The 2017 tax legislation brought sweeping changes to the rules for taxing individuals and business, the deductibility of state and local taxes, and the international tax regime. The complex legislation was drafted and passed through a rushed and secretive process intended to limit public comment...

What time periods should we use in tax and other fiscal policy to evaluate people’s circumstances, and thus to determine either how they are being treated, or how they ought to be? This question is both fundamental and pervasive.Standard economic reasoning offers grounds for entirely basing...

This amicus curiae brief in Altera Corporation v. Commissioner supports the government's position and the view of the majority in a 9th Circuit opinion issued on July 24, 2018 and later withdrawn. Amici are tax law professors who conclude that the stock-based compensation cost sharing...

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

Discussion of marginal tax rates (MTRs) on low-income households often ignores the significance of income-conditioned benefits such as TANF, Food Stamps, Medicaid, and housing vouchers, and fails to account properly for the payroll tax or the possible accrual of expected Social Security...

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...

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...

Marginal rates are frequently analyzed based solely on taxes, without regard to benefit phase-outs that have exactly the same incentive and distributional effects as increasing positive taxes. This myopia reflects the notion, rooted in our current fiscal language, that "taxes" and "spending" are...

One of the main advantages of consumption taxation that its advocates, including me, have claimed is simplification. However, the extent to which simplification actually would result from a major consumption-based tax reform would depend not only on the compliance and administrative issues...