Content Posted in 2023
A Case for Simpler GainBifurcation for Real Estate Developers, Bradley T. Borden, Nathan R. Brown, and E. John Wagner II
Accelerating Depreciation in Recession, Rebecca N. Morrow
Accommodating the "Low-Income" in a Cash-Flow or Consumed Income Tax World, George K. Yin
Accretion-Based Progressive Wealth Taxation, David Hasen
A Conceptual Framework for Capital Gain, Calvin H. Johnson
A Consumed Income World—The Low Income and Prospects for Simplification—Replies to Professors Fleming and Yin, Charles O. Galvin
Agency Activism as a New Way of Life: Administrative Modification of the Internal Revenue Code Through Limited Issue Focused Examinations, W. Edward Afield
A Hitchhicker's Guide to the OECD's International VAT/GST Guidelines, Walter Hellerstein
A Hitchhiker's Guide to Comparative Tax Scholarship, Kim Brooks
Allocating Business Profits for Tax Purposes: A Proposal to Adopt a Formulary Profit Split, Reuven S. Avi-Yonah, Kimberly A. Clausing, and Michael C. Durst
A Logic for Statutes, Sarah B. Lawsky
Anatomy of a Disaster Under the Internal Revenue Code, Francine J. Lipman
An Empirical Study of Innocent Spouse Relief: Do Courts Implement Congress's Legislative Intent?, Stephanie Hunter McMahon
An Equity-Based, Multilateral Approach for Sourcing Income Among Nations, Fred B. Brown
A New Model for Identifying Basis in Life Insurance Policies: Implementation and Deference, Mitchell M. Gans and Jay A. Soled
A New Paradigm for IRS Guidance: Ensuring Input and Enhancing Participation, Leslie Book
A Note on Horizontal Equity, Louis Kaplow
Another Uneasy Compromise: The Treatment of Hedging in a Realization Income Tax, Deborah L. Paul
An Overview Concerning Certain Recent Changes for Foreign Compensatory Trusts: 402(b)Trusts, Grantor Trusts and "Rabbi" Trusts, Steven W. Rabitz
(Anti)Poverty Measures Exposed, Francine J. Lipman
Applying Sustainability to Tax, Karie Davis-Nozemack and Kathryn Kisska-Schulze
Apportioning State Personal Income Taxes to Eliminate the Double Taxation of Dual Residents: Thoughts Provoked by the Proposed Minnesota Snowbird Tax, Edward A. Zelinsky
A Proposal for an Elective Benefits Transfer System, Ronald W. Blasi
A Proposal for Taking the Complexities Out of Taxing U.S. Retirement Distributions to Foreign Nationals, Cynthia Blum and Paula N. Singer
Assumption of Contingent Liabilities on Sale of a Business, Daniel Halperin
A Structural Critique of Trader Taxation, Shu-Yi Oei
A Tax Morale Approach to Compliance: Recommendations for the IRS, Marjorie E. Kornhauser
A Tax Professor's Guide to Formitive Assessment, Heather M. Field
Avoiding Phantom Income in Bankruptcy: A Proposal for Reform, Gregory L. Germain
Background and Implications of China's E-CNY, Jiaying Jiang and Karman Lucero
Back to the Future Interest: The Origin and Questionable Legal Basis of the Use of Crummey Withdrawal Powers to Obtain the Federal Gift Tax Annual Exclusion, Bradley E.S. Fogel
Bankruptcy & the Benefit Corporation, Christopher D. Hampson
Baseball Arbitration to Resolve International Law Disputes: Hit or Miss?, Joost Pauwelyn
Believing in Life After Loving: IRS Regulation of Tax Preparers, Alex H. Levy
Bespoke, Tailored, and Off-the-Rack Bankruptcy: A Response to Professor Coordes's 'Bespoke Bankruptcy', Christopher D. Hampson
Beyond Frustration: Section 162(f) and the Deductibility of Fines, Penaties, and Settlement Payments, Abraham N.M. Shashy Jr., Sara A. Silverstein, and Ariana F. Wallizada
Big Haven and Tax Haven Secrecy, Arthur J. Cockfield
Binding Constitutional History: Reverse Pollock and End Fatal Apportionment, Calvin H. Johnson
Biometrics: Solving the Regressivity of VATs and RSTs With "Smart Card" Technology, Richard Thompson Ainsworth
Bitcoin and the Definition of Foreign Currency, Adam Chodorow
Black Lives Matter in Criminology? Let's Prove It, Katheryn Russell-Brown
Blockchain Havens and the Need for Their Internationally-Coordinated Regulation, Omri Marian
Blum and Kalven at 50: Progressive Taxation, "Globalization," and the New Millenium, Michael A. Livingston
Book Review: International Tax Policy: Between Competition and Cooperation, Yariv Brauner
Book Review: Tax Credits for the Working Poor: A Call for Reform by Michelle Lyon Drumbl, Kerry A. Ryan
Book Tax Conformity for Financial Instruments, Yoram Keinan
Built-in Gaine and Biuilt-in Loss Property on Formation of a Partnership: An Exploration of the Grand Elegance of Partnership Capital Accounts, Daniel L. Simmons
