Susan C. Morse

University of Texas at Austin - School of Law

727 East Dean Keeton Street

Austin, TX 78705

United States

  • University of Texas at Austin - School of Law

SCHOLARLY PAPERS

36

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Scholarly Papers (36)

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1.

Startup Ltd.: Tax Planning and Initial Incorporation Location

14 Florida Tax Review 319 (2013)
Number of pages: 42 Posted: 07 Jun 2013 Last Revised: 12 Oct 2013
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 1,111 (27,743)

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incorporation location, startup, tax haven

2.

Tax Haven Incorporation for U.S. Headquartered Firms: No Exodus Yet

National Tax Journal, 66, 2013, Forthcoming
Number of pages: 39 Posted: 28 Oct 2011 Last Revised: 15 May 2013
Eric J. Allen and Susan C. Morse
University of California, Riverside (UCR) - School of Business Administration and University of Texas at Austin - School of Law
Downloads 859 (39,899)
Citation 4

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international taxation, initial public offerings, tax havens, headquarters, incorporation

3.

Cash Businesses and Tax Evasion

Stanford Law & Policy Review, Vol. 20, 2009
Number of pages: 32 Posted: 11 Sep 2008 Last Revised: 14 Nov 2012
Susan C. Morse, Stewart Karlinsky and Joseph Bankman
University of Texas at Austin - School of Law, San Jose State University - Donald and Sally Lucas Graduate School of Business and Stanford Law School
Downloads 717 (50,772)
Citation 1

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tax compliance, tax evasion, small businesses

4.

Revisiting Global Formulary Apportionment

Virginia Tax Review, Vol. 29, p. 593, 2010
Number of pages: 52 Posted: 29 May 2010 Last Revised: 14 Nov 2012
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 422 (98,068)
Citation 1

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5.

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 400 (104,322)
Citation 1

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

6.

Safe Harbors, Sure Shipwrecks

UC Davis Law Review, Vol. 49, 2016, U of Texas Law, Law and Econ Research Paper, U of Texas Law, Public Law Research Paper No. UTPUB630
Number of pages: 46 Posted: 03 Jun 2015 Last Revised: 22 Apr 2016
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 355 (119,332)

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safe harbors, sure shipwrecks, rules, standards

7.

Ask for Help, Uncle Sam: The Future of Global Tax Reporting

Villanova Law Review, Vol. 57(3) 529-550, 2012, UC Hastings Research Paper No. 35
Number of pages: 23 Posted: 05 Feb 2012 Last Revised: 16 Apr 2013
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 326 (130,895)

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tax evasion, offshore accounts, Foreign Account Tax Compliance Act

8.

The How and Why of the New Public Corporation Tax Shelter Compliance Norm

Fordham Law Review Vol. 75, No. 2, 2006
Number of pages: 58 Posted: 02 Jun 2006 Last Revised: 14 Nov 2012
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 325 (131,319)

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tax shelter, compliance, norm, Sarbanes-Oxley, organizational behavior

9.

Tax Compliance and Norm Formation Under High-Penalty Regimes

Downloads 318 (134,246)

Tax Compliance and Norm Formation Under High-Penalty Regimes

Connecticut Law Review, Vol. 44, No. 3, p. 675, 2012
Number of pages: 62 Posted: 13 May 2011 Last Revised: 14 Nov 2012
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 318 (133,521)

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tax compliance, high penalty, norm formation, expressive law, offshore account, FBAR, FATCA

Tax Compliance and Norm Formation Under High-Penalty Regimes

Gruter Institute Squaw Valley Conference: Law, Institutions & Human Behavior, 2011
Posted: 24 May 2011
Susan C. Morse
University of Texas at Austin - School of Law

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10.

Innovation and Taxation at Start-Up Firms

Tax Law Review, Vol. 69, No. 3, 2016
Number of pages: 32 Posted: 03 Nov 2016
Susan C. Morse and Eric J. Allen
University of Texas at Austin - School of Law and University of California, Riverside (UCR) - School of Business Administration
Downloads 314 (136,048)

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entrepreneurship, innovation, tax break, start-up, startup, patent box, research and development

11.

