Works in Progress

Articles

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Revitalizing the Estate Tax: 5 Easy Pieces (with Paul L. Caron), Tax Notes (2014)

In a previous article, we argued that contrary to the state of the law over...

 

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Horizontal Equity Revisited (with Diane M. Ring), Florida Tax Review (2013)

From the introduction:

No tax policy analysis stands complete without examination of equity implications. But...

 

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Occupy the Tax Code: Using the Estate Tax to Reduce Inequality and Spur Economic Growth (with Paul L. Caron), Pepperdine Law Review (Symposium Issue) (2013)

Inequality has been increasing in the United States. We should care about this increase because...

 

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The Estate Tax Non-Gap: Why Repeal a 'Voluntary' Tax? (with Paul L. Caron), Stanford Law & Policy Review (Symposium Issue) (2009)

Over thirty years ago, George Cooper wrote a seminal article arguing that the estate tax...

 

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Democracy and Opportunity: A New Paradigm in Tax Equity, Vanderbilt Law Review (2008)

Although there is consensus about the need for equity, academics and policy makers disagree about...

 

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Will U.S. Investment Go Abroad in a Territorial Tax: A Critique of the President's Advisory Panel on Tax Reform, Florida Tax Review (2007)

This article critiques the Report of the President's Advisory Panel on Federal Tax Reform (the...

 

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Textualism and Tax Shelters (with Noel B. Cunningham), Virginia Tax Review (2004)

A substantial debate about the approaches employed by courts to interpret statutes and regulations has...

 

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Introduction to the State of Federal Income Taxation: Rates, Progressivity, and Budget Processes, Boston College Law Review (2004)

Many fundamental changes have occurred in our tax system in the past four years. These...

 

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Democracy, Taxes, and Wealth, New York University Law Review (2001)

This article demonstrates why wealth concentration matters and why the tax system should be used...

 
Commentary: It's All About Valuation, Tax Law Review (2000)
 

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The Case for the Estate and Gift Tax, Tax Notes (2000)

Criticisms of the estate tax have often been contradictory and confusing. On the one hand,...

 

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Entrepreneurs and the Estate Tax, Tax Notes (1999)

This article analyzes the claims of a recent commentary by Douglas Holtz-Eakin, The Death Tax:...

 

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The Misuse of Tax Incentives to Align Management-Shareholder Interests, Cardozo Law Review (1997)

The U.S. tax system contains many provisions which are intended to align management of large...

 

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Minority Discounts: the Alchemy in Estate and Gift Taxation, Tax Law Review (1995)

[Also appears in Federal Wealth Transfer Tax Anthology, edited by Paul L. Caron, Grayson M.P....

 

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Horizontal and Vertical Equity: The Musgrave/Kaplow Exchange (with Paul R. McDaniel), Florida Tax Review (1993)

[Also appears in Tax Law, volume 1, edited by Patricia D. White, 439-454. New York:...

 

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Corporate Governance and Stockholder Abdication: Missing Factors in Tax Policy Analysis, Notre Dame Law Review (1992)

Policymakers recognize that management's ability to control publicly held corporations can negatively affect corporate productivity...

 
Long-Term Capital Gains, the Long-Term Investment Perspective, and Corporate Productivity, Tax Notes (1990)

[Also appears in The Capital Gains Controversy: A Tax Analysts Reader, edited by J. Andrew...

 

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Management Buyouts, Efficient Markets, Fair Value and Soft Information, North Carolina Law Review (1988)

Leveraged buyouts, particularly by a corporation's management, provide unique opportunities for investors to realize extraordinary...

 

Books

Introduction to United States International Taxation, 6th Edition (with Diane M. Ring and Paul R. McDaniel) (2014)

The new edition of this well-known reference work for the tax community provides an introduction...

 

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Partnership Income Taxation (with William H. Lyons) (2011)
 

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Federal Wealth Transfer Taxation: Cases and Materials (with Paul R. McDaniel and Paul L. Caron) (2009)

Accompanied by Study Problems. New York: Thomson Reuters/Foundation Press, 2010.

Also accompanied by Teacher's Manual....

 

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Introduction to United States International Taxation (with Paul R. McDaniel and Hugh J. Ault) (2005)
 

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Partnership Income Taxation (with Alan Gunn) (2005)
 

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Federal Wealth Transfer Taxation: Cases and Materials (with Paul R. McDaniel and Paul L. Caron) (2003)

Accompanied by 2005 Special Supplement: Family Limited Partnerships, by McDaniel, Repetti and Caron. New York:...

