The 100th Anniversary of the Revenue Act of 1913: Marking a Century of Income Tax Law in the United States

Speakers

 

Distinguished speakers include:

Alan Appel is a Professor of Law and Director of the International Tax Program at New York Law School.  Professor Appel specializes in international and domestic tax planning involving taxation of mergers and acquisitions, partnerships, joint ventures, limited liability companies and tax controversy matters. Prior to joining New York Law School, Professor Appel began his career as a trial attorney in the Office of Chief Counsel, Internal Revenue Service in Washington, D.C., and New York City. On behalf of the American Bar Association Tax Section, Professor Appel had the primary responsibility for drafting and submitting comments to the U.S. Treasury Department and IRS concerning the scope of the guidance provided by the proposed regulations under Section 1446 of the Internal Revenue Code and was also asked by the Office of the Chief Counsel to train its attorneys on this issue. Professor Appel published four articles on the Section 1446 regulations in The Journal of International Taxation, Tax Management Memorandum, and Tax Management International Journal. Professor Appel is on the Board of Advisors for the Journal of International Taxation and theJournal of Taxation and Regulation of Financial Institutions. He has published articles inThe Journal of Taxation, Tax Management Memorandum, Tax Management International Journal, The Journal of International Taxation, the New York Law Journal and the Westchester Bar Journal. He was formerly the Chair of the U.S. Activities of Foreigners and Tax Treaties Committee of the American Bar Association Section of Taxation and currently sits on the Section’s nominating committee. He is also a Fellow of the American College of Tax Counsel. Professor Appel has appeared on both radio and television discussing various income tax issues. He was also recently featured in “Taxpayers Strained by New FATCA Requirements” in AccountingToday.com, a leading provider of online business news for the tax and accounting community, concerning the Foreign Account Tax Compliance Act’s new requirements.

Valeriya Avdeev is an Assistant Professor at the Cotsakos College of Business at William Paterson University.  Professor Avdeev received her B.A. summa cum laude from Manhattan College in 2002 and her J.D. from St. John’s University School of Law in 2006. After law school she joined Deloitte Lead Tax Services group. Her responsibilities included corporate, partnership and high net worth individual compliance. Valeriya holds an LL.M in Taxation degree from New York Law School. Professor Avdeev joined William Paterson University faculty in 2010. She has authored a number of scholarly articles that have been published in the Duquesne Business Law Journal, Review of Business and Finance Studies, The CPA Journal, International Journal of Business and Social Science, International Journal of Business Humanities and Technology, and the International Journal of Humanities and Social Science.  Avdeev acts as a Director of the Volunteer Income Tax Program at William Paterson, by serving the University and the City of Paterson community and offering free tax help to qualifying individuals.  She is a co-chair of the Advisement and Registration Council and is a Member of the Property Maintenance Committee in her local town. Her principal areas of interest are effective tax planning for corporate and partnership entities, formation of new legal business structures, and effective teaching techniques.

Reuven Avi-Yonah is the Irwin I. Cohn Professor of Law and director of the International Tax LLM Program  at the University of Michigan Law School.  Professor Avi-Yonah specializes in corporate and international taxation. He has served as a consultant to the U.S. Treasury Department and the Organisation for Economic Co-operation and Development (OECD) on tax competition, and is a member of the steering group for OECD’s International Network for Tax Research. He is also the chair of the AALS Tax Section and trustee of the American Tax Policy Institute, a fellow of the American Bar Foundation, and an international research fellow at Oxford University’s Centre for Business Taxation. In addition to prior teaching appointments at Harvard University (law) and Boston College (history), he practiced law with Milbank, Tweed, Hadley & McCloy in New York; with Wachtell, Lipton, Rosen & Katz, New York; and with Ropes & Gray, Boston. After receiving his BA, summa cum laude, from Hebrew University, he earned three additional degrees from Harvard University: an AM in history, a PhD in history, and a JD, magna cum laude, from Harvard Law School. He has published over 150 books and articles, including International Tax as International Law (Cambridge University Press, 2007) and Global Perspectives on Income Taxation Law (Oxford University Press, 2011).

