Dear Colleague,
I'm writing with an update on Loyola’s Tax LLM program, which consistently ranks among the top 10 graduate tax law programs in the United States. Our program prepares students to be practice-ready tax attorneys by offering a thorough grounding in tax fundamentals and numerous tax experiential learning opportunities in a stimulating, supportive environment. In addition, we offer students rich intellectual opportunities to develop their interests in tax policy and cutting-edge tax scholarship. Some noteworthy features of our program:
- We continue to enroll students from across the U.S. in the online and hybrid versions of our highly ranked Tax LLM curriculum. Unlike the online courses in most other similarly ranked programs, which generally offer only recorded versions of live classes, Loyola’s custom-built online courses are designed by Loyola’s tax faculty specifically for online students, deploying cutting-edge technology to be interactive, engaging, and educationally effective.
- Our full-time tax professors are dedicated to teaching, scholarship, and service. We all teach courses in our Tax LLM program, supervise students’ directed research, participate in tax program events, and advise and mentor students and graduates. Our full-time tax faculty is widely cited and has many SSRN downloads. Our tax professors also participate in national, state, and local tax bar associations.
- Our location in downtown Los Angeles allows us to offer an exceptionally broad array of experiential learning opportunities, to help students hone the skills they will need in tax practice:
- Three live-client tax clinics
- Five simulated client courses
- Externships with:
- The U.S. Attorney’s Office, Tax Division
- The IRS Office of Chief Counsel
- The California State Board of Equalization
- The California Attorney General's Office (Business and Tax Division)
- The California Controller’s Office
We encourage every student in our tax program to take at least one such offering as part of his or her training.
- Our program emphasizes writing. Our curriculum includes a tax research and writing requirement, an advanced tax research elective, and multiple tax courses with writing components and professor feedback on students’ writing. All of our online courses include multiple written assignments with professor feedback.
- Our graduates place well in tax positions with law firms, accounting firms, businesses, and government. Each year, approximately 90% or more of our Tax LLM graduates have secured full-time tax employment within 10 months of graduation. Graduates of our program work at Sidley & Austin; McDermott; Milbank; Venable; O’Melveny & Myers; Munger, Tolles & Olson; Pillsbury; all four Big 4 accounting firms; the IRS Chief Counsel's Office; and the California Franchise Tax Board.
- We offer a fully sequenced 3-year Joint JD/Tax LLM program (the “Joint Program”). During the summer after a Joint Program student’s 1L or 2L year, the student participates in Loyola’s unique 12-unit virtual Summer Tax Intensive (“summer tax boot camp”), which provides a rigorous foundation in the basics of tax law, incorporating the material covered in Income Tax Timing Issues, Taxation of Property Transactions, Corporate Tax I and II, and Partnership Tax I and II. By the end of summer tax boot camp, students have most of the substantive knowledge and analytic skills they need to excel as a big firm tax associate. Employers come to Loyola specifically to recruit boot camp graduates.
The Joint Program combines rigorous, sequenced tax training with significant employment and financial advantages, especially if students participate after their 1L year. During the on-campus-interview season at the beginning of their 2L year, students are able to offer employers a credential (completion of the intensive summer tax session) not currently available from any other U.S. law school. Students are free to accept full-time employment during the summer after their 2L year, with no conflicting coursework obligations, and avoid the opportunity costs of attending a traditional full-time, year-long Tax LLM program.
JD students enrolled at other U.S. law schools may easily participate in the Joint Program Online and graduate from their home school JD program and the Loyola Tax LLM program in just three years, in a hybrid or purely online format. During the summer, the visiting student enrolls in the 12-unit summer tax boot camp. In the following academic years (their 2L and 3L years of law school), Joint Program students take at least 12 additional units of advanced tax courses. Thus far, visiting students from UC Davis, Pepperdine, Penn State, UNLV, Southwestern, University of Wyoming, and University of Idaho have participated in the Joint Program.
I hope you will encourage students interested in personalized and rigorous graduate tax training to consider Loyola.
The remainder of this letter updates you on recent tax conferences at Loyola and faculty activities and publications.
Tax Conferences at Loyola:
- Festschrift and Tribute to Ellen Aprill. Our Tax Program sponsored a March 2023 full-day, live Festschrift on our campus, to honor Ellen’s scholarship. I organized and moderated the Festschrift. The papers, written and presented by Samuel D. Brunson and Philip Hackney, Roger Colinvaux, Richard L. Hasen, Michelle D. Layser, and Lloyd Hitoshi Mayer, will be published in the Loyola of Los Angeles Law Review. Discussants for the symposium papers included Michael Helfand, Justin Leavitt, Edward McCaffery, Deanna Newton, and Eugene Volokh. Prof. Jennifer Kowal organized the Tribute to Ellen, moderated by former Loyola Dean Michael Waterstone, which followed the live symposium. Dozens of Ellen’s current and former colleagues from all over the country, her former students, and her family and friends honored Ellen’s decades of service, teaching, mentorship, and kindness during the Tribute.
