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Michael S. Knoll

University of Pennsylvania Wharton School -- Real Estate Department

Philadelphia, PA 19104-6330

United States

University of Pennsylvania Law School

Professor

3501 Sansom Street

Philadelphia, PA 19104

United States

  • University of Pennsylvania Wharton School -- Real Estate Department

  • University of Pennsylvania Law School

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

44

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CITATIONS
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25

Scholarly Papers (44)

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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 Law School
Downloads 1,637 (7,698)
Citation 5

Abstract:

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 Law School
Downloads 1,019 (15,016)
Citation 3

Abstract:

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

3.

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 Law School
Downloads 990 (17,031)
Citation 4

Abstract:

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

4.

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 Law School
Downloads 927 (16,632)

Abstract:

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

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 Law School and Fordham University School of Law
Downloads 844 (20,008)

Abstract:

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 Law School
Downloads 600 (29,775)
Citation 1

Abstract:

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 Law School
Downloads 599 (33,964)

Abstract:

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 Law School
Downloads 478 (44,327)
Citation 1

Abstract:

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.

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 Law School
Downloads 444 (49,342)
Citation 1

Abstract:

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

10.

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 Law School
Downloads 435 (51,401)
Citation 1

Abstract:

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)

11.

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 Law School
Downloads 433 (48,713)

Abstract:

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

12.

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 Law School
Downloads 363 (67,898)
Citation 2

Abstract:

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)

13.

The Tax Efficiency of Stock-Based Compensation

Tax Notes, Vol. 102, No. 15, April 12, 2004
Number of pages: 28 Posted: 22 Mar 2004
Michael S. Knoll
University of Pennsylvania Law School
Downloads 338 (71,818)
Citation 1

Abstract:

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

14.

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 Law School
Downloads 321 (74,559)
Citation 2

Abstract:

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

15.

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 Law School
Downloads 285 (86,377)

Abstract:

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

16.

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 Law School
Downloads 235 (87,382)

Abstract:

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

17.

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 Law School
Downloads 208 (114,496)
Citation 3

Abstract:

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

18.

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 Law School and University of Virginia School of Law
Downloads 119 (159,504)

Abstract:

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

19.

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 Law School
Downloads 106 (206,094)

Abstract:

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

20.

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: 164 Posted: 15 Nov 2013 Last Revised: 13 Sep 2014
Ruth Mason and Michael S. Knoll
University of Virginia School of Law and University of Pennsylvania Law School
Downloads 87 (223,117)

Abstract:

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

21.

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 Law School and University of Virginia School of Law
Downloads 60 (271,091)

Abstract:

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

22.

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 Law School and University of Virginia School of Law
Downloads 52 (266,945)

Abstract:

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

23.

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 Law School
Downloads 34 (361,459)

Abstract:

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

24.

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 Law School
Downloads 20 (361,459)
Citation 1

Abstract:

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 Law School
Downloads 0 (527,566)

Abstract:

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.

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

U of Penn, Inst for Law & Econ Research Paper No. 17-43
Number of pages: 21 Posted: 17 Oct 2017
Michael S. Knoll
University of Pennsylvania Law School
Downloads 0 (508,763)

Abstract:

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

27.

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 Law School
Downloads 0 (158,645)

Abstract:

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

28.

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, New York University School of Law, New York University Law School, University of San Diego 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, USC Gould School of Law, University of Pennsylvania Law School, Brooklyn Law School, Yale University - Law School, New York University School of Law, New York University School of Law, Georgetown University Law Center, New York University School of Law and University of Virginia School of Law
Downloads 0 (106,877)

Abstract:

29.

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 Law School and University of Virginia School of Law
Downloads 0 (217,153)

Abstract:

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

30.

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 Law School and University of Virginia School of Law
Downloads 0 (124,198)

Abstract:

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

31.

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 Law School and University of Virginia School of Law
Downloads 0 (266,945)

Abstract:

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

32.

The Case for Repealing the Corporate Alternative Minimum Tax

Southern Methodist University Law Review, Vol. 56, p. 305, 2003
Posted: 06 Jun 2003
Terrence R. Chorvat and Michael S. Knoll
George Mason University School of Law and University of Pennsylvania Law School

Abstract:

33.

Simplifying the Transition to a (Progressive) Consumption Tax

Southern Methodist University Law Review, Vol. 56, No. 53, 2003
Posted: 08 May 2003
Mitchell L. Engler and Michael S. Knoll
Benjamin N. Cardozo School of Law and University of Pennsylvania Law School

Abstract:

Consumption tax, Income tax

34.

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

Harvard Law Review, Vol. 116, p. 987, 2003
Posted: 18 Mar 2003
Michael S. Knoll and Thomas Douglas Griffith
University of Pennsylvania Law School and University of Southern California Law School

Abstract:

35.

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 Law School

Abstract:

36.

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 (568,809)

Abstract:

Abstract:

37.

Put-Call Parity and the Law

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

Abstract:

38.

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

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

Abstract:

39.

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 Law School

Abstract:

40.

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 Law School

Abstract:

41.

Put-Call Parity and the Development of the Modern Mortgage

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

Abstract:

42.

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 Law School

Abstract:

43.

An Accretion Corporate Income Tax

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

Abstract:

44.

A Primer on Prejudgment Interest

Downloads 0 (568,809)

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 Law School

Abstract:

A Primer on Prejudgment Interest

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

Abstract:

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