Richard Beck is a Professor of Law and founding director of the Graduate Tax Program at New York Law School.  Professor Beck has been teaching at New York Law School since 1986.  He teaches Individual Tax, Tax Policy, International Tax, and the Taxation of Property Transactions.   He has also taught Corporate and Partnership Tax Law. Professor Beck coauthored a casebook on taxation of business enterprises, and has published numerous articles on a wide variety of income tax issues.  An expert in federal individual income tax, Professor Beck has lectured and published widely on problems in the taxation of married persons.   Professor Beck was principal author of the ABA’s recommendation to repeal joint and several liability which led to the 1997 enactment of new innocent spouse rules.   He testified for reform of spousal liability for income taxes before the Oversight Subcommittee of the House Ways & Means Committee and the Senate Finance Committee.  While an assistant professor at the University of Denver College of Law, Professor Beck taught in the LL.M. program in taxation there.   He brought this experience to New York Law School where, with the collaboration of colleagues, he founded the LLM Program in Taxation.  After practicing law in New York City for four years, Professor Beck began publishing  articles on taxation and returned to teaching, first at the University of Denver School of Law, and then at New York Law School.  He has also taught in Paris at the Sorbonne, at the University of Osnabrück, the Wirtschaftsuniversität in Vienna, and the University of Rennes Faculty of Law.  He has lectured widely both in the U.S. and abroad, including invited lectures at Moscow’s Financial University and the Sochi University School of Law.   Professor Beck is a member of the Tax Section of the American Bar Association, as well as the NY City and State Bar Associations.

Peter H. Blessing heads Cross-Border Corporate Transactions in KPMG’s Washington National Tax practice and works from the New York City and Stamford offices of the firm.  His practice involves transactional, advisory and controversy matters, often in a cross-border context.  He advises clients in the financial services, information services, entertainment/media, automotive, manufacturing, pharmaceutical, medical device, natural resources, property, and other industries.  Mr. Blessing is a member of the Executive Committee of the New York State Bar Association Tax Section (Section Chair, 2010); member of the Permanent Scientific Committee of the International Fiscal Association and member of the USA Branch’s Executive Committee; member of the International Bar Association Taxes Committee (Co-Chair, 2010-11); member of the American Bar Association Tax Section (Chair, Committee on Foreign Activities of US Taxpayers 2004-06 and Council Director, 2007-10); director of the International Tax Institute (President, 2003-05); member of the Tax Forum; and fellow of the American College of Tax Counsel. Mr. Blessing has taught as an adjunct professor at Columbia Law School (2008-11).  He also a frequent lecturer on tax matters.  He has authored numerous articles and texts on taxation, including a treatise on US income tax treaties, and is the editor of a 2-volume set, “Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings.”  Recent articles include “Privileged Communications in the Context of U.S. Tax Practice”; “The Foreign Account Tax Compliance Act Provisions: Their Far-Reaching Effect”; “Divergence of Third Party Pricing from Arm’s Length Results”; “Limitation on Benefits as Applicable to Commercial Entities under the Canada-US Income Tax Treaty”; “The Debt-Equity Conundrum: A Prequel”; “Domestic and Treaty Anti-Abuse Rules as Applied to Dividends”; “Sovereign Immunity: A US and European View” (co-author);  and Tax Indemnities in M&A and Other Commercial Transactions.” Mr. Blessing is a frequent lecturer on international tax topics, including the OECD BEPS initiative. Mr. Blessing graduated from Princeton University, Columbia Law School and New York University School of Law (LLM Taxation).

Megan Brackney is a Partner at Kostelanetz & Fink, LLP.  Ms. Brackney is a native of Kansas, where she received her J.D. from the University of Kansas School of Law in 1998. She received her LL.M. in Taxation from New York University in 2009. From 2000 to 2004, Ms. Brackney was an Assistant United States Attorney for the Southern District of New York. Prior thereto, Ms. Brackney was an Assistant Attorney General for the State of Missouri. Ms. Brackney taught legal research and writing as an Adjunct Professor at Brooklyn Law School from 2002 to 2006, and has taught a seminar in Civil Tax Litigation at New York Law School. Ms. Brackney is a Council Director for  the American Bar Association Section of Taxation, former Chair of the Taxation Committee of the New York County Lawyers’ Association, former Chair of the Individual and Family Taxation Committee of the American Bar Association, Tax Section, and contributes to the two-volume ABA publication, “Effectively Representing Your Client Before the IRS.” She is the recipient of the American Bar Association Tax Section’s John S. Nolan Fellowship for 2008-2009. She joined Kostelanetz & Fink in 2004, and concentrates her practice in the areas of tax controversies, and civil and white collar criminal litigation.

