James S. Eustice Memorial Fun Run (Thurs., May 8th, 7:15 AM) – TIME CHANGE

Eustice Marathon

Professor James S. Eustice,
NYC Marathon, 1979

Unfortunately, as a result of expected inclement weather, this event will be POSTPONED until Thursday, May 8th at 7:15 AM. We hope you can join us on the new date (when the weather will hopefully be more cooperative). Details are below.

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On Thursday, May 8th from 7:15 AM to 8:30 AM, the Graduate Tax Program will host its first James S. Eustice Memorial Fun Run in Hudson River Park.

Professor James S. Eustice was a legendary tax scholar and lawyer, who served on the faculty of NYU School of Law for several decades, most recently as the Gerald L. Wallace Professor of Taxation Emeritus.  Professor Eustice passed away in 2011.  Professor Eustice’s treatise, Federal Income Taxation of Corporations and Shareholders, co-authored with Professor Boris Bittker of Yale Law School, has long been viewed as the authoritative work on the subject, and has been widely cited by the Supreme Court and used by tax academics and practitioners regularly.  In addition, Professor Eustice was an avid runner and he participated in dozens of marathons.

In honor of the arrival of spring and Professor Eustice, we hope you will join us for a fun, 3-mile run along the Hudson River.  The event will be very casual – so please join us whether you run, jog or speedwalk.  Members of the tax faculty, including Professors Kamin, Steines, Speck and Blank will participate.  Here are the key details:

WHAT: James S. Eustice Memorial Fun Run

WHEN:  **NEW DATE** Thursday, May 8th, 7:15 AM – 8:30 AM

WHERE: Please gather along the Hudson River at West 12th Street and West Street.  Shortly after 7:15 AM, we will run from this point downtown to Stuyvesant High School and then we will return back uptown to West 12th Street.  The total distance is approximately 3 miles.  After the run, we will have bagels and light refreshments.

RSVP: Please click here: https://nyu.qualtrics.com/SE/?SID=SV_8iBEB6mdDQDyuzz .

RAIN POSSIBILITY: Please check your e-mail during the evening of Wednesday, April 30th.  If heavy rain is anticipated, we may postpone the event.

If you have any questions, please e-mail Hannah Olson at hannah.r.olson@nyu.edu .  We hope you can join us!

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Graduate Tax Program Lunch Series with William McRae – February 11th, from 12:30-1:30PM in Snow Dining Room

On Tuesday, February 11th, from 12:30 PM to 1:30 PM in Snow Dining Room, William McRae (LL.M. ’02) will be the first guest speaker of Spring 2014 for the Graduate Tax Program Lunch Series.

Bill McRae

William McRae

William McRae is a Partner in the Tax Group at Cleary in New York.  His practice focuses on U.S. federal income tax matters, including the taxation of financial products, corporate transactions and international mergers and acquisitions.  Mr. McRae is a member of the Bar of New York, and the New York State Bar Association, where he serves on the Tax Section Executive Committee.  He regularly speaks on tax matters at conferences, and has published several articles on tax matters, including “Financial Modeling from the Bench: Bank One and the Internal Revenue Service’s Attempt to Fix the Consequences,” Journal of Taxation and Regulation of Financial Institutions, Nov/Dec 2003, Vol. 17, No 2; “Character and Timing Rules in the Proposed Contingent Swap Regulations: First, Do No Harm,” Journal of Taxation and Regulation of Financial Institutions, March/April 2005, Vol. 18, No 4; “Contingent Interest Convertible Bonds and The Economic Accrual Regime”, “Everything I Know About New Financial Products I Learned from DECS” (published by the Practising Law Institute).

If you are a current NYU student and are interested in participating, please e-mail Hannah Olson.

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Orly Mazur LL.M. ’13 Wins 2013 Bradford Prize

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


 

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Book Symposium on Dan Shaviro’s Fixing U.S. International Taxation at Hebrew University Law School

In June, Daniel N. Shaviro, Wayne Perry Professor of Taxation, participated in a symposium at Hebrew University Law School on his forthcoming book, Fixing U.S. International Taxation (Oxford University Press, 2014).  The commentators were Steve Shay (Harvard), Yariv Brauner (Florida), and Fadi Shaheen (Rutgers-Newark).

