Nearly forty years after his untimely death, Stanley Surrey, the renowned Harvard law professor (and Treasury official), remains perhaps the most important and influential tax law scholar in American history. The recent publication of his highly illuminating memoirs offers a convenient occasion...

Both the supporters and opponents of President Bush's 2001-2003 tax cuts assert that the cuts are steps toward smaller government. That claim appears to misunderstand the notion of the size of government and rests on spending illusion - confusing the amount of the nominal dollar flows between...

Nearly twenty years after the publication of Liam Murphy’s and Thomas Nagel’s landmark book, The Myth of Ownership, it is instructive to revisit the tax base debate (concerning the relative abstract merits of income and consumption taxation) that were prominent in my own interactions with...

In recent decades, a number of fantastically successful, mainly American, multinational entities (MNEs) – led and epitomized by the “Four Horsemen,” Apple, Amazon, Facebook, and Google – have risen to global economic hyper-prominence. While their market capitalizations and profits are...

In this article, the author addresses the destination-based cash flow tax, which was recently proposed as a tax reform option in the United States, compares it to its forebears, the flat tax and the X-tax, and concludes that, although its substance has potential merit, it does not warrant...

This paper, published in Tax Notes on July 9, 2018, is the second half of a two-part paper examining and analyzing the three main international provisions in the 2017 tax act. Part 1 discussed normative frameworks for international tax policy. Part 2, contained herein, focuses on the base...

This report, which appeared in Tax Notes on September 19, 2016, and is posted here with permission, critiques the U.S. Treasury's white paper condemning recent state aid investigations by the European Commission

Thomas Piketty's widely-noted and bestselling book, Capital in the Twenty-First Century, does much to advance our empirical understanding of rising high-end wealth concentration, which is one of the central issues of our time. But its theoretical approach and policy recommendations differ...

This is a slightly revised version of a lunch talk that the author gave at the National Tax Association's 46th Annual Spring Symposium on May 12. It addresses, among other topics, why there is so little consensus regarding international tax policy, and what lessons we learn from the recent wave...

This is the slightly expanded text of a talk that the author gave on June 1, 2016, at a conference in Amsterdam that was cosponsored by NYU Law School and the Amsterdam Centre for Tax Law. The conference concerned anti-BEPS implementation in the EU, and the talk concerned the U.S. response to...