- Critical Tax Conference. Loyola’s Graduate Tax Program also hosted the April 2023 Critical Tax Conference at our Los Angeles campus. I organized the three-day conference, which for the first time included a formal discussant for each paper presentation. Ellen Aprill, Ariel Jurow Kleiman, Ted Seto, Jennifer Kowal, and I hosted meals and social events, moderated conference sessions, and served as paper discussants.
- Tax Policy Colloquium. This year marks the 17th anniversary of Loyola’s Tax Policy Colloquium, which Ted Seto and I founded. The Colloquium offers global tax scholars and our students opportunities to discuss cutting-edge tax works-in-progress. Our Colloquium is designed to generate thoughtful, helpful comments for authors on their draft papers through: participation of one or two formal discussants for each paper; comments and questions from Ellen, Ariel, Ted and me; and questions from Loyola students and Colloquium guests. This fall’s Colloquium authors, speakers, papers, and commentators include:
- Prof. Rebecca Kysar (Fordham): The Global Tax Deal and Its Implications. Commentator: Prof. John Vella (Oxford)
- Profs. Vijay Raghavan (Brooklyn) and Luke Herrine (Alabama): Reconsidering the Tax Treatment of COD Income. Commentator: Prof. Shu-Yi Oei (Duke)
- Neil Mehrota (Fed. Reserve Bank of Minneapolis), John Bistline (Electric Power Research Institute) and Prof. Catherine Wolfram (MIT Sloan): Economic Implications of the Climate Provisions of the Inflation Reduction Act. Commentators: Profs. Roberta Mann (Oregon) and Shi-Ling Hsu (Florida State)
- Prof. Yariv Brauner (Florida): Taxing Residents, Not People. Commentator: Prof. Stephen Shay (Boston College)
- Prof. Nick Chater (Warwick Economics): The i-Frame and the s-Frame: How Focusing on Individual-Level Solutions Has Led Behavioral Public Policy Astray. Commentators: Profs. Jacob Goldin (Chicago) and Lauren Willis (LMU Loyola)
- Profs. Casey McQuillan (Princeton Economics), Amy Finkelstein (MIT Economics), Owen Zidar (Princeton Economics), and Eric Zwick (Chicago Economics): The Health Wedge and Labor Market Inequality. Commentators: Kathryn Edwards (Labor Economist and Policy Consultant) and Prof. Amy Monahan (Minnesota)
- Prof. Natasha Sarin (Yale): Broken Budgeting. Commentator: Bill Gale (Brookings Institution)
- Profs. John (Jake) Brooks (Fordham) and David Gamage (Indiana): Moore v. United States and the Original Meaning of Income. Commentators: Profs. Alice Abreu (Temple) and Ellen Aprill (LMU Loyola)
- Profs. Ariel Jurow Kleiman (LMU Loyola), Shayak Sarkar (UC Davis), and Emily Satterthwaite (Georgetown): Towards an Understanding of Domestic Childcare Workers' Tax Experiences and Preferences on Worker Classification and Reporting. Commentators: Prof. Jonathan Harris (LMU Loyola) and Polly Bone (Attorney, Manager of Texas Taxpayer Assistance Project)
We welcome tax professors from other law schools at the Colloquium. If you would like to attend a session or join the mailing list for the Colloquium, please email me at katherine.pratt@lls.edu, or Ted at theodore.seto@lls.edu.
Full-Time Faculty Activities:
- Although she retired from the full-time faculty in 2022, Prof. Ellen Aprill, now the John E. Anderson Professor of Tax Law Emerita, continues to remain very active as a scholar and member of the profession and our Loyola community. In September, she received the Vanguard Award in recognition for outstanding lifetime contribution and achievement in the field of nonprofit law from the ABA Business Section Committee on Nonprofit Organizations. Earlier this year, she published Reviewing For-Profit Philanthropy and the 1969 Tax Reform Act, 179 Tax Notes Federal 825 (2023) and Governmental and Semi-Governmental Federal Charitable Entities, 74 Hastings (UC) Law Journal 1555 (2023). Later this year, she will publish two new articles, 21st Century Churches and Federal Tax Law, 2024 University of Illinois Law Review (with Lloyd Hitoshi Mayer), and Administrative Law Meets Section 501(c)(3) Charitable Purpose, The Tax Lawyer (Winter 2024). Prof. Aprill submitted a comment letter to Treasury and the IRS on Section 6417, Elective Payment of Applicable Credits, and also organized a submission from five scholars of tax-exempt organizations in response to a request for information from the Ways and Means Committee on political activities of tax-exempt organization. She also submitted, with Donald Tobin, an amicus brief in the U.S. Supreme Court case of Moore v United States. Prof. Aprill spoke at the NYU Federal Tax Institute this fall in October in New York and in Berkeley. She continues to serve on the Executive Committee of the USC Federal Tax Institute and on the Academic Advisory Board of the Tannenwald Writing Competition. Jointly with UCLA, she is organizing the 27th-annual Western Conference on Tax-Exempt Organizations in spring 2024.
