Gregg D. Polsky

University of Georgia School of Law

Francis Shackelford Professor of Taxation

225 Herty Drive

Athens, GA 30602

United States

SCHOLARLY PAPERS

33

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CITATIONS
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12

Scholarly Papers (33)

1.

Acqui-Hiring

Duke Law Journal, Vol. 63, p. 281, 2013, UNC Legal Studies Research Paper No. 2040924
Number of pages: 66 Posted: 16 Apr 2012 Last Revised: 30 Oct 2013
John F. Coyle and Gregg D. Polsky
University of North Carolina School of Law and University of Georgia School of Law
Downloads 4,482 (1,748)

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start up companies, venture capital, acqhiring, acquire to hire, noncompetition, employment contract, silicon valley, social norms

2.

A Compendium of Private Equity Tax Games

UNC Legal Studies Research Paper No. 2524593
Number of pages: 18 Posted: 16 Nov 2014
Gregg D. Polsky
University of Georgia School of Law
Downloads 2,756 (4,090)

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tax, private equity, carried interest, management fee waiver, monitoring fees, management fee offset

Private Equity Management Fee Conversions

FSU College of Law, Public Law Research Paper No. 337, FSU College of Law, Law, Business & Economics Paper No. 08-18
Number of pages: 43 Posted: 06 Nov 2008 Last Revised: 14 Jan 2012
Gregg D. Polsky
University of Georgia School of Law
Downloads 2,406 (4,987)
Citation 1

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fee waiver, fee waivers, management fee waivers, private equity management fee waivers

Private Equity Management Fee Conversions

Tax Notes, Vol. 122, No. 7, 2009
Posted: 13 Feb 2009 Last Revised: 14 Jan 2012
Gregg D. Polsky
University of Georgia School of Law

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fee waivers, fee waiver, fee conversion, fee conversions, private equity, private equity management fees, private equity management fee waiver

4.

High Volatility, Negative Correlation, Roth IRA Conversions, and the Codified Economic Substance Doctrine

UNC Legal Studies Research Paper No. 1717019
Number of pages: 9 Posted: 30 Nov 2010
Gregg D. Polsky
University of Georgia School of Law
Downloads 580 (44,734)

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5.

Explaining Choice-of-Entity Decisions by Silicon Valley Start-Ups

University of Georgia School of Law Legal Studies Research Paper No. 2018-11
Number of pages: 46 Posted: 01 Mar 2018 Last Revised: 15 Feb 2019
Gregg D. Polsky
University of Georgia School of Law
Downloads 573 (45,429)

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6.

The Up-C Revolution

University of Georgia School of Law Legal Studies Research Paper No. 2016-40
Number of pages: 38 Posted: 15 Oct 2016 Last Revised: 13 Nov 2016
Gregg D. Polsky and Adam H. Rosenzweig
University of Georgia School of Law and Washington University in St. Louis - School of Law
Downloads 565 (46,270)

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Up-C structure, initial public offering, tax receivables agreement, IPO, TRA, stepped up basis, choice of entity

7.

Taxing Punitive Damages

Virginia Law Review, Vol. 96, No. 6, 2010
Number of pages: 66 Posted: 19 Jun 2009 Last Revised: 27 Sep 2010
Gregg D. Polsky and Dan Markel
University of Georgia School of Law and Florida State University College of Law (Deceased)
Downloads 478 (57,206)

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punitive damages, tax, torts, dispute resolution

8.

Reforming the Taxation of Deferred Compensation

North Carolina Law Review, Forthcoming, Georgetown Law and Economics Research Paper No. 913055, Minnesota Legal Studies Research Paper No. 06-29
Number of pages: 66 Posted: 30 Jun 2006
Ethan Yale and Gregg D. Polsky
University of Virginia School of Law and University of Georgia School of Law
Downloads 370 (77,761)
Citation 2

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taxes, executive compensation, corporate governance

9.

Deterring Tax-Driven Partnership Allocations

FSU College of Law, Public Law Research Paper No. 436, FSU College of Law, Law, Business & Economics Paper No. 10-3
Number of pages: 28 Posted: 22 Mar 2010 Last Revised: 24 Apr 2010
Gregg D. Polsky
University of Georgia School of Law
Downloads 305 (96,698)

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10.

Examining the Tax Advantage of Founders' Stock

Iowa Law Review, Forthcoming, UNC Legal Studies Research Paper No. 1997179
Number of pages: 78 Posted: 02 Feb 2012
Gregg D. Polsky and Brant J. Hellwig
University of Georgia School of Law and Washington and Lee University - School of Law
Downloads 243 (122,906)

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founders' stock, stock options, joint tax perspective, net operating losses, equity compensation, venture capital, startup companies

11.