Call for the Gradual Phase-Out of All Paper Tax Information Statements, Jay A. Soled
Can Anyone Be Trusted to Enforce National Treatment Disciplines With Respect to Tax Measures?, Patricia A. Brown
Can Audits Encourage Tax Evasion?: An Experimental Assessment, Emily Satterthwaite
Can We Clean This Up? A Brief Journey Through the United States Rules for Taxing Business Entities, Willard B. Taylor
Capital, an Elusive Tax Object and Impediment to Sustainable Taxation, Henry Ordower
Capital Equipment Expensing: Incremental Tax Reform for a Transition Realization-Based Income Tax, Charles T. Terry
Carbon Tax Shifts and the Revenue-Neutrality Dilemma, Rory Gillis
Charities and the Constitution: Evaluating the Role of Constitutional Principles in Determining the Scope of Tax Law's Public Policy Limitation for Charities, David A. Brennen
Charity in the 21st Century: Trending Toward Decay, Roger Colinvaux
Citizenship Taxation, Globalization and Inequality, Robert T. Kudrle
Citizens United, Tax Policy, and Corporate Governance, Michael A. Behrens
Cloudy with a Chance of Taxation, Rifat Azam and Orly Mazur
Commentary on Return Preparer Obligations, Michael B. Lang
Comments on the OECD Proposal for Secret and Mandatory Arbitration of International Tax Disputes, Michael J. McIntyre
Committee Opinions and Treasury Regulation: Tax Lawyer Ethics, 1965-1985, Michael Hatfield
Common Markets, Common Tax Problems, Ruth Mason
Compensatory and Punitive Damages for a Personal Injury: To Tax or Not to Tax, Douglas A. Kahn
Concentrated Enforcement, Leigh Osofsky
Congress Fiddles While Middle America Burns: Amending the Amt (and Regular Tax), Linda M. Beale
Congressional Unilateral Tax Treaty Overrides: The "Latter in Time Doctrine" is Out of Time!, Mark J. Wolff
Conservation Easements and the Valuation Conundrum, Nancy A. McLaughlin
Considering "Citizenship Taxation": In Defense of FATCA, Young Ran (Christine) Kim
Consolidating Foreign Affiliates, Jasper L. Cummings Jr.
Contengencies and the Estate Tax, Wendy C. Gerzog
Contribution and Distribution Flexibility and Tax Pass-Through Entities, Brett Freudenberg and Bradley T. Borden
Corporate Expatriation: A Case Analysis, Steven H. Goldman
Cosmopolitan Rights, Global Tax Justice, and the Morality of Cooperation, Carlo Garbarino
COVID Aftermath: The Impact of the Pandemic on Florida's Public School Students, Hannah Blount, Michael Figg, Autumn Finke, Christina Gilbert, Mackenzie O'Connell, Nyasia Minaya, Kylee Neeranjan, and Alyssa Rodriguez
Creating Complex Monsters: Joint Operating Agreements and the Logical Invalidity of Treasury Regulation 1.502-1(b), Darryll K. Jones
Crisis-Driven Tax Law: The Case of Section 382, Albert H. Choi, Quinn Curtis, and Andrew T. Hayashi
Dark Money Darker? IRS Shutters Collection of Donor Data, Philip Hackney
Dead Infants and Taking the Fifth, Tracey Maclin
Dedication to James J. Freeland, Jeffrey E. Lewis, Guy B. Maxfield, M. Carr Ferguson, and Stephen A. Lind
Defining Income, Alice G. Abreu and Richard K. Greenstein
Delaware Law for Non-Corporate Entities: A Commentary, Peter Molk
Democracy Avoidance in Tax Lawmaking, Clinton G. Wallace
Demystifying LIFO: Towards Simplification of Inflation-Adjusted Inventory Valuation, Edward A. Morse
Designing a 21st Century Corporate Tax—An Advance U.S. Minimum Tax on Foreign Income and Other Measures to Protect the Base, Stephen E. Shay, J. Clifton Fleming Jr., and Robert J. Peroni
Designing a U.S. Exemption System for Foreign Income When the Treasury is Empty, J. Clifton Fleming Jr., Robert J. Peroni, and Stephen E. Shay
Designing Aviation Taxes Within the EU—Chartering Ongoing Challenges and Proposing Future Solutions, Yvette Lind
Designing Nonrecognition Rules Under the Internal Revenue Code, Fred B. Brown
Designing the Tax Treatment of Litigation-Related Costs, Sachin S. Pandya and Stephen Utz
Diminished Criminal Responsibility: A Multinational Comparative Review, Lea Johnston, Kendall D. Runyan, Fernando José Silva, and Franscisco Maldonado Fuentes
Discretion and Deterrence in Tax Sentencing After Rita, Gall and Kimbrough—Opportunities for Alternative Sentences and Potential Abuses, Marla Schwaller Carew
Do GILTI + BEAT + BMT = GloBE?, Mindy Herzfeld
Don't Blame it in WTO Law: An Analysis of the Alleged WTO Law Incompatibility of Destination-Based Taxes, Alice Pirlot
Duplicative Taxation Among the States: A Problem Not Worth Solving?, Julie Roin
Economic Analysis of Tax Law from a Sustainability Perspective, Ute Schmiel
