University Of Michigan Essay 2015 Tax

This prompt represents a common category of supplement prompts that ask you why you want to study a specific program at a specific school. The main purpose of these “Why Us?” essays is to show the school why you are interested and why you are a good fit.


This is done in two parts: 1. why you want to study what you have indicated and 2. why you want to study it here at this specific school. Make sure to do some research so you can provide more than generic examples like “I want to go to a big school“ or “I like sports” that could apply to many other schools. To learn more about “Why Us?” type essays, read our essay guide, “How to Write the “Why Us?” College Essay.”


When you start to write this essay, you first want to develop why you wish to study what you have indicated on your application. An anecdote is often the most effective means of accomplishing this. You could recount how your time in physical therapy, love for your biology class, and long history of playing sports fueled your passion to learn more about the human body and how it moves. This perfectly lines up with the field of Kinesiology.


Next, you need to demonstrate why Michigan is the perfect place to study what you have selected. Continuing with the Kinesiology example, you could talk about its excellent reputation and some specific classes you really look forward to taking.


With preferred admission applications, it is important to discuss your future goals as well as past experiences that make you sure you will want to be a part of this program. For example, if you apply for the Pharmacy program, you will want to discuss why you are interested in pharmacy and detail the moments in your life that have led you to this decision. Perhaps you have always had a passion for chemistry and helping others, and hearing from your friend’s mom about her career in pharmacy was consistently one of your favorite parts of your weekly hangouts.


With dual-degree programs, the key is not only discussing why you want to pursue a degree in each of them, but why you think the combination is especially important for you.


For example, if you are applying to the dual-degree Ross School of Business and College of Engineering program, you could discuss your dream of beginning your own tech startup and needing both the technical engineering knowledge and business savvy. You could write about how you first came up with your idea and when/how you realized Michigan’s dual-degree program would be the perfect place to bring it to life.


In 1997, I wrote an article on the international tax challenges posed by the then-nascent electronic commerce, in which I suggested that the international tax regime is based on two principles: the benefits principle and the single tax principle. The benefits principle states that active (business) income should be taxed primarily by the country of source, and passive (investment) income should be taxed primarily by the country of residence. This is the famous compromise reached by the four economists at the foundation of the regime in 1923 and is not particularly controversial. It is embodied in every one of the over 3,000 tax treaties that reduce taxation at the source of passive income while allowing source countries to tax active income if there is a permanent establishment. The single tax principle states that cross-border income should be taxed once at the rate determined by the benefits principle. In other words, cross-border income should be taxed only once at the source-country rate for active income and at the residence-country rate for passive income. But if the preferred country (i.e., source for active, and residence for passive) does not tax, it is incumbent upon the other country to do so because otherwise, I argued in my article, double non-taxation would result, which is just as damaging as double taxation. This argument remains hugely controversial. While there are indications that the single tax principle was the idea underlying the adoption of the foreign tax credit by the United States in 1918, as far as tax treaties are concerned, the United States did not accept the single tax principle until more recent times.

Recommended Citation

Avi-Yonah, Reuven S. "Who Invented the Single Tax Principle?: An Essay on the History of US Treaty Policy." N. Y. L. Sch. L. Rev. 59, no. 2 (2015): 305-15.

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