Is Section 355(e) a Stalking-Horse for Mandatory Section 338?

Liberalism is back on its heels, pushed there by political movements in the United States and Europe and by the critiques of legal scholars and...

Income inequality is a national preoccupation, and the public’s imagination is captured by the astronomical incomes of Valley tech billionaires and...

Over the past twenty-five years, Congress has enacted several major reforms for employer-sponsored retirement plans and individual retirement accounts...

There have been a lot of intriguing developments in the Hamilton Reserve Bank vs Sri Lanka litigation lately, not least mounting questions around who...

In an era characterized by inequalities of income and influence, political polarization, and the segregation of social spaces, the income tax...

Over the past quarter century, Congress has enacted several major reforms for retirement plans and individual retirement accounts, usually with large...

Law students frequently find the U.S. Supreme Court’s Dormant Commerce Clause doctrine confusing. That is no surprise given the sharp disagreement...

At the inception of a new and potentially transformative type of tax enforcement, this Article reviews the goals underlying the prohibition on state...

When Jennifer Lopez and Ben Affleck got engaged the first time, in 2002, he gave her a very pricey ring. That engagement ring was reportedly worth as...

The Russian invasion of Ukraine in 2022 provoked the imposition of economic sanctions that are unprecedented in their swiftness, severity, and novelty...

A division exists between scholars who claim that Congress made only limited delegations to executive officials in the early Republic, and those who...

By the end of the 20th century, international tax law was a dinosaur: outdated, outmoded, and inadequate at collecting and allocating the taxing...

In this article, Mason reviews the advocate general opinion in the case against Ireland for granting illegal state aid to Apple. Advocate General...

This essay, to be included as a chapter in a volume on corporate taxation, briefly reviews U.S. efforts to achieve corporate tax integration, focusing...

When Stanley Surrey—possibly the most prominent tax academic of the twentieth century—died in 1984, the school of thought sometimes known as the “new...

The Inflation Reduction Act signed by President Biden on August 16, 2022, allocated $80 billion in additional funding for the IRS. While Democrats...

Section 1202 of the Internal Revenue Code grants a gain exclusion to certain shareholders who own "qualified small business stock." We describe the...

Income tax law and policy are fundamentally intertwined with private markets—causal effects run in both directions. The vitality of public markets can...