Economics & Economic Substance, Terrance O'Reilly
Economic Substance Doctrine: How Codification Changes Decided Cases, Bret Wells
Education Has Been "Dumbed Down" in Tax Reform, Melanie McCoskey and Doron Narotzki
EITC as Income (In)Stability?, Kerry A. Ryan
Endowment Taxation and Equality of Resources, Erick J. Sam
Equity and the Article I Court: Is the Tax Court’s Exercise of Equitable Powers Constitutional?, Leandra Lederman
Equity in the Distribution of Tax Preferences for Pensions: Capping the Amount Allowable in Tax-Preferenced Retirement Plans, Norman P. Stein and John A. Turner
Estate and Gift Tax Effects of Selling a Remainder: Having D'Ambrosio, Wheeler and Magnin Changed the Rules?, Ronald H. Jensen
Everything You Always Wanted to Know About Farid But Were Afraid to Ask, Linda Galler
Everything You Want: The Paradox of Customized Intellectual Property Regimes, Derek E. Bambauer
Exclusion from Income of Compensation for Services and Pooling of Labor Occuring in a Noncommercial Setting, Douglas A. Kahn
Executive Pay Clawbacks and Their Taxation, David I. Walker
Expanding the Frame: Using Masculinities Analyses to Challenge Gender and Race Hierarchy, Nancy Dowd
Exploiting the Medicare Tax Loophole, Karen C. Burke
Extinguishing and Amending Tax-Deductible Conservation Easements: Protecting the Federal Investment After Carpenter, Simmons, and Kaufman, Nancy A. McLaughlin
Fair and Sustainable Taxation—From a European Horizon, Åsa Gunnarsson
Fairness in International Taxation: The Ability-to-Pay Case for Taxing Worldwide Income, J. Clifton Fleming Jr., Robert J. Peroni, and Stephen E. Shay
Family Limited Partnerships: Discounts, Options, and Disappearing Value, Karen C. Burke and Grayson M.P. McCouch
FATCA, CRS, and the Wrong Choice of Who to Regulate, Noam Noked
Florida's Baker Act Laws: How Florida's Excessive Use of Baker Acts Can Be Harmful to Children, Kaitlin Gibbs
Focus on the Facts, Shay Menuchin
Foreign Law in U.S. International Taxation: The Search for Standards, Philip R. West
Forking Belief in Cryptocurrency: A Tax Non-Realization Event, David G. Chamberlain
Fostering Faith: Religion in the History of Family Policing, Elizabeth D. Katz
Full Taxation: The Single Tax Emperor's New Clothes, Leopoldo Parada
Ghosts of 1932: The Lost History of Estate and Gift Taxation, Jeffrey A. Cooper
Giving Credit Where Credits Are (Arguably) Due: A Half Century's Evolution in the Design of Personal Tax Expenditures, Lawrence Zelenak
GoTaxMe: Crowdfunding and Gifts, Jeffrey Kahn
Guaranteed Payments Made In Kind By A Partnership, Douglas A. Kahn and Faith Cuenin
Harper and its Aftermath, Eric Rakowski
Hidden Foreign Aid, David E. Pozen
Hidden in Plain Sight: IRS Publications and a New Path to Tax Reform, Andrea Monroe
Horizontal and Vertical Equity in Taxation as Constitutional Principles: Germany and the United States Contrasted, Henry Ordower
Horizontal and Vertical Equity: The Musgrave/Kaplow Exchange, Paul R. McDaniel and James R. Repetti
Horizontal Equity: A Further Note, Richard A. Musgrave
Horizontal Equity Revisited, James Repetti and Diane Ring
How to Think About How the US Congress Thinks About International Tax Reforms, Mindy Herzfeld
Implications of Denmark's Water Price Reform for Reverine and Coastal Surface Water Quality, Massimo Pizzol, Maria Molinos-Senante, Hans Thodsen, and Mikael Skou Andersen
Improving the Resolution if International Tax Disputes, Hugh J. Ault
In Defense of College Savings Plans: Using 529 Plans to Increase the Impact of Direct Federal Grants for Higher Education to Low- and Moderate-Income Students, Caroline Waldner
In Lieu of GILTI: Excessive Unrepatriated Earnings, Christine A. Davis
International Comity and the Foreign Tax Credit: Crediting Nonconforming Taxes, Glenn E. Coven
International Corporate Income Tax Reform: Issues and Proposals, Jane G. Gravelle
International Tax Reform by Means of Corporate Integration, Bret Wells
Interpreting Tax Legislation: The Role of Purpose, Deborah A. Geier
Interpreting the Interpreters: Assessing Forty-Five Years of Tax Literature, David M. Schneider
Introduction: A Tribute to Michael K. Friel, Yariv Brauner
Investment Income Withholding in the United States and Germany, Lily Kahng
Inviting Everyone to the ACA (Risk) Pool Party: Using Advanceable, Income-Based Tax Credits to Subsidize Purchases, Mary Leto Pareja
IRC §§ 7431 and 7433: Civil Remedies for Abusive Practices by the IRS, R. Tracy Sprouls
