- A combined practical and theoretical comparison of UK and EU corporate finance law giving unique perspectives and a forward looking approach.- Addresses key issues arising from the financial crisis, such as the scope for innovation in legal markets, as well as anticipating issues likely to be...

This document is the web appendix for Optimal Tax Policy and the Symmetries of Ignorance (June 2011). University of Pennsylvania, Institute for Law & Economic Research Paper No. 11-19; U of Penn Law School, Public Law Research Paper No. 11-21. Available at SSRN: "http://ssrn.com/abstract=1856123"...

This article considers the tax consequences of a booster's contribution to a college athletics program, using the case study of financier Robert Burton's multi-million dollar contribution to the University of Connecticut football program. This article discusses the income and gift tax issues...

As America enters the new decade, we enter a period of significant change. With the unexpected rise of the COVID-19 pandemic, many Americans are now questioning the current system and are looking for positive change. Politicians and policymakers need to seize this opportunity to protect...

While most children grow up in their families of origin with at least one of their parents, what happens when the parents die or are incapacitated? While they are alive, parents are presumed to be the legal guardians for their children, and if one dies or has had his/her parental rights...

The single-member LLC (SMLLC) is ubiquitous. Despite its ubiquity, the Internal Revenue Code (Code) does not squarely address its tax consequences nor even contemplate its existence. This article examines the tax lifecycle of an SMLLC through its formation, operation, and exit event (e.g., sale,...

Invoking allusions to Caligula and Roman tax law, the Sixth Circuit, in Summa Holdings, reversed the Tax Court and held that the Commissioner could not use the substance-over-form doctrine to prevent taxpayers from combining the tax savings effects of a domestic international sales corporation...

What are the constitutional limits on a state's power to tax a trust with no connection to the state, other than the accident that a beneficiary lives there? The Supreme Court of the United States will take up this question this term in the context of North Carolina v. Kimberley Rice Kaestner...

This article advances an exogenous-endogenous distinction for purposes of determining and calculating quid pro quos under section 170. This test holds that exogenous benefits — benefits that arise independently of, or arise outside of, the taxing authority — are properly considered quid pro...