Vol. 39 No. 2 - Winter 2020

Taxation

Interview with Evan Phoenix

By Tameka E. Lester, Georgia State University College of Law, Atlanta, GA

ABA Tax Times interviewer Tameka Lester recently spoke with Evan Phoenix, a 2019-2021 ABA Tax Section Christine Brunswick Fellow, about his work at Bet Tzedek Legal Services and his experiences as a Brunswick Fellow. ...

Taxation

TCJA Taxation of Certain Nonresident Sales of Partnership Interests

By Jim Lynch, Sobel & Co. LLC, Livingston, NJ

The 2017 tax legislation (TCJA) added a section to the Internal Revenue Code—section 864(c)(8)—under which nonresident alien individuals and foreign corporations can be taxed on all or a portion of the gain from the sale of certain partnership interests. ...

Taxation

Trust and Estate Distributions in 2020 May Provide 2019 Tax Savings

By Katie A. Lepore, Miller, Monson, Peshel, Polacek & Hoshaw, APPLC, San Diego, CA

As March comes upon us, practitioners should be cognizant of the 65-day rule for trusts and estates under section 663(b) and a similar rule for charitable deductions under section 642. In a world where most individuals and trusts follow calendar-year reporting, generally actions taken after December 31 will be reported in the following year. ...

Taxation

Income Tax Planning with Retirement Accounts

By Oleg Ikhelson, PagnatoKarp, Reston, VA

Most people understand the value of contributing to retirement accounts during their productive years of gainful employment and then living off the accumulated nest egg after they retire. Certainly, the government’s tax policies today encourage deferring earned income until retirement. There is a good reason for this...

Taxation

Providing Pro Bono Assistance at the 2019 Fall Tax Meeting

By Susan E. Morgenstern, Taxpayer Advocate Service, Cleveland, OH

"How may I help?" That’s the question posed by the more than two dozen Tax Section lawyers who participated in the Section’s first pro bono clinic at the Fall Tax Meeting in San Francisco last October. Organized by Amy Spivey, Carolyn Lee, Susan Morgenstern, and Mandi Matlock...

Taxation

Evolution of Settlement Days

By Frank DiPietro, Low Income Taxpayer Clinic, Indiana Legal Services, Inc., Bloomington, IN

This article focuses on the continued evolution of Settlement Days by IRS Counsel offices and Low-Income Taxpayer Clinics (LITC). Settlement Days have grown from humble beginnings of notifying pro se petitioners that IRS Counsel was available to discuss their case on a certain day to full-fledged events including IRS Counsel, revenue officers, examination officers, and LITC attorneys. ...

Taxation

Recipients of the 2020 Janet Spragens Pro Bono Award: Hardin Matthews, Kelley Miller, and Larry Sannicandro

By Guinevere Moore, Johnson Moore LLP, Chicago, IL

As current chair of the Tax Section’s Pro Bono Award Committee, it is my privilege to announce that this year’s co-recipients of the Janet R. Spragens Pro Bono Award are Hardin Matthews, Kelley Miller, and Larry Sannicandro. ...

Taxation

The Young Lawyer’s Perspective on Tax Practice

By Brandon King, Baker & McKenzie LLP, Washington, DC

Young lawyers starting to practice tax in a law firm are, of course, both excited about the job and worried about the many new areas of tax law we will encounter. One of the most important concerns for us is training: we know that we will need assistance as we “learn the ropes” of our new positions, and we are eager for that assistance to help us learn how to be better tax lawyers. ...

Taxation

Winners of the 19th Annual Law Student Tax Challenge

The Section is pleased to announce the winners of the 19th 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. The competition is open to both J.D. and LL.M. law students. ...

Taxation

The Incompetent Authority: Questions and Answers

By Andy Howlett, Miller & Chevalier, Washington, DC; Guinevere Moore, Johnson Moore LLP, Chicago, IL; and Andrew Strelka, Latham & Watkins LLP, Washington, DC

The Incompetent Authority: Questions and Answers, provides some useful responses to your questions about the mysteries of the tax profession, including tax career, business of tax, tax ethics, and other burning tax questions. ...

Taxation

Alex Parker, Roberta Mann, William Schmidt, Caroline Ciraolo, Eric Solomon, Beverly Winstead, and Travis Thompson

S02E08 through S02E16. James Creech interviews Alex Parker, Roberta Mann, William Schmidt, Caroline Ciraolo, Eric Solomon, Beverly Winstead, and Travis Thompson.

Taxation

Mister Tax Collector

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

To the tune of I’ve Grown Accustomed to Her Face, by Frederick Loewe and Alan Jay Lerner, from the 1957 Broadway Musical My Fair Lady, as sung by Rex Harrison or Dean Martin (1960) or Diana Krall (2016).

Taxation

Diversity and Inclusion: An Overview of the ABA’s CLE Policy and the Section’s Plan and Committee

By Lany L. Villalobos, Dechert LLP, Philadelphia, PA

On November 6, 2019, the American Bar Association Section of Taxation announced its new Diversity and Inclusion Scholarships to encourage diversity and inclusion at Section tax meetings. The first group of scholarship recipients were invited to attend the 2020 Midyear Meeting in Boca Raton, Florida: Arsalan Malik and Rene Morency. ...

Taxation

Call for Applications: Diversity and Inclusion Scholarships to 2020 May Tax Meeting

The Tax Section is now accepting applications for the Diversity and Inclusion Scholarships, designed to encourage members of diverse backgrounds or with a recognized commitment to diversity and inclusion to attend and participate in the 2020 May Tax Meeting...

Taxation

Report of the Nominating Committee: 2020-2021 Nominees

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 2020 Annual Meeting in August. ...

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

Coming Soon and Available for Pre-Order: New Edition of Multijurisdictional Admission to Practice Requirements for State and Local Tax Lawyers

A project of the State and Local Taxes Committee and now in its second edition, the Guide to Multijurisdictional Admission to Practice Requirements for State and Local Tax Lawyers synthesizes the admission to practice requirements faced by state and local tax lawyers...

Taxation

TaxIQ: 2020 Midyear 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 2020 Issue Available Now

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—March 2020 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

Call for Book Reviews

ATT welcomes the submission of book and article reviews on tax topics that might be of interest to our members, including the following new titles...

Taxation

Ginsburg Tribute at May Meeting Plenary Session

The 2020 May Tax Meeting’s plenary session and section luncheon will feature a tribute to the late Professor Martin D. Ginsburg and U.S. Supreme Court Justice Ruth Bader Ginsburg. The tribute was inspired by the 2018 movie On the Basis of Sex, which depicts the couple’s successful representation of the petitioner in a tax case involving an unmarried man’s expenses to care for his dependent mother. ...

Taxation

5th International Conference on Taxpayer Rights

Taxpayer Rights, Human Rights: Issues for Developing Countries. Sept. 30 to Oct. 01, 2020. Pretoria, South Africa. Convened by Center for Taxpayer Rights.

Taxation

Tax Section Adjusts Dates for 2021 May Meeting and 2024 Fall Meeting

The Tax Section recently changed the dates for two upcoming meetings: the 2021 May Tax Meeting and the 2024 Fall Tax Meeting.

Taxation

2020 IRS Nationwide Tax Forums

Registration for the 2020 IRS Nationwide Tax Forums opens March 1, 2020. Designed for tax professionals, the IRS Nationwide Tax Forums offer three full days of seminars with the latest word from IRS leadership and experts in the fields of tax law, compliance and ethics. ...

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

2020 Midyear Tax Meeting Sponsors

Thank You To Our 2020 Midyear Tax Meeting Sponsors!

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.