Published: 2026-10-20

Audit Guides and the Administrative State

Joshua D. Blank, Leigh Osofsky

475–543

Abstract

Scholars are engaged in deep debate about the transformative power of recent Supreme Court cases that appear to limit the role of agencies in...

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From Facilitation to Fragmentation

The Evolution and Reform of Low-Value Import Exemptions in EU and U.S. Law

Corinne Boismain

544–601

Abstract

This Article examines the legal architecture, constitutional constraints, and policy rationales underlying...

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Unlocking the Mystery of Private Equity

A New Tax Paradigm

David Elkins, Christopher H. Hanna

602–647

Abstract

The taxation of carried interests has been one of the hottest topics in the tax world for the last 15 years with the issue...

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What’s Next After Amount A?

Mindy Herzfeld

648–699

Abstract

An agreement on a two-pillar solution to the taxation of the digitalized economy brokered by the OECD was...

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No Trade Wars Without Taxation—Who’s to Blame, and What Comes Next?

Domenico Imparato, Reuven S. Avi-Yonah, Doron Narotzki

700–771

Abstract

As tariff policy again shapes U.S. trade strategy, this Article makes a foundational claim: Trade wars are, at...

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Local Fiscal Autonomy Under the Federal Constitution

Darien Shanske

772–811

Abstract

The exact role of local governments, including their fiscal powers, is unsettled under current federal constitutional law....

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Taxpayer Realization, Unrealized Capital Gains, and Economic Welfare

Steven M. Sheffrin

812–856

Abstract

Should we tax unrealized capital gains? This Article provides a new perspective on this controversial issue by...

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