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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…

Articles and Book Chapters

The Dormant Foreign Commerce Clause After Wynne, 39 VA. TAX REV. 357 (2020) (with Ruth Mason).

Steiner v. Utah: Designing a Constitutional Remedy, TAX NOTES STATE, March 9, 2020, at 845 (with Ruth Mason).

The TCJA and the Questionable Incentive to Incorporate, Part 2, TAX NOTES, March 25, 2019, at 1447.

The TCJA and the Questionable Incentive to Incorporate, TAX NOTES, March 4, 2019, at 977.

The Modigliani-Miller Theorem at 60: The Long-Overlooked Legal Applications of Finance's Foundational Theorem, 35 YALE J. REG. BULL. 1 (2018).

On the Disparate Treatment of Business and Personal SALT Payments, 158 TAX NOTES 331 (2018).

Dual Residents: A Sur-Reply to Zelinsky, STATE TAX NOTES, January 15, 2018, at 269 (with Ruth Mason).

Before International Tax Reform, We Need to Understand Why Firms Invert, 8:5 WHARTON PUBLIC POLICY INITIATIVE ISSUE BRIEF (September 2017).

Taxation, Competitiveness, and Inversions: A Response to Kleinbard, 155 TAX NOTES 619 (2017).

Is the Philadelphia Wage Tax Unconstitutional? And If It Is, What Can and Should the City Do?, 164 U. PA. L. REV. ONLINE 163 (2016) (with Ruth Mason).

The Economic Foundation of the Dormant Commerce Clause, 103 VA. L. REV. 309 (2017) (with Ruth Mason).

How the Massachusetts Supreme Judicial Court Should Interpret Wynne, 78 STATE TAX NOTES 921 (2015) (with Ruth Mason).

Comptroller v. Wynne: Internal Consistency, a National Marketplace, and Limits on State Sovereignty to Tax, 163 U. PA. L. REV. ONLINE 267 (2015) (with Ruth Mason).

Wynne: It's Not About Double Taxation, 75 STATE TAX NOTES 413 (2015).

Waiting for Perseus: A Sur-reply to Professors Graetz and Warren, 67 TAX L. REV. 375 (2014) (with Ruth Mason).

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).

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).

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

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

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

A Primer on Prejudgment Interest, 75 TEX. L. REV. 293 (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


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.


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

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