Wealth Taxes are Direct Taxes that are Subject to the Rule of Apportionment
David Schizer, the former Dean of the Columbia University School of Law, and I have just today posted a manuscript on SSRN at:
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4867878
It will be published in the Florida Law Review (2025).
We argue that the Direct Taxes Clause applies to taxes that fall straight upon a person, while imposts, duties and excises all fall only upon such transactions as: importing goods, buying or selling goods, inheriting an estate or giving a gift, renting someone’s property, or selling one’s labor to someone els
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