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The gravamen of the constitutional complaint against the individual mandate is its supposed intrusion on personal freedom. But, when all was said and done, no one attacked a state government’s requirement that individuals must purchase health insurance, nor advanced any constitutional...
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Forty-two years ago, in the Virginia Law Review, long before Congress twice enacted — and twice repealed — carryover basis for assets transferred at death, I published this article examining and evaluating a number of proposals for taxing gains at death, as well as for carryover basis. (One...
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Because of the importance of technological innovation to economic growth, nations strive to stimulate and attract the research and development (“R&D”) that leads to that innovation and to make themselves hospitable environments for the holding of intellectual property (“IP”). Tax...
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The author discusses the issues impacting the development of international tax policy. He states that the proper question in forming international tax policy should be, "what policy is in the United States' national interest?" However, advancing the competitive position of U.S. multinationals...
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In previous articles, we have argued that European Court of Justice's reliance on nondiscrimination as the basis for its decisions did not (and could not) satisfy commonly accepted tax policy norms, such as fairness, adminstrability, production of desired levels of revenues, avoidance of double...
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