Next Week’s Tax Workshop

Thursday, December 7: Andrew Hayashi (Virginia; Google Scholar) will present The Federal Architecture of Income Inequality as part of the Columbia Davis Polk & Wardwell Tax Policy Colloquium. If you would like to attend, please contact Michael Love.

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Fox Presents Who Benefits From Corporate Tax Cuts?: Evidence From Banks And Credit Unions Around The TCJA At NYU And Columbia This Week

Edward Fox (Michigan; Google Scholar) presents Who Benefits from Corporate Tax Cuts?: Evidence from Banks and Credit Unions around the TCJA (with Benjamin Pyle (Boston University; Google Scholar)) at NYU today as part of its Tax Policy and Public Finance Colloquium hosted by Daniel Shaviro and at Columbia on Thursday as part of its Davis Polk & Wardwell Tax Policy Colloquium hosted by Michael Love::

The TCJA of 2017 made large changes to the taxation of corporate and pass-through businesses in the U.S. Understanding the effects of these changes is complicated by the difficulty of finding control firms whose taxation was not altered by the Act. We study the effect of the TCJA on small and medium size banks using credit unions—which compete with these banks for deposits and in making loans—as a novel control group. Credit unions were not taxed both before and after the Act. Using a difference-in-difference framework, we find that an important fraction of the incidence of the tax cut goes to depositors. We find little evidence that employees or borrowers from banks receive a share of the tax cut in the form of higher wages or lower interest rates on loans or that banks increase their investment in fixed assets as a result of the Act.

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Kleiman, Sarkar & Satterthwaite Present Towards An Understanding Of Nannies' Tax Experiences And Preferences Today At Loyola-L.A.

Ariel Jurow Kleiman (Loyola-L.A.; Google Scholar), Shayak Sarkar (UC-Davis; Google Scholar), and Emily Satterthwaite (Georgetown; Google Scholar) present Towards an Understanding of Nannies' Tax Experiences and Preferences at Loyola-L.A. today as part of its Tax Policy Colloquium hosted by Katie Pratt:

Despite their indispensable work, nannies in the U.S. often work long hours for low wages and fear retaliation if they complain about work or pay conditions. Exacerbating this precarity is the fact that many nannies work “off the books” and thus must keep their work secret not only from state and federal tax agencies, but from employment and labor agencies as well. This Article investigates nannies’ preferences for or against formal employment and tax reporting, the reasons behind such preferences, and how such preferences correspond to nannies’ relationships with their employers and with society more broadly. 

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Next Week’s Tax Workshops

Monday, November 27: Ariel Jurow Kleiman (Loyola-L.A.; Google Scholar), Shayak Sarkar (UC-Davis; Google Scholar) & Emily Satterthwaite (Georgetown; Google Scholar) will present Towards an Understanding of Nannies' Tax Experiences and Preferences as part of the Loyola-L.A. Tax Policy Colloquium. If you would like to attend, please RSVP here. 

Tuesday, November 28: Edward Fox (Michigan; Google Scholar) will present Who Benefits from Corporate Tax Cuts?: Evidence from Banks and Credit Unions around the TCJA (with Benjamin Pyle (Boston University; Google Scholar)) as part of the NYU Tax Policy and Public Finance Colloquium. If you would like to attend, please contact Daniel Shaviro.  

Thursday, November 30: Edward Fox (Michigan; Google Scholar) will present Who Benefits from Corporate Tax Cuts?: Evidence from Banks and Credit Unions Around the TCJA (with Benjamin Pyle (Boston University; Google Scholar)) as part of the Columbia Davis Polk & Wardwell Tax Policy Colloquium. If you would like to attend, please contact Michael Love. 

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Danso Presents Contemporary Perspectives On African Taxation Today At Boston University

Isaac Agyiri Danso (D.Phil. Candidate, Oxford) presents Navigating the African Tax Terrain: Contemporary Perspectives on African Taxation at Boston University today as part of its Just Taxation Workshop hosted by Steven Dean:

African taxation today has been shaped by the complexity of its socio-political and economic history. The contemporary tax architecture in Africa has been shaped significantly by its colonial past.  For instance, colonial era taxes were designed and introduced to extract resources, primarily for the benefit of the colonisers. These exploitative taxes on indigenous populations laid the foundation for widespread scepticism towards taxation among many Africans which persist to today. Today, African taxation reflects a dynamic interplay of these historical legacies, in the ongoing strive to mobilise domestic revenue to finance the continent's development.  

African governments are daring to strike a delicate balance between mobilising domestic resources, reducing aid dependence, and promoting economic growth and equitable development.

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Brooks & Gamage Present The Sixteenth Amendment and Congress’s Income Tax Power Today At Loyola-L.A.

John (Jake) Brooks (Fordham; Google Scholar) and David Gamage (Indiana-Maurer; Google Scholar) present “From Whatever Source Derived”: The Sixteenth Amendment and Congress’s Income Tax Power at Loyola-L.A. today as part of its Tax Policy Colloquium hosted by Katie Pratt: 

The upcoming Supreme Court case of Moore v. United States raises questions that the Court has rarely had to address in the last 100 years—what is the meaning of the Sixteenth Amendment and Congress’s income tax power? Does that power only extend to realized income? And what does "realization" mean? The taxpayers in Moore (and the Ninth Circuit judges who dissented from the denial of rehearing en banc) argue that realization is necessarily a part of the meaning of “income” in the Sixteenth Amendment—i.e., that there must be some act of separation or conversion of property into cash or other property in order for there to be “income.” They are, in essence, aiming to revive a disputed reading of the discredited 1920 case of Eisner v. Macomber.

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Lawsky Presents Picturing Capital Gains And Losses Today At Boston College

Sarah Lawsky (Northwestern; Google Scholar) presents Picturing Capital Gains and Losses at Boston College today as part of its Tax Policy Collaborative hosted by James Repetti and Diane Ring:

Formalized statutes become susceptible to a particular kind of formalized reasoning, which can in turn lead to insights about and highlight connections implicit in the statute but obscured by the statute’s complexity. The article focuses, as an example, on reasoning with formalizations of Internal Revenue Code sections related to capital gains and losses. Formalizing these sections reveals an error in the statute that has been generally overlooked by leading treatises and casebooks. Reasoning with formalizations makes it straightforward to show that IRS has corrected this error in its forms and worksheets implementing this law. Moreover, reasoning with formalizations shows that while the IRS forms and worksheets present facially different algorithms than those dictated by the statute, the algorithms the IRS presents are generally faithful to the statute—-and actually improve upon the statute by making technical corrections that are inconsistent with the statute’s (incorrect) language and consistent with the statute’s intent. 

