Speaker 0 00:00:00 So a lot of the more sophisticated planning work actually in the private spaces has moved gradually from the bigger law firms, uh, over to the big four because they, again, they have sort of the multinational reach that a lot of law firms don't have
Speaker 2 00:00:24 All present having business before the honor for the Supreme court of the United.
Speaker 3 00:00:27 Welcome to the us law essentials law and language podcast, the legal English podcast for non-native English speakers that helps you improve your English, listening, improve your legal English vocabulary and build your knowledge of American legal culture. Hi, this is Daniel. And before we begin today's episode, I wanna remind you that us law essentials offers online courses in legal English, and online courses in us law. Our courses are designed for international attorneys, students, translators and bar candidates. If you have any questions, please
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Speaker 1 00:01:20 Welcome to the us law essentials law and language podcast. I'm your host, Steven Horowitz. And today we continue our series of interviews with multilingual lawyers with our special guest Ellis Duncan director of the graduate tax LLM program and adjunct professor of law at Georgetown law school. Ellis has a law degree from two lane law school and an LLM in taxation from Georgetown law. He also has a master's in accounting from George Washington university and an undergraduate degree in international business and Latin American studies from Tula university. Uh, welcome to the show Ellis.
Speaker 0 00:01:56 Hi Steven. Thank you so much for having me. It's uh, it's great to be here and, um, great to be talking to you again.
Speaker 1 00:02:04 Yeah, it's really nice to, it's really nice to be able to, to chat with you as well and to catch up. Um, so the, the first question I always like to ask our guests is, uh, what languages do you speak?
Speaker 0 00:02:15 So I will preface this by saying I speak English and, and that's the only language that I'd profess to be, uh, proficient in <laugh>. Um, I was, I was once, um, I would say like an intermediate Spanish speaker, um, as you just mentioned, I was, um, I was, uh, decided I, well, I took some, some Spanish in high school and then I decided to, um, minor in Latin American studies along with my international business major. And so obviously being a Latin American studies minor, it was very useful to be taking Spanish. Um, so I took, uh, you know, some Spanish at, in college and then some is part of a, a study abroad program in Mexico city. Um,
Speaker 0 00:03:01 Um, so doing this podcast just makes me think about, um, you know, at one point I would, I thought I was quite good in Spanish or at least, you know, pro proficient, proficient, and, um, you know, could read it, definitely could speak it and communicate, um, with other Spanish speakers, uh, relatively well, but again, college was a long time ago, um, learning a language or relearning Spanish was something I wanted to do during the pandemic. We all had these like, you know, checklists of things we wanted to do with all of our free time. And that was one of them. Yes, yes. And it, and it never actually happened. So, um, this, this podcast, like, you know, just being here makes me, um, put this back on the front burner in terms of things I would like to, um, accomplish at some point I'd like to get back to that level that I was in college when I was really immersed in the, in the study of a language.
Speaker 1 00:03:52 Oh, good. Well, we'll, we'll give you extra motivation cuz we'll do a follow up interview in one year and we'll do it in Spanish with you. <laugh> okay. That, is that a deal
Speaker 0 00:04:01 I was gonna, I was gonna say, you know, um, where I really learned the most was, you know, visiting a foreign country and we could talk about this later. Um, you know, studying abroad in Mexico is part of my Latin American studies program where I, um, lived with a family there. And, um, the, the rule number one of walking into the house was that no English was gonna be spoken in the house at all. So, oh, wow. This is, this was me with, you know, maybe two semesters of, um, written Spanish and then in one conversation class under my belt. So it was particularly challenging in those first few weeks, um, in the household, just kind of having basic conversations, but at the end of the, you know, at the end of the, the summer, I, I really was, I, I really felt quite confident in my ability to have all kinds of conversations in the classroom, you know, just, you know, casual conversations with my family over dinner and, um, loved the rule that I wasn't allowed to speak. I had to communicate in Spanish.
Speaker 1 00:05:02 That's really, that's really, uh, good that they did that. Huh?
