The unbridled intent to maximize the return for shareholders has earned an enviable place for the tax-planning fraternity in corporate structuring deliberations. More often than not, elevating the trend akin to an axiomatic proposition, cross-border transactions are tested for tax-efficiency...

In 2017, Congress passed major tax legislation at warp speed. After enactment, it fell to the Treasury Department to write regulations clarifying and implementing the new law. To assure democratic legitimacy in making regulations, administrative law provides that an agency must issue a notice of...

Professors Reuven S. Avi-Yonah, David Gamage, Orly Mazur, Young Ran (Christine) Kim, and Darien Shanske (collectively, “Tax Law Professors”) write this amici curiae brief in support of the Appellant in COMPTROLLER OF MARYLAND v. COMCAST — the Maryland Digital Advertising Case. Many digital...

This Handbook entry presents a conceptual, normative overview of the subject of taxation. It emphasizes the relationships among the main functions of taxation—notably, raising revenue, redistributing income, and correcting externalities—and the mapping between these functions and various...

The U.S. extraterritorial tax system has evolved such that today it is more consequential than one century ago. The system, conceived in the stigmatization of overseas Americans, consists of highly penalizing taxation and banking policies that make it difficult for overseas Americans to live...

The economic downturn has created an investment market in which some tax-advantaged strategies have become favored. To avoid taxable diversification, taxpayers have turned to exchange funds. Through the rules in sections 351, 721, and 368, taxpayers can diversify a single stock position without...

In early 1924, James Couzens was a Republican Senator from Michigan and reportedly the richest member of Congress. Andrew Mellon was beginning his fourth year as Secretary of the Treasury — a service that would eventually span 11 years under three Republican Administrations — and one of the...

These materials discuss as well as provide context to understand the significance of the most important judicial decisions and administrative rulings and regulations promulgated by the Service and Treasury during 2017. Amendments to the Code generally are not discussed except to the extent that...

David Herzig discusses the scope of the infrastructure problem, the history of the gasoline tax, and the various proposed alternative taxes to preserve the tax base, while addressing some of the intertwined issues

The U.S. economy exhibits high inequality and low economic mobility across generations relative to other high-income countries. The United States will need to raise more revenues in order to reduce these disparities, finance much-needed new services and investments, and address the nation's...