Susan C Morse

Susan C Morse

  • Angus G. Wynne, Sr. Professor in Civil Jurisprudence

Faculty Profile: Susan C Morse

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Susan Morse joined the University of Texas law faculty in 2013. She studies and writes about rules and standards, international tax reform and tax compliance; and has taught federal income tax, business tax, international tax, and tax policy courses. She has pioneered the Financial Methods for Lawyers course at Texas Law and won the 2016 Women's Law Caucus Teacher of the Year award. She edits the tax section at Professor Morse clerked for the Honorable Michael Boudin of the United States Court of Appeals for the First Circuit and spent seven years in business tax practice at Ropes & Gray, Boston and Wilson Sonsini Goodrich & Rosati, Palo Alto. Prior to joining the Texas faculty, she served as Associate Professor at UC Hastings College of the Law and as Research Assistant Professor at Santa Clara University School of Law.

Recent writings include Government-to-Robot Enforcement, 2019 Ill. L. Rev. (forthcoming); Seeking Comparable Transactions in Patent and Tax, 37 Rev. Litig. Brief (201); Entrepreneurship Incentives for Resource-Constrained Firms, Handbook of Law and Entrepreneurship (forthcoming); Regulating by Example, 35 Yale J. Reg. 127 (2018) (with Leigh Osofsky), which provides a theory for the interpretation of examples in regulations and inspired an online symposium, How Agencies Communicate, at JREG.

Morse wrote Safe Harbors, Sure Shipwrecks, 49 U.C. Davis L. Rev. 1385 (2016) and considers safe harbors in the news with op-eds, as here on special needs funding in public schools and here on food labeling. Safe Harbors, Sure Shipwrecks was selected for presentation at the Yale/Stanford/Harvard Junior Faculty Forum in 2015.

Morse submitted a cowritten Ninth Circuit amicus brief in 2016 in Altera Corp. v. Commissioner supporting the validity of Treasury’s regulation that requires cost-sharing arrangements to include stock-based compensation. Blog coverage here, here, here and here

Morse has also written Innovation and Taxation at Start-Up Firms, 69 Tax L. Rev. 357 (2016); Tax Anti-Avoidance Law in Australia and the United States, 49 Int'l Law. 111 (2015); A Simpler Offshore Profits Transition Tax, 76 Tax Notes Int'l 629 (Feb. 17, 2014); Startup Ltd.: Tax Planning and Initial Incorporation, 14 Fla. Tax Rev. 319 (2013); Tax Haven Incorporation for U.S. Firms: No Exodus Yet, 66 Nat’l Tax J. 395 (2013); The Transfer Pricing Regs Need a Good Edit, 40 Pepperdine L. Rev. 1415 (2013); and A Corporate Offshore Profits Transition Tax, 91 N.C. L. Rev. 549 (2013).

Courses for Fall 2018

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Professional Activities


July 31, 2018

Blog Post: The Ninth Circuit Reverses the Tax Court Decision in Altera

Procedurally Taxing

A review of the government's transfer pricing win in Altera at the Ninth Circuit, and an explanation of taxpayer Altera's weak hand in case of appeal.

April 30, 2018

Blog post: Government-to-Robot Enforcement

Oxford Business Law Blog

A blog summary of Government-to-Robot enforcement, 2019 U. Illinois L. Rev. ___.

April 17, 2018

Lecture: International Tax Reform and Closely Held Businesses

Austin Tax Study Group

Joint presentation with William Bell, Esq.

February 2, 2018

Blog Post: How Agencies Communicate: Wrapping Up

Yale J. on Reg.: Notice and Comment

January 29, 2018

Blog Post: How Agencies Communicate: Introduction and an Example

Yale J. on Reg.: Notice & Comment

Introduction to Online Symposium, How Agencies Communicate, featuring Regulating by Example, 35 Yale J. on Reg. __ (2018)


December 7, 2017

Blog post: Is "cash only" enough for a tax law obstruction charge?


Argument analysis in Marinello v. United States

November 28, 2017

Argument preview: What limits tax law obstruction-of-justice charges?


Argument preview of Marinello v. U.S., in which taxpayer contests government's obstruction charge based on destruction of evidence prior to a known audit or other tax enforcement proceeding.

October 17, 2017

Blog post: The Altera Oral Argument

Procedurally Taxing

Recap of the Ninth Circuit oral argument in Altera, a case about cost-sharing arrangements and administrative law case (with Steve Shay).

October 10, 2017

Blog post: Ninth Circuit Hears Altera Tomorrow

Procedurally Taxing

A summary of reasons why the Ninth Circuit should reverse the Tax Court in Altera, a case about cost-sharing of intangibles and administrative law, focusing on the inherent lack of comparability for available unrelated party data in the case of cost-shared IP.  With Steve Shay.



April 3, 2015

Blog post: Non-U.S. Acquirers: Clients for U.S. Targets' "Locked-Out" Earnings?


Review of Andrew Bird, Alexander Edwards & Terry J. Shevlin, Does the U.S. System of Taxation on Multinationals Advantage Foreign Acquirers? (working paper 2015)


June 23, 2014

Blog post: Opinion analysis: Court clarifies standard for evidentiary hearing in enforcement of IRS summons


Coverage of United States v. Clarke, 573 U.S. __ (2014)

March 19, 2014

Blog post: Can the IRS Tell a Good Story?

Procedurally Taxing

January 9, 2014

Blog post: There's Math for That! Delta Value and the Constructive Sale Rules


Review of Thomas J. Brennan, Law and Finance:  The Case of Constructive Sales, 5 Ann. Rev. Fin. Econ. 259 (2013)


February 22, 2013

Blog post: Obamacare and Lower-Income Workers


Review of David Gamage, Perverse Incentives Arising from the Tax Provisions of Healthcare Reform, 65 Tax L. Rev. 669 (2013)


July 16, 2012

Blog post: Corporate Tax Reform in Theory and in Politics


Review of Martin Sullivan, Corporate Tax Reform:  Taxing Profits in the 21st Century (2011)

February 20, 2012

Op-Ed: Underlawyering vs. Overlawyering

The Recorder


September 26, 2011

Blog post: Tax Compliance and the Love Molecule

Arizona State Law Journal Blog

Review of Paul J. Zak, The Moral Molecule (2012)


December 7, 2009

Blog post: Tax Policies, Public Opinions


Review of Andrea Louise Campbell, What Americans Think of Taxes, in The New American Fiscal Sociology (Isaac William Martin et al. eds., 2009)