Steve Bank is the Paul Hastings Professor of Business Law at the UCLA School of Law. In this episode, he provides historical context for the rise of the key tax concepts of realization and recognition. He explains how the rise of Delaware as the place to be for corporations clashed with a young income tax to pose fundamental questions of when shareholders can be taxed.The 1970s has long been known as the time when newspapers boasted countless ads promoting tax shelters. Bank’s research shows that those ads appeared much sooner. He also discusses the surprising populist uprising that spared banks from the obligation to withhold taxes that requires employers to set aside a portion of every paycheck. He shows that banks were not the only ones fighting against that broader approach to withholding, with letters from ordinary Americans overwhelming Congressional mailrooms.This episode also features a recording by one of our students, Fernando from Guayaquil, Ecuador, of a quote that made him “open up [his] eyes and see why, from a US perspective at least, worldwide taxation makes total sense.”[Although the first episode released after the COVID-19 pandemic, it was recorded earlier. Please note that while Steve Bank was in the studio, I was participating remotely, so my audio is sometimes less than perfect.]Resources:Professor Bank’s UCLA Biography.Professor Bank’s scholarship.Daniel Shaviro’s blog post about Bank’s visit to the NYU Law Tax Policy and Public Finance Colloquium.The Pencil Question article: Miranda Stewart, “Global Trajectories of Tax Reform: The Discourse of Tax Reform in Developing and Transition Countries”, 44 Harv. Int'l L.J. 139 (2003).The Rockefeller caseThe student-read quote came from Mindy Herzfeld’s International Taxation in a Nutshell.