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Next Week’s Tax Workshops

Monday, November 20: John (Jake) Brooks (Fordham; Google Scholar) & David Gamage (Indiana-Maurer; Google Scholar) will present “From Whatever Source Derived”: The Sixteenth Amendment and Congress’s Income Tax Power as part of the Loyola-L.A. Tax Policy Colloquium. If you would like to attend, please contact Katie Pratt. 

Monday, November 20: David M. Schizer (Columbia) will discuss his new book, How to Save the World in Six (Not So Easy) Steps: Bringing Out the Best in Nonprofits (2023), at San Diego. If you would like to attend, please RSVP here. 

Tuesday, November 21: Isaac Agyiri Danso (D.Phil. Candidate, Oxford) will present Navigating the African Tax Terrain: Contemporary Perspectives on African Taxation at Boston University. If you would like to attend, please contact Steven Dean. 

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Tazhitdinova Presents Understanding Capital Gains Responses To Taxes Using Transaction-Level Data Today At Columbia

Alisa Tazhitdinova (UC-Santa Barbara; Google Scholar) presents Understanding Capital Gains Responses to Taxes Using Transaction-Level Data at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium hosted by Michael Love:

We study how individuals' trading behavior responds to tax incentives using administrative transaction-level data on all taxable sales of broker-traded financial assets between 2011 and 2019. Our empirical design leverages a simple, salient, timing-based tax notch: in the U.S., assets held beyond one year qualify for a 10-20% reduction in capital gains rates. The size and granularity of the data allow us to study how this capital gains tax rate differentiation shapes individuals' trading behaviors across narrowly defined demographic and income groups. We find that: (1) retiming responses around the tax rate notch are weak in general; (2) individuals make clear misoptimization errors by realizing gains just before the notch; and (3) this pattern can be explained by both heterogeneous capital gains responses by asset type combined with rigidities in individual trading styles. 

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Newton Presents Closing the Opportunity Gap Today At Pepperdine

Deanna Newton (Pepperdine) presents Closing the Opportunity Gap at Pepperdine today as part of its Faculty Workshop Series hosted by Jacob Charles: 

Opportunity Zones are low-income areas or economically distressed communities in the United States. The Opportunity Zone program encourages investment in low-income areas or economically distressed communities by offering investors tax benefits. Scholars have found little evidence that Opportunity Zones positively impact zone residents’ lives, concluding that Opportunity Zone legislation mostly benefits wealthy investors and should be reformed to benefit community members better. Investors are currently not required to finance projects geared toward the needs of local communities; they are instead funding developments they would have already invested in, whether located in an Opportunity Zone or not. This Article argues that current reform efforts and related scholarship do not give adequate weight to active and direct participation by community members and investors as it relates to economic development tax incentives. It argues for a comprehensive framework that focuses on active, direct, and transformative participation by community members and investors.

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Mehrotra Presents American Economic Inequality, Fiscal Exceptionalism, And Resistance To Consumption Taxes Today At NYU

Ajay Mehrotra (Northwestern; Google Scholar) presents The Missing U.S. VAT: Economic Inequality, American Fiscal Exceptionalism, and the Historical U.S. Resistance to National Consumption Taxes at NYU today as part of its Tax Policy and Public Finance Colloquium hosted by Daniel Shaviro:

Since the 1970s, economic inequality has soared dramatically across the globe and particularly in the United States. In that time, one of the obstacles of using fiscal policy to address inequality has been the growing myth of the “overtaxed American”—the misguided notion that U.S. taxpayers pay more in taxes than residents of other advanced, industrialized countries. This myth has persisted, in part, because of the peculiar and distinctive nature of the fractured American fiscal and social welfare state. Even a cursory review of comparative tax data shows that the United States, by most measures, is a low-tax country compared to other affluent nations. One reason for this shortfall is the missing U.S. value-added tax (VAT).

Unlike the United States, other developed countries fund robust social spending through a balanced mix of levies, including by relying on broad-based national consumption taxes such as a VAT, which produces a tremendous amount of government revenue.

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Stewart & Maynard Present Tax Papers Today At Boston College

Miranda Stewart (Melbourne) presents The Future of Tax Jurisdiction at Boston College at 12:00 pm ET today as part of its Tax Policy Collaborative hosted by James Repetti and Diane Ring:

Tax jurisdiction is a legal concept, but is fundamentally dependent on state capacity, technology and politics. The jurisdictional boundaries of the tax state are in turn crucial in delimiting its taxing power. Governments can enhance tax capability by cooperating with each other and with global intermediaries and by adopting new technologies, but also take contradictory steps to abrogate tax jurisdiction. This article considers how tax jurisdictional concepts, in particular residence, source and the location of consumption, are changing as the capability of states to tax labour, capital and consumption changes in a global digital economy. The article illustrates the discussion with some examples of tax jurisdiction for individuals as residents, workers, investors or consumers; and for corporations, including recent global developments aimed at taxation of multinational enterprises. These changes are occurring through contestation in the borderlands of the tax state, between multiple states and non-state actors. The process could enhance states’ jurisdiction to tax in diverse ways, while denationalizing international tax law making in an evolving multilateral reality.

Goldburn P. Maynard, Jr. (Indiana-Kelley Business School; Google Scholar) presents Unfulfilled Promises of the FinTech Revolution, 111 Cal. L. Rev. ___ (2023) (with Lindsay Sain Jones (Georgia-Terry Business School; Google Scholar)) at Boston College at 5:00 PM ET today as part of its Boston College Tax Policy Collaborative hosted by James Repetti and Diane Ring:

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Stark Presents Retrofitting Prop 13 Through The Personal Income Tax Today At San Diego

Kirk J. Stark (UCLA) presents Retrofitting Prop 13 Through the Personal Income Tax at San Diego today as part of its Tax Speaker Series hosted by Miranda Fleischer:

Under constitutional limitations on California’s local property tax introduced via Proposition 13 in June 1978, homeowners are generally taxed not on the fair market value of their homes but rather the property’s historic cost. As home prices rise over time, this “acquisition value” feature has two predictable effects: (1) it results in significant property tax disparities, favoring longtime homeowners relative to more recent purchasers, and (2) it discourages homeowners from moving because of the increased property tax burdens associated with purchasing a new home. Less widely recognized is the offsetting effect of a longstanding feature of California’s income tax: the deduction for local property taxes. By directing a larger subsidy to those with higher property taxes, this provision favors recent homebuyers facing market-value property taxes relative to longtime owners with constitutionally limited assessed valuations. It also mitigates to some degree Prop 13’s lock-in effect by reducing the effective property tax rate for those who purchase new homes.

