Walter Hellerstein

Distinguished Research Professor & Francis Shackelford Distinguished Professor in Taxation Law

A.B., Harvard University
J.D., University of Chicago 

Courses: 

Federal Income Taxation
State and Local Taxation
U.S. Taxation of International Transactions
State and Local Taxation Seminar

Biographical Information: 

Walter Hellerstein joined the Georgia Law faculty in 1978 and was named the Francis Shackelford Distinguished Professor in Taxation Law during 1999 and a UGA Distinguished Research Professor in 2011. He teaches in the areas of state and local taxation, international taxation and federal income taxation.

Widely regarded as the nation's leading academic authority on state and local taxation, Hellerstein has devoted most of his professional life to the study and practice of state and local taxation. He is co-author, with his late father and John Swain, of the leading treatise on state taxation, State Taxation vols. I & II 3d ed. (Thomson Reuters 2014 rev.) (with tri-annual updates), and of the leading casebook on state and local taxation, State and Local Taxation, 10th ed. (West, 2014) (with Stark, Swain & Youngman). He is also co-author with Arthur Cockfield et al. of Taxing Global Digital Commerce (Kluwer Law International, 2013). In addition, he has written numerous law review articles on state taxation that have appeared in the Cornell Law Review, the Michigan Law Review, the Minnesota Law Review, The University of Chicago Law Review, the Virginia Law Review, The Supreme Court Review, Tax Lawyer, the Journal of Taxation, the National Tax Journal, the Tax Law Review, Tax Notes, State Tax Notes and other journals. Hellerstein's work is regularly cited by the U.S. Supreme Court and by state courts throughout the nation.

Hellerstein has also practiced extensively in the state tax field. He has been involved in numerous state tax cases before the U.S. Supreme Court, having successfully argued on behalf of taxpayers in both Hunt-Wesson, Inc. v. Franchise Tax Bd., 528 U.S. 458 (2000) and Allied-Signal, Inc. v. Director, Div. of Taxation, 504 U.S. 768 (1992). He has also been deeply involved in international cross-border tax issues, particularly with regard to consumption taxes. Hellerstein is an academic adviser to the Organisation for Economic Co-operation and Development (Committee on Fiscal Affairs, Working Party No. 9) on issues involving cross-border consumption taxation, and he is a member of the Working Party's Technical Advisory Group that is developing guidelines for the taxation of cross border supplies of services and intangibles. He has consulted with the United Nations and the World Trade Organization on e-commerce issues and has lectured at the European Tax College in Leuven, Belgium, and in Tilburg, The Netherlands; the International Bureau of Fiscal Documentation in Amsterdam, The Netherlands; and the University of Lyon (III) in Lyon, France.

Before joining the Georgia Law faculty, Hellerstein was a judicial clerk for Judge Henry J. Friendly of the U.S. Court of Appeals for the 2nd Circuit, served in the Honors Program of the Air Force General Counsel's Office, practiced law at Covington & Burling in Washington, D.C., and taught at the University of Chicago Law School. He formerly was associated with Morrison & Foerster (1986-96), Sutherland, Asbill & Brennan (1996-98, 2004-08) and KPMG (1999-2004). He is a member of the American Law Institute and the District of Columbia, Illinois and New York bars.

In 2008, Hellerstein was awarded the National Tax Association's Daniel M. Holland Medal for outstanding lifetime contributions to the study and practice of public finance and was recognized by State Tax Notes as the nation's "Most Influential Academic" in state taxation. Furthermore, he received the Latcham Award for Distinguished Service in State and Local Taxation in 2007 and the Multistate Tax Commission's 25th Anniversary Award for Outstanding Contributions to Multistate Taxation in 1992.

Hellerstein earned his bachelor's degree from Harvard College, graduating magna cum laude and Phi Beta Kappa, and his law degree from the University of Chicago, where he was editor-in-chief of The University of Chicago Law Review.

