|Present||Professor, Boston College Law School|
- Fall 2018: Tax Policy, Taxation II, Legal Scholarship Workshop
- Spring 2019: Law & Economics, Legal Scholarship Workshop
|2003||MTS, Harvard Divinity School|
|2003||JD, Harvard Law School|
|1999||BA, Brown University|
Boston College Law School
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Constituencies and Control in Statutory Drafting: Interviews with Government Tax Counsels Iowa Law Review, Forthcoming (2019)
Tax statutes have long been derided as convoluted and unreadable. But there is little existing research about drafting practices that helps us contextualize such critiques. In this Article, we conduct the first in-depth empirical examination ...
Is New Code Section 199A Really Going to Turn Us All into Independent Contractors? (2018)
There has been a lot of interest lately in new IRC Section 199A, the new qualified business income (QBI) deduction that grants passthroughs, including qualifying workers who are independent contractors (and not employees), a deduction ...
The Trouble with Gig Talk: Choice of Narrative and the Worker Classification Fights Law and Contemporary Problems (2018)
The term “sharing economy” is flawed, but are the alternatives any better? This Essay evaluates the uses of competing narratives to describe the business model employed by firms like Uber, Lyft, TaskRabbit, and GrubHub. It ...
The Offshore Tax Enforcement Dragnet Emory Law Journal (2018)
Taxpayers who hide assets abroad to evade taxes present a serious enforcement challenge for the United States. In response, the U.S. has developed a family of initiatives that punish and rehabilitate non-compliant taxpayers, raise revenues, ...
The Tax Lives of Uber Drivers: Evidence from Online Forums Columbia Journal of Tax Law (2016)
In this Article, we investigate the tax issues and challenges facing Uber and Lyft drivers by studying their online interactions in three internet discussion forums: Reddit.com, Uberpeople.net, and Intuit TurboTax AnswerXchange. Using descriptive statistics and ...
Human Equity? Regulating the New Income Share Agreements Vanderbilt Law Review (2015)
A controversial new financing phenomenon has recently emerged. New “income share agreements” (“ISAs”) enable an individual to raise funds by pledging a percentage of her future earnings to investors for a certain number of years. ...
Who Wins When Uncle Sam Loses? Social Insurance and the Forgiveness of Tax Debts UC Davis Law Review (2012)
Small-scale tax collections decisions have large-scale distributive consequences. The central question addressed in this Article is whether a deliberate government decision to forgive or to not collect a tax owed can be justified, given the ...
A Structural Critique of Trader Taxation Florida Tax Review (2008)
This article scrutinizes the structural elements underlying the unusual tax treatment of securities traders under current law. After summarizing the distinguishing features of trader taxation, this article explains how the treatment of securities traders today ...
Context Matters: The Recharacterization of Leases in Bankruptcy and Tax Law American Bankruptcy Law Journal (2008)
This article identifies an important but problematic business transaction that confronts both the bankruptcy and tax systems — the loan disguised as a lease — and compares the ways in which each system deals with ...
Rethinking the Jurisdiction of Bankruptcy Courts Over Post-Confirmation Federal Tax Liabilities: Towards a New Jurisprudence of 11 U.S.C. 505 Akron Tax Journal (2004)
This paper argues that the current approach that bankruptcy courts have taken in circumscribing the reach of § 505 over liabilities that may arise after the plan has been confirmed and discharged is unsatisfactory. Instead ...
Blog Posts (5)
Work-Related Distortions in the Tax Reform Bills: Understanding the New Proposed Provisions (2017)
Co-authored a two-part blog post with Diane M. Ring for On Labor. Part 2 is available here: https://onlabor.org/work-related-distortions-in-the-proposed-tax-bills-understanding-the-policy-conversations-part-2-of-2/.
Contributions to Books (1)
Tax Issues in the Sharing Economy: Implications for Workers The Cambridge Handbook of the Law of the Sharing Economy (2019)
From the publisher's description: This Handbook grapples conceptually and practically with what the sharing economy - which includes entities ranging from large for-profit firms like Airbnb, Uber, Lyft, Taskrabbit, and Upwork to smaller, non-profit collaborative ...