Foreword
Nina Olson, Executive Director of the Center for Taxpayer Rights*
In 1992, when I founded The Community Tax Law Project (CTLP), the first nonacademic low-income taxpayer clinic (LITC) in the United States, I thought the idea of providing both pro bono representation to low-income taxpayers and expanding volunteer opportunities for tax lawyers and other tax professionals would slowly come to be accepted in the tax community. At the time there were only a handful of tax clinics at law and accounting schools. It seemed to me that there was a natural fit for legal aid societies and other nongovernmental aid organizations who already served the low-income population to add tax controversy work to their service offerings. I hoped that the small tax clinic movement would eventually become national in scope.
But I certainly did not predict that tax clinics would expand at such a fast clip in the US and internationally. In the US, the LITC movement received the necessary boost of grant funding authorized in the United States Congress. What resonated with members of Congress from both parties was the plain truth that unrepresented taxpayers in tax disputes are at a fundamental disadvantage and often get the wrong result simply because they do not understand or meet the complex procedural requirements the tax agency establishes. Congress also grasped that case law developed in the federal courts was skewed toward taxpayers who could afford representation; a whole swath of issues affecting low- and middle-income taxpayers never received the benefit of judicial review, or if they did make it to court, again, the processes often determined a poor outcome. In all these instances, pro bono representation was essential to maintaining both the perception and reality of a fair and just tax system.
The LITC program immediately expanded in the first year funding was available, and has sustained a strong presence throughout the US, numbering over 120 clinics covering almost every state each year. However, the expansion was not limited to the US. In 2017, Annette Morgan came to visit the US with several of her students; in the course of their meeting with me to learn about the role of the National Taxpayer Advocate and the Taxpayer Advocate Service, we discussed the LITC program. Upon her return to Australia, Annette wasted no time in gathering support for establishing a tax clinic at Curtin University, and on my next visit to Australia, she arranged for us to meet with Australia Tax Office officials to gain their support for the program. The history of the tax clinic movement in Australia is recounted elsewhere in this volume, but suffice it to say that the programs continue to grow and evolve at a very impressive pace. Interest in establishing clinics is evidenced by the high attendance at the free annual online workshop offered each year by the Center for Taxpayer Rights, as part of the International Conference on Taxpayer Rights.
It is clear that tax clinics – either as an academic clinical program or as part of a portfolio of services offered by NGOs – are here to stay. The goal today is to expand the tax clinic’s reach to other countries, even as existing clinics strengthen their support in their communities and also add systemic advocacy, impact litigation and academic research to their current offerings. That is where this book comes in.
This volume is a treasure trove of information for anyone considering establishing a tax clinic. It acknowledges at the outset that given the diverse systems of taxation adopted by different countries, tax clinics will, of necessity, vary in terms of the populations they serve and the services they offer. For example, the US pulls tens of millions of low-income taxpayers into its income tax system via refundable credits that are social benefit programs run by the tax agency. Other tax systems include a value added tax or goods and services tax that can ensnare micro and small businesses. Although each clinic will decide its focus, this book, written by experienced clinicians from different backgrounds and different countries, provides a road map for how to start a clinic, establish relationships with tax agencies, publicize the clinic services and gain the trust of the targeted clientele, and find funding (not the least of one’s concerns).
But the editors and authors do not stop at the start-up considerations. The chapters on the pedagogy of clinical education, creating a curriculum and working with students are very thoughtful. The chapters nudging us to think beyond case-by-case representation and advice to undertake high-impact litigation, or commenting on rules and regulations, or filing amicus briefs in significant procedural cases, demonstrate that clinics can have a profound impact on the lives of all taxpayers, not just their immediate clients.
I, for one, am very grateful to the editors and authors for publishing this important work. It will certainly ease the path for clinics to come and will help ensure that the tax clinic movement does indeed become an international movement. The contributors to this book have charted a path for others who want to increase access to justice in their tax systems; only good can come from that.
Nina Olson
October 2022
*Nina Olson is the Executive Director of the Center for Taxpayer Rights. She was the National Taxpayer Advocate at the US Internal Revenue Service from 2001 to 2019, where she oversaw the Low-Income Taxpayer Clinic (LITC) grant program. In 1992, she founded the first independent LITC in the US and her testimony before Congress in 1997–8 contributed to the enactment of federal funding for low income taxpayer clinics.