Thursday, September 16, 2021

2021 NYU Tax Policy Colloquium Week 1: Brooks and Gamage on drafting a constitutional wealth tax, Part 2

 My prior post discussed the apportionment issues in the very interesting Brooks-Gamage paper that we discussed at the NYU Tax Policy Colloquium this past Tuesday. Herewith "everything else"- or rather, a few comments on just some of the many issues discussed elsewhere in the paper.


What I will do here is simply summarize several of the main arguments in the paper, and then offer brief response to them.

1) The paper's "Indirect Tax Canon" - The main route that Pollock found to invalidating the US federal income tax as a "direct tax," in violation of the Constitution's requirement that direct taxes be apportioned between the states, went something like this? A property tax (or at least a real property tax) is widely agreed to be an example of a direct tax. Taxing the income from property is tantamount to taxing the property itself. Hence, an income tax that includes the income from property is really just a property tax, at least in sufficient part to allow 1895's 5 right-wing ideologues (who were 5 in number) to strike the whole thing down.

The paper agrees with the 5 right-wingers from 1895 that there is an equivalence here. Modern scholarship has similarly talked a lot about the similarity between an income tax and a wealth tax, in terms such as the following: Say I have $100 of wealth that earns $5/year. A 20% income tax on the $5 annual flow, and a 1% wealth tax on the value that reflects the present value of all expected annual flows, not only raise $1/year each (at least, under the stated facts), but are simply very similar and to a degree interchangeable.

But here's the problem: If A is the same as B, then B is also the same as A. Is any seemingly indirect tax that could be stated as a direct tax thereby forbidden without apportionment? What about the fact that, equivalently, the direct tax version could be restated as an indirect tax? Why must everything that MIGHT be put in the form of a direct tax therefore qualify as such, rather than going the other way around (which is far more supportable based on pre-Pollock precedent)? The paper therefore sets forth the Indirect Tax Canon, which holds that, whenever Congress reasonably characterizes a tax as indirect, it should be so construed, even if one could also have stated it as a direct tax. They argue that (i) the pre- and post-Pollock precedents, (ii) the apparent original purpose of the apportionment clause and the Framers' broader intention regarding empowerment of the federal tax authorities, and (iii) common sense and workability all support the proposed canon.

Comment: This makes sense to me. But I believe that the current Supreme Court has shown signs of following what I would dub the "Modified Direct Tax Canon." This holds that, whenever a tax could be formally stated as either direct or indirect, they will choose whichever characterization permits them to get the policy result they want.

The PPL case from 2013 arguably foreshadows this approach. In that case, the Supreme Court determined that a UK tax was an income tax, rather than a wealth tax, and hence could qualify for foreign tax credits when paid by US multinationals. There were dueling amicus briefs by reputable academics, both pro and con creditability, and both sides noted that the UK tax could equivalently be stated and  thought of as either one. Each then gave nuanced rationales for following one characterization rather than the other.

For Justice Thomas on behalf of the Court, this was a super-easy case. Because it COULD be an income tax (this being one of the two equivalent forms), it WAS an income tax. Why? Apparently because Justice Thomas hated the UK "Labour Government" that had enacted  the tax. I have never seen any other US court case in which the political party of a foreign government that happened to have enacted a law raising US legal issues has been so emphasized, for absolutely no discernible reason behind unstated personal animus.

The funny thing about it is that Thomas didn't hurt the Labour Government by upholding creditability. Indeed, surely it was good for them because it meant the US Treasury, rather than companies that might have ongoing business in the UK, would be bearing the tax to the extent that credits were available. But he wasn't trying to hurt the Labour Government - he was trying to express contempt for them.

I view PPL, not as precedent here, but as evidence that right wingers on the Supreme Court will use the equivalence of direct and indirect taxes in order to make sure that they can always get the result they like.