Publications & Activities

ARTICLES
BOOK REVIEWS
BOOKS
CHAPTERS
PROCEEDINGS

ARTICLES

Jurisdiction to Tax in the Digital Economy: Permanent and Other Establishments, 68 Bull. Int'l Tax'n 346 (2014).

Designing the Limits of Formulary Income Attribution Regimes, 72 St. Tax Notes 45 (2014).

State Jurisdiction to Tax ‘Nowhere’ Activity, 33 Va. Tax Rev. 209 (2013) (with J. Swain).

A Unitary Business is the 'Linchpin of Apportionability' Not Nexus, 67 St. Tax Notes 865 (2013).

State Taxation of Cloud Computing: A Framework for Analysis, 117 J. Tax'n 11 (2012) (with J. Sedon).

Federal-State Tax Coordination: What Congress Should or Should Not Do, 64 St. Tax Notes 453 (2012).

The Questionable Constitutionality of Amazon's Distribution Center Deals, 62 St. Tax Notes 667 (Dec. 5, 2011) (with John A. Swain)

The Quest for Full 'Accountability' of Corporate Income, 61 St. Tax Notes 607 (Sept. 5, 2011).

Challenging Legal Issues Confronting VAT Regimes, 131 Tax Notes 409 (Apr. 25, 2011) (with Jon Sedon).

The Market State Approach to the Attribution of Receipts from Services, 59 St. Tax Notes 133 (Jan. 31, 2011) (with John A. Swain).

VAT and the Tax-Exempt Sector: Unique U.S. Issues, 129 Tax Notes 1373 (Dec. 20, 2010) (with Harley Duncan).

A Primer on State Tax Nexus: Law, Power, and Policy, 55 St. Tax Notes 555 (Feb. 22, 2010).

The VAT in the European Union, 127 Tax Notes 461 (Apr. 26, 2010) (with Timothy H. Gillis).

VAT Exemptions: Principles and Practice, 128 Tax Notes 989 (2010) (with H. Duncan).

Interjurisdictional Issues in the Design of a VAT, 63 Tax L. Rev. 359 (2010) (symposium issue, Structuring a Federal VAT: Design and Coordination Issues) (with M. Keen).

Classifying State and Local Taxes: Current Controversies, 54 St. Tax Notes 35 (Sept. 14, 2009) (with John A. Swain).

Reflections on Receipt of the Dan Holland Award, 51 St. Tax Notes 113 (Jan. 12, 2009).

Discriminatory State Taxation of Private Activity Bonds After Davis, 123 Tax Notes 447 (Mar. 25, 2009) (with Eugene W. Harper); also printed in 52 St. Tax Notes 295 (Apr 27, 2009).

Town Fair Tire and the Silliness of the Physical Presence Rule for Use Tax Collection Nexus, 50 St. Tax Notes 447 (Nov. 17, 2008).

Constitutional Restraints on Corporate Tax Integration in the EU and the US, 62 Tax L. Rev. 1 (2008) (symposium issue, European Tax Policy) (with G. Kofler and R. Mason).

Further Thoughts on the “Subject to Tax Exception” in State Corporate Income Tax Expense Disallowance Statutes, 48 St. Tax Notes 597 (May 19, 2008) (with John A. Swain).

Recent Developments in U.S. Subnational State Taxation with International Implications, 61 Bull. Int'l Tax'n 77 (2008).

MeadWestvaco and the Scope of the Unitary Business Principle, 108 J. Tax'n 261 (2008).

Is "Internal Consistency" Dead?: Reflections on an Evolving Commerce Clause Restraint on State Taxation, 61 Tax L. Rev. 1 (2007).

Cuno and Congress: An Analysis of Proposed Federal Legislation Authorizing State Economic Development Incentives, 4 Geo. J.L. & Pub. Policy 73 (2006).

Congressional Consent to State Taxation Under the Commerce Clause, 41 St. Tax Notes 629 (Sept. 4, 2006).

The Streamlined Sales Tax Project and the Local Sourcing Conundrum, 104 J. Tax'n 230 (2006) (with John A. Swain).

