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- Dormant commerce clause (2)
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- Comptroller of the State of Maryland v. Wynne (1)
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- Comptroller of the Treasury v. Wynne (1)
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Articles 1 - 5 of 5
Full-Text Articles in Taxation-State and Local
Dual Residents: A Sur-Reply To Zelinsky, Michael S. Knoll, Ruth Mason
Dual Residents: A Sur-Reply To Zelinsky, Michael S. Knoll, Ruth Mason
All Faculty Scholarship
In this article, we respond to Professor Zelinsky’s criticism of our arguments regarding the constitutionality of New York’s tax residence rule. We argue that the Supreme Court’s decision in Wynne requires reconsideration of the New York Court of Appeal’s decision in Tamagni.
On The Disparate Treatment Of Business And Personal Salt Payments, Michael S. Knoll
On The Disparate Treatment Of Business And Personal Salt Payments, Michael S. Knoll
All Faculty Scholarship
The Tax Cuts and Jobs Act, H.R. 1, would eliminate the federal income tax deduction for nonbusiness state and local taxes while maintaining the deduction for business state and local taxes. That disparate treatment has generated a storm of negative commentary. In this short essay, I consider whether the federal tax law should allow a deduction for business state and local taxes assuming that there is no deduction for nonbusiness state and local taxes. I argue that investors and businesses, including pass-through businesses, should be allowed to deduct state and local property and sales taxes, but not general income taxes.
How The Massachusetts Supreme Judicial Court Should Interpret Wynne, Michael S. Knoll, Ruth Mason
How The Massachusetts Supreme Judicial Court Should Interpret Wynne, Michael S. Knoll, Ruth Mason
All Faculty Scholarship
In this special report, Knoll and Mason discuss how the Massachusetts Supreme Judicial Court should apply Wynne when it hears on remand First Marblehead v. Commissioner of Revenue. The authors conclude that when it originally heard the case, the Massachusetts court mistakenly considered, as part of its internal consistency analysis, whether Gate Holdings Inc. experienced double state taxation. As developed by the U.S. Supreme Court and most recently applied in Wynne, the internal consistency test is not concerned with actual double taxation that may arise from the interaction of different states’ laws. Rather, the test is designed to determine …
The Taxation Of Cloud Computing And Digital Content, David Shakow
The Taxation Of Cloud Computing And Digital Content, David Shakow
All Faculty Scholarship
“Cloud computing” raises important and difficult questions in state tax law, and for Federal taxes, particularly in the foreign tax area. As cloud computing solutions are adopted by businesses, items we view as tangible are transformed into digital products. In this article, I will describe the problems cloud computing poses for tax systems. I will show how current law is applied to cloud computing and will identify the difficulties current approaches face as they are applied to this developing technology.
My primary interest is how Federal tax law applies to cloud computing, particularly as the new technology affects international transactions. …
The Integration Game, Abraham Bell, Gideon Parchomovsky
The Integration Game, Abraham Bell, Gideon Parchomovsky
All Faculty Scholarship
No abstract provided.