Is Argentina Ready for the New International Tax Era?, Axel A. Verstraeten
Is the Nation of Immigrants Punishing Its Emmigrants: A Critical Review of the Expatriation Rules Revised by the American Jobs Creation Act of 2004, Eva Farkas-DiNardo
Is the Report of Lazarus's Death Premature? A Reply to Cameron and Postlewaite, Douglas A. Kahn
It Does Not Compute: Copyright Restriction on Tax Deduction for Developer’s Donation of Software, William A. Drennan
It's Not a Rule: A Better Way to Understand the Definition of Income, Alice G. Abreu and Richard K. Greenstein
Joint Winners, Separate Losers: Proposals to Ease the Sting for Married Taxpayers Filing Separately, Michelle Lyon Drumbl
Jumping the Shark: The Case for Repealing the TEFRA Partnership Audit Rules, Peter A. Prescott
Just Enough: Substantial Performance, Ministerial Acts and the All Events Tests for Income and Expense Accruals, Glenn Walberg
Justice Delayed: Government Officials' Authority to Wind Down Constitutional Violations, Neil H. Buchanan and Michael C. Dorf
Leaving Money on the Table(s): An Examination of Federal Income Tax Policy Towards Indian Tribes, Mark J. Cowan
Legal and Clinical Issues Regarding the Pro Se Defendant: Guidance for Practitioners and Policy Makers, Christina L. Patton, Lea Johnston, Colleen M. Lillard, and Michael J. Vitacco
Legal Ethics and Federal Taxes, 1945-1965: Patriotism, Duties, and Advice, Michael Hatfield
Lifting the Shroud Obscuring Estate of Hubert: The Logic of the Income and Estate Tax Treatment of Estate Administration Expenses, Joseph M. Dodge
Lingering Partnership Classification Issues (Just When You Thought It Was Safe to Go Back Into the Water), William B. Brannan
Litigation Expenses and the Alternative Minimum Tax, Brant J. Hellwig and Gregg D. Polsky
Lost in Translation: Excess Returns and the Search for Substantial Activities, Lilian V. Faulhaber
Maaser Kesafim and the Development of Tax Law, Adam S. Chodorow
Main Tax Policy Matters for Establishing Chile as a Regional Operative Investment Hub, Hugo Hurtado and Jaime Del Valle
Making Tax Policy Great Again: America, You've Been Trumped, Phyllis C. Taite
Making the Internal Revenue Service Work, Jonathan Barry Forman and Roberta F. Mann
Mandatory Arbitration of International Tax Disputes: A Solution in Search of a Problem, Ehab Farah
Many Unhappy Returns: The Need for Increased Tax Penalties for Identity Theft-Based Refund Fraud, Pippa Browde
Mayday—Brexit, Bertil Wiman
Measuring the Effect of Social Background on Judicial Decision-Making in Tax Cases, Orli Oren-Kolbinger
Migrants with Retirement Plans: The Challenge of Harmonizing Tax Rules, Cynthia Blum
Mixing Management Fee Waivers with Mayo, Amandeep S. Grewal
More on Accounting for the Assumption of Contingent Liabilities on the Sale of a Business, Charlotte Crane
Mufled Chevron: Judicial Review of Tax Regulations, Ellen P. Aprill
Murphy and the Sixteenth Amendment in Relation to the Taxation of Non-Excludable Personal Injury Awards, Joseph M. Dodge
Neutral International Tax Rules Allocating Costs: Successful Formula for U.S. Research and Development, Karen B. Brown
Normative Capital Cost Recovery for a Realization-based Income Tax, Charles T. Terry
One Flesh, Two Taxpayers: A New Approach to Marriage and Wealth Transfer, Bridget J. Crawford
On the Fragility of the International Taxation Legal System, Monica Victor
Optional Basis Adjustments Under Subchapter K: Trap for the Unwary, Tax Planning Tool, or Both? Should they be Mandatory?, Philip F. Postlewaite
Partnership Distributions: Options for Reform, Karen C. Burke
Partnership Securities, Simon Friedman
Partnership Special Allocations Revisited, David Hasen
Perspectives on Social Security Reform, Karen C. Burke and Grayson M. P. McCouch
Poor Support/Rich Support: (Re)Viewing the American Social Welfare State, Wendy A. Bach
Practical Aspects of Implementing Formulary Apportionment in the European Union, Joann Martens Weiner
Privacy Implications of Central Bank Digital Currency, Jiaying Jiang
Provisions Denying a Deduction for Illegal Expenses and Expenses of an Illegal Business Should be Repealed, Douglas A. Kahn and Howard Bromberg
Reasonable Tax Rules: Advancing Process Values with Remedial Restraint, James M. Puckett
Reassessing Sales and Liquidations of Partnership Interests After the Omnibus Budget Reconciliation Act of 1993, James E. Tierney
Recent Developments in Federal Income Taxation: The Year 2000, Ira B. Shepard and Martin J. McMahon Jr.