Speaker 0 00:05:05 Yeah, no, it was, um, again, it was really, it was kind of the only way to learn it. So I feel like if I do go back, it's like doing a Rosetta stone is, is one thing. But really, um, if, if, you know, if I, and when I do study Spanish again, I would really like to do it in an immersive experience, but by traveling abroad,
Speaker 1 00:05:27 Did, did you ever have any frustrating moments with the language that you remember or, or funny moments perhaps?
Speaker 0 00:05:33 I did. I did. I, I, I had so many of them, but I think, you know, it was sort of a, um, a <laugh> I'll call it a semi tragic situation where, you know, I was a, I was a little naive and 20 year old college student and I, um, you know, had a full wallet and I had $200 in dollars in pesos in my wallet. And I boarded a crowded Metro train in Mexico city and got pick pocketed and, um, you know, left the train, like where, what happened. And, you know, you're, you're sort of in a, I don't know if you've been to Mexico city subway, but it's just, it is, it can be extremely crowded, extremely, extremely crowded. Um, and you know, you, you know, it's, it's pretty easy for someone to kind of take something out of your, out of your pocket.
Speaker 0 00:06:21 And I was, you know, I was pretty flustered after that experience. Again, this was my first time really traveling abroad and certainly, you know, studying abroad and living abroad this, these were all new experiences for me. And that was my first week in, you know, my first week in Mexico city. And I came home and I was, you know, kind of fighting back the tears. And I realized that I couldn't explain in Spanish to my family, like what had actually happened. Like I was using all of these hands signals to, you know, to have someone taking, you know, things out of my pocket. And I have no, you know, no tango de narrow, I don't have any credit cards with me anymore. Um, so it was, it was a little bit of a, um, um, I, you know, it was a, it was a learning experience like this is, this is me having to be on my own in a foreign country.
Speaker 0 00:07:10 It's me having to explain myself, um, in another language. But it also, I, I think that it, it, um, it was a little bit of a bonding experience between me and my family, because, you know, once I was able to sort of tell them what had happened, you know, they were, you know, really sympathetic, you know, they helped me, you know, work through the, you know, getting cash back to the house and getting my credit cards replaced. And, and, um, but yeah, that was, that was kind of, you know, trial by fire first experience, uh, in Mexico city.
Speaker 1 00:07:42 So you lost a wallet, but you gained a, a social bond and some important language learning
Speaker 0 00:07:48 <laugh> I did I, and I re I realized that, you know, look, I couldn't fall back on English. I actually had to speak Spanish. I had to explain to the family what had happened. And, um, it was, uh, it was a unique experience. And, um, yeah, one I, one, I won't forget.
Speaker 1 00:08:06 Uh, my, one of my most frustrating language experiences, it much mine, much more minor and inconsequential than yours, but I, when I first got to Japan, uh, it was after college and I, I went to a barber shop to get my haircut, and I was trying to tell him how much shorter to make my hair. And I was trying to say a little shorter and it seemed simple, but for some reason I could not communicate it <laugh>. And I, I, I don't think I ever did. And I don't, I don't remember what he did after that anyway. Yeah. But, but these, these experiences are, you know, I, I think everybody who goes abroad and, and students who come here as well must have them. Um, so absolutely. So you went, you were, you were a Latin American, um, studies major, uh, struggling your way through, through Spanish in Mexico. And then did that lead you to want to become, uh, a tax lawyer?
Speaker 0 00:08:59 Um, I dunno if those things were really related <laugh> I, I think that, um, you know, I, I did, I did, I was a business. Um, I was a business major. I was a Latin American studies minor, but that kind of went along with like my international business focus. Um, and, and then I ended up wanting to go to law school. I think I had so many reasons back then that I don't know if they made sense or not. Um, but I think at the time was just to kind of combine my, um, you know, combine my business degree with a law degree because I thought it would, you know, give me a whole lot of options, even though I couldn't really, um, narrow down what it was I wanted to do. So, um, I, I don't think that it did, I don't think that, um, you know, studying, studying abroad or studying a language wanted, you know, led me to, um, led me to law school necessarily, but, um, you know, it, it was still a wonderful experience and it, it was the first of, you know, that, I think that was my, the second country I'd been to, and now I've been to 60.
