Ruth Mason

University of Virginia School of Law

Edwin S. Cohen Distinguished Professor of Law and Taxation

United States

Max Planck Institute for Tax Law and Public Finance

Marstallplatz 1

Munich, 80539

Germany

SCHOLARLY PAPERS

72

DOWNLOADS
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35,125

TOTAL CITATIONS
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Top 25,488

in Total Papers Citations

33

Scholarly Papers (72)

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: 20 Oct 2023
Ruth Mason
University of Virginia School of Law
Downloads 2,813 (9,834)
Citation 9

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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 King's College London
Downloads 1,718 (21,547)

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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 Carey Law School
Downloads 1,476 (27,102)

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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.

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 King's College London
Downloads 1,444 (27,994)

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

5.

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: 13 Sep 2023
Ruth Mason
University of Virginia School of Law
Downloads 1,422 (28,658)
Citation 1

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

6.

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 1,188 (37,226)
Citation 3

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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

7.

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 1,128 (40,140)
Citation 2

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

8.

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 1,073 (43,176)
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

9.

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 910 (54,296)

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

10.

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 785 (66,347)

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

11.

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 779 (67,029)
Citation 1

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State Aid, EU, Tax, Transfer Pricing

12.
Downloads 762 (69,153)
Citation 2

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 762 (68,077)
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

Tax Discrimination and Capital Neutrality

In: World tax journal. - Amsterdam. - Vol. 2 (2010), no. 2 ; p. 126-138
Posted: 07 Dec 2022
Ruth Mason
University of Virginia School of Law

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OECD Model, non-discrimination, capital import neutrality, capital export neutrality, EU Treaty

13.

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 709 (75,875)

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

14.

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 704 (76,550)

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

15.

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 691 (78,352)
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

16.

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 677 (80,365)
Citation 1

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

17.

Constitutional Restraints on Corporate Tax Integration

Tax Law Review, Forthcoming
Number of pages: 66 Posted: 05 Mar 2008 Last Revised: 15 Jun 2020
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 661 (82,819)
Citation 1

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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.

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 King's College London
Downloads 615 (90,888)
Citation 1

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

19.

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 615 (90,888)

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

20.

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 608 (92,216)

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

21.

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 585 (96,862)

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

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 545 (105,878)

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

23.

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 541 (106,863)

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

24.

Rotten to the Core: The EU's Court of Justice Decision in Apple

Virginia Public Law and Legal Theory Research Paper No. 2024-68, Virginia Law and Economics Research Paper No. 2024-33, Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 15, TAX NOTES INTERNATIONAL, VOLUME 116, pp. 987-1007,  NOVEMBER 11, 2024 
Number of pages: 21 Posted: 22 Nov 2024
Ruth Mason and Stephen Daly
University of Virginia School of Law and King's College London - The Dickson Poon School of Law
Downloads 527 (110,646)

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25.

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 520 (112,195)

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

26.

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
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, University of Missouri School of Law, Northwestern Pritzker School 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 Law, San Francisco, Yeshiva University - Benjamin N. Cardozo School of Law and University of California, Los Angeles (UCLA) - School of Law
Downloads 504 (116,501)
Citation 1

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

27.

A Wrench in the GLOBE's Diabolical Machinery

Tax Notes International, Vol. 107, Virginia Law and Economics Research Paper No. 2022-22
Number of pages: 6 Posted: 04 Oct 2022 Last Revised: 13 Dec 2022
Ruth Mason
University of Virginia School of Law
Downloads 494 (119,668)

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BEPS, Globe, Pillar 2, OECD, European Union, Directive, fiscal fail-safe

28.

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 491 (120,523)
Citation 1

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

29.

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 477 (124,506)

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sovereign wealth funds, taxation

30.

The 2021 Compromise

172 Tax Notes Fed. 569 (2021)
Number of pages: 7 Posted: 16 Aug 2021 Last Revised: 17 Aug 2021
Ruth Mason
University of Virginia School of Law
Downloads 467 (127,637)

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BEPS, corporate tax avoidance, profit shifting, digital tax, minimum tax

31.

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 449 (133,860)

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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

32.

Bounded Extraterritoriality

Michigan Law Review, Forthcoming, U of Penn, Inst for Law & Econ Research Paper No. 23-23
Number of pages: 64 Posted: 02 Mar 2023 Last Revised: 03 Oct 2024
Ruth Mason and Michael S. Knoll
University of Virginia School of Law and University of Pennsylvania Carey Law School
Downloads 437 (138,668)

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dormant Commerce Clause, extraterritoriality, National Pork, Brown-Forman, horizontal federalism, internal consistency

33.

