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Home Faculty»Michael Knoll
Michael Knoll

Papers on SSRN

Michael Knoll

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

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.

Featured Research

More Publications

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).

In the News

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Articles
Disparate Tax Treatment of Business and Personal SALT Payments , Tax Notes (forthcoming)
Put-Call Parity and the Development of the Modern Mortgage, Working Paper (forthcoming)
Taxes and Competitiveness, Working Paper (forthcoming)
International Competitiveness, Tax Incentives, and a New Argument for Tax Sparing: Preventing Double Taxation by Crediting Implicit Taxes, Working Paper (forthcoming)
Economic and Legal Arguments in PPL v. Commissioner, Working Paper (forthcoming)
Bounded Extraterritoriality, Michigan Law Review (forthcoming)
Bibb Balancing: Regulatory Mismatches Under the Dormant Commerce Clause, George Washington Law Review (2023)
National Pork is a Bibb Case, Not a Pike Case, George Washington Law Review Arguendo (2022)
What Is Tax Discrimination?, Yale Law Journal (2021)
Steiner v. Utah: Designing a Constitutional Remedy, Tax Notes State (2020)
The Dormant Foreign Commerce Clause After Wynne, Virginia Tax Review (2020)
Why the Supreme Court Should Grant Certiorari in Steiner v. Utah, Tax Notes State (2020)
The TCJA and the Questionable Incentive to Incorporate, Part 2, Tax Notes (2019)
The TCJA and the Questionable Incentive to Incorporate, Tax Notes (2019)
Dual Residents: A Sur-Reply to Zelinsky, State Tax Notes (2018)
On the Disparate Treatment of Business and Personal SALT Payments, Tax Notes (2018)
The Modigliani-Miller Theorem at 60: The Long-Overlooked Legal Applications of Finance’s Foundational Theorem, Yale Journal on Regulation Bulletin (2018)
Before International Tax Reform, We Need to Understand Why Firms Invert, Wharton Public Policy Initiative Issue Brief (2017)
Taxation, Competitiveness, and Inversions: A Response to Kleinbard, Tax Notes (2017)
The Economic Foundation of the Dormant Commerce Clause, Virginia Law Review (2017)
New York’s Unconstitutional Tax Residence Rule, State Tax Notes (2017)
Is the Philadelphia Wage Tax Unconstitutional? And If It Is, What Can and Should the City Do?, University of Pennsylvania Law Review Online (2016)
How the Massachusetts Supreme Judicial Court Should Interpret Wynne, State Tax Notes (2015)
Comptroller v. Wynne: Internal Consistency, a National Marketplace, and Limits on State Sovereignty to Tax, University of Pennsylvania Law Review Online (2015)
Wynne: It's Not About Double Taxation, State Tax Notes (2015)
Amicus Brief in Maryland Comptroller v. Wynne, Working Paper (2014)
Waiting for Perseus: A Sur-reply to Professors Graetz and Warren, Tax Law Review (2014)
A Brief Sur-Reply to Professors Graetz and Warren, Yale Law Journal Forum (2013)
The Connection Between Competitiveness and International Taxation, Tax Law Review (2012)
Reconsidering International Tax Neutrality, Tax Law Review (2011)
The Corporate Income Tax and the Competitiveness of U.S. Industries, Tax Law Review (2010)
A Comprehensive Theory of Deal Structure: Understanding How Transactional Structure Creates Value, Texas Law Review (2010)
Taxation and the Competitiveness of Sovereign Wealth Funds: Do Taxes Encourage Sovereign Wealth Funds to Invest in the United States?, Southern California Law Review (2009)
Samuel Zell, the Chicago Tribune, and the Emergence of the S ESOP: Understanding the Tax Advantages and Disadvantages of S ESOPs, Ohio State Law Journal (2009)
The Ancient Roots of Modern Financial Innovation: The Early History of Regulatory Arbitrage, Oregon Law Review (2008)
The Taxation of Private Equity Carried Interests: Estimating the Revenue Effects of Taxing Profit Interests as Ordinary Income, William & Mary Law Review (2008)
The UBIT: Leveling an Uneven Playing Field or Tilting a Level One?, Fordham Law Review (2007)
Prejudgment Interest in International Arbitration, Transnational Dispute Management (2007)
Implicit Taxes and Economic Substance, Tax Notes (2007)
Compaq Redux: Implicit Taxes and the Question of Pre-tax Profit, Virginia Tax Review (2007)
Implicit Taxes and Pretax Profit in Compaq and IES Industries, Tax Notes (2007)
