This highlights a theme that I will continue to explore in upcoming research: that life insurance, a financial product that everyone considers to be boring and staid, is actually uniquely situated because of its favorable tax and regulatory treatment to serve as a stalking horse.

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This is mine

My website, including my CV, is here: sites.google.com/view/andrewg.... I'm excited to share my work!

My paper is on SSRN here: papers.ssrn.com/sol3/papers..... My principal teaching interests on FAR are in tax, business associations, contracts, corporate finance, and securities regulation, and my work also includes insurance, financial institutions, and bankruptcy.

My approach enables a novel policy rec: instead of trying another round of plugging loopholes using techniques that are known within tax but beleaguered, I argue the estate & gift tax "willing buyer, willing seller" valuation standard should change to that of appraisal.

I argue that while the bankruptcy and corporate law valuation variations are explainable by such adaptation, tax valuation is being undermined to nullify the gift & estate taxes even more than previously understood as well as separately incentivize poor corporate governance.

What accounts for these differences? I look to the purpose that each underlying substantive law (corporate, tax, bankruptcy) seeks to advance and whether judges are performing business interest valuations in accordance with this underlying purpose.

These differences matter: in cases of privately held and weakly traded interests, when applying the standard valuation methodologies of these signature corporate and tax law courts to an asset with the same cash flow, it will be worth roughly twice as much under corporate law.

I first employ natural language processing and an LLM to illustrate that valuation is near-totally siloed between all of these settings. For example, the academic literature and expert witnesses that courts rely on to conduct valuations are almost totally disjoint by court.

Different statutes require different courts to conduct firm valuations to reach legal outcomes, such as shareholder appraisals (merger disputes) in the Delaware Court of Chancery, estate & gift tax cases (in the Tax Court), and cramdowns (reorganization disputes) in bankruptcy.

One result of a new potential tax provision in the "Big, Beautiful Bill": anyone can get to that result with federal income taxes alone www.taxnotes.com/featured-ana...