Samuel D. Brunson

Loyola University Chicago School of Law

25 E. Pearson

Chicago, IL 60611

United States

SCHOLARLY PAPERS

34

DOWNLOADS
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Top 14,341

in Total Papers Downloads

4,950

SSRN CITATIONS

4

CROSSREF CITATIONS

7

Scholarly Papers (34)

1.

Brief of Amici Curiae Tax Law Professors and Economists in Support of Petitioner in South Dakota v. Wayfair

Number of pages: 30 Posted: 06 Nov 2017
New York University School of Law, University of Michigan Law School, Stanford Law School, University of Southern California Gould School of Law, New York University School of Law, Fordham University School of Law, Loyola University Chicago School of Law, Brigham Young University - J. Reuben Clark Law School, Indiana University Maurer School of Law, Ohio State University (OSU) - Michael E. Moritz College of Law, Stanford Law School, Elon University School of Law, Valparaiso University Law SchoolErnst & Young, University of Richmond - School of Law, University of Texas at Austin - School of Law, University of Illinois College of Law, University of Pennsylvania Carey Law School, Yale University - Law School, Yale Law School, University of Virginia School of Law, Kelley School of Business, Southern Methodist University - Dedman School of Law, University of Texas at Austin - School of Law, University of Connecticut - School of Law, Boston College - Law School, University of Chicago Law School, University of Richmond School of Law, Arizona State University (ASU) - Sandra Day O'Connor College of Law, New York University School of Law, Rutgers University, University of Colorado Law School, University of California, Los Angeles (UCLA) - School of Law, University of Arizona - James E. Rogers College of Law, University of Nebraska College of Law, UC Hastings Law, Yeshiva University - Benjamin N. Cardozo School of Law and University of California, Los Angeles (UCLA) - School of Law
Downloads 400 (104,222)
Citation 1

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amicus brief, Supreme Court, stare decisis, dormant Commerce Clause, Quill v. North Dakota, South Dakota v. Wayfair

2.

Repatriating Tax-Exempt Investments: Tax Havens, Blocker Corporations, and Unrelated Debt-Financed Income

Northwestern University Law Review, Vol. 106, No. I, 2012, Loyola University Chicago School of Law Research Paper No. 2011-003
Number of pages: 49 Posted: 29 Jan 2011 Last Revised: 26 Mar 2013
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 335 (127,049)

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tax-exempt entities, unrelated business income tax, UBTI, unrelated debt-financed income, reportable transactions, listed transactions, sale-leaseback, tax haven, hedge fund, blocker corporation

3.

Taxing Polygamy

Washington University Law Review, Vol. 91, No. 1, 2013, Loyola University Chicago School of Law Research Paper No. 2011-026
Number of pages: 57 Posted: 10 Oct 2011 Last Revised: 17 Jan 2014
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 303 (141,188)

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federal income tax, polygamy, joint filing, economic unit, marriage penalty, marriage bonus, same-sex marriage, domestic partnership, civil union, income-shifting

4.

Brigham Young vs. The Bureau of Internal Revenue

Number of pages: 58 Posted: 11 Oct 2017
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 246 (174,136)
Citation 2

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brigham young, john taggart, O.J. Hollister, civil war income tax, assessor, collector, bureau of internal revenue, tithing, polygamy, sovereignty

5.

The Taxation of RICs: Replicating Portfolio Investment or Eliminating Double Taxation?

Stanford Journal of Law, Business, and Finance, Forthcoming
Number of pages: 58 Posted: 27 Aug 2014 Last Revised: 16 Sep 2014
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 201 (210,684)
Citation 1

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federal income tax, ric, regulated investment companies, subchapter m, interest, pfic, quasi-pass-through, partnership taxation, corporate taxation, mark-to-market, mutual fund

6.

Addressing Hate: Georgia, the IRS, and the Ku Klux Klan

Number of pages: 35 Posted: 11 Sep 2020 Last Revised: 25 Sep 2020
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 189 (222,505)

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fraternal beneficiary society, nonprofit, tax-exempt, georgia, bureau of internal revenue, ku klux klan, kkk, arnall

7.

Mutual Funds, Fairness, and the Income Gap

Alabama Law Review, Vol. 65, No. 1, 2013, Loyola University Chicago School of Law Research Paper No. 2012-013
Number of pages: 47 Posted: 18 Aug 2012 Last Revised: 08 Nov 2013
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 183 (228,811)
Citation 1

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federal income tax, mutual fund, regulated investment company, RIC, exemption, dividend, capital gain dividends, savings, investment, vertical equity, fairness

8.