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Next Week’s Tax Workshops

Monday, November 13: Miranda Stewart (Melbourne) will present The Future of Tax Jurisdiction as part of the Boston College Tax Policy Collaborative. If you would like to attend, please contact James Repetti or Diane Ring.

Monday, November 13: Goldburn P. Maynard, Jr. (Indiana-Kelley Business School; Google Scholar) will present Unfulfilled Promises of the FinTech Revolution, 111 Cal. L. Rev. ___ (2023) (with Lindsay Sain Jones (Georgia-Terry Business School; Google Scholar)) as part of the Boston College Tax Policy Collaborative. If you would like to attend, please contact James Repetti or Diane Ring.

Monday, November 13: Kirk J. Stark (UCLA) will present Retrofitting Prop 13 through the Income Tax as part of the San Diego Tax Law Speaker Series. If you would like to attend, please contact Miranda Fleischer. 

Tuesday, November 14: Deanna Newton (Pepperdine) will present Closing the Opportunity Gap as part of the Pepperdine Faculty Workshop Series. If you would like to attend, please contact Jacob Charles. 

Tuesday, November 14: Ajay Mehrotra (Northwestern; Google Scholar) will present The Missing U.S. Vat: Economic Inequality, American Fiscal Exceptionalism, and the Historical U.S. Resistance to National Consumption Taxes as part of the NYU Tax Policy and Public Finance Colloquium. If you would like to attend, please contact Daniel Shaviro. 

Thursday, November 16: Alisa Tazhitdinova (UC-Santa Barbara; Google Scholar) will present Understanding Capital Gains Responses to Taxes Using Transaction-Level Data as part of the Columbia Davis Polk & Wardwell Tax Policy Colloquium. If you would like to attend, please contact Michael Love.

Friday, November 17: Sarah Lawsky (Northwestern; Google Scholar) will present Reasoning with Formalized Statutes: The Case of Capital Gains and Losses as part of the Boston College Tax Policy Collaborative. If you would like to attend, please contact James Repetti or Diane Ring.

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Kim Presents Taxing The Metaverse Today At St. Louis

Young Ran (Christine) Kim (Cardozo; Google Scholar) presents Taxing the Metaverse, 112 Geo. L.J. ___ (2024), at St. Louis today as part of its Faculty Workshop hosted by Henry Ordower:

The buzz surrounding the Metaverse has been growing steadily for the past couple of years, but the tax implications of this novel ecosystem remain fuzzy to most tax scholars. Such uncertainty is concerning, given the potential and momentum of this emerging technology. Although the Metaverse evolved from online video games focused only on user consumption, it now allows users to produce income and accumulate wealth entirely within the Metaverse. Current law seems to defer taxation of such until a realization or cash-out event. This paper challenges this approach.

This paper offers novel arguments justifying Metaverse taxation. Because economic activity within the Metaverse satisfies the Haig-Simons and Glenshaw Glass definitions of income, its exclusion will create a tax haven. Tax policy can also play an essential role in regulating the virtual economy. Furthermore, this emerging technology allows policymakers to modernize the tax system. 

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McQuillan Presents The Health Wedge And Labor Market Inequality Today At Loyola-L.A.

Casey McQuillan (Ph.D. Candidate, Princeton) presents The Health Wedge and Labor Market Inequality (with Amy Finklestein (MIT), Owen Zidar (Princeton) & Eric Zwick (Chicago)) at Loyola-L.A. today as part of its Tax Policy Colloquium hosted by Katie Pratt:

The uniquely American approach to providing health insurance through employers is a little-recognized but important driver of increasing labor market inequality, suggests a paper discussed at the Brookings Papers on Economic Activity (BPEA) conference on March 31.

The authors—Amy Finkelstein of the Massachusetts Institute of Technology, Casey McQuillan and Owen Zidar of Princeton University, and Eric Zwick of the University of Chicago—use a stylized model of the labor market to compare the current system, in which about half of Americans are covered by employer-provided health insurance, to a hypothetical system in which health insurance is financed by a payroll tax, similar in spirit to the universal health insurance in countries such as Germany and Canada.

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Next Week’s Tax Workshops

Monday, November 6: Casey McQuillan (Princeton) will present The Health Wedge and Labor Market Inequality (with Amy Finklestein (MIT), Owen Zidar (Princeton) & Eric Zwick (Chicago)) as part of the Loyola-L.A. Tax Policy Colloquium. If you would like to attend, please RSVP here. 

Thursday, November 9: Nyamagaga Gondwe (Wisconsin; Google Scholar) will present No Exit: How Tax-Based Welfare Reform Influences Cycles of Intimate Partner Violence Victimization as part of the Columbia Davis Polk & Wardwell Tax Policy Colloquium. If you would like to attend, please contact Michael Love. 

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Field Presents Tax Enforcement By The Private Sector: Deputizing Tax Insurers Today At San Diego

Heather Field (UC-San Francisco; Google Scholar) presents Tax Enforcement by the Private Sector: Deputizing Tax Insurers, 99 Ind. L. J. _ (2024), at San Diego today as part of its Tax Law Speaker Series hosted by Miranda Fleischer:

The IRS is outgunned when trying to ensure compliance by large corporations and other sophisticated taxpayers.  The private sector can help.  Private sector actors, such as financial institutions, employers, and whistleblowers, have been valuable allies in the IRS’s efforts to improve compliance and enforcement.  This Article argues for using another, largely overlooked, private sector party—tax insurers—to expand the IRS’s enforcement abilities.  Tax insurers insure sophisticated taxpayers’ uncertain tax positions (e.g., the tax-free treatment of a corporate spinoff or tax credits critical to a renewable energy project).  For a premium, a tax insurer agrees to pay any additional taxes owed with interest and penalties (up to the policy limit) if an insured tax position is successfully challenged by a tax authority.  The tax insurance industry has grown dramatically since the mid-2010s, but scholars and policymakers pay little attention to its enforcement-enhancing potential.  

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Dyreng Presents Tax Deficits And The Income Shifting Of U.S. Multinationals Today At Duke

Scott Dyreng (Duke-Fuqua; Google Scholar) presents Tax Deficits and the Income Shifting of U.S. Multinationals (with Robert Hills (Penn State; Google Scholar) & Kevin Markle (Michigan State; Google Scholar)) at Duke today as part of its Faculty Workshop Series: 

Significant controversy has emerged about the scope of the international tax planning of U.S. multinational firms, with estimates of income shifted out of the U.S., profits recognized in tax havens, and revenue loss ballooning over time. Most studies that derive these empirical estimates use macroeconomic data which support inferences drawn at an aggregate level but are not conducive to analyses at more granular levels. In this study, we use microeconomic data from firms’ publicly available financial statements to derive firm-year estimates that we use to evaluate existing aggregate estimates. We find that many estimates based on macroeconomic data are significantly overstated. We also use our firm-year estimates to analyze the distributions of these amounts within the economy. We show that all dimensions of international tax planning are concentrated in three industries and dominated by a small number of very large firms.

