By the end of the 20th century, international tax law was a dinosaur: outdated, outmoded, and inadequate at collecting and allocating the taxing... MORE
At the inception of a new and potentially transformative type of tax enforcement, this Article reviews the goals underlying the prohibition on state... MORE
Over the past quarter century, Congress has enacted several major reforms for retirement plans and individual retirement accounts, usually with large... MORE
When Stanley Surrey died in 1984, the school of thought sometimes known as the “new textualism” that has gained such influence in the United States... MORE
In this article, Mason explains why the Commission lost the Fiat state-aid appeal before the Court of Justice of the European Union. She also argues... MORE
In October 2022, the U.S. Supreme Court heard oral argument in National Pork Producers Council v. Ross, a Ninth Circuit case out of California,... MORE
Over the past four decades, persistent concerns about executive compensation have prompted the US Congress to enact penalty taxes aimed at various... MORE
Shifts in academic paradigms are rare. Still, it was not long ago that the values taken to govern the private law were thought to be distinct from... MORE
In this article, Mason explains how the OECD's proposed Pillar 2 global minimum tax rules induce cooperation by states, and how the proposal to enact... MORE
The district court erred when it concluded that because Proposition 12 applies only to in-state sales, it could not be extraterritorial. On the... MORE
A division exists between scholars who claim that Congress made only limited delegations to executive officials in the early Republic, and those who... MORE
The use of economic statecraft is at a high-water mark. The United States uses sanctions, tariffs, and import and export controls more than ever... MORE
In this essay, we review criticisms of both the concept of international tax arbitrage and regulatory responses meant to reduce such arbitrage. We... MORE
