Professor Ferdinand P. Schoettle is a nationally recognized scholar of federal and state tax law and policy. He teaches courses in state and local taxation, federal taxation, law and public policy (including tax policy), and economics for lawyers.
Professor Schoettle received his A.B. degree from Princeton University. He received his LL.B. degree with high honors and his M.A. and Ph.D. degrees in economics from Harvard University. During law school, he was an Editor of the Harvard Law Review. After graduating from law school, Professor Schoettle clerked for Judge Learned Hand of the United States Court of Appeals for the Second Circuit. He then worked for the United States Treasury Department in the Office of Tax Legislation Counsel and for Senator Joseph Clark. From 1963 to 1966, Professor Schoettle practiced law at Morgan, Lewis & Bockius in Philadelphia.
He joined the University of Minnesota Law School faculty in 1967. He has been a Guest Scholar at the Brookings Institution, Visiting Professor at Uppsala University in Sweden and a visiting scholar at Harvard Law School. Professor Schoettle is a member of the Tax Economists Forum, the American Law Institute, and the National Economics Club. He has been Chairman of the American Bar Association Taxes and Revenue Committee, consultant to the United States Comptroller General on state income taxation of multijurisdictional corporations, and Special Counsel to the United States Senate Select Committee on Equal Educational Opportunity, and Special Counsel to the Subcommittee on Intergovernmental Relations.
Consultant, United States Senate, Finance Committee 1973
Counsel, United States Senate, Subcommittee on Intergovernmental Relations 1972
Special Counsel, United States Senate, Select Committee on Equal Educational Opportunity 1970-71
Co-Campaign Manager, Genevieve Blatt for U. S. Senate, Democratic Primary Election, Pennsylvania 1964
Assistant to Senator Joseph S. Clark 1962-64
Office of Tax Legislative Counsel, United States Treasury Department 1961-62
Consulting Positions (Public)
Listed Consultant, United Nations Development Program; World Bank; International Monetary Fund 1992-
Consultant to the Comptroller General of the United States on state income taxation of multijurisdictional corporations 1981-82
Consulting Positions (Private)
Testimony as an economist in over a dozen state tax cases in more than eight states
Economic and legal consulting services to various clients largely in tax related matters
Awards and Recognitions
Who's Who in America Biographee
Bush Leadership Fellowship 1972-73
Americans for Democratic Action Southeastern Pennsylvania Chapter, Citation for Public Service and Political Courage 1965
United States Olympic Yachting Teams 1956 (Melbourne), 1960 (Rome/Naples).
Books and Monographs
State and Local Taxation: The Law and Policy of Multi-Jurisdictional Taxation (LexisNexis 2003)
Tax Policy Notes (1993 & Supps. 2-7 1993-1994)
"A New General Equilibrium Three-Sector Model for Tax Incidence Analysis: The Influence of Property and Income Taxes Upon Homeowners", Demand for Housing Services ((1983) and Oldman and Schoettle, State and Local Taxes and Finance (Foundation Press 1974).
