The current structure of U.S. federal tax law incentivizes state governments to adopt tax policies that inflict costs on the federal government, at the expense of national welfare. We label this the “tax cannibalization problem.” This article introduces the tax cannibalization problem to the...

This essay argues that the states should conform to the post-2017 federal tax law's provision for Global Intangible Low-Taxed Income (or “GILTI”). This essay is directed at state legislators and their staffs and presents the argument as succinctly as possible. Our argument can be summarized...

Should the federal government be involved in the regulation of municipal debt finance? The answer is arguably not. But this theoretical dispute is not the focus of this Article because, in fact, the federal government already regulates municipal debt finance extensively, generally much more...

This Essay refutes Adler's and Cannon's argument that the Affordable Care Act (“Obamacare”) does not authorize premium tax credits for insurance policies purchased from the federal healthcare Exchanges. Adler's and Cannon's argument is the basis of challenges in a number of ongoing lawsuits,...

This essay analyzes the implications of two recent Supreme Court cases on state and local taxation: Alabama Department of Revenue v. CSX Transportation Inc. and Direct Marketing Association v. Brohl. We argue that both of these decisions not only fail to resolve major issues in state and local...

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,...

Six members of Congress filed this amicus brief in South Dakota v. Wayfair in support of South Dakota's petition of certiorari. The question presented by the petition is: “Should this Court abrogate Quill's sales-tax-only, physical-presence requirement?” The members of Congress filed this...