Law

A Constitutional Right To Skirt State Income Tax?

Imagine this: A multimillionaire private equity investor in New York transfers interests in one of his private equity funds to a trust and appoints as his trustee an attorney who lives in Connecticut. The beneficiaries of the trust are his…

The IRS Boozily Resurrects the 3-Martini Lunch

IRS and Treasury have recently been so overwhelmed by the volume of regulation needed to implement the 2017 tax legislation that it’s easy to understand if they just really need a drink. It’s still surprising, though, that one piece of their recent…

There Is No Retroactivity Concern With Overruling Quill

A very long post about an admittedly esoteric issue that could determine the outcome of the Supreme Court’s hugely significant online sales tax case

What are lawyers and legal scholars good for?

These are strange days. My students and I are struggling with the enormity of the presidential election. I am trying to comprehend the implications for the future of our country and the world. I fear that we, as a nation, will lose the progressive…