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Monday, October 20, 2014
Dharmapala Presents Interest Deductions in a Multijurisdictional World Today at Loyola-L.A.
Dhammika Dharmapala (Chicago) presents Interest Deductions in a Multijurisdictional World at Loyola-L.A. today as part of its Tax Policy Colloquium Series:
The tax treatment of interest expenses in a multijurisdictional setting raises numerous complexities. This paper catalogs these difficulties and highlights the particular problems associated with efforts to achieve ownership neutrality among multinational corporations (MNCs) when debt financing is available. We argue that the differential deductibility of debt entailed by various current tax law provisions leads in general to potential distortions in the patterns of asset ownership across MNCs, and that various proposed solutions have significant limitations. We suggest several alternative regimes to address both the ownership distortions that we highlight, as well as other well-established problems of income-shifting through debt. These alternative regimes are extensions to a multinational setting of two general approaches to the neutral treatment of interest expenses - the CBIT (comprehensive business income tax) and ACC (allowance for corporate capital). These regimes – a worldwide debt cap (WDC) and a net financing deduction (NFD) – provide solutions to income-shifting and ownership distortions. However, they have the potential disadvantage of restricting other policy parameters.
Alexander Wu (UCLA) is the commentator.
October 20, 2014 in Colloquia, Scholarship, Tax | Permalink | Comments (0)
Frye: Crowdfunding as a Solution to the Inefficiency of the Charitable Deduction
Brian L. Frye (Kentucky), Solving Charity Failures, 93 Or. L. Rev. 155 (2014):
"Crowdfunding" is a way of using the Internet to raise money by asking the public to contribute to a project. This Article argues that crowdfunding has succeeded, at least in part, because it makes charitable giving more efficient by solving certain "charity failures," or inefficiencies created by the inability of the charitable contribution deduction to subsidize the charitable giving from low-income donors. The economic subsidy theory of the charitable contribution deduction explains that the deduction is justified because it solves market failures and government failures in charitable goods. According to this theory, free riding causes market failures in charitable goods, and majoritarianism causes government failures in charitable goods. The charitable contribution deduction solves these market and government failures by indirectly subsidizing charitable contributions, thereby compensating for free riding and avoiding majoritarianism. Crowdfunding is successful because it provides a technological solution to some of those charity failures. While the charitable contribution deduction causes charity failures because the deduction cannot subsidize contributions from low-income donors, crowdfunding can subsidize those contributions by offering rewards instead. As a result, crowdfunding should solve at least some of the charity failures caused by the deduction through providing an incentive for low-income donors to contribute. The remarkable success of crowdfunding suggests that the inefficiency associated with charity failures is quite large.
October 20, 2014 in Scholarship, Tax | Permalink | Comments (0)
Sunday, October 19, 2014
L.A. Times: Ed Kleinbard's We Are Better Than This Is 'Moral and Farsighted'
Los Angeles Times: On Fiscal Policy, USC Professor's Viewpoint is Moral and Farsighted, by Michael Hiltzik:
The left sees me as a Wall Street Journal Satanist, and the right as a stealth Marxian bent on destroying free enterprise," Edward D. Kleinbard was saying.
The USC law professor was referring to the reactions elicited by his recent op-ed in the New York Times, in which he asserted that the solution to economic inequality in the U.S. was not to make the tax system more progressive — it's already "the most progressive in the developed world," he wrote — but to make it bigger.
As he explained when we met last week at USC's Gould School of Law, where he has taught tax law since 2009, that would render the entire fiscal system more progressive, because it would fund more spending. Government spending is always progressive, benefiting middle- and lower-income people more than the wealthy. So: If you want to reduce inequality, expanding government is more effective than merely increasing the relative burden on the rich.
One can see why left and right alike felt that their shibboleths were being skewered.
But Kleinbard's viewpoint is both moral and farsighted. It's also an important theme of his newly published book, We Are Better Than This: How Government Should Spend Our Money.
October 19, 2014 in Book Club, Scholarship, Tax | Permalink | Comments (1)
Top 5 Tax Paper Downloads
There is quite a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads on SSRN, with new papers debuting on the list at #2 and #5:
- [338 Downloads] 2013 Developments in Connecticut Estate and Probate Law, by Jeffrey A. Cooper (Quinnipiac) & John R. Ivimey (Reid and Riege, Hartford)
- [236 Downloads] Trying Times 2014: Important Lessons to Be Learned from Recent Federal Tax Cases, by Nancy A. McLaughlin (Utah) & Steven J. Small ( Law Office of Stephen J. Small, Newton, MA)
- [139 Downloads] Rights Without Remedies, by Matthew L. M. Fletcher (Michigan State)
- [138 Downloads] Home-Country Effects of Corporate Inversions, by Omri Y. Marian (Florida)
- [136 Downloads] 'Show Me the Money!' -- Analyzing the Potential State Tax Implications of Paying Student-Athletes, by Kathryn Kisska-Schulze (North Carolina A&T) & Adam Epstein (Central Michigan)
October 19, 2014 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)
Friday, October 17, 2014
Open Access Legal Scholarship Is Cited 60% More in Law Review Articles, 40% More in Judicial Opinions
James Donovan (Kentucky), Carol Watson (Georgia) & Caroline Osborne (Washington & Lee), The Open Access Advantage for American Law Reviews:
Open access legal scholarship generates a prolific discussion, but few empirical details have been available to describe the scholarly impact of providing unrestricted access to law review articles. The present project fills this gap with specific findings on what authors and institutions can expect.
Articles available in open access formats enjoy an advantage in citation by subsequent law review works of 53%. For every two citations an article would otherwise receive, it can expect a third when made freely available on the Internet. This benefit is not uniformly spread through the law school tiers. Higher tier journals experience a lower OA advantage (11.4%) due to the attention such prestigious works routinely receive regardless of the format. When focusing on the availability of new scholarship, as compared to creating retrospective collections, the aggregated advantage rises to 60.2%. While the first tier advantage rises to 16.8%, the mid-tiers skyrocket to 89.7%. The fourth tier OA advantage comes in at 81.2%.
Citations of legal articles by courts is similarly impacted by OA availability. While the 15-year aggregate advantage is a mere 9.5%, new scholarship is 41.4% more likely to be cited by a court decision if it is available in open access format.
October 17, 2014 in Legal Education, Scholarship | Permalink | Comments (0)
Weekly SSRN Tax Roundup
- Peter Dietsch (Montreal) & Thomas Rixen (Bamberg), Tax Competition and Global Justice
- Michael Donohoe (Illinois), Financial Derivatives in Corporate Tax Avoidance: A Conceptual Perspective
- Patrick Driessen, Vanishing Corporate Income and Government Spending in Distribution Models
- Kasey Henricks (Loyola-Chicago), Passing the Buck: Race and the Role of State Lotteries in America's Changing Tax Composition
- John Hewson (Australian National University), The Politics of Tax Reform in Australia
- Fabian Kindermann (Bonn) & Dirk Krueger (Pennsylvania), High Marginal Tax Rates on the Top 1%? Lessons from a Life Cycle Model with Idiosyncratic Income Risk
- Chih-Chen Liu (National University of Kaohsiung), Horizontal Merger Under Strategic Tax Policy
- Dongmei Qiu (Hong Kong), The Concept of 'Beneficial Ownership' in China's Tax Treaties – The Current State of Play
- Patrick Smith (Ivins, Phillips & Barker, Washington, D.C.), More Ways Florida Bankers Misapplied the APA, 143 Tax Notes 361 (Apr. 21, 2014)
- Sam Thompson (Penn State), Legislative and Administrative Proposals Re Inversions
- Daniel Waldenström (Research Institute of Industrial Economics) & Jesper Roine (Stockholm School of Economics), Long Run Trends in the Distribution of Income and Wealth
- Neil Warren (New South Wales), A Politically Viable Strategy for Limiting Personal Income Tax Deductions: The Case for a Global Cap
October 17, 2014 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)
Weekly Student Tax Note Roundup
- Elizabeth Bolka (J.D. 2014, Indiana), Note, The Medical Device Excise Tax: An Unfair Burden, 89 Ind. L.J. 1691 (2014)
- Meredith Cipriano (J.D. 2015, Baltimore), Comment, The Illegal Immigrant Tax: Evaluating State Remittance Taxes Under the Dormant Commerce Clause and the Equal Protection Clause, 43 U. Balt. L. Rev. 255 (2014)
October 17, 2014 in Scholarship, Tax, Weekly Student Tax Note Roundup | Permalink | Comments (0)
ATPI Hosts Conference Today on Taxation and Migration
The American Tax Policy Institute hosts a conference today on Taxation and Migration organized by Reuven Avi-Yonah (Michigan) and Joel Slemrod (Michigan) in Washington, D.C.:
The conference assesses the effects of taxation on the migration across national and state boundaries of individuals at various stages of their lives. It will also evaluate whether corporate migrations (such as "inversions") involve migration of individuals, and what are the tax policy implications for the US and other jurisdictions.
