The immediate U.S. taxation of foreign subsidiaries' passive, but not active income is a scenario of increasing practical importance. This paper builds on Alvin Warren's recent analysis of this partially deferral-tempering case. It clarifies some of the legal and economic mechanics behind...

What government-observable characteristics should determine the taxes that an individual pays and/or the transfers that she receives? This article focuses on a specific aspect of this fundamental question of tax policy: the implications of policymakers' uncertainty regarding the outcomes of tax...

This document contains the web appendix referenced in the paper “Pass-Through, Public Trading, and the Dubious Obstacle of Inside Basis Adjustments”, which is available at "http://ssrn.com/abstract=2968794" http://ssrn.com/abstract=2968794

This document is the web appendix for the paper, A Critical Look at the Economic Argument for Taxing Only Labor Income. (Available at SSRN: http://ssrn.com/abstract=1353322.) For easy reference, the document is organized into the same subdivisions (parts, sections, subsections, etc...) as is...

The literature on optimal redistributional instruments begins with the assumption that society has some preference for equality, leaving the precise degree unspecified. It then asks: How should society pursue that preference? More specifically, what kinds of policy instruments — whether...

The question of which party should bear the burden of proof on a given factual issue remains one of the most important and problematic in evidence and procedure. This paper approaches the question from a relatively unstudied perspective, viewing litigation as a device for influencing primary...

Elective “inside basis adjustments” are a central feature of partnership taxation, and their prospective infeasibility for publicly traded companies has played an important role in shaping leading corporate integration proposals. This paper questions whether such adjustments are necessary in...

This paper, which is not a standalone document, is the web appendix referenced inChris William Sanchirico, The Ramsey Rule at 100: Pairing Back the Overgrowth, University of Pennsylvania Carey Law School, Institute for Law and Economics, Research Paper no. 21-25,...

In 1927 the mathematician Frank Ramsey published a paper on optimal taxation in which he put forward what has come to be known as the “Ramsey rule”. Nearly one hundred years later, Ramsey’s paper remains a go-to reference for normative tax theory in a number of fields, including legal...

In the literature on optimal taxation, a “tag” is a government-observable taxpayer attribute that is effectively immutable – like blindness, race, gender, or even height. Conventional optimal tax theory prescribes that tags should be included in the tax base so long as they are in some way...