Diane M. Ring is a Professor of Law and the Dr. Thomas F. Carney Distinguished Scholar at Boston College Law School, where she researches and writes primarily in the field of international taxation, corporate taxation, and ethical issues in tax practice. Her recent work addresses issues including information exchange, international tax relations, sharing and human equity transactions, and ethics in international tax. Ms. Ring was a consultant for the United Nation’s 2014 project on tax base protection for developing countries, and the U.N.'s 2013 project on treaty administration for developing countries. She was the U.S. National Reporter for the 2012 IFA Conference on the Debt Equity Conundrum, and the U.S. National Reporter for the 2004 IFA Conference on Double Nontaxation. She was the Assistant General Reporter for the 1995 IFA Conference on 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) (2015)
Can Sharing Be Taxed? (with Shu-Yi Oei) (2015)
The past few years have seen the rise of a new model of production and...
Human Equity? Regulating the New Income Share Agreements (with Shu-Yi Oei), Vanderbilt Law Review (2015)
A controversial new financing phenomenon has recently emerged. New “income share agreements” (“ISAs”) enable an...
The New Human Equity Transactions, California Law Review Circuit (2014)
This article begins to explore the legal and policy implications of a new form of...
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...
Transparency and Disclosure, United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries (2015)
Book Review: Resolving Transfer Pricing Disputes: A Global Analysis, Tax Notes International (2014)
Introduction to United States International Taxation, 6th Edition (with James R. Repetti and Paul R. McDaniel), James R. Repetti (2014)
The new edition of this well-known reference work for the tax community provides an introduction...
United States, Taxation of Permanent Establishments (2014)
Conceptualizing a New Institutional Framework for International Taxation, International Taxation Roundtable, Washington University Law School (2013)
Federal Income Taxation of Corporate Enterprise (with Bernard Wolfman) (2012)
This is a comprehensive casebook on federal income taxation of corporations, focusing almost entirely on...
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)
Ethics in Taxation
Ethical Problems in Federal Tax Practice (with Bernard Wolfman and Deborah H. Schenk) (2015)
This highly practical casebook introduces students to the ethical challenges that arise in federal tax...
Taxation of Financial Instruments
Moderator, International Taxation, Law & Society Annual Meeting (2014)
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)
Selected Professional Activities
Moderator, Recent Developments in Human Capital Investing, AALS 2015 Annual Meeting (2015)
Panel Chair, Ethical Issues in International Tax Practice, 27th Annual Institute on Current Issues in International Taxation (2014)
Transparency, Disclosure and Developing Countries, Finalising and Implementing the BEPS Agenda Program (2014)
Human Equity? Regulating the New Income Share Agreements, National Tax Association Annual Meeting (2014)
This article examines the regulatory implications of a controversial new financing phenomenon that has recently...