Flat Tax, Consumption Tax, Consumption-Type Income Tax Proposals
in the United States: A Tax Policy Discussion of Fundamental Tax Reform,
88 Calif. L. Rev. 2095-2185 (2000).
(In Japanese) International Aspects of Proposals for Corporate Income
Tax Reform in the United States: Integration of the Corporate and Individual
Income Taxes, 6 Nomos (Japan) Kansai International and Comparative
Law J., (1996).
A Tax Experiment in the United States Federal System: Limited Liability
Companies as an Escape from the Unintegrated Corporate Income Tax,
in Lang, J. (edit.), Die Steurrechts-Ordnung in der Diskussion (Festschrift
für Klaus Tipke), Köln: Verlag Dr. Otto Schmidt, pp. 683-705
Corporate Income Tax Reform In The United States: Proposals For
Integration Of The Corporate and Individual Income Taxes, 12 International
Tax and Business Lawyer (now the Berkeley Journal of International Law)
International Aspects Of Proposals For Corporate Income Tax Reform
In The United States: Integration Of The Corporate And Individual Income
Taxes, 3 Tilburg Foreign Law Review 307-333 (1994).
(In Japanese) Proposals for Integration of the Corporate and Individual
Income Taxes in the United States, Part I in February 1, 1994 "The
Jurist", Tokyo, Japan; Part II in February 15, 1994 "The Jurist",
International Aspects of Corporate Income Tax Reform in the United
States: Integration of the Corporate and Individual Income Taxes,
December 15, 1993, Korean Chamber of Commerce and International Fiscal
Assn., Seoul, Republic of Korea.
Why Subchapter S (Partnership Tax Treatment for Closely-Held Electing
Corporations) Should Be Retained Even If Integration By Some Other Method
Is Enacted In The United States, 2 Tilburg Foreign Law Review (The
Netherlands) 377-392 (1993).
Corporate and Individual Income Tax Integration in the United States
During the 1990s, 2 Tilburg Foreign Law Review 205-228 (1993).
Preserving the Virtues of Subchapter S in an Integrated World,
47 Tax L. Rev. 1001 (1992).
Reform of the Individual Income Tax By Integration of the Corporate
Income Tax, 46 Tax Notes 1445-1454 (1990); translated and published
(in Japanese) in 63 KEIO HOGAKU-KENKU (Journal of Law, Politics and
Sociology) (No. 12), pp. 373-400, January 1991 (Tokyo, Japan); republished
in the Republic of Korea (1992).
The United States' Individual and Corporate Income Tax: Future Reform
Possibilities, 1 Bond L. Rev. (Australia) 52-78 (1989).
Struktur der Einkommensteuer und Reformtendenzen der Besteuerung
in den Vereinigten Staaten, 2/1989 Steuer und Wirtschaft (Germany)
(In Japanese) The Basic Structure and Characteristics of the U.S.
Income Tax and Future Reform Possibilities, Part I, October 1988,
The Jurist (Japan), No. 919, pp. 80-85; Part II (on the corporate tax
integration question) Nov. 1988, The Jurist, No. 921, pp. 90-94.
(In Korean) The Basic Structure, Character and Possible Reforms
of the U.S. Federal Income Tax, 1989/4 Tax Monthly (Republic of
United States Taxation of Foreign Investment in the United States:
General Principles, Recent Developments and the New "Branch Tax"
(Republic of Korea, International Fiscal Association, Seoul 1988)
27 pages; rev. 1990.
Subchapter S, Section 1244 and Closely-Held Corporations (After
the Tax Reforms of 1980-1985 1/2), pp. 181-222 of N.Y.U., Corporate
Tax Planning, 1986 Summer Institute on Federal Taxation.
Public Policy and Private Charity: A Tax Policy Perspective,
3 Virginia Tax Review 229 (1984); revised and expanded from 1979 paper
delivered at Liberty Fund Seminar on "Private Charity and Public
Policy", U. of Miami (April 20-22, 1979), 34 pgs.
Integrating the Corporate Income Tax? 31 m.J.Comparative Law
"Tax Policy and Tuition Credit Legislation", 6 Tax Notes
Verlagerung und Zurechnung von Einkommen nach Amerikanischem Einkommensteuerrecht
(Income Shifting and Attribution Under the U.S. Federal Income Tax),
3/78 Steuer und Wirtschaft (Germany) (1978) pp. 234-243.