Section 83(b) Election for Restricted Stock: A Joint Tax Perspective, Southern Methodist University Law Review (2006)
The Calculation of Prejudgment Interest, Working Paper (2005)
Regulatory Arbitrage Using Put-Call Parity, Journal of Applied Corporate Finance (2005)
The Tax Efficiency of Stock-Based Compensation, Tax Notes (2004)
Taxing Sunny Days: Adjusting Taxes for Regional Living Costs and Amenities, Harvard Law Review (2003)
The Case for Replealing the Corporate Alternative Minimum Tax, Southern Methodist University Law Review (2003)
Simplifying the Transition to a (Progressive) Consumption Tax, Southern Methodist University Law Review (2003)
Put-Call Parity and the Law, Cardozo Law Review (2002)
Ethical Screening in Modern Financial Markets: The Conflicting Claims Underlying Socially Responsible Investment, Business Lawyer (2001)
Tax Planning, Effective Marginal Tax Rates and the Structure of the Income Tax, Tax Law Review (2001)
Corporate Finance, Corporate Law and Finance Theory, Southern California Law Review (2000)
Of Fruit and Trees: The Relationship Between Income and Wealth Taxes, Tax Law Review (2000)
Financial Innovation, Tax Arbitrage, and Retrospective Taxation: The Problem with Passive Government Lending, Tax Law Review (1999)
Product Liability and Legal Leverage: The Perverse Effect of Stiff Penalties, UCLA Law Review (1997)
A Primer on Prejudgment Interest, Texas Law Review (1996)
An Accretion Corporate Income Tax, Stanford Law Review (1996)
Designing a Hybrid Income-Consumption Tax, UCLA Law Review (1994)
Taxing Prometheus: How the Corporate Interest Deduction Discourages Innovation and Risk-Taking, Villanova Law Review (1993)
Perchance to Dream: The Global Economy and the American Dream, Southern California Law Review (1993)
Taxation, Negative Amortization and Affordable Mortgages, Ohio State Law Journal (1992)
A Tax-Induced Clientele for Index-Linked Bonds: A Comment, Journal of Finance (1991)
The Second Generation of Notes Indexed for Inflation, Emory Law Journal (1990)
An Economic Approach to the Determination of Injury Under United States Antidumping and Countervailing Duty Law, New York University Journal of International Law & Policy (1989)
Legal and Economic Framework for the Analysis of Injury by the U.S. International Trade Commission, Journal of World Trade (1989)
Taxes and the Absence of Bonds Indexed for Inflation from the U.S. Capital Market, George Mason Law Review (1989)
The Taxation and Marketing of Price-Level Adjusted Mortgages, Journal of Taxation of Investments (1989)
Uncertainty, Efficiency, and the Brokerage Industry, Journal of Law & Economics (1988)
The Crude Oil Windfall Profits Tax of 1980: An Economic Analysis of the Effect on Domestic Crude Oil Production, Resources and Energy (1987)
United States Antidumping Law: The Case for Reconsideration, Texas International Law Journal (1987)
Duties to Offset Competitive Advantages, Maryland Journal of International Law & Trade (1986)
Gray-Market Imports: Causes, Consequences and Responses, Law & Policy International Business (1986)
Resource Extraction and Anticipated Demand Shifts, Economic Letters (1980)
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Chapters
Business Taxes and International Competitiveness in Dimensions of Competitiveness (forthcoming)
Tax Discrimination in Research Handbook on International Taxation  (2020)
Prejudgment Interest in Litigation Services Handbook (2017)
Prejudgment Interest in Litigation Services Handbook (2012)
Prejudgment Interest in Litigation Services Handbook (2007)
A Primer on Prejudgment Interest in Litigation Services Handbook (2003)
Introduction in International Trade Law (2003)
Comment on M. Milevsky & E. Prisman, Hedging and Pricing with Tax Law Uncertainty: Managing Under an Arkansas Best Doctrine in Chicago Board of Trade Research Symposium Proceedings: Proceedings of the Annual Fall Research Seminar (1998)
Antidumping in The New Palgrave Dictionary of Economics and the Law (1998)
The Economics of ‘Injury’ in Antidumping and Countervailing Duty Cases: A Reply to Professor Sykes in Economic Dimensions of International Law (1998)
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Related Links

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Selected Publications
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