Professor  Dean's Distinguished Scholar

International tax law has been in the news a good deal lately, and one of the key developments widely discussed among international tax experts is the “OECD/G20 Inclusive Framework on BEPS,” which aims to take on base erosion and profit shifting (i.e., “BEPS”) behaviors of multinational enterprises (“MNEs”). Ruth Mason offers a broad new view of these developments in her article, The Transformation of International Tax.

Boston College Law School Faculty Papers

The New World of International Tax

Taxpayers who hide assets abroad to evade taxes present a serious enforcement challenge for the United States. In response, the United States has developed a family of initiatives that punish and rehabilitate non-compliant taxpayers, raise revenues, and require widespread reporting of offshore financial information by financial institutions and taxpayers. Yet, while these initiatives help catch willful tax cheats, they have also adversely affected immigrants, Americans living abroad, and “accidental Americans.”This Article critiques the United States’ offshore tax enforcement initiatives, such as the Foreign Account Tax Compliant Act and the Internal Revenue Service’s offshore voluntary disclosure programs. It argues that the United States has been overly focused on two policy priorities in designing enforcement at the expense of competing considerations: First, the United States has attempted to equalize enforcement against taxpayers with solely domestic holdings and those with harder-to-detect offshore holdings by imposing harsher reporting requirements and penalties on the latter. But in doing so, it has failed to appropriately distinguish among differently situated taxpayers with offshore holdings. Second, the United States has focused on revenue and enforcement, paying less attention to the significant compliance costs and potential social harms that its initiatives create.The confluence of these two policy priorities risks creating high costs for the wrong taxpayers. While offshore tax enforcement may have been designed to catch high-net-worth tax cheats, it may instead impose disproportionate burdens on those immigrants and expatriates who have less ability to complain, comply, or “substitute out” of the law’s grasp. This Article argues that the United States should redesign its enforcement approach to minimize these risks and suggests reforms to this end.

The Offshore Tax Enforcement Dragnet

The term “sharing economy” is flawed, but are the alternatives any better? This Essay evaluates the uses of competing narratives to describe the business model employed by firms like Uber, Lyft, TaskRabbit, and GrubHub. It argues that while the term “sharing economy” may be a misnomer, terms such as “gig economy,” “1099 economy,” “peer-to-peer economy” or “platform economy” are just as problematic, possibly even more so. These latter terms are more effective in exploiting existing legal rules and ambiguities to generate desired regulatory outcomes, in particular, the classification of workers as independent contractors. This is because they are plausible, speak to important regulatory grey areas, and find support in existing laws and ambiguities. They can therefore be deployed to tilt outcomes in directions desired by firms in this sector.This Essay’s analysis suggests that narratives that are at least somewhat supportable under existing law may be potent in underappreciated ways. In contrast, clearly erroneous claims may sometimes turn out to be hyperbolic, yet harmless. Thus, in evaluating the role of narrative in affecting regulatory outcomes, it is not only the obviously wrong framings that should concern us but also the less obviously wrong ones.This Essay is part of the Altruism, Community, and Markets Symposium organized by Duke University School of Law, the University of Virginia School of Law, and the American Enterprise Institute.

The Trouble with Gig Talk: Choice of Narrative and the Worker Classification Fights

When a debtor goes bankrupt and limited assets have to be divided between competing creditors, should unpaid taxes owed to the government be paid before the debts owed to other creditors? This Article defends the notion that some tax debts should be awarded priority. Insofar as bankruptcy protection transfers the risk of financial distress from a debtor to her creditors, the tax priority debate should be understood as a fight about how much debtor default risk the government should have to assume relative to other creditors. This Article argues that the government’s share of debtor default risk should be limited through the grant of tax priority because, contrary to the claims of critics, the government is constrained in its ability to diversify against such risk via both substantive tax policy and changes in tax administration. Tax priority therefore serves as an important structural limit on the government’s bankruptcy risk burden and safeguards the myriad important functions of government.

