Vol. 38 No. 3 - Spring 2019

Taxation

Tax Section Launches Podcasts

By Linda M. Beale, Wayne State University, Detroit, MI

We are delighted to announce the launch in this issue of the ABA Tax Times of a new feature, People in Tax Podcasts. These conversations will provide insight into the various careers in tax enjoyed by our members and information about career trajectories, from education through involvement in the Tax Section’s many activities.

Taxation

Lany Villalobos

In S01E01, James Creech and Lany Villalobos discuss the Christine Brunswick Fellowship, diversity, mentorship, and tax representation as social justice. (Interview at the 2019 Midyear Tax Meeting, New Orleans, LA.)

Taxation

Combating Aggressive Tax Planning Through Disclosure: A Comparison of U.S. and EU Rules Applicable to Tax Advisors

By Patricia A. Brown, Director of the Graduate Program in Taxation, University of Miami School of Law; Victor Jaramillo, Caplin & Drysdale, Washington, DC; Vincent van der Lans, Loyens & Loeff, New York, New York; Floris Verweijmeren, Loyens & Loeff, New York, New York; and Diane Ring, Professor and Dr. Thomas F. Carney Distinguished Scholar, Boston College Law School

We are amidst a major change in the world of taxation, focused in substantial part on deterring tax abuse in both the developed and developing world. Governments are now automatically exchanging financial account information. The IMF, OECD, UN, and WBG have taken aim at the disposition of assets through the use of offshore indirect transfers. Moreover, the publication of the OECD/G20 Base Erosion and Profit Shifting (BEPS) reports has sparked a number of reforms. The common goal of these initiatives is “compliance,” which creates the impression that everyone is paying their “fair share” of the tax burden.

Taxation

IRS Fumble: What to Do When a Tax Assessment’s Validity Is Questionable

By Guinevere Moore, Johnson Moore, Chicago, IL

Back-to-back opinions released by the United States Tax Court on May 20 and May 21 of 2019 serve as compelling reminders that what we learned in kindergarten is true: the same rules really do apply to everyone. When the IRS does not follow required procedures, the Tax Court will not hesitate to invalidate an assessment and find for the petitioner.

Taxation

Taxpayer Advocate Service: Not Just for Low-Income Taxpayers

By Andrew R. Roberson, McDermott Will & Emery LLP, Chicago, IL

Many tax practitioners I have talked to over the years are aware of the Taxpayer Advocate Service (TAS), but are unfamiliar with how TAS operates and what kinds of cases it handles. Some have indicated that they view TAS as dealing primarily with issues for low-income taxpayers and not a resource for issues affecting corporate taxpayers or high-income individuals. This article seeks to dispel this common misconception and provide guidance on how TAS can help with all types of taxpayers and issues.

Taxation

A Retrospective Interview with 2014-2016 Christine A. Brunswick Public Service Fellow Patrick Thomas

In 2014, Patrick Thomas began a two-year commitment with the Neighborhood Christian Legal Clinic, in Indianapolis, IN, through the Christine A. Brunswick Public Service Fellowship. The experience inspired him to get involved with the Indianapolis clinic starting the summer after his first year of law school and led eventually to his broader involvement in the low-income taxpayer clinic (LITC) community.

Taxation

An Introduction to Tax Careers for J.D.s

By Heather M. Field, Professor of Law & Eucalyptus Foundation Chair, University of California, Hastings College of the Law; Senior Co-Director of the UC Hastings Center on Tax Law

To many people, the tax field seems like a very narrow niche. The tax profession does require specialized expertise, but tax professionals know that there is actually great diversity in the career paths available to law school graduates. Yet for law students and junior lawyers interested in the tax field, it can be difficult to appreciate the range of possible tax careers and to distinguish between what different tax practitioners do.

Taxation

It Hurts

By Robert S. Steinberg, Law Offices of Robert S. Steinberg, Palmetto Bay, FL

To the tune of “Love Hurts” by Boudleaux Bryant, as recorded by Roy Orbison and the Everly Brothers or even Don McLean.

Taxation

2019–2021 Christine A. Brunswick Public Service Fellows

The ABA Section of Taxation is pleased to announce the 2019-2021 Christine A. Brunswick Public Service Fellowship class.

Taxation

2019–2020 John S. Nolan Fellowships

Named for the late Jack Nolan, a dedicated and respected ABA Section of Taxation member, the Nolan Fellow distinction is awarded to young lawyers who are actively involved in the Section and have shown leadership qualities.

Taxation

2019 Distinguished Service Award Recipient: Emily A. Parker

By Mary McNulty, Thompson & Knight LLP, Dallas, TX, and Lee Meyercord, Thompson & Knight LLP, Dallas, TX

The Distinguished Service Award is the highest honor awarded by the Section of Taxation of the American Bar Association. It is reserved for individuals who have had a distinguished career in taxation and who have provided an aspirational standard for all tax lawyers to emulate. The 2019 recipient of this award is Emily A. Parker – a landmark tax litigator, passionate and reasoned leader, long-time community advocate, and dedicated and effective mentor.

Taxation

Government Submissions Boxscore

Government submissions are a key component of the Section's government relations activities. The full archive is available to the public on our website.

Taxation

Tell the Tax Section What’s Missing in Your Tax Law Library

Help the ABA Section of Taxation fill the gap by letting us know what topics to publish next.

Taxation

TaxIQ: 2019 May Tax Meeting Materials Available

Did you know that ABA Section of Taxation members have access to thousands of pages of cutting-edge committee program materials presented at Section meetings?

Taxation

The Tax Lawyer – Winter and Spring 2019 Issues Are Available

The Tax Lawyer, the nation's premier tax law journal, is published quarterly as a service to members of the ABA Section of Taxation.

Taxation

The Practical Tax Lawyer – May 2019 Issue Now Available

Produced in cooperation with the ABA Section of Taxation and published by ALI-CLE, The Practical Tax Lawyer offers concise, practice-oriented articles to assist lawyers with all aspects of tax law.

Taxation

Support the Section’s Public Service Efforts with a Contribution to the TAPS Endowment

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.

Taxation

Get Involved in ATT

ABA Tax Times (ATT) is looking for volunteers to join its ranks as associate editors to assist in writing and acquiring articles for publication.

Taxation

Section Meeting & CLE Calendar

ABA Section of Taxation meetings are a great way to get connected, get educated, and get the most from your membership!

Taxation

2019 May Tax Meeting Photos

View photos from the 2019 May Tax Meeting in Washington, DC.

Taxation

Section CLE Products

Listen at your convenience to high-quality tax law CLE on a variety of topics.

Taxation

Sponsorship Opportunities

Opportunities are available to enhance your visibility, grow your network, and expand your reach at ABA Section of Taxation meetings.

Taxation

2019 May Tax Meeting Sponsors

The Section of Taxation thanks the sponsors and exhibitors of the 2019 May Tax Meeting.

Taxation

Thomson Reuters | Publishing Sponsor

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.