I'm just back from a whirlwind trip to Vienna (about 75 hours on the ground there), where I attended a conference, "Tax Treaties from a Legal and Economic Perspective," that was run by Michael Lang's Institute for Austrian and International Tax Law and the Vienna University of Economics and Business. I presented - or rather, in keeping with their format, Johannes Voget of Oxford ably presented - the shorter of the two extant versions of my paper on foreign tax credits. I felt it was generally well-received. Voget noted that firm heterogeneity could conceivably affect the analysis of a burden-neutral shift to deductibility, which is clearly right though I don't feel this paper is the right place to deal with it, and I was reminded again that I need to be clear about the distinction between (a) what a pure foreign tax credit does and (b) what happens in a system such as ours that, due to deferral and foreign tax credit limits, is often pretty far from being a pure foreign tax credit system. I focus on analyzing (a), as it's key to whether we should have foreign tax credits, and try to be clear on how (b) differs from (a), but perhaps this needs to be clarified just a tad more.
I almost always enjoy (and certainly did this time) these conference settings. You go to a faraway place, get to explore it for a brief time, and have all these sessions and meals over a short period with a set group, including a few people you already know, and you form these little groups that go through the adventure together. As is my practice when going to a conference in Europe, I took an overnight flight and arrived a day early. At 8 am (local time) last Thursday I hit the ground in Vienna, knowing that, despite almost no sleep on the plane, with an angry hamstring and a soon to be even angrier lower back, I needed to survive on my own and not go to sleep for the next 11 hours. After a cab to the hotel and brief recovery time, I headed out on foot to see Vienna's sites, or at least as many I could fit into the time period without wanting to tackle just yet its admittedly excellent public transit system.
When I'm walking around with other people, dating back to my childhood as the non-map-reading younger sibling, I'm pretty much clueless about directions, where anything is, etc. But generally I can function better when I have to. This time around I made it to the central landmark about 2 miles from my hotel (Stephensplatz, with a glorious medieval church), then took in a couple of Jewish museums that memorialize some of the bad things that have happened there over the centuries, had a Viennese rather than touristic lunch (finger sandwiches with herring & such), and staggered on to the city's primary art museum, the Kunsthistorisches Museum. I was able to find everything and even, eventually, navigate back to my hotel by an improvised route.
But by the time I got to the Kunsthistorisches Museum, I was so tired and sore that I really couldn't take in the Titians, Raphaels, Durers, Vermeers, etc. that it features, and indeed could do little more than sit on the comfy sofas in all of the large exhibition rooms looking at a few paintings from afar. And still only 2:30 - hours to go before the 7 pm reception that would start the conference officially. (I've found that, if you sleep before bedtime on this type of trip, your adjustment to the time zone is disastrously set back.)
Then it all changed for the better. The sun came out and the weather turned delightful, plus I found an outdoor cafe (not hard to do in Vienna) with cappuccino that happened to come with a complementary small fudge square. I felt like Harry, Ron, or Hermione being revived by Lupin's chocolates. And the sunlight was a big part of this - we're biologically tropical, after all, and it evidently helps a lot in body clock readjustment.
I spent the rest of the afternoon going to bakeries and gourmet supermarkets, both for fun and to acquire both a chocolate tart and an apple tart to bring home to my family. (Mission successful, and the tarts were still quite good when I got home on Sunday night.) Both from feeling better and from getting to see this side of Vienna, I began to like the place a lot more. It doesn't strike me as having a lot of must-see tourist sights if you've traveled elsewhere in western Europe, but it does seem very pleasant and livable, as well as frequently beautiful - a place where people like to linger in outdoor cafes, when the weather permits, and where they definitely like food.
The conference itself aimed to pioneer increased lawyer-economist dialogue, which is obviously crucial in tax policy but far less an established fact in Europe than the U.S. And it used the technique we have in the NYU Tax Policy Colloquium, of not having authors present their own papers, and of generally having economists comment on legal papers and lawyers on economist papers. The size of the group and the number of papers being presented - sometimes 5 in a single session - made it hard to succeed consistently in achieving the aims, plus the very fact that lawyer-economist dialogue is generally less far along in Europe than the U.S. inevitably meant there was occasional lack of connection (although this shows the value of the effort rather than suggesting it didn't work). I thought it was successful on the whole though perhaps the format could be tweaked a bit in future sessions.
Reflecting Vienna's location in central Europe, there were lots of attendees from countries whose tax people I really haven't met before (e.g., Poland, the Czech Republic, Slovakia, Estonia, and Khazakstan). Another interesting feature for me. Plus the dinners required traveling long distances by public transportation (bus, train, and tram) in order to get to what I think were pretty authentic, rather than just touristic, settings. Definitely fun, though I'm glad I didn't take it as far as the Canadian faction that decided to go out beer-drinking all night. (If you read this, you know who you are.)
Now it's back to NYC and NYU, not too badly jet-lagged and hoping that my back will hold out, for the 5-week sprint to the end of the semester.