Boston College Law Review

Taxing Bankrupts

Tax scholars generally agree that the years since the 2008 financial crisis have seen the emergence of a new international tax order, characterized by an increase in transparency, cooperation, and coordination among countries in matters of international tax policy. Such increased cooperation and coordination can be seen, for example, in recent global talks and moves towards agreement on a global minimum tax. A central—if not the central—component of this new order is the Organisation for Economic Cooperation and Development (OECD) and G20 Base Erosion and Profits Shifting (BEPS) Project, which was developed starting in 2013, and the BEPS Inclusive Framework, which was established in 2016. The BEPS Inclusive Framework is a multilateral agreement through which member countries commit to reforming their domestic tax laws and treaties to reflect the standards and policies articulated by the Framework. Its goal is to curtail tax avoidance, profit shifting, and other harmful behaviors by multinational enterprises (MNEs) that erode domestic tax bases and drain tax revenues. Spearheaded by the OECD at the request of the G20, the BEPS Inclusive Framework is undoubtedly one of the most important recent developments in international taxation. It is having clear impacts on domestic and cross-border tax law regimes. The effectiveness and reach of the BEPS Project and Inclusive Framework will impact how much revenue nation states can raise, the global distribution of tax revenues, and the capacity of welfare states around the world.

In short, this Article reveals how international organizations like the OECD can work in tandem with powerful actors like the EU to generate far-reaching scripts, norms, and models that shape global tax institutions and ultimately affect domestic tax regimes around the world. Its findings show how these actors may exert pressure on developing countries to adopt these scripts through a combination of normative and coercion-based processes. These findings also have implications for high-stakes claims frequently made by international tax commentators and policymakers. In particular, the findings about the interplay between EU tax haven listing processes and Inclusive Framework membership provide an important counter-narrative to accounts that have emphasized the increased voice and representation enjoyed by developing countries in the emerging global tax order. While a common and arguably dominant narrative surrounding the BEPS Project is that developing countries are well-represented and willing participants in the project by virtue of the endorsement and presence of the G20 in spearheading it, the apparent role of EU listing processes in motivating BEPS membership suggests that fears of the economic and political consequences of being listed might to some extent be driving developing country participation, and that this pathway might merit closer scrutiny. If coercion-based pathways are indeed playing a role in motivating Inclusive Framework membership and participation in follow-on initiatives, this implicates the legitimacy and inclusiveness of the BEPS Project and raises questions about its likelihood of success and substantive outcomes (including distribution among countries).

World Tax Policy in the World Tax Polity? An Event History Analysis of OECD/G20 BEPS Inclusive Framework Membership

In 2017, Congress passed major tax legislation at warp speed. After enactment, it fell to the Treasury Department to write regulations clarifying and implementing the new law. To assure democratic legitimacy in making regulations, administrative law provides that an agency must issue a notice of proposed rulemaking, followed by an opportunity for the public to comment (so called “notice and comment”). But, after the 2017 tax overhaul, many sophisticated actors did not wait until the issuance of a notice of proposed rulemaking to comment, instead going to Treasury immediately with comments designed to influence the regulations.In this Article, we examine empirically this phenomenon of post-enactment commenting by studying the making of the Code Section 199A regulations—some of the most important regulations implementing the 2017 tax reform. We examined the inputs into the regulatory process from legislative enactment through the regulations’ finalization. We find extensive engagement by sophisticated parties and industry groups prior to the official notice-and-comment period, which helped shape and anchor rulemaking outcomes. Subsequent comments submitted in the official notice-and-comment period led to technical and other discrete changes, but did not fundamentally change the initial rulemaking approach. Throughout the rulemaking process, there was little direct, public-interested engagement.Our study underscores how unorthodoxies in the legislative process bleed into the rulemaking process. Hasty legislation puts pressure on administrative law notice-and-comment procedures, exacerbating problems of unequal access and transparency already endemic to rulemaking, and potentially compromising democratic legitimacy. We propose solutions that may help ameliorate these problems and improve governance.

Legislation and Comment: The Making of the §199A Regulations

Tax statutes have long been derided as convoluted and unreadable. But there is little existing research about drafting practices that helps us contextualize such critiques. In this Article, we conduct the first in-depth empirical examination of how tax law drafting and formulation decisions are made. We report findings from interviews with government counsels who participated in the tax legislative process over the past four decades. Our interviews revealed that tax legislation drafting decisions are both targeted to and controlled by experts. Most counsels did not consider statutory formulation or readability important, as long as substantive meaning was accurate. Many held this view because their intended audience was tax experts, regulation writers, and software companies, not ordinary taxpayers. When revising law, drafters prioritize preserving existing formulations to not upset settled expectations, even at the cost of increasing convolution. While members of Congress (“Members”), Members’ staff, and committee staff participate in high-level policy decisions, statutory formulation decisions are largely left to a small number of tax law specialists. Our findings carry important implications for statutory interpretation, affirming prior research, but also calling into deeper question arguments for textualism and the validity of certain interpretive canons. Our findings also have important implications for the design of our tax system, illuminating the distributive tradeoffs inherent in drafting practices. Finally, our findings reveal a contrast between public expectations about the legislative process and how the process actually works, underscoring underexplored questions about what makes this process legitimate.