Diane Fahey is an Associate Professor of Law at New York Law School.  Professor Fahey received her LL.M in taxation from Georgetown University Law School and then clerked for the Honorable James Halpern at the U.S. Tax Court.  Following her clerkship, Professor Fahey taught at Vermont Law School as a visiting associate professor of law for several years and has taught at New York Law School as an associate professor of law since 2006.  Her courses include individual income tax, corporate tax, taxation of business entities, administrative law, civil procedure, and Sales (Article 2 of the U.C.C.).  Her most recent law review article, “The Movement to Destroy the Income Tax and the IRS: Who is doing it and how they are succeeding” will be published this year in the Florida Tax Review.

Lawrence Feld is a Partner at the Law Office of Lawrence S. Feld and Adjunct Professor at New York Law School.  He is engaged in the private practice of law in Manhattan where he concentrates on white collar criminal defense and criminal and civil tax litigation. Mr. Feld is a co-author of a two-volume legal treatise, Tax Fraud and Evasion which is published by Thomson Reuters. He is also the author of the following:  “Supreme Court in Upjohn Protects Attorney-Client Privilege; Upholds the Work Product Doctrine,” The Journal of Taxation, June, 1981. Co-author: “Lawyers Beware: The Use of Counsel’s Statements as Evidence Against His Client in Tax Fraud Cases,” 63 Taxes 618, September, 1985; “State, City Tax Amnesty—Panacea or Peril,” New York Law Journal, p.1, Col. 3, November 15, 1985; “Attending to Legal Tender: The Perils of Structuring Cash Transactions To Avoid Treasury’s Reporting Requirements,” 64 Taxes 222, April, 1986; “Voluntary Disclosure Revisited,” ABA Section of Taxation Newsletter, Winter, 1986; “The New Accountant-Tax Payer Privilege Corporate Counsellor (June 1999); “The KPMG Tax Shelter Prosecutions,” Business Crimes Bulletin (October 2005); Co-author: “Failure to Report Foreign Bank and Other Accounts Can Be a Crime,” Business Crime Bulletin (May 1995), after 2 Corp. Crim, Liab. Rep. No. 1, 1988.  Mr. Feld has served as Chair of the Committee on Civil and Criminal Tax Penalties, Section of Taxation, American Bar Association (1989-1991) and as Chair of the Committee on Criminal Advocacy of the New York City Bar Association (1998-2001). Mr. Feld was an Assistant U.S. Attorney in the United States Attorney’s Office, Southern District of New York, 1972-1975. He was Assistant Chief Appellate Attorney, Criminal Division, 1974-1975.

Michael Hirschfeld is a Partner at Dechert LLP and Chair of the American Bar Association Section of Taxation.  Mr. Hirschfeld gives taxation advice and represents clients in planning to minimize tax burdens in corporate, international, partnership, real estate, workouts, and leasing matters. He has previously served as the ABA Tax Section’s Vice Chair Committee Operations, Council Director for their International Committees, chair of their Government Submissions and Real Estate Committees and chair of their 9/11 Task Force. In addition, he is a former chair of their Taxation Committee. Mr. Hirschfeld is a former member of the executive committee of the New York State Bar Association Tax Section and among his activities for that group, he co-chaired their committees on U.S. Activities of Foreign Taxpayers and Real Estate Tax Matters. Mr. Hirschfeld is also a member of the Wolters Kluwer Legal Tax Advisory Board and a member of the Board of Trustees of the American Tax Policy Institute, the American College of Tax Counsel, the Committee on Business Entities of the Association of the Bar of the City of New York, and The Tax Review. He is on the board of editors for Business Entities, the Journal of Taxation and Investments, Mergers and Acquisitions (The Monthly Tax Journal), and the Journal of International Taxation.  Mr. Hirschfeld is a frequent lecturer on international, real estate and other tax related topics at virtually every major tax seminar in the United States, including on FATCA at many significant tax conferences. He has written more than 50 articles for the Journal of Taxation, the Journal of International Taxation, Taxes Magazine, Tax Times, Taxation for Accountants, the Real Estate Tax Digest, and the  Canadian Tax Journal.

