The Florida Tax Review, one of only a few faculty-edited academic law reviews, publishes articles, essays, and book reviews by leading legal academics, practitioners, and economists. FTR is sponsored by the Graduate Tax Program of the University of Florida Levin College of Law.

Vol. 26 No. 1 (2022): Fall 2022

Published: 2023-12-04

The Taxation of Treasury Inflation Protected Securities

Are They Tax-Disadvantaged?

Robin Morgan

1–30

Abstract

Inflation is back, causing problems for taxpayers looking for safe, inflation-protected investments. This Article engages in an in-depth...

--Read More

Taxation at a Distance

Jeff Gordon

31–75

Abstract

Wealthy Americans escape the income and estate taxes by holding assets at a legal remove. This general tax avoidance strategy—holding wealth “at...

--Read More

The Executive Compensation Threat to Retirement

Peter Wiedenbeck, Norman Stein

76–167

Abstract

In recent years a new phenomenon has appeared on the retirement savings landscape: the expansion into middle management ranks of a traditional...

--Read More

Revisiting the Interaction of the Interest Expense Deduction and the Foreign Tax Credit

Bret Wells

168–286

Abstract

This Article demonstrates that the most appropriate proxy for allocating and apportioning U.S. interest expense is one that first identifies the...

--Read More

The Dubious Constitutional Origins of Treaty Overrides

A Response to Rosenbloom and Shaheen

Reuven Avi-Yonah

287–325

Abstract

In 1888, the Supreme Court decided a case called Whitney v. Robertson, which is generally considered to be the source of the proposition that,...

--Read More

The Common Sense of a Wealth Tax

Thomas Paine and Taxation as Freedom from Aristocracy

Jeremy Bearer-Friend, Vanessa Williamson

326–368

Abstract

Thomas Paine’s writing helped spur the American colonies to independence and ensure that the new nation would be a republic, not a monarchy. In...

--Read More

Reimagining a U.S. Corporate Tax Increase as a Supplemental Subtraction VAT

Daniel S. Goldberg

369–418

Abstract

The U.S. federal government raises tax revenue almost exclusively through income taxes, both corporate and individual, whereas its trading...

--Read More

Safe Harbor Regimen in Transfer Pricing—An African Perspective

Alexander Ezenagu

419–457

Abstract

The transfer pricing methods established by the transfer pricing rules and practices of many countries (generally modelled after the OECD...

--Read More

View All Issues