Speaker 0 00:10:04 So, um, it, it definitely, um, spurred my interest in, in traveling. Um, absolutely
Speaker 1 00:10:12 Six you've been to 60 different countries. Yeah. Could you name them all in 10 seconds? Is that something that <laugh>, you know,
Speaker 0 00:10:21 Absolutely. Yeah, absolutely not. Um, cause a lot of these are, I kind of like jotted down and they're, you know, um, you know, stops on cruises in the Caribbean. They're like different countries like that, or, you know, I could, I could name them if you gave me a, a continent perhaps,
Speaker 1 00:10:36 But have you, have you been to Texas? Does that count as another country?
Speaker 0 00:10:40 It, uh, they seem to think it does.
Speaker 1 00:10:42 Yeah.
Speaker 0 00:10:43 Um, people from Texas,
Speaker 1 00:10:44 But we, we had another guest on, on the podcast a little while back. Um, another Georgetown law colleague, uh, John Dundon, uh, legal English professor Uhhuh. He's been to he's. He said he's been to, I think, 90 different countries. So I, I, I was thinking at 60, you would be the, that would be the most, but I realized that's a, that's a, a second place, but it's still extremely impressive.
Speaker 0 00:11:07 Yeah, no, it was, it was one of my goals when I, I think I hit like 30 and I had been to 30 countries when I turned 30. And so my goal when I turned 30 was that I wanted to visit like at least one new country for each year that I was alive. I I've been alive. So, um, um, that number has not ticked up in five years because of the pandemic and other considerations, but it's, um, yeah, it's, it's still my goal. I I'm, I'm not quite 60 years old yet, so I have, I have time.
Speaker 1 00:11:35 Um, so now it, it seems like as you talk about international business and, and some of your experience abroad, um, the work you're doing now really does seem to, to, uh, intersect very nicely with yeah. With sort of your, the themes in your earlier part of your life. Do you wanna, wanna talk a little bit about what you're doing now?
Speaker 0 00:11:55 Yeah, absolutely. So, um, I'm the director of the tax program? Um, I always sort of, um, I say that I always say first that I'm a graduate of the LM program, which I think you noted at the beginning. And I worked as the tax lawyer for many years before, um, coming to Georgetown. Um, in my current role, I wear a lot of different hats. It's, it's really a wonderful job for me because no two days are the same, but I am on a daily basis really, um, using, um, my background and everything. And, you know, being a lawyer, you know, being a, you know, international business, major Latin American studies. Um, so I, my primary job is I'm the academic advisor to about 275, um, different students enrolled across tax programs. And when I say, um, and tax programs, I'm talking about the tax L om, both us educated and foreign educated, um, students who come to the program.
Speaker 0 00:12:58 Um, but also students who are working professionals in our online program, um, as well as JD students who have an interest in tax. So, um, that's sort of my primary job is that, you know, working with students one on one, um, you know, to develop an academic plan, uh, to develop a career plan, to kind of get them to where they wanna be on the other side of the program. So I, I kind of see that as my main, you know, most important and probably the most enjoyable part of my position is the, is the academic advising. Um, I'm also involved in admissions and recruitment. So, um, I do a lot of, um, kind of webinars about the tax program. Um, I do, I used to do what I would call road shows, where I would go to different JD schools and talk to, you know, their tax law societies or groups of students that are interested in, um, in tax.
Speaker 0 00:13:53 And just tell 'em a little bit more about, you know, why do an LM, why Georgetown? Um, I read a lot of admissions files, so, um, that's, that is part of the job. And then, you know, work with our admissions office on, on scholarship, um, considerations. Um, I also do, um, do the scheduling and, uh, recruitment of adjunct faculty, uh, to teach our 60 plus different graduate level, uh, tax courses. So that's a lot of work that, yeah, that's a lot of work. Um, you know, again like identifying the right adjunct faculty, um, you know, to, uh, who are able and willing and have the right skillset to teach all of these different classes and, and kind of managing, not really managing the curriculum so much, but, you know, taking sort of a broader look and seeing, you know, where there are holes where we need, you know, to fill in, um, where, where coverage needs to be had and whatnot. And also, um, maybe most related to this particular interview is I am, I do teach a legal research and writing class for our foreign trained tax LLM students. Uh, particularly those, most of those who take it, uh, are looking to sit for the New York bar exam. So they're taking as part of their bar prep work, but some students actually take it for, you know, just for the, um, you know, to improve their written English and also their writing skills.