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Chater Presents How Focusing On Individual-Level Solutions Has Led Behavioral Public Policy Astray Today At Loyola-L.A.

Nick Chater (Warwick; Google Scholar) presents The i-Frame and the s-Frame: How Focusing on Individual-Level Solutions Has Led Behavioral Public Policy Astray (with George Loewenstein (Carnegie Mellon; Google Scholar)) at Loyola-L.A. today as part of its Tax Policy Colloquium hosted by Katie Pratt:

An influential line of thinking in behavioral science, to which the two authors have long subscribed, is that many of society’s most pressing problems can be addressed cheaply and effectively at the level of the individual, without modifying the system in which individuals operate. Along with, we suspect, many colleagues in both academic and policy communities, we now believe this was a mistake. Results from such interventions have been disappointingly modest. But more importantly, they have guided many (though by no means all) behavioral scientists to frame policy problems in individual, not systemic, terms: to adopt what we call the “i-frame,” rather than the “s-frame.” The difference may be more consequential than those who have operated within the i-frame have understood, in deflecting attention and support away from s-frame policies. Indeed, highlighting the i-frame is a long-established objective of corporate opponents of concerted systemic action such as regulation and taxation. 

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Next Week’s Tax Workshops

Monday, October 30: Nick Chater (Warwick; Google Scholar) will present The i-Frame and the s-Frame: How Focusing on Individual-Level Solutions Has Led Behavioral Public Policy Astray (with George Loewenstein (Carnegie Mellon; Google Scholar))  as part of the Loyola-L.A. Tax Policy Colloquium. If you would like to attend, please contact Katie Pratt. 

Wednesday, November 1: Scott Dyreng (Duke-Fuqua; Google Scholar) will present Tax Deficits and the Income Shifting of U.S. Multinationals (with Robert Hills (Penn State; Google Scholar) & Kevin Markle (Michigan State; Google Scholar)) as part of the Duke Faculty Workshop Series. 

Thursday, November 2: Heather Field (UC-San Francisco; Google Scholar) will present Tax Enforcement by the Private Sector: Deputizing Tax Insurers, 99 Ind. L. J. _ (2024), as part of the San Diego Tax Law Speaker Series. If you would like to attend, please contact Miranda Fleischer.

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Clausing Presents Capital Taxation And Market Power Today At NYU

Kimberly Clausing (UCLA; Google Scholar) presents Capital Taxation And Market Power at NYU today as part of its Tax Policy and Public Finance Colloquium hosted by Daniel Shaviro:

In recent decades, market power has increased substantially, according to multiple measures that describe industry concentration, mark-ups, and business profitability. While market power can generate benefits, it also raises vexing policy concerns, including the potential for adverse effects on labor markets, income inequality, and the dynamism of market competition. The concept of market power also has implications for how we conceptualize capital income, making it important to distinguish between normal and above-normal returns to capital. The tax system taxes both types of returns to capital, but often imperfectly and incompletely. Full consideration of the relationship between market power and capital income suggests important implications for optimal capital taxation design, including the role of entity taxation, the use of graduated business tax rates, and international tax reform.

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Brooks Presents The Sixteenth Amendment And Congress’s Income Tax Power Today At San Diego

John (Jake) Brooks (Fordham; Google Scholar) presents The Sixteenth Amendment And Congress’s Income Tax Power (with David Gamage (Indiana-Maurer; Google Scholar)) at San Diego today as part of its Tax Law Speaker Series hosted by Miranda Fleischer: 

The upcoming Supreme Court case of Moore v. United States raises questions that the Court has rarely had to address in the last 100 years—what is the meaning of the Sixteenth Amendment and Congress’s income tax power? Does that power only extend to realized income? And what does "realization" mean? The taxpayers in Moore (and the Ninth Circuit judges who dissented from the denial of rehearing en banc) argue that realization is necessarily a part of the meaning of “income” in the Sixteenth Amendment—i.e., that there must be some act of separation or conversion of property into cash or other property in order for there to be “income.” They are, in essence, aiming to revive a disputed reading of the discredited 1920 case of Eisner v. Macomber.

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Brauner Presents Taxing People, Not Residents Today At Loyola-L.A.

Yariv Brauner (Florida; Google Scholar) presents Taxing People, Not Residents at Loyola-L.A. today as part of its Tax Policy Colloquium hosted by Katie Pratt:

Essentially all states tax their residents’ worldwide income. This norm is difficult to justify beyond vague notions of state provided benefits enjoyed by residents. Past limited mobility of individuals curbed challenges to the desirability of residence taxation. Recent increased mobility (particularly mobility of wealthy individuals) and the growing importance of remote work and digital nomadism renew such challenges, especially in light of multiple new tax residence schemes, such as residence-for- investment and non domicile residence (non) taxation, that deviate from traditional ideas of residence.

The erosion of individual tax residence in the twenty-first century raises the question of alternatives. This draft examines whether exclusive source taxation of individuals could replace the existing rules which are based on a compromise between residence and source taxation. 

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Next Week’s Tax Workshops

Monday, October 23: Yariv Brauner (Florida; Google Scholar) will present Taxing People, Not Residents as part of the Loyola-L.A. Tax Policy Colloquium. If you would like to attend, please contact Katie Pratt. 

Monday, October 23: John (Jake) Brooks (Fordham; Google Scholar) will present The Sixteenth Amendment And Congress’s Income Tax Power (with David Gamage (Indiana-Maurer; Google Scholar)) as part of the San Diego Tax Law Speaker Series. If you would like to attend, please contact Miranda Fleischer. 

Tuesday, October 24: Kimberly Clausing (UCLA; Google Scholar) will present Capital Taxation And Market Power as part of the NYU Tax Policy and Public Finance Colloquium. If you would like to attend, please contact Daniel Shaviro. 