2. Pollock was a rogue case, that did not merit respect and has not received it. In addition to being clearly wrong based on prior precedent, when it was decided, it was poorly reasoned, reflected clear political bias rather than proper judicial behavior, and was confused and incoherent. I should note, the paper doesn't so much lay all this out in detail, as it has other fish to fry, as offer some supportive evidence and allow one to infer the rest.

Comment: I'll just add one thing here: a quotation from it that shows what sort of exercise it was. Here goes: "The present assault upon capital is but the beginning. It will be but the stepping stone to others, larger and more sweeping, till our political contests will become a war of the poor against the rich - a war constantly growing in intensity and bitterness. If the court sanctions ... [this tax], it will mark the hour when the sure decadence of our present government will commence."

All this for a 2%tax on income above a given threshold! 

Let me rephrase the Court's argument: "HELP! The commies are coming! The commies are coming!" This sort of rabid (and as it proved empirically false), nakedly political, exercise does not make for a precedent that one should be eager to respect.

3) Pollock has subsequently been substantially overruled, not just by subsequent cases but also bt the 16th Amendment, which authorized the income tax.

Comment: I don't have the time or space here to address this very interesting set of arguments, but a point that other tax law scholars should notice and think about pertains to the paper's view of the famous words in the 16th Amendment - income "from whatever source derived" - as not just allowing income to be defined broadly, but also as very specifically rebutting the line of argument that Pollock used to say that a tax on property income is really a property tax - because the income is "derived" from the property, hence making it a direct tax even if it initially seems to be indirect.

Although there is lots more, I think I will stop here. But a final note I will add is that, if my pessimism about the current Supreme Court is justified - if they are as lawless, willful, and politically / ideologically driven, at the expense of honest legal reasoning, as I believe - this has implications for how folks on the other side from the Court should go about things.

The rule of law is an instrument for opposing sides agreeing to regulate their political competition by agreeing to some basic rules of the game, to mutual advantage if both sufficiently comply. Even if it has always been true that both liberal and conservative justices tend to come out in favor of their own views a surprisingly high percentage of the time, when they are committed to reasonably honest and good faith legal reasoning - an aspect of the rule of law there is both a selfish detriment and a selfish benefit. The selfish detriment is that you accept that sometimes you won't be able to get the result you want, because the legal reasoning exercise couldn't reasonably get you there. The selfish benefit is that sometimes this same constraint applies to the folks on the other side. Both sides may benefit overall from the mutual constraint, which adds to predictability, limits gyrations, etcetera.

If both sides were doing this in secret, this would be a prisoner's dilemma. But since they can to a degree observe each other (ex post rationalizations notwithstanding), they can work their way to a decent equilibrium in which methods such as tit-for-tat, or the loss of respect from more neutral third-party observers, supply the motivation to act at least moderately honestly and honorably.

But what if one side simply rejects any notion of limiting themselves by plausible and good faith legal reasoning? The other side really just cannot keep on playing the same old game if they are the only ones still honoring it. That leads straight to systematic exploitation of the good actors by the bad ones. It's not sustainable if the bad actors are set in their ways.

Welcome to the United States in 2021.

2021 NYU Tax Policy Colloquium Week 1: Brooks and Gamage on drafting a constitutional wealth tax, Part 1

 This past Tuesday (on September 14), Jake Brooks and David Gamage jointly appeared at the colloquium (Gamage by Zoom) for a discussion of their paper, The Indirect Tax Canon, Apportionment, and Drafting a Constitutional Wealth Tax

This was the first of our seven public colloquium sessions for the year (the other 6 meetings are just with the enrolled students, and generally serve to gear us all up for the public session). It was the first time we've had a "hybrid, " live plus Zoom colloquium, although last year we were all-Zoom. I thought the hybrid aspect went decently well, although Zoom participants could only see the stage (with Jake Brooks and myself), rather than all of the speakers. I gather that the acoustics were also mainly okay, although the fact that all live participants were wearing masks surely did not help in this regard. [Footnote: I hate masks, necessary though I agree that they are.]