Constituencies and Control in Statutory Drafting: Interviews with Government Tax Counsels

In this chapter, we survey some of the key tax issues that have confronted individuals operating in the sharing economy. While our discussion focuses on the United States, these classification, documentation, and compliance challenges frequently arise in other countries. Many of the tax implications of this work stem from the threshold decision by many platforms to classify such individuals as independent contractors rather than employees. Therefore, we first discuss how the threshold classification decision affects the substantive and compliance- related tax issues faced by individuals operating in the sharing economy. We briefly summarize the doctrinal tax rules governing income taxation of sharing economy workers, discussing both the rules for income inclusion and the rules for expense tracking and taking. We then discuss some of the compliance challenges experienced by sharing economy participants in fulfilling their tax obligations, including the need to allocate expenses between business and personal use, the need to fi le estimated taxes, liability for self- employment taxes, and the need to track income given imperfect information reporting. The chapter then examines tax- related factors (such as lack of withholding) that may affect the labor- supply decisions of sharing economy participants. For example, we examine the potential impacts of lack of withholding and of expense estimation difficulties on how these individuals calculate their likely profit or loss from engaging in such work. Finally, we discuss possible reforms to the taxation of sharing economy participation that may help alleviate compliance challenges associated with work in this sector or may help these individuals make more informed decisions, and we explore the downsides of such reforms.

Tax Issues in the Sharing Economy: Implications for Workers

There has been a lot of interest lately in new IRC Section 199A, the new qualified business income (QBI) deduction that grants passthroughs, including qualifying workers who are independent contractors (and not employees), a deduction equal to 20% of a specially calculated base amount of income. One of the important themes that has arisen is its effect on work and labor markets, and the notion that the new deduction creates an incentive for businesses to shift to independent contractor classification. A question that has been percolating in the press, blogs, and on social media is whether new Section 199A is going to create a big shift in the workplace and cause many workers to be reclassified as independent contractors. Is this really going to happen? How large an effect will tax have on labor markets and arrangements? We think that predicting and assessing the impact of this new provision is a rather nuanced and complicated question. There is an intersection of incentives, disincentives and risks in play among various actors and across different legal fields, not just tax. Here, we provide an initial roadmap for approaching this analysis. We do so drawing on academic work we have done over the past few years on worker classification in tax and other legal fields.

Is New Code Section 199A Really Going to Turn Us All into Independent Contractors

In December 2017, Congress passed major tax reform. The reform included an important new provision that granted independent contractors and other pass-through taxpayers—but not employees or corporations—a potential tax deduction equal to 20% of their qualified business income. Critics have argued that this new deduction (codified at 26 U.S.C. § 199A) could lead to a widespread shift toward independent contractor jobs as workers seek to reduce taxes paid. This shift could cause workers to lose important employee protections and leave them more economically vulnerable.
This Article examines whether this new tax provision will create a large-scale workplace shift and, if it does, how that shift should be normatively evaluated. It argues that while tax law in general has important and underappreciated effects on work arrangements, it is difficult to isolate § 199A as the driver of a broad workplace shift. Several other nontax legal changes and nonlegal economic developments are transforming work arrangements and classification choices; § 199A is only one factor. Moreover, § 199A is not the only tax law change that is likely to impact classification choices.
Drawing on empirical data on contemporary workplace trends, this Article also argues that even if new § 199A induces a workplace shift, how this shift is evaluated must depend on the types of workers and the work at issue. While an independent contractor shift may increase precariousness for some workers, empirical data suggests that for others a shift may be less troubling or troubling for different reasons. This Article lays a framework for analyzing how tax law contributes to and interacts with other factors in ultimately shaping contemporary work arrangements.

Tax Law's Workplace Shift

The past few years have seen the rise of a new model of production and consumption of goods and services, often referred to as the “sharing economy.” Fueled by startups such as Uber and Airbnb, sharing enables individuals to obtain rides, accommodations, and other goods and services from peers via the Internet or mobile application in exchange for payment. The rise of sharing has raised questions about how it should be regulated, including whether existing laws and regulations can and should be enforced in this new sector or whether new ones are needed. 

