Michael S. Knoll

University of Pennsylvania Carey Law School

Professor

3501 Sansom Street

Philadelphia, PA 19104

United States

University of Pennsylvania Wharton School -- Real Estate Department

Philadelphia, PA 19104-6330

United States

  • University of Pennsylvania Carey Law School

    • Email
    • Tel: 215-898-6190
    • Fax: 215-573-2025

  • University of Pennsylvania Wharton School -- Real Estate Department

SCHOLARLY PAPERS

56

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8

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22

Scholarly Papers (56)

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1.

The Taxation of Private Equity Carried Interests: Estimating the Revenue Effects of Taxing Profit Interests as Ordinary Income

U of Penn, Inst for Law & Econ Research Paper No. 07-20, U of Penn Law School, Public Law Research Paper No. 07-32, William & Mary Law Review, Vol. 50, No. 1, 2008
Number of pages: 48 Posted: 19 Aug 2007 Last Revised: 12 Nov 2008
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 1,748 (13,835)
Citation 4

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private equity, profits interest, carried interest, carry, taxation of capital, taxation of services, capital gains, ordinary income, capital gains preference, tax deferral, stock-based compensation, equity-based compensation, option pricing, Black-Scholes formula, tax revenue estimation, H.R. 2834

2.

The Ancient Roots of Modern Financial Innovation: The Early History of Regulatory Arbitrage

Oregon Law Review, Vol. 87, p. 93, 2008, U of Penn, Inst for Law & Econ Research Paper No. 04-11
Number of pages: 24 Posted: 16 Jun 2004 Last Revised: 27 Jun 2009
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 1,327 (21,022)
Citation 7

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financial innovation, put-call parity, regulatory arbitrage, financial history, usury

3.

What is Tax Discrimination?

Yale Law Journal, Vol. 121, Pg. 1014, 2012, U of Penn, Inst for Law & Econ Research Paper No. 12-17
Number of pages: 104 Posted: 27 Mar 2011 Last Revised: 12 Apr 2012
Ruth Mason and Michael S. Knoll
University of Virginia School of Law and University of Pennsylvania Carey Law School
Downloads 1,264 (22,614)

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tax discrimination, capital export neutrality, capital import neutrality, capital ownership neutrality, European Court of Justice, Schumacker, Gerritse, de Groot, competitive neutrality

4.

The Section 83(B) Election for Restricted Stock: A Joint Tax Perspective

Southern Methodist University Law Review, Vol. 59, Pg. 721, 2006, U of Penn, Inst for Law & Econ Research Paper No. 05-26
Number of pages: 30 Posted: 10 Sep 2005 Last Revised: 21 Aug 2009
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 1,066 (28,967)
Citation 1

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Restricted stock, Section 83(b) election, taxation, executive compensation, equity-based pay, employee stock options, tax planning, compensation planning

5.

The Calculation of Prejudgment Interest

U of Penn Law School, Public Law Working Paper No. 06-21
Number of pages: 36 Posted: 01 Jun 2005
Michael S. Knoll and Jeffrey M. Colon
University of Pennsylvania Carey Law School and Fordham University School of Law
Downloads 993 (32,093)
Citation 4

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Prejudgment interest, litigation, trial, compensation

6.

Reconsidering International Tax Neutrality

Tax Law Review, Vol. 64, P. 99, 2011, U of Penn, Inst for Law & Econ Research Paper No. 09-16
Number of pages: 31 Posted: 22 May 2009 Last Revised: 24 Oct 2014
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 776 (45,098)
Citation 4

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foreign tax credit, worldwide taxation, competitiveness, tax competition, foreign direct investment, international taxation, capital export neutrality (CEN), capital import neutrality (CIN), capital ownership neutrality (CON)

7.

Samuel Zell, the Chicago Tribune, and the Emergence of the S ESOP: Understanding the Tax Advantages and Disadvantages of S ESOPs

Ohio State Law Journal, Vol. 70, pp. 519, 2009, U of Penn, Inst for Law & Econ Research Paper No. 08-14
Number of pages: 36 Posted: 12 Jun 2008 Last Revised: 30 Jun 2009
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 677 (54,101)

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Employee ownership, Employee stock ownership plans, ESOPs, S corporations, mergers and acquisitions, Samuel Zell, Chicago Tribune, valuation, taxation, synthetic equity, Charles Rangel

8.