Articles and Book Chapters
"Does the Tax Injunction Act Allow a Federal Court to Enjoin the Granting of a State Income Tax Credit", Preview (2004)
"Can Iowa Tax Racetrack Slot Machine Revenue at a Different Rate Than Casino Slot Machine Revenue?", Preview (2003)
"When Does the Full Faith and Credit Clause Require Nevada Courts to Apply California Immunity Law?", 5 Preview 301 (February 21, 2003)
"What Public Finance Do State Constitutions Allow?", R.D. Bingham, E.W. Hill & S.B. White (eds.), Financing Economic Development in the 21st Century (M.E. Sharpe, Inc. February, 2003)
"What Public Finance Measures Do State Constitutions Allow?", State Tax Notes, May 13, 2002
"Big Bucks, Cloudy Thinking Constitutional Challenges to State Income Taxes on the Multinationals: Dividends, Interest and Capital Gains -- Illumination From The GATT", 19 Virginia Tax L.Rev. 277 (September/October 1999)
"Can California Reduce the Interest Deduction of Nondomiciliary Corporate Income Tax Taxpayers Because of Dividends Received?", 4 Preview 202 (December 20, 1999)
"May Arizona Levy a Gross Receipts Tax on the Amounts Received by an Indian-owned Contractor from a Contract with the Bureau of Indian Affairs to Build Roads on Indian Reservations?", ABA Preview 160 November 1998
"Discriminatory Taxation: May a State Permit Only In-State Residents to Deduct Alimony Payments in Calculating State Income Tax Liability?", Christopher H. Lunding and Barbara J. Lunding v. Tax Appeals Tribunal of the State of New York, Commissioner of Taxation and Finance of the State of New York, 1997-98 Preview 120 October 20, 1997
"Taxing Nonresidents -- The Puzzling Failure of Economics", Christopher H. Lunding v. State of New York, State Tax Notes, November 3, 1997
"Should Federal Courts or Arkansas State Courts Decide If Arkansas Can Tax Farm Production Credit Associations?", Arkansas v. Farm Credit Services of Central Arkansas, PCA et al, 1996-97 Preview 460 April 3, 1997
"Charity Begins at Home: Can a State Limit Its Property Tax Exemption to Charities That Provide Most of Their Services to State Residents?", Camps Newfound/Owatonna, Inc. v. Town of Harrison, Maine, 1996-97 Preview 47 September 19, 1996
"May a State Constitutionally Grant Purchasers of Gas from Public Utilities a Special Exemption from an Otherwise Applicable Sales and Use Tax?", 9-17-96 WLN 9740, 1996 WL 52184 (1996)
"May the United States Constitutionally Tax Insurance Premiums for Policies Issued by Foreign Insurers on Exported Goods?", United States v. International Business Machines Corporation, 1995-96 Preview 272 March 7, 1996
"Court to Consider Commerce Clause Limits on State Efforts to Compensate Shareholders for State Taxes Paid to Domestic Corporations", 1-24-96 WLN (1996)
"The Earned Income Credit -- Integrating Tax & Welfare Provisions", Tax Policy Note No. 7 (July 1994)
"Distributional Effects of Taxes -- A Guide for the Uninitiated", Tax Policy Note No. 6 (June 1994)
Expert Testimony and Tax Accounting Systems That Meet the Fair Representation Standard of Section 18", Program Materials, Georgetown University, 1994 Institute on State & Local Taxation, Washington, D.C. (May 1994)
"State Jurisdiction to Tax -- Should The Federal Government Intervene?", Tax Policy Note No. 5 (April 1994)
"Tax Systems for the Developing Countries -- The Basic World Tax Code", Tax Policy Note No. 4 (March 1994)
"Tax Policy Note on International Taxation -- Are Foreign-Owned Multinationals Paying Their Fair Share of Taxes?", Tax Policy Note No 2 (December 1993)
"When Is a Tax a Tariff?", Program Materials, Georgetown University, 1993 Institute on State & Local Taxation, Washington, D.C. (May 1993)
"Thomas DeLong of Price Waterhouse Wins 'You Be The Judge' Contest", State Tax Notes May 25, 1993
Is New Hampshire discriminating against the out-of-state owners of the Seabrook nuclear power plant?", State of Connecticut, Commonwealth of Massachusetts, State of Rhode Island and Providence Plantations v. State of New Hampshire, 1992-93 Preview 364 April 30, 1993