In this Article, we explore those questions in the context of taxation. We argue that, contrary to the claims of some commentators, the application of substantive tax law to sharing is mostly (though not completely) clear, because current law generally contains the concepts and categories necessary to tax sharing. However, tax enforcement and compliance may present challenges, as a result of two distinctive features of sharing. First, some sharing businesses tend to opportunistically pick the more favorable regulatory interpretation if there is ambiguity regarding which rule applies or whether a rule applies. This leads to compliance and enforcement gaps. Second, the “microbusiness” nature of sharing raises unique compliance and enforcement concerns. We suggest strategies for addressing these dual challenges, including lower information reporting thresholds, safe harbors and advance rulings to simplify tax reporting, and targeted enforcement efforts.

Can Sharing Be Taxed?

This article begins to explore the legal and policy implications of a new form of financing -- income sharing agreements -- which have raised concerns that the effectively created "equity" in humans.

The New Human Equity Transactions

In the past few years, we have seen the rise of a new model of production and consumption of goods and services, often referred to as the “sharing economy.” Fueled by startups such as Uber and Airbnb, sharing enables individuals to obtain rides, accommodations, and other goods and services from peers via personal computer or mobile application in exchange for payment. The rise of sharing has raised questions about how it should be regulated, including whether existing laws and regulations can and should be enforced in this new sector or whether new ones are needed.In this Article, we explore those questions in the context of taxation. We argue that, contrary to the claims of some commentators, the application of substantive tax law to sharing is mostly (though not completely) clear, because current law generally contains the concepts and categories necessary to tax sharing. However, tax enforcement and compliance may present challenges, as a result of two distinctive features of sharing. First, some sharing businesses opportunistically pick the more favorable regulatory interpretation if there is ambiguity regarding which rule applies or whether a rule applies. The existence of these ambiguities has been exacerbated by the structures of the new sharing economy and this has led to compliance and enforcement gaps. Second, the “microbusiness” nature of sharing raises unique compliance and enforcement concerns. We suggest strategies for addressing these dual challenges, including lower information reporting thresholds, safe harbors and advance rulings to simplify tax reporting, and targeted enforcement efforts.

Over the past decade, a number of well-publicized data leaks have revealed the secret offshore holdings of high-net-worth individuals and multinational taxpayers, leading to a sea change in cross-border tax enforcement. Spurred by leaked data, tax authorities have prosecuted offshore tax cheats, attempted to recoup lost revenues, enacted new laws, and signed international agreements that promote “sunshine” and exchange of financial information between countries.The conventional wisdom is that data leaks enable tax authorities to detect and punish offshore tax evasion more effectively, and that leaks are therefore socially and economically beneficial. This Article argues, however, that the conventional wisdom is too simplistic. Leak-driven lawmaking has clear benefits, but it also carries distinctive risks, including agenda setting by third parties with specific interests and the leaks’ capacity to trigger nonrational responses. Even where leak-driven lawmaking is beneficial overall, it is important to appreciate its risks when determining how to utilize and respond to leaks.This Article is the first to thoroughly examine both the important beneficial effects of tax leaks, and their risks. It provides suggestions and cautions for making and enforcing tax law, after a leak, in order to best tap into the benefits of leaks while managing their pitfalls.

Leak-Driven Law

As the United States tax system continues grappling with how to accurately and appropriately tax workers in the gig economy, it confronts a number of questions. For example, what relationships are included in the gig economy? How many workers and firms are involved, and is the number increasing or decreasing? What particular problems do these workers encounter when engaging with the tax system, and are these meaningfully different from the problems confronted by other taxpayers? Is there a prototypical gig worker, or would gig-specific tax reform or relief have to be tailored to different types of gig workers (e.g., contributors of labor as opposed to contributors of capital)? If there is a prototypical gig worker, what is that worker’s profile, and is it shifting? Is independent contractor classification for gig workers appropriate, and is it desired by workers? Is the tax system affecting the labor supply decisions of gig workers?
Many of these questions have proven difficult to answer due a lack of adequate information. But the answers are important because they will shape how and whether the tax system responds to the gig economy, including how it approaches business deductions, tax withholding, and income definitions, how and whether it utilizes safe harbors and de minimis exceptions, how it designs taxpayer forms and instructions, and how it allocates enforcement and taxpayer education resources. In addition, as we have discussed in previous work, the tax system’s evolving responses to the gig sector will affect other legal areas such as employment law, labor law, and antitrust. Thus, the question of how to obtain the data and information necessary to formulate sound tax and related policies for gig work is vital.
This chapter discusses the limitations of quantitative empirical research on the gig economy and argues that incorporating more qualitative approaches will be essential in attaining a comprehensive understanding of the tax policy issues involved. Specifically, this chapter emphasizes that adoption of a diverse set of research approaches is crucial because the administrative tax return and labor survey data are insufficient and are shaped by prior decisions of gig economy firms and participants. Many questions remain that such quantitative data, by its very nature, cannot answer.