I look forward to our having more remote attendees in the future, including perhaps from even faraway time zones. (We had a few Zoom attendees from well outside NYC on Tuesday, although technically I think they were all in EST.)

We conducted the discussion on Tuesday in two distinct segments. The first was the paper's discussion of using apportionment to render a wealth tax constitutional after all if the Supreme Court were to hold that it was a "direct tax" and thus unconstitutional otherwise. The second topic was "everything else."

Apportionment logically comes second as a discussion topic, and indeed that is how the paper is organized. But the novelty of the paper's approach to this issue, which I think the authors would agree is its most important new contribution, supports putting it first for our purposes.


Two points have generally attracted near-consensus in the literature discussing the possible enactment of a federal wealth tax. The first is that, if  the infamous 1895 Supreme Court case, Pollock v. Farmers' Loan & Trust Co., is binding precedent, then a federal wealth tax is a "direct tax" under the Constitution, making it unconstitutional unless duly apportioned between the states. The second is that so apportioning a federal wealth tax is impossible and unacceptable, with the consequence that applying Pollock would be a death knell for such an enactment.

On the first of these two standard claims, the paper adds context and background regarding Pollock's status (well-known to the cognoscenti) as a truly rogue case by a blatantly political Supreme Court that did not care about precedent, history, or the basics of coherent legal reasoning. It also argues that Pollock has been subsequently overruled in large part, not just by subsequent cases but also (beyond just the boundaries of the income tax, they argue) by the Sixteenth Amendment. But I will return to this in Part 2 of this discussion.

More notably, the paper also rejects the second of the above claims. It argues not only that apportionment between the states has frequently been done before - albeit, not for some time - but also that it can politically, practically, and reasonably be done today, with regard to the wealth tax or even certain expansions to the income tax that the current right-wing Supreme Court might strike down.

Apportionment is a bit of an intricate thing, so a simple hypothetical may help to present clearly what we are talking about here.

Apportionment hypothetical: Suppose there are just 2 states, New York (NY) and Alabama (AL). Each has a population of 10 people. Congress enacts a 10% wealth tax on wealth above a statutory threshold, yielding the following toy example:

                        Population     People Subject to WealthTax            $$ Subject to Wealth Tax

NY                       10                                3                                                 $500

AL                        10                                2                                                 $300

Unapportioned Wealth Tax: Absent apportionment, this 10% tax on wealth above threshold would raise $50 from New York and $30 from Alabama, for a total of $80.

Apportioned Wealth Tax: If the Supreme Court held that this was a direct tax requiring apportionment, then,the two states' equal populations would mean that equal $$ had to come from each. Thus,  assuming it was still raising $80 of total revenue, both NY and AL taxpayers would need to supply $40.

Solution: The standard response would be to say: In that case, the wealth tax rate must be 8% in NY and 13.3% in AL, thus raising $40 from each. But this is assumed to be crazy. A higher tax rate in the state that, at least only counting $$ above  the threshold, is poorer??

Drawing on 19th century precedents, the paper suggests instead doing something like the following:

(a) 8% wealth tax in both jurisdictions, raising $40 in NY and $24 in AL.

(b) To make up AL's shortfall, raise an additional $16 there through, say, a federal tax on AL's real property base, using AL valuations, and perhaps exempting, say, the bottom 5 (or whatever) of AL's taxpayers, based on their personal income or wealth,

(c) What's unfair here, they argue, is not AL's taxpayers paying higher rates on something as such - given federalism, taxpayers in different states pay different net state and local tax rates all the time - but rather, AL's not getting the money from this extra $16 federal tax. This does indeed relate to the apparent reasons for the apportionment rule, which related to the feds using tax bases that applied unevenly in practice, such that some states ended up contributing excessively (in relative terms) to the common federal purse. So they say, all we need to do is give Alabama $16 (or so back), in a manner that is sufficiently independent of and unlinked to the $16 levy here that the Supreme Court will not in good faith be able to group this return of the $$ with the extra $16 levy and disregard the latter as a sham.