"Must the United States follow California procedure when asserting a claim for refund of sales taxes paid to California?", United States v. State of California and California State Board of Equalization, 1992-93 Preview 263 February 19, 1993
"You be the judge? Can sales tax action against California be brought in federal court", 4 State Tax Notes 340 (1993)
"Does Section 525 of the Soldiers' and Sailors' Civil Relief Act require military personnel to prove hardship or prejudice?", Thomas F. Conroy v. Walter S. Aniskoff, Jr., et al., 1992-93 Preview 188 December 31, 1992
"Economic analysis and expert testimony in commerce clause challenges", in T. F. Pogue (ed.), State Taxation of Business: Issues and Policy Options pp. 125-42 (Praeger Publishers 1992)
"For the Record", Washington Post, November 24, 1992
"Does Davis v. Michigan apply retroactively to require the refund of unconstitutionally discriminatory taxes?", Henry Harper, et al. v. Virginia Department of Taxation, 1992-93 Preview 154 November 30, 1992
"May New Jersey tax a non-domiciliary corporation on part of the income it derived from selling stock?", Allied-Signal, Inc. v. Director, Division of Taxation, 1991-92 Preview 348 June 1, 1992
"May Iowa tax foreign subsidiary dividends while not taxing domestic subsidiary dividends?", Kraft General Foods, Inc. v. Iowa Department of Revenue and Finance, 1991-92 Preview 351 June 1, 1992
"Can a state require an out-of-state mail-order vendor with no physical presence in the state to collect a use tax?", Quill Corporation v. State of North Dakota, 1991-92 Preview #210 February 21, 1992
Comment, "Tax Policy and the Economy", 54 Tax Notes 756 (February 10, 1992)
"Use Tax Collection -- Tax Policy and Adam Smith Provide No Clear Answers In the Quill Case", 2 State Tax Notes 89 (January 20, 1992)
"When does federal law deny states jurisdiction to tax the income of multistate taxpayers?", comment on William Wrigley, Jr. Company v. Wisconsin Department of Revenue (Docket No. 91-119), 1991-92 Preview
"The Dormant Commerce Clause", Program Materials, Georgetown University, 1991 Institute on State & Local Taxation, Washington, D.C.
"May Oklahoma require its electric utilities to use at least 10 percent Oklahoma-mined coal?", State of Wyoming v. State of Oklahoma, 1991-92 Preview 76 November 22, 1991
"Commerce Clause Challenges to State Taxes", 75 Minn. L. Rev. 907 (1991)
"Facts, Law and Economics in Commerce Clause Challenges to State Taxes", 50 Tax Notes 1149 (March 11, 1991)
"Another look at intangible property taxes, the commerce clause, and the internal consistency test", Ford Motor Credit Company v. Department of Revenue, State of Florida, 1990-91 Preview 132 December 14, 1990
"Must Georgia refund the taxes it collected from an out‑of‑state liquor company under an unconstitutional statute?", James B. Beam Distilling Co. v. State of Georgia, 1990-91 Preview 87 November 9, 1990
"Does the Civil Rights Act grant redress to a taxpayer for a state tax that violates the commerce clause?", Mark E. Dennis v. Margaret L. Higgins, Director, Nebraska Department of Motor Vehicles, et al., 1990-91 Preview 89 November 9, 1990
"Is Michigan claiming more than its fair share of the tax base of multistate taxpayers?", Trinova Corporation v. State of Michigan, 1990-91 Preview 27 September 28, 1990
"Use Taxes and the Out-of-State Seller", 48 Tax Notes 463 (July 23, 1990) reprinted in Software Taxation Letter (November, December 1990)
"What Public Finance Do State Constitutions Allow?", R.D. Bingham, E.W. Hill & S.B. White (eds.), Financing Economic Development (Sage Publications 1990)
"Must a state refund taxes that unconstitutionally discriminated against out-of-state taxpayers?", McKesson Corporation v. Division of Alcoholic Beverages and Tobacco, Department of Business Regulation of Florida, et al., American Trucking Associations, Inc., et al. v. Maurice Smith, Director, Arkansas Highway and Transportation Department, et al., 1989-90 Preview of United States Supreme Court Cases 214 (February 16, 1990)
