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.
Current Issue
Vol. 28 No. 2 (2025): Symposium Issue: Moore, Loper Bright, Corner Post, and the Future of the Federal Tax System
Published: 2025-09-24
Articles
Charles and Kathleen Moore and the Coming Tax Armageddon
AbstractThe Supreme Court decided last term, against predictions, that U.S. shareholders could be taxed on the undistributed earnings of their foreign...
Containing the Blast Radius
Can Congress Save the Code from Realization
Abstract
The Supreme Court’s decision in Moore v. United States avoided enshrining realization as a constitutional requirement for taxing income. But...
Moore Questions, Some Answers
Fixing the Personal Tax System Despite Constitutional Constraints
Abstract
Moore v. United States was expected to rule on the constitutional necessity of the tax-law realization requirement originating from Eisner v....
Have Your Cake and Eat It Too, Using Apportionment to Preserve Congress's Tax Power
AbstractThe Constitution provides Congress with extremely broad taxing power, and the Supreme Court has recognized that this power is “virtually without...
The Decline of Chevron, the Rise of Loper Bright and the Shifting Sands of Tax Law
AbstractThe repeal of the Chevron deference doctrine has triggered what some may argue is a seismic shift in how tax law may be interpreted and applied,...
Tax Regulations in a Loper Bright Light
AbstractThe Supreme Court’s decision in Loper Bright Enterprises. v. Raimondo overturned Chevron deference. In doing so, Loper Bright loosed chaos into...
The Tax Trench Deepens
AbstractCongress, long divided, has been in gridlock for decades. The result has been regulatory ossification. Existing statutes lack the flexibility to...