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).

Pathways to Tax Reform: The Future of Pass-Through Entity Taxation (Mon., April 22, 12:30 PM)

Please join us next Monday, April 22 from 12:30-1:30 PM in Furman Hall Room 324 for the next installment in our Pathways to Tax Reform Series.  Next week’s session is titled “The Future of Pass-Through Entity Taxation:  A Discussion of the Ways & Means Committee Proposals.” In March 2013, the House Ways and Means Committee released a discussion draft of proposals that would make fundamental changes to the way that partnerships and S-corporations are taxed.  If enacted, these provisions would take effect in 2014.  These proposals may play an important role as the discussion of business tax reform progresses in DC.  In this one-hour session, Professors Willard Taylor (NYU, Sullivan & Cromwell LLP) and John Steines (NYU) will provide an overview of the proposals and will moderate a group discussion.  In addition, Mark Warren and Harold Hancock (House Ways & Means Committee) will provide commentary by phone.  To help you prepare for the event, we have attached an outline, which describes the proposed legislation.

To RSVP for this event, please e-mail Jason Haynes at HaynesJ@exchange.law.nyu.edu.

Recent Developments in Tax Controversy (Thurs., April 4, 7:00 PM)

Thurs., April 4th, 7:00-9:00 PM, Faculty Library, 3rd Floor of Vanderbilt Hall

The New York Region of the Federal Bar Association Section on Taxation invites you to attend a discussion on recent developments in tax controversy. The presentation will include a discussion on recent court opinions on economic substance, debt-versus-equity, expert witness testimony, and discovery. The discussion will be followed by light refreshments. The primary speakers at the event will be Brian Power, Mayer Brown LLP and Elizabeth McGee, Shearman & Sterling LLP. Please RSVP to Erin Rodgers at erodgers@fedbar.org .

Ask the Expert (Witness): A Conversation With Professor Dan Shaviro (Thurs., April 4th, 12:30 PM)

Thurs., April 4th, 12:30-1:30 PM, Furman Hall Room 330

What happens when a law professor becomes an expert witness?  What sorts of challenges and issues does he or she face, what’s it like, and how does it relate to teaching and research activities?  Professor Daniel Shaviro, Wayne Perry Professor of Taxation (NYU), will address these questions and more, based generally on his recent experiences.  This program should be of interest to lawyers and future lawyers (especially tax lawyers) who may seek the services of expert witnesses, as well as to law professors who may consider becoming expert witnesses themselves.  Light refreshments will be served, but please feel free to bring your lunch.  To RSVP, please e-mail Greg Zwahlen at gregory.zwahlen@nyu.edu .

Pathways to Tax Reform: Progressive Consumption Taxation: The X Tax Revisited (Wed., April 3, 12:30 PM)

Please join us on Wednesday, April 3 from 12:30-1:30 PM in Vanderbilt Hall Room 216 for the next installment of our “Pathways to Tax Reform Series” for a discussion with Dr. Alan D. Viard, resident scholar at the American Enterprise Institute.  Dr. Viard will outline a proposal to “completely replace the income tax system with a progressive consumption tax.”  He will argue that his approach “avoids the problems arising from the adoption of a consumption tax alongside the income tax and also avoids the distributional problems posed by regressive consumption taxes, such as the VAT.” Before joining the American Enterprise Institute, Dr. Viard was a senior economist at the Federal Reserve Bank of Dallas and an assistant professor of economics at Ohio State University. He has also worked for the U.S. Treasury Department’s Office of Tax Analysis, the White House’s Council of Economic Advisers, and the Joint Tax Committee.  In January 2010, Dr. Viard was named by Tax Notes as a nominee for 2009 Tax Person of the Year.  To RSVP, please e-mail Greg Zwahlen at gregory.zwahlen@nyu.edu .

Tax Movie Night! To Pay or Not To Pay: Tax Dilemmas in Sitcoms (Thurs., Mar. 28, 6:30 PM)

This Thursday, March 28, from 6:30 PM-8:30 PM, please join us for the 4th Annual NYU Tax Movie Night! This year’s event is titled “To Pay or Not To Pay: Tax Dilemmas in Sitcoms.”  We will screen four classic television episodes, spanning different decades, where major characters are faced with tax compliance choices.  Some characters choose to report their tax liabilities honestly and others do not.  The episodes featured are from “The Honeymooners” (1956), “The Phil Silvers Show” (1956), “The Mary Tyler Moore Show” (1975) and “The Simpsons” (1998).  Professor Lawrence Zelenak from Duke Law School will join us as a special guest speaker and will lead a discussion on what popular culture can teach us about public attitudes toward tax compliance.  Refreshments, including popcorn, will be served.

