Education:
BS 1964, Brigham Young University; JD 1967, George Washington University. University Honors: note editor, George Washington Law Review; Order of the Coif; Emory University Law and Economics Center, Institute for Law Professors, July 2-18, 1984.
Law Practice:
Bogle & Gates, Seattle, 1967-73.
Experience:
Ernest L. Wilkinson Chair and Professor of Law, J. Reuben Clark Law School, Brigham Young University, 1998 to present.
Associate Dean for Faculty and Curriculum, J. Reuben Clark Law School, Brigham Young University, 1999 to 2004.
Associate Dean for Academic Affairs, J. Reuben Clark Law School, Brigham Young University, 1986 to 1999.
Visiting Professor, Murdoch University School of Law, Perth, Australia, January 2008.
James J. Freeland Eminent Visiting Scholar Chair, Fredric G. Levin College of Law, University of Florida, 2002.
Visiting Professor, Central European University, Budapest, Hungary, 2001-2008.
Visiting Professor, T.C. Beirne School of Law, University of Queensland, Brisbane, Australia, 1997, 1999.
Professor-in-Residence, Office of Chief Counsel, Internal Revenue Service, Washington, D.C., 1985-86.
Fulbright Visiting Professor, Faculty of Law, University of Nairobi, Kenya, 1977-78.
Professor, J. Reuben Clark Law School, Brigham Young University, 1976-98.
Associate Professor, J. Reuben Clark Law School, Brigham Young University, 1974-76.
Associate Professor, University of Puget Sound Law School (now Seattle University Law School), 1973-74.
Principal Research Interests: Federal Taxation, U.S. income taxation, and International and Comparative Taxation
Classes Taught:
US Taxation of Foreign Businesses and Investors, Basic Federal Income Taxation, Federal Income Taxation of Business Entities, Tax Treaties, Public International Law, Principles of International Taxation
ARTICLES, ETC:
Reinvigorating Tax Expenditure Analysis and Its International Dimension, with Robert J. Peroni, 27 Va. Tax Rev. 437 (2008).
Replacing the Federal Income Tax with a Postpaid Consumption Tax: Preliminary Thoughts Regarding a Government Matching Program for Wealthy Investors and a New Tax Policy Lens, 59 SMU L. Rev. 617 (2006).
Exploring the Contours of a Proposed U.S. Exemption (Territorial) Tax System, with Robert J. Peroni, 109 Tax Notes 1557 (2005), 41 Tax Notes International 217 (2006).
Eviscerating the Foreign Tax Credit Limitations and Cutting the Repatriation Tax–What’s ETI Repeal Got to Do with It?, with Robert J. Peroni, 104 Tax Notes 1393 (2004), 35 Tax Notes International 1081 (2004).
Reform and Simplification of the U.S. Foreign Tax Credit Rules, with Robert J. Peroni and Stephen E. Shay, 31 Tax Notes International 1177 (2003), 101 Tax Notes 103 (2003). Excerpted in Michael J. Graetz, Foundations of International Income Taxation (Foundation Press 2003).
American Offshore Business Tax Planning: Can Australian Lawyers Get a Piece of the Action?, 8 International Trade and Bus. Law. Ann. 215 (2003)
"What's Source Got to Do With It?", Source Rules and U.S. International Taxation, with Stephen E. Shay and Robert J. Peroni, 56 Tax L. Rev. 81 (2002)
Fairness in International Taxation: The Ability-to-Pay Case for Taxing Worldwide Income, with Robert J. Peroniand Stephen E. Shay, 5 Fla. Tax Rev. 299 (2001).
BOOKS
Federal Income Tax: Doctrine, Structure and Policy, 3rd ed., with Joseph Dodge and Deborah Geier, 881 pages, with teachers manual, 399 pages (Lexis Nexis 2004).
Federal Income Tax: Doctrine, Structure and Policy, 2d ed., with Joseph Dodge and Deborah Geier, 830 pages, with teachers manual, 483 pages (Lexis Law Publishing 1999).
Federal Income Tax: Doctrine, Structure and Policy, with Joseph Dodge and Deborah Geier, 750 pages, with teacher's manual, 404 pages (Lexis Law Publishing 1995).
Reviewed in Jensen, Not Just Another Casebook, 68 Tax Notes 223 (1995).