Green Light, Red Light, or Blue Light? New Mexico Supreme Court Sends Mixed Signals with Kmart Decision, 39 St. Tax Notes 141 (Jan. 16, 2006).

Capital Gains and Losses, Allocable and Apportionable Income, and General Electric Co. v. Iowa, 37 St. Tax Notes 865 (Sept. 19, 2005) (with Prentiss Willson, Jr.).

The Political Economy of the Streamlined Sales and Use Tax Agreement, 58 Nat'l Tax J. 605 (2005) (with John A. Swain).

Recent Amendments to the Streamlined Sales and Use Tax Agreement: Third-Party Reimbursement and Bundled Transactions, 37 St. Tax Notes 659 (Aug. 29, 2005).

Economic Development and the Dormant Commerce Clause: Lessons of Cuno v. DaimlerChrysler and Its Effect on State Taxation Affecting Interstate Commerce, 36 St. Tax Notes 715 (May 30, 2005) (testimony before the Subcomm. on the Constitution and the Subcomm. on Commercial and Administrative Law of the House Comm. on the Judiciary, 109th Cong., 1st Sess. (May 24, 2005)).

State Sales Tax Reform in the United States: The Streamlined Sales Tax Project, 59 Bull. Int'l. Fiscal Documentation 170 (2005).

International Income Allocation in the Twenty-first Century: The Case for Formulary Apportionment, 12 Int'l Transfer Pricing J. 103 (2005).

Travels with Charlie: Charles E. McLure Jr.'s Contributions to the Law of Taxation, 35 St. Tax Notes 897 (Jan. 3, 2005).

The European Commission's Report on Company Income Taxation: What the EU Can Learn From the Experience of the US States, 11 Int'l. Tax & Pub. Fin. 1 (2004) (with Charles E. McLure, Jr.).

Lost in Translation: Contextual Considerations in Evaluating the Relevance of US Experience for the European Commission's Company Tax Proposals, 58 Bull. Int'l. Fiscal Documentation 86 (March, 2004) (with Charles E. McLure, Jr.).

Congressional Intervention in State Taxation: A Normative Analysis of Three Proposals, 102 Tax Notes 1375 (Mar. 15, 2004) (also published in 31 St. Tax Notes 721 (Mar. 1, 2004) (with Charles E. McLure, Jr.).

State Personal Income Tax Issues Raised by Change of Residence, 30 St. Tax Notes 479 (Nov. 3, 2003).

State Taxation of Accumulated Trust Income: Restrains Imposed by Due Process, Commerce Clauses, 39 Wkly. St. Tax Rep. 5 (Sept. 26, 2003).

State Tax Treatment of Foreign Corporate Partners and LLC Members after Check the Box, 8 State & Loc. Tax Law. 1 (2003). 

Jurisdiction to Tax Income and Consumption in the New Economy: A Theoretical and Comparative Perspective, 38 Ga. L. Rev. 1 (2003).

Reconsidering the Constitutionality of the “Convenience of the Employer” Doctrine, 99 Tax Notes 1247 (May 26, 2003)(also published in 28 St. Tax Notes 535 (May 12, 2003)).

Federal Statutory Restraints on State Tax Nexus Generate Continuing Controversy, 97 J. Tax'n 290 (2002).

Does Sales-Only Apportionment of Corporate Income Violate International Trade Rules?, Tax Notes, Sept. 9, 2002 (simultaneously published in 27 Tax Notes Int'l 1281 (Sept. 9, 2002) and in 25 St. Tax Notes 779 (Sept. 9, 2002)) (with Charles E.McLure, Jr.).

Three-Party Multistate Sales Transactions: Drop Shipments and Similar Arrangements, 24 St. Tax Notes 621 (May 13, 2002).

The Business-Nonbusiness Income Distinction and the Case for its Abolition, 21 St. Tax Notes 725 (Sept. 3, 2001).

