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  international tax policy, tax compliance and regulatory design. She is interested in the interaction between legal systems and private ordering.  

Recent writings in tax policy include The Quasi-Global GILTI Tax, 18 Pitt. Tax Rev. 1932 (2021) (symposium contribution);  Do Tax Compliance Robots Follow the Law? (symposium contribution), 16 Ohio State Tech. L. J. 278 (2020); GILTI: The Co-operative Potential of a Unilateral Minimum Tax, 2019 British Tax Rev. 512; Does Parenting Matter?  U.S. Firms, Non-U.S. Firms, and Global Tax Accruals (with Eric J. Allen), 4 J. L. Fin. & Acct'g 239 (2019); International Cooperation and the 2017 Tax Act, 128 Yale L. J. Forum 362 (Oct. 25, 2018) and Seeking Comparable Transactions in Patent and Tax, 37 Rev. Litig. Brief (2018). 

Recent writings in regulatory design include Government-to-Robot Enforcement, 2019 Ill. L. Rev. 1497; When Robots Make Legal Mistakes, 72 Okla. L. Rev. 213 (2019); Regulating by Example, 35 Yale J. Reg. 127 (2018) (with Leigh Osofsky) (featured in online symposium, How Agencies Communicate, at JREG); Safe Harbors, Sure Shipwrecks, 49 U.C. Davis L. Rev. 1385 (2016) (selected for Yale/Stanford/Harvard Junior Faculty Forum, 2015); and Entrepreneurship Incentives for Resource-Constrained Firms, Handbook of Law and Entrepreneurship (forthcoming).

Morse cowrote a Supreme Court amicus brief in 2020 supporting the government in CIC Services, LLC v. Internal Revenue Service (blog coverage here). Morse submitted cowritten Ninth Circuit amicus briefs in 20162018 and 2019 in Altera Corp. v. Commissioner, supporting the government's position that it had validly issued a Treasury regulation that requires cost-sharing arrangements to include stock-based compensation. The Ninth Circuit held for the government and denied rehearing en banc, and the Supreme Court denied cert in 2020. Blog coverage here, here, hereherehere, and here.

Professor Morse teaches Property and Federal Income Tax, as well as the Financial Methods for Lawyers course, which she pioneered at Texas Law. She won the Women's Law Caucus Teacher of the Year award in 2016 and 2020. She is a member of the American College of Tax Counsel and 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.

Other publications include 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).

Most Recent Media

Courses for Spring 2022

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Professional Activities


January 9, 2022


American Association of Law Schools Annual Meeting

Panel, Hot Topic: The Promise and Pitfalls of the Global Tax Deal


September 14, 2021

Panelist, U.S. Tax Reform 2.0 - 2021 Proposals

International Tax Review Women in Tax Forum

August 9, 2021

Blog Post: Tax and Race


 Review of Dorothy Brown, The Whiteness of Wealth (2021)

July 6, 2021

Presenter, The Quasi-Global GILTI Tax

Oxford Centre for Business Taxation Academic Symposium

June 30, 2021


AMT21 Tax Scholarship Conference

June 20, 2021

Instructor, U.S. International Income Taxation

Oxford, Said Business School

June 15, 2021

Presentation, CIC Services, LLC v. Internal Revenue Service

Austin Tax Study Group

May 25, 2021


Federalist Society Webinar

Discussion of Supreme Court decision in CIC Services v Internal Revenue Service with Kristin Hickman and Robert Carney.

May 21, 2021


Texas Tax Faculty Workshop

CIC Services: Why Treasury Should Put the Reporting Position List Through Notice and Comment

May 14, 2021

NTA Panel Organizer

National Tax Association Spring Symposium

A Discussion of Tax Priorities in Legislation and Regulation

May 11, 2021


C. Boyden Gray Center

Podcast presentation of Emergency Money: Lessons from the Paycheck Protection Program

May 5, 2021

Regulatory Comment

Tax Law Center at NYU

Comment on FinCEN Advance Notice of Proposed Rulemaking relating to beneficial owner reporting requirements under Corporate Transparency Act