- Cynthia Blum (Rutgers), Migrants with Retirement Plans: The Challenge of Harmonizing Tax Rules
- Yariv Brauner (Florida), High-Skilled Migration: A Tax Perspective
- Karen Conway (New Hampshire), The Consequences of State Tax Preferential Treatment for the Elderly
- Carlo Garbarino (Bocconi University), Intra-EU Tax Mobility of Individuals and Companies
- William Hoyt (Kentucky), State Tax Differentials, Cross-Border Commuting, and Commuting Times in Multi-State Metropolitan Areas
- Omri Marian (Florida), Home Country Effects of Corporate Inversions
- Chris Sanchirico (Pennsylvania), As American as Apple, Inc.? International Tax and Ownership Nationality
- John D. Wilson (Michigan State), Competitive Income Taxation with Migration
- Cristobal Young (Stanford), Millionaire Migration and the Taxation of the Elite: Evidence from US State Taxation
October 17, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)
62nd Annual Montana Tax Institute
The 62nd Annual Montana Tax Institute kicks off today:
- Jonathan Blattmachr (ILS Management), Asset Protection and Related Tax Consequences
- Jessica Browde (Montana), Professional Responsibility in Tax Practice: Circular 230 Update
- Martin Burke (Montana) & Michael Friel (Florida), Income in Respect of a Decedent: Section 691
- Sam Donaldson (Georgia State), Annual Federal Income Tax Update
- Elaine Gagliardi (Montana), Annual Wealth Transfer Tax Update
- Kristen Juras (Montana), Limitations of Activities of Nonprofit Organizations
- Roberta Mann (Oregon), Earth, Wind and Fire: Comparing the Taxation of Energy Sources
- Nancy McLaughlin (Utah), Conservation Easements: Contemporary Issues and Challenges
- Martin McMahon (Florida), Corporate and Partnership Tax Recent Developments
- Daniel Simmons (UC-Davis), Impact of Partner and Partnership Liabilities under Subchapter K
- Chris Treharne, (Gibraltar Business Appraisals), Justifying Discounts for Farm and Ranch Minority Ownership Interests
October 17, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)
Thursday, October 16, 2014
Virginia Tax Review Publishes New Issue
The Virginia Tax Review has published Vol. 33, No. 4 (Spring 2014):
- Tsilly Dagan (Bar-Ilan) & Avital Margalit (Sapir), Tax, State, and Utopia, 33 Va. Tax Rev. 549 (2014)
- Linda D. Jellum (Mercer), Codifying and "Miscodifying" Judicial Anti-abuse Tax Doctrines, 33 Va. Tax Rev. 579 (2014)
- J. Manhire, Toward a Perspective-dependent Theory of Audit Probability for Tax Compliance Models, 33 Va. Tax Rev. 629 (2014)
- Wei Cui (British Columbia), Taxing Indirect Transfers: Improving an Instrument for Stemming Tax and Legal Base Erosion, 33 Va. Tax Rev. 653 (2014)
October 16, 2014 in Scholarship, Tax | Permalink | Comments (0)
Cauble: Relying on the IRS
Emily Cauble (DePaul), Relying on the IRS:
The IRS issues different types of guidance to taxpayers, and the extent to which taxpayers can rely on IRS guidance depends on the form in which it was offered. For instance, taxpayers generally cannot rely on oral advice provided over the phone but can rely on more formal types of advice. The current state of the law harms unsophisticated taxpayers who disproportionately obtain informal advice -- the least reliable type of IRS guidance.
Existing literature lacks a thorough discussion of why, as a policy matter, we allow taxpayers to rely on some forms of IRS guidance more than others. This Article fills that gap by suggesting and critically evaluating potential justifications for this practice.
October 16, 2014 in Scholarship, Tax | Permalink | Comments (0)
A Case for Simpler Gain Bifurcation for Real Estate Developers
Bradley T. Borden (Brooklyn), Nathan Brown (Proskauer Rose, Boca Raton) & John Wagner II (Williams Parker Harrison Dietz & Getzen, Sarasota), A Case for Simpler Gain Bifurcation for Real Estate Developers, 15 Fla Tax Rev. 279 (2014):
This Article examines the judicially-sanctioned bifurcation of real estate developers' gain. The Article recognizes that even though some commentators oppose granting favorable tax treatment to capital gains, the law most likely will not change. With that in mind, the Article examines the all-or-nothing approach of characterizing gain from the sale of real estate as either capital gain or ordinary income. The Article rejects the all-or-nothing approach of characterizing income under the current statutory system. Instead, it embraces gain bifurcation in the second-best setting that taxes capital gains and ordinary income differently. Illustrating the policy justification for gain bifurcation and judicially-sanctioned bifurcation structures, the Article recommends that lawmakers should more fully embrace gain bifurcation for real estate developers by creating a simple statutory election for bifurcating gain that would enhance equity, accuracy, and transparency of gain bifurcation. Although the Article limits its analysis to real estate developers, the idea of gain bifurcation, once improved in this area, could be a catalyst for exploring bifurcation in other areas.
October 16, 2014 in Scholarship, Tax | Permalink | Comments (0)
Dharmapala: Base Erosion and Profit Shifting -- A Simple Conceptual Framework
Dhammika Dharmapala (Chicago), Base Erosion and Profit Shifting: A Simple Conceptual Framework:
The issue of tax-motivated income shifting within multinational firms – or "base erosion and profit shifting" (BEPS) – has attracted increasing global attention and has become the subject of an ongoing OECD initiative. This paper provides a simple conceptual framework that helps to clarify aspects of governments' responses to the BEPS phenomenon and the potential role of the OECD initiative. An important implication of this framework is that multilateral cooperation of the type envisaged in the BEPS initiative has the potential to reduce the deadweight costs of MNCs' tax planning and compliance activities, thereby enhancing global welfare.
October 16, 2014 in Scholarship, Tax | Permalink | Comments (0)
Penalizing Tax Petitions: Why the Erroneous Refund Penalty in § 6676 Violates Taxpayers' First Amendment Rights
Derek T. Ho & Christopher Klimmek (both of Kellogg, Huber, Hansen, Todd, Evans & Figel, Washington, D.C.), Penalizing Tax Petitions: Why the Erroneous Refund Penalty in Code § 6676 Violates Taxpayers' First Amendment Rights, 68 Tax Law. ___ (2015):
In 2007, Congress enacted the so-called "erroneous refund penalty," which imposes a 20% penalty on any taxpayer who submits a claim for tax refund that the IRS deems "inaccurate," even if the taxpayer's position is legally non-frivolous and asserted in good faith. In part because the IRS has rarely imposed the penalty since its enactment, the statute has thus far not been analyzed extensively by legal scholars or policymakers. However, the penalty continues to impose a significant chilling effect on tax refund claims, and the Treasury Department has now signaled the possibility of more aggressive application in the future. This article argues that the erroneous refund penalty is unconstitutional under the Petition Clause of the First Amendment. Penalizing taxpayers financially for asking their government to return money they believe is legally theirs strikes at the heart of the Petition Clause's protections. Indeed, protecting citizens' right to complain about abusive taxation by the national Government was one of the Framers' core motivations for enacting the First Amendment. The article draws on the history of the First Amendment, the Supreme Court's Petition Clause jurisprudence, and recent lower court decisions in exposing the constitutional infirmity of the penalty. The article also explains that the erroneous refund penalty is unjustified as a matter of tax policy, because it fails to promote voluntary compliance, is irrationally harsh and unfair to taxpayers, and is not necessary to solve the narrow, targeted problems that Congress intended to address in enacting the statute. Finally, the article suggests ways in which the penalty could be amended, if it is not repealed altogether, to avoid infringing on taxpayers' First Amendment rights and ensure that refund claims are treated fairly.
October 16, 2014 in Scholarship, Tax | Permalink | Comments (0)
Symposium: Expanding the Boundaries of Legal Education
Symposium, On Task? Expanding the Boundaries of Legal Education, 65 S.C. L. Rev. 519-638 (2014) (Video):
- Vordman Carlisle Traywick, III (J.D. 2014, South Carolina), Introduction, 65 S.C. L. Rev. 519 (2014)
- William C. Hubbard (President-elect, ABA), Opening Remarks for the Keynote Address, 65 S.C. L. Rev. 523 (2014)
- James R. Silkenat (President, ABA), Keynote Address: Be the Change, 65 S.C. L. Rev. 527 (2014)
- Barbara Madsen (Chief Justice, Washington Supreme Court), Luncheon Address: The Promises and Challenges of Limited Licensing, 65 S.C. L. Rev. 533 (2014)
- Neil W. Hamilton (St, Thomas (Minnesota)), Changing Markets Create Opportunities: Emphasizing the Competencies Legal Employers Use in Hiring New Lawyers (Including Professional Formation/ Professionalism), 65 S.C. L. Rev. 547 (2014)
- Elizabeth Chambliss 9South Carolina), Law School Training for Licensed "Legal Technicians"? Implications for the Consumer Market, 65 S.C. L. Rev. 579 (2014)
- Stephen R. Crossland (Washington Limited License Legal Technician Board) & Paula C. Littlewood (Washington State Bar), The Washington State Limited License Legal Technician Program: Enhancing Access to Justice and Ensuring the Integrity of the Legal Profession [Includes illustration], 65 S.C. L. Rev. 611 (2014)
- Appendix [Includes Photographs], 65 S.C. L. Rev. 623 (2014)
October 16, 2014 in Legal Education, Scholarship | Permalink | Comments (0)
Afield: A Market for Tax Compliance
W. Edward Afield III (Ave Maria), A Market for Tax Compliance, 62 Clev. St. L. Rev. 315 (2014):
It is becoming increasingly clear that, due to political realities and budgetary constraints, the IRS is going to have to attempt to enforce the tax laws by doing more with less. Current enforcement efforts have yielded a tax gap (i.e., the difference between the amount of taxes that should be paid and the amount that are collected) of roughly $450 billion annually. Faced with this task, one of the steps that the IRS has recently taken is to try to improve the quality in services performed by paid tax preparers, a group that historically has been subject to little IRS regulation or monitoring but that continues to play an increasingly important role in the tax system.
Although the IRS's recent efforts to better regulate paid preparers is a good step in improving the quality of tax services, its current structure as a mandatory regulatory regime causes it to miss a number of compliance oriented advantages that could be achieved through a voluntary system of tax preparer regulation in which tax preparers could choose to seek certifications indicating whether they had a positive track record of compliance.
This paper explores in detail for the first time in the literature how preparer regulation could achieve significantly more compliance gains if it were structured as a voluntary system designed to create a market that rewards tax compliance.
October 16, 2014 in Scholarship, Tax | Permalink | Comments (0)
Wednesday, October 15, 2014
Borden Presents REIT Stuff at Florida
Bradley T. Borden (Brooklyn) presented REIT Stuff at Florida as part of its Graduate Tax Program Colloquium Series:
Real estate investment trusts (REITs) have made headlines recently because they provide favorable tax treatment to corporations that primarily own real estate, which contrasts with the typical double-tax that generally applies to corporations. The media appears to be particularly concerned that existing corporations are spinning off their real estate holdings into REITs, eroding the corporate tax base. It is also concerned that the IRS has extended REIT classification to entities that hold property, such as telecommunications equipment, billboards, mortgages, oil and gas pipeline systems, timber, casinos, and data centers, which do not fit within the traditional definition of real estate. Such extension broadens the scope of favorable REIT tax treatment to property that was not held in real estate trusts when Congress enacted the REIT regime. Despite all of this attention, the effect of REIT spinoffs and the formation of REITs with non-traditional real estate assets may not have a very significant effect on federal tax revenues. This Article will closely examine the revenue effect of REIT spinoffs and the extension of REIT treatment to non-traditional real estate assets. Early work in this are suggests that the revenue effect appears to be nominal, and it is a result of dual, overlapping tax policies—favorable tax treatment of real estate and tax-exempt status for retirement plans. The analysis will set the stage for discussing potential action in this area by recounting the history of REITs and the important events that have directed the course of REIT legislation to its current status. The early analysis appears to suggest that lawmakers should either reconsider the preference for real estate and pensions or consider relaxing the law to provide more efficient ways for corporations to bifurcate real-estate income from operating income and more easily obtain the benefits available under current law.