Role of States/Provinces in Taxation in the Canada/U.S. Context, 27 Canada-U.S. L.J. 75 (2001).

State Taxation of Electronic Commerce: What John Due Knew All Along, St. Tax Notes, January 1, 2001at 41.

Constitutional Restraints on State Interest Expense Allocation after Hunt-Wesson, 92 J. Tax'n 241 (2000).

State Taxation of Electronic Commerce: Perspectives on Proposals for Change and Their Constitutionality. (Electronic Commerce Taxation Symposium), 2000 BYU L. Rev. 9 (2000) (with Kendall L. Houghton).

The Treatment of Warranties and Associated Repair Work Under State Sales and Use Taxes, St. Tax Notes, June 19, 2000 at 2095.

Deconstructing the Debate Over State Taxation of Electronic Commerce, 13 Harv. J.L. & Tech. 549 (2000).

Federal Constitutional Limitations on Congressional Power to Legislate Regarding State Taxation of Electronic Commerce, 52 Nat'l Tax J. 87 (2000).

The Law of Sales Taxes in a Cyberspace Economy. 84 Tax Notes 475 (1999).

Internet Tax Freedom Act Limits States' Power to Tax Internet Access and Electronic Commerce. 90 J. Tax'n 5 (1999).

State and Local Taxation of Electronic Commerce: Reflections on the Emerging Issues, 52 U. Miami L. Rev. 691 (1998).

State Taxation of Electronic Commerce, 52 Tax L. Rev. 425 (1997).

Commerce Clause Restraints on State Tax Incentives, 82 Minn. L. Rev. 413 (1997).

Transaction Taxes and Electronic Commerce: Designing State Taxes that Work in an Interstate Environment.(The Post-Election Agenda: Implementation or Confrontation?), 50 Nat'l Tax J. 593 (1997).

Suspect Linkage: the Interplay of State Taxing and Spending Measures in the Application of Constitutional Antidiscrimination Rules, 95 Mich. L. Rev. 2167 (1997) (with Dan T. Coenen).

Taxing Electronic Commerce: Preliminary Thoughts on Model Uniform Legislation. 75 Tax Notes 819 (1997).

State Taxation of Telecommunications and Electronic Commerce: Overview and Appraisal, St. Tax Notes, Feb. 17, 1997, at 519.

Commerce Clause Restraints on State Business Development Incentives, 81 Cornell L. Rev. 789 (1996) (with Dan T. Coenen).

Supreme Court Preview - 1996-97 Term, St. Tax Notes, Sept. 6, 1996, at 839.

Commerce Clause Restraints on State Tax Incentives, The Region (Federal Reserve Bank of Minneapolis), Vol. 10, No. 2, 1996.

On the Proposed Single-Factor Formula in Michigan, St. Tax Notes, October 2, 1995.

Commerce Clause Restraints on State Taxation After Jefferson Lines, 51 Tax L. Rev. 47 (1995) (with Michael J. McIntyre and Richard D. Pomp).

State Taxation of Corporate Income from Intangibles, Tax Management Multistate Portfolios, 1190 T.M. (1995).

Implications of the Uruguay Round Multilateral Trade Agreements for American Subnational Taxation of International Commerce, 49 Bull. Int'l Fiscal Documentation 3 (1995).

West Lynn Creamery and the Constitutionality of State Tax Incentives, 65 Tax Notes 619 (1994).

State and Local Taxation of Intangibles Generates Increasing Controversy, 80 J. Tax'n 296 (1994).

Federal Constitutional Limitations on State Taxation, Tax Management Multistate Tax Portfolio, 1400 T.M. (1994)

State Taxation of Corporate Income from Intangibles: Allied Signal and Beyond, 48 Tax L. Rev. 739 (1993).

Supreme Court Says No State Use Tax Imposed on Mail-order Sellers ... for now, 77 J. Tax'n 120 (1992).

State Taxation of Nonresidents' Pension Income, 56 Tax Notes 221 (1992) (with James C. Smith).

