This short article briefly summarizes the chief arguments of PPL corporation and the IRS as to whether the United Kingdom's Windfall Tax qualifies for a United States foreign income tax credit under 26 U.S.C. § 901. PPL argues that the Windfall Tax is a tax on income and that PPL is therefore...

Many emerging companies' business models center on helping consumers to share assets in new ways. This “sharing economy” has already experienced tremendous growth and attracted considerable investment capital and talent. Yet, as is often the case with economic innovations, existing...

The years 2014-2015 saw a number of thoughtful and insightful articles on corporate tax. This article provides a short survey of these articles, with the goal of bringing readers' attention to articles that may be of interest but might have escaped their notice

Recent years have seen an explosion of scholarship on “personalized law.” Commentators foresee a world in which regulators armed with big data and machine learning techniques determine the optimal legal rule for every regulated party, then instantaneously disseminate their decisions via...

This amicus brief, filed with the Second Circuit Court of Appeals in Gelboim v. Bank of America (LIBOR Manipulation Litigation), primarily aims to help the Court by providing relevant background information. Many of the plaintiffs in this case are bringing antitrust claims based on defendant...

We explore Time-Phased Voting (“TPV”), an arrangement in which long-term shareholders receive more votes per share than short-term shareholders. TPV has gained prominence in recent years as a proposed remedy for perceived corporate myopia. We begin with theory, situating TPV relative to...

This document is a technical appendix containing supplemental information for the regressions that appear in Lynne L. Dallas & Jordan M. Barry, Long-Term Shareholders and Time-Phased Voting, 40 Del. J. Corp. L. 541 (2016), 'http://ssrn.com/abstract=2625926' http://ssrn.com/abstract=2625926