Recent Developments in Federal Income Taxation: The Year 2001, Ira B. Shepard and Martin J. McMahon Jr.
Recent Developments in Federal Income Taxation: The Year 2002, Ira B. Shepard and Martin J. McMahon Jr.
Recent Developments in Federal Income Taxation: The Year 2003, Ira B. Shepard and Martin J. McMahon Jr.
Recent Developments in Federal Income Taxation: The Year 2004, Ira B. Shepard and Martin J. McMahon Jr.
Recent Developments in Federal Income Taxation: The Year 2005, Ira B. Shepard and Martin J. McMahon Jr.
Recent Developments in Federal Income Taxation: The Year 2006, Ira B. Shepard and Martin J. McMahon Jr.
Recent Developments in Federal Income Taxation: The Year 2007, Martin J. McMahon Jr., Ira B. Shepard, and Daniel L. Simmons
Recent Developments in Federal Income Taxation: The Year 2008, Martin J. McMahon Jr., Ira B. Shepard, and Daniel L. Simmons
Recent Developments in Federal Income Taxation: The Year 2009, Martin J. McMahon Jr., Ira B. Shepard, and Daniel L. Simmons
Recent Developments in Federal Income Taxation: The Year 2010, Martin J. McMahon Jr., Ira B. Shepard, and Daniel L. Simmons
Recent Developments in Federal Income Taxation: The Year 2011, Martin J. McMahon Jr., Ira B. Shepard, and Daniel L. Simmons
Recent Developments in Federal Income Taxation: The Year 2012, Martin J. McMahon Jr., Ira B. Shepard, and Daniel L. Simmons
Recent Developments in Federal Income Taxation: The Year 2013, Martin J. McMahon Jr., Ira B. Shepard, and Daniel L. Simmons
Recent Developments in Federal Income Taxation: The Year 2014, Martin J. McMahon Jr., Bruce A. McGovern, and Ira B. Shepard
Recent Developments in Federal Income Taxation: The Year 2015, Martin J, McMahon Jr. and Bruce A. McGovern
Recent Developments in Federal Income Taxation: The Year 2016, Martin J. McMahon Jr. and Bruce A. McGovern
Redefining a Blurry Line: A Proposal to Reform the Taxation of Pension Fund Business and Investment Income, Jesse Boretsky
Reforming the Charitable Contribution Substantiation Rules, Ellen P. Aprill
Regulation and Dishonest Behavior: How Controlling Regulatory Mechanisms Prompt Dishonesty in Tax Consulting, Ilanit Gavious, Yaron Lahav, and Hagit Weihs
Relighting the Charitable Deduction: A Proposed Public Benefit Exception, Kristin Balding Gutting
Resolving the Conflicts of Citizenship Taxation: Two Proposals, Grace Nielsen
Rethinking Section 2702, Grayson M. P. McCouch
Rethinking the Risk of Defined Contribution Plans, Regina T. Jefferson
Rethinking the Tax-Revenue Effect of REIT Taxation, Bradley T. Borden
Revisiting Federal Tax Treatment of States, Political Subdivisions, and Their Affiliates, Ellen P. Aprill
Revisiting Section 367(d): How Treasury Took the Bite Out of Section 367(d) and What Should Be Done About It, Bret Wells
Revisiting the Tax Treatment of Citizens Abroad: Reconciling Principle and Practice, Michael S. Kirsch
Rewarding Honest Taxpayers: An Experimental Assessment, Emily A. Satterthwaite
Saving the Planet by Cutting Corporate Taxes: A Comparative Case Study Analysis, Roberta Mann, Fiona Martin, and Bill Butcher
Schneer v. Commissioner: Continuing Confusion Over the Assignment of Income Doctrine and Personal Service Income, Ronald H. Jensen
Scoping Out the Uncertain Simplification (Complication?) Effects of VATs, BATs and Consumed Income Taxes, J. Clifton Fleming Jr.