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Polsky Presents U.S. Taxation Of Private Equity And Venture Capital Today At Florida

Gregg D. Polsky (Georgia; Google Scholar) presents U.S. Taxation of Private Equity and Venture Capital at Florida today as part of its Tax Colloquium hosted by Yariv Brauner:

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Agrawal Presents State & Local Governments As Tax Havens? Today At University Of British Columbia

David R Agrawal (Kentucky; Google Scholar) presents Hidden Havens: State and Local Governments as Tax Havens? at Peter A. Allard School of Law, University of British Columbia today as part of itsTax Law and Policy Speaker Series hosted by Wei Cui:

An international tax haven is usually a low-tax jurisdiction that seeks to attract investment by foreign investors. But, there are many state and local jurisdictions within federal systems that set zero tax rates on personal or corporate income, consumption, property, and wealth in an effort to attract activity from other high-tax jurisdictions. This paper discusses whether subnational tax havens are distinct from intense tax competition, and concludes that in a federal system, the economic implications of the two may be similar, but the policy responses differ subtly. 

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Fleischer Presents Tax Optics: The Inflation Reduction Act Of 2022 Today At Columbia

Victor Fleischer (UC-Irvine; Google Scholar) presents Tax Optics: The Inflation Reduction Act of 2022 at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium hosted by Michael Love: 

This Article argues that understanding optics—how legislation appears to average voters, as opposed to how it appears to experts—is critical to understanding how and why the tax legislation that makes it into law looks so different from the tax policy preferences of Congressional and Treasury staff, academics and other policy experts.

This Article evaluates the Inflation Reduction Act through the lens of tax optics. I argue that optics, not policy or politics alone, best explains why the final bill looks like it does.

To illustrate my argument, I start with one part of the Build Back Better agenda that did not make it into law—carried interest reform—before turning to the Inflation Reduction Act. Each section of the Inflation Reduction Act reflects, at least in part, the importance of optics in the modern tax legislative process. In concrete ways, the resulting legislation takes advantage of common errors in tax policy analysis, such as focusing on tax rates rather than the tax base, focusing on the nominal incidence of a tax rather than the economic incidence of a tax, and discounting the perceived cost of tax expenditures compared to direct spending.

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Christians Presents Taxing Big Data When the United States Disagrees Today At UC-San Francisco

Allison Christians (McGill; Google Scholar) presents Taxing Big Data When the United States Disagrees (with Tarcísio Diniz Magalhães (Antwerp; Google Scholar)) at UC-San Francisco today as part of its Tax Speaker Series:

Why might countries seek to tax Big Data, and if there are good reasons to do so, what kind of rules would be most feasible to adopt without contravening the existing global legal architecture? A number of countries have begun imposing stand-alone digital services taxes pending multilateral agreement on a coordinated solution (aka pillar 1). But if pillar 1 fails to materialize, the United States and U.S. firms will likely seek redress against these unilateral taxes through trade and investment regimes. This Article argues that alternative legal approaches might be less exposed to the same pushback. In particular, unilaterally extending domestic withholding tax regimes to specified digital services fees might be the best option to tax Big Data when the United States disagrees. 

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Mehrotra Presents Economic Implications Of The Climate Provisions Of The Inflation Reduction Act Today At Loyola-L.A.

Neil Mehrotra (Federal Reserve Bank of Minneapolis; Google Scholar) presents Economic Implications of the Climate Provisions of the Inflation Reduction Act (with John Bistline (Electric Power Research Institute) & Catherine Wolfram (MIT)) at Loyola-L.A. today as part of its Tax Policy Colloquium hosted by Katie Pratt:

The climate provisions of the Inflation Reduction Act (IRA) signed by President Biden in August could dramatically transform the energy sector of the U.S. economy, but the costs and the extent of new investment are highly uncertain, suggests a paper discussed at the Brookings Papers on Economic Activity (BPEA) conference on March 30, 2023.

“The problem IRA confronts is massive—re-orienting the way the U.S. and global economies produce and consume energy,” write the authors—John Bistline of the Electric Power Research Institute, Neil R. Mehrotra of the Federal Reserve Bank of Minneapolis, and Catherine Wolfram of Harvard University (on leave from the University of California-Berkeley). “IRA’s incentives span the entire energy sector, from producers of raw materials to end-use consumers, and will set considerable new forces in motion.”

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Next Week’s Tax Workshops

Monday, October 16: Neil Mehrotra (Federal Reserve Bank of Minneapolis; Google Scholar) will present Economic Implications of the Climate Provisions of the Inflation Reduction Act (with John Bistline (Electric Power Research Institute) & Catherine Wolfram (MIT)) as part of the Loyola-L.A. Tax Policy Colloquium. If you would like to attend, please RSVP here. 

Tuesday, October 17: Allison Christians (McGill; Google Scholar) will present Taxing Big Data When the United States Disagrees (with Tarcísio Diniz Magalhães (Antwerp; Google Scholar)) as part of the UC-San Francisco Tax Speaker Series. If you would like to attend, please contact Heather Field. 

Tuesday, October 17: David M. Schizer (Columbia) will present Red, White, and Blue—and Also Green: How Energy Policy Can Protect Both National Security and the Environment as part of the the UBC Tax Law and Policy Speaker Series. If you would like to attend, please contact Wei Cui. 

Thursday, October 19: Victor Fleischer (UC-Irvine; Google Scholar) will present Tax Optics: The Inflation Reduction Act of 2022 as part of the Columbia Davis Polk & Wardwell Tax Policy Colloquium. If you would like to attend, please contact Michael Love.

Friday, October 20: Gregg D. Polsky (Georgia; Google Scholar) will present as part of the Florida Tax Colloquium. If you would like to attend, please contact Yariv Brauner. 

Friday, October 20: David R Agrawal (Kentucky; Google Scholar) will present Hidden Havens: State and Local Governments as Tax Havens? as part of the UBC Tax Law and Policy Speaker Series. If you would like to attend, please contact Wei Cui. 

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Givati Presents Tax Law Enforcement And Redistributive Politics Today At Columbia

Yehonatan Givati (Hebrew University) presents Tax Law Enforcement and Redistributive Politics (with Andrew Hayashi (Virginia; Google Scholar)) at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium hosted by Michael Love:

The Inflation Reduction Act signed by President Biden on August 16, 2022, allocated $80 billion in additional funding for the IRS. While Democrats unanimously supported the bill, not a single Republican voted in favor of it. The first legislation advanced by the new Republican majority this year was to repeal this increase in IRS funding. Given the diminished state of IRS enforcement capacity, increasing the resources devoted to tax enforcement seems like an obvious imperative without a clear partisan valence. One might think that political and ideological battles would be fought over what the tax law is, not whether the IRS has the resources to enforce it. But IRS funding has become a major political point of contention. Why is tax law enforcement such a partisan issue?