Taxes and Competitiveness

U of Penn, Inst for Law & Econ Research Paper No. 06-28
Number of pages: 43 Posted: 22 Dec 2006
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 547 (70,930)

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international competitiveness, tax competition, foreign direct investment, international tax, international finance, tax incentives, cross-border transactions, foreign tax credits, capital export neutrality, capital import neutrality, capital ownership neutrality, mihir desai, james hines, ubit

9.

Prejudgment Interest in International Arbitration

U of Penn, Inst for Law & Econ Research Paper No. 07-32, Fordham Law Legal Studies Research Paper No. 1029710
Number of pages: 24 Posted: 16 Nov 2007
Jeffrey M. Colon and Michael S. Knoll
Fordham University School of Law and University of Pennsylvania Carey Law School
Downloads 530 (74,099)
Citation 1

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Prejudgment interest, international arbitration, international trade, alternative dispute resolution, law & economics, compensation, coerced loan, damages, time value of money, award, currency conversion

10.

International Competitiveness, Tax Incentives, and a New Argument for Tax Sparing: Preventing Double Taxation by Crediting Implicit Taxes

U of Penn, Inst for Law & Econ Research Paper No. 08-21
Number of pages: 40 Posted: 29 Aug 2008
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 527 (74,261)

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tax sparing, foreign tax credit, worldwide taxation, competitiveness, tax competition, implicit taxes, foreign direct investment, international taxation, capital export neutrality, CEN, capital import neutrality, CIN, capital ownership neutrality, CON, national neutrality, NN

11.

The Corporate Income Tax and the Competitiveness of U.S. Industries

U of Penn, Inst for Law & Econ Research Paper No. 09-01
Number of pages: 30 Posted: 21 Jan 2009
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 485 (82,159)
Citation 1

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foreign direct investment, international taxation, tax competition, capital export neutrality (CEN), capital import neutrality (CIN), capital ownership neutrality (CON), automobiles, bailout, credit crunch, value added tax, formulary apportionment, and cost of capital allowance (COCA)

12.

Ninth Circuit Amicus Brief of 19 Tax Law and Administrative Law Professors, Altera v. Commissioner, Nos. 16-70496, 16-70497

USC Law Legal Studies Paper No. 16-5, USC CLASS Research Paper No. CLASS16-23
Number of pages: 41 Posted: 07 Jul 2016 Last Revised: 05 Aug 2016
Anne Alstott, Reuven S. Avi-Yonah, Lily L. Batchelder, Joshua D. Blank, Noel B. Cunningham, Victor Fleischer, Ari D. Glogower, David Kamin, Mitchell Kane, Sally Katzen, Edward D. Kleinbard, Michael S. Knoll, Rebecca M. Kysar, Zachary D. Liscow, Daniel Shaviro, John P. Steines, David Super, Clint Wallace and George K. Yin
Yale University - Law School, University of Michigan Law School, New York University School of Law, University of California, Irvine School of Law, New York University Law School, UC-Irvine School of Law, Ohio State University (OSU) - Michael E. Moritz College of Law, New York University School of Law, New York University (NYU), New York University School of Law, University of Southern California Gould School of Law, Deceased, University of Pennsylvania Carey Law School, Fordham University School of Law, Yale University - Law School, New York University School of Law, New York University School of Law, Georgetown University Law Center, University of South Carolina School of Law and University of Virginia School of Law
Downloads 431 (94,429)

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13.

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
Daniel J. Hemel, Reuven S. Avi-Yonah, Joseph Bankman, Jordan M. Barry, Lily L. Batchelder, John R. Brooks, Samuel D. Brunson, J. Clifton Fleming, David Gamage, Ari D. Glogower, Jacob Goldin, Andrew J. Haile, David Herzig, David Herzig, Hayes Holderness, Calvin H. Johnson, Richard L. Kaplan, Michael S. Knoll, Zachary D. Liscow, Yair Listokin, Ruth Mason, Goldburn Maynard Jr., Orly Mazur, Susan C. Morse, Richard Pomp, James R. Repetti, Julie Roin, Daniel Schaffa, Erin Adele Scharff, Daniel Shaviro, Jay A. Soled, Sloan G. Speck, Kirk J. Stark, John A. Swain, Adam B. Thimmesch, Manoj Viswanathan, Edward A. Zelinsky and Eric M. Zolt
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 399 (103,564)
Citation 1

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

14.

