TAX MAT T E R S AT U S D S C H O O L O F L AW

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Nickolas Peters
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1 TAX MAT T E R S AT U S D S C H O O L O F L AW The University of San Diego School of Law is building on its strong tradition of training leaders in tax law by recruiting outstanding new faculty, expanding its curriculum and tax programs, and providing new opportunities for hands-on, practical experience.

tax law by recruiting outstanding new faculty, expanding its curriculum and

2 RECENT APPOINTMENTS Howard Abrams A renowned expert in partnership and corporate taxation and member of the American Law Institute, Howard Abrams will join the USD faculty in the academic year from Emory Law School. Abrams, who was a visiting professor at USD School of Law in fall 2012, is currently visiting at Harvard Law School and has been a visiting professor at Cornell, Berkeley and Yale law schools. Abrams graduated cum laude from Harvard Law School and clerked for Judge Theodore Tannenwald, Jr., former Chief Judge of the U.S. Tax Court. His book, Federal Income Taxation of Corporations and Partnerships (Aspen, 2008) (with R. Doernberg and D. Leatherman), is widely used both in law schools and by tax practitioners. Miranda Perry Fleischer Miranda Perry Fleischer joins USD from the University of Colorado Law School. Fleischer graduated from the University of Chicago School of Law and received an LLM in Taxation from New York University. She clerked for Judge Morris Sheppard Arnold of the U.S. Court of Appeals for the Eighth Circuit. She has also taught at NYU and the University of Illinois law schools. Fleischer teaches and writes in the areas of individual taxation, federal estate and gift tax, and tax-exempt organizations. Her recent articles, which focus on the design of the charitable tax subsidies, have been published in the Boston University, Washington University and Minnesota law reviews and the Tax Law Review. Victor Fleischer Victor Fleischer comes to USD from the University of Colorado Law School. He graduated from Columbia Law School and clerked for Judge M. Blane Michael of the U.S. Court of Appeals for the Fourth Circuit and Judge Alex Kozinski of the U.S. Court of Appeals for the Ninth Circuit. Fleischer teaches and writes in the areas of partnership and corporate taxation, deals, tax policy and private equity. His articles, Two and Twenty: Taxing Partnership Profits in Private Equity Funds (NYU Law Review) and Taxing Founders Stock (UCLA Law Review), address the hotly debated topic of the tax treatment of carried interest. Fleischer s Standard Deduction column runs regularly on dealbook.nytimes.com, the financial blog of The New York Times. Adam Hirsch Adam Hirsch, a leading authority on wills and trusts and an academic fellow of the American College of Trust and Estate Counsel, comes to USD from Florida State University School of Law. Hirsch was a visiting professor at USD School of Law in A graduate of Yale Law School, he also holds a PhD in history from Yale University, where his doctoral dissertation received the George Washington Egleston Prize and was expanded into a book, The Rise of the Penitentiary Prisons and Punishment in Early America (Yale Historical Publications, 1992). Hirsch teaches and writes in the areas of wills and trusts, creditors rights and American legal history.

Abrams, who was a visiting professor at USD School of Law in fall 2012, is currently visiting at Harvard Law School and has been a visiting professor at Cornell, Berkeley and Yale law schools.

3 VISITING FACULTY Paul Caron Paul Caron has been named USD s Herzog Summer Visiting Professor in Taxation since He is one of the leading entrepreneurial tax scholars in the country and the publisher and editor of the popular TaxProf blog. Caron currently teaches at Pepperdine University School of Law. Previously, he was the Charles Hartsock Professor of Law at the University of Cincinnati College of Law and has been a visiting professor at the University of Florida College of Law and Florida State University College of Law. M. Carr Ferguson M. Carr Ferguson is joining USD in Spring 2014 for his 18th consecutive year as visiting professor. Ferguson is senior counsel to Davis Polk & Wardwell. He served as the assistant attorney general in the Tax Division of the U.S. Department of Justice and was one of the original thirty lawyers in the department s Honor Graduate Program. Ferguson has been Denison Professor of Law at New York University School of Law and has also taught law at the University of Iowa and Stanford University. Brian Galle Brian Galle is visiting USD School of Law in spring 2014 to teach corporate taxation and tax policy. Galle, an associate professor at Boston College Law School, has taught as a visiting professor at George Washington University Law School and Georgetown University Law Center. He is also a visiting fellow at the Urban/ Brookings Tax Policy Center. Galle previously practiced as an attorney in the Criminal Appeals and Tax Enforcement Policy Section of the Tax Division, U.S. Department of Justice. Honorable David Laro Judge David Laro returns to USD School of Law in spring 2014 to teach valuation. Judge Laro has served on the U.S. Tax Court since Prior to appointment to the bench, Laro practiced tax law for more than two decades and held several public offices: regent of the University of Michigan, member of the State Board of Education, and chairman of the State Tenure Commission in Michigan. Willard B. Taylor Willard Taylor is visiting USD School of Law in fall 2013 and teaching advanced corporate tax. Taylor is of counsel to Sullivan & Cromwell, LLP, an adjunct professor at New York University Law School, and a visiting lecturer at Yale Law School. He is former chairman of the Tax Section of the New York State Bar Association and of the Tax Advisory Group of the Federal Income Tax project of the American Law Institute. Taylor is a member of the U.S. Council of International Fiscal Association and the American College of Tax Counsel.

