Ruth Mason

University of Virginia School of Law

Edwin S. Cohen Distinguished Professor of Law and Taxation

United States

  • University of Virginia School of Law

SCHOLARLY PAPERS

56

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12

Scholarly Papers (56)

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1.

The Transformation of International Tax

American Journal of International Law, forthcoming July 2020, Virginia Public Law and Legal Theory Research Paper No. 2020-36, Virginia Law and Economics Research Paper No. 2020-08
Number of pages: 60 Posted: 15 Apr 2020 Last Revised: 14 May 2020
Ruth Mason
University of Virginia School of Law
Downloads 1,581 (13,879)
Citation 2

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BEPS, corporate tax avoidance, full tax, single tax, OECD, tax competition, fiscal fail-safes, tax, soft law, Inclusive Framework, OECD acquis

2.

Digital Battlefront in the Tax Wars

Virginia Law and Economics Research Paper No. 2018-16, 92 Tax Notes International 1183 (2018)
Number of pages: 15 Posted: 14 Nov 2018 Last Revised: 15 Aug 2019
Ruth Mason and Leopoldo Parada
University of Virginia School of Law and University of Leeds School of Law
Downloads 1,291 (19,001)

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digital services tax, DST, digital tax, EU law, digital PE, permanent establishment, tech tax, web tax, google tax

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 Law School
Downloads 1,222 (20,624)

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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.

Citizenship Taxation

Southern California Law Review, Vol. 89, Forthcoming, Virginia Law and Economics Research Paper No. 2015-07
Number of pages: 72 Posted: 17 May 2015 Last Revised: 16 Jun 2016
Ruth Mason
University of Virginia School of Law
Downloads 1,120 (23,504)

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citizenship, immigration, taxation, benefits theory, ability to pay, FATCA, FBAR

5.

U.S. Tax Treaty Policy and the European Court of Justice

Tax Law Review, Vol. 59, 2005
Number of pages: 85 Posted: 12 Sep 2005 Last Revised: 27 Feb 2013
Ruth Mason
University of Virginia School of Law
Downloads 1,114 (23,652)

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International tax, tax harmonization, multitlateral tax treaty, European Union, tax treaties, limitation on benefits, European Court of Justice, tax policy, Open Skies, Member State sovereignty, treaty shopping, qualification conflicts

6.

Double Taxation: A European 'Switch in Time'?

Columbia Journal of European Law, Vol. 14, No. 1, 2007
Number of pages: 36 Posted: 13 Apr 2007 Last Revised: 27 Feb 2013
Georg Kofler and Ruth Mason
Vienna University of Economics and Business - Institute for Austrian and International Tax Law and University of Virginia School of Law
Downloads 967 (29,018)
Citation 3

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ECJ, European Court of Justice, tax discrimination, double taxation, EC Treaty, double burdens, mutual recognition, Kerckhaert, Moorman, Container Corporation, Supreme Court, Commerce Clause, apportionment, Bibb, internal market, common market, freedom of movement, double tax treaties, DTC, imputati

7.

The Legality of Digital Taxes in Europe

Virginia Tax Review, 2020, Virginia Public Law and Legal Theory Research Paper No. 2020-50, Virginia Law and Economics Research Paper No. 2020-10
Number of pages: 37 Posted: 04 Jun 2020
Ruth Mason and Leopoldo Parada
University of Virginia School of Law and University of Leeds School of Law
Downloads 953 (29,631)

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digital taxes; indirect discrimination; EU law; legality; fundamental freedoms; Vodafone; Tesco

8.

A Theory of Tax Discrimination

NYU Jean Monnet Working Paper No. 09/06
Number of pages: 61 Posted: 09 Apr 2007 Last Revised: 29 Aug 2008
Ruth Mason
University of Virginia School of Law
Downloads 808 (37,258)

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tax discrimination, European Union, United States, European Court of Justice, Supreme Court, international tax

9.

State Aid: The General Court Decision in Apple

99 Tax Notes Int'l 1317 (2020) [also published as 168 Tax Notes Federal 1791 (2020)], Virginia Public Law and Legal Theory Research Paper No. 2020-71, Virginia Law and Economics Research Paper No. 2020-17, King's College London Law School Research Paper No. 2020-46
Number of pages: 19 Posted: 21 Oct 2020 Last Revised: 12 Dec 2020
Stephen Daly and Ruth Mason
King's College London - The Dickson Poon School of Law and University of Virginia School of Law
Downloads 727 (43,074)

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State Aid, EU, Tax, Transfer Pricing, Apple, arm's length

10.

