Distinguished Research Professor & Francis Shackelford Distinguished Professor in Taxation Law Emeritus
hellerstein pic
(706) 542-5556

University of Georgia
School of Law
303 Rusk Hall
Athens, GA 30602
United States

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


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

Biographical Information

Walter Hellerstein joined the University of Georgia School of 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 taught in the areas of state and local taxation, international taxation and federal income taxation until he retired from teaching at the School of Law in 2015. He is currently a Visiting Professor at the Vienna University of Economics and Business, and he remains actively involved in his scholarship, consulting and, in particular, his work as an academic advisor to the Organisation for Economic Cooperation and Development (OECD).

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 Andrew Appleby, of the leading treatise on state taxation, State Taxation vols. I & II, 3d ed. (Thomson Reuters 2024 rev.), and of the leading casebook on state and local taxation, State and Local Taxation, 11th ed. (West Academic, 2020) (with Stark, Swain & Youngman). He is also co-author, with Arthur Cockfield et al., of Taxing Global Digital Commerce, 2d ed. (Kluwer Law International, 2020). 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, the Florida Tax Review, the Virginia Tax 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 OECD (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, which provides guidance in the development and implementation of OECD's VAT/GST 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, Netherlands; the International Bureau of Fiscal Documentation in Amsterdam, Netherlands; the University of Lyon (III) in Lyon, France; and the WU Vienna University of Economics and Business, in Vienna, Austria.

Before joining the School of 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



The Internet Tax Freedom Act at 25, 107 Tax Notes St. 7 (2023) (with A. Appleby). 

Are State and Local Taxes Constitutionally Distinguishable? (Revised), 103 Tax Notes St. 743 (2022). 

Platforms: The Postscript, 100 Tax Notes St. 1365 (2021) (with A. Appleby). 

John Due's Wisdom Only Ripens With Age, 99 Tax Notes St. 1159 (2021). 

State Tax Credit Issues Raised by SALT Cap Workaround Legislation, 99 Tax Notes St. 211 (2021). 

State Estate Taxes and the Due Process Clause, 98 Tax Notes St. 771 (2020) (with A. Appleby).

U.S. State Tax Experience with Employees Working Remotely, 99 Tax Notes Int'l 1757 (2020) (part of the Global Roundtable Series "Displaced Employees and COVID-19: The New Tax Obligations").

Distortion of Income in a Single-Factor Sales Formula World, 96 Tax Notes St. 729 (2020).

Reviewing Wayfair's Impact, Int'l Tax Rev. 53 (2020).

Platforms: The Finale, 95 Tax Notes St. 11 (2020) (with J.A. Swain & J.E. Maddison).

Reflections on the Cross-Border Tax Challenges of the Digital Economy, 96 Tax Notes Int'l 671 (2019) (also published in 94 Tax Notes St. 615 (2019)).

Taxes Falling Disproportionately on Nonresidents: Reflections on Saban, 93 St. Tax Notes 15 (2019).

How Not to Read International Harvester: A Response, 92 St. Tax Notes 665 (2019).

The Transformation of the State Corporate Income Tax into a Market-Based Levy, 130 J. Tax'n 4 (2019).

Digital Taxation Lessons From Wayfair and the U.S. States' Responses, 94 Tax Notes Int'l 241 (2019) (with J. Owens and C. Dimitropoulou) (published simultaneously in 92 St. Tax Notes 219 (2019)).

Substantive and Enforcement Jurisdiction in a Post-Wayfair World, 90 St. Tax Notes 283 (2018) (with A. Appleby).

State Corporate Income Tax Consequences of Federal Tax Reform, 88 St. Tax Notes 187 (2018) (with J. Sedon).

Platforms, 86 St. Tax Notes 1165 (2017) (with J. Swain & J. Maddison).

Is Use of Tax Proceeds Relevant to Whether a Tax Discriminates?, 85 St. Tax Notes 561 (2017).

Are State and Local Taxes Constitutionally Distinguishable?, 83 St. Tax Notes 1091 (2017).

Foreign Corporations Do Enjoy the Protection of Public Law 86-272, 183 St. Tax Notes 219 (2017).