Previously, he was the Charles Hartsock Professor of Law at the University of Cincinnati College of Law and has been a visiting professor at the University of Florida College of Law and Florida State

4 LLM IN TAXATION AND DIPLOMA IN TAXATION Since 1978, USD s Graduate Tax Program has trained leaders in tax law. The LLM in Taxation degree and Diploma in Taxation program provide candidates with the theoretical and practical framework necessary for success in tax practice. In addition to obtaining a broad skill set in traditional tax lawyering skills, students gain a deep understanding of Internal Revenue Service pronouncements and the policies forming the basis of our tax laws and are trained to analyze the various proposals for tax reform and their correlation with current tax laws. HANDS-ON LEARNING: USD TAX CLINICS Federal Tax Clinic This federally funded clinic assists low-income individuals in resolving disputes with the Internal Revenue Service. Under the supervision of a faculty member, students receive practical training in tax law, tax procedure and lawyering skills as they represent individual clients in tax controversy proceedings before the Internal Revenue Service and in the federal courts. State Income Tax Clinic and State Sales & Use Tax Clinic The State Income Tax Clinic focuses on income tax appeals. Under the supervision of an attorney from the California Board of Equalization s Taxpayers Rights Advocate Office, law students represent taxpayers who are appealing income tax disputes with the California Franchise Tax Board. The State Sales & Use Tax Clinic focuses on sales and use tax disputes. Under the supervision of an attorney from the California Board of Equalization s Taxpayers Rights Advocate Office, students assist taxpayers at the petitions stage of proceedings with the California Board of Equalization.

In addition to obtaining a broad skill set in traditional tax lawyering skills, students gain a deep understanding of Internal Revenue Service pronouncements and the policies forming the basis of our

5 TAX LAW EVENTS AT USD SCHOOL OF LAW USD School of Law s Tax Law Speaker Series The Tax Law Speaker Series brings high-profile tax scholars to USD School of Law to present papers on topics of current research interest. The following tax scholars are scheduled to speak during the academic year: Joseph Bankman, Ralph M. Parsons Professor of Law and Business at Stanford University Law School Richard Schmalbeck, Simpson Thacher & Bartlett Professor of Law at Duke University School of Law J. Clifton Fleming, Ernest L. Wilkinson Chair and Professor of Law at J. Reuben Clark Law School, Brigham Young University Roberta Mann, Frank Nash Professor at University of Oregon School of Law Brian Galle, Associate Professor at Boston College Law School USD School of Law - Procopio International Tax Institute The ninth annual International Tax Institute, on October 24-25, 2013, will focus on the latest developments in international tax laws of Canada, Mexico and the U.S. This bilingual educational and networking event attracts recognized government leaders and practitioners from each side of the border. Richard C. Pugh Lecture on Tax Law & Policy Established in 2009 in honor of USD s Professor Emeritus Richard Crawford Pugh, this lecture series brings to USD School of Law prominent practitioners, judges or government officials who have played a significant role in shaping federal and international tax policy to discuss current and developing tax law and policy trends. On February 27, 2014, the Richard C. Pugh Lecture will be given by Edward D. Kleinbard, former chief of staff of the congressional Joint Committee on Taxation. Transfer Pricing Symposium On March 27-28, 2014, USD School of Law will host the second annual Transfer Pricing Symposium designed for professional service providers in global tax, finance, accounting and legal areas. This intensive conference brings together tax directors from leading companies and experts from government, academia, and private practice to present and discuss cutting-edge legal and economic trends impacting transfer pricing compliance, planning, and controversy jurisdiction. USD School of Law - Mayer Brown LLP Tax Controversy Conference On May 2, 2014, USD School of Law will co-sponsor a conference on Practical Approaches to Resolving Tax Controversies. The conference program will explore practical topics related to resolving tax controversy issues, including litigating in U.S. Tax Court, succeeding on appellate issues, and trends, enforcement changes, and best practices related to IRS proceedings. Summer Tax Seminars Designed for professionals in law, accounting and finance, as well as for corporate executives and business owners, USD s Summer Tax Seminars provide attendees with updated knowledge in specific tax areas rife with new and ever-changing legislation and compliance regulations, as well as a forum to discuss how these changes will affect business.

Parsons Professor of Law and Business at Stanford University Law School Richard Schmalbeck, Simpson Thacher & Bartlett Professor of Law at Duke University School of Law J. Clifton Fleming, Ernest L.

6 School of Law 5998 Alcalá Park San Diego, CA

PUBLICATIONS. How Is the Opera Like a Soup Kitchen?, in The Philosophical Foundations of Tax Law (Oxford University Press, forthcoming 2016)

PUBLICATIONS. How Is the Opera Like a Soup Kitchen?, in The Philosophical Foundations of Tax Law (Oxford University Press, forthcoming 2016) MIRANDA PERRY FLEISCHER Professor of Law The University of San Diego School of Law Legal Research Center 318 5998 Alcala Park San Diego, California 92110 619.260.2319 mirandafleischer@sandiego.edu ACADEMIC