Isaac Christopher Samuel

Citizenship Overreach

Peter Spiro, Citizenship Overreach, 38 Mich. J. Int’l L. 167 (2017). This article examines international law limitations on the ascription of citizenship in the context of U.S. taxation of non-resident citizens. U.S. citizenship practice is exceptionally generous, extending citizenship to almost all persons in its territory at the moment of birth. At the …

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Tax: Different Not Exceptional

Alice G. Abreu and Richard K. Greenstein, Tax: Different Not Exceptional, 71 Adm. L. Rev. **(Forthcoming 2019). This article examines the concept of tax exceptionalism–the idea that tax law is fundamentally different from other fields of law and perhaps isn’t law at all. It explores the reasons tax has been …

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Feminist Judgments: Operationalizing Diversity

Alice G. Abreu, Feminist Judgments: Operationalizing Diversity, 16 Pitt. Tax Rev. 189 (2019). This is a short Essay reviewing the recent volume on Feminist Judgments: Rewritten Tax Opinions and offering some thoughts on feminist values in the tax law.

Embracing the TBOR

Alice G. Abreu and Richard K. Greenstein, Embracing the TBOR, 157 Tax Notes 1281 (2017).  This article develops three arguments is support of the proposition that the Taxpayer Bill of Rights, enacted in 2015 as part of the Internal Revenue Code, is not a mere cosmetic but has the potential to transform tax administration.

What We Talk About When We Talk About Tax Complexity

Andrea Monroe, What We Talk About When We Talk About Tax Complexity, 5 Mich. Bus. & Entrepreneurial L. Rev.193 (2017). This essay offers some preliminary evidence of the pervasive influence of legal craft values in partnership taxation. Legal craft values shape our perception of the law, and they shape the law …

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Rebranding Tax / Increasing Diversity

Alice G. Abreu and Richard K. Greenstein, Rebranding Tax / Increasing Diversity, 96 Denver L. Rev. 1 (2018). This article offers one possible answer to the question: Why is the tax bar so white? It posits that the mainstream view of tax as a field of law that should properly …

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Tax 2018: Requiem for Ability to Pay

Alice G. Abreu, Tax 2018: Requiem for Ability to Pay, 51 Loyola L.A. L. Rev. 1 (2018). This Essay analyzes four changes made by the 2017 tax regulation and argues that each unmoors the determinations of the tax base from the foundational concept that taxation should be based on ability …

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Hidden in Plain Sight: IRS Publications and a New Path to Tax Reform

Andrea Monroe, Hidden in Plain Sight: IRS Publications and a New Path to Tax Reform, 21 Florida Tax Rev. 81 (2017). This article suggests that IRS publications can do more than help non-expert stakeholders navigate their annual tax filing obligations; these publications can also offer significant and unexpected value for experts …

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