Supreme Court Settles Some State Tax Issues While Creating Other Problems, 75 J. Tax'n 180 (1991).

The Constitutional Dimension of the "Business/Nonbusiness" Income Distinction, St. Tax Notes, Dec. 2, 1991, p. 477.

State Taxation and the Supreme Court, 1990-91 Term, St. Tax Notes, Sept. 9, 1991, at 41.

Justice Scalia and the Commerce Clause: Reflections of a State Tax Lawyer, 12 Cardozo L. Rev. 1763 (1991).

The Finnigan Case: A Reply to Vogelenzang's 'Second Stage Apportionment of Unitary Income,' 51 Tax Notes 891 (1991) (with the late Jerome R. Hellerstein).

Preliminary Reflections on McKesson and American Trucking Associations, 48 Tax Notes 325 (1990).

Are Days of World-Wide Unitary Taxation by States Limited? 72 J. Tax'n 172 (1990) (with Peters).

Equal Protection Run Amok?: An Analysis of the Nebraska Supreme Court's Decision in the Northern Natural Gas Case, 45 Tax Notes 995 (1989).

Recent Supreme Court Decisions Have Far-Reaching Implications, 70 J. Tax'n 306 (1989).

State Taxation of Federally Deferred Income: The Interstate Dimension, 44 Tax L. Rev. 349 (1989) (with James C. Smith).

State Taxation and the Supreme Court, 1989 Sup. Ct. Rev. 223 (1989).

Is "Internal Consistency" Foolish? Reflections on an Emerging Commerce Clause Restraint on State Taxation, 87 Mich. L. Rev. 138 (1988).

Commerce Clause Restraints on State Taxation: Purposeful Economic Protectionism and Beyond, 30 Corp. Prac. Commentator 349 (1988).

Utility Gross Receipts Taxes and Interexchange Telecommunications Carriers, 40 Tax Notes 529 (1988) (with Levine).

Florida's Sales Tax on Services, 41 Nat'l Tax J. 1 (1988).

State Taxation of Interstate Business: Perspectives on Two Centuries of Constitutional Adjudication, 41 Tax Law. 37 (1987).

Tax Notes Does Disservice to Florida's Services Tax (letter to the editor), 36 Tax Notes 641 (1987).

A Primer on Florida's Sales Tax on Services, 35 Tax Notes 1219 (1987).

Extending the Sales Tax to Services: Notes from Florida, 34 Tax Notes 823 (1987).

Commerce Clause Restraints on State Taxation: Purposeful Economic Protectionism and Beyond, 85 Mich. L. Rev. 758 (1987).

Selected Issues in State Business Taxation, 39 Vand. L. Rev. 1033 (1986).

Complementary Taxes as a Defense to Unconstitutional State Tax Discrimination, 39 Tax Law. 405 (1986).

Recent Judicial Developments in State Income Taxation of the Oil and Gas Industry, 34 Oil & Gas Tax Q. 533 (1986).

Legal Perspectives on the Interstate Incidence and Shifting of State and Local Taxes, 10 Int'l Regional Sci. Rev. 67 (1986).

Discrimination in the State Tax Arena, 4 NYU Inst. On St. & Local Tax. 13-1 (1986).

Supreme Court in Metropolitan Life Strikes Down Discriminatory State Insurance Tax, 63 J. Tax'n 108 (1985) (with Leegstra).

Political Perspectives on State and Local Taxation of Natural Resources, 19 Ga. L. Rev. 31 (1984).

Federal Constitutional and Statutory Constraints on State Taxation of Natural Resources, 1 NYU Inst. On St. & Local Tax. 245 (1983).

State Income Taxation of Multijurisdictional Corporations and the Supreme Court, 35 Nat'l Tax J. 401 (1982).

State Income Taxation of Multijurisdictional Corporations, part II: Reflections on ASARCO and Woolworth, 81 Mich. L. Rev. 157 (1982).

Reflections on Commonwealth Edison Co. v. Montana, 43 Mont. L. Rev. 165 (1982) (with Mike McGrath).