The Importance of Qualitative Research Approaches to Gig Economy Taxation

This Article examines how increasingly ubiquitous data and information affect the role of “slack” in the law. Slack is the informal latitude to break the law without sanction. Pockets of slack exist for various reasons, including information imperfections, enforcement resource constraints, deliberate nonenforcement of problematic laws, politics, biases, and luck. Slack is important in allowing flexibility and forbearance in the legal system, but it also risks enabling selective and uneven enforcement. Increasingly available data is now upending slack, causing it to contract and exacerbating the risks of unfair enforcement.
This Article delineates the various contexts in which slack arises and presents a bounded defense of slack, despite its risks and notwithstanding the parallel existence of formal leniency provisions in the law. It explains how increasingly available data is reshaping slack and highlights the risk of disparate contraction of slack for different populations along lines of race, political power, and sophistication. Ultimately, this Article proposes a framework for managing the complex relationship between slack and data and suggests policy solutions to address data-driven contraction of slack while minimizing slack’s risks. These policy solutions include limits on data collection, construction of data silos, and fundamental rethinking of legal rules and the role of government.

"Slack" in the Data Age

Over the last decade, there has been a revolution in cross-border tax information exchange and reporting. While this dramatic shift was the product of multiple forces and events, a fundamental reality is that politics, technology, and law intersected to drive the shift to the point where nation-states will now transmit and receive from each other significant ongoing flows of taxpayer information. States can now expect to accumulate large stashes of data on cross-border income, assets, and activities on a scale and level of comprehensiveness unmatched by previous information exchange regimes.This article examines the pressing follow-up question of how this data will be used and what issues nation-states will confront when data comes home. Although concerns about data protection and use have been raised in critiquing the new crossborder information exchange regimes, a systematic examination of how governments might use or fail to use data and when those uses will pose unacceptable risks has yet to be undertaken. This article analyzes how domestic politics, priorities, and institutions are likely to affect tax enforcement and data usage at the nation-state level going forward. We argue that despite the dominant focus on global developments, domestic politics and technological constraints will likely play an equally if not more significant role in data use and protection as countries receive data and decide what to do with it. The mere fact that collective political will on a global level produced the information revolution does not prevent domestic forces from either derailing the revolution in practice or redirecting data to other uses. This article maps the potential risks and examines the extent to which individual nation-states will have the capacity or inclination to conduct enforcement, protect taxpayer privacy, and attend to distributional outcomes and risks. We ultimately articulate a framework for understanding the country-level factors likely to affect outcomes and pathways when data comes home.

When Data Comes Home: Next Steps in International Taxation's Information Revolution

A controversial new financing phenomenon has recently emerged. New “income share agreements” (“ISAs”) enable an individual to raise funds by pledging a percentage of her future earnings to investors for a certain number of years. These contracts, which are offered by entities such as Fantex, Upstart, Pave, and Lumni, raise important questions for the legal system: Are they a form of modern-day indentured servitude or an innovative breakthrough in human financing? How should they be treated under the law?
This Article constitutes the first real attempt in the legal literature to comprehensively address the public policy and legal issues raised by ISAs and to articulate an analytical approach to evaluating and regulating them. While there has been a nascent movement in favor of enacting overarching regulatory schemes to govern these new arrangements, this Article suggests we should resist that trend because a unified approach is likely to create more problems than it solves. Instead, we suggest adoption of a case-by-case approach that examines each ISA’s distinctive economics and draws analogies to more familiar financial arrangements in designing its legal treatment. Such case-by-case regulation by analogy is likely to generate rules that are more equitable and efficient. We offer a multifactor framework for implementing this “regulation by analogy.”