We should have plenty of space, but we would like to get a sense of how much food to order.  To RSVP, please click here .

Pathways to Tax Reform Series: “Supplemental Expenditure Tax” (March 6, 12:30 PM)

On Wednesday, March 6th from 12:30 PM to 1:50 PM in Vanderbilt Hall Room 202, the Graduate Tax Program will continue its Pathways to Tax Reform Series, which began last week at the Law School’s Forum.

Victor Thuronyi, Senior Counsel at the International Monetary Fund, will present a proposal for a “Supplemental Expenditure Tax,” which would facilitate an overall tax reform package.  A copy of the paper is attached.  The Supplemental Expenditure Tax would be very similar to the current income tax, except that includable receipts would be defined more broadly, the tax would not apply until income is consumed and investment would generally be deductible.  In addition to describing the proposal, the program will compare the Supplemental Expenditure Tax to several consumption tax alternatives.  Professor Daniel Shaviro, the Wayne Perry Professor of Taxation at NYU School of Law, and David Miller, Partner at Cadwalader, Wickersham & Taft LLP, will provide commentary.

Please feel free to bring your lunch to this event.  To RSVP, please email Kevin Agnese at kevin.agnese@nyu.edu .  We hope you will join us for what should be an interesting and informative discussion.

Cliffs Forever? Tax Reform and the Future of Fiscal Policy (Wed., Feb. 20th)

Cliffs Forever?

Tax Reform and the Future of Fiscal Policy

Wednesday, February 20, 12:25-1:50 p.m.

Vanderbilt Hall, Greenberg Lounge

40 Washington Square South

After weeks of negotiations, in the first days of January, Congress and the Obama Administration struck a last-minute deal that averted the so-called “fiscal cliff”, a combination of federal tax increases and budget cuts. Yet this compromise merely deferred until March 1st “sequestration”, which will cause the military and dozens of other government agencies to face about $1 trillion in automatic budget cuts over the coming decade. And, the debt limit again looms later in the year. Did Congress make progress toward reducing our fiscal shortfalls by enacting tax increases earlier this year? What is likely to happen in the upcoming sequestration negotiations and how will it affect the economy? Is tax reform the way forward, or is it a distraction? And why do budget and tax debates appear to occur only when the clock is ticking on looming high-stakes deadlines? Join a panel of experts for a timely discussion of these questions and more as we consider approaches to addressing America’s fiscal future.

Click here to RSVP for this event.

PANELISTS:

Rosanne Altshuler, Professor and Chair, Department of Economics, Rutgers University
David Kamin ’09, Assistant Professor of Law, NYU School of Law

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

MODERATOR:

Joshua Blank (LL.M. ’07), Professor of Tax Practice; Faculty Director of the Graduate Tax Program, NYU School of Law

Mitchell Kane files amicus brief in US Supreme Court foreign tax credit case, PPL Corp. v. Comm’r. Erin Scharff (’11) is counsel of record.

Mitchell Kane, Professor of Law, has co-authored an amicus brief in PPL Corp. v. Commissioner, Docket No. 12-43.  Erin Scharff, Acting Assistant Professor of Tax Law, was the counsel of record on the brief.  The U.S. Supreme Court will hear oral arguments in the case on February 20th.  The issue presented is “Whether, in determining the creditability of a foreign tax, courts should employ a formalistic approach that looks solely at the form of the foreign tax statute and ignores how the tax actually operates, or should employ a substance-based approach that considers factors such as the practical operation and intended effect of the foreign tax.”  A copy of the brief is available here.

