Stanley Surrey, the Code and the Regime

14 Pages Posted: 8 Jul 2019 Last revised: 6 Dec 2019

See all articles by Reuven S. Avi-Yonah

Reuven S. Avi-Yonah

University of Michigan Law School

Nir Fishbien

University of Michigan at Ann Arbor - Law School - SJD Candidate

Gianluca Mazzoni

University of Michigan at Ann Arbor - Law School - SJD Candidate

Date Written: July 4, 2019

Abstract

Stanley Surrey (1910-1984) was arguably the most important tax scholar of his generation. Surrey was a rare combination of an academic (Berkeley and Harvard law schools, 1947-1961 and 1969-1981) and a government official (Tax Legislative Counsel, 1942-1947; Assistant Secretary for Tax Policy, 1961-1969). Today he is mostly remembered for inventing the concept of tax expenditures and the tax expenditure budget. This paper will argue that while Surrey was influential in shaping domestic tax policy for a generation and had an impact after his death on the Tax Reform Act of 1986, his longest lasting contributions were in shaping the international tax regime, since the concept of the single tax principle that shapes contemporary international tax reform efforts can be traced directly to his writing and activities both in academia and in the government.

Keywords: Stanley Surrey, Tax Expenditures, Single Tax Principle, Tax Reform

JEL Classification: H26

Suggested Citation

Avi-Yonah, Reuven S. and Fishbien, Nir and Mazzoni, Gianluca, Stanley Surrey, the Code and the Regime (July 4, 2019). U of Michigan Public Law Research Paper No. 652. Available at SSRN: https://ssrn.com/abstract=3414965 or http://dx.doi.org/10.2139/ssrn.3414965

Reuven S. Avi-Yonah (Contact Author)

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

Nir Fishbien

University of Michigan at Ann Arbor - Law School - SJD Candidate ( email )

Ann Arbor, MI
United States

Gianluca Mazzoni

University of Michigan at Ann Arbor - Law School - SJD Candidate ( email )

Ann Arbor, MI
United States

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