Statement on Reform of the Federal Estate and Gift Taxes, Hearings
of House Ways and Means Comm., (March 15, 1976) 485; "A Transfer
Tax Alternative: Inclusion Under the Income Tax", Tax Notes No.
26, 1976, p. 24.
Tax Policy and Tuition Credit Legislation: Federal Income Tax Allowances
for the Personal Costs of Higher Education, 61 Calif. L. Rev. 1
Report on Taxation of Foreign, Particularly Swiss, Investments in
the United States, St. Gallen Hochschule (Switzerland, 1973) 150
Corporations and the Intertemporal Conflict of Laws, 55 Calif.
L. Rev. 21 (1967); reprinted at 10 Corporate Practice Commentator 1
Note, Bad Debt Deductions for Capital Lost Through Breach of Contract
(U.S. v. Kyle, 4th Cir.), 67 Yale L.J. 492 (1958).
Federal Income Taxation of Individuals (6th ed., West Pub. Co.,
Federal Estate and Gift Taxation (5th ed., West Pub. Co., 1994).
Subchapter S and S Corporations, Chapter 10 of O'Hara, Durst,
Griffith & Schurtz, Corporate Taxation (1992), 207 pgs.
Federal Income Taxation of S Corporations, Foundation Press,
208 pgs. (1992).
Federal Income Taxation of Business Enterprises: Cases, Statutes
and Rulings (w/ R. Westin & R. Beck, 2nd ed., Lexis Pub. Co.,
Federal Income Taxation of Business Enterprises: Cases, Statutes
and Rulings (with Westin, R. & Beck, R.C.E), Michie/Butterworth
Cases and Materials on Federal Income Taxation (Individuals,
Corporations, Partnerships) (with Kragen, retired), 4th ed., West Publishing
U.S. Taxation of Foreign Investment in United States Real Property
(and the Foreign Investment in Real Property Act of 1980): "FIRPTA"
as amended by ERTA in 1981, in ALI/ABA Course of Study Material "Advanced
Business Tax Planning," 2 vols., for use in June 13-18, 1982 Course
of Study in Boston, MA on "Advanced Business Tax Planning"
Tax Problems of the Artist and Art Group in The Visual Artist
and the Law, Sandison, H. (ed.), B.A.L.A. (1975), 6-100 through
An End of the Century Review of the Unintegrated Corporate and Individual
Income Taxes in the U.S.A. (An Essay in Honor of Professor Klaus
Vogel) (Ch. in Staaten und Steuern, (Ed. by Kirchhof, Lehner, Raupach
& Rodi), Heidelberg, C.F. Müller Verlag, pp. 873- 886 (2000).
A Student's Tribute to Fritz Kessler, 104 Yale L. J. 2133 (1995).
Dedication to Friedrich Kessler Upon His Eightieth Birthday,
August 25, 1981, 69 Calif. L. Rev. (frontispiece) (1981).
"Organization of the Corporation and Tax Benefits of Doing Business
in the Corporate Form", in Fundamental Concepts of Corporate
Taxation, PLI (1981) 41 pgs.
Commentary: "Creditability of Foreign Taxes", in Hellawell,
R. (ed.) U.S. Taxation and Developing Countries, Colum. U. Center
for Law and Economics (1980), pp. 141-152.
"Fundamental Alternatives to Present Transfer Tax Systems,"
in Death, Taxes and Family Property (West Pub. Co.) (1977).
Background Study (Consultant's Report) on California Constitution
Article XII, Corporations and Public Utilities (prepared for the
California Constitutional Revision Commission) 135 pgs. (1966); Summary
of Background Study, Article XII, 39 pgs. (1966).
Reviews and Reports
Book Review of Strickland (ed.), Hugo Black and the Supreme Court,
A Symposium, 56 Calif. L. Rev. 1178 (1968) 10 pgs.
Book Review of Leflar, The Law of Conflict of Laws, 40 Texas
L. Rev., 168 (1961).
"Estate and Gift Tax", audiotape, 9.2 hours, Pub. by Sum
& Substance (West Professional Training Prog., Inc.), 2nd ed., 1997.
Last updated: February 7, 2002