Throughout the twentieth century, state governments and the individuals who have led them have played a vital role in the development of American tax policy. As the political leaders of our country's quot;laboratoriesquot; of democracy, state executives have helped forge fiscal policies that...

In November 2007 the U.S. House of Representatives passed H.R. 3996, which would have added new section 710 to the code. Section 710 would treat a partner's net income from a partnership as ordinary compensation income, if certain conditions are satisfied. Section 710 was aimed at partners who...

The state corporate income tax is about to undergo its most serious re-examination in over 50 years. The National Conference of Commissioners on Uniform State Laws has initiated a review of the Uniform Division of Income for Tax Purposes Act (UDITPA), which either has been adopted by most states...

Prior research indicates that audit and tax professionals' judgments are influenced by their client's preferences, both directly and indirectly (via information search). In an experiment with tax professionals as participants, we examine whether high practice risk (i.e., exposure to monetary and...

Studies in the theory of the firm help explain partnership attributes and the relationships partners have with each other, which in turn inform the analysis of partnership tax allocation rules. Those studies suggest that partners apportion partnership economic items (such as income and loss) to...

This paper develops an analytical model that describes how to construct a hedging portfolio that takes into account the adverse tax treatment of derivative securities so that a position is fully hedged on an after-tax basis regardless of the tax treatment. A pre-tax hedge, under the presumption...

Originally published in The Tax Lawyer, this article provides a comprehensive review of existing corporate tax integration literature (e.g. economic journals, NBER working papers, Treasury and ALI Reports, law reviews, and other academic literature). It also explores partial integration under...

The intersection of buffalo law and taxation hasn't been a busy one, but accidents still happen: not everyone understands that buffalo have the right of way. This article critically analyzes the recent Tax Court summary opinion in Wheir v. Commissioner, which involved a bodybuilder who sought to...

Tax-exempt organizations are subject to the Unrelated Business Income Tax on the profits of business activities unrelated to their exempt mission. This study extends recent research on the expense allocations of charitable nonprofit organizations by examining a group of non-charitable...

Samuel Zell's acquisition of the Chicago Tribune Company (the Tribune) in December 2007 using a little-known type of Employee Stock Ownership Plan (ESOP) made headlines. In a complicated transaction, which took nearly a year to complete, the Tribune converted from a subchapter C corporation to a...