In late July 2022, as the Inflation Reduction Act was being finalized, a provision limiting the carried interest preference, which allows billionaire hedge fund managers to qualify for the long-term capital gains rate on their highly lucrative “carry,” was scrapped. This continued a string...

This Essay examines the question of how state and local government officials should consider federal tax law principles, like the commerciality doctrine, when they challenge state and local property tax exemptions that rely, at least in part, on tax-exempt charitable status for federal income...

Efficiency is often used as a proxy for discussing nonprofit charity effectiveness, but such ostensibly objective measures can limit any true understanding of charities' potential. Although efficiency is the hallmark of many theories of charitable tax exemption and is sometimes useful, the...

This symposium issue of the Georgia Law Review provides an excellent opportunity to showcase both the subject matter of the January 2007 AALS section program and the growing field of legal study on matters concerning nonprofit and philanthropy law. Professor Garry Jenkins' article, included in...

A Diversity Theory of Charitable Tax Exemption is an initial attempt at understanding the charitable tax exemption beyond the borders of the law and economics vision of efficiency. Efficiency is the hallmark of many of the existing theories of charitable tax exemption. This is especially true of...

This essay endeavors to document and to preserve the story of the origins of the book Taxing America (NYU Press 1997) edited by Karen B. Brown and Mary Louise Fellows. The publication of that text was a key milestone in the development of critical tax theory as an intellectual discipline. By...

The OECD’s Base Erosion Profit Shifting (BEPS) project has taken a powerful and welcome look at many of the tax avoidance strategies that proliferate in a world where multinational enterprises are in the business of exploiting gaps in the tax laws of different countries to minimize their...