Scholarship

Presentations

Books

  • Federal Income Taxation, 17th ed. (2017) (Coauthor with Joseph Bankman, Daniel Shaviro and Kirk Stark).
  • We Are Better Than This: How Government Should Spend Our Money (Oxford Univ. Press, 2014)

Articles and Book Chapters

  • "The Right Tax at the Right Time" (working paper). - (SSRN)
  • “Business Taxes Reinvented: A Term Sheet,” 156 Tax Notes 999 (2017). - (SSRN) - (PDF)
  • "Capital Taxation in An Age of Inequality," 90 Southern California Law Review 593 (2017). - (SSRN) - (PDF)
  • "The Trojan Horse of Corporate Integration," 152 Tax Notes 957 (2016) - (SSRN)
  • "U.S. Corporate Income Tax Reform and its Spillovers" (with Kimberly Clausing and Thornton Matheson), IMF Working Paper No. 16/127 (July 2016) - (PDF)
  • "Stateless Income And Its Remedies," a chapter in Global Tax Fairness (Thomas Pogge and Krishen Mehta, eds.). Oxford University Press (2016).
  • "Why Corporate Tax Reform Can Happen," 146 Tax Notes 91 (2015). - (SSRN) - (PDF)
  • "Competitiveness Has Nothing to Do With It," 144 Tax Notes 1055 (2014). - (SSRN)
  • “Corporate Tax Reform, Business Tax Reform, or Capital Income Tax Reform?” 18 Chapman Law Review 1 (Fall 2014). - (Hein)
  • In Praise of the Tax Policy Center's Microsimulation Model: A Comment on "Curbing Tax Expenditures," in Pathways to Fiscal Reform in the United States (John W. Diamond and George R. Zodrow, eds., 273-282). MIT Press (2014).
  • "Through a Latte, Darkly: Starbucks’ Stateless Income Planning," 139 Tax Notes 1515 (2013). - (SSRN)
  • "Corporate Capital and Labor Stuffing in the New Tax Rate Environment" (Mar. 26, 2013). - (SSRN)
  • "Why Tax Revenues Must Rise"  (Feb. 14, 2013). - (SSRN)
  • “3 Cheers for Dave Champ,” 138 Tax Notes 619 (2013).
  • "Stateless Income’s Challenge to Tax Policy, Part 2," 136 Tax Notes 1431 (2012). - (SSRN)
  • "Paul Ryan’s Roadmap to Inequality," 136 Tax Notes 1195 (2012). - (SSRN)
  • "The Better Base Case," 135 Tax Notes 1237 (2012) (with Joseph Rosenberg). - (SSRN)
  • "The Lessons of Stateless Income," 65 Tax Law Review 99 (2011). - (SSRN)
  • "Stateless Income," 11 Florida Tax Review 699 (2011). - (SSRN)
  • "The Role of Tax Reform in Deficit Reduction," 133 Tax Notes 1105 (2011). - (SSRN)
  • "Herman Cain’s 9-9-9 Plan," 133 Tax Notes 469 (2011). - (SSRN)
  • "Stateless Income’s Challenge to Tax Policy," 132 Tax Notes 1021 (2011). - (SSRN)
  • "Constitutional Kreplach," 128 Tax Notes 755 (2010). - (SSRN)
  • "Tax Expenditure Framework Legislation," 63 National Tax Journal 353 (June 2010). - (SSRN)
  • "An American Dual Income Tax: Nordic Precedents," 5 Northwestern Journal of Law and Social Policy 41 (2010). - (SSRN)
  • "The Congress Within a Congress: How Tax Expenditures Distort Our Budget and Our Political Process," 36 Ohio Northern University Law Review 1 (2010) (publication version of the Fourteenth Annual Woodworth Lecture, delivered in Washington, DC). - (SSRN)
  • “Where Can We Stand to Gain Perspective?, Toward Tax Reform: Recommendations for President Obama’s Task Force,” Tax Analysts (2009). - (PDF)
  • "Systematic Underinvestment in Straddle Rules," 125 Tax Notes 1301 (December 21, 2009) (a compilation of invited essays, "Examining the Straddle Rules After 25 Years").