Speaker 1 00:15:16 How, how big is the tax LLM program or the graduate tax program at Georgetown and, and approximately how many, um, foreign educated attorneys would you say are in the program?
Speaker 0 00:15:27 Yeah, so, um, you know, again, across programs, do you count everybody if you, which I do, um, you count you're us educated. You're, part-time, uh, you're, full-time, you're foreign educated and you're online students, as well as your students pursuing specialty certificates. We have about 275 students across all of those programs. Oh, wow. Um, in, in an average year, we probably have between 30 and 35, sometimes as many as 40 last year, we had 38, um, foreign educated students usually coming from somewhere between 15 and 20 different countries. So, um, it's a good portion of the what's 40 into that. It's like 20% of the students, um, are foreign educated, 15, something like that.
Speaker 1 00:16:10 So that's a, that's a pretty diverse class. And, and has the number of foreign educated attorneys in tax LM programs? Has that been, has that gone up over recent years or is that something that's been steady over the years?
Speaker 0 00:16:23 I think it has actually ticked up. I think that we've seen, um, an uptick in foreign educated lawyers coming to, to, um, the tax LLM programs specifically that is actually where we've seen a little bit of an uptick, whereas the us students have kind of stayed the same and the part-time students, at least in the, in person part-time program, you've seen a little bit of a decrease, but yeah, absolutely. I've seen, I think the number was in the twenties maybe, you know, five years ago and now is, you know, definitely the mid thirties most year.
Speaker 1 00:16:57 And, and what's your experience been working with foreign educated attorneys through your teaching and, and through your academic advising as well? What do you,
Speaker 0 00:17:05 I love, I love them. I, I can't play favorites between my students of course, right.
Speaker 0 00:17:10 J just love the diversity that comes into every single class. Um, it really is like for our us trained students, um, you know, the, the tax LLM is kind, some of them see it as a, as an extension of their JD program. So we, we, we sometimes refer to them as four LS and, you know, they're kind of like they wanna, they know they wanna do tax. They wanna, you know, use the LLM to sort of bridge the gap between their JD and, and, you know, again, find a job. Um, the, the foreign students really see their, you know, usually one year in, in the United States, in Washington, DC as a whole experience. Um, so it is, you know, I, I feel like our conversations, you know, veer sometimes out of tax sometimes and into how should I spend my time in Washington and, you know, where should I go on the weekends and what kind of, you know, day trips should I take or weekend trips should I take?
Speaker 0 00:18:04 And, you know, again, it's the, um, you know, what I'm teaching in particular and, and trying to discuss like a particular area of tax law or, you know, the way, um, you know, a particular, just trying to illustrate a concept. What is wonderful about the foreign students is they can a, a lot of them come to the program with experience in their own home countries. So they're able to, you know, tell me about their tax systems and how, you know, what I'm saying might be different or viewed differently in their own country. So I always feel like I walk out of every class session with, um, um, a little more knowledge and a little more perspective, um, because, um, you know, again, it's the, the diversity of, of countries and experience that our, our foreign educated students bring, uh, to the program.
Speaker 1 00:18:58 So when you teach, um, a legal research and writing course for tax LM students, um, how, how is that course different from say, um, uh, a, a legal research, a legal research and writing course that, that students in a general LLM program might take?
Speaker 0 00:19:15 I think that's a good question because I haven't actually, um, compared my syllabus with some of the, like the syllabi of other, uh, professors who are teaching, um, legal research and writing like for non-tax students. But what I do in particular is that I think it's important to, um, give students, uh, like important background on, um, the tax system overall. So, um, what I do is I usually spend the first four or five classes discussing the overall tax system in the us, starting with the us constitution and how, you know, powers are given to three different branches. Um, but also all of those three branches of government in the us are, are, um, involved in the process of like, you know, making and interpreting and judging, um, us tax laws. So, um, you know, I spend a lot of time talking about, you know, how a bill becomes the law and how, you know, how that works with tax legislation and the role of the executive branch, uh, including the, uh, department of treasury and the internal revenue service.