Taxation and the Competitiveness of Sovereign Wealth Funds: Do Taxes Encourage Sovereign Wealth Funds to Invest in the United States?

Southern California Law Review, Vol. 82, Pg. 703, 2009, U of Penn, Inst for Law & Econ Research Paper No. 08-28
Number of pages: 66 Posted: 31 Oct 2008 Last Revised: 13 Aug 2010
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 385 (107,594)
Citation 1

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sovereign wealth funds, section 892, worldwide taxation, territorial taxation, tax subsidy, international competitiveness, tax competition, foreign investment, direct investment, portfolio investment, international taxation, capital export neutrality (CEN), capital import neutrality (CIN)

15.

The Tax Efficiency of Stock-Based Compensation

Number of pages: 28 Posted: 22 Mar 2004
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 374 (111,147)

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Employee stock options, restricted stock, ESOs, NQOs, ISOs, taxation

16.

Business Taxes and International Competitiveness

U of Penn, Inst for Law & Econ Research Paper No. 08-12
Number of pages: 29 Posted: 28 May 2008
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 358 (116,741)

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competitiveness, taxation, international competitiveness, international taxation, territorial taxation, worldwide taxation, foreign tax credit, source-based taxation, residence-based taxation, capital export neutrality, capital import neutrality, capital ownership neutrality

17.

The Connection between Competitiveness and International Taxation

Tax Law Review, Vol. 65, pp. 349, 2012, U of Penn, Inst for Law & Econ Research Paper No. 12-29
Number of pages: 27 Posted: 21 Sep 2012
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 325 (129,672)

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International Taxation, investment, international competitiveness, tax competition, foreign direct investment, asset acquisition, international finance, tax incentives, cross-border transactions, foreign tax credits, capital export neutrality, capital import neutrality, capital ownership neutrality

18.

Compaq Redux: Implicit Taxes and the Question of Pre-Tax Profit

Virginia Tax Review, Vol. 26, Pg. 821, 2007, U of Penn Law School, Public Law Working Paper No. 06-46, U of Penn, Inst for Law & Econ Research Paper No. 06-27
Number of pages: 38 Posted: 17 Dec 2006 Last Revised: 21 Aug 2009
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 308 (137,187)
Citation 1

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tax shelter, dividend stripping, Compaq, international tax, implicit taxes, tax arbitrage, economic substance, pre-tax profit, Taxation - Federal Income, Law & Economics

19.

The Economic Foundation of the Dormant Commerce Clause

103 Virginia Law Review 309 (2017), Virginia Law and Economics Research Paper No. 8, U of Penn, Inst for Law & Econ Research Paper No. 16-9
Number of pages: 46 Posted: 25 Mar 2016 Last Revised: 23 May 2017
Michael S. Knoll and Ruth Mason
University of Pennsylvania Carey Law School and University of Virginia School of Law
Downloads 280 (151,436)

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dormant commerce clause, Wynne, tax discrimination, competitive neutrality, protectionism

20.

The Modigliani-Miller Theorem at 60: The Long-Overlooked Legal Applications of Finance's Foundational Theorem

Yale Journal on Regulation Bulletin, Vol. 35, Pg. 1, 2018, U of Penn, Inst for Law & Econ Research Paper No. 17-43
Number of pages: 21 Posted: 17 Oct 2017 Last Revised: 03 Dec 2018
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 279 (151,942)

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Law and financial economics, economic theory, corporate finance, arbitrage, debt, equity, leverage, Modigiliani-Miller, reverse M&MI, legal practice and education, deals, transactions

21.

The UBIT: Leveling an Uneven Playing Field or Tilting a Level One?

Fordham Law Review, Vol. 76, p. 857, 2007, U of Penn, Inst for Law & Econ Research Paper No. 07-29
Number of pages: 37 Posted: 07 Nov 2007 Last Revised: 17 Aug 2009
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 241 (175,629)

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Unrelated business income tax, tax-exempt entity, charity, religious organization, nonprofit organization, debt-financed investments, for-profit business, federal income taxation, competitiveness, unfair competition, tax competition, competitive advantage, private activity bonds, property tax

22.