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 429 (141,288)

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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

34.

Has Cross-Border Arbitrage Met Its Match?

Virginia Tax Review, Vol. 41, 2021, Virginia Law and Economics Research Paper No. 2021-19
Number of pages: 12 Posted: 02 Sep 2021 Last Revised: 11 Apr 2022
Ruth Mason and Pascal Saint-Amans
University of Virginia School of Law and Director, Centre for Tax Policy and Administration
Downloads 421 (144,351)

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35.

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 397 (154,407)

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Wayfair, Sales Tax, Digital Services Tax, Amazon Tax

36.

Tax Competition and State Aid

Forthcoming 2023 Oxford Yearbook of European Law, Virginia Public Law and Legal Theory Research Paper No. 2022-38, 2022. , Virginia Law and Economics Research Paper No. 2022-10, 2022
Number of pages: 30 Posted: 06 Jun 2022 Last Revised: 11 Apr 2023
Ruth Mason
University of Virginia School of Law
Downloads 374 (165,053)

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state aid, TFEU, tax competition, Apple, transfer pricing

37.

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 339 (183,835)
Citation 1

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digital tax, Hervis, Vodafone, CJEU, Tesco

38.

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 339 (183,835)
Citation 1

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

39.

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 336 (185,549)
Citation 1

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state aid, selectivity, Apple state aid, tax competition

40.

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 Carey Law School and University of Virginia School of Law
Downloads 319 (196,084)

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

41.

Legal Problems with Digital Taxes in the United States and Europe

Number of pages: 18 Posted: 02 Feb 2023
Ruth Mason
University of Virginia School of Law
Downloads 304 (206,560)

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digital tax, tax discrimination

42.

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
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, Northwestern Pritzker School of Law, New York University School of Law, New York University School of Law, 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 286 (220,264)
Citation 1

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

43.

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 286 (220,264)

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

44.

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 275 (229,223)

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EU, state aid, Apple, base-erosion

45.

Bibb Balancing: Regulatory Mismatches Under the Dormant Commerce Clause

George Washington Law Review, Vol. 91, No. 1, p. 1 2023 (published), U of Penn, Inst for Law & Econ Research Paper No. 22-30, Virginia Public Law and Legal Theory Research Paper No. 2022-52
Number of pages: 78 Posted: 01 Aug 2022 Last Revised: 03 Apr 2023
Michael S. Knoll and Ruth Mason
University of Pennsylvania Carey Law School and University of Virginia School of Law
Downloads 272 (231,763)

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dormant Commerce Clause, Pike balancing, legal mismatches, federalism, horizontal federalism, balkanization

46.

The Advocate General’s Opinion in Apple: Two Steps Forward, One Step Back

VOLUME 112, Tax Notes International, p. 1315 (DEC 4, 2023), Virginia Public Law and Legal Theory Research Paper No. 2023-79, Virginia Law and Economics Research Paper No. 2023-19
Number of pages: 6 Posted: 18 Dec 2023 Last Revised: 21 Dec 2023
Ruth Mason
University of Virginia School of Law
Downloads 259 (244,516)

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state aid, tax, Apple, Gibraltar, Fiat, transfer pricing

47.

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
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 236 (266,978)

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

48.

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 Carey Law School and University of Virginia School of Law
Downloads 233 (270,324)

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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

49.

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 233 (270,324)

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

50.

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 219 (286,974)
Citation 1

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

51.

Ding-Dong! The EU Arm’s-Length Standard Is Dead

TAX NOTES INTERNATIONAL, VOLUME 108, page 1249, DECEMBER 5, 2022, Virginia Public Law and Legal Theory Research Paper No. 2022-79, Virginia Law and Economics Research Paper No. 2022-30
Number of pages: 9 Posted: 19 Dec 2022
Ruth Mason
University of Virginia School of Law
Downloads 200 (312,483)

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52.

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
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, University of Missouri School of Law, Northwestern Pritzker School of Law, New York University School of Law, University of Southern California Gould School of Law, 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 200 (312,483)

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

53.

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 Carey Law School and University of Virginia School of Law
Downloads 196 (318,279)

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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

54.

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 195 (319,830)

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

55.