Speaker 0 00:20:18 And, um, you know, a lot of times Congress, they're not tax experts, so they write these laws and they don't, they don't sort of like fill in the, um, you know, like how these laws work in practice. So that, that, that goes over to the treasury department and the IRS to draft regulations and other rulings. So they take a huge part in the development of our tax law, and again about how our, our, the court system works for tax cases, because it is very different because we do have, uh, the tax court, which is a very specific, you know, tax only venue for taxpayers. Um, so I do spend the first part of the class, you know, talking about, you know, three branches of government, how tax laws are made, what this means practically for you as a, um, as someone who's gonna presumably practice in the, you know, tax law in the us.
Speaker 0 00:21:11 And then of course the, um, how research and writing in, in tax is a little bit different than it might be in other areas, particularly the research part, because, um, you are, um, the students have to be familiar with like a number of different databases and like, know to find, um, different pieces of, of legislation and treatises and whatnot. So I usually start the, the class with that. And so I think that might be a lot different than what other, um, other professors might do, um, is to give them the background. Um, and then we, we, we dive into two different, um, uh, they write two different memos after that.
Speaker 1 00:21:54 That does seem like a, I mean, it seems like a very different experience than the students in the general LLM are getting. So,
Speaker 0 00:21:59 Yeah. Yeah. Like they wanna go, they wanna get into the writing right away because they want writing samples and I get it, but I'm, you know, I do have to, you know, a lot of times I have to say, okay, well, I'm giving you all this background information, but that's just because you're not getting it in other classes, but you're gonna, you're gonna need this, this background information somewhere. So I do try to, uh, spend a few classes on, um, you know, the, the, the, the system for tax, the tax law creation and, and interpretation.
Speaker 1 00:22:29 Yeah. And I mean, that's one of the challenges, I mean, I guess working with, with any, any law students interested in tax, but, but especially for an educated attorneys, that if you don't have the background knowledge, it's very difficult to write effectively, whatever you write. Can't, it's not gonna be good if you don't fully understand the, the topic that you're writing about. Well,
Speaker 0 00:22:49 AB absolutely. Absolutely.
Speaker 1 00:22:52 Um, now one thing, a lot of, um, foreign educated attorneys, um, are interested in when they, when they come to do an LLM program in the us is the job market and, and the work opportunities afterwards. Um, what are, what are some of the unique characteristics of, of doing a tax LLM in the us for foreign educated attorneys? Well,
Speaker 0 00:23:12 Yeah, it's, it's really different. I, I think that, um, in some areas of law, like the, um, it seems like, and this is, I I'm completely over generalizing here, but it's many students, um, view the opportunities either as, you know, private law firms or the government and tax law is, is, is kind of a lot. There's a lot of a, there's a, there's a wider, um, array of opportunities within tax law. So for example, in the PRI in the private market, um, you know, services are provided not only by law firms, but like more, um, more recently, a lot of, um, you know, tax planning services have been provided by one of the big four accounting firms. And when I say big four, I'm talking about price Waterhouse, Coopers, KPMG, Ernston young and Deloitte. And so these, um, these accounting firms have, you know, offices and virtually like every single developed country, all over the world and higher tax attorneys with tax LLMs, um, specifically they, they come to LLM programs, um, looking at the LM degree as a prerequisite for practice.
Speaker 0 00:24:27 And so a lot of the more sophisticated planning work actually in the private spaces has moved gradually from the bigger law firms, uh, over to the big four, because they, again, they have sort of the multinational reach that a lot of law firms don't have. Um, so that, I think that's what makes tax law a little bit different in the private space is that, you know, you do have your law firms, your big law firms, your boutique law firms, your midsize regional law firms, but, you know, big four accounting firms tend to be the majority of placements we have out of the LLM program. And certainly the vast majority of placements for foreign, um, LLM students, because the big four are, uh, more, typically more willing to sponsor visas to work in the United States than, um, than law firms are. So, um, you know, for that reason, I think that, you know, in the private space that it, it's, it's very interesting and different because you have the, the big four accounting firms, hiring lawyers, um, to work as tax lawyers and, and tax planning.
