David J. Shakow

University of Pennsylvania Law School

Professor of Law (Emeritus)

3501 Sansom Street

Philadelphia, PA 19104

United States

Chamberlain Hrdlicka

Counsel

300 Conshohocken State Rd

West Conshohocken, PA 19428

United States

  • University of Pennsylvania Law School

  • Chamberlain Hrdlicka

SCHOLARLY PAPERS

12

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1,792

CITATIONS

3

Scholarly Papers (12)

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1.

The Taxation of Cloud Computing and Digital Content

Tax Notes, Vol. 140, No. 4, July, 22, 2013, Tax Notes International, Vol. 71, No. 4, July, 22, 2013, State Tax Notes, Vol. 69, No. 4, July 22, 2013, U of Penn, Inst for Law & Econ Research Paper No. 13-26
Number of pages: 37 Posted: 03 Aug 2013
David J. Shakow
University of Pennsylvania Law School
Downloads 541 (49,402)
Citation 1

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State & federal taxation, Internet sales, taxing software in the cloud, hosting out-of-state servers, nexus, foreign income taxation, international transactions, income allocation among jurisdictions, defining a permanent establishment, collecting tax judgments in foreign court, int’l tax neutrality

2.

A Comprehensive Wealth Tax

Downloads 439 ( 64,188)
Citation 3

A Comprehensive Wealth Tax

University of Pennsylvania Law School, Institute for Law and Economics, Working Paper No. 266
Number of pages: 59 Posted: 13 Aug 1999
David J. Shakow and Reed Shuldiner
University of Pennsylvania Law School and University of Pennsylvania Law School
Downloads 439 (63,554)
Citation 3

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A Comprehensive Wealth Tax

Tax Law Review, Vol. 53, Issue 3
Posted: 27 Jun 2000
David J. Shakow and Reed Shuldiner
University of Pennsylvania Law School and University of Pennsylvania Law School

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3.

The Tax Treatment of Tokens: What Does it Betoken?

Tax Notes, Vol. 156, P. 1387, Sept. 11, 2017, U of Penn, Inst for Law & Econ Research Paper No. 17-45
Number of pages: 19 Posted: 24 Oct 2017
David J. Shakow
University of Pennsylvania Law School
Downloads 226 (133,437)

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Taxation, securities, corporate finance, digital tokens, bitcoins, block chain, e-commerce, bearer instruments, virtual currencies, taxation, DAO token, tax treatment of tokens, tokens as equity, issuer obligations

4.

The Tao of the DAO: Taxing an Entity that Lives on a Blockchain

Tax Notes, Vol. 160, Pg. 929, August 13, 2018, U of Penn, Inst for Law & Econ Research Paper No. 18-23
Number of pages: 23 Posted: 11 Sep 2018
David J. Shakow
University of Pennsylvania Law School
Downloads 137 (207,663)

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Income taxation, blockchain, smart contracts, The Ethereum Platform, blockchain forks, classification, Foreign Account Tax Compliance Act, FATCA, enforcement, taxation of owners, taxation of the entity, cryptocurrency, artificial intelligence

5.

A Concrete Shoe for Brand X?

Tax Notes, Vol. 135, p. 651, April 2012, U of Penn, Inst for Law & Econ Research Paper No. 12-21
Number of pages: 4 Posted: 04 May 2012
David J. Shakow
University of Pennsylvania Law School
Downloads 103 (256,558)

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Taxation, administrative law, administrative rules and regulations, Administrative Procedure Act, Treasury Regulation, judicial deference to IRS rulemaking, Chevron doctrine, Home Concrete, APA, Mayo Foundation

6.

Who’s Afraid of the APA?

Tax Notes, Vol. 134, No. 7, p. 825, February 2012, U of Penn, Inst for Law & Econ Research Paper No. 12-09, U of Penn Law School, Public Law Research Paper No. 12-15
Number of pages: 14 Posted: 24 Feb 2012
David J. Shakow
University of Pennsylvania Law School
Downloads 103 (256,558)

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Taxation, administrative law, administrative rules and regulations, judicial deference to IRS rulemaking, IRS legislative regulations, IRS interpretive regulations, IRS rulings, retroactive rules, good cause exception

7.

Does It Hurt a State to Introduce an Income Tax?

State Tax Notes, Vol. 58, p. 679, 2010, U of Penn, Inst for Law & Econ Research Paper No. 11-04
Number of pages: 8 Posted: 23 Feb 2011
David J. Shakow
University of Pennsylvania Law School
Downloads 78 (305,684)

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Income Taxation, State Income Tax, Arthur Laffer, Causation of Relative Decline in Gross State Product, Causation, Statistical Correlation, State Economies, State GDP

8.

Lessons from the Soon to Be Repealed (and Reenacted) Section 68 Limitation

U of Penn, Inst for Law & Econ Research Paper 01-17
Number of pages: 49 Posted: 03 Oct 2001
Reed Shuldiner and David J. Shakow
University of Pennsylvania Law School and University of Pennsylvania Law School
Downloads 78 (305,684)
Citation 1

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9.

Valuation Misstatement Penalties Require Valuation Misstatements

Tax Notes, Vol. 139, No. 11, p. 1283, 2013, U of Penn, Inst for Law & Econ Research Paper No. 13-20
Number of pages: 40 Posted: 20 Jun 2013
David J. Shakow
University of Pennsylvania Law School
Downloads 60 (351,994)

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Taxation, Internal Revenue Code section 6662(h), section 6659, statutory interpretation, valuation, basis, overvaluation, penalties, tax shelters without economic substance

10.

From Rochdale Principles to Llcs: The Ongoing Evolution of the Cooperative Structure

Tax Notes, Vol. 104, No. 5, August 2, 2004
Number of pages: 19 Posted: 30 Jul 2004 Last Revised: 27 Jun 2013
David J. Shakow
University of Pennsylvania Law School
Downloads 27 (475,904)

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11.

Lessons from the Limitation on Itemized Deductions

Tax Notes, Vol. 93, No. 5, October 29, 2001
Posted: 25 Oct 2001
Reed Shuldiner and David J. Shakow
University of Pennsylvania Law School and University of Pennsylvania Law School

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12.

Taking Wealth Taxes More Seriously

Institute for Law And Economics, University of Pennsylvania School of Law, Discussion Paper No. 235
Posted: 10 Jul 1997
David J. Shakow
University of Pennsylvania Law School

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