J.D., University of Minnesota (magna cum laude)
B.A., Augsburg College (cum laude)
Teaching and Scholarship
- University of Florida: Joined Law faculty as Associate Professor, 1974. Named Professor (1977) and Hugh Culverhouse Eminent Scholar in Taxation (1994).
- Previous Educational Experience: University of Georgia, Assistant Professor of Law, (1968-70); New York University, Professor of Law (1980-93), Associate Dean for Graduate Division (1984-87).
- Visiting Faculty: University of Minnesota (1973-74); Duke University (1988); Southern Methodist University (2003); Northwestern University (2004-2005); University of Leiden, The Netherlands (1978, 1993, 1995, 1999, 2002-2005); Munster University, Germany (1999-2002); Rand Africaans University (2001); Warsaw University, Poland (2000, 2002).
- Consulting: Research Consultant for Harvard Law School International Tax Program (1977-82), United Nations Ad Hoc Group of Experts on International Tax Matters (1995-98).
- Private Law Practice: Henson & Efron, Minneapolis, Minnesota (1967-68, 1970-73).
Income Taxation I (3 credits) – LAW 7602
- Tax problems of individual taxpayers; problems incident to the sale, exchange and other disposition of property, including recognition and characterization concepts.
U.S. International Tax I (2 credits) – LAW 7614
- Tax definition of resident; distinction between domestic and foreign entities; taxation of business income and nonbusiness income of foreign persons; taxation of income of trades or business carried on by foreign persons in the U.S.; special rules on the U.S. real property interests; and branch interest taxes.
U.S. International Tax II-LLM (2 credits) – LAW 7615
- The foreign tax credit; special rules on controlled foreign corporations; foreign currencies; and cross-border transfers in nonrecognition transactions.
Prerequisite: U.S. International Tax I
Transfer Pricing (2 credits) – LAW 7683
- Transactions between related entities in connection with the tax requirement that such transactions be priced as if between unrelated persons.
Tax Treaties (2 credits) – LAW 7931
- Bilateral income tax convention between countries to alleviate double taxation of income from international investments and activities and to provide for exchanges of tax information and consultation between tax authorities.
International Tax Policy Seminar (2 credits) – LAW 7931
- Issues related to a country’s taxation of foreign persons deriving income and doing business in the country, including policies affecting a country’s basic system for taxing international income, the debate over so-called harmful tax competition, and selected topics in tax treaties.
- FUNDAMENTALS OF INTERNATIONAL TAXATION (with Boris I. Bittker)(1990, 1997, 1999, 2001-2005)
- FEDERAL TAXATION OF INCOME, ESTATES & GIFTS (Treatise) (with Boris I. Bittker) Volumes 1-5. 2nd ed. (1989, 1990, 1991, 1992, 1993) and 3rd ed. (1999, 2000, 2001, 2003).
Representative Law Reviews / Journals
- Does the U.S. Tax System Disadvantage U.S. Multinationals in the World Marketplace? 4 J. Tax’n of Global Transactions 53 (Summer 2004)
- As the World of Partnership Taxation Turns, 56 SMU L. Rev. 365 (2003)
- A Tax Lawyer’s Observations on Scary Numbers, Politics, and Irresponsibility, 45 BC L. Rev. 1335 (2004)