Ninth Circuit Supplemental Brief of Amici Curiae Reuven Avi-Yonah, Lily Batchelder, Joshua Blank, Noel Cunningham, Victor Fleischer, Ari Glogower, David Kamin, Mitchell Kane, Michael Knoll, Rebecca Kysar, Leandra Lederman, Zachary Liscow, Ruth Mason, Susan Morse, Daniel Shaviro, Stephen Shay, John Steines, David Super, Clinton Wallace, Bret Wells in Support of Respondent-Appellant Commissioner

Number of pages: 27 Posted: 15 Oct 2018
Susan C. Morse, Stephen E. Shay, Reuven S. Avi-Yonah, Lily L. Batchelder, Joshua D. Blank, Noel B. Cunningham, Victor Fleischer, Ari D. Glogower, David Kamin, Mitchell Kane, Michael S. Knoll, Rebecca M. Kysar, Leandra Lederman, Zachary D. Liscow, Ruth Mason, Daniel Shaviro, John P. Steines, David Super, Clint Wallace and Bret Wells
University of Texas at Austin - School of Law, Boston College Law School, University of Michigan Law School, New York University School of Law, University of California, Irvine School of Law, New York University Law School, UC-Irvine School of Law, Ohio State University (OSU) - Michael E. Moritz College of Law, New York University School of Law, New York University (NYU), University of Pennsylvania Carey Law School, Fordham University School of Law, Indiana University Maurer School of Law, Yale University - Law School, University of Virginia School of Law, New York University School of Law, New York University School of Law, Georgetown University Law Center, University of South Carolina School of Law and University of Houston Law Center
Downloads 238 (177,771)
Citation 1

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Altera, transfer pricing, Section 482, arbitrary and capricious, stock-based compensation

23.

Taxation, Competitiveness, and Inversions: A Response to Kleinbard

Tax Notes, Vol. 155, P. 619, 2017, U of Penn, Inst for Law & Econ Research Paper No. 17-21
Number of pages: 35 Posted: 23 May 2017
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 219 (192,396)

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Tax Law and Policy, Empirical Legal Studies, International Taxation, Multinational Corporations, Corporate Inversions, Mergers and Acquisitions, M&a, Pfizer, Allergan, Emerson Electric, Competitiveness, Earnings Stripping

24.

Wynne: It's Not About Double Taxation

State Tax Notes, Vol. 75, P. 413, 2015, U of Penn, Inst for Law & Econ Research Paper No. 14-44, Virginia Law and Economics Research Paper No. 3, Virginia Public Law and Legal Theory Research Paper No. 1
Number of pages: 11 Posted: 16 Jan 2015 Last Revised: 06 Mar 2015
Michael S. Knoll and Ruth Mason
University of Pennsylvania Carey Law School and University of Virginia School of Law
Downloads 204 (205,515)

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Constitutional law, Supreme Court of the United States, Maryland, state and local income tax, internal consistency test, interstate and intra-state commerce, due process clause, uniform source, uniform residence, tax-induced competitive disadvantage, double taxation

25.

Before International Tax Reform, We Need to Understand Why Firms Invert

Wharton Public Policy Initiative Issue Brief, Volume 5, Issue 8, September 2017., U of Penn, Inst for Law & Econ Research Paper No. 17-44
Number of pages: 9 Posted: 17 Oct 2017
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 147 (271,650)

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Taxation, law & economics, corporations, multi-national business organizations, foreign competition, re-flagging of MNCs, inversions, global effective tax rates, tax disadvantages of U.S.-domiciled corporations, motivations to invert, improving competitiveness, post-inversion ETRs

26.

Waiting for Perseus: A Sur-Reply to Professors Graetz and Warren

Tax Law Review, Forthcoming, U of Penn, Inst for Law & Econ Research Paper No. 13-32, Virginia Law and Economics Research Paper No. 2014-02
Number of pages: 80 Posted: 15 Nov 2013 Last Revised: 15 Jun 2020
Ruth Mason and Michael S. Knoll
University of Virginia School of Law and University of Pennsylvania Carey Law School
Downloads 134 (291,878)

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Taxation, discrimination, capital export neutrality, CEN, capital import neutrality, CIN, capital ownership neutrality, CON, European Court of Justice, ECJ, competitive neutrality, European Union

27.

