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As I write this column, we are well into the Tax Section’s 2016–2017 year. I am pleased that we have made good progress on many tasks, but there is much that remains to be accomplished, not least of which is how we as tax lawyers will prepare for the tax reforms that will likely come our way as a result of this last election cycle and how the Section can contribute to the process.
In Analog Devices, Inc. v. Commissioner, the Tax Court overturned the BMC Software case that was the applicable precedent. It did so largely because the Fifth Circuit overturned its own BMC Software ruling. This choice comes with significant consequences.
In a welcome decision for Canadian acquirors and targets, the Tax Court of Canada recognized, in Rio Tinto Alcan Inc. v The Queen, that certain “oversight expenses”—including certain investment banking and other professional advisory fees—should be deductible in the context of M&A transactions.
State and local governments have been able to issue bonds that bear interest that is exempt from federal income tax. Those bonds, however, must meet certain conditions.
Partnership tax aficionados will recall that Congress passed the Bipartisan Budget Act of 2015 (the BBA) as amended by the PATH Act of 2015, in record time. That law established a new partnership audit and assessment regime and repealed prospectively the current TEFRA partnership audit rules. Even though more than a year has passed, much remains unknown—both at the federal and the state level.
For this edition of Pro Bono Matters, I thought it would be interesting to write about some of the tax cases that have been handled on a pro bono basis. Most cases are settled short of trial, and therefore the tremendous results obtained by pro bono volunteers are not publicized. Nevertheless, there have been several reported opinions in the past that are noteworthy and important for the specific taxpayers and the low-income taxpayer community as a whole.
As chair of the Tax Section’s Pro Bono Award Committee, I am honored to announce that this year’s recipient of the Janet R. Spragens Pro Bono Award is C. Wells Hall, III, of Charlotte, NC, the former Tax Section Vice Chair of Pro Bono and Outreach.
The Second Edition of The Supreme Court’s Federal Tax Jurisprudence comes at a time when Congress is pushing the tax law into new and uncharted territory while we all hold out hope for the fundamental reform of the Internal Revenue Code that is long overdue. This review was originally published as the Foreword in The Supreme Court’s Federal Tax Jurisprudence, Second Edition.
The move to a digital-only format has allowed ATT to expand the types of materials we publish. One new feature is reviews of books and articles on topics of interest to our members.
The Section is pleased to announce the winners of the 16th Annual Law Student Tax Challenge, a contest designed to give students an opportunity to research, write about, and present their analyses of a real-life tax planning problem.
Sing along with Tax Bits to the tune of “Without a Song,” by Vincent Youmans, Billy Rose and Edward Eliscu (1929).
This conference—now in its thirty-third year as the National Institute on Criminal Tax Fraud, and its sixth year since combining with the National Institute on Tax Controversy—brings together tax practitioners, judges, and representatives from the IRS and the Department of Justice for three days of workshops and programming topics related to tax controversy, tax litigation, and criminal tax prosecution and defense.
In accordance with Sections 4.2, 6.1, and 6.3 of the Section of Taxation Bylaws, the following nominations have been submitted by the Nominating Committee for terms beginning at the conclusion of the 2016 Annual Meeting in August.
Since January 1, 2016, the Section has coordinated government submissions, which are available to the public on the Section’s website.
Named for the late Jack Nolan, a dedicated and respected Tax Section member, the Nolan Fellow distinction is awarded to young lawyers who are actively involved in the Section and have shown leadership qualities.
The Tax Lawyer, the nation’s premier tax law journal, is published quarterly as a service members of the Tax Section.
What is an hour of your time worth?
Through the Tax Assistance Public Service (TAPS) endowment fund, the Section of Taxation seeks to provide stable, long-term funding for its tax-related public service programs.
Produced in cooperation with the Tax Section and published by ALI-CLE, The Practical Tax Lawyer offers concise, practice-oriented articles to assist lawyers with all aspects of tax law.
ABA Tax Times (ATT) is looking for volunteers to join its ranks as associate editors to assist in writing and acquiring articles for publication.
ABA Tax Section meetings are a great way to get connected, get educated, and get the most from your membership!
Listen at your convenience to high-quality tax law CLE on a variety of topics.
Opportunities are available to enhance your visibility, grow your network, and expand your reach at ABA Section of Taxation meetings.
New editions of the Supreme Court's Federal Tax Jurisprudence and State & Local Tax Deskbooks are now available!
Did you know that Tax Section members have access to thousands of pages of cutting-edge committee program materials presented at Section of Taxation Meetings?
The Section of Taxation thanks the sponsors and exhibitors of the 2017 Midyear Meeting.
Thomson Reuters Checkpoint Catalyst™ delivers tax research framed in an entirely new way, so you see the clarity, color and context you need to get the whole picture of each business tax issue.