Constitutional Limitations on State Exportation, 1982 Am. B. Found. Res. J. 1 (1982).

Supreme Court Bars Louisiana's First Use Tax: Upholds Calif.'s Retaliatory Insurance Tax, 55 J. Tax'n 109 (1981).

State Taxation in the Federal System: Perspectives on Louisiana's First Use Tax on Natural Gas, 55 Tul. L. Rev. 601 (1981).

State Income Taxation of Multijurisdictional Corporations: Reflections on Mobil, Exxon, and H.R. 5076, 79 Mich. L. Rev. 113 (1980).

The Governmental-Proprietary Distinction in Constitutional Law, 66 Va. L. Rev. 1073 (1980) (with Michael Wells).

Hughes v. Oklahoma: The Court, the Commerce Clause, and State Control of Natural Resources, 1979 Sup. Ct. Rev. 51 (1980).

State's Power to Tax Foreign Commerce Dominates Supreme Court's 1978 Agenda, 51 J. Tax'n 106 (1979).

Construing the Uniform Division of Income for Tax Purposes Act: Reflections on the Illinois Supreme Courts Reading of the "Throwback" Rule, 45 U. Chi. L. Rev. 768 (1978).

Constitutional Constraints on State Taxation of Energy Resources, 31 Nat'l Tax J. 245 (1978).

State Taxation and the Supreme Court: Toward a More Unified Approach to Constitutional Adjudication?, 75 Mich. L. Rev. 1426 (1977).

Michelin Tire Corp. v. Wages: Enhanced State Power to Tax Imports, 1976 Sup. Ct. Rev. 99 (1977).

State Taxation of Interstate Business and the Supreme Court, 1974 Term: Standard Pressed Steel (Standard Pressed Steel Co. v. Department of Revenue of Wash. 95 Sup. Ct. 706) and Colonial Pipeline (Colonial Pipeline Co. v. Traigle, 95 Sup. Ct. 1538), 62 Va. L. Rev. 149 (1976).

Some Reflections on the State Taxation of a Nonresident's Personal Income, 72 Mich. L. Rev. 1309 (1974).

"Body-Snatching" Reconsidered: The Exhumation of Some Early American Legal History, 39 Brook. L. Rev. 350 (1972).

BOOK REVIEWS

Federalism in Taxation: The Case for Greater Uniformity, 47 Nat'l Tax J. 225 (1994).

Sales and Use Tax Desk Book, 1992-93 3d., 45 Tax Exec. 284 (1993).

Constitutional Uniformity and Equality in State Taxation, 5 Prop. Tax J. 52 (1986).

BOOKS

State and Local Taxation: Cases and Materials, 10th ed. (Thomson Reuters, 2014) (with K. Stark, J. Swain, and J. Youngman).

State Taxation vols. I & II 3d ed. (Thomson Reuters 2014 rev.) (with tri-annual updates)

Taxing Global Electronic Commerce: A Study in Tax Law and Technology Change (Kluwer Law International, 2013) (with A. Cockfield et al.)

State Taxation, 3d ed. (Warren, Gorham & Lamont 2013 rev.) (updated three times per year) (with J. Swain)

State and Local Taxation: Cases and Materials, 9th ed. (Thomson Reuters, 2009) (with Kirk Stark, John Swain, and Joan Youngman).

State Taxation, 3d ed. (Warren, Gorham & Lamont, 1998) (cumulative supplements, 2008-1, 2008-2, 2008-3, 2009-1) (with John Swain).

Streamlined Sales and Use Tax, 2008/09 ed. (Thomson Reuters, 2008) (with John Swain).

Streamlined Sales and Use Tax, 2006/07 ed. (Warren Gorham & Lamont, 2006) (with John Swain).

State and Local Taxation: Cases and Materials,  8th ed. (Thomson/West Publishing Co., 2005) (with the late Jerome Hellerstein and Joan Youngman).