Is the Philadelphia Wage Tax Unconstitutional? And If It Is, What Can and Should the City Do?

University of Pennsylvania Law Review Online, Vol. 164, P. 163, 2016, U of Penn, Inst for Law & Econ Research Paper No. 16-10
Number of pages: 17 Posted: 09 May 2016
Michael S. Knoll and Ruth Mason
University of Pennsylvania Carey Law School and University of Virginia School of Law
Downloads 127 (303,952)

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Constitutional Law, Supreme Court of the United States, SCOTUS, Local Taxation, Tax Discrimination, Dormant Commerce Clause, Internal Consistency, Philadelphia Wage Tax, Economic Development

28.

Economic and Legal Arguments in PPL v. Commissioner

U of Penn, Inst for Law & Econ Research Paper No. 13-5
Number of pages: 15 Posted: 09 Feb 2013
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 120 (316,848)

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UK Windfall Profit Tax Act of 1997, foreign tax credits, privatization of British utilities, corporate valuation, historical earnings vs. expected value of earnings, creditable tax

29.

The TCJA and the Questionable Incentive to Incorporate

Tax Notes, March 4, 2019, P. 977., U of Penn, Inst for Law & Econ Research Paper No. 19-12
Number of pages: 12 Posted: 02 Apr 2019
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 114 (328,442)

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federal income taxation, tax reform, Tax Cuts & Jobs Act, TCJA, passthrough entities, mass conversion, C corporations, comparison, top statutory tax rates, rate changes, passthrough deduction, deferral of income, consumption and investment with different entities, basic and tax equivalence

30.

On the Disparate Treatment of Business and Personal SALT Payments

Tax Notes, Vol. 158, p. 331, 2018, U of Penn, Inst for Law & Econ Research Paper No. 18-5
Number of pages: 7 Posted: 16 Nov 2017 Last Revised: 12 Feb 2018
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 102 (354,160)

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Tax Law and Policy, Law and Economics, SALT Deduction, Real & Personal Property Taxes, Wage & General Income Taxes, Public Benefits

31.

The Dormant Foreign Commerce Clause After Wynne

39 Virginia Tax Review 357 (2020), Virginia Law and Economics Research Paper No. 2020-03, U of Penn, Inst for Law & Econ Research Paper No. 20-21
Number of pages: 62 Posted: 11 Mar 2020 Last Revised: 26 May 2020
Michael S. Knoll and Ruth Mason
University of Pennsylvania Carey Law School and University of Virginia School of Law
Downloads 100 (358,755)

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32.

Amicus Brief in Maryland Comptroller v. Wynne

U of Penn, Inst for Law & Econ Research Paper No. 14-38, Virginia Public Law and Legal Theory Research Paper No. 2014-67
Number of pages: 42 Posted: 30 Sep 2014 Last Revised: 04 Nov 2015
Michael S. Knoll and Ruth Mason
University of Pennsylvania Carey Law School and University of Virginia School of Law
Downloads 97 (365,805)
Citation 1

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Dormant commerce clause, tax discrimination, Wynne, Complete Auto, Moorman, jefferson Lines, double taxation

33.

How the Massachusetts Supreme Judicial Court Should Apply Wynne

State Tax Notes, Vol. 78, P. 921, 2015, U of Penn, Inst for Law & Econ Research Paper No. 16-4
Number of pages: 8 Posted: 16 Jan 2016 Last Revised: 21 Mar 2016
Michael S. Knoll and Ruth Mason
University of Pennsylvania Carey Law School and University of Virginia School of Law
Downloads 95 (370,541)

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tax discrimination, dormant commerce clause, Wynne, Supreme Court, apportionment formulas, double taxation, state taxes

34.