Speaker 0 00:25:31 Um, but even in the government, you have like more interesting opportunities. You know, there's both opportunities on the planning side. Uh, like if you wanna be a planner, um, you know, there are, you could start say working at the internal revenue service ox, chief council, where there are, um, various different specialized branches that an attorney can work in. In addition to, like, if you wanna litigate, you would go work for a field office, or maybe for the department of justice. And then there are like just unique, like jobs in the tax space. Like they're like some students go work for tax publications and they, they write about tax law, or they become editors like at a, at a place like tax analysts or Bloomberg B, um, or they work kind of like quasi tax. They work in house or they work, um, you know, for a bank or another financial institution. So I would say they, the, the array of tax jobs, that's what kind of makes tax really unique, particularly in Washington DC, where you have the government, is, is that just the sheer number of different places that, that, um, a tax lawyer can work?
Speaker 1 00:26:39 What, what kind of advice or suggestions do you have for students who are thinking about doing a tax LM, or maybe they know they wanna do it, and now they're preparing to start a tax LM?
Speaker 0 00:26:52 Well, I think like my general advice to students is, is really to, to keep an open mind. I think that, um, there are so many like specialties and subspecialties within tax that a lot of students believe that they want to, or think that they should specialize early or at the LLM level in order to position themselves for, for different kinds of opportunities. But I always tell students to stay broad, like, first of all, you know, doing a tax L om, the only thing that you really need to know is that you have an interest in tax and you don't need to know anything beyond that. Um, but I, I usually tell students, you know, look, I think it's to your benefit to use the tax to really refine your interest. So, and so there, there are sort of a, I guess, a list like I always call it sort of a, um, maybe bucket list is the, is the wrong word, but <laugh>, um, a li a list of boxes that you should tick to be like a well-rounded tax lawyer.
Speaker 0 00:27:51 But beyond that, um, you know, explore your interests, like take a seminar, um, you know, write a paper, do an externship, if you can, um, take a wide variety of, of, of courses to really use the LLL M year to figure out what it is you wanna do, because there, because in tax law, there are so many, you know, specialties and sub-specialties, and as I just mentioned, there are so many different spaces where a tax lawyer can work. Um, it's, it's perfectly okay to use this year to gather information, you know, both in both in the courses that you take, but also in the, in the people that you meet to sort of really figure out what, which of these many different opportunities is, is right for that particular student.
Speaker 1 00:28:36 That, that reminds me of a, an Ellen student I once had, who was from Italy. And she told me that she was at a, a networking event or something, and a lawyer asked her, what kind of law do you wanna practice? And she wasn't sure how to answer that, because she said in Italy, there was just civil law and criminal law. So yeah, she, she had to learn a lot about all the different areas that there's so many areas to practice just within the us. It's a whole different legal culture. And I'm just realizing that within tax law, there's a whole nother universe or metaverse prep, um, of, of specialties and subspecialties that one can do. So it's not enough to just say, I wanna be a tax lawyer.
Speaker 0 00:29:16 Yeah. And even like, you know, students who want to go into international tax, it's like, well, what part of international tax do you wanna do? You know, planning for, you know, foreign entities that are coming into the us. Do you wanna focus your planning on advising us companies with multinational, you know, operations? Do you wanna work in transfer pricing? I won't even go into what transfer pricing is, cuz I don't really understand it myself, but it's um, um, the ability or, um, you know, the ability to make the correct, the price between companies that are affiliated. So that's this whole different area, um, of international tax. Um, so, you know, even within a, especially like international tax, there, there are so many different opportunities to specialize within that. Even
Speaker 1 00:30:05 Now, when you worked in tax law, you worked for a couple law firms and you also worked at Ernston young. What, what kind of tax work or what kind of cases or client work did you, did you encounter?
