Richard T. Page (J.D. 2010, Tulane) has published Comment, The International and Comparative Tax War: A Strategic Tax Cut Recommendation for the Obama Administration, 18 Tul. J. Int'l & Comp. L. 287 (2009): A. Purpose Statement:  The purpose of this Comment is to answer three comparative tax policy questions. First, should the Obama Administration reduce…

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Kristin E. Hickman (Minnesota) has published IRB Guidance: The No Man’s Land of Tax Code Interpretation, 2009 Mich. St. L. Rev. 239.  Here is the abstract: This Symposium Essay compares current patterns and practices surrounding IRS utilization of IRB guidance (revenue rulings, revenue procedures, and notices) with administrative law doctrine concerning informal agency guidance documents.…

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Long-time readers of this blog will recall the family trauma we endured 3 1/2 years ago when we had to put down our beloved family dog Sandy: Sandy soon became enmeshed in the daily rhythms of our family life. She came with me when I coached my kids' sports teams …  As time passed and we…

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Following up on my post exactly one month ago on The Give Blog:  in today's Chicago Tribune, Champaign Husband, Wife Are Ultra-Frugal So They Can Help Charities; They Aren't Giving Christmas Gift to One Another, but They Hope to Give Away $50,000: Suja Thomas, who wears socks with holes, isn't giving her husband anything for…

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Over 276,000 federal workers and retirees owed more than $3 billion in back income taxes in 2008 (up from $2.7 billion owed in 2007). The cabinet departments with the largest percentages of employee/retiree tax deadbeats are: Housing & Urban Development:  4.05% Veterans Affairs:  3.91% Health & Human Services:  3.86% Army:  3.76% Education:  3.60% Air Force:  3.25% Defense:  3.16% State:  3.14%…

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Dan Markel (Florida State), How Much Time Should a Job Offer be Open to Avoid Being Thought of as "Exploding?" Michael Froomkin (Miami), Exploding Offers Are Evil Brian Leiter (Chicago), What Constitutes an "Exploding Offer"? Dan Filler (Drexel), Are Exploding Offers So Bad? Jennifer Mnookin (UCLA), Law Teaching and "Exploding Offers" Ted Seto (Loyola-L.A.), "Exploding…

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The Berkeley Daily Planet, The Death of a Public Law School, by Benjamin Eisenberg (J.D. 2011, UC-Berkeley): The University of California Berkeley Law School is poised to become the most expensive publicly owned law school in the world. Over the next two years, fees will increase by 32%. That means that California students will soon pay…

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The Institute for Law Teaching and Learning has published the Fall 2009 issue of The Law Teacher. Stewart Harris (Appalachian) offers advice for those soon to hand out student evaluation forms in Sometimes, We Really Do Suck: While I don’t try to influence my written student evaluations — other than by teaching well — I have occasionally…

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Following up on my prior post: the IRS has filed a $34 million tax lien against Girls Gone Wild founder Joe Francis', two weeks after U.S. District Judge S. James Otero sentenced Francis to 301 days time served following his guilty plea to two misdemeanor counts of filing false tax returns. Tax Girl TMZ WebCPA  It was…

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From SSRN: SSRN HAS RELEASED ITS FREE iPHONE APPLICATION: iSSRN iSSRN provides instant access to the latest Social Science and Humanities papers from scholars around the world through the iPhone and iPod Touch. iSSRN is available as a free download from Apple's iTunes store. iSSRN allows SSRN's iPhone and iPod Touch users to search over…

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Former Joint Committee on Taxation Chief of Staff and current USC Tax Prof Edward D. Kleinbard is testifying today before the President's Task Force on Tax Reform, a part of the President's Economic Recovery Advisory Board (PERAB).  President Obama meets today with PERAB: Anna Burger, Chair, Change to Win John Doerr, Partner, Kleiner, Perkins, Caufield & Byers William…

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Following up on Friday's meeting of the President's Tax Reform Panel (President's Economic Recovery Advisory Board (PERAB)): Wall Street Journal, White House Panel Urged To Back Ready-Made Tax Returns, by Martin Vaughan Citizens for Tax Justice, Suggested Principles for Tax Reform Testimony of Barry Melancon (President & CEO, American Institute of Certified Public Accountants), Tax Reform…