October 15, 2014 in Colloquia, Scholarship, Tax | Permalink | Comments (0)
The Need for a Patent Box Tax Regime to Encourage Domestic Manufacturing
Bernard Knight (Partner, McDermott, Will & Emery, Washington, D.C.) & Goud Maragani (Senior Counsel, USPTO), It Is Time for the United States to Implement a Patent Box Tax Regime to Encourage Domestic Manufacturing, 19 Stan. J.L. Bus. & Fin. 39 (2013):
In order to curb the outsourcing of industries and jobs, the United States must provide better incentives to encourage manufacturers to operate domestically. The United States is at a strategic disadvantage vis-à-vis many other industrialized nations that attract industry and jobs by taxing income from intellectual property sourced in those countries at a lower tax rate. This Article suggests that the United States should consider a patent box regime and outlines the benefits that such a regime should produce in terms of additional domestic manufacturing and job creation. The Article begins by discussing scholarly work that explores the link between domestic manufacturing and research and development, and explains why domestic manufacturing is critical to innovation. In turn, innovation leads to more productivity, higher paying jobs and lower unemployment. The next Section summarizes the significant features of the existing patent box tax regimes in certain European Union nations and China. Taking into account the positive attributes and deficiencies of the existing patent box regimes, the Article concludes by suggesting features that should be considered for inclusion in a U.S. patent box regime.
October 15, 2014 in Scholarship, Tax | Permalink | Comments (0)
Deadline Today: Call for Tax Papers and Panels for 2015 Law & Society Annual Meeting
Today is the deadline for Neil Buchanan's call for tax papers and panels for next year's annual meeting of the Law & Society Association in Seattle (May 28-31, 2015):
For the eleventh consecutive year, I will organize sessions for the the Law, Society, and Taxation group (Collaborative Research Network 31).
Although there is an official call for papers, please remember that you are not bound by the official theme of the conference. I will give full consideration to proposals in any area of tax law, tax policy, distributive justice, interdisciplinary approaches to tax issues, and so on.
October 15, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)
SSRN Tax Professor Rankings
SSRN has updated its monthly rankings of 944 American and international law school faculties and 3,000 law professors by (among other things) the number of paper downloads from the SSRN database. Here is the new list (through October 1, 2014) of the Top 25 U.S. Tax Professors in two of the SSRN categories: all-time downloads and recent downloads (within the past 12 months):
Reuven Avi-Yonah (Mich.)
Reuven Avi-Yonah (Mich.)
Paul Caron (Pepperdine)
Ed Kleinbard (USC)
|Louis Kaplow (Harvard)
|Richard Ainsworth (BU)
D. Dharmapala (Chicago)
D. Dharmapala (Chicago)
Vic Fleischer (San Diego)
Paul Caron (Pepperdine)
James Hines (Michigan)
Robert Sitkoff (Harvard)
Ted Seto (Loyola-L.A.)
Omri Marian (Florida)
Richard Kaplan (Illinois)
Richard Kaplan (Illinois)
Ed Kleinbard (USC)
Katie Pratt (Loyola-L.A.)
Katie Pratt (Loyola-L.A.)
Bridget Crawford (Pace)
Dennis Ventry (UC-Davis)
Jen Kowal (Loyola-L.A.)
Carter Bishop (Suffolk)
Brad Borden (Brooklyn.)
Jen Kowal (Loyola-L.A.)
David Gamage (UCBerkeley)
David Weisbach (Chicago)
Jeff Kwall (Loyola-Chicago)
Chris Sanchirico (Penn)
Louis Kaplow (Harvard)
Richard Ainsworth (BU)
James Hines (Michigan)
Robert Sitkoff (Harvard)
Francine Lipman (UNLV)
Francine Lipman (UNLV)
Dan Shaviro (NYU)
Brad Borden (Brooklyn)
Dick Harvey (Villanova)
David Walker (Boston Univ.)
Vic Fleischer (San Diego)
Bridget Crawford (Pace)
Ted Seto (Loyola-L.A.)
Herwig Schlunk (Vanderbilt)
|Carter Bishop (Suffolk)
Dan Shaviro (NYU)
David Weisbach (Chicago)
Ed McCaffery (USC)
Gregg Polsky (North Carolina)
Wendy Gerzog (Baltimore)
Chris Sanchirico (Penn)
Note that this ranking includes full-time tax professors with at least one tax paper on SSRN, and all papers (including non-tax papers) by these tax professors are included in the SSRN data.
October 15, 2014 in Scholarship, Tax, Tax Prof Rankings | Permalink | Comments (0)
Tuesday, October 14, 2014
Fleischer Presents Curb Your Enthusiasm for Pigouvian Taxes Today at Columbia
Victor Fleischer (San Diego) presents Curb Your Enthusiasm for Pigouvian Taxes at Columbia today as part of its Tax Policy Colloquium Series hosted by Alex Raskolnikov, David Schizer, and Wojciech Kopczuk:
Pigouvian (or "corrective") taxes have been proposed or enacted on dozens of products and activities that may be harmful in excess: carbon, gasoline, fat, sugar, guns, cigarettes, alcohol, traffic, zoning, executive pay, and financial transactions, among others. Academics of all political stripes are mystified by the public's inability to see the merits of using Pigouvian taxes more frequently to address serious social harms.
This enthusiasm for Pigouvian taxes should be tempered. A Pigouvian tax is easy to design — as a uniform excise tax — if one assumes that each individual causes the same amount of harm with each incremental increase in activity on the margin. This assumption of uniform marginal social cost pairs well with the limited information and enforcement capacity of tax institutions. But when marginal social cost varies significantly, a Pigouvian tax will not lead to an optimal allocation of economic resources. Focusing on carbon emissions, where the assumption of uniform marginal social cost happens to be reasonable, obscures this common design flaw.
Broadly speaking, Pigouvian taxes should be employed only when (1) the harm is (or is properly analogized to) global pollution, and where the harm does not vary based on the source, or (2) the variation in marginal social cost is easily observed and categorized, as with traffic congestion charges.
October 14, 2014 in Colloquia, Scholarship, Tax | Permalink | Comments (0)
Fleischer: Charitable Giving and Utilitarianism
Miranda Perry Fleischer (San Diego), Charitable Giving and Utilitarianism: Problems and Priorities, 89 Ind. L.J. 1484 (2014):
Charitable giving is redistributive at heart. It is thus surprising that scholarship on the charitable tax subsidies focuses on the efficient and pluralistic production of public goods while largely ignoring distributive justice concerns. Existing scholarship and current law leave crucial questions unanswered: How should we prioritize among charities? Should subsidized groups be required to help the poor? Are criticisms that charities do too little to help the poor valid? This Article is part of a series that examines how each common theory of distributive justice would answer these questions.
October 14, 2014 in Scholarship, Tax | Permalink | Comments (0)
Law Faculty Rankings Should Focus More on Non-Academic Influence
Patrick Arthur Woods, Stop Counting (Or At Least Count Better):
For American legal scholarship to fulfill its purpose, it must have an impact on the development of the actual law as it is enacted and interpreted in the United States. However, legal scholarship broadly — and law review articles in particular — has become less influential on judges and members of the practicing bar over time. This short essay argues that the decline is partly attributable to the open reliance on metrics that primarily represent influence within the legal academy when measuring the value of a scholar's work. In particular, I argue that a focus on metrics with only a tenuous connection to non-academic usage of a new scholar's work, such as download counts, law journal citation count-based rankings methodologies, and article placement, incentivizes new legal writers to write for other academics rather than for judges, attorneys in practice, or policy-makers.
October 14, 2014 in Law School Rankings, Scholarship, Tax | Permalink | Comments (3)
Call for Papers: University of North Carolina Tax Symposium
The University of North Carolina Kenan-Flagler School of Business has issued a call for papers for its Eighteenth Annual Tax Symposium to be held April 10-11, 2015. The symposium "is designed to bring together leading tax scholars from economics, accounting, finance, law, political science, and related fields." The deadline for the call for papers is January 1, 2015:
October 14, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)
Thimmesch: The Tax Hangover -- Trailing Nexus
Adam B. Thimmesch (Nebraska), Evaluating the Tax Hangover: Trailing Nexus, 74 State Tax Notes 83 (Oct. 13, 2014):
In this article, which is adapted from a longer law review article [The Tax Hangover: Trailing Nexus, 33 Va. Tax Rev. 497 (2014)], Thimmesch examines the concept of trailing nexus. He argues that the concept is consistent with the physical presence standard and proposes an economic latency approach, which he asserts is consistent with both constitutional principles and economic reality.
