It comes as no surprise to any observant person in this country that there is a wide disparity in our federal income tax treatment of persons who have differing incomes and financial resources. But while much has been written on tax law complexity and inefficiency, little or nothing has been...

When a debtor goes bankrupt and limited assets have to be divided between competing creditors, should unpaid taxes owed to the government be paid before the debts owed to other creditors? This Article defends the notion that some tax debts should be awarded priority. Insofar as bankruptcy...

The Internal Revenue Code is riddled with features that allow U.S. taxpayers to reduce their federal tax liability by operating through tax haven companies. Some of these provisions are historic anomalies. Others are better understood as inadvertent loopholes than considered legislative grace....

Our system of federal taxes is a set of laws, enacted by Congress and signed by the President. The practice of tax law is generally the practice of law. So why are the non-lawyers the ones practicing in this field? This article examines the regulation of the practice of law, including the...

This manuscript summarizes key provisions of the so-called "Tax Cuts and Jobs Act" affecting United States individuals, small businesses, estates, and trusts. It does not cover changes made to pension and retirement accounts, provisions applicable only to certain industries, rules applicable to...

After Mack Brown resigned, the University of Texas, a school that has one of the premier football programs in the country, looked to hire a new head football coach. The school set its eyes on Charlie Strong. One roadblock was that Strong was still employed as the head football coach of the...

This paper discusses the theory and practice of tax design to achieve an efficient and equitable outcome, i.e. in support of inclusive growth. It starts with a discussion of the key principles from tax theory to guide practical tax design. Then, it elaborates on more granular tax policy,...

This paper describes the relevance to lawyers and law students of the concept of income for tax purposes and tax policy. Three reasons are given for law practitioners to have an understanding of the policies underlying tax legislation: the complexity of the legislation; the fact that it can...

U.S. Effective marginal tax rates (EMTRs) for 2018 through 2027 are calculated for the TaxCuts and Jobs Act (TCJA). These EMTRs take account of the extension and subsequent phaseout of bonus depreciation with a methodology used by Cohen, Hansen, and Hassett (2002) toestimate the user cost of...