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 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...

This essay argues that, if the federal government fails to act sufficiently regarding the COVID-19 budget crisis, states should consider either real property surtaxes on their wealthiest residents or partial deemed realization of the unrealized capital gains of the very wealthy

Amici write to address specific matters of tax policy and history raised by this case. In particular, amici address 1) the history and justification for water's edge combined reporting (the “water's edge method”) and 2) the history and justification for the remedial provisions that are...

Amici write to address specific matters of tax policy and history raised by this case. In particular, amici address 1) the history and justification for water's edge combined reporting (the “water's edge method”) and 2) the history and justification for the remedial provisions that are...