Vol. 39 No. 3 - Spring 2020

Taxation

Interview with Dianne Mehany

By Jeremiah Coder, Washington, DC

ABA Tax Times interviewer Jeremiah Coder recently spoke with Dianne Mehany, a member of Caplin & Drysdale Chtd., about her decision to choose a career in tax and her experiences working in tax controversy. ...

Taxation

Foreign Asset Reporting and U.S. Territories

By Usman Mohammad, Kostelanetz & Fink, LLP, New York, NY

Puerto Rico, American Samoa, Guam, The United States Virgin Islands, The Northern Mariana Islands—these are all United States territories or possessions. Individuals born in these territories are deemed by law to be either United States citizens or United States nationals. ...

Taxation

The OECD’s International Compliance Assurance Programme

By Kun-Chol Kim, S.J.D. Candidate, University of Florida Levin College of Law, Gainesville, FL

Cooperative compliance, a model that emerged in 2008, aims to improve taxpayer service and tax compliance by requiring transparency in exchange for certainty. The model requires taxpayers to demonstrate how they handle transactions and tax risks; in return, it requires tax administrations...

Taxation

Impact of Basis Adjustment for Sale of Lower-Tier CFC Stock on Upper-Tier GILTI and Subpart F

By Charles E. A. Lincoln, IV, Washington, DC

This article deals with one of the many unanswered questions of the 2017 tax legislation—the potential impact of a basis adjustment on sale of a lower-tier controlled foreign corporation’s (CFC’s) stock for an upper-tier CFC’s global intangible low-taxed income (GILTI) and Subpart F calculations. ...

Taxation

Consider Establishing a New Low Income Taxpayer Clinic

By Tamara Borland, Director, LITC Program, Taxpayer Advocate Service, IRS

As Director of the LITC Program at the IRS, I would like to invite readers to consider whether you or an organization you are affiliated with might be interested in applying for a 2021 Low Income Taxpayer Clinic (LITC) grant. ...

Taxation

Economic Impact Payment Information Translation and Outreach

By Frank Agostino, Agostino & Associates, Hackensack, NJ

On March 21, 2020, Congress passed the CARES Act, a package of measures intended to provide emergency assistance to individuals and businesses in light of the coronavirus pandemic. The CARES Act provides for Economic Impact Payments (EIP) of $1,200, plus an additional $500 per qualifying child, to every eligible American. ...

Taxation

The Next Normal—Tax Responses to COVID-19

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

The Greek philosopher Heraclitus has been attributed with coining the phrase “change is the only constant in life.” His philosophical expressions have been quoted by judges in many cases. For example, Judge Posner once invoked Heraclitus’ famous statement that no person ever steps into the same river twice...

Taxation

Women in Tax: Making It Better for Others

By Bridget T. Roberts, Deputy National Taxpayer Advocate, Washington, DC

Giving a keynote address is an extraordinary privilege and requires some level of inspiration in picking a topic. When I spoke at Villanova last fall, I decided to consider my personal experience and what, based on that experience, women in the tax profession can do to make things better for those who come after us. ...

Taxation

Tax Section Offers COVID-19 Tax News

By Julie Divola, Pillsbury Winthrop Shaw Pittman LLP, San Francisco, CA and Keith Fogg, Clinical Professor of Law, Harvard Law School, Jamaica Plain, MA

In response to the COVID-19 pandemic, the Tax Section is pleased to offer COVID-19 Tax News and Information, a regularly updated source of tax information and resources related to the pandemic. We curate the page daily, seeking to include all relevant listings from government, private, and Section sources. ...

Taxation

Thriving Partnership of The Tax Lawyer with Northwestern Tax Program

By Keith Fogg, Clinical Professor of Law, Harvard Law School, Jamaica Plain, MA, and Vice-Chair, Publications, ABA Tax Section

Nearing completion of its second year, The Tax Lawyer partnership with the Northwestern Tax Program provides excellent student editing for the journal’s authors and readers. Under the guidance of faculty editor David Cameron...

Taxation

Shanthy Bala, Justin Miller, Arsalan Malik, Carolyn Lee, Anson Asbury, and Stephanie Lipinski Galland

S02E17 through S02E22. James Creech interviews Shanthy Bala, Justin Miller, Arsalan Malik, Carolyn Lee, Anson Asbury, and Stephanie Lipinski Galland.

Taxation

Who’s Willful Now?

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

To tune of, Who’s Sorry Now?, performed by Frankie Carle in 1952, written by Ted Snyder, Bert Kalmer and Harry Ruby (1923), and made into a hit recording by Connie Francis (1958) and Patsy Cline.

Taxation

Tax Section Virtual Meetings in June and July

The Tax Section is pleased to announce the Virtual 20th Annual U.S and Europe Tax Practice Trends Conference, which will provide sessions developed for the meeting previously intended to be held in Munich. The Section is also pleased to announce development of the Virtual 2020 May Tax Meeting...

Taxation

2020–2022 Christine A. Brunswick Public Service Fellows

The ABA Section of Taxation is pleased to announce the 2020-2022 Christine A. Brunswick Public Service Fellowship class.

Taxation

2020–2021 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

Tax Implications of COVID-19 Webinars

The Tax Section is pleased to offer Tax Implications of COVID-19, a series of webinars providing the latest guidance and analysis on taxation initiatives responding to the pandemic. The series launched on April 2 and has included numerous webinars, with more planned. ...

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

TaxIQ: Access Materials from Past Section Meetings

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—Spring 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—May 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

2020 IRS Nationwide Tax Forums Go Virtual

The 2020 IRS Nationwide Tax Forums will be virtual, and registration is now open. Designed for tax professionals, the IRS Nationwide Tax Forums offer 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

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.