In the wake of the Financial Accounting Standard Board's decision to require firms that grant employee stock options (ESOs) to treat such options as an expense, many large and sophisticated firms are switching from ESOs to restricted stock. Restricted stock - stock granted to an employee as part...

This study examines the effect of allowing qualifying individual taxpayers that do not deduct any interest expenses on their tax returns (called quot;qualified saversquot;) to partially exclude their interest, dividend, and capital gain income, subject to a maximum exclusion. Meanwhile,...

Leveraged Employee Stock Ownership Plan (quot;ESOPquot;) transactions originated in the 1950s, yet there are still unresolved valuation issues that arise from a complex set of operating expenses, financing structures and contingent claims that are unique to leveraged ESOPs. Although complex,...

The Internet has completely changed the landscape of the planet. As a result, many areas of the law are being re-thought or re-developed, while other new issues emerge that defy all remotely related regulations. Online gambling is one of those areas in which the laws have lagged behind the...

This article proposes a conceptual foundation for the field of international tax law. The article refers to this foundation as the institutional competence of nations in global economic development. A nation's institutional competence is its discretion to make decisions in pursuit of our...

Audit and tax professionals tend to make judgments consistent with their client's preference, even when that preference is aggressive. Client preference affects judgments directly and indirectly, via information search. In particular, professionals focus their search on information that supports...

It is well-known that derivatives can be structured to replicate the underlying security and therefore can be used to create an index fund. This paper shows that while perfect replication is achieved on a before-tax basis, taxes render derivatives inferior to direct investment in the index. This...

Employee share ownership (ESO) has been the subject of significant public policy debate. In these debates, ESO plans are usually said to be implemented for a variety of reasons including alignment of employer and employee interests, increased employee productivity, improved workplace harmony,...

The tax-free treatment of like-kind exchanges presents one of tax law's most compelling equity conundrums. Tax law generally does not tax property holders on the appreciation in the property's value, but it does tax gain or loss recognized by property sellers and exchangers of non-like-kind...

Originally published in The Tax Lawyer, this article provides a comprehensive review of existing corporate tax integration literature (e.g. economic journals, NBER working papers, Treasury and ALI Reports, law reviews, and other academic literature). It also explores partial integration under...