- Prof. Ariel Jurow Kleiman will publish two new articles later this year, Subjective Costs of Tax Compliance, 108 Minn. L. Rev. (with Jonathan Choi), and The Future of Anti-Poverty Legislation, 112 Georgetown L.J. (with Andrew Hammond & Gabriel Scheffler). She presented Subjective Costs of Tax Compliance at the University of Michigan Legal Theory Workshop, as well as tax policy workshops at the Max Planck Institute for Tax Law and Public Finance, Columbia University, and one jointly held by Oxford-MIT-Michigan-Munich-Georgetown. Ariel was also invited to speak on a panel at the National Tax Association Spring Symposium, titled Lessons from the Pandemic: Administrative Issues in Delivering Assistance Through the Tax System. In the spring of 2023, Ariel was selected to serve as an independent third-party reviewer for the IRS Direct File Task Force, a role mandated by the Inflation Reduction Act of 2022. The Task Force's work received significant media attention, including in The Wall Street Journal, Bloomberg, Associated Press, Politico, and other major media outlets. The Task Force produced the IRS Direct File Independent Third Party Report to Congress, which was transmitted to Congress in May 2023. Ariel also recently joined the Executive Board of the Institute for Responsive Government. In July 2023, Ariel was a Hugh Ault Fellow at the Max Planck Institute for Tax Law and Public Finance. She is currently serving as the Herman Phleger Visiting Professor at Stanford Law School.
- Prof. Jennifer Kowal teaches Advanced Tax Research and Planning, Income Tax Timing Issues and Taxation of Property Transactions, Tax Law Practice, and Income Tax Intensive in the summer bootcamp. She also teaches Trusts and Wills in the JD program, advises students in the JD Tax Concentration, and serves as a coach to students participating in the ABA Law Student Tax Challenge each year.
- I (Katie Pratt) have a forthcoming publication, Making the Best of Long-Term Services and Supports for Seniors, in Law and the 100-Year Life (Anne Alstott & Abbe Gluck eds.). This year, I was named the John E. Anderson Chair in Tax Law at Loyola Law School. I was invited to speak on a panel on tax information reporting at the February 2023 ABA Tax Section meeting in San Diego. After my talk, I met with Treasury officials several times to brief them on the State of California’s plan to issue Form 1099 information returns to payee-survivors of state-sponsored forced sterilization. I was delighted when Treasury and the IRS subsequently issued an information release concluding the payee-survivors could exclude the payments from California, and the state should not issue Form 1099 information returns for the payments. During the April 2023 Critical Tax Conference, I presented two works in progress: Untangling the General Welfare Doctrine and Taxing Reparations. Katie also presented Taxing Reparations at Seattle University School of Law in September 2023 and will present the paper at Northwestern University School of Law in February 2024. In 2023, I continued to serve on the National Tax Association (NTA) Board of Directors and chaired the Membership Committee. Also, I was an invited member of the Planning Committee for NTA’s November 2023 Annual Conference on Taxation in Denver. In addition, I was an invited speaker on the NTA conference panel that honored Prof. Daniel Shaviro as the recipient of the Daniel Holland Medal, the NTA’s lifetime achievement award. Recently, I also was invited to become a Trustee of the American Tax Policy Institute. She is serving on ATPI’s Conference Planning Committee and Tax Literacy Committee. Prof. Bridget Crawford and I are organizing a two-day, fall 2024 Gender and Tax conference in Washington, DC, sponsored by ATPI. I also serve as a member of the Legislation and Policy Committee of the Food and Nutrition Section of the American Public Health Association. I co-organize and co-teach the Tax Policy Colloquium with Ted Seto.
- Prof. Ted Seto’s most recent article was published in the Tax Law Review. Modeling the Welfare Effects of Advertising: Preference-Shifting Deadweight Loss, 75 Tax L. Rev. 55 (2022). His next paper, The Role of Marriage in the Internal Revenue Code, will appear in the Florida Tax Review. In November, he presented a third paper, Four Principles of Optimal Tax System Design, at the National Tax Association annual conference. He also filed an amicus brief in Moore v. United States before the United States Supreme Court. He has since been invited to speak on Moore at a plenary session of the American Taxation Association in February. Ted teaches Loyola’s Tax Policy Colloquium with Katie Pratt, two courses on Partnership Taxation, and the partnership tax portion of the summer tax bootcamp in Loyola’s three-year Joint JD/Tax LLM program. He was heavily involved in taking Loyola’s Tax LLM online (now ranked third in the nation) and is currently teaching a newly built, partially asynchronous property course in Loyola’s new Hybrid JD Evening program. He also chairs the Graduate Tax Program committee and serves on the committee supervising the university’s reaccreditation.
As you can tell from this letter, our Loyola tax community of students, graduates, and faculty is intellectually vibrant, engaged, and cohesive. We hope you will encourage your students to consider our graduate tax program.
Warmest wishes,
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Katie Pratt
John E. Anderson Professor of Tax Law
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