Diane M. Ring is a Professor of Law at Boston College Law School, where she researches and writes primarily in the field of international taxation, corporate taxation, and the taxation of financial instruments. Her recent work addresses issues including cross border tax arbitrage, advance pricing agreements, and international tax relations. Ms. Ring was the U.S. National Reporter for the 2004 IFA Conference on Double Nontaxation. She was the Assistant General Reporter for the 1995 IFA Conference on Financial Instruments and was a consultant to the IFA research project on the impact of technological and financial innovation on the taxation of income and activities. Ms. Ring is also co-author of three case books in taxation – one on corporate taxation, one on international taxation, and one on ethical problems in federal tax practice.

Prior to joining the Boston College Law School, Ms. Ring was an associate professor of law at the University of Florida Levin College of Law, and an assistant professor at Harvard Law School. Before entering academia, Ms. Ring practiced at the firm of Caplin & Drysdale in Washington, D.C., specializing in the area of international tax and the taxation of financial instruments. Ms. Ring also clerked for Judge Jon O. Newman of the Second Circuit Court of Appeals.

EDUCATION

A.B., J.D., Harvard University.

RECENT ACTIVITIES

Work in Progress: 
"Democracy, Sovereignty and Tax Competition: The Role of Tax Sovereignty in Shaping Tax Cooperation."  Forthcoming in Florida Tax Review

"Understanding the Role of International Organizations in Tax Policy" 

"International Dynamics of International Tax"

Recent Presentations:

University of Florida International Tax Symposium, "Democracy Sovereignty and Tax Competition: The Role of Tax Sovereignty in Shaping Tax Cooperation."(2008).

University of Montreal Invited Conference on Tax Competition, " Tax Sovereignty as a Window onto The Possibilities and Limits of Tax Cooperation,"(August 2008).

Harvard Law School Tax Policy Seminar, presented “What’s at Stake in the Sovereignty Debate? International Tax and the Nation-State" (2008).

Law Society Meeting, Montreal, "what's at Stake in the Sovereignty Debate,"(May 2008)

International Law Association, International Law Weekend, presented “Sovereignty and International Tax Policy,” (October 2007).

Harvard Law School Seminar on Current Research Issues in Tax Policy, presented “Role of Sovereignty in International Tax (August 2007).

“Sovereignty and International Tax,” 2007 Annual Critical Tax Conference, UCLA Law School (April 2007).

Brooklyn Law School, presented “International Tax Relations: Theory and Implications” (March 2007).

University of Toronto Law School, presented, “International Tax Relations: Theory and Implications (October 2006).

“International Tax Relations: Theory and Implications,” 2006 Annual Critical Tax Conference, Mercer University School of Law, Macon, GA (April 2006).

“Inside the United States APA Program,” Peking University, China (May 2005). Presentation of draft on International Relations and International Tax to the ATPI (American Tax Policy Institute in D.C.) that sponsored the research.

Presentation at the 2004 IFA US meeting (NYC) on the Double Nontaxation Report.

Participated in Harvard Law School conference on current tax research.

Other: Met with staff of the International Taxation Department as part of a discussion of adjudication of tax matters and the role of courts in taxation, State Administration of Taxation, Beijing, China, in May.

COURSES

Fall '09: Taxation II
Spring '10: Tax I

PUBLICATIONS

• "A New View of Global Tax."  BC Law Magazine 16, no.2 (Spring/Summer 2008): 30, 52-53.
  
• "What's at Stake in the Sovereignty Debate?: International Tax and the Nation-State." Virginia Journal of International Law 49, no.1 (Fall 2008): 155-233.
  
• WithAllison Christians, Steven Dean and Adam H. Rosensweig.  "Taxation as a Global Socio-Legal Phenomenon." ILSA Journal of International and Comparative Law 14, no.2 (Spring 2008): 303-315.
  
• With Bernard Wolfman. Federal Income Taxation of Corporate Enterprise. 5th ed. New York: Foundation Press, 2008.
  
