Nearly 40 years ago I wrote Interest in Disguise: Taxing the Time Value of Money. The article showed that if the party’s marginal tax...

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This Article examines whether Article 12 of the OECD Model Tax Convention should be redrafted to tax royalties where value is created in an...

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The OECD has spent the last fifteen years working on the design and implementation of rules for the taxation of income...

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By its own account, the federal government spends more than $500 billion every year to subsidize retirement savings in...

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Recently, the Supreme Court decided in SFFA v. Harvard/UNC that colleges are restricted in their use of race-based affirmative action...

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The contours of the U.S. Supreme Court’s dormant Commerce Clause doctrine of internal consistency, which asks whether a state tax intrinsically...

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In Connelly v. United States, the Supreme Court resolved a long-standing...

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Two recent federal court decisions have reignited the debate over whether “Federal financial assistance” as...

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