The U.S. as Tax Haven? Aiding Developing Countries by Revoking the Revenue Rule

Columbia Journal of Tax Law, Vol. 5, No. 2, 2014, Loyola University Chicago School of Law Research Paper No. 2013-013
Number of pages: 37 Posted: 09 Nov 2013 Last Revised: 30 Aug 2014
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 175 (237,755)

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Tax haven, federal income tax, revenue rule, treaties, capital flight, foreign tax judgments, recognize, enforce

9.

Watching the Watchers: Preventing I.R.S. Abuse of the Tax System

Florida Tax Review, Vol. 14, No. 6, 2013
Number of pages: 59 Posted: 23 Mar 2013 Last Revised: 18 Nov 2013
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 174 (238,914)

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IRS, administrative, oversight, RIC, 501(c)(3), telephone excise tax, federal income tax, fire-alarm oversight, police patrol oversight, taxpayer advocate, IRS oversight board

10.

Grown-Up Income Shifting: Yesterday’s Kiddie Tax Is Not Enough

Kansas Law Review, Vol. 59, No. 3, 2011, Loyola University Chicago School of Law, Public Law & Legal Theory Research Paper No. 2009-0017
Number of pages: 36 Posted: 07 Nov 2009 Last Revised: 27 Jan 2012
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 171 (242,451)

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income tax, kiddie tax, realization, income-shifting, economic unity, distortions, gifts, mark-to-market, efficiency, family, joint returns, savings, investment

11.

Paying for Gun Violence

Minnesota Law Review, Vol. 104, No. 2, 2019
Number of pages: 53 Posted: 20 Oct 2018 Last Revised: 06 Jan 2020
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 167 (247,235)

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gun violence, pigouvian tax, excise tax, property tax, tax, negative externalities, guns, firearms, second amendment, direct taxes, takings clause, ex post facto clause, heller, shootings, earmarking, constitutional law, constitution

12.

Reigning in Charities: Using an Intermediate Penalty to Enforce the Campaigning Prohibition

Pittsburgh Tax Review, Vol. 8, No. 2, 2011, Loyola University Chicago School of Law Research Paper No. 2010-002
Number of pages: 47 Posted: 29 Apr 2010 Last Revised: 26 Mar 2013
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 158 (259,114)

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Federal income tax, 501(c)(3), tax-exempt, public charity, tax policy, charitable donation, prohibition on campaigning, no substantial part, subsidy

13.

Taxing Investors on a Mark-to-Market Basis

Loyola of Los Angeles Law Review, Vol. 43, No. 2, 2010
Number of pages: 45 Posted: 26 Jun 2009 Last Revised: 27 Jan 2012
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 155 (263,157)

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tax law, mark-to-market, elections, 475(f), Haig-Simons, realization

14.

Tax Exemption, Public Policy, and Discriminatory Fraternities

Virginia Tax Review, Forthcoming
Number of pages: 29 Posted: 22 Jul 2015
David Herzig, David Herzig and Samuel D. Brunson
Valparaiso University Law SchoolErnst & Young and Loyola University Chicago School of Law
Downloads 153 (265,850)

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income tax, tax-exempt, 501(c)(3), 501(c)(7), 501(i), fraternities, social clubs, bob jones university, disparate impact, public policy

15.

Taxing Investment Fund Managers Using a Simplified Mark-to-Market Approach

Wake Forest Law Review, Vol. 45, No. 1, 2010, Loyola University Chicago School of Law Public Law and Legal Theory Research Paper No. 2009-0013
Number of pages: 44 Posted: 28 Aug 2009 Last Revised: 27 Jan 2012
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 146 (276,074)

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carried interest, mark-to-market, hedge fund, private equity fund, investment fund, deferral, preferential tax rates, capital gains, ordinary income, profits interests

16.

Lance Armstrong and the Race for Deductibility

Loyola University Chicago School of Law Research Paper No. 2013-010
Number of pages: 7 Posted: 26 Oct 2012
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 142 (282,139)

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Lance Armstrong, doping, claim of right, Tour de France, deduction, section 162, section 1341, Internal Revenue Code, federal income tax, trade or business, repayment

17.