Speaker 0 00:30:18 Yeah, so, um, I usually describe my time. Um, you know, I described and I, and I, I will say that I actually started my career in an accounting firm. So I started at UI, um, in their mergers and acquisitions group. So, uh, mergers and acquisitions is, is, um, it's actually a lot more than just, you know, like corporate mergers. It's, it's, it's, um, a lot of different, um, a lot of different areas, but I, I focus most of my time on, uh, corporate reorganization. So, um, generally like mergers between two public companies or mergers between, you know, affiliated groups of companies. I won't get into that jargon right there, but I did a lot of, you know, tax planning for, for corporate entities. And then on the other side of my LLM, I, I found that I, when I moved over to a law firm, the thing that's different about, I think about the big four and then a law firm, whichever way you move, um, or wherever you start your career is that, um, law firms tend to have much broader practice practices.
Speaker 0 00:31:25 So when I moved over to a law firm, I wasn't just working with like corporate clients. Like I was at EY, I was working with, um, private equity clients that were doing M and a deals. I was working on hedge funds, set ups. I was working on, um, I was even doing work on financial instruments. Um, those were sort of the rage back in the mid OS, if we remember, um, kind of the exotic financial instruments that were yes. Um, that were happening before the great recession. So I wouldn't say I was completely involved in that, but I did see a little bit of that kind of work as part of like a broad, transactional, um, broad, transactional practice, and even working more with, um, partnerships and LLCs and S corporations and various types of transactions. So I, again, I would say I was, uh, kind of, you know, ended up starting specializing in corporate M and a, and then my practice kind of shifted into, uh, more of a broader, you know, transactional planning space.
Speaker 1 00:32:27 Um, do you think if you were, if you were working in the tax practice of a law firm today, do you think you might be working on crypto and taxes? Is that something that, that students, that graduates end up working on? Is that a thing? Yeah, I,
Speaker 0 00:32:40 This is like, this is something that I think that we're still trying to, um, uh, like get our heads around in the tax space because there isn't a lot of guidance out there other than, you know, crypto is considered property and every time you're supposed to, you know, every time you use crypto to like buy, say a cup of Starbucks, that's actually like a taxable transaction cuz you're, um, you're, you're selling your, like, you're you bought crypto your cryptocurrency at some price and then you're, you're exchanging it at another price. So there's actually a taxable event there. So the tax law in the crypto space is just not well developed. I think. Um, it's gonna be interesting to see like where this goes. Um, and I, I don't know which law firms are, are operating in this space, but there isn't a lot of federal tax guidance on, on the use of crypto currently.
Speaker 1 00:33:36 Oh, seems, seems like, uh, I mean, I guess that's, that's maybe some of the point of crypto I guess, is to avoid all of that, but I guess it's gotta come out somewhere and somebody somewhere is gonna wanna tax it. So
Speaker 0 00:33:47 Yeah, no, no. We're trying to wrap
Speaker 1 00:33:48 Laws around
Speaker 0 00:33:49 It first. We're trying to wrap our heads around it first and how like what it actually is for tax base. And then, you know, obviously I think that like better rules need to be developed so that, you know, again, like every single time that you have a crypto transaction, it, it shouldn't be a taxable event. Um, so there needs to be rules around that. And, but when that happens is, is, um, not something that I'm willing to predict. So,
Speaker 1 00:34:14 Um, now I, I remember when I, uh, earlier in my, in my career, a number of years ago, um, I had a brief, uh, unsuccessful stint as a legal recruiter and I would call around to, to law firms and talk to associates. And the one thing that I always remember is that I, I talk to a lot of very unhappy, um, law firm associates, you know, doing, trying to make their way through and work a little bit, pay off their student loans. But every time I talked to a tax lawyer, they always said they love their job. And when I asked them why they always said, they either said, because it's like going to work and doing puzzles, or they said, because this is what law practice, this is kind of what I always thought law practice is supposed to be like. Um, and the third response I would get is because I get to go to work every day and screw the government <laugh>. So I, I was really struck by how it was the tax law associates were that seemed to be the happiest, um, practices of law. Have you ever come across that sentiment?