Elizabeth Kessenides is a Principal at Berdon LLP in the tax department.  Ms. Kessenides advises clients on corporate tax, reorganizations, cross border investment transactions and executive compensation. She has extensive experience in fund formation and acquisitions of interests in portfolio companies. She also advises executives on matters relating to their compensation arrangements.  She has worked with high-net worth individuals (both U.S. and non-U.S.) on deferred compensation issues, source of income issues (both federal and state), and planning investments in the United States. She has advised collectors on sales and charitable contributions of significant art collections. Before joining Berdon, Ms. Kessenides had a private tax practice in New York City and served as a tax partner in the New York office of a prominent law firm. She remains current on emerging tax policy issues and is active in the Tax Section of the New York State Bar Association, serving as a member of its Executive Committee.

Edward Kleinbard is a Professor of Law and a Fellow at the Century Foundation at the University of Southern California Gould School of Law. Professor Kleinbard joined USC Law in 2009. Before joining USC Law, Professor Kleinbard served as Chief of Staff of the U.S. Congress’s Joint Committee on Taxation. The JCT Staff are the nonpartisan tax resource to Congress, helping legislators to formulate legislation, writing analyses of legislative proposals or tax issues of interest to the Congress, and estimating the revenue consequences of legislative proposals. Professor Kleinbard’s work focuses on the taxation of capital income, international tax issues, and the political economy of taxation. His recent papers include Stateless Income (Florida Tax Review), The Lessons of Stateless Income (Tax Law Review), The Better Base Case (Tax Notes), Paul Ryan’s Roadmap to Inequality (Tax Notes), Herman Cain’s 9-9-9 Plan (Tax Notes), Tax Expenditure Framework Legislation (National Tax Journal) and An American Dual Income Tax: Nordic Precedents (Northwestern J. of Law and Social Policy). Professor Kleinbard has testified before the Congress on tax policy matters, and has written opinion pieces for the New York Times, the Huffington Post, CNN.com, and other media outlets. Prior to his appointment to the Staff of the Joint Committee on Taxation, Kleinbard was for over 20 years a partner in the New York office of Cleary Gottlieb Steen & Hamilton LLP.

William P. LaPiana is the Rita and Joseph Solomon Professor of Wills, Trusts, and Estates Director, Estate Planning, Graduate Tax Program at New York Law School.  Professor LaPiana holds both a Ph.D. in History and a J.D. from Harvard, where he also received his B.A. and an M.A. After graduating from Harvard Law School in 1978, Professor LaPiana, who is originally from suburban Buffalo, spent four years as an associate at Davis Polk & Wardwell in New York.  Professor LaPiana joined the faculty at New York Law School in 1987. In 1993, he was named the Rita and Joseph Solomon Professor of the Law of Wills, Trusts and Estates. Professor LaPiana also has been active with the trusts and estates sections of both the New York State and the American Bar Associations, and is an academic fellow of the American College of Trust and Estate Counsel, serving on its Committees on State Laws and Legal Education. He is also a member of the American Law Institute and served on the Members Consultative Groups for the Restatements (Third) of Trusts and of Property (Donative Transfers). Since 2009 he has been a member of the Office of Court Administration Surrogates Court Committee and has served on the New York City Bar Associations Surrogates Court and Trusts and Estate Committee since 2011. Prof. LaPiana was the reporter for the revised Uniform Disclaimer of Property Interests Act, which was promulgated by the Uniform Law Commission in 1999 and has been adopted in fifteen states, the District of Columbia, and the Virgin Islands. He was the American Bar Association advisor to the drafting committee for the Uniform Power of Attorney Act promulgated in 2006.