The solution they propose, therefore, is that Congress also enact a fiscal equalization program between states like that which countries, with federal systems, that are more civilized than the US already have. AL, as the poorer state, would be losing in a certain sense relative to NY under the apportioned wealth tax, but winning under fiscal equalization, so overall it would be doing fine. And, we should take the fiscal equalization into account in deciding whether things are fair and just, but the Supreme Court must ignore it because they have no authority in this sort of context to look at EVERYTHING in the federal fiscal system - just at the particular tax instrument that is being tested under an apportionment requirement.

This might be done by enacting the straight-up wealth tax, but with back-up provisions implementing this thing instead if the Supreme Court, as expected given its right-wing political slant, upholds the applicability of Pollock to a modern federal wealth tax. Or maybe a tricky way of doing it is to enact the back-up proposal first - and then, a week later, enact the federal wealth tax, saying that it repeals the apportioned version, but conditional on its not being itself held a direct tax. This might have formal or technical advantages under Byrd Rule angles that I don't personally know much about.

We had an interesting discussion about all this on Tuesday, which even continued to a degree by emails between some of the participants afterwards. But, for present purposes, I will settle for offering the following discrete comments. (I am hoping that this blogpost will help the paper's analysis enter the broader dialogue for consideration by lots of people outside this particular space.) Anyway, here with the comments:

1) What with the lack of an explicit link (or one at the margin) to fiscal equalization, this might still be a hard sell politically. Also, if we did fiscal equalization just right but then added this, we would in effect now be giving AL, as the poorer state, too little. But then again, the US has no explicit fiscal equalization program today (although it does of course effectively transfer $$ between states).

2) While the best shouldn't be the enemy of the good, it is possible that this proposal, as it ended up operating, would be less to the taste of wealth tax proponents than the program that they preferred. A key feature is getting the make-up revenues from people below the top threshold where the wealth tax would otherwise have exclusively applied.

3) In this example, AL is by hypothesis both the poorer state and the one that gets socked with the extra $16 under apportionment. But a state that, in a pure wealth tax, would pay "too little" and thus get hit up for extra would not necessarily win under fiscal equalization that went from richer states to poor states. Suppose Minnesota (MN) is richer than Louisiana (LA) per capital because it has more middle class folks and fewer oppressed poor. But suppose as well that LA has more super-rich people (its oppressing plutocrats), or more precisely more $$ per capital held by rich people that is subject to the wealth tax. In short, while LA is richer at the top, MN is more affluent overall. Then MN would have to pay the supplemental tax under apportionment, AND fiscal equalization transfers might be expected to flow from MN to LA.

4) The paper also discusses doing this for income tax enactments that a right-wing Supreme Court might strike down under the authority (such as it is) of Eisner v. Macomber, with its ludicrously constitutionalized realization requirement. Suppose Senator Wyden's proposal to tax people above a certain threshold on a mark-to-market basis were struck down by the current Supreme Court - as they would no doubt be slavering to do, and I note that (ever since Barrett joined the Court as right-winger #6) their reluctance to do whatever they want has certainly declined. Applying apportionment here might be trickier, as the rest of the income tax would still presumably be valid. But that is not to say that it would be impossible, e..g, based on "stacking" the income from this provision on top of everything else in the tax code in order to determine its marginal revenue yield that then needed to be equalized relative to population.