Speaker 0 00:35:21 Yeah, no, I think I've, I've actually, I've, I've read studies like this and yeah. That have suggested the same thing. Um, the one thing I found when I was in tax law, and this is in no way to like, say anything bad about other areas of law, but like in tax law there isn't there aren't kind of any, um, any hours that, that like your brain can take off. Right. So, um, like for instance, if you're in a corporate group and you're drafting documents, you know, sometimes, um, you know, that's like not pardon the pun, but not as taxing on your brain or if you're, if you're a litigator and you're doing document for you, if you're a tax lawyer, you're like, you're, you're always involved. Like every single day, um, uh, uh, in the office is like, you are always involved. You're always thinking you're always solving problems. A lot of you spend a whole lot of time doing research to try to figure out, you know, what the right answer is. And sometimes there isn't a right answer. So yeah, it, it, it is solving puzzles there aren't like, you know, for better or for worse, like your brain, doesn't, it it's always at work when you're in a tax practice. Um, I felt, so that was absolutely one of the things that I enjoyed the most about my job.
Speaker 1 00:36:39 Oh, that's really nice to hear. And because when people think about tax, a lot of times their brains freeze up and they think, oh my gosh, tax, I don't even wanna think about this and it,
Speaker 0 00:36:49 I know
Speaker 1 00:36:49 Anxiety and yet it's, I mean, and you're, you're affirming that it's actually one of the areas of practice that people really seem to enjoy as lawyers, so that that's great perspective to have. Yeah. Um, well thank you so much, Alice, thank you for taking the time to join me today. This is, this has been really, um, helpful and insightful and educational.
Speaker 0 00:37:12 Yeah. It's, it's been great to, to sort of share my experience and, um, yeah, it's been, I mean, I think I've had an amazing career and, and again, I, I always tell, I always tell students, I kind of have the best job in the world, I think, because I'm able to kind of Lee into my background of, of, you know, studying tax and practicing tax. But, um, you know, doing the teaching and advising is really where, like, those are sort of the things that I love the most about, um, my current role. So I think it, it really brings in like all of the things, like all of my background, but, um, again, like day to day, I'm doing all of the things that I love. So I I'm, I'm always happy to talk about, you know, tax tax law or, or what I'm doing in particular.
Speaker 1 00:38:00 <laugh> good. That's, that's really great to hear it. Uh, and if you have any questions, comments, reactions, ideas, etcetera. We always love hearing from our listeners. You can contact us by email at Daniel, us law, essentials.com or through us law essentials, Facebook group, or LinkedIn group. Um, okay. Now Ellis, I'm gonna end with a, with a joke that I'm, it's not originally a lawyer joke. It's really an accounting joke, but I'm gonna turn it into a tax lawyer joke. Um, okay. Are you okay with this?
Speaker 0 00:38:30 Um, I am absolutely okay with this.
Speaker 1 00:38:31 Yes. Okay. I'm I'm gonna guess you've heard this one, so don't, don't stop me me, but you're free to laugh or not laugh at the end. Okay. How do you tell an introvert tax lawyer from an extrovert tax lawyer?
Speaker 0 00:38:44 Ooh, that's a good question. Um, cause I'm kinda a little bit of both. So
Speaker 1 00:38:48 Do, do you know that? Do you know the answer to this one?
Speaker 0 00:38:50 I don't, I don't, I'm I'm really curious. Cause I'm a little bit of both, so yeah.
Speaker 1 00:38:53 Okay. The extrovert tax lawyer looks at the other person's feet while they're talking <laugh> hopefully, hopefully not. I
Speaker 0 00:39:01 Mean all, yeah, those are always down. So
Speaker 1 00:39:03 All, all my, all the tax lawyers I've met have actually been very, um, interesting, engaging social people. So, uh, maybe, maybe that joke does not, does not exactly on target, but it's a fun joke to, yeah,
Speaker 0 00:39:16 I think I, I think, I think tax lawyers get, um, I mean they they're rightfully like a little bit of nerdy and is kind of like a little bit of a nerdy space, but, um, I don't know. You'd be surprised. Like if you go to a cocktail party full of tax lawyers, like what kinds of conversations come up that are not tax, so,
Speaker 1 00:39:32 Oh, okay. I'll, I'll look forward to that. You just made me a little more excited about going to a,
Speaker 0 00:39:38 One of the bar association conferences. Great place.
Speaker 1 00:39:43 I'm booking my next vacation right now. Okay. Well thank you so much Ellis and thanks to everybody for listening to the us law essentials law and language podcast and stay essential.
