Taxation-Federal Commons^™

The Indirect Taxes, Conor Clarke, Ari Glogower

Scholarship@WashULaw

Article I of the Constitution empowers Congress to “lay and collect Taxes, Duties, Imposts and Excises.” It is arguably Congress’s most important power. A government’s first task is to fund itself, and the absence of an enforceable funding mechanism under the Articles of Confederation was a primary reason for the Constitution in the first place. Yet scholarly and judicial attention has focused mostly on the term “taxes” (and specifically what constitutes a “direct tax” that must be apportioned) while largely overlooking the three terms that follow—the duties, imposts, and excises that are collectively known as the “indirect taxes.” 

While poorly …

Secret Bancaire Et Fiscalité Au Liban, François Debbané

Proche-Orient, Études juridiques

No abstract provided.

Le Secret Fiscal, Paul‑Marie Gaudemet

Proche-Orient, Études juridiques

No abstract provided.

Le Secret Dans L’Administration Fiscale Libanaise, Sleiman Gemayel

Proche-Orient, Études juridiques

No abstract provided.

The U.S. Tax Paradox, Doron Narotzki, Tamir Shanan, Reuven S. Avi-Yonah

Texas A&M Law Review

The U.S. federal tax system is a paradox. It rejects one of the most effective and widely used federal revenue tools while embracing one of the most inefficient and economically harmful taxes. U.S. policymakers dismiss proven solutions as politically unfeasible yet rely on a system that disproportionately burdens consumers and disrupts trade both domestically and internationally. This contradiction is not just irrational. It undermines the very principles of sound tax policy and economic stability.

This Article traces the historical roots of this paradox, from early American tax revolts to modern trade policies, exposing the irony of a nation that once …

Comments On Reg-119882-25, Application Of The Personal Responsibility And Work Opportunity Reconciliation Act Of 1996 To The Refunded Portion Of Certain Federal Refundable Tax Credits, 91 Fed. Reg. 53,812 (Aug. 20, 2026); Irs Docket No. Irs- 2026-1057, Islame Hosny, Addison H. Brown, Andrew E. Hoppe, Nafisa Jeb, Parker W. Kinney, Shane M. Rice, Audrey Hager, Anna Russell, Cornell Law School Low-Income Taxpayer Clinic

Cornell Law School J.D. Student Research Papers

On October 5, 2026, the Cornell Law School Low-Income Taxpayer Clinic submitted this comment letter on proposed Treasury and IRS regulations (REG-119882-25, 91 Fed. Reg. 53,812). The regulations would apply the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) to the refunded portions of the adoption tax credit, child tax credit, American opportunity tax credit, and earned income tax credit. The letter argues that Treasury has not adequately reconciled PRWORA's "qualified alien" test with the Code's residency and Social Security number rules. It also argues that Treasury has not justified treating the adoption credit as a federal public …

Masthead

Seattle University Law Review

No abstract provided.

Table Of Contents

Seattle University Law Review

No abstract provided.

Getting Money Out Of Politics By Putting Money Into Politics: A Few Modest Proposals To Reform Seattle’S Democracy Voucher Program, Decker O’Donnell

Seattle University Law Review

Seattle’s Democracy Voucher Program offers an unconventional response to the growing influence of money in American elections: rather than restricting political spending, it seeks to amplify the participation of ordinary voters by providing publicly funded vouchers that residents may assign to participating candidates. This Article examines the program’s development, operation, and constitutional foundation within the modern campaign-finance framework established by Buckley v. Valeo and subsequent Supreme Court decisions. It argues that democracy vouchers provide a constitutionally viable means of broadening participation in campaign financing while mitigating the influence of wealthy donors. The Article identifies two weaknesses in the current system: …

Legal Malpractice In Washington: Use Of The Rules Of Professional Conduct, Angelo Tadrous

Seattle University Law Review

Legal malpractice claims are difficult to prove. They are difficult to prove because many jurisdictions require that a plaintiff prove that, but for the lawyer’s misconduct, the client would have fared better. Thus, in a malpractice suit, a plaintiff must try a case within a case. Despite this difficulty, many jurisdictions prohibit the use of the Rules of Professional Conduct when litigating a malpractice case. Washington State is one of these jurisdictions. The Washington Supreme Court held in Hizey v. Carpenter that the Rules of Professional Conduct may not be referred to during trial. This Note argues that this prohibition …