5) More on this in Part 2 (which will be a separate blog post), but a Supreme Court that was acting in bad faith, as I for one certainly believe that the current majority does, would surely find a way - or perhaps, many ways - to strike it down, simply because they don't like it. The paths they might use, if so minded, might include at least the following:

a) Despite the clear precedents in favor of amalgamating the separate pieces of a given enactment - as here, where NY pays "too much" under the wealth tax proper and AL pays "too much" under the property tax add-on - they'd look at each part separately and ruled that both, albeit in opposite directions, violated apportionment. Why would they do this? A better question might be: Why wouldn't they do this?

b) They could call the extra piece a sham given fiscal equalization, even if the offset was imprecise and the two were not actually linked at the margin,

c) They could say that the interstate competitive pressure on AL to rebate fiscal equalization $$ about equal to the extra property tax placed them under an improper constraint, analogous to the reasons for the Court's holding that states must be allowed to reject free Medicaid $$ under the ACA.

d) No matter how the residual tax to even up the pure wealth tax part worked, they could say: Sorry, but you didn't do it just right, so the whole thing is invalid! Again, why wouldn't they do this?

In my next blogpost, Part 2 on the Brooks-Gamage paper, I will address selected aspects of "everything else" in the paper apart from apportionment.

Let me just say, however, that people who are interested in the prospects for a federal wealth tax - if not this year, than under a future Congress that has not loosed the shackles of a runaway right-wing Supreme Court - should definitely read the article for themselves.

Thursday, July 29, 2021

New short video

Here you can watch my cat Gary steal the show as I discuss a recent tax paper of mine with Leandra Lederman and Allison Christians on their new short video series, Break Into Tax.

New book forthcoming next year

I've signed a contract with Anthem Press for the publication of my most recent book, currently titled Bonfires of the American Dream in American Rhetoric, Literature, and Film. Anthem also published Literature and Inequality. Currently scheduled to come out in May 2022.

The book includes 3 main case studies. The first discusses Russell Conwell's Acres of Diamonds speech and the John Galt speech near the end of Ayn Rand's Atlas Shrugged. The second discusses The Great Gatsby, with reference not just to the text itself but also its changing reception across the decades. The third discusses the films It's a Wonderful Life and The Wolf of Wall Street.

The new book is only half as long as Literature and Inequality, and more tightly focused. L & I not only had a much broader canvas but also was engaged in making the methodological case for such studies. Here much of the focus is on what features of our national culture across time could have brought us to where we are now.

Sunday, July 11, 2021

Recent short explainers

 I have recently posted a couple of sort "explainer" pieces on websites that cover ongoing issues.

First, on the Just Security website run by my NYU colleague Ryan Goodman, I posted this piece on the Weisselberg indictment, aiming to correct misperceptions in the press that this was merely a technical or politically motivated "fringe benefits" case, rather than an assertion of rampant fraud that no responsible prosecutor could reasonably decline to file. This one got much broader coverage than reflections I post on this blog, so it probably isn't news to most of my readers here.

Second, last night posted a short solicited piece of mine entitled "Taxing Multinational Corporations." Here the question of interest is as follows:

"In debates regarding higher versus lower corporate income taxes, an important issue is the impact that changes in either direction would have on the level of domestic investment, and consequently on economic growth, the strength of the labor market, and government revenues.... What do economic reasoning and recent experience teach us about the effects of corporate tax rates on investment and economic growth in a global environment?"

This one dovetails nicely with an article in progress, entitled "The Economics, Law, and Politics of Increased Taxation of Multinationals" that I presented this past Friday at the Indiana-Leeds Summer Zoom Tax Workshop Series. I will probably post a draft of this on SSRN soon, but thought that I would advance it closer to a final draft first. That is the piece I will most likely be workshopping this fall at places such as the National Tax Association (although it might conceivably be superseded in some settings by other stuff that I'm working on now). It's fairly crisp, short, and I hope readable, and I might aim to publish it in Tax Notes, although it's not impossible that I might aim instead for a tax law review, especially one with decently quick turnaround.

Thursday, June 24, 2021

Remote attendance at the 2021 NYU Tax Policy Colloquium

This coming fall, I will be doing the NYU Tax Policy Colloquium solo, and hence cutting it back from a 4-credit to a 2-credit course. This means that, rather than meeting twice each week - first with the students, and then in a public session with the author(s), I'll meet with the students one week to discuss the upcoming paper, and then in public the next week. Hence, the public sessions will only be biweekly, or if you prefer fortnightly. However, since we're having a 13-week semester, I've decided to have the extra session be a public one.