David Kamin presents “Are We There Yet?: On a Path to Closing America’s Long-Run Deficit” (Jan. 23, 2013)

KaminOn Tuesday, January 22, David Kamin, Assistant Professor of Law, NYU School of Law, will present Are We There Yet?: On a Path to Closing America’s Long-Run Deficit at the Tax Policy Colloquium at NYU School of Law.  The co-convenors of the Colloquium are Daniel Shaviro, Wayne Perry Professor of Taxation, NYU School of Law, and William Gale, the Arjay and Frances Miller Chair in Federal Economic Policy in the Economic Studies Program at the Brookings Institution.  A brief abstract is below:

Many decry the fact that policymakers are nowhere close to addressing the longterm fiscal shortfall and as evidence they point to the Congressional Budget Office’s projection of enormous long-term deficits under current policy. This report contends that the minimum deficit reduction incorporated in leading progressive and conservative budgets can put us on a path toward closing the long-term deficit. A significant gap would remain even if consensus were fully realized. However, this report describes a plausible path for further cutting the long-term deficit, as well as important revenue and spending backstops. Finally, it explains that while the country can and should try to reach a fiscally sustainable path, because of the uncertainty surrounding many of those reforms — especially the restructuring of the healthcare system — we cannot expect an immediate solution.

A complete list of the Tax Policy Colloquium presentations for the rest of the Spring 2013 semester is available here.

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

Meet the Tax Press (Wed., Oct. 17th, 4 PM to 5:50 PM)

On Wednesday, October 17th from 4:00 PM to 5:50 PM in Vanderbilt Hall Room 214, please join us for a discussion with Zach Carter (Huffington Post) and Jia Lynn Yang (Washington Post), two reporters who cover tax stories. The panel will discuss what makes a great “tax story”, the sources of information for tax stories, why certain tax issues are often misreported in the press and, of course, tax issues in the upcoming Presidential election.  Professor Erin Scharff will moderate the discussion.

The In-House Tax Function (Mon. Oct. 15, 12:30 PM)

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.

Tax Orientation Events — Week of August 27th

During the week of August 27th, we will welcome all incoming Tax LL.M. students at the following tax orientation events:

  • Tax Specialization Meeting (Monday, August 27th, 3:30 PM to 5:00 PM, Greenberg Lounge, 1st Floor of Vanderbilt Hall). This session will address degree requirements, course selection and the tax job market, among other topics.  This session is mandatory for all full-time Tax LL.M. students.
  • Tax Welcome Reception (Monday, August 27th, 5:00 PM to 6:00 PM, Greenberg Lounge, 1st Floor of Vanderbilt Hall). Shortly after the tax specialization meeting, we will welcome you with a wine and cheese reception.  This will also be a great opportunity for you to meet your classmates.  This event is open to all Tax LL.M. students.
  • Tax Alumni Advising Breakfast (Tuesday, August 28th, 9:00 AM to 10:30 AM, Lipton Hall and the Faculty Club, D’Agostino Hall, 110 West 3rd Street). Recent alumni of the Graduate Tax Program will join us for a light breakfast to answer your questions and offer advice.  The atmosphere will be casual, so feel free to stay for all or part of the event.  This event is open to all Tax LL.M. students.
  • Tax Faculty Lunch (Tuesday, August 28th, 12:00 PM to 1:30 PM, Lipton Hall and the Faculty Club, D’Agostino Hall, 110 West 3rd Street). At this lunch, you will have a chance to meet with the tax faculty.  This event is open to full-time Tax LL.M. students only.  During the academic year, you will be assigned to a faculty advisor.  Many of our faculty advisors will be at the lunch. Foreign-educated students who are attending the preceding bar exam session may arrive late, as that session runs until 12:30 pm.
  • Tax Research Workshop (Friday, August 31st, 2:00 PM to 3:00 PM, Vanderbilt Hall Room 210). At this workshop, Professor Joshua Blank will provide an overview of helpful tax research tools that you can use as students at NYU and during your careers as practicing tax lawyers.  He will also provide general advice regarding class and exam preparation.  This event is open to all Tax LL.M. students.  Full-time Tax LL.M. students are strongly encouraged to attend.

NYU Tax Movie Night!: “We’re Not Broke” (Wed., Apr. 11, 6:30 PM)

On Wednesday, April 11th, from 6:30 PM to 9:00 PM in Vanderbilt Hall Room 204, the NYU Graduate Tax Program will host a special screening of a new documentary, “We’re Not Broke”, which premiered at the 2012 Sundance Film Festival.

