Congratulations to Orly Mazur LL.M. ’13, the winner of the 2013 David F. Bradford Memorial Prize for Best Paper in Taxation. The Bradford Prize is dedicated to the memory of David F. Bradford, who taught at Princeton University and NYU School of Law.
Orly’s paper is titled “Taxing the Cloud”. A brief abstract of the paper follows:
After decades of expanding worldwide, companies have now reached the clouds. The cloud represents a new method of using information technology resources that may forever change how we use our computers and the Internet. Instead of purchasing or downloading software, we can now use the Internet to access software and other fundamental computing resources located on remote computer networks operated by third parties. These transactions offer companies lower operating costs, increased scalability and improved reliability, but also give rise to a host of international tax issues. Despite the rapid growth and prevalent use of cloud computing, U.S. taxation of international cloud computing transactions has yet to receive significant scholarly attention. This Article seeks to fill that void by analyzing the U.S. tax implications of operating in the cloud. Such an analysis shows that the technological advances associated with the cloud put pressure on traditional U.S. federal income tax principles, which creates uncertainty, compliance burdens and liability risks for companies and a potential loss of revenue for the government. In light of these problems, federal attention is warranted to clarify how U.S. federal income tax principles apply to businesses operating in the cloud. Thus, this Article proposes that Congress and Treasury issue guidance that clearly addresses the U.S. tax implications of international cloud computing services. Specifically, Congress should issue new statutory guidance to clarify the characterization, source, and taxation of global cloud computing transactions and collaborate with other countries to achieve international consensus on these issues. Together these changes will ensure that the United States appropriately taxes the cloud and does so in a manner that minimizes double taxation and promotes efficiency, equity and administrative simplicity.
- Orly Mazur
On Monday, October 15th, from 12:30 PM to 1:30 PM in Vanderbilt Hall Room 210, Elena Romanova (JD ’02, LL.M. ’03), Director and Head of Consumer Banking Tax Advisory, at Citigroup, Inc. will lead a session on the in-house tax function at large companies. The objectives of this program are to (a) inform students who plan to work for corporate law firms and accounting firms about the duties and needs of the in-house tax director, “the client” and (b) describe the skills that students need to develop over time if they plan to transition to an in-house position in the future. This event is open to all students.
Elena V. Romanova is a Director and the Head of Consumer Banking Tax Advisory at Citigroup Inc. in New York. She was an associate at Cleary Gottlieb Steen & Hamilton LLP from 2003 to 2010 and served as a Tax Policy Fellow at the U.S. Treasury Department, Office of Tax Policy in the fall of 2002. In her work, she focuses on U.S. federal income tax aspects of financial products and corporate transactions and on cross-border tax planning.
Ms. Romanova received a J.D. degree, magna cum laude, from New York University School of Law in 2002 where she served as a student editor of the Tax Law Review, an undergraduate degree, summa cum laude, from the University of Houston in 1996, and a degree of Master of Professional Accountancy in Taxation from Indiana University in Bloomington in 1999. She also received an L.L.M. in Taxation from New York University School of Law in 2003.
Alumni Tax Luncheon in Los Angeles, CA
Wednesday, February 8 at 12:00 p.m.
Beverly Hills Hotel, Sunset Ballroom,
9641 Sunset Blvd, Beverly Hills, CA
The Office of Alumni Relations invites you to a luncheon for tax alumni in Los Angeles on Wednesday, February 8, 2012 hosted by Charles P. Rettig (LL.M. ’82), principal at Hochman, Salkin, Rettig, Toscher & Perez, P.C. The event features Professor Joshua Blank who will present a paper titled “Corporate Tax Abuse in the Supreme Court” (co-authored with Professor Nancy Staudt of USC School of Law). Click here to register!
NYU Law’s International Tax Program (ITP) has announced the formation of the Practice Council, a new organization that will serve in an advisory and supporting capacity for the ITP. Its members, distinguished tax practitioners from 15 countries, will promote the ITP throughout the world, provide assistance in recruiting students and global faculty, participate in seminars and other programs at the Law School, help with fundraising and scholarship efforts, and advise on curriculum development. It will meet once a year, usually in New York. “We expect great things from the new Practice Council,” says ITP director David Rosenbloom. “It will bolster our educational efforts in many ways.”
The ITP provides full-time, foreign-trained students a firm grounding in the U.S. international tax system and offers multiple courses that reflect the globalization of tax law principles and practices. It draws students from around the world – participants to date have come from 40 countries.
The University of Kansas has named Stephen W. Mazza (LL.M. ’93) as dean of its School of Law
Mazza has been interim dean since July 1, 2010. Mazza joined the KU law faculty in 1998. An honors graduate of the University of Alabama School of Law, he received his master of laws degree from New York University School of Law, where he was managing editor of the Tax Law Review. After practicing in the tax section of a large Atlanta law firm, he returned to NYU as an acting assistant professor.
The announcement from the University of Kansas is available here.
Craig M. Boise (LL.M. '99)
Cleveland State University has named Craig M. Boise (LL.M. ’99) as dean of the Cleveland-Marshall College of Law.
Most recently, Boise served as law professor at DePaul University in Chicago, where he was director of the Graduate Tax Program. Prior to that, he was an associate law professor at Case Western Reserve University. Boise will be Cleveland-Marshall’s 14th dean and the law school’s first African-American dean.
The announcement from Cleveland State University is available here.
On January 24, 2011, the Internal Revenue Service selected Charles Rettig (LL.M. ’82) to serve as the 2011 chairman of the IRS Advisory Council (IRSAC). In 2010, Rettig was vice chair of IRSAC, which offers a public forum for IRS officials and the public to discuss key tax administration issues.
Rettig, a partner at Hochman, Salkin, Rettig, Toscher & Perez in Beverly Hills, is a member of the National Board of Advisors of the NYU School of Law Graduate Tax Program and the advisory boards of the NYU Institute on Federal Taxation and the California Franchise Tax Board. In 2009, Rettig was among Tax Notes/Tax Analysts’s tax people of the year.