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...

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 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...

The 2017 tax legislation brought sweeping changes to the rules for taxing individuals and business, the deductibility of state and local taxes, and the international tax regime. The complex legislation was drafted and passed through a rushed and secretive process intended to limit public comment...

Professors Reuven S. Avi-Yonah, David Gamage, Orly Mazur, Young Ran (Christine) Kim, and Darien Shanske (collectively, “Tax Law Professors”) write this amici curiae brief in support of the Appellant in COMPTROLLER OF MARYLAND v. COMCAST — the Maryland Digital Advertising Case. Many digital...

For more than seven decades, state and local governments as well as market actors have labored under an export tax regime that is inconsistent, inefficient, and inequitable. The petition for a writ of certiorari in Loudoun County, Virginia, v. Dulles Duty Free, LLC, presents the Supreme Court...

This essay analyzes the retroactivity issues that have been raised in regard to mark-to-market and other accrual income tax reforms, with a focus on New York State’s proposed Billionaire Mark-to-Market Tax Act

Amici are individual law professors who have extensive knowledge in the development of the law of federal and state taxation. These amici offer their expertise in support of the State’s position in this case, that Engrossed Substitute Senate Bill 5096’s (“ESSB 5096’s”) tax on capital...