Employment Discrimination Remedies and Tax Gross Ups

Iowa Law Review, Vol. 90, October 2004
Number of pages: 43 Posted: 03 May 2004
Gregg D. Polsky and Stephen F. Befort
University of Georgia School of Law and University of Minnesota Law School
Downloads 233 (128,225)

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12.

Fixing Section 409A: Legislative and Administrative Options

Villanova Law Review, Forthcoming, UNC Legal Studies Research Paper No. 1996746
Number of pages: 15 Posted: 02 Feb 2012
Gregg D. Polsky
University of Georgia School of Law
Downloads 231 (129,335)

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taxation, deferred compensation, nonqualified deferred compensation, section 409A, constructive receipt, economic benefit doctrine, rabbi trusts, deferral

13.

Regulating 527 Organizations

George Washington Law Review, Forthcoming, Minnesota Legal Studies Research Paper No. 05-21
Number of pages: 36 Posted: 17 Jun 2005
Gregg D. Polsky and Guy-Uriel E. Charles
University of Georgia School of Law and Duke University School of Law
Downloads 230 (129,875)
Citation 1

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527 organizations, FEC, Buckley, MCFL

14.

The Diminishing Returns of Incentive Pay in Executive Compensation Contracts

Notre Dame Law Review, Forthcoming, UNC Legal Studies Research Paper No. 1838387
Number of pages: 55 Posted: 13 May 2011
Andrew Lund and Gregg D. Polsky
Villanova University School of Law and University of Georgia School of Law
Downloads 229 (130,438)

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incentive pay, executive compensation, stock options, agency costs, managerial labor market, pay for performance

15.

The Contingent Attorney's Fee Tax Trap: Ethical, Fiduciary Duty, and Malpractice Implications

Virginia Tax Review, Vol. 23, 2004
Number of pages: 23 Posted: 12 Nov 2003
Gregg D. Polsky
University of Georgia School of Law
Downloads 216 (137,980)

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16.

A Tax Lawyer's Perspective on Section 527 Organizations

Cardozo Law Review, February 2007, Minnesota Legal Studies Research Paper No. 06-49
Number of pages: 14 Posted: 24 Sep 2006
Gregg D. Polsky
University of Georgia School of Law
Downloads 210 (141,767)
Citation 2

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17.

Private Equity Monitoring Fees as Disguised Dividends: Collateral Impact

Tax Notes, Vol. 143, No. 1053, 2014, UNC Legal Studies Research Paper No. 2461733
Number of pages: 5 Posted: 04 Jul 2014
Gregg D. Polsky
University of Georgia School of Law
Downloads 205 (144,983)

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tax, private equity, monitoring fees, disguised dividends, Sun Capital

18.

Can Treasury Overrule the Supreme Court?

Boston University Law Review, Vol. 84, 2004
Number of pages: 65 Posted: 20 Oct 2003
Gregg D. Polsky
University of Georgia School of Law
Downloads 196 (151,203)
Citation 3

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19.

Controlling Executive Compensation through the Tax Code

Washington and Lee Law Review, Vol. 64, No. 3, Summer 2007, FSU College of Law, Public Law Research Paper No. 291, FSU College of Law, Law and Economics Paper No. 07-26
Number of pages: 50 Posted: 15 Nov 2007
Gregg D. Polsky
University of Georgia School of Law
Downloads 191 (154,876)
Citation 3

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20.

Taxing the Promise to Pay

Minnesota Law Review, Vol. 89, April 2005
Number of pages: 60 Posted: 02 Apr 2005
Brant J. Hellwig and Gregg D. Polsky
Washington and Lee University - School of Law and University of Georgia School of Law
Downloads 187 (157,859)

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21.

Taxing Structured Settlements

Boston College Law Review, Forthcoming, FSU College of Law, Public Law Research Paper No. 373
Number of pages: 50 Posted: 21 May 2009 Last Revised: 23 Sep 2009
Gregg D. Polsky and Brant J. Hellwig
University of Georgia School of Law and Washington and Lee University - School of Law
Downloads 185 (159,366)

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22.

The End of Cash, the Income Tax, and the Next 100 Years

Florida State University Law Review, Vol. 41, 2013, FSU College of Law, Public Law Research Paper No. 676, UNC Legal Studies Research Paper No. 2401636, FSU College of Law, Law, Business & Economics Paper
Number of pages: 14 Posted: 27 Feb 2014
Jeffrey H. Kahn and Gregg D. Polsky
Florida State University - College of Law and University of Georgia School of Law
Downloads 154 (186,964)

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tax gap, income tax, consumption tax, cash, cashless

23.

Must Contingent Fee Lawyers Capitalize Litigation Costs?