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The Internal Revenue Code at 100 (Oct 19th)

The NYU Graduate Tax Program and UCLA School of Law cordially invite you to the second annual NYU/UCLA Tax Policy Symposium, titled “The Internal Revenue Code at 100,” on Friday, October 19, 2012 from 9:00 a.m. to 5:00 p.m. in Greenberg Lounge, Vanderbilt Hall, NYU School of Law, located at 40 Washington Square South.

This program is free of charge and will offer attendees 6 credits of CLE in the Area of Professional Practice.

The symposium will celebrate the 100th anniversary of the income tax in the United States. Participants will consider the evolution of the American income tax over the past century and will consider prospects for tax reform as the income tax begins its second century. The conference will feature panels on business taxation, international taxation, inequality and taxation and politics.  A list of the panels and participants is below.
The NYU/UCLA Tax Policy Symposium hosted by NYU School of Law and UCLA School of Law is a joint annual conference focusing on tax policy issues from both a legal and economic perspective. It provides a forum in which leading scholars, policy-makers, and practitioners can analyze complex tax policy questions and options for reform and brings together members of both NYU Law’s tax law faculty and UCLA Law’s business law and policy program. It builds on tax policy symposia that have historically been hosted by the Tax Law Review, the premier law school journal for tax policy scholarship published at NYU School of Law, and the UCLA Colloquium on Tax Policy and Public Finance, started in 2004.  Financial support for this conference is provided by NYU School of Law and the Lowell Milken Institute of Business Law and Policy, UCLA School of Law.

For more information and to RSVP for the conference, please click here, or copy and paste the following registration link:  http://nyulaw.imodules.com/taxconference .

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The Internal Revenue Code at 100, October 19th, 9:00 AM to 5:00 PM

Breakfast and Registration  8:30-9:00 a.m.  Greenberg Lounge

Introduction/Opening Remarks  9:00-9:20 a.m.

Deborah Schenk, Marilynn and Ronald Grossman Professor of Taxation, NYU Law School and Editor-in-Chief, Tax Law Review

Business Tax Panel 9:20-10:50 a.m.

Moderator:  Josh Blank, Professor of Tax Practice; Faculty Director, Graduate Tax Program, NYU Law School

  1. Kimberly Clausing, Thormund A. Miller and Walter Mintz Professor of Economics, Reed College
  2. Steven Bank, Professor of Law, UCLA Law School
  3. Noël Cunningham, Professor of Law, NYU Law School and Mitchell Engler, Professor of Law, Cardozo Law School

Break 10:50-11:05 a.m.

Inequality Panel   11:05 a.m. -12:35 p.m.

Moderator:  Jason Oh, Acting Professor of Law, UCLA Law School

  1. David Kamin, Assistant Professor of Law, NYU Law School
  2. Eric Zolt, Michael H. Schill Distinguished Professor of Law, UCLA Law School
  3. Len Burman, Daniel Patrick Moynihan Professor of Public Affairs, Maxwell School, Syracuse University

Lunch break 12:45-1:45 p.m.

International Tax Panel 1:45 – 3:15 p.m.

Moderator:  Daniel Shaviro, Wayne Perry Professor of Taxation, NYU Law School

  1. Mitchell Kane, Professor of Law, NYU Law School
  2. David Lenter, Legislation Counsel, Joint Committee on Taxation
  3. John Steines, Professor of Law, NYU Law School

Break  3:15 – 3:30 p.m.

Politics Panel 3:30 – 5 p.m.

Moderator:  Kirk Stark, Professor of Law, UCLA Law School

  1. George Yin, Edwin S. Cohen Distinguished Professor of Law and Taxation, Thomas F. Bergin Teaching Professor, University of Virginia School of Law
  2. Anne Alstott, Jacquin D. Bierman Professor of Taxation, Yale Law School
  3. Joseph Thorndike, Director, Tax History Project, Tax Analysts
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