Tax Anti-Avoidance Law in Australia and the United States

49 Int'l Law. 111 (2015)
Number of pages: 38 Posted: 09 Jul 2016
Susan C. Morse and Robert Deutsch
University of Texas at Austin - School of Law and Government of the Commonwealth of Australia - Administrative Appeals Tribunal
Downloads 281 (152,689)

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Australia, United States, tax anti-avoidance, GAAR, Part IVA, 7701(o)

12.

Why FATCA Intergovermental Agreements Bind the U.S. Government

Tax Notes International, Vol. 70, No. 3, 2013
Number of pages: 3 Posted: 18 Apr 2013
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 279 (153,748)

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FATCA, treaty, intergovernmental agreement, withholding tax

13.

Using Salience and Influence to Narrow the Tax Gap

Loyola University Chicago Law Journal, Vol. 40, p. 483, 2009
Number of pages: 48 Posted: 03 Jun 2008 Last Revised: 14 Nov 2012
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 259 (165,820)

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tax gap, salience, influence, self-employed taxpayers, small business taxpayers

14.

GILTI: The Co-operative Potential of a Unilateral Minimum Tax

2019 Brit. Tax Rev. 512, U of Texas Law, Public Law Research Paper No. 713
Number of pages: 27 Posted: 13 Nov 2019 Last Revised: 13 May 2020
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 251 (170,982)

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TCJA, GILTI, minimum tax, cooperation, corporate income tax

15.

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 240 (178,532)
Citation 1

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

16.

Narrative and Tax Compliance

UC Hastings Research Paper No. 14
Number of pages: 21 Posted: 18 Dec 2012 Last Revised: 02 Jun 2015
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 230 (185,869)

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narrative, tax compliance, enforcement, prosocial

17.

How Australia Got a VAT

The VAT Reader, Tax Analysts, 2011
Number of pages: 21 Posted: 05 Aug 2010 Last Revised: 14 Nov 2012
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 229 (186,635)

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18.

Government-to-Robot Enforcement

2019 University of Illinois Law Review 1497, U of Texas Law, Public Law Research Paper No. 696, U of Texas Law, Law and Econ Research Paper
Number of pages: 30 Posted: 22 Mar 2018 Last Revised: 18 Dec 2019
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 228 (187,384)

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enforcement, compliance, negative externalities, robot, cyberspace, automation, centralization, capture

19.

Does Parenting Matter? U.S. Parents, Non-U.S. Parents, and Global Firm Taxes

Eric J. Allen and Susan C. Morse (2019), "Does Parenting Matter? U.S. Parents, Non-U.S. Parents, and Global Firm Taxes", Journal of Law, Finance, and Accounting: Vol. 4: No. 2, pp 239-290. Doi.org/10.1561/108.00000038
Number of pages: 52 Posted: 20 Dec 2016 Last Revised: 05 Feb 2020
Eric J. Allen and Susan C. Morse
University of California, Riverside (UCR) - School of Business Administration and University of Texas at Austin - School of Law
Downloads 226 (188,936)

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Accounting for Income Taxes, Multinational Taxation, U.S. and Non-U.S. Firms, Effective Tax Rates

20.

When Robots Make Legal Mistakes

Oklahoma Law Review, Vol. 72, 2019, U of Texas Law, Public Law Research Paper No. 709
Number of pages: 19 Posted: 23 Jul 2019 Last Revised: 27 Aug 2021
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 220 (193,928)

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robot, legal process, institutional settlement, standing, overcompliance, undercompliance, explainability

21.

An Analysis of the FBAR High-Penalty Regime

2011 IRS Research Bulletin
Number of pages: 37 Posted: 15 Oct 2009 Last Revised: 14 Nov 2012
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 219 (194,799)

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FBAR, offshore account, tax compliance

22.

Regulating by Example

Yale Journal on Regulation, Vol. 35, No. 1, 2017, University of Miami Legal Studies Research Paper No. 17-3, U of Texas Law, Public Law Research Paper No. 661
Number of pages: 52 Posted: 15 Feb 2017 Last Revised: 07 Nov 2017
Susan C. Morse and Leigh Osofsky
University of Texas at Austin - School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 209 (203,454)

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Regulation, Agencies, Law

23.

