• An unsettled issue of immense practical and economic importance: how to tax the new “reward tokens” created in public cryptocurrency networks.• The wrong policy would drive innovation elsewhere. Fortunately, the correct policy is mandated by existing law: these new tokens – like all...

In 1992, the Treasury Department proposed a comprehensive business income tax, or CBIT, as a reform option for the taxation of business income. In Treasury's proposal, all taxes on business income (including income of sole proprietorships) would be replaced by a flat, entity-level tax. Interest...

This short paper provides a summary of a Special Report on a modified version of the comprehensive business income tax, or CBIT, scheduled to appear in Tax Notes on August 26, 2013. The Special Report advocates adoption of a CBIT similar to the one Treasury proposed in 1992. The main difference...

Datafied business models avoid traditional taxation in many respects since data, being among the important value drivers of datafied business, are neither adequately priced nor accounted for in the firm’s accounts. From a tax perspective, ignoring the value of data is inconsistent with the...

Recent news reports have suggested that the Vanguard Group family of mutual funds may need to quadruple investors' fees to cover corporate income tax liabilities. Professor Reuven Avi-Yonah has estimated that Vanguard's federal tax liability for the 2007-2014 period is roughly $34.6 billion. For...

Economic substance - the concept that a transaction should actually move money around - is one of a short list of doctrines designed to back stop the tax system. It is possible, indeed, the aim of not a few tax practitioners, to create transactions that meet the requirements of the Code - the...

Recent developments - including greater taxpayer sophistication in structuring and locating international financing arrangements, increased government concerns with the role of debt in sophisticated tax avoidance techniques, and disruption by decisions of the European Court of Justice of member...

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...

New cryptocurrency staking "reward" tokens are not and should not be taxable when they are created. This article presents the basic economics of cryptocurrency staking and the applicable income tax law. It responds to counterarguments from the New York State Bar Association's Tax Section and...

Cross-border loss relief may well be the last milestone, barring total tax consolidation, in the EU market integration from a tax law perspective. As the Commission's Communication on the Tax Treatment of Losses in Cross-Border Situations demonstrates, there is yet a lot of ground to be covered...