gay marriages? Presumably, yes.
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What Can Brown Do To You: UPS Tax Lawyer Drops Dime on FedEx, Prompts Ohio to Reclassify Drivers as Employees, Resulting in $654k Tax Liability
Bloomberg News: UPS Lobbyist Secretly Spurred Ohio to Demand Taxes From FedEx, by John Hughes: A secret report from a lobbyist who represents United Parcel Service Inc. prompted an Ohio state investigation into employment practices of FedEx Corp., leading to a finding that FedEx owed back taxes and interest. Kenneth Kies, a Washington tax lawyer
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Crimm: Online Training for Charitable Trustees
Nina J. Crimm (St. John’s) has published a letter to the editor in this week’s Chronicle of Philanthropy, How to Avoid Scandals: Online Training for Trustees: The Chronicle of Philanthropy and other news organizations repeatedly report stories involving conflicts of interest, financial scandals, and other abuses of fiduciary duties by charities’ board members. … [A]
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Corn Products
Corn Products Refining Co. — of § 1221 fame — (350 U.S. 46 (1955)) is being acquired by Bunge for $4.4 billion. Corn Products Press Release Associated Press Bloomberg News New York Times Reuters Wall Street Journal (Hat Tip: David Shakow.)
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David Cay Johnston Launches Tax Notes Column
David Cay Johnston, who won the Pulitzer Prize for his tax reporting in 2001 and recently accepted a buyout after thirteen years with the New York Times, has agreed to write a regular column for Tax Notes called Johnston's Take. The inaugural column, The Price of Civilization, appears in this week's issue (119 Tax Notes
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Aprill: Legislation Needed to Exclude All Student Loan Forgiveness From Income
On Friday, I blogged the IRS’s issuance of Rev. Rul. 2008-34, which clarifies that law school public interest loan forgiveness programs qualify for the § 108(f) exception (and, as a result, students need not report the forgiven interest as discharge of indebtedness income). Ellen Aprill (Loyola-L.A.) cautions that "because the tax-free status of loan forgiveness
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You Might Be An Economist If…
Last year, I blogged the comedy stylings of Yoram Bauman, Ph.D., the "World’s First and Only Stand Up Economist." Check out his very funny bit, You Might Be An Economist If… Friday’s New York Times’ Freakonomics Blog gave him a shout-out. (Hat Tip: Martin Tittle.)
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IRS Blesses Law School Student Loan Forgiveness Programs
I previously blogged (links below the fold) the uncertainty over whether law school loan forgiveness programs (in which law schools forgive the debt of their students who work in the public following graduation) result in discharge of indebtedness income to the students or whether the programs qualify for the exception in § 108(f)(1). The IRS
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Sharpton Lawyers Up in Tax Probe
From today’s New York Daily News: Sharpton Gets Big Gun to Fend Off Feds, by John Marzulli: Facing an escalating federal probe into his charity’s finances, the Rev. Al Sharpton now has his own muscle: former Brooklyn U.S. Attorney Zachary Carter. Sharpton said Thursday he hired Carter – a respected ex-prosecutor – to represent him
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U.S. Firms Repatriated Billions More Than Expected
Bloomberg News: U.S. Firms Repatriated Billions More Than Expected, Study Says, by Ryan J. Donmoyer: U.S. companies such as McDonald’s Corp. and Procter & Gamble Co. took advantage of a one-year tax incentive to repatriate a total of $312 billion, dwarfing forecasts, a study found. Grant Thornton LLP, the Chicago-based accounting firm, said about 8%
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Gay Marriage and the Marriage Penalty
Gay Marriage and the Marriage Penalty, by Stephen Bainbridge (UCLA): In states that recognize gay marriage, does state tax law likewise impose a marriage penalty? If so, will it be applied to gay marriages? Presumably, yes. If so, will gays be less likely to marry in states with a marriage penalty? If the federal government
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Ex-UBS Banker Birkenfeld Pleads Guilty in Tax Evasion Case
Former UBS banker Bradley Birkenfeld pleaded guilty today in federal court in Fort Lauderdale, Florida, admitting that he helped California billionaire real estate developer Igor Olenicoff evade income taxes on $200 million in assets hidden in Liechtenstein and Switzerland. Associated Press Bloomberg News Reuters
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Welcome to the Tax Blogosphere: Ted Seto
Ted Seto (Loyola-L.A.) has joined the Tax Prof blogosphere with Understanding Tax, with his inaugural post on Bonus Depreciation is Not Necessarily a Good Idea.
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New $10 Million Fund to Support Tax Research
The Tax Policy Center today announced a new $10 million fund to support tax research: The Urban-Brookings Tax Policy Center, a joint project of the Urban Institute and the Brookings Institution, has launched a new intellectual venture capital fund to help policymakers, the public, and the media better understand the U.S. tax system and the
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JK Harris Settles Lawsuit by 18 State AGs
JK Harris, which bills itself as "The Nation’s Largest Tax Resolution Company" with 425 locations in 45 statesand and advertises its ability to help taxpayers settle tax issues with the IRS for pennies on the dollar, has agreed to pay $1.5 million in restitution to former clients and to change its advertising as part of
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WSJ: Should Mortgage Foregiveness Exception be Extended to Nonhousing-Related Debt-Financed Spending?
Today’s Wall Street Journal: More Loan Forgiveness Sought; Group Is Lobbying to Extend Tax Relief for Homeowners, by Arden Dale: A new law to give tax relief to homeowners who refinance a mortgage doesn’t go far enough for some. The Mortgage Forgiveness Debt Relief Act of 2007 gives a tax break to a homeowner when