Ninth Circuit Brief of Amici Curiae J. Richard Harvey, Leandra Lederman, Ruth Mason, Susan Morse, Stephen Shay and Bret Wells in Altera Corp. v. Commissioner, in Support of Respondent-Appellant Commissioner

Number of pages: 45 Posted: 08 Jul 2016 Last Revised: 02 Sep 2016
Susan C. Morse, J. Richard (Dick) Harvey, Leandra Lederman, Ruth Mason, Stephen E. Shay and Bret Wells
University of Texas at Austin - School of Law, Villanova University School of Law and Graduate Tax Program, Indiana University Maurer School of Law, University of Virginia School of Law, Boston College Law School and University of Houston Law Center
Downloads 206 (206,162)

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Cost-Sharing, Clear Reflection of Income, Comparability, Arm's Length Standard, Arbitrary, Capricious

24.

A Corporate Offshore Profits Transition Tax

91 N.C. L. Rev. 549 (2013), UC Hastings Research Paper No. 10
Number of pages: 57 Posted: 14 Nov 2012 Last Revised: 03 Feb 2013
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 194 (217,687)

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transition tax, territoriality, repatriation, unremitted earnings, permanently reinvested earnings

25.

Qualified Intermediary or Bust?

Tax Notes, Vol. 124, No. 5, 2009, Santa Clara Univ. Legal Studies Research Paper No. 2009
Number of pages: 4 Posted: 10 Aug 2009
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 163 (252,591)

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qualified intermediary, international information exchange, residence taxation

26.

Do Tax Compliance Robots Follow the Law?

16 Ohio State Technology L. J. 278 (2020), U of Texas Law, Public Law Research Paper 707
Number of pages: 29 Posted: 08 Mar 2020 Last Revised: 13 May 2020
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 162 (253,945)

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Tax compliance, TurboTax, data, taxpayer confidentiality, overcompliance, undercompliance, tax compliance robot

27.

Ninth Circuit Brief of Law Academics and Professors as Amici Curiae in Opposition to the Petition for Rehearing En Banc in Altera v. Commissioner

Number of pages: 34 Posted: 18 Sep 2019
Leandra Lederman, Susan C. Morse, Stephen E. Shay, Clint Wallace, Reuven S. Avi-Yonah, Lily L. Batchelder, Jeremy Bearer-Friend, Joshua D. Blank, Leslie Book, Bryan Camp, Noel B. Cunningham, Victor Fleischer, J. Clifton Fleming, Keith Fogg, David Gamage, Ari D. Glogower, Mitchell Kane, Ariel Jurow Kleiman, Edward D. Kleinbard, Rebecca M. Kysar, Zachary D. Liscow, Ruth Mason, Omri Y. Marian, Robert J. Peroni, Darien Shanske, Daniel Shaviro, John P. Steines, Bret Wells and Eric M. Zolt
Indiana University Maurer School of Law, University of Texas at Austin - School of Law, Boston College Law School, University of South Carolina School of Law, University of Michigan Law School, New York University School of Law, George Washington University Law School, University of California, Irvine School of Law, Villanova University School of Law, Texas Tech University School of Law, New York University Law School, UC-Irvine School of Law, Brigham Young University - J. Reuben Clark Law School, Tax Clinic at Legal Services Center of Harvard Law School, Indiana University Maurer School of Law, Ohio State University (OSU) - Michael E. Moritz College of Law, New York University (NYU), Loyola Law School Los Angeles, University of Southern California Gould School of Law, Deceased, Fordham University School of Law, Yale University - Law School, University of Virginia School of Law, University of California, Irvine School of Law, University of Texas at Austin - School of Law, University of California, Davis - School of Law, New York University School of Law, New York University School of Law, University of Houston Law Center and University of California, Los Angeles (UCLA) - School of Law
Downloads 134 (295,340)

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Altera, transfer pricing, arm's length, Tax Court, en banc, Section 482, stock-based compensation

28.