October 14, 2014 in Scholarship, Tax, Tax Analysts | Permalink | Comments (0)
Symposium on the Work of Larry Ribstein: Unlocking the Law
Symposium, Unlocking the Law: Building on the Work of Professor Larry E. Ribstein, 38 Int'l Rev. L. & Econ. 1-173 (2014):
- Larry E. Ribstein (1946-2011) [Photograph], 38 Int'l Rev. L. & Econ. 1 (2014)
- Henry N. Butler (George Mason) & Bruce Kobayashi (George Mason), Unlocking the Law: Building on the Work of Larry E. Ribstein, 38 Int'l Rev. L. & Econ. 2 (2014)
- William D. Henderson (Indiana), From Big Law to Lean Law, 38 Int'l Rev. L. & Econ. 5 (2014)
- Daniel Currell (Corporate Executives Board) & M. Todd Henderson (Chicago), Can Lawyers Stay in the Driver's Seat?, 38 Int'l Rev. L. & Econ. 17 (2014)
- Benjamin H. Barton (Tennessee), A Glass Half Full Look at the Changes in the American Legal Market, 38 Int'l Rev. L. & Econ. 29 (2014)
- Gillian K. Hadfield (USC), The Cost of Law: Promoting Access to Justice Through the (Un)corporate Practice of Law, 38 Int'l Rev. L. & Econ. 43 (2014)
- Richard A. Epstein (NYU), Big Law and Big Med: The Deprofessionalization of Legal and Medical Services, 38 Int'l Rev. L. & Econ. 64 (2014)
- Nuno Garoupa (Illinois), Globalization and Deregulation of Legal Services, 38 Int'l Rev. L. & Econ. 77 (2014)
- Erin O'Hara O'Connor (Vanderbilt) & Peter B. Rutledge (Georgia), Arbitration, the Law Market, and the Law of Lawyering, 38 Int'l Rev. L. & Econ. 87 (2014)
- Henry G. Manne (Former Dean, George Mason), How the Structure of Universities Determined the Fate of American Legal Education -- A Tribute to Larry Ribstein, 38 Int'l Rev. L. & Econ. 107 (2014)
- John O. McGinnis (Northwestern) & Russell D. Mangas (Kirkland & Ellis, Chicago), An Undergraduate Option for Legal Education, 38 Int'l Rev. L. & Econ. 117 (2014)
- Robert G. Bone (Texas), Decentralizing the Lawmaking Function: Private Lawmaking Markets and Intellectual Property Rights in Law, 38 Int'l Rev. L. & Econ. 132 (2014)
- Barry E. Adler (NYU), Lawyers as Lawmakers, Privilege, and Agency, 38 Int'l Rev. L. & Econ. 1449 (2014)
- Michael Bradley (Duke), Irving De Lira Salvatierra (Duke) & Mitu Gulati (Duke), Lawyers: Gatekeepers of the Sovereign Debt Market?, 38 Int'l Rev. L. & Econ. 150 (2014)
- Vikram Maheshri (Houston) & Clifford Winston (Brookings Institution), An Exploratory Study of the Pricing of Legal Services, 38 Int'l Rev. L. & Econ. 169 (2014)
October 14, 2014 in Conferences, Legal Education, Scholarship | Permalink | Comments (0)
Monday, October 13, 2014
Sanchirico Presents International Tax and Ownership Nationality Today at Florida
Chris Sanchirico (Pennsylvania) presents As American as Apple, Inc.: International Tax and Ownership Nationality, 68 Tax L. Rev. ___ (2014), at Florida today as part of its Graduate Tax Program Colloquium Series:
The ownership nationality of large US multinational companies plays an implicit but important role in the current debate over how such companies should be taxed. This paper identifies that role and investigates what is actually known about where these companies' shareholders reside.
October 13, 2014 in Colloquia, Scholarship, Tax | Permalink | Comments (0)
Mayer Presents Taxing Politics Today at Loyola-L.A.
Lloyd Hitoshi Mayer (Notre Dame) presents Taxing Politics at Loyola-L.A. today as part of its Tax Policy Colloquium Series:
This draft Article addresses two key questions relating to the interaction between federal tax law and political activity. First, is it advisable as a policy matter for Congress to use the tax law to regulate the flows of money in politics in furtherance of non-tax goals such as combatting corruption, promoting equality, and encouraging democratic participation? I answer this first question generally no, in significant part because the tax law and the IRS are poorly suited for this role and suffer significant collateral damage when their poor fit becomes evident, as the ongoing controversy over the IRS' handling of exemption applications filed by Tea Party and other conservative groups reveals. Second, does tax law in its current form treat political activity properly based on longstanding tax policies relating to what constitutes income, what expenses should be deductible, what constitutes a taxable gift, and what characteristics organizations should have in order to qualify for tax exemption? I answer this second question generally yes, but identify several areas where the tax law needs to be changed to achieve greater consistency with such policies, including with respect to reducing the amount of political activity that is deemed permissible for most types of tax-exempt organizations.
Ellen Aprill (Loyola-L.A.) and Justin Levitt (Loyola-L.A.) are the commentators.
October 13, 2014 in Colloquia, Scholarship, Tax | Permalink | Comments (0)
Christians: It's Time to Fix FBAR
Allison Christians (McGill), Paperwork and Punishment: It's Time to Fix FBAR, 76 Tax Notes Int'l 147 (Oct. 13, 2014):
Allison Christians argues that the U.S. Foreign Bank Account Report regime is excessive and offers suggestions to narrow its scope and ease compliance burdens.
October 13, 2014 in Scholarship, Tax, Tax Analysts | Permalink | Comments (0)
Sunday, October 12, 2014
Top 5 Tax Paper Downloads
There is a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads on SSRN, with a new paper debuting on the list at #5. The #1 paper is now #19 in all-time downloads among 10,386 tax papers:
- [3288 Downloads] 'Competitiveness' Has Nothing to Do with it, by Edward D. Kleinbard (USC)
- [336 Downloads] 2013 Developments in Connecticut Estate and Probate Law, by Jeffrey A. Cooper (Quinnipiac) & John R. Ivimey (Reid and Riege, Hartford)
- [219 Downloads] The OECD'S Flawed and Dated Approach to Computer Servers Creating Permanent Establishments, by Monica Gianni (Florida)
- [131 Downloads] Rights Without Remedies, by Matthew L. M. Fletcher (Michigan State)
- [126 Downloads] Home-Country Effects of Corporate Inversions, by Omri Y. Marian (Florida)
October 12, 2014 in Scholarship, Tax, Top 5 Downloads | Permalink | Comments (0)
Saturday, October 11, 2014
Ryan: Valuation Lessons From Estate of Adell
Kerry A. Ryan (St. Louis), Valuation Lessons From Estate of Adell, 144 Tax Notes 1455 (Sept. 22, 2014):
In Estate of Adell [T.C. Memo. 2014-155], the Tax Court determined that the correct value of a decedent's interest in a closely held corporation was the figure reported on the original estate tax return. The court rejected alternative values as either using the incorrect valuation method or failing to account for the significant value of a key employee's personal goodwill.
October 11, 2014 in Scholarship, Tax, Tax Analysts | Permalink | Comments (0)
Friday, October 10, 2014
Brooklyn Hosts 2014 Scholar's Roundtable Today
Brooklyn hosts the 2014 Scholar's Roundtable today with this tax panel:
- Khagesh Gautam (Jindal Global Law School), Tax Avoidance Versus Tax Evasion – Judicial Decision Making in the Supreme Court of India and Its Comparativist Critique
- Omri Marian (Florida), Home-Country Effects of Corporate Inversions, 90 Wash. L. Rev. ___ (2015)
- Orly Mazur (SMU), Taxing the Cloud
October 10, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)
Weekly SSRN Tax Roundup
- John Barrick (BYU) & Raquel Meyer Alexander (Washington & Lee), Tax Lobbying and Corporate Political Activity: How Do Firms Seek Tax Relief?
- Andrew Bauer (Illinois), Alan Macnaughton (Waterloo) & Anindya Sen (Waterloo), Income Splitting and Anti-Avoidance Legislation: Evidence from the Canadian 'Kiddie Tax'
- Tsilly Dagan (Bar-Ilan), Pay as You Wish: The Global Market for Tax & Legal Rules
- David Joulfaian (U.S. Treasury Department, Office of Tax Analysis), Household Debt and Capital Gains Taxation
- Nancy McLaughlin (Utah) & Stephen Small, Trying Times 2014: Important Lessons to Be Learned from Recent Federal Tax Cases
- Justice T.N. C. Rangarajan, Tax Tentacles
- Charles Rettig (Hochman, Salkin, Rettig, Toscher & Perez), IRS Changes Streamlined OVDP Reducing FBAR Penalty Exposure!
- Masha Shunko (Purdue), Hung Do (Vermont) & Andy Tsay (Santa Clara), Should a Multinational Firm Place Part of its Supply Chain in a Tax Haven?: Strategies to Enable International Tax Arbitrage
- Frank Wolpe (Bentley), A White Paper on Executive Action to Restore Trust in the Internal Revenue Service by Rebuilding Field Operations (Subtitle: If You See Something, Say Something; and Make No Mistake, Restoring Trust in the IRS is a National Security Need.)
October 10, 2014 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)
Weekly Student Tax Note Roundup
- Zachary J. Buxton (J.D. 2014, St. Louis), Comment, Community Benefit 501(r)edux: An Analysis of the Patient Protection and Affordable Care Act's Limitations Under Community Benefit Reform, 7 St. Louis U. J. Health L. & Pol'y 449 (2014)
- Tyler J. Kassner (J.D. 2014, UC-Hastings), Note, Bringing Dark Money Into the Light: 501(c)(4) Organizations, Gift Tax, and Disclosure, 10 Hastings Bus. L.J. 471 (2014)
October 10, 2014 in Scholarship, Tax, Weekly Student Tax Note Roundup | Permalink | Comments (0)
Boston College and Tax Analysts Host Conference Today on Reforming Entity Taxation
Boston College and Tax Analysts host a conference today on Reforming Entity Taxation at Boston College:
Keynote Speaker: Lee Sheppard (Tax Analysts)
Panel #1: Reforming Entity Taxation: Corporations
- Papers: Mirit Eyal-Cohen (Alabama), Deborah Schenk (NYU), Dan Shaviro (NYU)
- Moderator: Jeremy Scott (Tax Analysts)
- Commentator: Brian Galle (Boston College)
Panel #2: Reforming Entity Taxation: Partnerships
- Papers: Karen Burke (Florida), Andrea Monroe (Temple), Gregg Polsky (UNC)
- Moderator: Amy Elliot (Tax Analysts)
- Commentator: James Repetti (Boston College)
Panel #3: Reforming Entity Taxation: International
- Papers: Allison Christians (McGill), Robert Peroni (Texas), Martin Sullivan (Tax Analysts)
- Moderator: Sam Young (Tax Analysts)
- Commentator: Diane Ring (Boston College)
October 10, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)
Thursday, October 9, 2014
Call for Tax Papers: Michigan Young Scholars' Conference
The organizers of the 2015 Michigan Law School Young Scholars' Conference are seeking submissions for a tax panel:
The University of Michigan Law School is pleased to invite submissions for its 2015 Young Scholars' Conference to be held on March 27-28, 2015, at the University of Michigan Law School.