Selected Issues in the Taxation of Swaps, Structured Finance, and Other Financial Products, Lewis R. Steinberg
Serenity Now! The (Not So) Inclusive Framework and the Multilateral Instrument, Yariv Brauner
Sham on You: Too Good to Be True, Mitchell L. Engler
Sharing Bank Deposit Information With Other Countries: Should Tax Compliance or Privacy Claims Prevail?, Cynthia Blum
Should We Give Away the Annual Exclusion?, Robert B. Smith
Simplification and IRC § 415, Norman P. Stein
Slouching Towards a Consumption Tax and the End of Retirement Income Security, Norman Stein
Source as a Solution to Residence, Adam H. Rosenzweig
Stabilizing "Pillar One": Corporate Profit Reallocation in an Uncertain Environment, Itai Grinberg
Stanley Surrey, the Code and the Regime, Reuven Avi-Yonah and Nir Fishbien
Startup Ltd.: Tax Planning and Initial Incorporation Location, Susan C. Morse
State Bans on Debtors' Prisons and Criminal Justice Debt, Christopher D. Hampson
Stateless Income, Edward D. Kleinbard
Structural Impediments to Tax Reform: The Environment as Case Study, Leo P. Martinez
Sunshine and Shadows on Charity Governance: Public Disclosure as a Regulatory Tool, Evelyn Brody
Superfluous Judicial Activism: The Takings Gloss, Michael Allan Wolf
Suppose FIRPTA Was Repealed, Willard B. Taylor
Sustainable Tax Policy Through the Lens of Intergenerational Justice, Neil H. Buchanan
Taking Tax Due Process Seriously: The Give and Take of State Taxation, Hayes R. Holderness
Targetting Risk Lovers? Taxation of Private Pension Savings, Risk Preferences, and Gender, Bo Larsson and Jenny Säve-Söderbergh
Tax Abuse According to Whom?, Shannon Weeks McCormack
Tax Amnesty: An Old Debate as Viewed from Current Public Choices, Gerald P. Moran
Tax and Cross-Collateralized Nonrecourse Liability, Douglas A. Kahn and Jeffrey H. Kahn
Tax Aspects of REMIC Residual Interests, Kirk Van Brunt
Taxation and the Cross-Border Trade in Services: Rethinking Non-Discrimination Obligations, Catherine A. Brown
Taxation in Support of Equality: The Swedish RUT Deduction and the Circular Economy, Cristina Trenta
Taxation of Electronic Commerce: Federal Income Tax Issues in the Establishment of a Software Operation in a Tax Haven, David R. Tillinghast
Taxation of Private Business Firms: Imagining a Future Without Subchapter K, Lawrence Lokken
Tax Base Erosion: Reformation of Section 482's Arm's Length Standard, Bret Wells and Cym Lowell
Tax Compliance as a Wicked System, J. T. Manhire
Tax Consequences of Assigning Life Insurance—Time for Another Look, Douglas A. Kahn and Lawrence W. Waggoner
Tax Consequences When a New Employer Bears the Cost of the Employee's Terminating a Prior Employment Relationship, Douglas A. Kahn and Jeffrey H. Kahn
Tax Discrimination: A Comparative Analysis of U.S. and EU Approaches, Tracy A. Kaye
Tax-Exempt Hospitals and the Community Benefit Standard: A Flawed Standard and a Way Forward, Mark C. Westenberger
Tax Fairness by Convention: A Defense of Horizontal Equity, Ira K. Lindsay
Taxing Anxiety, Morgan L. Holcomb
Taxing Book Profits: New Proposals and 40 Years of Critiques, Mindy Herzfeld
Taxing Cross-Border Services: Two LATAM Experiences and a Couple of Conclusions for the (Developing) World, Andrés Báez Moreno
Taxing Income Where Value is Created, Allison Christians and Laurens van Apeldoorn
Taxing Interstate Remote Workers After New Hampshire v. Massachusetts: The Current Status of the Debate, Edward Zelinsky
Taxing Litigation: Federal Tax Concerns of Personal Injury Plaintiffs and Their Lawyers, Gregg D. Polsky
Taxing Losers, Eric D. Chason
Taxing Middle Class Trust(s), Pamela Champine
Taxing Social Impact Bonds, Orly Mazur
Taxing the Business of Sports, Robert Holo and Jonathan Talansky
Tax Lawyers, Tax Defiance, and the Ethics of Casual Conversation, Michael Hatfield
Tax My Ride: Taxing Commuters in our National Economy, Morgan L. Holcomb
Tax Neutrality and Tax Amenities, David Hasen
Taxpayers' Rights: Comparative Analysis of the United States of America and the Latin American Institute of Tax Law (ILADT), Andres E. Bazó
Teaching Algorithms and Algorithms for Teaching, Sarah B. Lawsky
Tearing Out the Income Tax by the (Grass)Roots, Lawrence Zelenak
Territorial vs. Worldwide International Tax Systems: Which is Better for the U.S.?, Paul R. McDaniel
Text, Purpose, Capacity and Albertson's: A Response to Professor Geier, Edward A. Zelinsky
The Agency Tax Costs of Mutual Funds, Danielle A. Chaim
The Appropriate Roles for Equity and Efficiency in a Progressive Individual Income Tax, James R. Repetti
The Architecture of the Country-by-Country Minimum Tax Regime Proposed by the United States, Carlo Garbarino
"The Bottom Calling the Top"—The Selling of Function (PSS) as a Business Model for Sustainability, in Need of Some Assistance from the Legislator, Olle Karlsson and Jan Kellgren
The Case Against BEPS: Lessons for Tax Coordination, Mindy Herzfeld
The Case for Residency-Based Taxation of Financial Transactions in Developing Countries, Yoram Keinan
The Coming(?) Inflation and the Income Tax: Lessons from the Past, Lessons from the Future, David Gliksberg
The Constitutionality of Taxing Compensatory Damages for Mental Distress When There Was No Accompanying Physical Injury, Douglas A. Kahn
The Constitutionality of the Taxation Consequences for Renouncing U.S. Citizenship, William Thomas Worster
The Corporate Income Tax: A Persistent Policy Challenge, Jane G. Gravelle
The Criminality of "Tax Planning", Michelle M. Kwon
The Deceptively Disparate Treament of Business and Investment Interest Expense Under a Cash-Flow Consumption Tax and a Schanz-Haig-Simons Income Tax, J. Clifton Fleming Jr.