Converting Buildings Is Hard: Why Seattle’S Municipal Government Should Streamline Commercial-To-Residential Conversions, Tyler M. King

Seattle University Law Review

The conversion of commercial buildings into housing is a promising solution to the growing housing crisis in many urban areas. However, despite its potential benefits, the process of repurposing commercial spaces is often stymied by complex zoning codes, high conversion costs, and bureaucratic hurdles. This Article argues that the local and state governments in Seattle should adopt more streamlined policies and offer greater incentives to developers to facilitate these conversions. By reforming zoning regulations and providing targeted financial support, municipalities can reduce the barriers to conversion and unlock the potential of underutilized commercial properties. This article examines the legal and …

Who Decides The Dead? Interpreting Washington’S Disposition Of Remains Statute, Wyatt Young

Seattle University Law Review

Washington’s disposition-of-remains statute, RCW 68.50.160, is designed to honor a decedent’s expressed wishes regarding the control and disposition of their body after death. Yet recent litigation reveals a critical gap between the statute’s intent-centered design and its practical enforceability. In Larotonda v. Blackburn, a trial court acknowledged that irreparable harm would occur if a decedent’s burial wishes were ignored but nonetheless denied relief on the grounds that the individual designated to carry out those wishes lacked standing. The result was a legal paradox: a statute that recognizes decedent autonomy in theory but withholds any meaningful mechanism for its enforcement …

The Case For Fixing The Unprincipled Residence Tax Exemption, Samuel Singer, Allison Christians

Osgoode Hall Law Journal

When Canada overhauled its income tax to include capital gains in 1972, lawmakers suddenly had to decide how to deal with personal home sales. After heated debate, they opted to exclude the gains on an individual’s principal residence on the grounds that the core purpose of a home is to provide “basic shelter” for its owner-occupants.

The principal residence tax exemption has since become one of Canada’s biggest tax shelters and now amounts to one of Canada’s largest tax subsidies to individuals. Along the way, it has created economic distortions, administrative challenges, and inequitable distributive outcomes. While lawmakers have occasionally …

The Contemporary Tax Journal’S Interview With Ms. Julia Ushakova-Stein, Shuang Zhang

The Contemporary Tax Journal

No abstract provided.

2026 Uworld Cpa Exam Review Questions

The Contemporary Tax Journal

No abstract provided.

The Contemporary Tax Journal Volume 15, No. 1 – Summer 2026

The Contemporary Tax Journal

No abstract provided.

Equality Before Tax Law, Charles Delmotte

Washington and Lee Law Review

The income tax code is riddled with exceptions—exclusions, rate preferences, and deductions—that reduce tax burdens for dominant majorities and powerful interest groups. These carveouts now amount to an astonishing $1.9 trillion, equivalent to 75 percent of all federal income tax revenue. By granting policymakers discretion to allocate tax exceptions, the tax system not only invites capture but also the weaponization of taxation against disfavored economic and political groups. Yet despite the central role of these exceptions, tax scholars have not articulated a principle requiring taxation according to general rules.

This Article bridges philosophy with insights from political economy to reveal …

Protecting Dependent Children In Bankruptcy, Michael D. Sousa, L. Alexis Whitley Esq.

Villanova Law Review (1956 - )

No abstract provided.

Algorithmic Tax Ownership Young Ran (Christine) Kim &, Young Ran (Christine) Kim, Dmitry Erokhin

BYU Law Review

Tax ownership is a crucial concept for determining tax liabilities, compliance, and enforcement. However, neither the courts nor the IRS has provided clear guidance on how to analyze it. Since the Supreme Court first outlined a twenty-six-factor test for determining tax ownership in Frank Lyon Co. v. United States in 1978, this multifactor test has remained largely unchanged, and there has been no further guidance from the courts or the IRS to this day. Even tests with shorter lists of factors only add to the confusion regarding compliance and enforcement, as there is no clarity on which factors are most …

Table Of Contents

Seattle University Law Review

Table of Contents