Dear I.R.S., It Is Time to Enforce the Campaigning Prohibition. Even Against Churches

University of Colorado Law Review, Vol. 87, 2016, Loyola University Chicago School of Law Research Paper No. 2015-003
Number of pages: 62 Posted: 09 Jan 2015 Last Revised: 05 Mar 2016
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 141 (283,699)

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federal income tax, 501(c)(3), campaigning prohibition, church, public charity, rule of law, administrative discretion, I.R.S., enforcement, pulpit freedom sunday, excise tax, judicial review, revocation

18.

Standing On the Shoulders of LLCs: The Tax Entity Status and Decentralized Autonomous Organizations

Number of pages: 42 Posted: 25 Jul 2022 Last Revised: 03 Aug 2022
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 135 (293,460)

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dao, decentralized autonomous organizations, llc, limited liability company, check-the-box, entity election, entity status, federal income tax, partnership, partnership tax

19.

Taxing Utopia

Number of pages: 66 Posted: 18 Dec 2013 Last Revised: 01 Aug 2015
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 119 (322,119)

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religious or apostolic organizations, communitarian, utopia, section 501(d), corporate income tax, partnership tax, pass-through taxation, federal income taxation, Establishment Clause, quasi-pass-through, employment taxes, SECA, dividends, anti-abuse, polygamy

20.

Elective Taxation of Risk-Based Financial Instruments: A Proposal

Houston Business and Tax Law Journal, Vol. 8, No. 1
Number of pages: 36 Posted: 22 Sep 2009
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 117 (325,941)

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tax, financial instruments, derivatives, election, mark-to-market, risk-based

21.

A Diachronic Approach to Bob Jones: Religious Tax Exemptions after Obergefell

Indiana Law Journal, Vol. 92, No. 3, 2017
Number of pages: 46 Posted: 03 Feb 2017 Last Revised: 19 Jan 2018
Samuel D. Brunson, David Herzig and David Herzig
Loyola University Chicago School of Law and Valparaiso University Law SchoolErnst & Young
Downloads 110 (340,357)
Citation 1

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Obergefell, Bob Jones, Fundamental Public Policy, Safe Harbor, Strict Scrutiny, Civil Rights Act, Blacklist

22.

Accept this as a Gift: Unilaterally Enforcing Foreign Tax Judgments

Tax Notes Vol. 146, No. 4, 2015
Number of pages: 6 Posted: 21 Feb 2015
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 105 (351,203)

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23.

Introduction: God and the IRS: Accommodating Religious Practice in United States Tax Law

Samuel D. Brunson, God and the IRS: Accommodating Religious Practice in United States Tax Law (New York: Cambridge University Press, 2018), 1-6.
Number of pages: 7 Posted: 05 Aug 2018
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 103 (355,632)

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accommodation, income tax, religious taxpayers, parsonage allowance, framework, first amendment, establishment clause, free exercise clause, mortgage interest deduction, tax protestor

24.

God Is My Roommate? Tax Exemptions for Parsonages Yesterday, Today, and (if Constitutional) Tomorrow

Indiana Law Journal, Forthcoming
Number of pages: 44 Posted: 08 Mar 2020 Last Revised: 15 Apr 2020
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 93 (379,696)

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property tax, parsonage, property tax exemptions, parsonage allowance, establishment clause, historical significance test, constitution, religion, minister, section 107, seventh circuit, gaylor, freedom from religion foundation, gaylor v mnuchin, history

25.

Let Prophets Be (Non) Profits

Wake Forest Law Review, Forthcoming
Number of pages: 60 Posted: 08 Sep 2017
David Herzig, David Herzig and Samuel D. Brunson
Valparaiso University Law SchoolErnst & Young and Loyola University Chicago School of Law
Downloads 93 (379,696)

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section 501(c)(3), tax exemption, federal income tax, subsidy, section 170, fundamental public policy, deductabilty, charitable donation

26.

Afterlife of the Death Tax

Indiana Law Journal, Vol. 94, No. 2 (2019)
Number of pages: 35 Posted: 08 Mar 2018 Last Revised: 17 Aug 2019
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 92 (382,208)

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estate tax, income tax, inheritance tax, stepped-up basis, death tax, zombie, inheritance, basis, exemption amount, unified credit, progressivity, dynastic wealth, revenue

27.

