Vol. 29 No. 4 - Summer 2010

Opinion Point

Taxation

The Ethereal Angel List

Thomas Greenaway

In March 2010, Congress codified the economic substance doctrine by adding section 7701(o) to the Code. Health Care and Education Reconciliation Act of 2010, Pub. L. No. 111-152, § 1409, 124 Stat. 1029, 1067. To pass muster, a transaction now must meaningfully change the taxpayer’s economic position...

From the Chair

Taxation

From the Chair

Stuart M. Lewis

The Tax Section is a truly impressive operation. Over the last year I have come to an even greater appreciation of how well the Section functions. While many aspects of the Section’s work have been impressive, the three that most caught my attention have been...

From the Chair-Elect

Taxation

From the Chair-Elect

Charles H. Egerton

Experience has taught me that before charting a course for the coming year, it is important to reflect on the year that has passed. The Section has been very fortunate during the past year to have had the leadership of our outgoing Chair, Stuart Lewis. ...

Interview

Taxation

William J. Wilkins

Jasper L. Cummings, Jr. and Alan J.J. Swirski

President Obama appointed Bill Wilkins to be Chief Counsel of the Internal Revenue Service, and he has served in that position since August 2009. Previously Bill was a partner with Wilmer Hale in the D.C. office. Bill served as Chair of the Section of Taxation in 2008-2009. ...

Points to Remember

Taxation

Correcting Code Section 409A Document Failures

Brian A. Benko

In general, section 409A regulates nonqualified deferred compensation plans. Under these plans, a legally binding right is created between the service recipient and the service provider (herein referred to as “employer” and “employee”) to pay compensation in a subsequent taxable year. Section 409A requires, among other things...

Taxation

Academic Tracks? The Tax Attorney as Accounting Professor

Cheryl Crespi

If you are interested in an academic career and lifestyle, and an alternative to the 16-hour days which often typify the life of a tax attorney, then the option of an academic career in a school of business might be of interest. ...

Taxation

FATCA Provisions of the HIRE Act: Possible Effects on International Disclosure Norms

Vlad Frants

On March 18, 2010, President Obama signed the Hiring Incentives to Restore Employment Act (“HIRE Act”). Pub. L. No. 111-147, 124 Stat. 71. As its title suggests, this legislation was meant to incentivize new hiring by employers in order to stimulate the U.S. economy. ...

Taxation

Tax Court Invalidates New Section 6501(e) Regulations

Steve R. Johnson

The title of an article of mine in the Fall 2009 issue of the NewsQuarterly asked “What’s Next in the Section 6501(e) Overstated Basis Controversy?” The Tax Court answered that question on May 6, 2010, in its decision Intermountain Insurance Service of Vail, LLC v. Commissioner, 134 T.C. No. 11. ...

Taxation

Social Security Benefits Formula 101: A Practical Primer

Francine J. Lipman* and James E. Williamson

Social Security benefits redistribute income broadly and deeply every month across America. One out of every four households and one out of every six Americans receive these critically important benefits. ...

Distinguished Service Award

Taxation

2010 Distinguished Service Award Recipient: Ronald A. Pearlman

Susan P. Serota

The Section of Taxation is pleased to honor Ronald A. Pearlman, a professor of law at the Georgetown University Law Center, as our recipient of the Section of Taxation’s 2010 Distinguished Service Award in recognition of his lifelong contributions to the tax profession and the development of tax law and policy. ...

Public Service Fellowship

Taxation

2009 Public Service Fellow: Laura Newland

ABA Section of Taxation

Laura Newland received one of the first two Public Service Fellowships awarded by the Section in the program’s inaugural year, 2009. She began her Fellowship after graduating from Georgetown University Law Center in the spring of 2009, and has been providing tax assistance to low-income seniors in the Washington, DC area...

In Remembrance

Taxation

In Remembrance: Martin D. Ginsburg, 1932 – 2010

ABA Section of Taxation

On June 27 the Section and the tax law community lost a longtime friend, leader, and colleague, Martin D. Ginsburg. Marty served on the Section Council from 1984 to 1987 and received the Section’s highest award, the Distinguished Service Award, on May 5, 2006. His remarks from that day were subsequently published in the Summer 2006 issue of the NewsQuarterly and are reprinted here to honor his memory. ...

News Briefs

Taxation

News Briefs

ABA Section of Taxation

ABA Tax Section news and announcements.

Boxscore

Taxation

Boxscore

ABA Section of Taxation

Since April 2010, the Section has coordinated the following government submissions, which can be viewed and downloaded free of charge from the Section’s website.

American Bar Association TM American Bar Association

Vol. 29 No. 4 - Summer 2010

NewsQuarterly, Vol. 29 No. 4

Opinion Point

The Ethereal Angel List

From the Chair

From the Chair

From the Chair-Elect

From the Chair-Elect

Interview

William J. Wilkins

Points to Remember

Correcting Code Section 409A Document Failures

Academic Tracks? The Tax Attorney as Accounting Professor

FATCA Provisions of the HIRE Act: Possible Effects on International Disclosure Norms

Tax Court Invalidates New Section 6501(e) Regulations

Social Security Benefits Formula 101: A Practical Primer

Distinguished Service Award

2010 Distinguished Service Award Recipient: Ronald A. Pearlman

Public Service Fellowship

2009 Public Service Fellow: Laura Newland

In Remembrance

In Remembrance: Martin D. Ginsburg, 1932 – 2010

News Briefs

News Briefs

Boxscore

Boxscore