Glenn Coven

Mills E. Godwin Professor of Law

gecove|at|wm.edu

Degrees

LL.B., Columbia
B.A., Swarthmore

Areas of Specialization

Tax Law; Tax Law--Corporate; Tax Law--Income.

Teaching This Coming Year (2008-2009)

Federal Income Taxation, International Taxation

Representative Professional Activities & Achievements

Joined the faculty in 1983. Clerked for Judge Harold R. Medina of the U.S. Court of Appeals for the Second Circuit. Practiced law at Winthrop, Stimson, Putnam & Roberts in New York City, taught at the University of Tennessee School of Law and was a visiting professor at the University of San Diego, University of Florida, University of North Carolina, University of Pennsylvania and UCLA law schools.

Author of articles in the Michigan Law Review, California Law Review, the Virginia Tax Review, and Tax Law Review. Co-author of Taxation of Business Enterprises.

Director of the William and Mary Tax Conference since 1989.

Professor Coven's publications

Books

Co-author, Report of the American Bar Association Tax Section Task Force on Integration of the Corporate and Individual Tax Systems 1998 (co-chairs Robert A. Bergquist and Jennifer J.S. Brooks) (with Jack Cummings, Richard Gordon and Jennifer Brooks).
Co-author, The Taxation of Business Enterprises (West Pub. 1998) (with Robert J. Peroni & Richard Crawford Pugh).
Co-author, The Taxation of Income (Commerce Clearing House, Inc. 19th ed. 1994) (with B. B. Barton, R. W. Campfield, M. B. Dickinson, Jr., and C. H. Gustafson) .

Book Revisions and Supplements

Co-author, The Taxation of Business Enterprises (West Pub. 3d ed. 2006) (with Robert J. Peroni & Steven A. Bank).
Co-author, The Taxation of Business Enterprises (West Pub. 2d ed. 2002) (with Robert J. Peroni & Richard Crawford Pugh).

Articles

Basis Shifting -- A Radical Approach to an Intractable Problem, 105 Tax Notes 1541 (2004).
What Corporate Tax Shelters Can Teach Us About the Structure of Subchapter C, 105 Tax Notes 831 (2004).
Bad Drafting -- A Case Study of the Design and Implementation of the Income Tax Subsidies for Education, 54 Tax Law. 1 (2000).
Co-author, No HOPE (Credits) for Louisiana Coffers, 18 State Tax Notes 2173 (2000), reprinted in 88 Tax Notes 275 (2000) (with Michael B. Lang).
International Comity and the Foreign Tax Credit: Crediting Noncomforming Taxes, 4 Fla. Tax Rev. 83 (1999).
Who Should Be Entitled to Claim the New Education Credits?, 84 Tax Notes 1643 (1999), reprinted in 26 Exempt Org. Tax Rev. 383 (1999).
And the Rebuttal, 11 Va. Tax Rev. 493 (1991).
Corporate Tax Policy for the Twenty-First Century: Integration and Redeeming Social Value, 50 Wash. & Lee L. Rev. 495 (1993).
Redefining Debt: Of Indianapolis Power and Fictitious Interest, 10 Va. Tax Rev. 587 (1991).
Taxing Corporate Acquisitions: A Proposal for Mandatory Uniform Rules, 44 Tax L. Rev. 145 (1989).
Congress as Indian-Giver: "Phasing-Out" Tax Allowances Under the Internal Revenue Code of 1986, 6 Va. Tax Rev. 505 (1987).
Subchapter S Distribution and Pseudo Distributions: Proposals for Revising the Defective Blend of Entity and Conduit Concepts, 42 Tax L. Rev. 381 (1987).
Limiting Losses Attributable to Nonrecourse Debt: A Defense of the Traditional System Against the At-Risk Concept, 74 Cal. L. Rev. 41 (1986).
Making the Subchapter S Work, 32 Tax Notes 271 (1986).
Co-author, The Subchapter S Revision Act of 1982 -- An Analysis and Appraisal, 50 Tenn. L. Rev. 569 (1983) (with Hess).
The Relevance of Fresh Investment to the Characterization of Corporate Distributions and Adjustments, 38 Tax L. Rev. 419 (1983).
The Decline and Fall of Taxable Income, 79 Mich. L. Rev. 1525 (1981).
The Alternative Minimum Tax: Proving Again that Two Wrongs Do Not Make a Right, 68 Cal. L. Rev. 1093 (1980).
Liabilities in Excess of Basis: Focht, Section 357(c)(3) and the Assignment of Income, 58 Or. L. Rev. 61 (1979).
Affinity Provisions of the Internal Revenue Code: A Case Study in Nonsimplification, 45 Tenn. L. Rev. 557 (1978).
Work Product Exception to Discovery -- The New York Experience, 53 Cornell L. Rev. 98 (1967).

Other

Interpreting Tax Legislation in the 90s, 17 Taxation Newsletter, Point and Counterpoint (ABA), Spring 1998, at 11.
Letter, 38 Tax Notes 517 (1998).

Resources