Doron Narotzki (Akron; Google Scholar) has posted 4 tax papers on SSRN:

Tax Implications of Contributing Appreciated Property Abroad, 179 Tax Notes Fed. 431 (April 17, 2023) (with Tamir Shanan (School of Administration)): 

On this article, Narotzki and Shanan study the applying of part 367 to part 351 exchanges and the revenue inclusion points that will come up upon a U.S. particular person’s contribution of property to a overseas entity. 

The Potential Federal Earnings Tax Legal responsibility of International Digital Nomads, 179 Tax Notes Fed. 65 (April 3, 2023) (with Vered Kuperberg): 

On this article, Narotzki and Kuperberg study the federal revenue tax implications for nonresident alien digital nomads working in the US and argue that this rising body of workers shouldn’t be topic to U.S. federal revenue tax.

Company Earnings Tax: We Tried the Stick, How Concerning the Carrot? (with Tamir Shanan (School of Administration)): 

Attributable to companies’ on-going give attention to tax planning and their steady efforts discovering new tax minimization methods, multinational companies are usually not paying their “justifiable share” in taxes for a very long time now, and because of this the federal company revenue tax regulation is unable to generate a lot tax revenues. The federal government’s response to this downside has at all times been the identical: introducing new tax legal guidelines and rules, revising outdated tax legal guidelines with a purpose to shut-down the so-called “loop-holes” and hoping this can put an finish to the issue of company revenue tax evasion. For many years this strategy has failed us.

This paper examines the historical past of the company revenue tax regime and the evolution of company revenue tax avoidance observe/trade, which corresponded with the company revenue tax coverage the U.S. authorities selected to undertake (anti abusive/avoidance guidelines) and sadly had minimal success over time because the tax revenues giant scale company teams is pretty modest and it appears that there’s a consensus that these entities don’t pay their justifiable share. The paper lastly proposes to alter the mindset and to undertake a brand new coverage that may encourage entrepreneurs and companies put money into the U.S. economic system by means of tax and different financial incentives.

Our proposal would advocate adopting collection of guidelines that in a approach would allocate the optimistic externality such financial exercise has over the U.S. economic system between the IRS and the companies and its shareholders.

Planning Round Extra Foundation in Company Formation Transfers, 176 Tax Notes Fed. 1209 (August 22, 2022) (with Melanie McCoskey (Akron; Google Scholar): 

On this article, McCoskey and Narotzki clarify why the premise guidelines underneath part 358 require tweaking when, in alternate for inventory, a transferor of property additionally receives an installment be aware with extra foundation.

Code Part 304: A Roadmap, An Up to date Evaluation, and Coverage Issues, 16 Va. L. & Bus. Rev. 471 (2022) (with Melanie McCoskey (Akron; Google Scholar):  

Code Part 304 requires the reclassification of inventory gross sales between affiliated companies as dividends. Nevertheless, for a few years, Code Part 304 has not fulfilled the unique “anti-avoidance” tax coverage that was behind its laws. This text goals to supply an up to date evaluation and clarification of the mechanics of Code Part 304 and to supply some perception into the tax planning methods that make the most of Code Part 304 with a purpose to decrease U.S. federal revenue tax. The article can even exhibit how these tax avoidance outcomes are nonetheless efficient post-TCJA. The article will then counsel a possible tax regulation change to return this code part to its supposed anti-abuse standing. Lastly, the article suggests reconsideration of the tax coverage associated to dividend distributions.

https://taxprof.typepad.com/taxprof_blog/2023/05/narotzki-posts-five-tax-papers-on-ssrn.html