In this Article we propose an answer. We argue that the income tax is the primary instrument for income redistribution, and so the efficacy of tax enforcement shapes people’s support for redistribution. When the IRS makes sure people pay their taxes, support for income redistribution increases. And when the IRS is unable to enforce the nation’s tax laws, support for income redistribution decreases. Thus, for political progressives increasing tax enforcement generates a double dividend. It both provides more funds for redistribution and also increases political support for redistribution, which can then be translated into redistributive changes to the tax law. For symmetric reasons, reducing tax enforcement generates a double dividend for those who disfavor income redistribution.

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Bearer-Friend Presents Race-Based Tax Weapons Today At NYU

Jeremy Bearer-Friend (George Washington; Google Scholar) presents Race-Based Tax Weapons, 14 U.C. Irvine L. Rev. __ (2023), at NYU today as part of its Tax Policy and Public Finance Colloquium hosted by Daniel Shaviro: 

In the United States, the term “poll tax” often refers to a very specific tactic of white supremacy: the use of tax policy to prevent voting by Black citizens. While “poll tax” is an accurate descriptor of these taxes, poll taxes have a much more expansive history within the twentieth century. Following in the rich tradition of comparative tax scholarship that looks at multiple jurisdictions to arrive at broader tax policy conclusions, this Article examines four distinct poll taxes applied by Anglophone governments in the twentieth century to illustrate a broad phenomenon I call “tax weapons”—the use of tax policy to harm political adversaries.

The primary contribution of this comparative research on twentieth century poll taxes is to further demonstrate how universal language in tax statutes can be used to effectively target political rivals, with a focus on the targeting of taxpayers by race, ethnicity, or ancestry. By contrasting two poll taxes where race, ethnicity, or ancestry are explicitly mentioned in the law with two poll taxes where there is no mention of race, ethnicity, or ancestry, I uncover that the poll taxes that do not mention specific targets can be equally effective—if not more effective—at achieving discriminatory goals than poll taxes that specify their targets.

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Brauner Presents Taxing People, Not Residents Today At Florida

Yariv Brauner (Florida; Google Scholar) presents Taxing People, Not Residents at Florida today as part of its Marshall M. Criser Distinguished Internal Faculty Workshop:

Essentially all states tax their residents’ worldwide income. This norm is difficult to justify beyond vague notions of state provided benefits enjoyed by residents. Past limited mobility of individuals curbed challenges to the desirability of residence taxation. Recent increased mobility (particularly mobility of wealthy individuals) and the growing importance of remote work and digital nomadism renew such challenges, especially considering multiple new tax residence schemes, such as residence-for-investment and non-domicile residence (non) taxation, that deviate from traditional ideas of residence.

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Next Week’s Tax Workshops

Monday, October 9: Yariv Brauner (Florida; Google Scholar) will present Taxing People, Not Residents as part of the Florida Marshall M. Criser Distinguished Faculty Workshop. If you would like to attend, please contact Yariv Brauner. 

Tuesday, October 10: Jeremy Bearer-Friend (George Washington; Google Scholar) will present Race-Based Tax Weapons, 14 U.C. Irvine L. Rev. __ (2023), as part of the NYU Tax Policy and Public Finance Colloquium. If you would like to attend, please contact Daniel Shaviro. 

Thursday, October 12:  Yehonatan Givati (Hebrew University) will present Tax Law Enforcement and Redistributive Politics (with Andrew Hayashi (Virginia; Google Scholar)) as part of the Columbia Davis Polk & Wardwell Tax Policy Colloquium. If you would like to attend, please contact Michael Love. 

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Sugin Presents Proxy Taxes Today At Boston College

Linda Sugin (Fordham; Google Scholar) presents Proxy Taxes at Boston College today as part of its Tax Policy Workshop hosted by Jim Repetti and Diane Ring:

This article offers a conceptual and theoretical framework for seemingly oddball and unprincipled provisions in the Internal Revenue Code, praising them for increasing progressivity and producing revenue. “Proxy taxes” impose liability on taxpayers with ability to pay who are connected, in some way, to income earners who pay insufficient or no tax on that income. Given the combination of rising income and wealth inequality and the political impossibility of raising taxes on income in a straightforward way, policymakers should embrace proxy taxes as a flexible solution to a pressing tax justice problem. This article argues that proxy taxes contribute to a more comprehensive income tax system, despite their departure from classic income tax principles, and can also be more efficient than higher taxes imposed on income.

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Sarin Presents The Coming Fiscal Cliff: A Blueprint For Tax Reform In 2025 Today At Columbia

Natasha Sarin (Yale; Google Scholar) presents The Coming Fiscal Cliff: A Blueprint for Tax Reform in 2025 (with Kimberly Clausing (UCLA; Google Scholar)) at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium hosted by Michael Love:

At the end of 2025, almost all of the individual, estate, and pass-through provisions of the Tax Cuts and Jobs Act (TCJA) will expire. This looming expiration creates an important opportunity to improve tax policy along multiple dimensions at the same time that TCJA provisions are evaluated for possible extension. In this paper, we suggest four key principles to guide tax policy choices in 2025: first, reforms should raise revenue on net, improving fiscal sustainability; second, reforms should respond to persistent inequalities by increasing the progressivity of the tax code; third, reforms should work to reduce tax-based inefficiencies in the code, and finally, reforms should address global collective action problems such as climate change and tax competition. Using these principles as a guide, we then evaluate possible TCJA extensions and consider a menu of revenue-raising reforms that together have the potential to raise about $3.5 trillion over the coming decade, while improving the progressivity and efficiency of the tax system.

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Raghavan & Herrine Present Two Papers Today At Loyola-L.A.

Vijay Raghavan (Brooklyn) and Luke Herrine (Alabama) present two papers at Loyola-L.A. today as part of its Tax Policy Colloquium hosted by Ted Seto. 

Vijay Raghavan, The Case Against The Debt Tax, 91 Fordham L. Rev. 1849 (2023): 

Americans are increasingly agitating for debt relief. In the last decade, there have been national campaigns to cancel student debt, credit card debt, and mortgage debt. These national campaigns have paralleled local efforts to cancel taxi medallion debt, carceral debt, and lunch debt. But as the public increasingly pursues broad-scale debt relief outside bankruptcy, they face an important institutional obstacle: canceled debt is generally taxable.

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Next Week’s Tax Workshops

Monday, October 2: Vijay Raghavan (Brooklyn) will present The Case Against The Debt Tax, 91 Fordham L. Rev. 1849 (2023), and Reconsidering the Tax Treatment of COD Income (with Luke Herrine (Alabama)), as part of the Loyola-L.A. Tax Policy Colloquium. If you would like to attend, please RSVP here. 