According to the filmmakers, the documentary “tells the story of U.S. corporations dodging billions of dollars in income tax, and how seven fed-up Americans take their frustration to the streets…and vow to make the corporations pay their fair share.”  We will screen the film and then engage in a debate and Q&A discussion, featuring the following panelists:

Learn more about the film (and watch the trailer) here .

Refreshments, including popcorn, will be served.  We should have plenty of space, but we would like to get a sense of how much food to order.  To RSVP, please enter your contact information here .

GTP Lunch Series: Jim Peaslee, LLM’ 79 (Cleary Gottlieb) — April 2, 2012

Jim Peaslee

On Monday, April 2, from 12:30 PM to 1:30 PM in the Faculty Club, Jim Peaslee (LL.M. ’79) will be the fourth guest speaker of the Spring 2012 Graduate Tax Program Lunch Series.

Jim Peaslee is a Partner at Cleary Gottlieb. His practice focuses on tax matters. He is the co-author of Federal Income Taxation of Securitization Transactions (4th Edition, www.securitizationtax.com), as well as a number of articles on tax subjects. Best Lawyers selected Mr. Peaslee as its “2011 New York Tax Lawyer of the Year” and has consistently recognized him in The Best Lawyers in America. He is also distinguished as one of the best tax lawyers by Chambers Global, Chambers USA, The International Who’s Who of Business Lawyers, The Legal 500 and Euromoney Legal Media Group’s Best of the Best Guide. Mr. Peaslee is similarly included in the PLC Which Lawyer? Yearbook and the PLC Handbook: Tax on Corporate Transactions as a “highly recommended” tax lawyer. Mr. Peaslee was also recognized in International Tax Review’s “World Tax” rankings for his outstanding work in capital markets.

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

“Offshore Accounts, Tax Amnesties and Tax Compliance” (Tues., Apr. 3, 12:30 PM, VH 210)

On Tuesday, April 3 from 12:30 PM to 1:50 PM in Vanderbilt Hall Room 210, the Graduate Tax Program will host an event titled “Offshore Accounts, Tax Amnesties and Tax Compliance.”

In recent years, the federal government has pursued an aggressive crack down on U.S. taxpayers who have hid income in offshore bank accounts.  In a series of voluntary disclosure programs, the IRS has entered settlement agreements with thousands of U.S. taxpayers who have disclosed their accounts.  In other cases, the federal government has successfully prosecuted individuals who have not disclosed this information to the IRS.  This program will provide students with an overview of the offshore tax evasion dilemma and the government’s response and will also critique the use of tax amnesty programs as a way to increase voluntary compliance.  Participants in this event will offer both theoretical and “on the ground” analysis.

Moderator, Professor Joshua Blank, NYU School of Law

Please feel free to bring your lunch to this event!

**UPDATE**:  To view the panel, please click here .


Tax Movie Night!: First Encounters with the Income Tax

On Thursday, March 29th from 6:30 PM to 8:30 PM in the Lester Pollack Colloquium Room, Furman Hall, 9th Floor (245 Sullivan Street), the Graduate Tax Program will host a special event:  “Tax Movie Night!: First Encounters with the Income Tax.”  **NOTE NEW ROOM***

During this event, we will screen three classic television episodes, spanning four decades, involving individuals’ first encounters with the U.S. income tax system. The episodes featured are from “The Bill Dana Show” (1963), “Green Acres” (1970) and “3rd Rock from the Sun” (2000).  Professor Lawrence Zelenak from Duke Law School will join us as a special guest speaker.  After we screen the episodes (about 75 minutes), Professor Zelenak will lead a Q&A discussion.  Refreshments, including popcorn, will be served.

We should have plenty of space, but we would like to get a sense of how much food to order.  To RSVP, please enter your contact information here.

GTP Lunch Series: David Schnabel (LL.M. ’93) (Mon., March 26, 12:30 PM)

David Schnabel

On Monday, March 26, from 12:30 PM to 1:30 PM in the Snow Dining Room (4th Floor Vanderbilt), David Schnabel (LL.M. ’93) will be the third guest speaker of the Spring 2012 Graduate Tax Program Lunch Series.

