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Tel: 215.898.6190
Fax: 215.573.2025
Email: mknoll@law.upenn.edu
Expertise
- Finance
- Income Taxation
- International Trade
- Tax Law
- Tax Policy
- Real Estate Transactions
- Corporate Finance
- Corporate and Financial Law
Bio
Michael Knoll is an insightful commentator on the income tax laws and a creative proponent of how that tax could be redesigned.
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Michael Knoll is an insightful commentator on the income tax laws and a creative proponent of how that tax could be redesigned. Much of Knoll’s recent and current research involves the application of finance principles to tax policy issues. His 1993 article, “Taxing Prometheus”, explains how the income tax preferential treatment of debt relative to equity discourages investment in risky, growing companies using intangible capital because such firms cannot use as much debt as safe, mature firms using tangible capital. His 1996 article, “An Accretion Corporate Income Tax”, advances the highly original idea of taxing a publicly traded corporation on the change in market value of its outstanding securities and shows that under certain assumptions that would be equivalent to an ideal income tax. His recent article, “Taxing Sunny Days”, shows how the tax system discourages investment in high-cost and low-amenity regions and describes how this bias could be eliminated by requiring taxpayers who could exchange jobs to pay the same amount in tax.
At the U.S. International Trade Commission, where Knoll started his career, he developed an economic and legal analysis for determining injury in antidumping and countervailing duty cases. That analysis, which greatly increased the coherence of the Commission’s decisions, is used in the United States and abroad and has produced a large and growing literature.
His 1996 article, “A Primer on Prejudgment Interest” is routinely relied upon by courts and lawyers when calculating prejudgment interest – the interest that a losing defendant pays a prevailing plaintiff on damages from the time of injury until the time of recovery.
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Representative Professional Positions
Penn Law - Theodore K. Warner Professor of Law (2006 -); Associate Dean (2004-06); Earle Hepburn Professor of Law (2004-06); Professor of Law (2000-04); Wharton – Professor of Real Estate (2000 -); Center for Tax Law and Policy at Penn - Co-Director (2007 -)
University of Southern California, Law School - Professor (1995-2000); Associate Professor (1992-95); Assistant Professor (1990-92)
Irell & Manella - Associate (1989-90)
Debevoise & Plimpton - Associate (1987-89)
Legal Advisor to Vice Chairman Anne Brunsdale, U.S. International Trade Commission (1986-87)
Law Clerk to Judge Alex Kozinski, U.S. Court of Appeals for the Ninth Circuit (1986)
Representative Publications
Compaq Redux: Implicit Taxes and the Question of Pre-Tax Profit, VA. TAX REV. (forthcoming 2007).
Implicit Taxes and Pretax Profit in Compaq and IES Industries, 114 TAX NOTES 679 (2007).
The Section 83(b) Election for Restricted Stock: A Joint Tax Perspective, 59 SMU L. REV. 721 (2006).
Regulatory Arbitrage Using Put-Call Parity, 15 J. APPLIED FIN. 64 (2005)
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The Tax Efficiency of Stock-Based Compensation, 103 TAX NOTES 203 (2004).
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The Case for Repealing the Corporate Alternative Minimum Tax, 56 SMU L. REV. 305 (2003) (with Terrence R. Chorvat).
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Simplifying the Transition to a (Progressive) Consumption Tax, 56 SMU L. REV. 53 (2003) (with Mitchell L. Engler).
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Taxing Sunny Days, A Beautiful View and a Low Cost of Living, 116 HARV. L. REV. 987 (2003).
A Primer on Prejudgment Interest, LITIGATION SERVICES HANDBOOK (2003).
Put-Call Parity and the Law, 24 CARDOZO L. REV. 61 (2002).
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The Economic and Policy Implications of Repealing the Corporate Alternative Minimum Tax, Tax Foundation Background Paper No. 40, February 2002 (coauthor).
Ethical Screening in Modern Financial Markets: The Conflicting Claims Underlying Socially Responsible Investment, 57 BUS. LAW. 681 (2001).
Tax Planning, Effective Marginal Tax Rates, and the Structure of Income Tax, 54 TAX. L. REV. 555 (2001).
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Antidumping, in THE NEW PALGRAVE DICTIONARY OF ECONOMICS AND THE LAW (Stockton Press, 1998) (coauthor).
Products Liability and Legal Leverage: The Perverse Effect of Stiff Penalties, 45 UCLA L. REV. 99 (1997).
An Accretion Corporate Income Tax, 49 STAN. L. REV. 1 (1996).
A Primer on Prejudgment Interest, 75 TEX. L. REV. 293 (1996).
Designing A Hybrid Income-Consumption Tax, 41 UCLA L. REV. 1791 (1994).
Taxing Prometheus: How the Corporate Interest Deduction Discourages Innovation and Risk-Taking, 38 VILL. L. REV. 1461 (1993).
For additional publications, please consult
Current & Recent Research
Current Working Papers
The Ancient Roots of Modern Financial Innovation: The Early History of Regulatory Arbitrage, (U of Penn, Inst for Law & Econ Research Paper 04-11, June 2004).
The Calculation of Prejudgment Interest, (May 2005) (with Jeffrey M. Colon).
Restricted Stock and the Section 83(b) Election: A Joint Tax Perspective , (August 2005).
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