The public sessions will be hybrid, meaning that they are both live and on Zoom. I already knew that the authors can attend remotely via Zoom if they wish, although I am hoping to see them live. But now it's been confirmed that, for the public sessions, I can offer remote Zoom attendance to any and all who are interested, apart from the enrolled students, who - like me - are required to be there in person. Hence, I am hoping that, without too much cannibalizing of our live audience, we will get remote attendees from different places, time zones, and indeed continents.

So mark your virtual calendar if you are potentially interested. The live sessions, all meeting from 2:15 to 4:15 pm EST, will feature the following speakers and their papers:

1) Tuesday, September 14 - Jake Brooks and David Gamage

2) Tuesday, September 28 - Daniel Hemel

3) Tuesday, October 12 - Jennifer Blouin

4) Tuesday, October 26 - Manoj Viswanathan

5) Tuesday, November 9 - Ruth Mason and Michael Knoll

6) Tuesday, November 23 - Mindy Herzfeld

7) Tuesday, November 30 - Alan Auerbach.

There might also be small group dinners after the sessions - only for live attendees! (although I suppose one could attend via Zoom and then join the live dinner). But obviously that depends on pandemic developments, including both NYU's rules as they evolve or not over the course of  the year, and my own (along with potential attendees') degrees of comfort with doing this by the fall. Also, I would think we won't do a dinner in any week when the author is Zooming in.

Friday, June 18, 2021

New Jotwell post on Isabel Wilkerson's CASTE

 At Jotwell (aka "The Journal of Things We Like Lots"), I have posted here a short review of Isabel Wilkerson's recent book Caste.  It also mentions Dorothy Brown's recent book, The Whiteness of Wealth, although I don't review that book as such, as another Jotwell contributor had already stepped up to do that.

My piece also discusses broader issues of race and class in tax scholarship, albeit briefly as these are very short pieces.

Monday, June 07, 2021

G7 Finance Ministers Communique re. international tax policy

The G7 Finance Ministers' Communique from this past weekend included the following discussion of international tax policy:

"We strongly support the efforts underway through the G20/OECD Inclusive Framework to address the tax challenges arising from globalisation and the digitalisation of the economy and to adopt a global minimum tax. We commit to reaching an equitable solution on the allocation of taxing rights, with market countries awarded taxing rights on at least 20% of profit exceeding a 10% margin for the largest and most profitable multinational enterprises. We will provide for appropriate coordination between the application of the new international tax rules and the removal of all Digital Services Taxes, and other relevant similar measures, on all companies. We also commit to a global minimum tax of at least 15% on a country by country basis. We agree on the importance of progressing agreement in parallel on both Pillars and look forward to reaching an agreement at the July meeting of G20 Finance Ministers and Central Bank Governors."

Here are a few comments on this paragraph:

1) The proposed allocation to market countries raises a few questions. For one, what is the relevant "profit"? By definition, this term requires comparing specified gross revenues to specified expenses and other deductible outlays. Are these to be determined by using standard income tax source rules? I would think not, as this would make the proposed allocation wildly ineffective. For example, the UK may consider itself the market country with respect to the revenues that Facebook earns from the use of its digital platform by UK residents. This probably has more in common with how gross revenues are defined in its digital services tax (DST) than with anything in its income tax. 

2) Note also that this rule will ostensibly apply to all of the "largest and most profitable multinational enterprises," without apparent limitation to those that are subject to DSTs. And it is also supposed to apply in countries that don't have DSTs. Moreover, even those that do have DSTs may define relevant revenues (as well as companies subject to the DST) quite distinctively.

3) Next and relatedly, what about the outlay/deduction side? This is needed not only to define profit, but also to determine the profit that exceeds a 10% margin.

