Alex Zhang

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The Forgotten Income-Attribution Power

Inequality has reached record levels, and the judiciary has shown increasing willingness to intervene through tax policy. This Feature excavates forgotten litigation materials to uncover the federal income-attribution power, which grants Congress broad discretion to tax A on income realized by B, paving the constitutional path for structural tax reform.

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The Origins of U.S. Territorial Taxation and the Insular Cases

This Essay examines Congress’s design of territorial revenue systems during 1898-1900. Eager to protect the federal fisc, lawmakers instituted tariffs between Puerto Rico and the mainland.  Their choices segregated the territories from the federal fiscal apparatus, prompted the Insular Cases, and created the territories’ distinct tax status as foreign countries.