Published: 2023-12-04
Articles
The Taxation of Treasury Inflation Protected Securities
Are They Tax-Disadvantaged?
1–30
AbstractInflation is back, causing problems for taxpayers looking for safe, inflation-protected investments. This Article engages in an in-depth...
Taxation at a Distance
31–75
AbstractWealthy Americans escape the income and estate taxes by holding assets at a legal remove. This general tax avoidance strategy—holding wealth “at...
The Executive Compensation Threat to Retirement
76–167
AbstractIn recent years a new phenomenon has appeared on the retirement savings landscape: the expansion into middle management ranks of a traditional...
Revisiting the Interaction of the Interest Expense Deduction and the Foreign Tax Credit
168–286
AbstractThis Article demonstrates that the most appropriate proxy for allocating and apportioning U.S. interest expense is one that first identifies the...
The Dubious Constitutional Origins of Treaty Overrides
A Response to Rosenbloom and Shaheen
287–325
AbstractIn 1888, the Supreme Court decided a case called Whitney v. Robertson, which is generally considered to be the source of the proposition that,...
The Common Sense of a Wealth Tax
Thomas Paine and Taxation as Freedom from Aristocracy
326–368
AbstractThomas Paine’s writing helped spur the American colonies to independence and ensure that the new nation would be a republic, not a monarchy. In...
Reimagining a U.S. Corporate Tax Increase as a Supplemental Subtraction VAT
369–418
AbstractThe U.S. federal government raises tax revenue almost exclusively through income taxes, both corporate and individual, whereas its trading...
Safe Harbor Regimen in Transfer Pricing—An African Perspective
419–457
AbstractThe transfer pricing methods established by the transfer pricing rules and practices of many countries (generally modelled after the OECD...