Diane M. Ring is Associate Dean for Academic Affairs and a Professor of Law at Boston College Law School, where she researches and writes primarily in the field of international taxation, corporate taxation, and the taxation of financial instruments. Her recent work addresses issues including cross border tax arbitrage, advance pricing agreements, and international tax relations. Ms. Ring is currently the U.S. National Reporter for the 2012 IFA Conference on the Debt Equity Conundrum, and was the U.S. National Reporter for the 2004 IFA Conference on Double Nontaxation. She was the Assistant General Reporter for the 1995 IFA Conferenceon Financial Instruments and was a consultant to the IFA research project on the impact of technological and financial innovation on the taxation of income and activities. Ms. Ring is also co-author of three case books in taxation– one on corporate taxation, one on international taxation, and one on ethical problems in federal tax practice. Prior to joining Boston College Law School, Ms. Ring was an associate professor of law at the University of Florida Levin College of Law, and an assistant professor at Harvard Law School. Before entering academia, Ms. Ring practiced at the firm of Caplin & Drysdale in Washington, D.C., specializing in the area of international tax and the taxation of financial instruments. Ms. Ring also clerked for Judge Jon O. Newman of the Second Circuit Court of Appeals.
Works in Progress
Concepts and Enforcement of Tax Fraud in Switzerland and the United States (with Luzi Cavelti) (2012)
Horizontal Equity Revisited (with James R. Repetti), The Proper Tax Base: Structural Fairness from an International and Comparative Perspective (2012)
In the years since McDaniel and Repetti’s 1993 article evaluating the intellectual landscape on horizontal...
Federal Income Taxation of Corporate Enterprise (with Bernard Wolfman) (2011)
International Dynamics of International Tax, Beyond Economic Efficiency (2011)
U.S. International Taxation: Cases and Materials (with Reuven S. Avi-Yonah and Yariv Brauner) (2011)
The Promise of International Tax Scholarship and its Implications for Research Design, Theory and Methodology, St. Louis University Law Journal (2010)
What should international tax scholars be doing? Over the past two decades, international tax has...
Who is Making International Tax Policy? International Organizations as Power Players in a High Stakes World, Fordham International Law Journal (2010)
Who makes international tax policy in today’s world? Certainly no single body possesses that power...
Democracy, Sovereignty and Tax Competition: The Role of Tax Sovereignty in Shaping Tax Cooperation, Florida Tax Review (2009)
This paper considers the question of how sovereignty shapes arguments over the merits of tax...
The Debt-Equity Conundrum: U.S. National Report, Cahiers De Droit Fiscal International (2012)
One of the fundamental challenges in corporate taxation is managing the distinction between debt and...
Federal Income Taxation of Corporate Enterprise (with Bernard Wolfman) (2008)
Federal Income Taxation of Corporate Enterprise (with Bernard Wolfman) (2005)
Risk-Shifting Within a Multinational Corporation: The Incoherence of the U.S. Tax Regime, Boston College Law Review (1997)
Case Comment: Religious Payments as Deductible Charitable Contributions: Hernandez v. Commissioner, Harvard Law Review (1989)
Ethics in Taxation
Horizontal Equity Revisited (with James R. Repetti), Florida Tax Review (2013)
From the introduction:
No tax policy analysis stands complete without examination of equity implications. But...
Ethical Problems in Federal Tax Practice (with Bernard Wolfman and Deborah H. Schenk) (2008)
Ethical Problems in Federal Tax Practice, Fourth Edition, is the ideal tool for introducing students...
Taxation of Financial Instruments
Commentary: Exploring the Challenges of Electronic Commerce Taxation Through the Experience of Financial Instruments, Tax Law Review (1996)
Taxation of Financial Instruments (with Reuven Avi-Yonah and David Newman) (1996)
Commentary: Fixing Realization Accounting: Symmetry, Consistency and Correctness in the Taxation of Financial Instruments, Tax Law Review (1995)
Tax Aspects of Derivative Financial Instruments (with David Rosenbloom and Charles Plambeck), Cahiers de Droit Fiscal International (1995)
United States, Taxation of Permanent Establishments (2012)
Taxation as a Global Socio-Legal Phenomenon (with Allison Christians, Steven Dean, and Adam H. Rosensweig), ILSA Journal of International and Comparative Law (2008)
This essay makes a proposal that might be controversial among tax scholars even if it...
Why Happiness?: A Commentary On Griffith's Progressive Taxation And Happiness, Boston College Law Review (2004)
This Commentary examines three issues raised in Professor Thomas D. Griffith's Article on the connection...