Thursday, October 5: Natasha Sarin (Yale; Google Scholar) will present The Coming Fiscal Cliff: A Blueprint for Tax Reform in 2025 (with Kimberly Clausing (UCLA; Google Scholar)) as part of the Columbia Davis Polk & Wardwell Tax Policy Colloquium. If you would like to attend, please contact Michael Love. 

Friday, October 6: Linda Sugin (Fordham; Google Scholar) will present Proxy Taxes as part of the Boston College Tax Policy Workshop. If you would like to attend, please contact Jim Repetti or Diane Ring. 

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Brooks Presents The Sixteenth Amendment And The Meaning Of ‘Income’ Today At Columbia

John Brooks (Fordham; Google Scholar) presents The Sixteenth Amendment and the Meaning of "Income" (with David Gamage (Indiana-Maurer; Google Scholar)) at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium hosted by Michael Love:

The upcoming Supreme Court case of Moore v. United States raises questions that the Court has rarely had to address in the last 100 years—what is the meaning of income under the Sixteenth Amendment, and of the Sixteenth Amendment generally? And furthermore, is realization required before the gain from property ownership can be treated as income? And what does realization mean? The taxpayers in Moore (and the Ninth Circuit judges who dissented from the denial of rehearing en banc) argue that realization is necessarily a part of the meaning of “income” in the Sixteenth Amendment—i.e., that there must be some act of separation or conversion of property into cash or other property in order for there to be “income.” They are, in essence, aiming to revive a disputed reading of the discredited 1920 case of Eisner v. Macomber.

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Kysar Presents The Global Tax Deal And The New International Economic Order Today At NYU

Rebecca Kysar (Fordham; Google Scholar) presents The Global Tax Deal and the New International Economic Order at NYU today as part of its Tax Policy and Public Finance Colloquium hosted by Daniel Shaviro:

The ethos of economic integration and trade liberation no longer reigns supreme. Instead of multilateral trade agreements, nations are turning towards protectionism and unilateralism. Yet in late 2021, nearly 140 countries agreed to a new international tax system that is aimed at levelling the playing field among them, curtailing competition on corporate tax rates and corporate profit shifting to tax havens through a new global minimum tax as well as constructing a new allocation of taxing rights among nations.

Although multilateral trade agreements now seem out of reach, tax multilateralism is ascendant. This is surprising given the deep connection between taxation and national sovereignty. It also perplexing since international tax does not exhibit the same theoretical harmony between national and worldwide welfare that international trade enjoys. The traditional account offered by economists is that trade liberalization is a rising tide that will lift all boats because countries will produce according to their competitive advantages and trade the rest, making trade suitable for international coordination. In contrast, tax is largely described as a zero-sum contest for a fixed pot of tax revenues, deeming it ill-suited for collective action.

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Next Week’s Tax Workshops

Tuesday, September 26: Rebecca Kysar (Fordham; Google Scholar) will present The Global Tax Deal and the New International Economic Order as part of the NYU Tax Policy and Public Finance Colloquium. If you would like to attend, please contact Daniel Shaviro. 

Thursday, September 28:  John Brooks (Fordham; Google Scholar) will present The Sixteenth Amendment and the Meaning of "Income" (with David Gamage (Indiana-Maurer; Google Scholar)) as part of the Columbia Davis Polk & Wardwell Tax Policy Colloquium. If you would like to attend, please contact Michael Love.

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Avi-Yonah Presents Taxing Nomads: Reviving Citizenship-Based Taxation For The 21st Century Today At Boston College

Reuven Avi Yonah (Michigan; Google Scholar) presents Taxing Nomads: Reviving Citizenship-Based Taxation for the 21st Century at Boston College today as part of its Tax Policy Collaborative hosted by James Repetti and Diane Ring.

The COVID pandemic and the rise of zooming has increased the ability of many people (primarily the rich) to work remotely. This in turn has led to more people moving to other countries to benefit from the ability to work remotely while enjoying other benefits such as lower housing prices, a more leisurely lifestyle, and in some cases greater political stability. Many Americans have used their newfound freedom to move overseas, e.g., to Italy. They and others like them are the new nomads.

Such a move is not tax motivated because Italy has higher personal tax rates than the US. It does, however, raise interesting tax issues because the US (uniquely) imposes worldwide taxation on its citizens wherever they live, while Italy (like most countries) does not tax non-resident citizens but taxes its residents on worldwide income regardless of their citizenship status.

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Osofsky Presents Legitimacy And Tax Enforcement Today At Florida

Leigh Osofsky (North Carolina; Google Scholar) presents Legitimacy and Tax Enforcement, 61 Harv. J. on Leg. __ (2024) (with Joshua D. Blank (UC-Irvine; Google Scholar)) at Florida today as part of its Tax Colloquium hosted by Yariv Brauner:

One of the most powerful charges that can be leveled against the IRS is that it is targeting taxpayers. Charges of political targeting have dogged the IRS for over a century, including in major controversies such as the so-called Tea Party auditing scandal in 2013. Commentators and scholars have long-critiqued the IRS for focusing audit resources on some of the lowest-income Americans. And, most recently, a group of researchers estimated that the IRS audits Black taxpayers at a 2.9 to 4.7 times greater rate, as compared to non-Black taxpayers. In response, legislators demanded action, there was widespread public consternation, and IRS officials stated that they were “deeply concerned by these findings.” These, and other, controversies suggest deep disdain for the targeting of taxpayers by the IRS.

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Goldin Presents Measuring And Mitigating Racial Disparities In Tax Audits Today At Columbia

Jacob Goldin (Chicago; Google Scholar) presents Measuring and Mitigating Racial Disparities in Tax Audits (with Hadi Elzayn (Stanford; Google Scholar), Evelyn Smith (Michigan), Thomas Hertz (U.S. Treasury), Arun Ramesh (Chicago), Robin Fisher (U.S. Treasury) & Daniel E. Ho (Stanford)) at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium hosted by Michael Love:

Government agencies around the world use data-driven algorithms to allocate enforcement resources. Even when such algorithms are formally neutral with respect to protected characteristics like race, there is widespread concern that they can disproportionately burden vulnerable groups. We study differences in Internal Revenue Service (IRS) audit rates between Black and non-Black taxpayers. Because neither we nor the IRS observe taxpayer race, we propose and employ a novel partial identification strategy to estimate these differences. Despite race-blind audit selection, we find that Black taxpayers are audited at 2.9 to 4.7 times the rate of non-Black taxpayers. The main source of the disparity is differing audit rates by race among taxpayers claiming the Earned Income Tax Credit (EITC). Using counterfactual audit selection models for EITC claimants, we find that maximizing the detection of underreported taxes would not lead to Black taxpayers being audited at higher rates.