Comptroller v. Wynne: Internal Consistency, a National Marketplace, and Limits on State Sovereignty to Tax

University of Pennsylvania Law Review Online, Vol. 163, p. 267, 2015, U of Penn, Inst for Law & Econ Research Paper No. 15-10
Number of pages: 18 Posted: 25 Mar 2015
Michael S. Knoll and Ruth Mason
University of Pennsylvania Carey Law School and University of Virginia School of Law
Downloads 95 (370,541)

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Dormant commerce clause, tax discrimination, double taxation, Moorman, Supreme Court of the United States, internal consistency, source and residence priority rule, interstate and intrastate commerce, federalism, competitive advantage

35.

Regulatory Arbitrage Using Put-Call Parity

Journal of Applied Finance, Vol. 15, No. 1 Spring/Summer 2005
Number of pages: 11 Posted: 20 Aug 2005
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 90 (383,239)

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36.

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
Daniel J. Hemel, Reuven S. Avi-Yonah, Lily L. Batchelder, Samuel D. Brunson, J. Clifton Fleming, David Gamage, Ari D. Glogower, Jacob Goldin, Hayes Holderness, Michael S. Knoll, Zachary D. Liscow, Ruth Mason, Goldburn Maynard Jr., Richard Pomp, James R. Repetti, Julie Roin, Erin Adele Scharff, Jay A. Soled and Edward A. Zelinsky
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 (394,116)

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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

37.

The TCJA and the Questionable Incentive to Incorporate, Part 2

Tax Notes, March 25, 2019, p. 1447., U of Penn, Inst for Law & Econ Research Paper No. 19-15
Number of pages: 17 Posted: 22 Apr 2019
Michael S. Knoll
University of Pennsylvania Carey Law School
Downloads 78 (417,099)
Citation 1

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Federal income taxation, tax reform, Tax Cuts & Jobs Act, TCJA, passthrough entities, mass conversion, C corporations, comparison, statutory tax rates, rate changes, passthrough deduction, potential tax advantages of incorporation, business reinvestment, tax risk from incorporation

38.

Dual Residents: A Sur-Reply to Zelinsky

State Tax Notes, P. 269, January 15, 2018, U of Penn, Inst for Law & Econ Research Paper No. 18-4, Virginia Law and Economics Research Paper No. 2018-01
Number of pages: 7 Posted: 14 Feb 2018 Last Revised: 20 Feb 2018
Michael S. Knoll and Ruth Mason
University of Pennsylvania Carey Law School and University of Virginia School of Law
Downloads 61 (474,663)

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Constitutional law, state income taxation, dormant commerce clause, Comptroller of the Treasury v. Wynne, internal consistency test, subsidies, residence rules, double taxation, discriminatory taxation

39.

A Brief Sur-Reply to Professors Graetz and Warren

Yale Law Journal Online, 123:1 2013, U of Penn, Inst for Law & Econ Research Paper No. 13-17
Number of pages: 16 Posted: 20 May 2013 Last Revised: 12 Nov 2013
Ruth Mason and Michael S. Knoll
University of Virginia School of Law and University of Pennsylvania Carey Law School
Downloads 56 (493,977)

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ECJ, tax discrimination, competitive neutrality, CON, capital ownership neutrality, CEN, capital export neutrality

40.

New York’s Unconstitutional Tax Residence Rule

85 State Tax Notes 787 (2017)
Number of pages: 10 Posted: 28 Jun 2019
Ruth Mason and Michael S. Knoll
University of Virginia School of Law and University of Pennsylvania Carey Law School
Downloads 47 (532,593)

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wynne, Tamagni, dormant commerce clause, internal consistency test, New York tax residence rule

41.

Amicus Brief in Wayfair v. South Dakota

Number of pages: 24 Posted: 25 Apr 2018
Alex Brill, Michael S. Knoll, Ruth Mason and Alan D. Viard
American Enterprise Institute (AEI), University of Pennsylvania Carey Law School, University of Virginia School of Law and American Enterprise Institute
Downloads 41 (561,663)

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Dormant Commerce Clause, Wynne, Pike, Wayfair, Quill, Bellas Hess

42.

Steiner v. Utah: Designing a Constitutional Remedy

95 Tax Notes State 845
Number of pages: 7 Posted: 08 Apr 2022
Ruth Mason and Michael S. Knoll
University of Virginia School of Law and University of Pennsylvania Carey Law School
Downloads 12 (760,343)

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Steiner, Wynne, dormant Commerce Clause, tax credits

43.