The Transfer Pricing Regs Need a Good Edit

Pepperdine Law Review, Vol. 40, 2013
Number of pages: 26 Posted: 16 May 2013
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 121 (318,671)

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transfer pricing, regulatory discretion, formulary, incremental

29.

The Quasi-Global GILTI Tax

Pittsburgh Tax Review, Vol. 18, No. 2, 2021, U of Texas Law, Public Law Research Paper
Number of pages: 28 Posted: 08 Jun 2021
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 120 (320,495)

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GILTI, GloBE, minimum tax, global minimum tax

30.

Taxing the $2.5 Trillion

Tax Notes, Vol. 154, No. 2, Jan. 2017, U of Texas Law, Public Law Research Paper
Number of pages: 4 Posted: 24 Feb 2017
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 116 (328,207)

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Transition Tax, Deemed Repatriation, Foreign Tax Credits

31.

Brief of Amici Curiae Former Government Officials in Support of Respondents, CIC Services, LLC v. Internal Revenue Service

Number of pages: 43 Posted: 05 Nov 2020
Daniel J. Hemel, Susan C. Morse and Clint Wallace
New York University School of Law, University of Texas at Austin - School of Law and University of South Carolina School of Law
Downloads 99 (365,326)

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tax shelter, CIC Services v. IRS, Supreme Court, amicus brief

32.

Seeking Comparables in Patent and Tax

37 Rev. Litig. Brief (2018)
Number of pages: 9 Posted: 17 Mar 2018 Last Revised: 21 Sep 2018
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 90 (387,771)

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Tax, Transfer Pricing, Patent Litigation, Patent Damages

33.

International Cooperation and the 2017 Tax Act

128 Yale Law Journal Forum 362 (2018)
Number of pages: 21 Posted: 16 Nov 2018
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 80 (415,891)
Citation 1

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2017 tax act, GILTI, BEAT, international tax, international cooperation, minimum tax, competitiveness

34.

Entrepreneurship Incentives for Resource-Constrained Firms

Handbook of Law and Entrepreneurship, Forthcoming, U of Texas Law, Public Law Research Paper No. 669
Number of pages: 20 Posted: 29 Apr 2017 Last Revised: 09 Jan 2019
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 77 (425,135)

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entrepreneurship, innovation, legal incentives, tax incentives, losses

35.

Out of Time? APA Challenges to Old Tax Guidance and the Six-Year Default Limitations Period

Number of pages: 37
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 38

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default federal limitations period, 28 USC 2401(a), Notices, CIC Services, Administrative Procedure Act, Govig

36.

Emergency Money: Lessons from the Paycheck Protection Program

University of Michigan Journal of Law Reform, Vol. 55, No. 1, 2021
Number of pages: 64 Posted: 28 Mar 2022
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 2 (877,942)

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Paycheck Protection Program, emergency, disaster, back-end adjustment, descending price auction

Other Papers (2)

Total Downloads: 59
Actions:
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1.

How Agencies Communicate

Yale Journal on Regulation, Notice & Comment Blog
Number of pages: 21 Posted: 28 Mar 2018
Susan C. Morse, Leigh Osofsky, Elizabeth G. Porter, Kathryn A. Watts, Michael Herz, Andy Grewal, Nicholas R. Parrillo, Kevin M. Stack, Kristin E. Hickman, Christopher J. Walker and Aaron L. Nielson
University of Texas at Austin - School of Law, University of North Carolina (UNC) at Chapel Hill, University of Washington School of Law, University of Washington - School of Law, Yeshiva University - Benjamin N. Cardozo School of Law, University of Iowa - College of Law, Yale University - Law School, Vanderbilt University - Law School, University of Minnesota - Twin Cities - School of Law, University of Michigan Law School and Brigham Young University - J. Reuben Clark Law School
Downloads 42

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Administrative Law, Administrative Guidance, Communication, Deference, Regulations, Notice-and-Comment, Rulemaking, Examples

2.

Tax Compliance and the Love Molecule

Arizona State Law Journal Blog
Number of pages: 2 Posted: 27 Sep 2011
Susan C. Morse
University of Texas at Austin - School of Law
Downloads 17 (260,224)

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tax, compliance, enforcement, oxytocin, reciprocity