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Newton Presents Closing The Opportunity Gap Today At UC-San Francisco

Deanna Newton (Pepperdine) presents Closing the Opportunity Gap at UC-San Francisco today as part of its Tax Speaker Series hosted by Heather Field:

Opportunity Zones are low-income areas or economically distressed communities in the United States. The Opportunity Zone program encourages investment in low-income areas or economically distressed communities by offering investors tax benefits. Scholars have found little evidence that Opportunity Zones positively impact zone residents’ lives, concluding that Opportunity Zone legislation mostly benefits wealthy investors and should be reformed to benefit community members better. Investors are currently not required to finance projects geared toward the needs of local communities; they are instead funding developments they would have already invested in, whether located in an Opportunity Zone or not. This Article argues that current reform efforts and related scholarship do not give adequate weight to active and direct participation by community members and investors as it relates to economic development tax incentives. It argues for a comprehensive framework that focuses on active, direct, and transformative participation by community members and investors.

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Dean Presents Global Jim Crow: Taxation And Racial Capitalism At Boston University

Steven Dean (Boston University) presents his forthcoming book Global Jim Crow: Taxation And Racial Capitalism (Oxford University Press) at Boston University today as part of its Congresswoman Barbara Jordan Speaker Series on Race, Law, and Inequality (register here):

What makes some nations rich and others poor? Why do even the most powerful states struggle to tax giant multinationals? One answer to both questions lies in a system of Global Jim Crow created as a response to fears over the rise of sovereign African states in the late 1950s and 1960s. For more than half a century, the Organization for Economic Cooperation and Development has shielded multinationals from taxation, doing its job so well that even the wealthiest states lack urgently needed tax revenues. More than six decades into its existence, the OECD has still never had a majority-Black member and continues to exploit anti-Black racism to preserve its power.

Congresswoman Barbara Jordon Speaker Series on Race, Law & Inequality
Despite the laudable ideals expressed by this nation’s founders, US law has routinely been written, enacted, and interpreted by those in power in ways that reinforce, rather than dismantle, racial inequality. In this sense, law has become one part of the structures in which racism is embedded. This structural racism touches upon every area of the law, and nearly 250 years into this democratic experiment that is the United States, people of color have still not gained full and equal membership in US society. 

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Kysar Presents The Global Tax Deal And Its Implications Today At Loyola-L.A.

Rebecca Kysar (Fordham; Google Scholar) presents The Global Tax Deal and Its Implications at Loyola-L.A. today as part of its Tax Policy Colloquium hosted by Katie Pratt and Ted Seto:

The ethos of economic integration and trade liberation no longer reigns supreme. Instead of multilateral trade agreements, nations are turning towards protectionism and unilateralism. Yet in late 2021, nearly 140 countries agreed to a new international tax system that is aimed at levelling the playing field among them, curtailing competition on corporate tax rates and corporate profit shifting to tax havens through a new global minimum tax as well as constructing a new allocation of taxing rights among nations.

Although multilateral trade agreements now seem out of reach, tax multilateralism is ascendant. This is surprising given the deep connection between taxation and national sovereignty. It also perplexing since international tax does not exhibit the same theoretical harmony between national and worldwide welfare that international trade enjoys. The traditional account offered by economists is that trade liberalization is a rising tide that will lift all boats because countries will produce according to their competitive advantages and trade the rest, making trade suitable for international coordination. In contrast, tax is largely described as a zero-sum contest for a fixed pot of tax revenues, deeming it ill-suited for collective action.

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Next Week’s Tax Workshops

Monday, September 18: Deanna  Newton (Pepperdine) will present Opportunity Gap as part of the UC-San Francisco Tax Speaker Series. If you would like to attend, please contact Heather Field.

Monday, September 18: Rebecca Kysar (Fordham; Google Scholar) will present The Global Tax Deal and Its Implications as part of the Loyola-L.A. Tax Policy Colloquium. If you would like to attend, please RSVP here. 

Monday, September 18: Steven Dean (Boston University) will present Global Jim Crow: Taxation and Racial Capitalism (Oxford University Press 2023) as part of the Boston University Congresswoman Barbara Jordan Speaker Series On Race, Law, & Inequality. If you would like to attend, please RSVP here. 

Thursday, September 21: Jacob Goldin (Chicago; Google Scholar) will present Measuring and Mitigating Racial Disparities in Tax Audits  (with Hadi Elzayn (Stanford; Google Scholar), Evelyn Smith (Michigan), Thomas Hertz (U.S. Treasury), Arun Ramesh (Chicago), Robin Fisher (U.S. Treasury) & Daniel Ho (Stanford)) as part of the Columbia Davis Polk & Wardwell Tax Policy Colloquium. If you would like to attend, please contact Michael Love.

Friday, September 22: Reuven Avi Yonah (Michigan; Google Scholar) will present Taxing Nomads: Reviving Citizenship-Based Taxation for the 21st Century as part of the Boston College Tax Policy Collaborative. If you would like to attend, please contact Jim Repetti or Diane Ring. 

Friday, September 22: Leigh Osofsky (North Carolina; Google Scholar) will present Legitimacy and Tax Enforcement, 61 Harv. J. on Leg. __ (2024) (with Joshua D. Blank (UC-Irvine; Google Scholar)) as part of the Florida Tax Colloquium. If you would like to attend, please contact Yariv Brauner. 

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Kim Presents Taxing The Metaverse Today At Columbia

Young Ran (Christine) Kim (Cardozo; Google Scholar) presents Taxing the Metaverse, 112 Geo. L.J. __ (2024) at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium hosted by Michael Love:

The buzz surrounding the Metaverse has been growing steadily for the past couple of years, but the tax implications of this novel ecosystem remain fuzzy to most tax scholars. Such uncertainty is concerning, given the potential and momentum of this emerging technology. Although the Metaverse evolved from online video games focused only on user consumption, it now allows users to produce income and accumulate wealth entirely within the Metaverse. Current law seems to defer taxation of such until a realization or cash-out event. This paper challenges this approach.

This paper offers novel arguments justifying Metaverse taxation. Because economic activity within the Metaverse satisfies the Haig-Simons and Glenshaw Glass definitions of income, its exclusion will create a tax haven. Tax policy can also play an essential role in regulating the virtual economy. Furthermore, this emerging technology allows policymakers to modernize the tax system. 

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