This Article analyzes the behavioral economics literatures on how individuals understand taxation (i.e., tax salience). We evaluate how taxpayers respond to different presentations of tax prices both in their roles as market participants and as voters. We aim to combat several naïve notions...

The reverberations of the tax revolt that began in California in 1978 remain very much with us. Taxes were cut dramatically first in California, then throughout the country at the state level, and then at the federal level. The tax revolt has generated a huge literature in the legal academy (and...

Proposition 13 and successive state constitutional limitations on property taxes put California cities in a fiscal bind. Cities responded by making developers pay “up front” for the cost of infrastructure and other public services. Impact fees, affordable-housing mandates and ad-hoc...

The near adoption of Worldwide Combined Reporting (WWCR) in Minnesota has led to a blizzard of critical claims about WWCR from corporate tax lobbyists, the Tax Foundation, and the editorial board of the Wall Street Journal. These various groups have made a number of policy arguments that do not...

This Note aims to enable better appeals to equity through advancing four theses about the history and the concept of equity. The four theses are as follows:1) Aristotle's account of equity (epieikeia) has been received into the western legal tradition many times and this reception is ongoing...

This article argues for the contemporary relevance of Aristotle's doctrine of equity. Too often, similar arguments make this doctrine relevant by abstracting from the details of Aristotle's position or, conversely, fixating on details without due consideration of the epochal gap that separates...

This essay argues that the states should conform to the post-2017 federal tax law's provision for Global Intangible Low-Taxed Income (or “GILTI”). This essay is directed at state legislators and their staffs and presents the argument as succinctly as possible. Our argument can be summarized...

The purpose of this brief is to correct and respond to two arguments in Petitioner-Appellee Altera's petition for rehearing en banc and briefs of amici supporting the petition for rehearing. First, Treasury's regulation requiring cost sharing of stock-based compensation and the Ninth Circuit...