In this installment of Academic Perspectives on SALT, the authors argue that if New York’s proposed Billionaire Mark-to-Market Tax Act is enacted, it should be upheld against any constitutional challenge based on retroactivity.
Avi-Yonah, Reuven S., David Gamage, Kirk J. Stark, and Darien Shanske. "Is New Y Is New York’s Mark-t s Mark-to-Market Act Unconstitutionally Retr et Act Unconstitutionally Retroactive?" TaxNotes State 99, no. 6 (2021): 541-548.
Available for download on Saturday, February 08, 2031