Published: 2026-10-20
Articles
Audit Guides and the Administrative State
475–543
AbstractScholars are engaged in deep debate about the transformative power of recent Supreme Court cases that appear to limit the role of agencies in...
From Facilitation to Fragmentation
The Evolution and Reform of Low-Value Import Exemptions in EU and U.S. Law
544–601
AbstractThis Article examines the legal architecture, constitutional constraints, and policy rationales underlying...
Unlocking the Mystery of Private Equity
A New Tax Paradigm
602–647
AbstractThe taxation of carried interests has been one of the hottest topics in the tax world for the last 15 years with the issue...
What’s Next After Amount A?
648–699
AbstractAn agreement on a two-pillar solution to the taxation of the digitalized economy brokered by the OECD was...
No Trade Wars Without Taxation—Who’s to Blame, and What Comes Next?
700–771
AbstractAs tariff policy again shapes U.S. trade strategy, this Article makes a foundational claim: Trade wars are, at...
Local Fiscal Autonomy Under the Federal Constitution
772–811
AbstractThe exact role of local governments, including their fiscal powers, is unsettled under current federal constitutional law....
Taxpayer Realization, Unrealized Capital Gains, and Economic Welfare
812–856
AbstractShould we tax unrealized capital gains? This Article provides a new perspective on this controversial issue by...