This article maintains that the U.S. Tax Court’s decision in Toulouse — that U.S. tax treaties with France and Italy do not provide a treaty-based foreign tax credit against the net investment income tax — is mistaken

Using a nationwide restaurant sample, we document that minority-owned businesses are more likely to apply to the Paycheck Protection Program through fintech than traditional lenders. We motivate our analysis by a two-sided matching model where this phenomenon can be generated through "technology...

New technology promises to expand the supply of financial services to small businesses poorly served by the banking system. Does it succeed? We study the response of FinTech to financial services demand created by the introduction of the Paycheck Protection Program (PPP). We find that FinTech is...

Prudent credit risk management within a bank requires that a number of agents within the firm communicate, agree and act in a concerted fashion to manage credit risk both at the individual exposure level and at the broader portfolio level. This can be challenging given the nature of credit...

A recent chief counsel memorandum held that U.S. - source interest income of a foreign corporation is income effectively connected with that corporation's lending business. This article evaluates the analysis of the memorandum and concludes that its position is incorrect under current law