This paper explains the various structures that permit offshore funds with U.S. managers to originate loans without the fund or its investors being subject any meaningful amount of U.S. tax. This paper also suggests a legislative change that would render these structures moot

This essay proposes a comprehensive mark-to-market tax for the 0.1% wealthiest and highest-earning taxpayers. Publicly-traded securities would be subject to an annual mark-to-market tax. Nontraded assets would be subject to a “deemed mark-to-market” tax: They would not be subject to tax...

This report describes various tax games, roadblocks, and glitches in the tax legislation currently before Congress, titled the Tax Cuts and Jobs Act (TCJA). The complex rules proposed in the House and Senate bills will allow new tax games and planning opportunities for well-advised taxpayers,...

Sexual harassment victims are taxable on their recoveries. Recoveries for personal injuries that are not “physical” are taxable, and the Internal Revenue Service and most courts hold that the injuries arising from harassment are not physical. This is bad policy. Taxing a plaintiff’s...

This note finds a negative, non-linear relationship between bond yield and liquidity using data on Portuguese, Irish, Italian, Greek, and Spanish (PIIGS) sovereign bonds from 2010-2015. This relationship is predicted by the asymmetric information model of bond liquidity by Holmstrom (2015) and...

While the surge in 501(c)(4)s that led to the current IRS scandal is widely attributable to Citizens United, it was a very deliberate IRS action – the decision to exempt donations to 501(c)(4)s from gift tax – that was equally responsible for the unprecedented spending by 501(c)(4)s in the...

This paper responds to Jeff Bezos' request for philanthropic ideas, but with a suggestion for the structure of his grant making. Gifts of appreciated stock should be made to section 501(c)(3) organizations only to the extent that Bezos will be able to use the charitable deduction that the...