This projected chapter addresses issues associated with automatically indexing fiscal policies, such as those in the U.S. income tax and Social Security systems. Under indexing, a statistical measure - pertaining, for example, to inflation, wage levels, life expectancy, or income inequality - is...

Should (or when should) separate governments, including sub-units in a federal system, be encouraged to engage in tax competition rather than harmonizing their tax systems? The question is akin to asking when government should be used to solve collective action problems through coercion, and...

Should (or when should) separate governments, including sub-units in a federal system, be encouraged to engage in tax competition rather than harmonizing their tax systems? The question is akin to asking when government should be used to solve collective action problems through coercion, and...

Amici file this brief to provide the Ninth Circuit with relevant background information on the basics of transfer pricing and cost-sharing agreements, and to advance four key points. First, the 2003 cost-sharing regulation at issue in this case is substantively reasonable under the...

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...

Shifting from an income tax to a consumption tax would offer major simplification advantages. Even if Congress created as many preferences and other special rules as under the existing income tax, the massive set of complications that relate to realization and to the taxation of financial...

Debate about U.S. international tax policy often emphasizes norms, such as capital export neutrality (CEN) and capital import neutrality (CIN), that relate to worldwide welfare rather than U.S. national welfare. While this focus may seem paradoxical, or at least surprisingly altruistic in a...

The United States has a huge long-term fiscal gap, perhaps with a present value of around $74 trillion. By contrast, the explicit national debt of the U.S. is only around $6 trillion. The U.S. may thus be unable to continue meeting its current spending commitments without eventually enacting...

International tax policy experts often mistakenly conflate two distinct margins: (1) the overall tax burden on outbound investment, and (2) the marginal reimbursement rate (MRR) for foreign taxes paid, which is 100 percent under a foreign tax credit system, but equals the marginal tax rate for...