Andrews & Kurth Centennial Professor of Law, University of Texas at Austin - School of Law, USA

8 years
Fixing the Constitutional Absurdity of the Apportionment of Direct Tax

Fixing the Constitutional Absurdity of the Apportionment of Direct Tax argues that the Constitutional requirement that "direct tax" be apportioned among the states according to population should never...

8 years
Capitalize Costs of Software Development

Under current law, a taxpayer may deduct the costs of development of computer software as soon as the costs are paid or accrued. The immediate deduction of investment costs that have continuing value ...

9 years
Omnibus Capitalization Proposals

This shelf project proposal covers several expenditures that are allowed as expenses as soon as they are incurred under current law but should be treated as capital expenditures. Given the treatment o...

9 years
Common Trust Funds: The Living Fossil of Passthroughs

A common trust fund (CTF) is a fund maintained by a bank exclusively for the collective investment of the funds of trust clients. Under section 584 of the code, a CTF pays no tax, but each participant...

9 years
Taxing the Publicly Traded Stock In a Corporate Acquisition

Under current law, if a corporate acquisition qualifies as a reorganization, the target shareholders do not recognize built-in gain on the stock they surrender when they receive publicly traded stock....

9 years
How to Raise $1 Trillion without a VAT or a Rate Hike

We should be able to raise at least $1 trillion more revenue a year within the current income tax system just by making our tax accounting better reflect economic income. Our system has too many tax p...

10 years
Closing Deferred Revenue

Under current law, taxpayers can receive cash but not pay tax on it because the cash is considered deferred revenue. When a taxpayer writes an option or sells stock short, for example, the taxpayer re...

10 years
Percentage Depletion of Imaginary

Costs Of all the dispensations . . . percentage depletion is the most remarkable achievement. It enables certain taxpayers to reduce their incomes by imaginary costs. Other taxpayers are not consid...

10 years
Tax on Insurance Buildup

Andrew Pike Eric A. Lustig Life insurance contracts often combine a savings or investment element with pure insurance protection that covers the risk of death during the year. Current law will t...

10 years
End Tax-Free Monetization of Wealth

Cash withdrawn from appreciated property using financial instruments has become a major source of untaxed support for the standard of living of our wealthiest citizens. The proposal would treat cas...

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