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Michael Knoll

Theodore K. Warner Professor of Law & Professor of Real Estate; Co-Director, Center for Tax Law and Policy

Michael Knoll

Michael Knoll is an insightful commentator on how income tax laws affect business and investment decisions and a creative proponent of how those laws could be redesigned. Much of his recent research involves the application of finance principles to questions of international tax policy, especially the connection between taxation and competitiveness. Continue reading… Michael Knoll is an insightful commentator on how income tax laws affect business and investment decisions and a creative proponent of how those laws could be redesigned. Much of his recent research involves the application of finance principles to questions of international tax policy, especially the connection between taxation and competitiveness. Professor Knoll’s recent research includes writings on sovereign wealth funds, private equity, international tax arbitrage, and the impact of the corporate income tax on the competitiveness of the U.S. auto industry.

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Expertise

  • Tax Law
  • Tax Policy
  • Income Taxation
  • Corporate Finance
  • Corporate and Financial Law
  • Finance
  • Real Estate Transactions
  • International Trade

Articles and Book Chapters

Waiting for Perseus: A Sur-reply to Professors Graetz and Warren, TAX L. REV. (with Ruth Mason). (forthcoming)

The Connection between Competitiveness and International Taxation, 65 TAX L. REV. 349 (2012).

What is Tax Discrimination?, 121 YALE L. J. 1014 (2012) (with Ruth Mason).

Reconsidering International Tax Neutrality, 64 TAX L. REV. 99 (2011).

A Comprehensive Theory of Deal Structure: Understanding How Transactional Structure Creates Value, 89 TEX. L. REV. SEE ALSO 35 (2011) (with Daniel M. G. Raff).

The Corporate Income Tax and the Competitiveness of U.S. Industries, 63 TAX L. REV. 771 (2010).

Business Taxes and International Competitiveness: Understanding How Taxes Can Distort Capital Ownership and Designing a Nondistortive International Tax System, in DIMENSIONS OF COMPETITIVENESS (Paul De Grauwe, ed., 2010).

Taxation and the Competitiveness of Sovereign Wealth Funds: Do Taxes Encourage Sovereign Wealth Funds to Invest in the United States? 82 S. CAL. L. REV. 703 (2009).

Samuel Zell, the Chicago Tribune and the Emergence of the S ESOP: Understanding the Tax Advantages and Disadvantages of S ESOPs, 70 OHIO ST. L.J. 519 (2009).

The Ancient Roots of Modern Financial Innovation: The Early History of Regulatory Arbitrage, 87 OR. L. REV. 93 (2008).

The Taxation of Private Equity Carried Interests: Estimating the Revenue Effects of Taxing Profit Interests as Ordinary Income, 50 WM. & MARY L. REV. 115 (2008).

Implicit Taxes and Pretax Profit in Compaq and IES Industries, 114 TAX NOTES 679 (2007).

Prejudgment Interest in International Arbitration, 4 TRANSNAT'L DISP. MGMT. 1 (2007) (with Jeffrey M. Colon).

Compaq Redux: Implicit Taxes and the Question of Pre-Tax Profit, 26 VA. TAX REV. 821 (2007).

The UBIT: Leveling an Uneven Playing Field or Tilting a Level One?, 76 FORDHAM L. REV. 857 (2007).

Prejudgment Interest, in LITIGATION SERVICES HANDBOOK: THE ROLE OF THE FINANCIAL EXPERT (4th ed., 2007) (with Jeffrey M. Colon).

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)

The Tax Efficiency of Stock-Based Compensation, 103 TAX NOTES 203 (2004).

The Case for Repealing the Corporate Alternative Minimum Tax, 56 SMU L. REV. 305 (2003) (with Terrence R. Chorvat).

Simplifying the Transition to a (Progressive) Consumption Tax, 56 SMU L. REV. 53 (2003) (with Mitchell L. Engler).

Taxing Sunny Days, A Beautiful View and a Low Cost of Living, 116 HARV. L. REV. 987 (2003).

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).

An Accretion Corporate Income Tax, 49 STAN. L. REV. 1 (1996).

More publications can be found here.

Working Papers

Economic and Legal Arguments in PPL v. Commissioner (U. Pa. Inst. for Law & Econ., Research Paper No. 13-5, 2013)
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International Competitiveness, Tax Incentives, and a New Argument for Tax Sparing: Preventing Double Taxation by Crediting Implicit Taxes (U. Pa. Inst. for Law & Econ., Research Paper No. 08-21, 2008).
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Taxes and Competitiveness (U. Pa. Inst. for Law & Econ., Research Paper No. 06-28, 2006).
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Research Areas

  • Tax Policy
  • Tax Planning
  • The Application of Finance to Law

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- )

University of Southern California, Law School - Professor (1990-2000)

Law Clerk to the Hon. Alex Kozinski, U.S. Court of Appeals for the Ninth Circuit (1986)

Visiting Professor or Visiting Scholar - Virginia, Georgetown, Toronto, Columbia, NYU, Boston University

Legal Advisor to Vice Chairman Anne Brunsdale, U.S. International Trade Commission (1984-87)

Member, Academic Advisory Committee, Joint Committee on Taxation (2000-02)

Professional Activities

Academic Director (Law), Law and Business Fellowship Program (LBFP), 2006 – 2009. (LBFP is a joint program of the University of Pennsylvania, the U.S. State Department, Middle East Partnership Initiative and Amideast that brings approximately 40 women from the Middle East and North Africa to the United States each year for 6 months to study and for internships)

Member, Academic Advisory Committee, Joint Committee on Taxation, 2000 ? 2001.

Editor, Forensic Economic Abstracts, SSRN, 1997 ? Present.

Executive Committee, AALS Section on Business Associations, 1994 ? January 1997. Member, American Law and Economics Association, 1990 ? Present.

Member, American Finance Association, 1990 ? Present.

Courses

  • Federal Income Taxation
  • Corporate Finance
  • Taxes and Business Strategy
  • Tax Policy Seminar
  • Deals: The Economic Structure of Transactions and Contracting

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