The OECD's International VAT/GST Guidelines, 83 St. Tax Notes 119 (2017).

An Introduction to the OECD's International VAT/GST Guidelines, 125 J. Tax'n 256 (2016).

25 Years with State Tax Notes: A Bibliographic Perspective, 81 St. Tax Notes 755 (2016).

Florida's Not So Bizarre Tax on Florists' Sales: A Reply to Brunori, 81 St. Tax Notes 189 (2016).

Taxing Remote Sales in the Digital Age: A Global Perspective, 65 Am. U. L. Rev. 1195 (2016).

Substance and Form in Jurisdictional Analysis: Corrigan v. Testa, 80 St. Tax Notes 849 (2016).

A Hitchhiker's Guide to the OECD's International VAT/GST Guidelines, 18 Fla. Tax. Rev. 589 (2016).

Deciphering the Supreme Court's Opinion in Wynne, 123 J. Tax'n 4 (2015).

Facial State Tax Discrimination Allegedly Causing No Harm, 75 St. Tax Notes 749 (2015) (with J. Swain).

State Conformity to Federal Income Taxation of Foreign Corporations, 76 Tax Notes Int'l 435 (2014) (with J. Friedman and J. Libin).

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).


European Value Added Tax in the Digital Era: A Critical Analysis and Proposals for Reform, 27 Int'l VAT Monitor No. 2 (2016).

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).


State Taxation vols. I & II 3d ed. (Thomson Reuters 2023) (with tri-annual updates). 

State and Local Taxation, Cases and Materials, 11th ed. (West Academic, 2019) (with K. Stark, J. Swain & J. Youngman).

Taxing Global Digital Commerce, 2d. ed. (Wolters Kluwer, 2019) (with A. Cockfield et al.).

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

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

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

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.).


“Joint and Several Liability for Collection of Tax On Supplies Over Platforms,” in CJEURecent Developments in Value Added Tax 2021, p. 155 (Linde 2023) (G. Kofler, et al., eds). 

"The Application of Formulary Apportionment to Related Entities: Lessons from the US Experience" in The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option (Wolters Kluwer, 2020) (R. Krever and F. Vaillancourt, eds.).

"US Experience and Recent Developments in the Collection of Tax on Online Sales" in CJEU: Recent Developments in Value Added Tax 2018 (M. Lang, et al., eds.) (Linde 2019).

"Simplified registration and collection mechanisms for taxpayers that are not located in the jurisdiction of taxation: A review and assessment" in Organisation for Economic Co-operation and Development Taxation Working Papers (Organisation for Economic Co-operation and Development Publishing, Paris, 2018) (with S. Buydens and D. Koulouri).

"Dispute Resolution and Dispute Prevention under EU VAT: A Global Perspective" in CJEU: Recent Developments in Value Added Tax 2016 (M. Lang, et al., eds.) (Linde, 2017).

"Consumption Taxation of Remote Supplies in the Global Digital Economy" in Neuva fiscalidad (New Taxation), Estudios en homenaje a Jacques Malherbe (Studies in Honor of Jacques Malherbe), (Catalina Jimenez, et al., eds., ICDT, 2017).

"The U.S. Supreme Court's State Tax Jurisprudence: A Template for Comparison" in Comparative Fiscal Federalism (R. Avi-Yonah and M. Lang, eds.) (Kluwer Law Int'l, 2nd ed. 2016).

"Specialized Courts in Multijursidictional Systems: An American Perspective" in Recent Developments in Value Added Taxes (M. Lang, et al. eds.) (2016).

"Consumption Taxation of Cloud Computing: Lessons from the US Subnational Retail Sales Tax Experience" in Value Added Tax and the Digital Economy: The 2015 EU Rules and Broader Issues (Lamensch et al. eds.) (Kluwer Law International, 2015).

"Exploring the Potential Linkages Between Income Taxes and VAT in a Digital Global Economy" in VAT/GST in a Global Digital Economy (M. Lang and I. Lejeune, eds.) (Kluwer Law International, 2015).

"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 (?ditions 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 Tribut?rio 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).

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