This Essay examines Congress’s design of territorial revenue systems during 1898-1900. Eager to protect the federal fisc, lawmakers instituted tariffs between Puerto Rico and the mainland. Their choices segregated the territories from the federal fiscal apparatus, prompted the Insular Cases, and created the territories’ distinctive tax status as foreign countries.

- The Yale Law Journal

- VOLUME 134

Alex Zhang is an Assistant Professor of Law at Emory University School of Law, specializing in federal taxation, tax policy, administrative law, and the legal history of U.S. territories. He teaches courses including Federal Income Taxation, Corporate Taxation, and Partnership Taxation, as well as seminars that explore tax policy through historical, comparative, and philosophical lenses.(alextzhang.com, law.emory.edu)

Zhang's scholarship focuses on the intersection of taxation and democracy. His recent works delve into topics such as fiscal citizenship and taxpayer privacy, the origins of U.S. territorial taxation, and the constitutional framework governing Congress's authority to tax unrealized gains. His research has been published in leading law journals, including the Columbia Law Review, Cornell Law Review, NYU Law Review, Virginia Law Review, Stanford Law Review, and Yale Law Journal. Notably, his work has been cited by the U.S. Supreme Court in Moore v. United States, a significant case concerning federal taxing power.(law.emory.edu, alextzhang.com)

In addition to his legal scholarship, Zhang has an interest in classical political theory. He has written on topics such as ostracism in ancient Athens and its relevance to modern democratic practices, as well as the concept of damnatio memoriae and its parallels in contemporary movements like Black Lives Matter.(law.emory.edu, alextzhang.com)

Prior to joining Emory, Zhang clerked for Judge William A. Fletcher on the U.S. Court of Appeals for the Ninth Circuit and Judge Guido Calabresi on the Second Circuit. He earned his J.D. from Yale Law School, where he served as Managing Editor of the Yale Law Journal and received the Clifford L. Porter Prize in Taxation. He also holds a Ph.D. in Classics and Philosophy from Yale University.(law.emory.edu, alextzhang.com, law.emory.edu)