• With Jessica L. Katz and Charles T. Plambeck. U.S. Income Taxation of Foreign Corporations. Arlington, VA: Bureau of National Affairs, 2008.
  
• “United States.” In Taxation of Permanent Establishments, edited by Irene J.J. Burgers et al. Amsterdam, IBFD Publications, 1993- (Updates: December 2008)
  
• With Bernard Wolfman and Deborah H. Schenk. Ethical Problems in Federal Tax Practice. 4th ed. New York: Aspen Publishers,  2008.
  
• "International Tax Relations: Theory and Implications."  Tax Law Review  60 (2007): 83-154.
  
• “Inside the United.States APA Program.” In The Proceedings of the International Seminar on Harmonious Society & Tax Judicial Reform in China & PKU-UMICH Tax Law Forum, 555-607. Peking, China: Peking University, 2006.
  
• With Reuven S. Avi-Yonah and Yariv Brauner. U.S. International Taxation: Cases and Materials. 2nd ed. New York: Foundation Press, 2005.
  
• With Bernard Wolfman. Federal Income Taxation of Corporate Enterprise. 4th ed. New York: Foundation Press, 2005.
  
• "Why Happiness? : A Commentary on Griffith's Progressive Taxation and Happiness." Boston College Law Review 45, no.5 (2004): 1413-1424.
  
• "U.S. National Report on Double Taxation." Cahiers de Droit Fiscal International 89A (2004): 725-747.
  
• "Book Review: Solid Foundations for Tax Theory, Policy." Tax Notes International 31, no.11 (2003): 961-962.
  
• "One Nation Among Many: Policy Implications of Cross-Border Tax Arbitrage." Boston College Law Review 44, no.1 (2002): 79-176.
  
• "Prospects for a Multilateral Tax Treaty." Symposium: International Tax Policy in the New Millenium: Panel IV: The Pursuit of National Tax Policies in a Globalized Environment: Commentaries. Brooklyn Journal of International Law 26, no.4 (2001): 1699-1710.
  
• "On the Frontier of Procedural Innovation: Advance Pricing Agreements and the Struggle to Allocate Income for Cross Border Taxation." Michigan Journal of International Law 21, no.2 (2000): 143-234.
  
• "Risk-Shifting within a Multinational Corporation: The Incoherence of the U.S. Tax Regime." Boston College Law Review 38, no.4 (1997): 667-736.
  
• Commentary: "Exploring the Challenges of Electronic Commerce Taxation through the Experience of Financial Instruments." Tax Law Review 51, no.4 (1996): 663-676.
  
• With Reuven Avi-Yonah and David Newman. Taxation of Financial Instruments. Deerfield, IL: Clark Boardman Callaghan, 1996.
  
• Commentary: "Fixing Realization Accounting: Symmetry, Consistency and Correctness in the Taxation of Financial Instruments." Tax Law Review 50, no.4 (1995): 797-802.
  
• With David Rosenbloom and Charles Plambeck. "Tax Aspects of Derivative Financial Instruments." Cahiers de Droit Fiscal International 80b (1995): 653-823.
  
• With David Rosenbloom and David Sutherland. "Taxation of Permanent Establishments: United States" in Taxation of Permanent Establishments, edited by I.J.J. Burgers and R. Betten. Amsterdam: International Bureau of Fiscal Documentation, 1995.
  
• "Final Currency Regulations Alleviate Restrictions of the Temporary Regulations." Journal of International Taxation 3, no.2 (1992): 98-105.
  
• "Character, Source, and Integration Rules are Provided for Currency Transactions." Journal of International Taxation 3, no.3 (1992): 140-147.
  
• Notes: "Tax Treatment of Notional Principal Contracts." Harvard Law Review 103, no.8 (1990): 1951-1968.
  
• Case Comment: "Religious Payments as Deductible Charitable Contributions: Hernandez v. Commissioner." Harvard Law Review 103, no.1 (1989): 361-372.