In this essay, Gamage and Walczak share their opening statements in their debate over Quinn v. Washington, the recent Washington Supreme Court decision upholding a state tax on capital gains as an excise tax

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...

The purpose of this brief is to correct and respond to two arguments in Petitioner-Appellee Altera's petition for rehearing en banc and briefs of amici supporting the petition for rehearing. First, Treasury's regulation requiring cost sharing of stock-based compensation and the Ninth Circuit...

Wealth tax reform proposals are playing a major role in the 2020 presidential campaign. However, some opponents of these wealth tax reform proposals have claimed that a wealth tax would be unconstitutional. Other prominent critics have argued that wealth tax reforms are probably...

State governments are considering new charitable tax credits designed to circumvent the 2017 federal tax overhaul's cap on state and local tax deductions. Will these plans work? This essay argues that the answer is: yes, but with some qualifications

This report describes various tax games, roadblocks, and glitches in the tax legislation currently before Congress, titled the Tax Cuts and Jobs Act (TCJA). The complex rules proposed in the House and Senate bills will allow new tax games and planning opportunities for well-advised taxpayers,...

This essay analyzes ways that U.S. state governments can raise revenue by rethinking whether and how they conform to the Tax Cuts and Jobs Act. This essay is the first in a two-part series, with this essay focusing on strategic nonconformity with the TCJA for state-level personal income taxes,...

This essay argues that the current COVID-19 crisis is the perfect time to make revenue-raising reforms to state corporate income taxes — reforms that would have been desirable policy improvements even during an economic upturn, but that are even more clearly good policy moves in light of the...