Maria M. Pirrone is an Assistant Professor of Accounting and Taxation at the Tobin College of Business at St. John’s University. Professor Maria M. Pirrone holds an LL.M degree in Taxation from New York Law School and a J.D. degree from St. John’s University.  She is currently registered as a licensed Certified Public Accountant and Attorney at Law in the State of New York.  She graduated from St. John’s University with a B.S. in Finance and M.B.A. in Public Accounting. Professor Pirrone teaches Individual Tax Planning, Taxation of Estates and Gifts, Taxation of Financial Products and Tax Research. She is a member of the NYS Society of Certified Public Accountants, the New York State Bar Association and the American Accounting  Association.

Diane Ring is a Professor of Law at Boston College Law School, where she researches and writes primarily in the fields of international taxation, corporate taxation, and ethical issues in tax practice. Her recent work addresses topics including international tax relations, information exchange, and equity in tax policy. Ms. Ring served as the U.S. National Reporter for the 2012 IFA Conference on the Debt Equity Conundrum, and was the U.S. National Reporter for the 2004 IFA Conference on Double Nontaxation.  She was the Assistant General Reporter for the 1995 IFA Conference on Financial Instruments and was a consultant to the IFA research project on the impact of technological and financial innovation on the taxation of income and activities.  Ms. Ring worked on the UN project regarding tax treaty policy for developing countries, and authored the chapter on “Exchange of Information” in the 2013 U.N. Handbook on Selected Issues in the Administration of Tax Treaties for Developing Countries.  Ms. Ring is also co-author of three case books in taxation– one on corporate taxation, one on international taxation, and one on ethical problems in federal tax practice.

Michael L. Schler is a partner in the Tax Department of Cravath, Swaine & Moore LLP. His practice includes corporate tax, corporate finance (including structured finance and securitizations), mergers and acquisitions and international transactions. Mr. Schler is a former chair of the New York State Bar Association Tax Section, and he remains an active member of the Tax Section Executive Committee. He is a member of the American College of Tax Counsel, the chair of the New York Tax Forum, a trustee and the former president of the American Tax Policy Institute, a past Consultant in tax programs of the American Law Institute, the author of many published tax articles, and a frequent speaker at tax conferences. He is the co‑chair of the annual merger and acquisition tax institute co‑sponsored by Penn State Dickinson School of Law and the New York City Bar. Mr. Schler has been repeatedly cited as one of the preeminent tax lawyers in the country and was the winner of the Chambers USA Award for Excellence in Corporate Tax in 2006.

Fadi Shaheen is an Assistant Professor of Law at Rutgers-Newark School of Law.  Professor Shaheen joined the faculty in 2011. His scholarship and teaching interests focus on international taxation, U.S. taxation, tax policy, and tax and economics. Professor Shaheen holds an LL.B. cum laude from the University of Haifa Law School and an LL.M. and an S.J.D. from the University of Michigan Law School, where he was an IASP Fulbright Scholar and a Michigan Grotius Fellow. Before joining the faculty, Professor Shaheen served as an associate at the tax group of Cleary Gottlieb Steen & Hamilton in New York. Previously, he had served as a visiting attorney at Caplin & Drysdale in Washington D.C., and as a law clerk and a practicing lawyer in Haifa. His native language is Arabic, and he is fluent in Hebrew. 

Stephen Shay is a Professor of Practice at Harvard Law School. Before joining the Harvard Law School faculty, Professor Shay was Deputy Assistant Secretary for International Tax Affairs in the United States Department of the Treasury and prior to re-joining the Treasury Department in 2009, he was a tax partner for 22 years with Ropes & Gray, LLP. Professor Shay served in the Office of International Tax Counsel at the Department of the Treasury, including as International Tax Counsel, from 1982 to 1987. Professor Shay has published scholarly and practice articles relating to international taxation, and testified for law reform before Congressional tax-writing committees. He has had extensive practice experience in the international tax area and has been recognized as a leading practitioner in Chambers Global: The World’s Leading Lawyers, Chambers USA: America’s Leading Lawyers, The Best Lawyers in America, Euromoney’s Guide to The World’s Leading Tax Advisers and Euromoney’s, Guide to The Best of the Best. Professor Shay has been active in the American Bar Association Tax Section as a Council Director and Chair of the Committee on Foreign Activities of U.S. Taxpayers, in the American Law Institute as an Associate Reporter, in the American Tax Policy Institute as a member of the Board of Trustees, and in the New York State Bar Association Tax Section and the International Bar Association. Professor Shay is a 1972 graduate of Wesleyan University, and he earned his J.D. and his M.B.A. from Columbia University in 1976.