Why the Supreme Court Should Grant Certiorari in Steiner v. Utah

95 Tax Notes State 377 (2020)
Number of pages: 13 Posted: 08 Apr 2022
Ruth Mason and Michael S. Knoll
University of Virginia School of Law and University of Pennsylvania Carey Law School
Downloads 11 (769,330)

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44.

The Case for Repealing the Corporate Alternative Minimum Tax

Posted: 06 Jun 2003
Terrence R. Chorvat and Michael S. Knoll
George Mason University - Antonin Scalia Law School, Faculty and University of Pennsylvania Carey Law School

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45.

Simplifying the Transition to a (Progressive) Consumption Tax

Posted: 08 May 2003
Mitchell L. Engler and Michael S. Knoll
Yeshiva University - Benjamin N. Cardozo School of Law and University of Pennsylvania Carey Law School

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Consumption tax, Income tax

46.

Taxing Sunny Days: Adjusting Taxes for Regional Living Costs and Amenities

Posted: 18 Mar 2003
Michael S. Knoll and Thomas Douglas Griffith
University of Pennsylvania Carey Law School and University of Southern California Law School

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47.

Socially Responsible Investment and Modern Financial Markets

USC Law Center Working Paper No. 94-13
Posted: 14 Sep 1999
Michael S. Knoll
University of Pennsylvania Carey Law School

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48.

Hedging in an Economy with Asymmetric Taxes: A Comment on Moshe Ayre Milevsky & Eliezer Z. Prisman, Hedging and Pricing with Tax Law Uncertainty: Managing Under an Arkansas Best Doctrine

Downloads 0 (891,729)

Hedging in an Economy with Asymmetric Taxes: A Comment on Moshe Ayre Milevsky & Eliezer Z. Prisman, Hedging and Pricing with Tax Law Uncertainty: Managing Under an Arkansas Best Doctrine

Annual Proceedings of the Chicago Board of Trade
Posted: 17 Feb 1999
Michael S. Knoll
University of Pennsylvania Carey Law School

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49.

Put-Call Parity and the Law

USC Working Paper No. 94-12
Posted: 10 Oct 1998
Michael S. Knoll
University of Pennsylvania Carey Law School

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50.

Financial Innovation, Tax Arbitrage, and Retrospective Taxation: The Problem with Passive Government Lending

Posted: 28 May 1998
Michael S. Knoll
University of Pennsylvania Carey Law School

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51.

The Principle of Marginal Deterrence in Torts: The Potentially Perverse Effects of Stiffer Tort Penalties and Higher Taxes

Olin Working Paper No. 97-18
Posted: 05 Apr 1998
Michael S. Knoll
University of Pennsylvania Carey Law School

Abstract:

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52.

Antidumping

Olin Working Papers 97-15
Posted: 10 Jan 1998
Ronald A. Cass, Richard D. Boltuck, Seth T. Kaplan and Michael S. Knoll
Center for the Rule of Law, Consultant, Trade Resources Company and University of Pennsylvania Carey Law School

Abstract:

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53.

Put-Call Parity and the Development of the Modern Mortgage

Posted: 09 Apr 1997
Michael S. Knoll
University of Pennsylvania Carey Law School

Abstract:

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54.

Products Liability and Legal Leverage: The Perverse Effects of Stiff Penalties

University of Southern California Law Center, Working Paper Series No. 97-3
Posted: 25 Mar 1997
Michael S. Knoll
University of Pennsylvania Carey Law School

Abstract:

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55.

An Accretion Corporate Income Tax

Stanford Law Review, Vol. 49, No. 1, November 1996.
Posted: 21 Oct 1996
Michael S. Knoll
University of Pennsylvania Carey Law School

Abstract:

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56.

A Primer on Prejudgment Interest

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A Primer on Prejudgment Interest

Working Paper No. 95-3, University of Southern California Law Center
Posted: 03 May 1995
Michael S. Knoll
University of Pennsylvania Carey Law School

Abstract:

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A Primer on Prejudgment Interest

Texas Law Review, Vol. 75, No. 2 (1997).
Posted: 17 Apr 1997
Michael S. Knoll
University of Pennsylvania Carey Law School

Abstract:

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