This article considers recent proposals to replace subchapters K and S with a unified passthrough system. It argues that resistance to a unified approach may pave the way for further expansion of subchapter S and discusses proposed fixes to the section 1374 tax on built-in gains. The article...

There have been a number of proposals lately to impose a new tax on securities or financial transactions, both as a revenue measure and a way of disciplining Wall Street speculation. This article argues that such a tax would be a bad idea and that it makes more sense to tax financial activities...

This article reviews the impact of the Tax Reform Act of 1986 after 25 years. While there are many ways that TRA 1986 has permanently altered the structure of federal taxation, it is hard to find ways in which it changed anything real in terms of economic growth, employment, or productivity....

Republicans frequently criticize Democrats for "class warfare" when they suggest raising taxes on the rich. But Republicans also engage in class warfare by regularly attacking the close to half of all federal income tax filers with no tax liability. They imply that this is a major source of the...

Under current law, a taxpayer may generally take a tax return position without penalty or disclosure if there is substantial authority that the position will be sustained if challenged. Taxpayers can therefore take positions that they believe are unlikely to be right, but might be. The...

The trend of the last 50 years has been to reduce taxes on the wealthy. But this article argues that the United States has come to the end of that trend. The need for additional federal revenue, and rising wealth and income inequality are fueling a change in direction. There is rising support in...

On January 24, 1963, John F. Kennedy sent a message to Congress proposing tax reduction and tax reform. On the 50th anniversary of this event, this article reviews the political hurdles to its enactment, which were much more severe than generally realized today

One reason conservatives oppose a value-added tax so strenuously it that they believe it is virtually impossible to evade. In fact, there is a growing problem of and literature related to VAT evasion. If conservatives were more aware of this, it might lessen their opposition to a VAT in the U.S