A Taxing Blog

Friday, July 25, 2003
Government Victory  
NYTimes article on the Seventh Circuit's decision that an accountant's clients did not have an expectation of privacy and thus the accountant must disclose the identity of investors in tax shelters.

Wednesday, July 23, 2003
Tax Policy Project  
Taxprof Katie Pratt and I are thinking about doing a research project looking at how we teach tax policy in American law schools.

The main goal of the project would be descriptive -- what are we teaching students, and what sources are we using? The end result would be a sort of annotated bibliography that might be useful to teachers, tax policy students, students interested in teaching, and maybe even policy wonks (e.g. staffers on the Hill who want to read up on the EITC or the flat tax debate).

I'm also thinking of going beyond the descriptive, though, and writing a commentary piece on where I think there might be gaps in the literature. In particular, I think that not enough is being written (or taught) about business tax policy issues and about tax planning.

The one exception to this is tax shelters, where there is probably more than enough out there.

My personal goal out of this, like the tax canon post I wrote a while back, is to think about what I want to teach in my "Deals" class and my basic tax class at UCLA.

Comments or thoughts on this topic would be most welcome. For the practitioners out there --- what do you wish had been covered in your tax policy class, or your tax curriculum in general? For taxprofs and tax students out there, would an annotated bibliography be useful? What information would you want to see?

Email me at fleischer at law.ucla.edu with any thoughts.

Monday, July 21, 2003
Paper on Corporate Expatriations  
Elizabeth Chorvat has posted a paper on corporate inversions or expatriations, i.e. moving headquarters to Bermuda: You Can't Take It With You: Behavioral Finance and Corporate Expatriations. Here's the abstract:

In 2002, reports of corporate expatriations filled the headlines. These reports come as something of a surprise because the tax rules enacted in the early 1990's should have prevented almost all of these transactions. Various commentators have tried to explain this phenomenon. However, these explanations are not consistent with the empirical evidence. This article proposes a solution to this problem by arguing that corporate managers are exploiting fluctuations in stock prices to expatriate at reduced cost. The article proposes legislation to reduce expatriations consistent with this model.

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