 
Federal Wealth Transfer Taxation: Cases and Materials (3rd ed.) (with Paul R. McDaniel and Paul L. Caron) (1999)

Accompanied by Federal Wealth Transfer Taxation, 4th ed. Study Problems, by McDaniel, Repetti and Caron....

 

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Tax Aspects of Organizing and Operating a Business (1991)

Chapter author for: "The Impact of Taxation on Selection of a Form of Business Organization."...

 

Contributions to Books

2013 Supplement (with Paul R, McDaniel and Paul L. Caron), Federal Wealth Transfer Taxation: Cases and Materials (2013)
 
2012 Supplement, Federal Wealth Transfer Taxation: Cases and Materials & Federal Wealth Transfer Taxation: Study Problems (2012)
 
2012 Supplement, Federal Wealth Transfer Taxation: Teacher's Manual (2012)
 

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Horizontal Equity Revisited (with Diane M. Ring), 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...

 
2011 Supplement (with Paul L. Caron), Federal Wealth Transfer Taxation: Cases and Materials & Federal Wealth Transfer Taxation: Study Problems (2011)
 
2011 Supplement, Federal Wealth Transfer Taxation: Teacher's Manual (2011)
 

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The United States, Comparative Income Taxation: A Structural Analysis (2010)
 
United States - Partnerships, Partnerships: IBFD Tax Research Platform (2010)

(Online only, by subscription: http://ip-online2.ibfd.org/kbase/) (accessed April 7, 2010)

 

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The Uneasy Case for a Comprehensive Tax Base, Tax Compliance Costs for Companies in an Enlarged European Community (2008)

In discussing tax simplification, commentators often advocate a comprehensive income tax system that has a...

 
United States, Partnerships (2008)
 

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Contributing Author, Comparative Income Taxation: A Structural Analysis (2004)

This work presents a comparative analysis of some of the structural and design issues which...

 
General Description: United States, Comparative Income Taxation: A Structural Analysis (1997)
 
Entity Classification and Overview of Subchapter K, 94 Federal Tax Institute of New England (1996)
 
International Guide to Partnerships -- United States, The International Guide to Partnerships (1996)

Updated by loose-leaf supplementation to The International Guide to Partnerships, edited by Kees van Raad...

 
Supplement 9 (Oct. 2005 update): “United States.”, The International Guide to Partnerships (1996)
 

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Selected Uses of a Partnership, The Partnership Maze: Answers to Puzzling Tax and Business Issues (1990)
 
Recent Developments in 10b-5, Recent Developments in Business Law: Proceedings of the Annual Midwinter Meeting of the Massachusetts Bar Association Business Law Section (1987)
 

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Tax Consideration in Selecting a Form of Business Organization, Fundamentals of Corporate Taxation (1987)

Also appears in Fundamentals of Corporate Taxation, 23-54. Boston: Massachusetts Continuing Legal Education, 1988.

 
Development, Acquisitions and Disposition of Technology and Intellectual Property (with David S. Davenport), 70th Forum of the Federal Tax Institute of New England: A Saturday Forum on Tax Planning for High-Tech and New Ventures (1984)
 
High Technology Investments (with David S. Davenport), 18th Annual Southern Federal Tax Institute (1983)
 

Popular Press

Selected Professional Activities

Revitalizing the Estate Tax, Pepperdine Law Review Symposium (2014)
 
Using the Estate Tax to Reduce Inequality, Columbia Law School Tax Policy Forum (2013)
 
Moderator, Tax Policy and Economic Efficiency, Annual Meeting of the Law and Society Association (2013)
 
Occupy the Tax Code: Using the Estate Tax to Reduce Inequality, Pepperdine Law Review Symposium (2013)

Defense of the estate tax as an important policy tool to address inequality.

 
Partnership Capital Shifts, 60th Annual Tax Institute, University of Montana Law School (2012)
 
Death and Taxes: Now and Beyond, AALS 2012 Annual Meeting (2012)
 
Horizontal Equity Revisited, University of Indiana School of Law (2011)
 
The Uneasy Case for Efficiency in Tax Policy, University of Colorado Law School (2010)
 
What is the Proper Role for Economic Efficiency?, University of Colorado Round Table on Tax and Distributive Justice (2010)
 
The Uneasy Case for Efficiency in Tax Policy, University of Indiana School of Law (2009)
 
Do We Need the Estate and Gift Tax?, Boston Probate and Estate Planning Forum (2009)
 
Democracy and Opportunity: A New Paradigm in Tax Equity, University of Florida Law School Colloquia Series in November and Loyola University Tax Policy Colloquia in October (2007)
 
The Uneasy Case for a Comprehensive Income Tax, Jean Monnet Conference (2006)
 
Alternatives before Congress for Changing US International Taxation, Federal Tax Institute of New England (2003)