Associate Professor of Law
B.S., Florida State University
M.B.A., University of Massachusetts - Amherst
J.D., Wake Forest University School of Law
LL.M., Georgetown University Law Center
Federal Income Taxation I, Federal Income Taxation II, Business Entities, Comparative Taxation and Multijurisdictional Taxation
Professor Andrew Appleby focuses his teaching and scholarship on tax and business law. He has particular expertise in state and local taxation, taxation of the digital economy, sports taxation, and applied tax policy. Professor Appleby has published in many prominent law journals, most recently the Harvard Journal on Legislation, Arizona State Law Journal, and Maryland Law Review.
He has been featured extensively in the media, including The New York Times, Bloomberg TV, and Tax Notes. Professor Appleby also co-authors the leading treatise on state taxation, Hellerstein’s State Taxation (3d. ed) (with Jerome Hellerstein & Walter Hellerstein), which is cited regularly by the United States Supreme Court and many other courts across the nation.
Professor Appleby practiced tax and corporate law at leading law firms for nearly a decade. Most recently, he was special counsel in the tax group in Pillsbury Winthrop Shaw Pittman LLP's New York office. Professor Appleby was a partner in the tax group in Eversheds Sutherland (US) LLP's New York office, and an associate in the corporate group in Alston & Bird LLP's Atlanta office. Prior to his legal career, Professor Appleby was an information technology and business consultant.
Professor Appleby earned an LL.M. in Taxation from Georgetown University Law Center, where he participated in the Graduate Tax Scholar fellowship program. He earned a J.D. from Wake Forest University School of Law, an M.B.A. from the University of Massachusetts – Amherst, and a B.S. from Florida State University.
This Article begins by examining exit tax theory and advancing novel applications of theories that support subnational exit taxation, both domestically and internationally. With a robust theoretical and technical foundation, this Article turns to state and local exit tax design. This discussion examines constitutional constraints to address specific tax base migration challenges—focusing on the justifications, distributional impact, and optimal exit tax design features to address each situation.
This Article presents options for subnational digital service taxation. These options range from slightly modified existing tax regimes to novel approaches that may more appropriately tax digital services, specifically those services that extract and monetize user data. This Article also analyzes the constitutional, federal preemption, and sourcing challenges facing subnational digital services taxes.