The Florida Tax Review, one of only a few faculty-edited academic law reviews, publishes articles, essays, and book reviews by leading legal academics, practitioners, and economists. FTR is sponsored by the Graduate Tax Program of the University of Florida Levin College of Law.

Vol. 23 No. 1 (2019)

Published: 2020-03-13

Crisis-Driven Tax Law: The Case of Section 382

Albert H. Choi, Quinn Curtis, Andrew T. Hayashi

1-72

Abstract

At the peak of the 2008 financial crisis, the Internal Revenue Service (IRS) issued Notice 2008–83 (the Notice), administrative...

--Read More

Revisiting Federal Tax Treatment of States, Political Subdivisions, and Their Affiliates

Ellen P. Aprill

73-129

Abstract

Several provisions of the 2017 tax legislation, known as the Tax Cuts and Jobs Act (TCJA), focused attention on federal taxation...

--Read More

Stabilizing “Pillar One”: Corporate Profit Reallocation in an Uncertain Environment

Itai Grinberg

130-192

Abstract

This Article is about how the world reestablishes international tax order.

The Article focuses on...

--Read More

Can Anyone Be Trusted to Enforce National Treatment Disciplines With Respect to Tax Measures?

Patricia A. Brown

193-237

Abstract

Because the traditional non-discrimination article of tax treaties seem­ingly provides protection against only the most blatant...

--Read More

Saving the Planet by Cutting Corporate Taxes: A Comparative Case Study Analysis

Roberta Mann, Fiona Martin, Bill Butcher

238-292

Abstract

This Article examines corporate tax trends in the context of the press­ing global issue of climate change. Multinational...

--Read More

Carbon Tax Shifts and the Revenue-Neutrality Dilemma

Rory Gillis

293–348

Abstract

Over the past two decades, numerous experts and politicians have proposed “revenue-neutral carbon tax shifts,” under which a government...

--Read More

Contribution and Distribution Flexibility and Tax Pass-Through Entities

Brett Freudenberg, Bradley T. Borden

349–431

Abstract

The way jurisdictions design their tax systems for business operations can be a contentious issue, as they try to balance the competing goals of...

--Read More

Don't Blame It on WTO Law: An Analysis of the Alleged WTO Law Incompatibility of Destination-Based Taxes

Alice Pirlot

432–493

Abstract

The idea that corporations should be taxed in the jurisdiction where they make their sales or provide their services is getting more and more...

--Read More

View All Issues