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March 09, 2023 From the Chair

It Is a Great Time to Be a Tax Lawyer

Wells Hall

San Diego Midyear Meeting

The Midyear Meeting in the Hilton San Diego Bayfront Hotel met our attendance expectations with 1090 registrants for the three-day meeting in sunny Southern California. It was great to see the committee meeting rooms filled to capacity and panels dealing with current tax developments, including guidance from the IRS and Treasury implementing the Inflation Reduction Act (the IRA). The IRS Chief Counsel’s Office played a significant role in the meeting through participation in numerous panels and hosting two booths in the Exhibit Area focusing on (i) career opportunities with the Chief Counsel’s office and (ii) upcoming guidance under the IRA. The Welcome Reception on Thursday evening (sponsored by Asbury Law Firm) and the Joint Forum Reception on Friday evening (co-hosted by the Women in Tax Forum and the LBGTQ+ Lawyers in Tax Forum and sponsored by Taylor Nelson Amitrano)—both located on the Sapphire Terrace overlooking the San Diego Bay—were delightful networking opportunities for everyone in attendance. The meeting was concluded by the Section Luncheon and Plenary Session on Saturday, featuring a presentation by Lily Batchelder, Assistant Secretary for Tax Policy for the Treasury Department, the presentation of the 2023 Janet Spragens Pro Bono Award, and the recognition of the new Section Officers and Council for 2023–2024. All registrants were provided with access to the audio recordings of the Midyear Meeting at no extra cost. Non-registrants can order the audio recordings for a nominal charge.

The Next Generation of Tax Lawyers

It was great to see so many young lawyers and diverse lawyers in attendance at the Midyear Meeting and participating in panel discussions and presentations—even moderating panel discussions. As noted in my last From the Chair Column, “It’s All About Membership,” the shift to virtual and hybrid Section meetings during the pandemic exposed many Section members, including law students and members recently admitted to the bar, to the quality of our Section programs.

Law and accounting firms are hiring new tax lawyers at an unparalleled clip. Careers in tax are plentiful and “it is a great time to be a tax lawyer!” Still, it has been disconcerting to hear from a number of Section members that “my firm will not reimburse associates for attending in-person meetings unless they are speaking or participating in a panel discussion.” For those of us who appreciate what the Tax Section has to offer, this is a short-sighted approach for law and accounting firms to take. How do you get to speak or serve on a panel for a committee if you cannot first come to a Tax Section meeting to meet committee members? Signing up to work on a committee comment project is an excellent way to get involved with one of the Section’s 36 substantive committees. The substantive committees of the Section need volunteers to work on comment projects, serve on panels, lead subcommittees, and support committee activities. These opportunities open the doors for all new Section members to move into leadership positions with the committees and the Section. Committee chairs are actively recruiting young and diverse Section members to get involved. Only by attending meetings in person can members fully appreciate the relationship and network building opportunities the Section has to offer!

Section Involvement in Government Submissions

Consistent with our mission, “to serve our members and the public by providing education about taxes and tax systems, and by providing leadership to support the development of an equitable, efficient and workable tax system,” the Section has been hard at work drafting and submitting comments to the IRS and the Treasury Department on provisions of the IRA enacted in August 2022. Many of our committees have collaborated in the comment process, including participation in virtual and in-person meetings with the IRS Chief Counsel’s Office and the Treasury Department in December. The government appreciates the technical feedback provided in our comment letters. All Section comments are reviewed by the Committee on Government Submissions (COGS), which is chaired by Michael Desmond. Vice Chair of Government Submissions Lisa Zarlenga, Section Counsel Meg Newman, and the Chair of the Section sign off on comments, as required under the COGS style manual and conflict of interest policy. The 2022–2023 government submissions are available on the Section website, along with the archives of prior Section submissions since 1997.