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The Treasury Inspector General for Tax Administration yesterday released Procedures to Address Noncompliance With the Reporting Requirements for Contributions of Motor Vehicles Continue to Be Inadequate (2009-30-116): The Treasury Inspector General for Tax Administration (TIGTA) today publicly released its audit of taxpayer compliance with reporting requirements for motor vehicle donations. The report concluded that some…

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David Cay Johnston (left) delivered the Fourteenth Annual David R. Tillinghast (right) Lecture on International Taxation on Faux Firms and Fairness: Taxing Capital, Trade, and Production in a Global Economy at NYU: Johnston argued that government acquiescence in self-dealing transactions and foreign tax havens subverts revenue collection efforts to the detriment of the middle and lower…

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Stephen E. Shay, a tax partner at Ropes & Gray (Boston), has been named Deputy Assistant Secretary for International Tax Affairs in the U.S. Treasury Department.  From the Ropes & Gray press release: As deputy assistant for international tax affairs, Shay will be part of the Treasury’s Office of Tax Policy and have responsibility for…

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Eric A. Holzer, 34, a former tax associate at Paul, Hastings, Janofsky & Walker, pled guilty to insider trading after raking in $120,000 in illegal profits after an ex-Lehman Brothers broker tipped him off to upcoming M&A transactions.  Although the call for a maximum of 25 years in prison, the parties agree that the U.S. Sentencing Guidelines call for…

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I previously blogged California's list of the 250 biggest state tax deadbeats — which included Burt Reynolds, Sinbad, and Dionne Warwick.  TMZ reports that California has slapped a $284,000 tax lien on rapper Snoop Dogg.

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Tom Herman, author of the Wall Street Journal's weekly Tax Report column for 16 years, announced his retirement today: [T]his will be my final Tax Report as a full-time staffer for The Wall Street Journal, which I joined after graduating from college in 1968. After well over 1,000 articles on the tax beat since 1993,…

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Associated Press: Proposed Fee on Smelly Cows, Hogs Angers Farmers, by Bob Johnson: For farmers, this stinks: Belching and gaseous cows and hogs could start costing them money if a federal proposal to charge fees for air-polluting animals becomes law. Farmers so far are turning their noses up at the notion, which is one of…

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Posted by Neil H. Buchanan In "UBS Finds Limited Tax Fraud Involving Wealthy Americans," Julia Werdigier of The New York Times reports that "UBS has discovered only a small number of tax-fraud cases as part of an investigation into whether the Swiss bank helped clients dodge American taxes, the bank’s chairman, Peter Kurer, said Thursday." …

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Posted by Neil H. Buchanan Much of the discussion about a possible rescue of the Big Three automakers has been colored by the claim that blue collar workers at those companies earn $70/hour.  The original (or, at least, the most prominent) source of this claim seems to have been a recent column in The New…

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Posted by Neil H. Buchanan Wednesday's New York Times included a very good article by David Leonhardt about President-Elect Obama's selection of Lawrence Summers to be the Director of the National Economic Council.  For those who (like me) find Summers endlessly fascinating, frustrating, and impossible to categorize, it is a must-read.  Although Leonhardt takes a…

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Posted by Victor Fleischer Important changes in the tax law don't always make their way through the usual legislative process.  Some significant changes come in the form of a Notice, Revenue Procedure, or Revenue Ruling.  Notices and Revenue Procedures are sometimes used to give taxpayers a safe harbor — some certainty for planning purposes —…

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Posted by Victor Fleischer As Paul has already highlighted, tax lawyers are scratching their heads over the Treasury's legal authority to issue Notice 2008-83, which allows banks (but no one else) to avoid the usual application of Section 382's limitation on built-in losses following a change in control.  Apparently the staffs of the tax-writing committees…

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Michael Knoll (Penn) has posted Taxation and the Competitiveness of Sovereign Wealth Funds: Do Taxes Encourage Sovereign Wealth Funds to Invest in the United States? on SSRN.  Here is the abstract: Sovereign wealth funds (SWFs) control vast amounts of capital and have made and are continuing to make numerous large, high-profile investments in the United States, especially in…

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