Tax Discrimination and Capital Neutrality

World Tax Journal, Forthcoming
Number of pages: 21 Posted: 02 Dec 2008 Last Revised: 27 Feb 2013
Ruth Mason
University of Virginia School of Law
Downloads 670 (48,078)
Citation 2

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tax discrimination, nondiscrimination, tax treaty, EC treaty, taxation, OECD, capital export neutrality, capital import neutrality, protectionist taxes, exit taxes

11.

Exporting FATCA

142 Tax Notes, Forthcoming, NYU Law and Economics Research Paper No. 14-05
Number of pages: 7 Posted: 02 Feb 2014 Last Revised: 20 Mar 2014
Joshua D. Blank and Ruth Mason
University of California, Irvine School of Law and University of Virginia School of Law
Downloads 666 (48,435)

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FATCA, sanctions, tax compliance, tax delinquent, tax enforcement, tax evasion, offshore

12.

Tax Rulings as State Aid FAQ

Tax Notes, Vol. 154, 2017, Virginia Law and Economics Research Paper No. 2017-16
Number of pages: 13 Posted: 24 Feb 2017 Last Revised: 30 Oct 2017
Ruth Mason
University of Virginia School of Law
Downloads 665 (48,527)
Citation 1

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State Aid, EU, Tax, Transfer Pricing

13.

Made in America for European Tax: The Internal Consistency Test

Boston College Law Review, Vol. 49, No. 4, 2008
Number of pages: 50 Posted: 31 Oct 2007 Last Revised: 27 Feb 2013
Ruth Mason
University of Virginia School of Law
Downloads 633 (51,764)
Citation 1

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Supreme Court, European Union, European Court of Justice, ECJ, state taxation, Member State taxation, compensatory taxes, double taxation, per-country approach, overall approach, internal consistency, disparities, tax discrimination, Schumacker, Schempp, Marks & Spencer, Manninen, integration

14.

Flunking the ECJ's Tax Discrimination Test

Columbia Journal of Transnational Law, Vol. 46, 2007
Number of pages: 62 Posted: 31 Oct 2007 Last Revised: 08 Apr 2015
Ruth Mason
University of Virginia School of Law
Downloads 603 (55,085)
Citation 1

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European Union, tax, international tax, tax discrimination, ECJ, Biehl, economic integration, protectionism, tax exportation, tax preferences, exit restrictions

15.

Special Report on State Aid — Part 3: Apple

Tax Notes, Vol. 154, 2017, Virginia Law and Economics Research Paper No. 2017-18
Number of pages: 18 Posted: 07 Mar 2017 Last Revised: 30 Oct 2017
Ruth Mason
University of Virginia School of Law
Downloads 589 (56,895)

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state aid, Apple, CCCTB, transfer pricing, profit allocation, branch, corporate tax avoidance, BEPS, stateless income

16.

When Tax Treaty Derivative Benefits Provisions Don't Apply

Tax Notes International, Vol. 43, p. 563, August 14, 2006 (extended reprint of article appearing in Tax Notes, Vol. 112, p. 367, 2006)
Number of pages: 6 Posted: 15 Jul 2006 Last Revised: 29 Aug 2008
Ruth Mason
University of Virginia School of Law
Downloads 576 (58,309)

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tax treaties, derivative benefits, limitation on benefits, withholding taxes, double taxation, equivalent beneficiary

17.

Constitutional Restraints on Corporate Tax Integration

Tax Law Review, Forthcoming
Number of pages: 66 Posted: 05 Mar 2008 Last Revised: 15 Jun 2020
Walter Hellerstein, Georg Kofler and Ruth Mason
University of Georgia School of Law, Vienna University of Economics and Business - Institute for Austrian and International Tax Law and University of Virginia School of Law
Downloads 568 (59,354)

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Corporate tax integration, United States, European Union, cross-border dividends, DRD, imputation, capital export neutrality, locational neutralituy, double tax, double corporate tax

18.

Identifying Illegal Subsidies

American University Law Review, 2020, Forthcoming
Number of pages: 86 Posted: 20 Jun 2019 Last Revised: 04 May 2020
Ruth Mason
University of Virginia School of Law
Downloads 524 (65,672)

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state aid, apple, fundamental freedoms, tax, corporate tax avoidance, tax expenditures, subsidies, gibraltar

19.

The Tillinghast Lectures: A Decade of International Tax Law Proposals

THE TILLINGHAST LECTURE 1996-2005, NYU School of Law, 2007
Number of pages: 30 Posted: 22 Jun 2007 Last Revised: 08 Dec 2008
Ruth Mason
University of Virginia School of Law
Downloads 508 (68,595)

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international tax, taxation, Tillinghast, OECD, EU, ECJ, WTO, NAFTA, GATT, IAS, NYU, intangibles

20.