Brief of Tax Law Professors As Amici Curiae in Support of Petitioner in Loudoun County, Virginia v. Dulles Duty Free, LLC

Number of pages: 33 Posted: 02 Feb 2018 Last Revised: 01 Sep 2021
New York University School of Law, University of Michigan Law School, New York University School of Law, Loyola University Chicago School of Law, Brigham Young University - J. Reuben Clark Law School, Indiana University Maurer School of Law, Ohio State University (OSU) - Michael E. Moritz College of Law, Stanford Law School, University of Richmond - School of Law, University of Pennsylvania Carey Law School, Yale University - Law School, University of Virginia School of Law, Kelley School of Business, University of Connecticut - School of Law, Boston College - Law School, University of Chicago Law School, Arizona State University (ASU) - Sandra Day O'Connor College of Law, Rutgers University and Yeshiva University - Benjamin N. Cardozo School of Law
Downloads 86 (398,356)

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tax, taxation, public, policy, law, sales, use, state, export, multistate, amicus brief, Supreme Court, jurisprudence, stream of export, constitutional, constitution, commerce, due process, import-export, interstate, clause, stare decisis

28.

'I’d Gladly Pay You Tuesday for a (Tax Deduction) Today': Donor-Advised Funds and the Deferral of Charity

Wake Forest Law Review, Forthcoming
Number of pages: 48 Posted: 30 Jan 2020
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 85 (401,078)

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daf, donor advised funds, private foundations, public charities, excise tax, deductibility, circumvent

29.

Bargain Basement Progressivity? Constitutional Flat Taxes, Demogrants, and Progressive Income Taxation

Loyola University Chicago Law Journal, Forthcoming
Number of pages: 33 Posted: 06 Apr 2022
Samuel D. Brunson
Loyola University Chicago School of Law
Downloads 75 (431,003)

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flat tax, state income tax, illinois, constitution, demogrant, credit, refundable credit, consitutional convention

30.

An Employee Home Office Expense Deduction for the New Normal

Tax Notes Federal Vol. 171 Iss. 1 (April 5, 2021) p. 41, Widener Law Commonwealth Research Paper No. 21-21
Number of pages: 10 Posted: 05 Jun 2021
Christian A. Johnson and Samuel D. Brunson
Widener University - Commonwealth Law School and Loyola University Chicago School of Law
Downloads 75 (431,003)

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Home office deduction; home office expenses; pandemic; rent expense; office expense

31.

A Diachronic Approach to Bob Jones: Religious Tax Exemptions after Obergefell

Indiana Law Journal, Forthcoming, Valparaiso University Legal Studies Research Paper No. 17-1
Number of pages: 62 Posted: 28 Aug 2017
David Herzig, David Herzig and Samuel D. Brunson
Valparaiso University Law SchoolErnst & Young and Loyola University Chicago School of Law
Downloads 72 (440,631)

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tax, Obergefell, religious tax exemptions, public policy, tax-exempt organizations

32.

The University, Ideology, and Tax Exemption

Tax Notes Federal, Aug. 10, 2020, pp. 1037-1041, Loyola Law School, Los Angeles Legal Studies Research Paper No. 2020-24
Number of pages: 6 Posted: 21 Sep 2020
Ellen P. Aprill and Samuel D. Brunson
Loyola Law School Los Angeles and Loyola University Chicago School of Law
Downloads 61 (479,642)

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33.

Good Intentions: Administrative Fiat and the General Welfare Exclusion

Washington University Law Review, Forthcoming, Widener Law Commonwealth Research Paper No. 22-04
Number of pages: 71 Posted: 24 Mar 2022
Samuel D. Brunson and Christian A. Johnson
Loyola University Chicago School of Law and Widener University - Commonwealth Law School
Downloads 53 (511,615)

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general welfare exclusion, indian general welfare exclusion, income, gross income, social security, apa, regulations, administrative discretion, irs, internal revenue service, federal income tax, congress, legislation, regulations, treasury

34.

Education Reform and Cross-Sectoral Financing: A Practice-Based Approach

Loyola University Chicago School of Law Research Paper No. 2012-018
Number of pages: 35 Posted: 20 Aug 2012
Samuel D. Brunson, Robert B. Couch and Grant Matthews
Loyola University Chicago School of Law, Willamette University - Atkinson Graduate School of Management and Chemeketa Community College
Downloads 37 (588,702)
Citation 1

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