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 184 (337,296)

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state aid, tax, amazon, European Commission

56.

Solidarity Federalism

Notre Dame Law Review, Vol. 98, No. 2, 2022, Virginia Public Law and Legal Theory Research Paper No. 2023-05, Northwestern Public Law Research Paper No. 23-20
Number of pages: 54 Posted: 10 Jan 2023 Last Revised: 06 Apr 2023
Erin F. Delaney and Ruth Mason
Northwestern University - Pritzker School of Law and University of Virginia School of Law
Downloads 180 (345,848)

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federalism, federal solidarity, dormant Commerce Clause, state sovereign immunity, horizontal federalism, nondiscrimination, state autonomy, competitive federalism, comparative federalism, cooperative federalism, collective action federalism, nested citizenship, vertical federalism, National Pork

57.

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 Carey Law School and University of Virginia School of Law
Downloads 169 (363,573)

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58.

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 Carey Law School
Downloads 161 (378,988)

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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

59.

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 Last Revised: 01 Sep 2021
New York University School of Law, 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, University of Missouri School of Law, Northwestern Pritzker School of Law, Stanford Law School, University of Richmond - School of Law, University of Pennsylvania Carey Law School, Yale University - Law School, University of Virginia School of Law, Kelley School of Business, 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 144 (415,799)

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tax, taxation, public, policy, law, sales, use, state, export, multistate, amicus brief, Supreme Court, jurisprudence, stream of export, constitutional, constitution, commerce, due process, import-export, interstate, clause, stare decisis

60.

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 Carey Law School and University of Virginia School of Law
Downloads 121 (476,527)
Citation 1

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

61.

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 Carey Law School and University of Virginia School of Law
Downloads 115 (495,293)

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

62.

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 Carey Law School and University of Virginia School of Law
Downloads 114 (498,487)

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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

63.

Reconsidering Citizenship Taxation

Virginia Public Law and Legal Theory Research Paper No. 2024-69, Virginia Law and Economics Research Paper No. 2024-34, Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 16, Forthcoming in Taxing People: The Next One Hundred Years, (Tsilly Dagan & Ruth Mason, eds.), Cambridge University Press
Number of pages: 16 Posted: 22 Nov 2024
Tsilly Dagan and Ruth Mason
University of Oxford, Faculty of Law and University of Virginia School of Law
Downloads 112 (522,184)

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64.

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 108 (518,721)

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state aid, Deutsche Bahn deference, EU directives

65.

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 Carey Law School
Downloads 87 (597,843)

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

66.

Seeds of Discord: Inside Apple's EU Tax Controversy

Max Planck Lawcast, Episode 18
Number of pages: 3 Posted: 07 Oct 2024
Ruth Mason and Christopher Murphy
University of Virginia School of Law and Max Planck Institute for the Study of Crime, Security and Law
Downloads 78 (641,184)

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Max Planck Lawcast

67.

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 Carey Law School and University of Virginia School of Law
Downloads 78 (636,707)

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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

68.

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 Carey Law School
Downloads 77 (641,184)

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

69.

Amicus Brief of Michael Knoll and Ruth Mason Supporting Petitioners in National Pork Producers Council v. Ross

Number of pages: 39 Posted: 23 Aug 2022
Michael S. Knoll and Ruth Mason
University of Pennsylvania Carey Law School and University of Virginia School of Law
Downloads 73 (659,968)

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70.

Amicus Brief in Wayfair v. South Dakota

Number of pages: 24 Posted: 25 Apr 2018
American Enterprise Institute (AEI), University of Pennsylvania Carey Law School, University of Virginia School of Law and American Enterprise Institute
Downloads 67 (689,808)

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

71.

Why the Supreme Court Should Grant Certiorari in Steiner v. Utah

95 Tax Notes State 377 (2020)
Number of pages: 13 Posted: 08 Apr 2022 Last Revised: 24 May 2023
Ruth Mason and Michael S. Knoll
University of Virginia School of Law and University of Pennsylvania Carey Law School
Downloads 51 (785,051)

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72.

Steiner v. Utah: Designing a Constitutional Remedy

95 Tax Notes State 845 (2020)
Number of pages: 7 Posted: 08 Apr 2022 Last Revised: 24 May 2023
Ruth Mason and Michael S. Knoll
University of Virginia School of Law and University of Pennsylvania Carey Law School
Downloads 43 (843,410)

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Steiner, Wynne, dormant Commerce Clause, tax credits