The near adoption of Worldwide Combined Reporting (WWCR) in Minnesota has led to a blizzard of critical claims about WWCR from corporate tax lobbyists, the Tax Foundation, and the editorial board of the Wall Street Journal. These various groups have made a number of policy arguments that do not...

In 2016, Congress enacted a statutory Taxpayer Bill of Rights containing a list of ten rights but lacking an explicit remedy or enforcement mechanism. Are the rights listed therefore merely aspirational, or are some or all of them enforceable? It is worth noting that the statute does not say...

This is the General Report for the United States on the theme of “Surcharges and Penalties in Tax Law” for the 2015 meeting of the European Association of Tax Law Professors in Milan, Italy. The Report addresses questions relating to the treatment of civil penalties, criminal penalties and...

This white paper responds to questions asked by Senator Cassidy in regard to testimony that Professor Gamage presented to the Senate Finance Fiscal Responsibility and Economic Growth Subcommittee on April 27, 2021. The questions are on estate and wealth taxes and liquidity concerns, on concerns...

This white paper report provides Revenue, Economic, and Constitutional Analysis of the proposed California Tax on Extreme Wealth (ACA 8 & AB 310) and also a Plain-English Summary Outline of its major provisions

The Constitution requires that “direct taxes” be “apportioned”—that is, that the revenues collected from each State be in proportion to population. Based on this obscure provision, prior scholarship has debated whether unapportioned wealth tax or related accrual-income tax reforms...

Amici are individual law professors who have extensive knowledge in the development of the law of federal and state taxation. These amici offer their expertise in support of the State’s position in this case, that Engrossed Substitute Senate Bill 5096’s (“ESSB 5096’s”) tax on capital...

The “fraud triangle”—a theory of why people commit fraud—is the preeminent framework for analyzing fraud in the accounting literature. It developed out of studies of fraudsters, including inmates convicted of embezzlement. The three components of the fraud triangle are (1) an incentive...