2015 Spiegel Sohmer Tax Policy Colloquium
The Spiegel Sohmer Tax Policy Colloquium was made possible by a generous grant from the law firm Spiegel Sohmer, Inc., for the purpose of fostering an academic community in which learning and scholarship may flourish.
In its second installment, the Colloquium focused on the fundamentals of corporate tax policy by critically examining issues in national and international tax policy. The Colloquium was convened by Allison Christians, H. Heward Stikeman Chair in Taxation Law.
Monday, September 28, 2015: Rosanne Altshuler
is Dean of Social and Behavioral Science and a Professor of Economics at Rutgers University. She was the Chair of the Department of Economics at Rutgers from 2011 to 2015. She has written widely on federal tax policy, including her most recent article “Lessons the United States Can Learn from Other Countries’ Territorial Systems for Taxing Income of Multinational Corporations.”
Monday, October 5, 2015: Steven Dean
 is a Professor at Brooklyn Law School and a specialist in tax law. His research addresses a range of tax and budgetary issues, including unconventional solutions to problems such as tax havens, regulatory complexity and tax shelters. His recent article, “Tax Deregulation,” considered the surprising implications of enhancing taxpayer autonomy.
Monday, November 2, 2015: Richard Murphy
is a chartered accountant and economist. He is the founder of the Tax Justice Network and the director of Tax Research LLP, which undertakes work on tax policy, advocacy and research. Mr. Murphy is the co-author of several publications on tax policy, including his most recent book, “Over Here and Undertaxed: Multinationals, Tax Avoidance and You.”
Tuesday, November 10, 2015: Daniel N. Shaviro: Recent International Tax Policy Developments
is a Professor of Taxation at the New York University School of Law. Professor Shaviro has written several books examining tax policy, budget policy and entitlements issues. His most recent book, “Fixing US International Taxation,” offers an analytical framework for international tax policy that sidesteps the standard worldwide taxation vs. territorial taxation framework.
Monday, November 23, 2015: Kim Brooks Scott Wilkie
Scott Wilkie, a partner at Blakes' Toronto offices, has a practice that is is primarily focused on international taxation including international corporate tax planning, transfer pricing and tax treaty advice, although in his 30 years of experience, he has advised on most areas of income taxation. Wilkie is vice-chair of the Permanent Scientific Committee of the International Fiscal Association. He is a past chair of the Canadian Tax Foundation and a member of the International Advisory Council of the International Bureau of Fiscal Documentation. Furthermore, he is an adjunct professor at the University of Toronto Faculty of Law, where he teaches international taxation, a co-director of the Osgoode Hall Law School Professional LL.M. in tax law and an adjunct professor in international taxation in that program.
(We regret that Professor had to cancel her presentation.)
Monday, November 30, 2015: Albert Baker: Base Erosion & Profit Shifting
is the Global Leader in Tax Policy at Deloitte LLP, where he specializes in international tax, including mergers and acquisitions, corporate financing and corporate reorganizations. His recent research focuses on base erosion & profit shifting, a project to address concerns that current international tax frameworks result in double non-taxation, or stateless income, or reducing the tax base in high tax countries.
Citizenship and Taxation Symposium, University of Michigan Law School, Ann Arbor, Michigan - Friday, October 9, 2015.
This symposium focused on ongoing developments regarding the unique US practice of taxing citizens who live permanently overseas. With the adoption of regimes such as the expatriation tax added by IRC § 877A and the Foreign Account Tax Compliance Act (FATCA), the taxation of non-residents with US person status now has serious and tangible implications.Â
Background
Like most countries, the United States claims the right to tax on a worldwide basis all of the people resident in its territory regardless of their legal status. But virtually alone in the world, the United States also claims worldwide fiscal jurisdiction over its citizens whether or not those persons are or ever have been resident within the territory. The legal claim over citizens dates to the first national income tax and has been continued through the present, but enforcement has always been an abstract ideal rather than a viable program.
This status quo has dramatically changed as an unexpected side effect of the adoption of the Foreign Account Tax Compliance Act (FATCA) in 2010. By introducing an unprecedented regime for global third party reporting, FATCA enables the IRS to enforce citizenship taxation on a worldwide basis for the first time in the history of the income tax. As will becomes ability, the normative foundations of citizenship taxation are coming under intense scrutiny.
To explore these issues, the symposium presenters offered different perspectives on the meaning, feasibility, efficiency, and fairness of the U.S. practice of citizenship taxation, and commented on the practical and policy effects of new legislative developments. We invited proposals that consider U.S. citizenship-based taxation from a historical, economic, social, political, institutional, or philosophical perspective.Â
Symposium Participants
In addition to the conveners, the symposium featured a panel of distinguished speakers, including:
- Wei Cui, University of British Columbia School of Law
- Tessa Davis, University of South Carolina Law School
- Michael Kirsch, Notre Dame Law School
- Patrick Martin, Procopio, Cory, Hargreaves & Savitch LLP
- Ruth Mason, University of Virginia Law School
- Saul Templeton, University of Calgary Faculty of Law
- Phil West, Steptoe & Johnson
- Ed Zelinsky, Cardozo School of Law
The Symposium was jointly hosted by the University of Michigan School of Law, the Ď㽶ĘÓƵ Faculty of Law, and Procopio, Cory, Hargreaves & Savitch LLP
Guide for Proposals
- Deadline for proposals: February 28, 2015. Now closed.
- Paper proposals must be between 300–500 words in length and should be accompanied by a CV.
- Successful applicants will be notified by the end of March 2015.
- Proposals should be submitted by email to Reuven Avi-Yonah (aviyonah [at] umich.edu) and to Allison Christians (allison.christians [at] mcgill.ca).
- Successful applicants must submit a working draft of their paper by September 8, 2015 for circulation among conference participants.
- Some support will be available for travel and accommodations; please indicate in your proposal should you require it.
- We anticipate gathering papers for a potential symposium issue or edited volume.