Samuel D. Brunson

Loyola University Chicago School of Law

25 E. Pearson

Chicago, IL 60611

United States

SCHOLARLY PAPERS

18

DOWNLOADS
Rank 15,296

SSRN RANKINGS

Top 15,296

in Total Papers Downloads

2,492

CITATIONS
Rank 40,132

SSRN RANKINGS

Top 40,132

in Total Papers Citations

4

Scholarly Papers (18)

1.

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 234 (84,114)

Abstract:

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

2.

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 216 (96,342)

Abstract:

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

3.

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 154 (148,438)

Abstract:

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

4.

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 143 (150,048)

Abstract:

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

5.

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 137 (155,762)

Abstract:

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

6.

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 133 (154,928)

Abstract:

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

7.

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 129 (165,908)

Abstract:

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

8.

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 126 (177,881)
Citation 2

Abstract:

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

9.

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 121 (182,283)
Citation 1

Abstract:

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

10.

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 116 (186,762)

Abstract:

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

11.

Tax Exemption, Public Policy, and Discriminatory Fraternities

Virginia Tax Review, Forthcoming
Number of pages: 29 Posted: 22 Jul 2015
David Herzig and Samuel D. Brunson
Valparaiso University Law School and Loyola University Chicago School of Law
Downloads 106 (191,548)

Abstract:

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

12.

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 95 (144,552)

Abstract:

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

13.

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 82 (218,615)
Citation 1

Abstract:

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

14.

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 80 (194,035)

Abstract:

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

15.

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 77 (234,381)

Abstract:

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

16.

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 72 (227,867)

Abstract:

17.

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 20 (394,428)

Abstract:

18.

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

Indiana Law Journal, Forthcoming
Number of pages: 63 Posted: 03 Feb 2017
Samuel D. Brunson and David Herzig
Loyola University Chicago School of Law and Valparaiso University Law School
Downloads 0 (298,007)

Abstract:

Obergefell, Bob Jones, fundamental public policy, safe harbor, strict scrutiny, civil rights act, blacklist