The conference is designated to provide aspiring doctoral students and recent graduates with a forum to present and discuss their work among academic peers from different nationalities and legal disciplines. The conference aims to promote fruitful research collaboration between its participants, and to encourage their integration in a community of legal scholars. ...
We welcome applications from current doctoral students, both in law and law-related disciplines, and from recent graduates of doctoral programs. The deadline for abstract submissions is December 2, 2014.
October 9, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)
Abreu & Greenstein: The Rule of Law as a Law of Standards -- Interpreting the Internal Revenue Code
Alice Abreu (Temple) & Richard K. Greenstein (Temple), The Rule of Law as a Law of Standards: Interpreting the Internal Revenue Code, 63 Duke L.J. Online ___ (2014):
Although fields of law ordinarily comprise both rules and standards, and foundational tax scholars such as Professors Surrey, Warren, and Bittker understood the importance of standards in tax law, many tax scholars and professionals have come to regard federal tax law as "the paradigmatic system of rules." The vision of tax-as-rules is particularly alluring because rules have been associated with rule-of-law values, and it seems that the rule of law might be especially important in the field of taxation. The rule of law constrains the coercive power of government, and perhaps few powers are viewed with as much suspicion as the taxing power. Our claim that the existence of many rules in the tax law does not dictate the interpretation of all tax formulations as rules seems to threaten critical rule-of-law values. Nevertheless, we believe with Surrey and Warren that tax, like other areas of law, can flourish only if the IRS and the courts are able to respond to "unforeseen cases as they arise" and that this flexibility demands that many Code provisions be interpreted as standards. We also believe that this use of standards does not threaten rule-of-law values. In this essay we defend both propositions.
To do so we engage pointedly with Professor Larry Zelenak's critique of the position we took in our earlier article, Defining Income [11 Fla Tax Rev. 295 (2011)], where we claimed that the category of "gross income" in the Internal Revenue Code is best understood as a standard, not a rule. In Custom and the Rule of Law in the Administration of the Income Tax, Professor Zelenak worried that our position threatened the rule of law by "stretch[ing] beyond the breaking point" the concept of interpretation [Custom and the Rule of Law in the Administration of the Income Tax, 62 Duke L.J. 855 (2012)].
October 9, 2014 in Scholarship, Tax | Permalink | Comments (1)
Wednesday, October 8, 2014
The Tax Lawyer Publishes New Issue
The Tax Lawyer has published Vol. 67, No. 4 (Summer 2014):
- Rick Handel (South Carolina), A Conceptual Analysis of Nexus in State and Local Taxation, 67 Tax Law. 623 (2014)
- William J. Kolarik II (Ernst & Young) & Steven N. Wlodychak (Ernst & Young), The Economic Substance Doctrine in Federal and State Taxation, 67 Tax Law. 715 (2014)
- William C. Brown (BrownWinick, Des Moine), A Primer on Income Tax Compliance for Multistate Pass-Through Entities and Their Owners, 67 Tax Law. 821 (2014)
- Sherry Tehrani (California State-Northridge), Welcome to the Amazon: Leading Online Retail from Local Tax Avoidance into Your Backyard, 67 Tax Law. 875 (2014)
- Ann M. Burkhart (Minnesota), Taxing Manufactured Homes, 67 Tax Law. 909 (2014)
- Lisandra Ortiz (J.D> 2014), Comment, Joyce v. Finnigan: Adoption of the "Best" Approach in Hopes of Some Uniformity, 67 Tax Law. 979 (2014)
- Emily Prezioso (J.D. 2014, Georgetown), Note, Satellite Taxation: The Dormant Commerce Clause in DirectTV, Inc. v. Levin, 67 Tax Law. 1009 (2014)
October 8, 2014 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0)
Smith: Changes in Agencies' Interpretations of Their Own Regulations and Auer Deference
Patrick J. Smith (Ivins, Phillips & Barker, Washington, D.C.), Changes in Agencies' Interpretations of Their Own Regulations and Auer Deference:
Perez v. Mortgage Bankers Association, a case that is currently pending before the Supreme Court, involves the validity of a D.C. Circuit rule relating to the Administrative Procedure Act notice-and-comment requirements for rulemaking. Under the APA, substantive rules are subject to the notice and comment requirements but interpretative rules are not. Under this D.C. Circuit rule, if an agency has adopted an interpretation of one of its own substantive regulations in a guidance document that would not itself otherwise be a substantive rule, the agency must nevertheless use notice-and-comment procedures to change the interpretation. Although the D.C. Circuit has not done so, this rule can be justified based on the Auer deference principle under which agency interpretations of their own regulations are given deference similar to the deference that is given under Chevron to agency statutory interpretations. Under Auer, an agency interpretation of its own regulation can be viewed as having the force of law, and as a result should be viewed as itself a substantive rule, since a substantive rule is a rule with the force of law. As a substantive rule, notice-and-comment procedures are required.
October 8, 2014 in Scholarship, Tax | Permalink | Comments (0)
Schizer: The Influence of Tax on Managerial Agency Costs
David Schizer (Columbia), Tax and Corporate Governance: The Influence of Tax on Managerial Agency Costs:
This chapter of the Oxford Handbook on Corporate Law and Governance canvasses a broad range of ways that tax influences managerial agency costs, focusing especially on the United States. In doing so, this chapter has two goals. The first is to help corporate law experts target managerial agency costs more effectively. The analysis here flags when tax is likely to exacerbate agency costs, and when it is likely to mitigate them. Armed with this information, corporate law experts have a better sense of how vigorous a contractual or corporate law response they need. In some cases, a change in the tax law may also be justified. This chapter's second goal, then, is to enhance our understanding of tax rules, shedding light on a set of welfare effects that are important but understudied. After all, tax policy is more likely to enhance welfare if policymakers weigh all possible welfare effects, including managerial agency costs.
Overall, the U.S. tax system's record in influencing agency costs is not encouraging. After all, a tax system's priority is not to reduce agency costs, but to raise revenue efficiently and fairly. Government tax experts do not usually have the expertise or motivation to tackle corporate governance problems. Tax also is a poor fit because it typically applies mandatorily and uniformly, while responses to agency cost should be molded to the context. For example, promoting stock options or leverage will be valuable in some settings, but disastrous in others. There also are political hurdles to be overcome. Accordingly, when tax rules target agency costs, the results often are poorly tailored or even counterproductive.
October 8, 2014 in Scholarship, Tax | Permalink | Comments (0)
ATPI Hosts Conference on Taxation and Migration
The American Tax Policy Institute hosts a conference on Taxation and Migration organized by Reuven Avi-Yonah (Michigan) and Joel Slemrod (Michigan) in Washington, D.C. (Skadden, Arps, Slate, Meagher & Flom, 1441 New York Avenue, N.W.) on October 17 (free registration here):
The conference assesses the effects of taxation on the migration across national and state boundaries of individuals at various stages of their lives. It will also evaluate whether corporate migrations (such as "inversions") involve migration of individuals, and what are the tax policy implications for the US and other jurisdictions.
- Cynthia Blum (Rutgers) Migrants with Retirement Plans: The Challenge of Harmonizing Tax Rules
- Yariv Brauner (Florida), High-Skilled Migration: A Tax Perspective
- Karen Conway (New Hampshire), The Consequences of State Tax Preferential Treatment for the Elderly
- Carlo Garbarino (Bocconi University), Intra-EU Tax Mobility of Individuals and Companies
- William Hoyt (Kentucky), State Tax Differentials, Cross-Border Commuting, and Commuting Times in Multi-State Metropolitan Areas
- Omri Marian (Florida), Home Country Effects of Corporate Inversions
- Chris Sanchirico (Pennsylvania), As American as Apple, Inc.? International Tax and Ownership Nationality
- John D. Wilson (Michigan State), Competitive Income Taxation with Migration
- Cristobal Young (Stanford), Millionaire Migration and the Taxation of the Elite: Evidence from US State Taxation
October 8, 2014 in Conferences, Scholarship, Tax | Permalink | Comments (0)
Afield: Harnessing Taxpayer Choices to Improve Educational Quality
W. Edward Afield III (Ave Maria), Winning the Crowd: Harnessing Taxpayer Choices to Improve Educational Quality, 63 Cath. U. L. Rev. 297 (2014):
This article presents a novel approach to the debate over the best way to improve educational policy. Building off of research showing that decisions made by groups can be superior to those made by even the smartest members of those groups, this piece shows how this concept of a "wise crowd" can be applied to improve outcomes even in a complex policy debate like educational policy. Educational policy currently exhibits a host of competing ideas for the best mechanism to improve student outcomes. These competing ideas can be seen in the wide variety of schools that exist and that compete for resources to implement their approaches. Public schools, charter schools, magnet schools, International Baccalaureate programs, secular private schools, religious private schools, home schooling — all of these and more offer unique approaches to education. Even within these types of schools, different educational teaching philosophies abound. Although some schools unquestionably have better outcomes for students than others, there is not universal agreement about how to measure the quality of any particular school because of the host of factors involved in educating a student. In other words, some schools are likely better than others, but separating good schools from weak ones is difficult.
October 8, 2014 in Scholarship, Tax | Permalink | Comments (0)
Winchester: Obama's Gift to the Rich: A Permanent Payroll Tax Holiday
Richard Winchester (Thomas Jefferson), Obama's Gift to the Rich: A Permanent Payroll Tax Holiday, 48 Val. U. L. Rev. 83 (2013):
President Obama made a concerted effort to enact tax legislation that benefited middle and lower income individuals over the rich. The temporary payroll tax cut in effect during 2011 and 2012 is a case in point. However, many high-income individuals enjoyed an even greater measure of payroll tax relief as a result of legislation that he signed. But instead of being granted directly under the terms of a bill, this relief was made possible because the tax legislation that he signed perpetuated what had been only a temporary incentive for individuals to avoid the payroll tax entirely when they work for a corporation that they also own or otherwise control. Simply put, these individuals can take a payroll tax holiday by substituting a dividend for any wages they could otherwise receive. What's more, this tax dodge operates in a way that favors the rich far more than anyone else. This tax dodge would have died after Mr. Obama's second year in office. However, the legislation he signed gave it perpetual life, reinforcing the need to address the multiple defects in the nation's employment tax system.