Download (PDF)


September 18, 2020

Blog post, Why a Win for CIC Services Would Be A Win for Tax Shelters

Procedurally Taxing

Blog post (with Daniel Hemel and Clinton Wallace) explaining tax shelter aspects of Supreme Court case CIC Services v. Internal Revenue Service

September 15, 2020

Brief of Amici Curiae Former Government Officials in Support of Respondents, CIC Services v Internal Revenue Service

Co-wrote (with Daniel Hemel and Clinton Wallace) amicus brief in Supreme Court case in support of government

August 10, 2020

Blog post, Regulating Compliance Robots

The Regulatory Review

Summary of Susan Morse, Do Tax Compliance Robots Follow the Law?, 16 Ohio St. Tech. L. J. 278 (2020)

June 29, 2020

Presentation: Intermediaries and the Law on the Ground

University of Texas School of Law Drawing Board Series

May 21, 2020

Blog Post: Pending cert petition in Altera: Tax law in an administrative law wrapper

Yale JREG Notice & Comment Blog, cross-posted at Procedurally Taxing

May 21, 2020

Blog Post: Pending cert petition in Altera: Tax law in an administrative law wrapper

Yale JREG Notice & Comment Blog, cross-posted at Procedurally Taxing

April 21, 2020

Panelist: Legal Responses to COVID-19

University of Texas School of Law

February 28, 2020

Presentation: Artificial Intelligence as Customary Law

AI and Justice in 2035, UCLA School of Law

February 17, 2020

Presentation: Artificial Intelligence as Customary Law

Marshall M. Criser Distinguished Lecture Series, University of Florida Levin College of Law

February 17, 2020

Presentation: Do Tax Compliance Robots Follow the Law?

Tax Colloquium Series, University of Florida Levin College of Law


November 23, 2019


National Tax Association Annual Meeting

Commented on John Vella, Digital Services Taxes: Principle as a Double-Edged Sword, 72 Nat'l Tax J. 821 (2019)

November 8, 2019


University of Virginia Invitational Tax Conference

Commented on Clinton Wallace, Democratizing Tax Policymaking (working paper)

September 9, 2019

Presentation: Do Tax Compliance Robots Follow the Law?

University of Texas School of Law Drawing Board

June-July 2019

Instructor: U.S. International Income Taxation Course

Oxford University, Said Business School

May 21, 2019


Works-in-Progress Roundtable in Comparative Law, University of Texas School of Law

On Lydia Tiede, Judicial Vetoes: Institutions and Decision-Making on Constitutional Courts

May 17, 2019

Participant: Texas Tax Faculty Workshop

University of Houston School of Law

April 22, 2019

Presentation: GILTI: The Cooperative Potential of a Unilateral Minimum Tax

Pepperdine Tax Policy Workshop

March 6, 2019

Presentation: Government-to-Robot Enforcement

University of Utah, SJ Quinney College of Law

Howard H. Rolapp Distinguished Visiting Scholar Program

February 19, 2019

Presentation: Government-to-Robot Enforcement

NYU Tax Policy Colloquium

February 8, 2019

Presentation: When Robots Make Legal Mistakes

Symposium on Lawyering in the Age of Artificial Intelligence, Oklahoma Law Review

January 15, 2019

Presentation: International Cooperation and the 2017 Act

Austin Tax Study Group


December 11, 2018

Presentation: International Cooperation and the 2017 Act

International Tax Cooperation: The Challenges and Opportunities of Multilateralism Conference, Said Business School, Oxford

November 16, 2018

Presentation: International Cooperation and the 2017 Act

National Tax Association Annual Meeting

October 26, 2018

Panelist: The Future of the New International Tax Regime

Fordham Journal of Corporate and Financial Law Symposium, Fordham Law School

September 14, 2018

Panelist: Voices in the Room: Professional Ethics of Advising Clients on Responding to Cyber Extortion Demands

ABA Business Law Section Annual Meeting, Austin Texas

August 27, 2018

Presentation: International Cooperation and the 2017 Act

University of San Diego School of Law Tax Speaker Series 


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)