CHAPTERS AND SUPPLEMENTS
2005, 2006, 2007, and 2008 Supplements to Federal Income Tax: Doctrine, Structure and Policy, 3d ed.
2000, 2001, 2002 and 2003 Supplements to Federal Income Tax: Doctrine, Structure and Policy
1993, 1994, and 1995 Supplements to Tax Aspects of Forming and Operating Closely Held Corporations, with Janet Spragens.
1985, 1986, 1987, 1988, 1989, 1990, 1991, 1992 and 1994 Supplements to Tax Aspects of Buying and Selling Corporate Businesses.
Survival of Major Corporate Tax Attributes (1985), revised chapter 18 in Tax Aspects of Buying and Selling Corporate Businesses.
Public Utility Dividend Reinvestment Plans, Ch. 63 in The Economic Recovery Tax Act of 1981 (ALI/ABA 1981).
OUTLINES
Using an S Corporation to Avoid Federal Employment and Self-Employment Taxes (Utah Bar Tax Section 2006)
American Offshore Business Tax Planning: Can Australian Lawyers Get a Piece of the Action? (Mallesons Stephen Jaques 2002)
Getting Serious About Curtailing Deferral of U.S. Tax on Foreign Source Income (ABA Tax Section Committee on Tax Structure and Simplification 1997), with Robert J. Peroni.
Update on 1995 Corporate Developments (ABA Tax Section Midyear Meeting Materials 1996).
Selected Corporate Tax Planning Issues and Techniques (Seattle Attorney-CPA Tax Clinic 1993).
Important Things We Do Not Know About a Broad Based Consumption Tax (ABA Tax Section Committee on Tax Structure and Simplification 1993).
Drafting Buy-Sell Agreements and the Impact of the New Estate Freeze Rules (Rocky Mountain Tax Planning Institute 1992).
TEACHING MATERIALS
Materials for International Tax Law, Central European University, Budapest, Hungary (2008)
International Taxation, Murdoch University School of Law, Perth, Australia (2008).
Supplementary Materials for Tax II (2006)
Tax Treaties, University of Florida, Fredric G. Levin College of Law (2002)
Materials for Introduction to International Taxation Law, T.C. Beirne School of Law, University of Queensland, Brisbane, Australia (1999).
PROFESSIONAL LECTURES AND PROGRAMS:
Research Presentation, Defending Tax Expenditure Analysis Against Its American Critics, European Association of Tax Law Professors Annual Congress, June 7, 2007, Helsinki, Finland.
Lecture, Using an S Corporation to Avoid Federal Employment and Self-Employment Taxes, Utah Bar Tax Section, September 27, 2006, Salt Lake City, Utah.
Paper presentation, Replacing the Federal Income Tax with a Value Added Tax or Retail Sales Tax: Creating an Investment Assistance Program for the Wealthy, Law and Society Association Annual Meeting, June 4, 2005, Las Vegas, Nevada.
Lecture, American Offshore Business Tax Planning, Can Australian Lawyers Get a Piece of the Action?, offices of Mallesons Stephen Jaques, July 11, 2002, Brisbane, Australia; July 17, 2002, Melbourne, Australia; July 18, 2002, Sydney, Australia
Speaker, Making Something Out of Nothing: An Introduction to the Fundamental Principles of Disregarded Entities, ABA Section of Taxation National Teleconference, February 27, 2002
MISCELLANEOUS
Worldwide Taxation vs. Territorial Taxation: Framing the Debate, Letter to the Editor (with Robert J. Peroni), 110 Tax Notes 549 (2006).
Framing the Debate Over Worldwide Versus Territorial Taxation, Letter to the Editor, (with Robert J. Peroni) 41 Tax Notes International 349 (2006).
The United States Should Tax U.S. Corporations on Their Worldwide Income, with Robert J. Peroni and Stephen E. Shay, 21 ABA Tax Section Newsletter 14 (Fall 2001).
More Thoughts on the Capitalization vs. Deduction Conundrum, Letter to the Editor, 89 Tax Notes 417 (2000).
Taking Territorial Taxation to Task, Letter to the Editor (with Robert J. Peroni and Stephen E. Shay), 87 Tax Notes 447 (2000), 20 Tax Notes International 1778 (2000).
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