October 8, 2014 in Scholarship, Tax | Permalink | Comments (1)
Tuesday, October 7, 2014
Shackelford Presents The Taxation of Foreign Investors in U.S. REITs Today at Columbia
Douglas Schackelford (North Carolina) presents Taxes, Investors, and Managers: Exploring the Taxation of Foreign Investors in U.S. REITs (with Margot Howard (North Carolina) & Katherine Pancak (Connecticut)) at Columbia today as part of its Tax Policy Colloquium Series hosted by Alex Raskolnikov, David Schizer, and Wojciech Kopczuk:
Exploiting a 2004 reduction in a unique capital gains withholding tax for foreign investors in U.S. REITs, this paper explores both the sensitivity of real estate investors to changes in their own taxes and the reaction of real estate managers to changes in their investors' taxes. We find that both foreign investors and REIT managers responded to the tax change. This is consistent with taxes both restricting the flow of foreign capital into U.S. REITs and affecting the management of their real estate properties. To our knowledge, this is the first paper documenting that U.S. managers change their U.S. operations in response to the tax positions of foreign investors. This work should spur further study of the interplay between real estate and income taxes, the role of taxes on foreign portfolio investment, and the role of taxes on real managerial decisions. It also should aid policymakers who are considering further relaxing the discriminatory tax treatment for foreign investors in U.S. real estate.
October 7, 2014 in Colloquia, Scholarship, Tax | Permalink | Comments (0)
Gamage: On Double-Distortion Arguments, Distribution Policy, and the Optimal Choice of Tax Instruments
David Gamage (UC-Berkeley), On Double-Distortion Arguments, Distribution Policy, and the Optimal Choice of Tax Instruments:
There are both administrative and political constraints on the extent to which real-world tax systems might plausibly be reformed. No one seriously suggests that tax avoidance and evasion could be completely eliminated in real-world contexts. To better cope with tax avoidance and evasion, and to complement attempts to reform existing tax systems, this research project argues that governments should also raise revenues and promote distribution through a number of supplementary policy instruments. Among other applications, this research project argues that governments should probably: (a) levy both personal labor-income taxes and value-added consumption taxes, (b) tax both capital income and wealth, and (c) make use of a number of other tax and non-tax legal rules for distributive purposes.
October 7, 2014 in Scholarship, Tax | Permalink | Comments (0)
Yin: Reforming (and Saving) the IRS by Respecting the Public's Right to Know
George K. Yin (Virginia), Reforming (and Saving) the IRS by Respecting the Public's Right to Know, 100 Va. L. Rev. 1115 (2014):
The current controversy involving possible political targeting by the IRS in administering the exempt organization ("EO") tax laws is simply the latest in a long succession of similar allegations spanning at least five decades. This Article proposes to address the problem through increased transparency of the IRS's administrative actions involving EOs. Greater transparency responds directly to the public's frustration in not being able to monitor the agency and gain confidence that the laws are being applied in an even-handed manner.
October 7, 2014 in Scholarship, Tax | Permalink | Comments (1)
Monday, October 6, 2014
Norman Presents Corporate Tax and Beyond: Compliance Norms Today at McGill
Wayne Norman (Duke University, Department of Philosophy) presents Corporate Tax and Beyond: Compliance Norms at McGill today as part of its Spiegel Sohmer Tax Policy Colloquium hosted by Allison Christians and Daniel Weinstock:
Using the media's recent coverage of Apple's tax avoidance strategies as a case study, Professor Norman will discuss how we ought to understand and rationalize corporate social responsibility and self-regulation norms emerging around the taxation of multinationals, and whether these rationalizations are, or should be, different than the rationalization of corporate tax regulation.
October 6, 2014 in Colloquia, Scholarship, Tax | Permalink | Comments (0)
Galle Presents The Price of Knowledge: Regulatory Design in an Uncertain World Today at Florida
Brian Galle (Boston College) presents The Price of Knowledge: Regulatory Design in an Uncertain World at Florida today as part of its Graduate Tax Program Colloquium Series:
I examine a regulator's choice of how and when to regulate when marginal costs and marginal social benefits of compliance vary across regulated parties and are costly to observe. Recent commentary suggests that heterogeneity of marginal cost favors "carrots" over "sticks." Other commentary argues that heterogeneity of marginal social benefit may favor ex post over ex ante regulation, or may weigh in favor of "command and control" regulation rather than either sticks or carrots. While these recent papers add important nuance to the regulatory design literature, I argue here that their analysis overlooks several other critical factors that may alter their final policy recommendations. For example, I show that when marginal cost varies and moral hazard is possible, optimal government policy is a mix of stick and carrot, much as the optimal insurance contract provides for some co-payment by the insured. Ex post regulation does provide useful additional information when regulated parties are heterogeneous, but also carries significant and sometimes prohibitive social cost, especially when externalities are produced by limited-liability firms. Further, drawing on results from mathematical simulations, I show that the costs of heterogeneity can be sharply reduced even with a small degree of government flexibility. I apply these insights to a series of examples, including the pending U.S. cap-and-trade regulations, fat taxes, and the regulation of systemic risk in the banking sector.
October 6, 2014 in Colloquia, Scholarship, Tax | Permalink | Comments (0)
McMahon Presents Reforming Taxation of Privately Held Businesses Today at Loyola-L.A.
Martin J. McMahon Jr. (Florida) presents Reforming Taxation of Privately Held Businesses at Loyola-L.A. today as part of its Tax Policy Colloquium Series:
This article proposes the repeal of current Subchapters K and S, as well as the removal from the ambit of Subchapter C of all privately held corporations and the replacement of the current tax regime for privately held business with a new regime under which all privately held businesses (including wholly owned corporations and limited liability companies, and unorganized sole proprietorships) would be taxed at the entity level under a uniform rate schedule, regardless of the form of organization. (All publicly traded companies, and their controlled corporate subsidiaries, would continue to be governed by all of the structural rules of Subchapter C (and any other relevant Code sections outside of Subchapter C.))
October 6, 2014 in Colloquia, Scholarship, Tax | Permalink | Comments (0)
Wells: Pass-Through Entity Taxation -- A Tempest in the Tax Reform Teapot
Bret Wells (Houston), Pass-Through Entity Taxation: A Tempest in the Tax Reform Teapot, 14 Hous. Bus. & Tax L.J. 1 (2013):
Pass-through entities represent a major conceptual challenge for policy-makers today. But, pass-through entities did not occupy its dominant position with respect to growth-oriented small businesses prior to 1986, and the exponential growth in the importance of pass-through entity taxation since 1986 creates an impressive backdrop for the current business tax reform discussion. However, if tax reform proceeds along the path where corporate tax rates are significantly lower than individual tax rates, then small business taxpayers will be provided with a compelling economic incentive to exit pass-through entity structures in favor of C corporate entities. Tax reform that creates a monumental paradigm shift in the business planning premises of closely-held businesses will bring about transformative reactive tax planning on the part of the business community. Consequently, before enacting such a significant paradigm shift, Congress should clearly articulate the policy goals of this tax rate paradigm so that taxpayers will know which attempts to utilize C corporation vehicles as a mechanism to avoid the higher individual tax rate are acceptable and which such attempts cross the line. Where to draw the line is the historic challenge of the pre-1980 paradigm, but this reality has been shielded from our view due to the inverted rate structure that has existed since 1986.
October 6, 2014 in Scholarship, Tax | Permalink | Comments (0)


text: We were just spending the night on our way to Waco. We were hungrey and looking for the best BBQ. We found it just by looking across the way from our Hotel. There were 4 of us some ladies, 3 were not used to walking in and ordering, but we had good representation from the cashier. All had pulled pork,... More

subset: commoncrawl


text:
Billy Graham
A Look at the life and legacy of Billy Graham.
A Look at the life and legacy of Billy Graham.
700 Club Interactive takes a close look at the history and meaning of various symbols we associate with Christmas.
Does the Christmas shopping frenzy seem a little out of hand? We'll give you some easy ideas to...
Gordon cooks pear tarte tatin with skype guest Lynda Jordan.
Candace Cameron Bure is known for her acting, and manages to balance family life with her successful career. Here,...
Ben Carson compares President Obama to Vladimir Putin
The graffiti on a building in Belgium says it all: "Welcome to 'Belgistan." In fact, some are now calling...
Carson 'Feels Fingers' of God On Possible Presidential Run


text:
Molly Eadie
Phone: 518-290-3941
Molly Eadie covers covers politics, local government, police and courts.
Recent articles
General news
Troy City Council postpones budget vote
TROY >> The City Council postponed a vote on the proposed 2015 budget at Thursday's finance committee meeting, but it will likely vote on the budget Dec. 1.
General news
Troy police officer indicted in tip-off case
TROY >> City Police Officer Brian Gross, accused of tipping off at least one suspect in a drug ring investigation, was indicted on five charges Friday in Rensselaer County Court.
Police: Body found was missing St. Rose student
COEYMANS >> A body found along the Hudson River on Wednesday has been confirmed to be Connor Trapatsos, a College of Saint Rose student who went missing five weeks ago.
House, cars not targets in shots fired incident
TROY>> One house and two vehicles on Ingalls Ave were hit in an exchange of gunfire Monday morning, according to police. Captain Daniel DeWolf, spokesman for the Troy Police Department, did not believe the house, at 55 Ingalls Avenue, or cars were targeted in the fired shots.
General news
Troy Community Land Bank holds inaugural meeting, elects board officers
TROY >> The Troy Community Land Bank got right to work during its first meeting on Wednesday morning, electing officers to its Board of Directors.
New York State for TroyRecord
Jury finds Greenfield guilty of attempted murder
TROY >> On Tuesday afternoon, a jury found David Greenfield guilty in a retrial for the attempted murder of his ex-girlfriend, Ruth Morant
General news
Troy mayor, city council members still incorporating council's recommendations into 2015 budget proposal
TROY >> The city council will most likely not vote on the 2015 proposed budget during its finance committee meeting tonight.