4) To identify the "largest and most profitable multinational enterprises," one needs a measure of global income. How is this to be computed?

5) What if a country wants to retain its DST? The G7 statement says only that it will "provide for appropriate coordination between the application of the new international tax rules and the removal of all Digital Services Taxes, and other relevant similar measures, on all companies."

6) Obviously, the 15% global minimum tax has lots of design work ahead (to put it mildly). It is presumably to be applied by the multinationals' residence countries - requiring a uniform definition of corporate residence? - and presumably with (100%?) foreign tax credits for source-based taxes. While the foreign tax credits would make it a residual tax, applying only insofar as the source-based taxes don't get there, this might leave plenty of scope for it, if source countries restrict themselves to 20% of profits above the 10% level (especially given the likelihood that there will be plenty of flex in how those profits are being defined).

7) How are countries are likely to respond in practice? While there is certainly room for pessimism, I don't think the standard view of how countries pursue their self-interest (like profit-seeking individuals in a simple neoclassical model) necessarily applies very strongly. Countries are collective entities that make political choices based on multiple actors who themselves may have narrow, not national, goals in mind. These may also be symbolic goals reflecting internal political dynamics. Consider the "self-interest" of the United States. Even in academic debate among knowledgeable people who are debating things in good faith, there is absolutely no consensus as to what is in the national self-interest in the international tax policy realm. Indeed, even only counting people whom I consider good personal friends, there is extreme dissensus.

8) When we start thinking in terms of a Biden Administration versus a Trump Administration, things get even less determinate, insofar as predicting the settings of the national policymaking compass is concerned. Even if we accept both administrations as trying to act in what they deem to be the national interest (which I don't think accurately describes the corrupt and treasonous Trump White House), they evidently define it radically differently. Suppose that all of the G7 countries had either (a) center-left to progressive regimes, or alternatively (b) right-wing "nationalist," plutocratic, pseudo-populist regimes. These two scenarios would lead to very different sets of policies being followed.

Monday, May 24, 2021

Upcoming summer Zoom talks

 Can you be in two places at once? With Zoom, the answer is yes. Thus, towards the end of this week I will be attending and participating in two conferences during the same stretch of days, although if not for the pandemic they would have been held live in distinct locations. I will also be an active participant in one session of each.

This Friday (May 28), at the Fifth Annual Public Finance Consortium at Indiana University (normally held in Bloomington, IN), from 10 to 10:40 am EST, I will be the discussant when David Gamage and Jake Brooks present their work-in-progress, "Tax Now or Tax Never: Political Optionality and the Case for Current-Assessment Reform."

Then this Sunday (May 30) at the Law and Society Association's 2021 Annual Meeting, which in the ordinary course would have been held in Chicago, from 10 to 11:45 am EST, I will participate in an "Author Meets Readers" session regarding my book Literature and Inequality. Tracey Roberts will be the session's moderator, and I very much look forward to the comments that will be offered by Diane Klein, Shu-Yi Oei, and Luisa Scarcella (plus members of the virtual audience).

Somewhat further down the road, on July 9, from 11:30 am to 1 pm EST, I will present my work-in-progress, "The Economics, Law, and National Politics of Seeking Increased Taxation of Multinationals" at the Indiana/Leeds Summer Tax Workshop Series, hosted by Leandra Lederman and Leopoldo Parada. I will also be presenting this paper later in the year, e.g., most likely at both the National Tax Association's Annual Meeting and in Vienna, Austria towards the end of the year.

I also anticipate attending a conference in USC Law School on November 5, honoring Ed Kleinbard, at which Joe Bankman and I are planning to present (after we have written it) a paper discussing Ed's work and contributions to the field.

Meanwhile I will be hosting the Tax Policy Colloquium at NYU this fall, although with what mix between live and Zoom is not yet clear. I am hoping for live public (as well as class) sessions, but it would be better still if the former accommodated remote attendees by Zoom. We will see.