Ruth Mason

University of Virginia School of Law

Edwin S. Cohen Distinguished Professor of Law and Taxation

United States

SCHOLARLY PAPERS

55

DOWNLOADS
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Top 1,476

in Total Papers Downloads

21,726

SSRN CITATIONS
Rank 33,022

SSRN RANKINGS

Top 33,022

in Total Papers Citations

11

CROSSREF CITATIONS

12

Scholarly Papers (55)

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 1,273 (17,201)
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.

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 1,193 (19,017)

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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

3.

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 1,106 (21,242)

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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

4.

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 1,083 (21,997)

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

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: 16 Jun 2016
Ruth Mason
University of Virginia School of Law
Downloads 1,080 (22,022)

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

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 952 (26,421)
Citation 1

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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.

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 781 (34,915)

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

8.

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 647 (45,041)
Citation 1

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

9.

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 640 (45,726)

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

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 637 (46,026)

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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 631 (46,777)
Citation 1

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State Aid, EU, Tax, Transfer Pricing

12.

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 620 (47,633)
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

13.

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 592 (50,735)
Citation 1

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

14.

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 569 (53,201)

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

15.

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 559 (54,382)

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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

16.

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 530 (58,346)

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

17.

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 489 (64,399)

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

18.

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 488 (64,547)

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

19.

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 481 (65,699)

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

20.

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 446 (72,086)

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

21.

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 436 (74,059)

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sovereign wealth funds, taxation

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 397 (83,123)

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

23.

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 390 (84,344)

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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

24.

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 383 (86,177)

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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

25.

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
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, University of California Hastings College of the Law, Yeshiva University - Benjamin N. Cardozo School of Law and University of California, Los Angeles (UCLA) - School of Law
Downloads 356 (93,767)
Citation 1

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

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 325 (104,269)

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

27.

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 325 (103,926)

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Wayfair, Sales Tax, Digital Services Tax, Amazon Tax

28.

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 317 (106,841)

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

29.

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 287 (118,825)

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

30.

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 268 (128,224)
Citation 1

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

31.

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 261 (131,266)

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

32.

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 259 (132,385)

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

33.

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
Number of pages: 18 Posted: 21 Oct 2020 Last Revised: 22 Oct 2020
Stephen Daly and Ruth Mason
King's College London - The Dickson Poon School of Law and University of Virginia School of Law
Downloads 257 (133,908)

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

34.

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 248 (138,816)
Citation 1

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state aid, selectivity, Apple state aid, tax competition

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
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 202 (168,082)
Citation 1

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

36.

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 197 (172,117)

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

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 194 (174,535)

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

38.

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 188 (179,543)

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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

39.

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 178 (189,382)

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EU, state aid, Apple, base-erosion

40.

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 177 (189,382)
Citation 1

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

41.

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 170 (196,130)

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digital tax, Hervis, Vodafone, CJEU, Tesco

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 156 (211,021)

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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 126 (250,100)

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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 123 (254,756)

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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.

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 (315,301)
Citation 1

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

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 89 (317,550)

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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.

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, Indiana University Maurer School of Law, Ohio State University (OSU) - Michael E. Moritz College of Law, New York University (NYU), University of San Diego School of Law, University of Southern California Gould School of Law, 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 88 (319,830)

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

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 86 (324,438)

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

49.

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
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 73 (357,221)

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50.

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 60 (395,608)

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51.

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 56 (409,270)

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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

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 53 (419,554)

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state aid, Deutsche Bahn deference, EU directives

53.

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 53 (419,554)

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

54.

Amicus Brief in Wayfair v. South Dakota

Number of pages: 24 Posted: 25 Apr 2018
American Enterprise Institute (AEI), University of Pennsylvania Law School, University of Virginia School of Law and American Enterprise Institute
Downloads 35 (493,045)

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

55.

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 26 (540,510)

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