General news
Jury expected to begin deliberations in David Greenfield retrial
TROY >> Closing arguments were heard Monday in the retrial for David Greenfield, who is accused of attempting to murder his former girlfriend.
Troy Local News
Crash victim's mother speaks to teens about safe driving habits
ALBANY >> Chris Stewart, a Clifton Park teen who was killed nearly two years ago in a car crash, is not buried in a cemetery. Instead, he lives on in several different places.
City clerk assistant job filled despite Troy City Council opposition
TROY >> The appointment of an assistant to the city clerk was approved by the City Council, but not before some City Councilmembers spoke up against the proposal.


text:
Morton's The Steakhouse - Charlotte
- Address:
227 W. Trade Street
Charlotte, NC 28202Neighborhood:
- Cuisine:
SteakhousePrice: $50 and over
Morton's The Steakhouse - Charlotte
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Friday & Saturday 5:30pm-11:00pm
Sunday: 5:00pm - 10:00pm
- Payment Options: AMEX,Diners Club,MasterCard,Visa
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- Dress Code: Business Casual
- Accepts Walk-Ins: Yes
- Additional Details: Banquet/Private Rooms, Bar Dining, Bar/Lounge, Happy Hour, Private Room, Smoking Area, Smoking Area (bar only), Takeout, Wine
- Catering: Private and group dining available. Contact our dedicated Sales and Marketing Manager to plan your next business or social event. Hosting a party at your home or office? Ask about Morton's Prime To Go and Prime Platters!
- Special Events: Morton's in Charlotte (Uptown) hosts a variety of special events featuring fine wine & spirits, the best steak and a great time! For more information, visit http://www.mortons.com/charlotte
A word from Morton's The Steakhouse - Charlotte
Morton's The Steakhouse, the nation's premier steakhouse group, specializes in classic, hearty fare, serving generous portions of USDA prime aged beef, as well as fresh fish, lobster and chicken entrees. The menu features a variety of favorite cuts, including a 24 ounce porterhouse, which is the house specialty; a 16 ounce New York Strip and a 12 ounce double cut filet.Continued
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Morton's The Steakhouse - Charlotte - Best Restaurants in Uptown ›
Morton's The Steakhouse - Charlotte reviews from OpenTable diners
78 reviews since July 31, 2014
- Food4.6Service4.6
- Ambiance4.4Noise LevelModerate
special occasion (64)romantic (39)notable wine list (34)good for groups (24)fit for foodies (22)neighborhood gem (7)great for lunch (3)late-night find (2)scenic view (1)Show More
- OpenTable Diner Since 2010Dined on 11/23/2014We visited to try the new offering of steak and lobster. The food was outstanding. Perfectly prepared and presented. It was a quiet Sunday evening and the staff treated us like VIP's. We will definitely visit again.Special Features:I would recommend this to a friend.
- A WINNER HANDS DOWNRonkDined on 11/21/2014Among the best when you're looking for fabulous steak and impeccable service. Consistently delivers on both counts. Pricey for sure, but you get what you pay for. This time we enjoyed the lobster/steak special, the crisp/hot fries, and the chopped salad. All prepared to perfection. The warm chocolate lava cake with ice cream was the perfect end to a perfect meal.,and the wine selection is to die for.Special Features:I would recommend this to a friend.
- Best steak!BobbyDined on 11/17/2014Tender, juicy, not enough adjectives to describe how good the steak is.Special Features:I would recommend this to a friend.
- Perfect AnniversaryOpenTable Diner Since 2007Dined on 11/14/2014My wife and I celebrated 22 years at Morton's. I let them know while making the reservation that it was our anniversary and they went above and beyond to make our night very special. The food was outstanding along with the service. We will go back next year for sure.Special Features:I would recommend this to a friend.
- Tom B.ThomasDined on 11/12/2014My wife and I celebrated our 37th wedding anniversary with a luscious steak dinner. Everything was awesome from the crab cakes and oysters on the half shell to the endive salad to the Chicago style bone in ribeye to the cauliflower mash topped with key lime pie. Mmmmmm!!!Special Features:I would recommend this to a friend.
- ServerOpenTable Diner Since 2010Dined on 11/10/2014Our waitress was outstanding! She made the evening very enjoyable.Special Features:I would recommend this to a friend.
- birthday dinnerdentechDined on 11/7/2014Took my wife to Charlotte for the week end to celebrate her birthday. Morton's was the place I chose to really "wow" her. The ambiance, food, and attention to detail of the wait staff was excellent. We were not only served the best steak in Charlotte we were also pampered and spoiled by the friendly and very professional staff. My birthday is in February and guess where I plan to celebrate it!Special Features:
- Charlotte BEATDOWN!!whodat2014Dined on 11/1/2014Awesome dining experience. Food superb, great service. Maitre'D EXTREMLY people person. This is a fabulous restaurant the crew gave me a wonderful Birthday to remember. My sister and I are forever appreciative of this most special occasion. THANK YOU!!!Special Features:I would recommend this to a friend.
- Awesome Filet!MoniqueInQCDined on 10/31/2014My meal was awesome and flavorful. My filet was tender and the onions and mushrooms were a great accompaniment. I shared that I had gluten allergies with my server and he protectively adjusted my side of broccoli to be prepared without the bread crumbs, which was great, because I would have had to send it back.Special Features:I would recommend this to a friend.
- Perfect For CelebratingNancyDined on 10/31/2014A special treat on Halloween night. We celebrated my Mom's 85th birthday. Service, special requests, and food were all just perfect! All treats, no tricks!Special Features:
- Always AwesomeAnniversaryDined on 10/31/2014Kevin and the team at Morton's always makes the evening a true night out. My wife and I would rather go here than anywhere else. Just wonderful service and great food.Special Features:I would recommend this to a friend.
- To Die ForBonBonDined on 10/25/2014My wife and I had a Panthers weekend staying at the Omni and walked to Morton's. I ordered the 22 oz bone in rib eye and it was succulent and delicious. just as I had on two recent occasions in Boston at two very fine steakhouses. The cauliflower, truffle and Parmesan side was unbelievable. So light and fluffy my wife who does not like cauliflower though it was better than her potato. She ordered the filet and lobster and said it was one of the best she'd eaten. The bread and wedge salad (that we split and still couldn't eat it all) are awesome too. Overall great food and great serviceI would recommend this to a friend.
- Dinner at MortonsJerrykDined on 10/18/2014Great food, great service and great attention to detail. We really enjoyed our evening and the warm welcome we received when we arrived. I would highly recommend this restaurant for special occasions.Special Features:
- Excellent restauranteOpenTable Diner Since 2010Dined on 10/18/2014Our meal was just devine! I think it was one of our best meals. Everything was great--food, service, staff. Everyone treated us like we were so special. Great night out!! Excellent food!Special Features:I would recommend this to a friend.
- Surprise FavoriteLimeDined on 10/17/2014So - Yes - dinner at Morton's. You know you are going to get the very best steak - hands down. But, Broccoli? No - we are not vegetarian. It was not a prior favorite. However, the broccoli we had at Morton's was by far the best I / we had ever had. For a restaurant that is known for its steak to prepare such a surberb vegetable dish - says it all. Pride & excellence in all that is served. And the Cheesecake- oh my the cheesecake.!!! The BEST ever!!!Special Features:I would recommend this to a friend.
- Steak average-everything else good!SteveVIPDined on 9/27/2014First time back at Mortons in a long time...overall was a good experience and the service was very good. The salad, sides, and dessert were excellent, but was really disapointed in the steak. I had the NY Strip (priced at $59) and it was pretty much an average cut of beef...it was thin and wide and did not seem like a "prime" cut steak. I have frankly had better steaks from the grocery store. Not sure if it was a one time deal, but when spending that type of money - I want it to be something I don't buy for myself at home!Special Features:
- Above and beyondgwg01Dined on 9/24/2014I took a group of customers to this location and was blown away at the level of service and the excellent food. Everyone's steak was cooked to perfection and was fork tender. The wait staff was over the top and was there for every need and more.Special Features:
- excellentVisitingUNCDined on 9/21/2014My son and I love the food! He ate the entire 24oz porterhouse! The steaks are seasoned and cooked to perfection! The wine list is outstanding!Special Features:I would recommend this to a friend.
- FordFordDined on 9/21/2014Steaks were average and well overpriced Appetizers were fair Would not eat here again For the money there are many more resturants nearby with better steaksSpecial Features:
- Birthday CelebrationHeirloomDined on 9/20/2014My best friend and I went for my birthday. They presented me with a personalized menu as a keepsake. The food and the service was fabulous. I look forward to going again.Special Features:I would recommend this to a friend.
- Good good & great serviceOpenTable Diner Since 2010Dined on 9/20/2014We were treated very well with special touches because it was our anniversary dinner. I appreciate the picture and special menu.Special Features:
- Always GreatOpenTable Diner Since 2009Dined on 9/20/2014As a huge Panther fan, I travel to Charlotte from the Outer Banks of NC. I have eaten at Morton's on many occasions and have always had a terrific meal, great service and a good time. It's hard to beat a fillet and lobster and nobody does it better than Morton's. I highly recommend them.Special Features:
- OpenTable Diner Since 2013Dined on 9/14/2014Delicious food, terrific waitstaff, ate at a different Morton's last year for my birthday, this time in Charlotte!Special Features:
- OpenTable Diner Since 2011Dined on 9/13/2014Food fine. Ambiance ok. Service questionable. Manager approached every table but ours. Husband 's birthday disregarded yet table across got candle and picture. Do not like no price menu. Will not return.
- CelebrateFeelslikehomeDined on 9/13/2014Food is wonderful especially the steaks. Plentiful sides and impeccable service. Very welcoming.Special Features:I would recommend this to a friend.
- Outstanding as Expected !MacirishDined on 9/13/2014Morton's is fitst class in every way.....from greeting upon arrival to departure with their complimentery valet parking. We took advantage of their Summer Special and were auite pleased. Great Salads and perfectly cooked steaks of the highest quality ! You can't go wrong with Morton'sSpecial Features:
- Always an exceptional standard!realtimereviewerDined on 9/13/2014Amazing food and service as we have grown to expect from Morton's. Great to have consistency in the food preparation time and time again. There are lots of options in fine dining but Morton's is a wonderful staple and we never hesitate in choosing to dine here. I must say that I have been to 4 other locations and they are all exceptional so it is always good to have a restaurant of this caliber in your city.Special Features:
- Gone downhillNCState1988Dined on 9/12/2014Morton's used to be a good restaurant with great food. The past three or four times we have visited, our steaks have not been cooked properly and on one occasion the scallops were burnt, and served "turned over" so that the burnt side was hidden. This last visit, steaks were over cooked. This is an expensive restaurant and you would expect that steaks would be prepared properly and as ordered. It is a steak house restaurant by the way. That should be the one thing that you would think would be right.
