The (Not So) Inclusive Framework and the Multilateral Instrument
The Article demonstrates that the most important initiatives to promote inclusivity within the international tax regime (Country-by-Country...
Lost in Translation
Excess Returns and the Search for Substantial Activities
Since 2010, international tax policymakers have proposed a variety of minimum taxes on excess returns, but every proposal has defined excess...
Duplicative Taxation Among the States
A Problem Not Worth Solving?
Recent legal and economic changes—not to mention the rise in telecommuting caused by COVID—have raised the salience of a long-simmering fact...
The Guardians of the New Internal Revenue Code
The proliferation of electronic filing (e-filing) of income tax returns creates new problems and opportunities for the regulation of the tax...
Binding Constitutional History
Reverse Pollock and End Fatal Apportionment
The Constitution requires that direct taxes be apportioned among the states by population. The original purpose of the rule was to apportion...
Taxing Interstate Remote Workers After New Hampshire v. Massachusetts
The Current Status of the Debate
Under the dormant Commerce Clause, Massachusetts, New York and other states emulating them violate their constitutional duty to apportion when...
Citizenship Taxation, Globalization and Inequality
The U.S alone claims the right to tax its citizens regardless of country of residence. Other states allow their citizens to forego national...
The Architecture of the Country-by-Country Minimum Tax Regime Proposed by the United States
The Article discusses the structural dynamics that will underlie the international negotiations prompted by a U.S. proposal about a minimum...