This essay examines the extent of Surrey’s influence on developments in tax law after his death. It argues that his ideas clearly impacted the tax reform of 1986, but can even be seen in later enactments like the Tax Cuts and Jobs Act of 2017 and contemporary developments in international...

The United States faces an unsustainable fiscal deficit, which is made worse as interest rates rise and as borrowing from China becomes politically difficult. To resolve this problem either spending must be cut, or revenues need to increase; printing money is not an option, as current inflation...

Value added taxes are destination based, i.e., tax is imposed on imports and exports are zero rated (so that the exporter can receive a refund on VAT collected in previous stages of production). Income taxes, on the other hand, are typically origin based, i.e., imports are deductible and exports...

This paper comments on Alan Auerbach's "A Modern Corporate Tax" (Hamilton Project/CAP, December 2010) and argues that it is not a significant improvement over previous proposals to replace the corporate tax with a cash flow tax

The current controversy surrounding President Obama’s international tax proposals seems like an opportune moment to try to consider them in context. How do these proposals fit in with an agenda for US corporate and international tax reform? Few observers doubt that such reforms are sorely...

Congress is likely to consider domestic climate change legislation during 2009, with a cap-and-trade system continuing to draw support from the Obama Administration and many leaders in Congress. Yet cap-and-trade regulations would take years for EPA to develop and implement, the desired price...

There is a wide bipartisan consensus that the US international tax regime is broken. We have the highest corporate tax in the OECD, which at 35% imposes a real burden on corporations earning mostly US source income. At the same time, US based multinationals pay very low effective tax rates on...

In this article, the authors critically appraise the government’s proposal not to allocate research and development deductions to subpart F inclusions and global intangible low-taxed income for foreign tax credit limitation purposes. They say the proposal is an unprecedented interpretation of...