  • “A Revenue Estimate Case Study: The Repatriation Holiday Revisited,” 120 Tax Notes 1191 (2008) (with Patrick Driessen).
  • “Rethinking Tax Expenditures,” an address to the Chicago-Kent College of Law Federal Tax Institute (2008). - (www)
  • “Rehabilitating the Business Income Tax,” The Hamilton Project at the Brookings Institution (2007). - (www)
  • “Designing an Income Tax on Capital,” a chapter in Taxing Capital Income, The Urban Institute Press (2007).
  • “Throw Territorial Taxation From the Train,” 114 Tax Notes 547 (2007).
  • “A Holistic Approach to Business Tax Reform,” 114 Tax Notes 90 (2007).
  • “Is It Time to Liquidate LIFO?” 113 Tax Notes 237 (2006) (with George A. Plesko and Corey M. Goodman).
  • "IRS Should Release Schedules M-3, Not Entire Corporate Tax Returns," 106 Tax Notes 1485 (2006) (with Peter Canellos).
  • "The Business Enterprise Income Tax:  A Prospectus," 106 Tax Notes 97 (2005). - (SSRN)
  • "Proposed Treasury Regulatiaons Offer Dealers and Traders Safe Harbor for Section 475 Mark-to-Market Valuations," 19 Journal of Taxation and Regulation of Financial Institutions 5 (September/October 2005). - (SSRN)
  • “Taxing Convertible Debt: A Layman’s Perspective,” 56 S.M.U. Law Review 453 (2003). - (Hein)
  • “Competitive Convergence in the Financial Service Markets,” 81 Taxes 225 (2003). - (Hein)
  • “Disclosing Book-Tax Differences,” 96 Tax Notes 999 (2002) (with Peter C. Canellos).
  • “Contingent Interest Convertible Bonds and the Economic Accrual Regime,” 95 Tax Notes 1949 (2002) (with Erika W. Nijenhuis and William L. McRae).
  • “A Short Course in Valuing Derivatives,” 94 Tax Notes 380 (2002).
  • "Some Thoughts on Market Valuation of Derivatives," 91 Tax Notes 1173 (2001).
  • “The U.S. Taxation of Equity Derivative Instruments,” Chapter 24 in The Handbook of Equity Derivatives. New York: John Wiley & Sons, Inc., 2000.
  • “Everything I Know About New Financial Products I Learned From DECS, Practicing Law Institute,” Tax Law and Practice Course Handbook Series #457 (1999 and following years) (with Erika W. Nijenhuis).
  • “Corporate Tax Shelters and Corporate Tax Management,” 51 The Tax Executive 231 (1999). - (Hein)
  • “The Role of Mark-to-Market Accounting in a Realization-Based Tax System,” 75 Taxes 788 (1997) (with Thomas L. Evans). - (Hein)
  • "Final Tax Regulations Governing Contingent Payment Debt Obligations," 72 Tax Notes 499 (1996).
  • “Short Sales and Short Sale Principles in Contemporary Applications,” Chapter 17 in N.Y.U. Fifty-Third Institute on Federal Taxation. New York: Matthew Bender, 1995 (with Erika W. Nijenhuis).
  • “Risky and Riskless Positions in Securities,” 71 Taxes 12 (1993).
  • “Equity Derivative Products: Financial Innovation’s Newest Challenge to the Tax System,” 69 Texas Law Review 6 (1991). - (Hein)
  • “Beyond Good and Evil Debt (And Debt Hedges): A Cost of Capital Allowance System,” 67 Taxes 12 (1989). - (Hein)
  • “Business Hedges After Arkansas Best,” 43 Tax Law Review 393 (1988) (with Suzanne F. Greenberg). - (Hein)
  • “The Miracle of Compound Interest: Interest Deferral and Discount After 1982,” 38 Tax Law Review 4 (1983) (with Peter C. Canellos). - (Hein)

Testimony

  • U.S. Congress. House Committee on Ways and Means. International Tax Reform Begins at Home. Hearings, 114 Cong., 2d sess. February 24, 2016. - (PDF)