Federalism and the Taxing Power

California Law Review, Vol. 99, p. 975, 2011
Number of pages: 62 Posted: 22 Apr 2011 Last Revised: 27 Feb 2013
Ruth Mason
University of Virginia School of Law
Downloads 504 (68,938)

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federalism, tax expenditure, tax penalty, conditional grants, state taxes, local taxes, EITC, TANF

21.

IFA 2008 Brussels Congress: USA Branch Report: Non-Discrimination at the Crossroads of International Taxation

Cahiers de Droit Fiscal International, Vol. 93b, 2008
Number of pages: 33 Posted: 17 Oct 2007
Herman Bouma and Ruth Mason
Buchanan Ingersoll & Rooney PC and University of Virginia School of Law
Downloads 491 (71,202)

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tax discrimination, nationality discrimination, residence, tax treaties, Commerce Clause, trade treaties

22.

Tax Rulings as State Aid — Part 4: Whose Arm's-Length Standard?

Tax Notes, Vol. 155, No. 7, May 2017, Virginia Law and Economics Research Paper No. 2017-19
Number of pages: 22 Posted: 23 Jun 2017 Last Revised: 30 Oct 2017
Ruth Mason
University of Virginia School of Law
Downloads 443 (80,606)

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State Aid, Tax, Tax Rulings, Transfer Pricing, Apple

23.

Sovereign Wealth Funds and the Efficient Management of the Wealth of Nations

Tax Notes, September 29, 2008
Number of pages: 2 Posted: 22 Aug 2008 Last Revised: 30 Oct 2008
Ruth Mason
University of Virginia School of Law
Downloads 439 (81,461)

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sovereign wealth funds, taxation

24.

Common Markets, Common Tax Problems

Florida Tax Review, Vol. 8, 2007
Number of pages: 31 Posted: 16 Dec 2007 Last Revised: 02 May 2008
Ruth Mason
University of Virginia School of Law
Downloads 398 (91,351)

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common market, tax, comparative fiscal federalism, United States, European Union, U.S., EU, Commerce Clause, Foreign Commerce Clause, treaty power, external tax competence, tax discrimination, Schumacker, Lunding, Moorman, Cuno, West Lynn Creamery, tax competition, tax sovereignty, tax harmonization

25.

Tax Expenditures and Global Labor Mobility

New York University Law Review, Forthcoming
Number of pages: 79 Posted: 11 Mar 2009 Last Revised: 27 Feb 2013
Ruth Mason
University of Virginia School of Law
Downloads 388 (94,068)

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labor mobility, labor taxation, international taxation, Schumacker, tax expenditures, cross-border work, OECD Model Tax Treaty, labor export neutrality, labor import neutrality, ECJ, Supreme Court, immigration, labor migration, refundable tax credits

26.

Implications of the Rulings in Starbucks And Fiat for the Apple State Aid Case

Tax Notes Federal, October 7, 2019, p. 93
Number of pages: 9 Posted: 07 Oct 2019 Last Revised: 07 Nov 2019
Ruth Mason
University of Virginia School of Law
Downloads 382 (96,116)

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state aid, Starbucks, Fiat, Apple, arm's-length

27.

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, Hayes Holderness, Calvin H. Johnson, Richard L. Kaplan, Michael S. Knoll, Zachary D. Liscow, Yair Listokin, Ruth Mason, Goldburn Maynard, 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
University of Chicago - Law School, University of Michigan Law School, Stanford Law School, University of San Diego School of Law, New York University School of Law, Georgetown University Law Center, 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, Ernst & Young, University of Richmond - School of Law, University of Texas at Austin - School of Law, University of Illinois College of Law, University of Pennsylvania Law School, Yale University - Law School, Yale Law School, University of Virginia School of Law, Louis D. Brandeis School of Law, 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 374 (98,133)
Citation 1

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

28.

Company Size Matters

British Tax Review 5, 2019
Number of pages: 42 Posted: 11 Jan 2019 Last Revised: 20 Dec 2019
Ruth Mason and Leopoldo Parada
University of Virginia School of Law and University of Leeds School of Law
Downloads 353 (105,092)

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EU law, digital services tax, disproportionate impact, company size, discriminatory intent

29.

Implications of Wayfair

46 Intertax 810 (2018)
Number of pages: 10 Posted: 04 Aug 2018 Last Revised: 02 Dec 2018
Ruth Mason
University of Virginia School of Law
Downloads 347 (106,769)

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Wayfair, Sales Tax, Digital Services Tax, Amazon Tax

30.

Spinning Morris Trust: Interpreting 355(E) According to its Purpose

Tax Notes, Vol. 94, No. 12, March 25, 2002
Number of pages: 21 Posted: 23 Mar 2002
Ruth Mason
University of Virginia School of Law
Downloads 344 (107,850)

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spin-offs, tax-free reorganizations, Morris Trust, I.R.C. Sec 355(e)

31.