Streamlined Sales and Use Tax, 2d ed. (Warren Gorham & Lamont, 2005) (with John Swain).

Electronic Commerce and Multijurisdictional Taxation. (Kluwer Law International, 2001) (with L. Doernberg).

State Taxation, 3d ed. (Warren, Gorham & Lamont, 1998) (with J. Hellerstein) (supplemented tri-annually).

State and Local Taxation of Natural Resources in the Federal System: Legal, Economic, and Political Perspectives. (American Bar Association, Section of Taxation, 1986).

Financial Reporting by State and Local Government Units. (Center for Management of Public and Nonprofit Enterprise, University of Chicago, 1977) (with Sidney Davidson, et al.).

CHAPTERS

“Designing the Limits of Formula Income Attribution Regimes” in U.S. State Tax Considerations for International Tax Reform (Tax Analysts, 2014).

"Commentary on CFC Rules within the CCCTB" in Corporate Income Taxation in Europe: The Common Consolidated Corporate Tax Base (CCCTB) and Third Countries (Edward Elgar Publishing, 2013).

"Reflections of a Third-Country Observer on the Proposed CCCTB CFC Rules" in CCCTB and Third Countries (M. Lang et al. eds.) (Kluwer Law International, 2013).

"Formulary Apportionment in the EU and the US: A Comparative Perspective on the Sharing Mechanism of the Proposed Common Consolidated Corporate Tax Base" in Tax Mobility (A. Dourado ed.) (International Bureau of Fiscal documentation, 2013).

"Comparing the Treatment of Charities Under Value Added Taxes and Retail Sales Taxes” in VAT Exemptions: Consequences and Design Alternatives (R. de la Feria ed.)(Kluwer Law International, 2013).

“Tax Coordination Between the US States – The Role of the Courts,” in Horizontal Tax Coordination (M. Lang et al. eds.) (IBFD 2013).

"Tax Planning under the CCCTB’s Formulary Apportionment Provisions: The Good, the Bad and the Ugly,” CCCTB: Selected Issues (D. Weber ed.) (Kluwer Law International, 2012).

“Tax Aspects of Fiscal Federalism in the United States” in Tax Aspects of Fiscal Federalism (C. Sacchetto and G. Bizioli eds.) (International Bureau of Fiscal Documentation, 2011).

“Tax Planning Under the CCCTB’s Formulary Apportionment Provisions: The Good, the Bad, and the Ugly” in Common Consolidated Corporate Tax Base (D. Weber ed.) (Kluwer Law International, 2011).

"Consumption Taxation of Cross-Border Trade in Services in an Age of Globalization" in Globalization and the Impact of Tax on International Investments, A. Cockfield, ed. (U. Toronto Press, 2010).

"Jurisdiction to Impose and Enforce Income and Consumption Taxes: Towards a Uniform Conception of Tax Nexus" in Value Added Tax and Direct Taxation -- Similarities and Differences M. Lang & P. Melz, eds. (International Bureau of Fiscal Documentation, 2009).

"Lessons of US Subnational Experience for EU CCCTB Initiative" in A Common Consolidated Corporate Tax Base for Europe, W. Schon, U. Schreiber, and C. Spengel, eds. (Springer, 2008).

"Federal Constitutional Restraints on Tax Competition Among the American States" in Liber Amicorum for Jacques Malherbe (Éditions Juridiques Bruylant, 2006).

"The U.S. Supreme Court's State Tax Jurisprudence: A Template for Comparison" in Comparative Fiscal Federalism: Comparing the European Court of Justice and the U.S. Supreme Court's Tax Jurisprudence, M. Avi-Yonah, ed. (Kluwer, 2007).

"Subnational State Tax Incentives in the United States: Constitutional Restraints and Congressional Oversight" in Direito Tributário Internacional Aplicado, H. Torres, ed. (Editora Quartier Latin, 2005).

"State Aid Control in the American Federal System" in European Competition Law Annual: Selected Issues in the Field of State Aids,. C. Ehlermann and M. Everson, eds. (Hart, 2001).