Tax Notes, Vol. 141, No. 295, 2013, UNC Legal Studies Research Paper No. 2345314
Number of pages: 12 Posted: 26 Oct 2013
Gregg D. Polsky and R. Crawford
University of Georgia School of Law and Robinson, Bradshaw & Hinson, P.A.
Downloads 147 (194,309)

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litigation costs, capitalization, Boccardo, INDOPCO regulations

24.

The Problem of Abusive Related-Partner Allocations

Florida Tax Review, Vol. 16, No. 479, 2014, UNC Legal Studies Research Paper No. 2526464
Number of pages: 40 Posted: 19 Nov 2014
Emily Cauble and Gregg D. Polsky
DePaul University - College of Law and University of Georgia School of Law
Downloads 134 (209,399)

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partnership tax, related partners, allocations, substantial economic effect, anti-abuse rule, blockers

25.

Comments on the Proposed Regulations on Disguised Payments for Services

UNC Legal Studies Research Paper No. 2690905
Number of pages: 13 Posted: 16 Nov 2015
Gregg D. Polsky
University of Georgia School of Law
Downloads 99 (261,138)

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management fee waivers, private equity tax

26.

Revisiting the Taxation of Punitive Damages

Virginia Law Review In Brief, Vol. 97, pp. 73-82, 2011, FSU College of Law, Public Law Research Paper No. 510, UNC Legal Studies Research Paper No. 1885722
Number of pages: 10 Posted: 15 Jul 2011 Last Revised: 10 Sep 2011
Gregg D. Polsky and Dan Markel
University of Georgia School of Law and Florida State University College of Law (Deceased)
Downloads 99 (261,138)

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tax, torts, punitive damages

27.

Reconstructing the Individual Mandate as an Escrow Account

Michigan Law Review First Impressions, Vol. 109, p. 73, March 2010, UNC Legal Studies Research Paper No. 1786627
Number of pages: 5 Posted: 18 Mar 2011
Gregg D. Polsky
University of Georgia School of Law
Downloads 76 (307,584)

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health care, individual mandate

28.

Tax Consequences of Distributing Equity Compensation Rights in Divorce

88 Florida Bar Journal 14 (January 2014), UNC Legal Studies Research Paper No. 2382736
Number of pages: 12 Posted: 23 Jan 2014
Gregg D. Polsky, Jeffrey Fisher and Zachary Potter
University of Georgia School of Law, Fisher & Bendeck, P.L. and Fisher & Bendeck, P.L.
Downloads 71 (319,668)

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stock options, restricted stock, divorce, tax, equitable distribution

29.

End Tax Floats by Taxing Receivables or Deferring Payables

Tax Notes, Vol. 129, p. 1243, December, 2010, The Shelf Project
Number of pages: 14 Posted: 30 May 2012
Calvin H. Johnson and Gregg D. Polsky
University of Texas at Austin - School of Law and University of Georgia School of Law
Downloads 49 (382,876)

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30.

Close the Yield Exemption Loophole Created by Childs

Tax Notes, Vol. 123, No. 9, pp. 1141-1145, June 1, 2009, The Shelf Project
Number of pages: 6 Posted: 03 Dec 2009
Gregg D. Polsky and Brant J. Hellwig
University of Georgia School of Law and Washington and Lee University - School of Law
Downloads 41 (411,164)

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contractual obligation payment, Section 83

31.

There's a Problem With Buybacks, But It's Not What Senators Think

Tax Notes, February 18, 2019, Volume 162, Number 7, p. 765
Number of pages: 5 Posted: 02 May 2019
Daniel Jacob Hemel and Gregg D. Polsky
University of Chicago - Law School and University of Georgia School of Law
Downloads 27 (471,426)

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buybacks, redemptions, share repurchases, corporate tax, corporate distributions, dividends

32.

A Correct Analysis of the Tax Treatment of Contingent Attorney's Fee Arrangements: Enough with the Fruits and the Trees

Georgia Law Review, Vol. 37, No. 57, 2002
Posted: 06 Mar 2003
Gregg D. Polsky
University of Georgia School of Law

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33.

Taxing Contingent Attorneys' Fees: Many Courts are Getting it Wrong

Tax Notes, November 13, 2000
Posted: 09 Nov 2000
Gregg D. Polsky
University of Georgia School of Law

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Other Papers (1)

Total Downloads: 71    Citations: 0
1.

The Untold Story of Sun Capital: Disguised Dividends

Tax Notes, Vol. 142, No. 556, 2014
Number of pages: 7 Posted: 08 May 2014
Gregg D. Polsky
University of Georgia School of Law
Downloads 71

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private equity, portfolio companies, management fee offsets, disguised dividends, compensatory intent