Document Type

Prize Paper

Publication Date

2024

Abstract

The five essays below comment on a selection of current topics in tax analyzed and discussed in the Tax Policy Seminar taught by Professors Shuldiner & Sanchirico. The essays were informed by scholarship and the discussions and insights of those in the course as well as the professors. As a broad overview, the essays respond to various issues and proceed as follows: (1) The first essay discusses scholarship on monetary finance and evaluates the role of the Federal Reserve in determining the cost of monetary finance; (2) The second essay evaluates initiatives in cross-border taxation, specifically the possible benefits of the substance-based income exclusion found in Pillar Two of the OECD framework; (3) The third essay responds to scholarship on the comparative taxation of labor versus capital and analyzes flat tax regimes as well as the decision in scholarship to use stylized, integrated ETRs as opposed to backward-looking ETRs; (4) The fourth essay reacts to rule changes and discussion around Malta pension schemes and wonders if the competent authority agreement between the United States and Malta should be viewed as a treaty amendment, requiring input from the legislature; (5) Lastly, the fifth essay discusses amicus briefs and scholarship surrounding the Moore case and questions the opaque concept of constructive realization.

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Tax Law Commons

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