"Electronic Commerce and the Future of State Taxation" in The Future of State Taxation. (Urban Institute Press 1998).

"Taxation of Telecommunications" in Telecommunications: Law, Regulation, and Policy. (Ablex Pub. Corp., 1998).

"U.S. Supreme Court: Review and Preview" in Proceedings of the New York University Institute On State and Local Taxation. (Matthew Bender, 1998).

"Taxation of Telecommunications" in Telecommunications: Law, Regulation, and Policy. (Ablex Pub. Corp., 1998).

"Sales Taxation of Services: An Overview of the Critical Issues" in Sales Taxation: Critical Issues in Policy and Administration. (Praeger, 1992).

"Critical Issues in State Taxation of Telecommunications" in State Taxation of Business: Issues and Policy Options. (Praeger, 1992).

"Constitutional Limitations on State Taxation of Interstate Branching" in American Bankers Association, Facts, and Issues Concerning State Taxation of Commercial Banks. (1991).

"State and Local Property and Production Taxation of Minerals" in American Law of Mining, 2d ed. (Matthew Bender, 1988) (revision of chapters 190-194 in 2005 & 2006).

"Dividing the State Corporate Income Tax Base: Developments in the Supreme Court and Congress" in The State Corporation Income Tax: Issues in Worldwide Unitary Combination. (Hoover Press, 1984).

"Legal Constraints on State Taxation of Natural Resources" in Fiscal Federalism and the Taxation of Natural Resources. (Lexington Books, 1983).

"Federal Limitations on State Taxation of Interstate Commerce" in Courts and Free Markets: Perspectives from the United States and Europe. (Oxford University Press, 1982).

PROCEEDINGS

Brief for Amici Curiae Rosanne Altshuler, et al., PPL Corp. and Subsidiaries v. Commissioner of Internal Revenue  (No 12-43) (August 2012).

Testimony on Tax Reform: What It Means for State and Local Tax and Fiscal Policy, Before the Committee on Finance, 112th Cong., 2nd Session ___ (April 25, 2012)

Reflections on Receipt of the Dan Holland Award, 2008 Proceedings of the National Tax Association, 51 St. Tax Notes 113 (Jan. 12, 2009).

Testimony on H.R. 1054, the "Internet Tax Freedom Act". Before the Subcommittee on Commercial and Administrative Law of the House Committee on the Judiciary, 105th Cong., 1st Session __ (1997).

State and Local Taxation of the Information Highway, Proceedings of the 87th Annual Conference of the National Tax Association 221(1995) (with Steele).

Testimony on State Tax Implications of Full Interstate Branching. Before the Subcommittee on Economic Stablization of the House Committee on Banking. 102nd Cong., 1st Sess. 37 (1991).

Testimony on H.R. 1242, H.R. 1891, and H.R. 3521, the Interstate Sales Tax Collection Act of 1987 and the Equity in Interstate Competition Act of 1987. Before the Subcommittee on Monopolies and Commercial Law of the House Committee on the Judiciary. 100th Cong., 2nd Sess. 344 (1988).

Current Legal Issues in State Taxation of Telecommunications: A Preliminary Inquiry. 1986 Proceedings of the National Tax Association - Tax Institute of America 69 (1987).

Testimony on S. 463, The Severance Tax equity Act of 1982, in State Severance Taxes. Before the Subcommittee on Energy and Agricultural Taxation of the Senate Committee on Finance. 98th Cong., 2nd Sess. 119 (1984).

Testimony on the Commerce Clause and State Severance Taxes, in Fiscal Disparities, Part II: the Commerce Clause and the Severance Tax. Before the Subcommittee on Intergovernmental Relations of the Senate Committee on Government Affairs, 97th Cong., 1st Sess. 19 (1982).

Sales and Use Taxation of Movable Property in Interstate Commerce. 1981 Proceedings of the National Tax Association - Tax Institute of America 69 (1982) (with Kaufman).