If you are interested in becoming involved in the comment process with respect to the IRA or other items on the priority guidance list, the first step is to reach out to the Chair of the committee with responsibility for the applicable Code sections, join the committee, and volunteer to join or lead a working group for the project comments.

Corporate Counsel Section Involvement

The ABA Section Officers Conference (SOC) recently announced that it is recruiting “in-house counsel” members of Sections Divisions and Forums (SDFs) of the ABA to participate in a recently commissioned “In-House Counsel Outreach Strategies Task Force.” We have identified a group of Section members who are interested in exploring the possibility of creating a Corporate Counsel Committee of the Section and participating in the SOC Task Force, as well as considering further ways to collaborate with the similar committees of the Business Law and Litigation Sections. If you are serving in an in-house counsel or tax director role or otherwise have an interest in being involved in the new committee, please contact me ([email protected]), Jennifer Noel ([email protected]) or Jennifer Austin ([email protected]), and we will get you involved.

Registration for the Loretta Collins Argrett Fellowships Is Now Open

In 2022, the Section announced the inaugural class of Loretta Collins Argrett Fellows. The goal of the Argrett Fellowship is to identify, engage, and infuse historically underrepresented individuals into the Section, create a more accessible, equitable, and inclusive pathway into Section leadership, and support the expansion, diversification, and inclusiveness of the tax profession in order to create a space and sense of belonging for those looking to become involved with the Section. The Loretta Collins Argrett Fellowship is a three-year program. Applicants need not be members of the Section or ABA.

Each year, the Section will award a maximum of five Fellowships, renewable for up to three years. Because of the excitement about the new program and the Section’s desire to acknowledge the impressive group of applicants, eight Fellowships were awarded in the initial year, and all of the Fellows attended the Midyear Meeting in San Diego. Applications for the 2023 Fellowships are now open, and due by Sunday, April 2, 2023.

Nolan Fellow Nominations Open

The Section committee chairs, vice-chairs and Council members will make nominations for the 2023–2024 Class of Nolan Fellows now through April 3, 2023. Nominees must be current members of the Section who have made some significant contribution to a Tax Section committee or task force, or to the Tax Section in general. It is generally recommended that nominees be a member of the bar of any state or the District of Columbia for 10 years or less and be under 40 years of age. Either or both of these limitations may be waived by the selection committee in appropriate circumstances upon request.

The fellowship covers travel and registration for the three Section Meetings beginning in the fall of 2023 and other networking benefits. This is a wonderful opportunity for mid-career members of Section committees with leadership potential to network, gain exposure to the Section, and build their professional resumes. Many of the Section’s officers and Council members were once Nolan Fellows. Members of the Section are encouraged to suggest potential nominees to nominators for consideration.

Upcoming Section Events

Helped by the dedicated work of Alice Abreu and led by former Section Chair Julie Divola, the Section co-sponsored with the American Tax Policy institute (ATPI) and other organizations a symposium on “The Federal Income Tax: Racially Blind but Not Racially Neutral” in Washington, DC on February 24, 2023. In addition, the Section is sponsoring several in-person, virtual, and hybrid programs to provide members with ongoing access to current tax education and CLE credit, including the following:

2023 ABA/IPT Advanced Tax Seminars
March 13–17, 2023
Royal Sonesta, New Orleans, LA

23rd Annual U.S. and Europe Tax Practice Trends
March 29–31, 2023
Dolder Grand, Zurich, Switzerland

2023 May Tax Meeting
May 4–6, 2023
Marriott Marquis, Washington, DC

15th Annual U.S. and Latin America Tax Practice Trends
June 14–16, 2023
Mandarin Oriental, Miami, Florida

Look for additional offerings in the future as Chris Tank, our Director of CLE, is continually rolling out new programs to meet the demand.

Register for the May Meeting

We hope to see you and your colleagues at the May Meeting at the Marriott Marquis in Washington D.C. on May 4–6! You can register online now.

Wells Hall

Nelson Mullins Riley & Scarborough LLP, Charlotte, NC

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