"Must a state refund taxes that unconstitutionally discriminated against out-of-state taxpayers?", McKesson Corporation v. Division of Alcoholic Beverages and Tobacco, Department of Business Regulation of Florida, et al., 1989-90 Preview 214 February 16, 1990
American Trucking Associations, Inc., et al. v. Maurice Smith, Director, Arkansas Highway and Transportation Department, et al., 1989-90 Preview 214 February 16, 1990
"UDITPA--Time for a Broader Perspective?", (mimeo. May, 1986) remarks at Georgetown University Law Center 1986 Institute on State and Local Taxation Washington, D.C., May 22-23, 1986
"The Tax-Price Advantage of the Natural-Resource States and the Deduction for State and Local Taxes", a paper prepared for the Coalition Against Double Taxation (April, 1986)
"Legal and Statistical Issues in Establishing Assessment Ratios", a paper presented at the 6th Annual Legal Seminar of the International Association of Assessing Officers, San Diego, California, January, 1986
"Proof of the Assessment Ratio: A Governmental Responsibility", a paper presented at the 6th Annual Legal Seminar of the International Association of Assessing Officers, Savannah, Georgia, March, 1985
"A Three-Sector Model for Real Property Tax Incidence", 27 Journal of Public Economics 355 (1985)
"Minnesota's Taxes and the Business Climate", 1 Minnesota Tax Journal 223 (Summer 1985)
"State and Local Taxes and Finance", (2d Ed. mimeo. 1985)
"Comments on J. R. Hellerstein, State Taxation Under the Commerce Clause: The History Revisited", in McLure (ed.), The State Corporation Income Tax: Issues in Worldwide Combination (1984)
"A New General Equilibrium Three-Sector Model for Tax Incidence Analysis: The Influence of Property and Income Taxes Upon Homeowners' Demand for Housing Services", (Ph. D. Thesis, Harvard University, May, 1983)
"A Federal Proposal to Limit the State Taxation of Foreign Source Income and Dividends: An Academic Point of View", National Administration of Tax Administrators, Revenue Administration 1980 5 (1981)
With E.F. Corrigan and W.D. Dexter, "The Search for Equity and Accountability in State and Local Taxation of Multistate-Multinational Corporations", 12 Urban Lawyer 553 (1980)
With P.J. DiQuinzio, "Recent Legal Trends in State Taxation of Multistate Businesses", Institute on State and Local Taxation of Business, 29 American Law Review 361 (1980)
"Testimony and Statement on H. R. 5076", United States House, Committee on Ways and Means, State Taxation of Foreign Source Income pp. 336‑46 (1980)
"Taxes and Housing Demand", paper delivered Cambridge, Mass., National Bureau of Economic Research (mimeo. April 18, 1980)
"State Taxation of Income from Businesses in Interstate Commerce: Is There a Need for Federal Legislation?", memorandum prepared for the General Accounting Office, reprinted in United States Senate, Committee on Finance, State Taxation of Interstate Commerce and Worldwide Corporate Income: Hearings on S. 1668 pp. 816-49 (1980)
"1909-1930: The National Tax Association Tries and Abandons Tax Reform", 32 National Tax Journal 429 (1979)
"The U.K. Treaty and the State Taxation of Corporate Income", 5 Tax Notes No. 14 at 3 (1977)
"The British Income Tax of 1842", (mimeo. 1974)
"Review of Real Property Valuations in the Court", 4 International Property Assessment Administration 161 (Chicago 1972)
"Judicial Requirements for School Finance and Property Tax Redesign: The Rapidly Evolving Case Law", 25 National Tax Journal 455 (1972)
"A Comment on Metropolitan Government: A Review of Stanley Baldinger's Planning and Governing the Metropolis", 56 Minnesota Law Review 393 (1972)
"The Equal Protection Clause in Public Education", 71 Columbia Law Review 1355 (1971)
"The City and the Metropolitan Area: Legal Structure and Values", University of Minnesota, Experimental City Project, Volume I 205 (1967)
"Tax Benefits of Section 346 Liquidation Clouded by Unclear Purpose of Law", 15 Journal of Taxation 242 (1961)
"Section 346 of the Internal Revenue Code: A Legislative Enigma", 109 Univ. Pa. L. Rev. 944 (1961).