- Excellent for a special occasionConcordDined on 9/3/2014Service was excellent. The steak was cooked to perfection. Great wine choices. A wonderful dining experience.Special Features:I would recommend this to a friend.
- They did our anniversary right!dccshazamDined on 9/1/2014Wasn't expecting such a wonderful experience. Photo of us in a nice frame to remember the night. Custom menu with our names and anniversary on it. Everything was perfect.Special Features:I would recommend this to a friend.
- ribIandcabDined on 8/30/2014Outstanding service is what seperates Morton's from other high end steak houses. After 3 mediocre experiences at Del Frisco's, I switched to Morton's and have never looked back. Steaks were perfectly prepared. Wine list is extraordinary. This is the place for a special event.Special Features:I would recommend this to a friend.
- Group outingHkimDined on 8/30/2014Food was fantastic, service was great. Everyone enjoyed their meal but our server was def a smoker and had to stop another server to ask what the wine feature of the night was. Everytime he came around, we cringed from the cigarette smell still leftover from his cloths.Special Features:I would recommend this to a friend.
- ncfoodieDined on 8/23/2014Have eaten here several times. Was a little disappointed in the food this time - the fillet was a little stringy, and the 2 pound lobster was definitely over cooked. But the service was excellent, and the balance of the food - asparagus and lemon soufflé were outstanding.Special Features:
- Lobster night!We3go4funDined on 8/22/2014Took a group of friends and family for August Lobster night! Lobsters huge and our favorite waitperson, Tara, super as usual! Love Morton's quality!Special Features:I would recommend this to a friend.
- WILL NOT BE BACKKEETDined on 8/15/2014I could not believe the amount of time that it took for us to order. There were several open tables, both upstairs and down, so I could not understand why it was close to an hour before our order was taken. Once our food arrived, I had to send the $50 Lamb Chops back 3 times. When you pay this much to dine, you would think that the service would match. NOT even close. I will say the table beside mine seemed to have their food flowing to them with a different waiter. VERY poor service. This was my first dining experience at the Charlotte Morton's, and it will be a lasting one. I will not pay money to dine here again, unless proven otherwise to come back!!Special Features:
- skeyDined on 8/15/2014To sum it up in one word excellence! The food and service was outstanding! Staff did a wonderful job making our occasion special.Special Features:I would recommend this to a friend.
- Way to GoGoing2MortonsDined on 8/10/2014From the time we drove up to the time we left the service was excellent. The maître d' ensured we were settled in a great seat and took the time to ask why we were joining. He complimented us on our 7 year anniversary and ensured that our waitress knew as well. She was exceptional and offered us great suggestions on our food selection. They topped the evening with a complimentary desert for our anniversary. This was a great place to dine for such a special occasion.Special Features:I would recommend this to a friend.
- Wonderful fine dining in CharlotteTravelagentTVIPDined on 8/8/2014For years Morton's has provided quality fine dining along with an atmosphere that is above elegant. Wine selection is extensive and provides something for everyone. The Soufflés are delicious!Special Features:
- Great foot with excellent serviceMonkeyManDined on 8/1/2014As a veteran of Morton's from other cities (San Francisco, San Jose) my first trip to Morton's in Charlotte didn't disappoint. Outstanding steaks bring you to Morton's, the impeccable professional staff makes you come back. A two sentence note about our guests having an anniversary in the reservation created a fabulous experience for our dinner guests. Everyone addressed them by name from the front door till the end of the night, menu's were personalized, the food was excellent, and the night was capped off with a nice photo for them to take home. The staff made the night memorable for them just as I knew they would.Special Features:I would recommend this to a friend.
- The following 948 reviews are from the Morton's The Steakhouse - Charlotte reviews archive.
- Perfect!DrFritzDined on 7/28/2014Went for our anniversary. Could NOT have been better.Special Features:I would recommend this to a friend.


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Tel: (786)554-4017
School Overview
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State avg.: 33%
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National avg.: 13:1
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HialeahWe Love Kids
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(305)885-2490Daycare / Preschool0.3 mi | 14 students | Gr. K
HialeahBethel Baptist Christian School
3805 W 8th Ave
Hialeah, FL, 33012
(305)825-4958Daycare / Preschool (Baptist)0.4 mi | 6 students | Gr. KG
HialeahPrecious Little Angels Learning Center
325 W 29th St
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HialeahEbenezer International Christian Academy
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(786)312-1893Alternative School0.6 mi | 65 students | Gr. 9-12
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(305)885-85560.8 mi | 112 students | Gr. K-4
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What do you do when you are dissatisfied with your local public schools? Homeschool your children? Send them to private school? Let's look at your options.
Your religion matters to you. You want your child to attend a school which will combine academics and religious education. Here is an overview of what is available together with some links to denominational web sites.
Add things up and you'll quickly find the answer- math is crucial both in academics and the real world. By following these strategies and following personal training programs, students can uncover their weaknesses and conquer math.


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The 2014 Adequan/USDF Annual Convention will be in Cambridge, MA December 3 through December 6, 2014. The host hotel is the Hyatt Regency Cambridge, located at 575 Memorial Drive, Cambridge, MA.
The New England Dressage Association (NEDA), will be sponsoring the welcome party on Thursday Night at Ned Devine's Irish Pub at Faneuil Hall in historic Boston, which is right across the Charles River from the Hyatt Cambridge, our host hotel. Faneuil Hall has served as a marketplace and a meeting hall since 1742. Inspirational speeches by Samuel Adams and other patriots were given at Faneuil Hall. These oratories became the foundation for America's desire to obtain independence from the British. After the party, you can enjoy the many restaurants in this historic area and take the later courtesy bus back to the hotel.
USDF Announces
new tests for
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2015 USDF Region 1 Finals Competition Dates
BLM Championships
Oct 9-11, 2015
Horse Park of New Jersey, Allentown, NJ
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Virginia Horse Park, Lexington, VA
Use the following link to submit events and important dates to the USDF Region 1 Calendar. Include the event Name, the Date(s), a 2 sentence Description, and the GMO (w/website link), Contact Name, Phone, and email. Links to pictures and additional information should be included in the description.
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District Collector S. Lalithambika has said that all election-related victory processions in the district should be wound up by 6 p.m. on Friday. The decision was taken in consultation with the City Police Commissioner N. Gopalakrishnan to maintain law and order, she said. Election results of all the 11 constituencies in the district were expected to be out by noon.
Expenses of the victory procession would also have to be covered by the expenditure register of the candidates declared elected. Strict restrictions would be in force at all the counting centres. Only those with passes issued by the Election Commission would be allowed to enter the counting centres.
None would be allowed to use mobile phones in the counting centre. Each candidate could have one representative as agent at each counting table. Those entering the counting halls would be allowed t leave the hall only with the permission of the returning officer.
The Collector said arrangements had been made at the media centre, set up at the Civil Station complex, for mediapersons to monitor the progress of the counting.


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The lifetime of silicon detectors in a severe radiation environment at CERN LHC depends strongly upon careful detector design and material selection, due to the anticipated radiation-induced damage. We fabricated recently more radiation-tolerant CMS forward pixel sensors with new designs of silicon pixel detectors with the n+/n/p + and double-sided multiguard ring structure. Electrical characterization of such devices was performed before and after irradiation to neutron fluences (1 MeV equivalent) up to 6×1014 n/cm2, measuring leakage current, potential distribution over the guard rings and full depletion voltage. Studies on the radiation hardness using oxygen-enriched silicon substrates are being presented separately


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By Rick Warren
— May 21, 2014
Search me, O God, and know my heart; test me and know my anxious thoughts. See if there is any offensive way in me, and lead me in the way everlasting. Psalm 139:23-24 (NIV)
"Remember that your goal here is not to gain information, but to feed on the Word and get to know Christ better. "
(This devotional is adapted from Rick Warren's Bible Study Methods.)
To have a meaningful quiet time, you will need a plan or some kind of general outline to follow. But keep your plan simple.
Here's one plan --
1. Wait on God (Relax) -- Be still for a minute; don't come running into God's presence and start talking immediately. Follow God's admonition: "Be still and know that I am God" (Psalm 46:10; see also Isaiah 30:15; 40:31). Be quiet for a short while to put yourself into a reverent mood.
2. Pray briefly (Request) -- This is not your prayer time, but a short opening prayer to ask God to cleanse your heart and guide you into the time together. Two good passages of Scripture to memorize are:
You need to be in tune with the Author before you can understand his Book!
3. Read Scripture (Read) -- This is where your conversation with God begins. He speaks to you through his Word, and you speak with him in prayer. Read your Bible ...
Do you ever feel tired, drained or "beat-up" and just don't know why? That's because every day you're fighting an unseen spiritual war. You can't see it, but its effects are very real. In his 7 session Study Kit "The Invisible War: Winning the Battle of Temptation," Pastor Rick will teach you how to overcome the three predictable types of temptations that Satan uses to entice and defeat you: Passion, Possession, and Position.
Why is everything in life so hard? Why does doing the right thing often feel like a battle? In this new series, Pastor Rick shares insights from God's Word about the unseen spiritual forces working against us; the invisible war between good and evil. This series will help you win the battle within.
Purchase this seriesListen to this series


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The No. 21-ranked Alabama Crimson Tide (4-3, 0-0 SEC) will play its first road series of the 2014 season when it travels Lafayette, La. for three games against the No. 10 ranked Louisiana-Lafayette Ragin Cajuns (8-1, 0-0 SunBelt). The series gets underway on Friday night with first pitch scheduled for 6 p.m. CT from Moore Field. Game two, which will be televised on ESPN3, is scheduled to start at 2 p.m. CT and the series finale will begin at 1 p.m. on Sunday.
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