David Schnabel is a tax partner at Debevoise & Plimpton LLP whose practice focuses on M&A transactions for private equity and corporate clients, as well as acquisition financing and private fund formation. He is also a member of the firm’s Management Committee. Mr. Schnabel is recognized as a leading corporate tax lawyer by Chambers USA (2010-2011), where he is noted for his “encyclopedic knowledge and thoughtful judgment.” He is also recommended by The Legal 500 US (2011), where he is noted as “one of the real experts in partnership tax – who can integrate technical tax answers with actionable and commercial solutions.” Mr. Schnabel is the Secretary of the Tax Section of the New York State Bar Association, former co-chair of the Investment Funds Committee, the Consolidated Returns Committee and the Partnership Committee, a member of the planning committee for the University of Chicago Law School Tax Conference and a fellow of the American College of Tax Counsel. He is a frequent speaker on the tax aspects of M&A and private equity, including at the NYSBA Annual Meeting, the Practising Law Institute, the ABA Section of Taxation Meeting and the NYU Tax Institute. He writes frequently on tax issues and is the author of the New York State Bar Association’s Report on the Cancellation of Indebtedness and AHYDO Rules of Sections 108(i) and 163(e)(5)(F) (2009), Report on Proposed Treasury Regulation Section 1.1502-13(g) Relating to Intercompany Obligations (2008), Report Responding to Notice 2006-14 Relating to the Treatment of Partnership Distributions under Section 751(b) (2006), Report on the Proposed Regulations and Revenue Procedure Relating to Partnership Equity Transferred in Connection with the Performance of Services (2005) and Report on Disguised Sales of Partnership Interests Responding to Notice 2001-64 (2003), as well as Great Expectations–The Basic Problem with Distressed Debt (University of Chicago Tax Institute), Structuring Preferred Stock Investments by Private Equity Funds (Practising Law Institute) and Revisionist History: Retroactive Federal Tax Planning (The Tax Lawyer 2007). He is also a contributing author of The Private Equity Primer: The Best of the Debevoise & Plimpton Private Equity Report and the Debevoise & Plimpton Private Equity Report.

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

“Taxation and Multi-period Global Cap and Trade” by Mitchell Kane

Mitchell Kane

Taxation and Multi-period Global Cap and Trade by Mitchell Kane, Professor of Law, NYU School of Law, has been published in the New York University Environmental Law Journal (19 NYU Env.L.J. 87 (2011)).  A brief abstract is below:

This paper analyzes the ways in which taxation can distort prices in greenhouse gas emissions permit markets that encompass multiple periods and multiple jurisdictions. The paper first distinguishes between two broad ways in which the tax system intersects with permit markets. The first relates to the optimal provision of public goods and encompasses the set of questions typically dealt with under the analysis of a potential “double dividend” from environmental taxes. The second relates to abatement efficiency and involves the removal of tax induced distortions to otherwise efficient incentives for firms to abate emissions at least cost. The paper then describes two ways in which a tax system can seek to address abatement efficiency. The tax system can attempt to equalize tax treatment of actual abatement across firms and the tax treatment of permits across firms (inter-firm neutrality). Or, the system can attempt to equalize the tax treatment of actual abatement and permits within each firm (intra-firm neutrality). The paper describes the requisite conditions for these two neutrality approaches and the predicted effects on permit prices. It also demonstrates that in a multi-period regime one can expect to observe both premia to banking permits (the typical lock-in problem described in the literature) as well as penalties to banking permits. Moreover, only the norm of inter-firm neutrality can adequately address both banking premia and banking penalties. The paper also shows that the preferred approach to neutrality is likely to evolve with the geographic expansion of the market. Inter-firm neutrality is the preferred approach in a national market because of its superior ability to deal with inter-temporal distortions; intra-firm neutrality is the preferred approach in the multi-jurisdictional context because of the relative ease of coordinating tax treatment within firms as opposed to across firms. Finally, the paper applies the relevant neutrality norms to two crucial tax policy questions that arise under permit markets: the appropriate treatment of permits allocated gratis and the appropriate sourcing of abatement and permit costs.

The NYU Graduate Tax Program

This Web site contains the latest news about events and happenings at the NYU Graduate Tax Program, the preeminent program of its kind. It is a resource for our students, faculty, alumni and anyone interested in learning more about our program.

Here is a link to the main Graduate Tax Program Web site which contains course information, faculty profiles and more.