State Aid Special Report — Part 2: Legitimate Expectations

Tax Notes, Vol. 154, 2017, Virginia Law and Economics Research Paper No. 2017-17
Number of pages: 9 Posted: 13 Mar 2017 Last Revised: 30 Oct 2017
Ruth Mason
University of Virginia School of Law
Downloads 289 (130,122)
Citation 1

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State Aid, EU, Tax, Transfer Pricing, legitimate expectations, Treasury white paper

32.

An American View of State Aid

Tax Notes, Vol. 157, 2017
Number of pages: 18 Posted: 12 Dec 2017 Last Revised: 15 Oct 2018
Ruth Mason
University of Virginia School of Law
Downloads 276 (136,570)
Citation 1

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state aid, selectivity, Apple state aid, tax competition

33.

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 269 (140,167)

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

34.

2006 ECJ Direct Tax Cases

Number of pages: 48 Posted: 15 Dec 2008 Last Revised: 13 Mar 2009
Ruth Mason
University of Virginia School of Law
Downloads 262 (144,000)

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ECJ, European Court of Justice, tax discrimination, cross-border dividends, European Union

35.

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 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 227 (165,594)
Citation 1

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

36.

What the CJEU’s Hungarian Cases Mean for Digital Taxes

Number of pages: 11 Posted: 02 Apr 2020 Last Revised: 28 Apr 2020
Ruth Mason
University of Virginia School of Law
Downloads 208 (179,884)
Citation 1

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digital tax, Hervis, Vodafone, CJEU, Tesco

37.

Delegating Up: State Conformity with the Federal Tax Base

Duke Law Journal, Vol. 62, Number 7, April 2013
Number of pages: 82 Posted: 15 Mar 2012 Last Revised: 20 May 2013
Ruth Mason
University of Virginia School of Law
Downloads 205 (182,291)

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tax base conformity, federalism, state taxes, tax competition, fiscal federalism

38.

State Aid: Arm's-Length on Appeal

Tax Notes, Vol. 158, No. p. 771, 2018
Number of pages: 26 Posted: 09 Mar 2018
Ruth Mason
University of Virginia School of Law
Downloads 203 (183,934)

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EU, state aid, Apple, base-erosion

39.

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 201 (185,705)

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

40.

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 194 (191,729)

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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

41.

2005 ECJ Direct Tax Cases

Number of pages: 17 Posted: 14 Dec 2008 Last Revised: 13 Jan 2011
Ruth Mason
University of Virginia School of Law
Downloads 179 (205,904)
Citation 1

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Schempp, Blanckaert, Marks & Spencer, ECJ, European Court of Justice, direct taxation

42.

United States National Report on Exchange of Information

Proceedings of Annual Congress of the European Association of Tax Law Professors, 2014, NYU Law and Economics Research Paper No. 14-22
Number of pages: 26 Posted: 17 Aug 2014 Last Revised: 25 Aug 2014
Joshua D. Blank and Ruth Mason
University of California, Irvine School of Law and University of Virginia School of Law
Downloads 160 (226,515)

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FATCA, sanctions, tax compliance, tax delinquent, tax enforcement, tax evasion, offshore

43.

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 Law School
Downloads 129 (269,163)

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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

44.

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 125 (275,588)

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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

45.

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 108 (305,730)

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

46.

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 92 (339,590)

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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

47.

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 90 (344,321)
Citation 1

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

48.

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 89 (346,724)

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

49.

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 Law School and University of Virginia School of Law
Downloads 87 (351,614)

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50.

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
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, Richard Pomp, James R. Repetti, Julie Roin, Erin Adele Scharff, Jay A. Soled and Edward A. Zelinsky
University of Chicago - Law School, 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 Law School, Yale University - Law School, University of Virginia School of Law, Louis D. Brandeis School of Law, 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 78 (375,228)

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51.

State Aid Enforcement After Amazon

102 Tax Notes Int'l 1171 (May 31, 2021)
Number of pages: 8 Posted: 02 Jun 2021
Ruth Mason
University of Virginia School of Law
Downloads 70 (398,509)

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state aid, tax, amazon, European Commission

52.

A Political-Process Defense of Deference to EU Directives

Virginia Law and Economics Research Paper No. 2018-17
Number of pages: 5 Posted: 14 Nov 2018 Last Revised: 13 Dec 2018
Ruth Mason
University of Virginia School of Law
Downloads 61 (431,434)

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state aid, Deutsche Bahn deference, EU directives

53.

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 Law School and University of Virginia School of Law
Downloads 60 (431,434)

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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

54.

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 55 (449,590)

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

55.

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 Law School, University of Virginia School of Law and American Enterprise Institute
Downloads 39 (516,862)

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

56.

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 Law School
Downloads 34 (541,836)

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