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Rationalizing the Taxation of Reorganizations and Other Corporate Acquisitions
(Virginia Tax Review, 2007)
This article examines the taxation of human shareholders in the
case of mergers and acquisitions. Currently, the relevant law is
extraordinarily complex, utterly inconsistent, and in many instances
arguably unfair. There ...
Little Boxes: Can Optimal Commodity Tax Methodology Save the Debt-Equity Distinction?
(Texas Law Review, 2002)
Optimal commodity tax methodology has been proposed as a way of making difficult line drawing decisions in the income tax. This paper explores some practical difficulties with the approach, and concludes that in one area ...
How I Learned to Stop Worrying and Love Double Taxation
(Notre Dame Law Review, 2003)
This Article is divided into three Parts. The first Part is devotedto an example demonstrating that, while double taxation may be gratuitous in a purely domestic context, it invariably becomes necessary in a multinational ...
I Come Not to Praise the Corporate Income Tax, But to Save It
(Tax Law Review, 2003)
This Article began with a search for a theoretical underpinning that
could explain the structure of the current corporate income tax regime,
and found such underpinning lacking. It proposed an alternative
underpinning for ...
A Minimalist Approach to Corporate Income Taxation
(SMU Law Review, 2006)
An ever-shrinking hallmark of our federal income tax system is the apparent double taxation of some, but not all, business income. That is, some business income ultimately flows to the human shareholders of C corporations. ...
A Lifetime Income Tax
(Virginia Tax Review, 2006)
Under current tax law, there can be considerable period-by-period divergence between a taxpayer's after-tax income and her desired or actual consumption. This divergence will cause the taxpayer to borrow. One can view such ...
Why Every State Should Have an Income Tax (and a Retail Sales Tax, Too)
(Mississippi Law Journal, 2009)
Some states (like Florida and Texas) collect retail sales taxes but no income taxes; one state (Oregon) collects income taxes but no retail sales taxes; most states collect both. This paper examines the decision of a state ...
The Cashless Corporate Tax
(Tax Law Review, 2001)
Proposals for reforming the federal corporate income tax are neverending and ever-multiplying. They range from those that merely tinker around the edges, such as most recent proposals attacking the various perceived abuses ...
The Zen of Corporate Capital Structure Neutrality
(Michigan Law Review, 2000)
Given the current tax rate structure - where the marginal tax rate of some persons exceeds the corporate tax rate and the marginal tax rate of others is exceeded by it - corporations are generally well advised to employ ...