Lee Sheppard is a contributing editor of Tax Notes, a Washington-based weekly tax journal. Sheppard is one of the most widely read and respected tax commentators in the world. She has been a mainstay of Tax Analysts’ publications for 30 years. She was recently named one of the Global Tax 50 most influential players in international taxation by International Tax Review. She was written up in The New York Times for her unique contribution to tax reporting. Sheppard specializes in financial issues and taxation of multinational corporations. She is known for her commentary on the international consensus, treaty issues, transfer pricing, and European tax developments. She writes about cutting-edge financial issues such as derivatives, hybrid securities and hedge fund questions. She also writes about banking and securities law issues. Sheppard is well known for her trenchant and truthful observations. She is fond of spiking her articles with humor and social commentary. She frequently comments on fashion and soccer. She also writes a blog for Forbes. She is frequently asked to speak on tax subjects. She has appeared on television shows such as 60 Minutes and Frontline, as well as in the documentary We’re Not Broke. Sheppard is trained as a lawyer, having attended Northwestern University and Northwestern University School of Law. She joined Tax Analysts in 1983 after a brief stint in practice. Tax Analysts, the publisher of Tax Notes and related publications, is a nonprofit publisher that provides the latest and most in-depth tax information worldwide. www.taxanalysts.com.

Ann F. Thomas is the Otto L. Walter Distinguished Professor of Tax Law and Director of the Graduate Tax Program at New York Law School.  Professor Thomas began a second career in academic law with a fellowship year at the Bunting Institute at Radcliffe College working in the corporate tax department at Fried Frank Harris Shriver & Jacobson, where she specialized in mergers and acquisitions. She spent two years as an adjunct professor at Yale Law School and joined New York Law School’s faculty in 1995.  Professor Thomas, who teaches a range of tax courses and is director of the Graduate Tax Program, was drawn to academia because of the chance to explore and develop a subject she views as fundamental to how societies function. Professor Thomas says her first love in taxation research is in the corporate and business context, but she also concentrates her scholarship on income tax and urges a re-examination of the assumptions about marriage and family that underlie current policy.  Although teaching tax law to future lawyers and practitioners is her primary mission, Professor Thomas uses her work in tax history to bring tax policy back to the citizens. As she sees it, tax literacy is the only way to ensure tax policies that reflect the needs of all citizens.  Professor Thomas studies and teaches about comparative systems of corporate taxation around the world and sees a need in the increasingly global marketplace for an expansion of international cooperation on business and tax issues. Professor Thomas is in the process of finishing a book examining the history of the U.S. tax system during the Progressive Era and the emergence of the modern income tax system in 1913.

Dennis Ventry is a Professor of Law at the University of California Davis School of Law.  Professor Ventry is a graduate of UC Los Angeles (B.A., History), UC Santa Barbara (Ph.D., Economic and Legal History), and New York University School of Law (J.D.). He is the author of dozens of articles, book chapters, and an edited volume. His research interests include tax policy, tax theory and history, family taxation, legal ethics and professional standards, tax administration and compliance, distributive justice, and public finance. He is a frequent contributor to TAX NOTES, the leading publisher of tax policy and tax information, and he has provided commentary to popular media including the Wall Street Journal, Los Angeles Times, Washington Post, International Business Times, USA Today, CNN, National Public Radio, and the Christian Science Monitor. Professor Ventry has been awarded numerous fellowships, including residential appointments from the UCLA School of Law, NYU School of Law, the Brookings Institution, the American Bar Foundation, Harvard University, and the UC Washington Center. He is also an accomplished teacher, having won department and university-wide teaching awards.