The De-Gentrification of New Markets Tax Credits, Roger M. Groves
The De Novo Doctrine: Irrelevant to Relevancy in Civil Tax Litigation, Michael Kummer
The Devolution and Inevitable Extinction of the Continuity of Interest Doctrine, David S. Miller
The Ethics of Tax Cloning, Anthony C. Infanti
The Export Clause, Erik M. Jensen
The Fair Tax: The Personal Realization Income Tax, Joseph M. Dodge
The Fallacious Objections to the Tax Treatment of Carried Interest, Douglas A. Kahn and Jeffrey H. Kahn
The Future of Profit Splits, Debora de Souza Correa Talutto
The Future Taxation of Private Business Firms, George K. Yin
The GATT-Legality of Border Adjustments for Carbon Taxes and the Cost of Emissions Permits: A Riddle, Wrapped in a Mystery, Inside an Enigma, Charles E. McLure Jr.
The Global Market for Tax and Legal Rules, Tsilly Dagan
The Global Shadow Bank—Systemic Risk and Tax Policy Objectives: The Uncertain Case of Foreign Hedge Fund Lending to U.S. Borrowers and Transacting in U.S. Debt Securities, Julie A.D. Manasfi
The Good, the Bad, and the Ugly in Post-Drye Tax Lien Analysis, Steve R. Johnson
The Guardians of the New Internal Revenue Code, Douglas C. Michael
The Historical Origins of the Debt-Equity Distinction, Camden Hutchinson
The Illusory Promise of Economic Nexus, Adam B. Thimmesch
The Impact of the 2017 Act's Tax Rate Changes on Choice of Entity, James R. Repetti
The Internal Revenue Code and Automobiles: A Case Study of Taxpayer Noncompliance, James Alm and Jay A. Soled
The Internal Revenue Service and a Crisis of Confidence: A New Regulatory Approach for a New Era, Donald B. Tobin
The Intersection of EU State Aid and U.S. Tax Deferral: A Spectacle of Fireworks, Smoke, and Mirrors, Romero J.S. Tavares, Bret N. Bogenschneider, and Marta Pankiv
The Latin American Opposition to Mandatory Arbitration in Tax Treaties: Origins, the Calvo Doctrine, and a Reappraisal, Yariv Brauner
The Lazarus Effect: A Commentary on In-Kind Guaranteed Payments, David L. Cameron and Philip F. Postlewaite
The Making of International Tax Law: Empirical Evidence from Tax Treaties Text, Elliott Ash and Omri Marian
The Merger Puzzle, John A. Miller
The Misconstruction of the Deductions for Business and Personal Casualty Losses, Jeffrey H. Kahn
The Monetization of Business Tax Credits, Thomas W. Giegerich
The Movement to Destroy the Income Tax and the IRS: Who is Doing it and How They Are Succeeding, Diane L. Fahey
The Multitudinous Racial Harms Caused by Florida's Stop WOKE and Anti-DEI Legislation, Katheryn Russell-Brown
The Myth of Realization: Mark-to-Market Taxation of Publicly-Traded Securities, David Elkins
The New American Debtors' Prisons, Christopher D. Hampson
The New OECD Approach on Profit Allocation: A Step Forward Towards Neutral Treatment of Permanent Establishments and Subsidiaries, Irene J.J. Burgers
The Outer Limits of Realization: Weiss v. Stearn and Corporate Dilution, Jeffrey L. Kwall and Katherine K. Wilbur
The PACT Act as Indicum of the Due Process Validity of the Marketplace Fairness Act, Eric S. Smith
The Pension Protection Act of 2006: A Misguided Attack on Donor-Advised Funds and Supporting Organizations, Terry W. Knoepfle
The Problem of Abusive Related-Partner Allocations, Emily Cauble and Gregg D. Polsky
The Recharacterization of Cross-Border Interest Rate Swaps: Tax Consequences and Beyond, Bruce A. Elvin
There is No Spoon: Reconsidering the Tax Compliance Puzzle, J. T. Manhire
The Return-ReducingRipple Effects of the "Carried Interest" Tax Proposals, Heather M. Field
The Right and the Good: Taxing Rights, Value Creation, and the Rhetoric of International Taxation, David Elkins
The Right Tax at the Right Time, Edward D. Kleinbard
The Rise of Law and the Fall of Circular 230: Tax Lawyer Professional Standards, 1985–2015, Michael Hatfield
The Role and Function of Taxation for Sustainable Economic Recovery Post-Covid-19, Yvette Lind
The Roll of Offset in the Collection of Federal Taxes, Keith Fogg
The Taxation of Interest Swaps and the Financial Service Charge: Toward a Consistent Approach, Yishai Beer
The Tax Hedging Rules Revisited, Dr. Yoram Keinan
The Three Parties in the Race to the Bottom: Host Governments, Home Governments and Multinational Companies, Roseanne Altshuler and Harry Grubert