Human Equity? Regulating the New Income Share Agreements

In this Article, we investigate the tax issues and challenges facing Uber and Lyft drivers by studying their online interactions in three internet discussion forums: Reddit.com, Uberpeople.net, and Intuit TurboTax AnswerXchange. Using descriptive statistics and content analysis, we examine (1) the substantive tax concerns facing forum participants, (2) how taxes affect their driving and profitability decisions, and (3) the degree of user sophistication, accuracy of legal advising, and other cultural features of the forums.We find that while forum participants displayed generally accurate understandings of tax filing and income inclusion obligations, their approaches to expenses and deductions were less accurate and more varied in sophistication and willingness to comply with tax law. Forum participants also frequently discussed whether driving was profitable and exhibited a range of awareness concerning how taxes affected profitability. Finally, while the forums contained a surprising degree of sophisticated and accurate tax and legal advice, they also contained many examples of inaccurate or confusing information. It is thus uncertain whether forum readers were able to successfully distinguish between accurate and inaccurate advice dispensed in the forums.Based on our findings, we make tentative recommendations for effective tax administration in the ridesharing and related sectors, including use of industry-specific guidance, clarification of how existing tax rules apply to ridesharing, and guidance on Form 1099-K interpretation. We analyze the implications of our findings regarding taxes and profitability for Uber’s business model and its potential regulation. Finally, we discuss the possible impacts of targeted tax compliance initiatives on internet communities.

The Tax Lives of Uber Drivers: Evidence from Online Forums

The United States is currently trying to manage a fast-moving public health crisis due to the coronavirus outbreak (COVID-19). The economic and financial ramifications of the outbreak are serious. This Working Paper discusses these ramifications and identifies three interrelated but potentially conflicting policy priorities at stake in managing the economic and financial fallout of the COVID-19 crisis: (1) providing social insurance to individuals and families in need; (2) managing systemic economic and financial risk; and (3) encouraging critical spatial behaviors to help contain COVID-19 transmission. The confluence of these three policy considerations and the potential conflicts among them make the outbreak a significant and unique regulatory challenge for policymakers, and one for which the consequences of getting it wrong are dire.
This Working Paper—which will be continually updated to reflect current developments—will analyze the major legislative and other policy initiatives that are being proposed and enacted to manage the economic and financial aspects of the COVID-19 crisis by examining these initiatives through the lens of these three policy priorities. It starts by analyzing the provisions of H.R. 6201 (the “Families First Coronavirus Responses Act”) passed by the house on March 14, 2020. By doing so, this Working Paper provides an analytical framework for evaluating these initiatives.

Shu-Yi Oei

Works

The New World of International Tax

The Offshore Tax Enforcement Dragnet

The Trouble with Gig Talk: Choice of Narrative and the Worker Classification Fights

Taxing Bankrupts

World Tax Policy in the World Tax Polity? An Event History Analysis of OECD/G20 BEPS Inclusive Framework Membership

Legislation and Comment: The Making of the §199A Regulations

Constituencies and Control in Statutory Drafting: Interviews with Government Tax Counsels

Tax Issues in the Sharing Economy: Implications for Workers

Is New Code Section 199A Really Going to Turn Us All into Independent Contractors

Tax Law's Workplace Shift

Can Sharing Be Taxed?

The New Human Equity Transactions

Can Sharing Be Taxed?

Leak-Driven Law

The Importance of Qualitative Research Approaches to Gig Economy Taxation

"Slack" in the Data Age

When Data Comes Home: Next Steps in International Taxation's Information Revolution

Human Equity? Regulating the New Income Share Agreements

The Tax Lives of Uber Drivers: Evidence from Online Forums

Regulating in Pandemic: Evaluating Economic and Financial Policy Responses to the Coronavirus Crisis

.repo-1h6ne0y{background:#ffffff;text-transform:uppercase;padding-right:1.5rem;}.repo-1h6ne0y:after{content:'';position:absolute;background:#adadad;transform:translateY(-50%);top:50%;left:0;width:100%;height:0.1rem;z-index:-1;}Works

.repo-96qggn{color:inherit;text-align:left;font-weight:500;line-height:2.3rem;font-size:1.8rem;overflow-wrap:break-word;-webkit-box-orient:vertical;display:-webkit-box;-webkit-line-clamp:4;overflow:hidden;hyphens:auto;}.repo-96qggn:hover{color:inherit;}The New World of International Tax

Works

The New World of International Tax