Intercollegiate athletics are a fundamental part of the American college experience. Nothing else unites and impassions entire campuses while providing educational opportunities to thousands of students who might not otherwise be able to attend college. Congress and the IRS have long recognized...

Taxation of international athletes is a failure. The lack of a single, consistent regime results in substantial enforcement difficulties for tax administrators as well as a massive compliance burden and potential double taxation for athletes. International athletes' unique characteristics...

This article examines the Wayfair case through the lens of substantive and enforcement jurisdiction and focuses on the question of whether there is a constitutionally required relationship between the nexus of the person that the state seeks to enlist as the tax collector and the underlying...

Existing tax regimes fail to tax digital services appropriately. Digital services based on extracting and monetizing user data—most notably digital advertising—are particularly problematic because tax regimes do not adequately account for the enormous value derived from user data....

After two decades of relative dormancy, we are witnessing a resurgence in state estate tax controversies. Federal estate tax amendments beginning in 2001, which eliminated the federal credit for state estate taxes, greatly diminished the general significance of state estate taxes, as most states...

The movement of people and the movement of money are often discrete. As such, governments can address the effects of each separately. Because residence provides a general jurisdictional basis for state personal income taxation, however, money often moves with people. States must disentangle the...