The TurboTax Defense, Rodney P. Mock and Nancy E. Shurtz
The Unruly World of Tax: A Proposal for an International Tax Cooperation Forum, H. David Rosenbloom, Noam Noked, and Mohamed S. Helal
The U.S. and Chile Tax Treaty and its Impact on Foreign Direct Investment, Hugo Hurtado
The Virtual Tax Library: A Comparison of Five Electronic Tax Research Platforms, Katherine Pratt, Jennifer Kowal, and Daniel Martin
The War Triggered by a Ten Cents Tax on Natural Resources, Alvaro Villegas Aldazosa
The Widening Gap Under the Internal Revenue Code: The Need for Renewed Progressivity, Vada Waters Lindsey
Time for a U.S.–Brazil Tax Treaty, Luis Eduardo Schoueri and Gustavo Lian Haddad
Too Much SALT? The Nuanced Impact of the State and Local Tax Deduction Cap on Pass-Through Business Taxpayers, Jeffrey H. Kahn, Miles A. Romney, and John S. Treu
Toward Income Tax Accounting Consistency: Eliminating Accrual, Depreciation, and the Existing Tax Treatment of Borrowing, Joseph M. Dodge
Trading One Danger for Another: Creating U.S. Tax Residency While Fleeing Violence at Home, Mark S. Hoose
Transparency in Private Collection of Federal Taxes, T. Keith Fogg
Treaty Override by Administrative Regulation: The Multiparty Financing Regulations, Richard L. Doernberg
Treaty Override: The False Conflict Between Whitney and Cook, H. David Rosenbloom and Fadi Shaheen
Treay-Based Nondiscrimination: Now You See It Now You Don't, Sanford H. Goldberg and Peter A. Glicklich
Tufts and the Evolution of Debt-Discharge Theory, Deborah A. Geier
UF Law Fall 2008, University of Florida Levin College of Law
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UF Law Magazine Fall 2016, University of Florida Levin College of Law
UF Law Spring 2008, University of Florida Levin College of Law
UF Law Spring 2009, University of Florida Levin College of Law
UF Law Spring 2010, University of Florida Levin College of Law
UF Law Spring 2011, University of Florida Levin College of Law
UF Law Spring 2012, University of Florida Levin College of Law
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Understanding Consolidated Returns, Martin J. McMahon Jr.
Understanding the OECD Model Tax Convention: The Lesson of History, John F. Avery Jones
Unfair Business Competition and the Tax on Income Destined for Charity: Forty-Six Years Later, Donald L. Sharpe
Use and Abuse of Section 704©, Laura Cunningham
U.S. Federal Income Taxation of U.S. Branches of Foreign Banks: Selected Issues and Perspectives, Yaron Z. Reich
U.S. Income Taxation of Cross-Border Pensions, Cynthia Blum
Utopian Visions Toward a Grand Unified Global Income Tax, Henry Ordower
Valuing Personal Consumption: Cost Versus Value and the Impact of Insurance, Daniel Halperin
Voting Rights Compared to Income Taxation and Welfare Benefits Through the Swedish Lens, Yvette Lind
Watchdogs That Failed to Bark: Standards of Tax Review After Enron, Harold S. Peckron
Watching the Watchers: Preventing I.R.S. Abuse of the Tax System, Samuel D. Brunson
What the BEPS?, Yariv Brauner
When Charity Aids Tax Shelters, Darryll K. Jones
Who's Afraid of Being WOKE? – Critical Theory as Awakening to Erascism and Other Injustices, Berta E. Hernández-Truyol
Why Atlas Hasn't Shrugged: Review Essay, Ajay K. Mehrotra
Why the Buffett=Gates Pledge Requires Limitation of the Estate Tax Charitable Deduction, Edward A. Zelinsky
Why the Optimal Long-Run Tax Rate on Capital is Zero . . . or Very High: The Missing Explanation, Chris William Sanchirico
Will U.S. Investment Go Abroad in a Territorial Tax: A Critique of the President's Advisory Panel on Tax Reform, James R. Repetti
Winner-Take-All Markets: Easing the Case for Progressive Taxation, Martin J. McMahon Jr. and Alice G. Abreu
Work Hours & Income Tax Cuts: Evidence from Federal-State Tax Interactions, Michael Simkovic and Eric J. Allen
Work Product Immunity for Attorney-Created Tax Accrual Workpapers?: The Aftermath of United States v. Textron, Henry J.J. Lischer Jr.
Wrestling Control from the UNICAP Regulations: The Irrelevance of Quality Control in Determining Capitalizable Trademark Royalties, Glenn Walberg
Zero Basis Hoax or Contingent Debt and Failure of Proof? Sorting Out the Issues in the Lessinger Case, Jasper L. Cummings Jr.