BC Law Magazine sat down with Professor Diane Ring, who was recently named the inaugural Marianne D. Short and Ray Skowyra Professor. An internationally recognized scholar on international taxation, corporate taxation, and ethical issues in tax practice, Ring is also co-author of an important forthcoming article in the emerging area of international cooperation on corporate taxation, “Global Tax Decluttering.” We talked about her work, what led her to pursue it, her time as interim dean of BC Law, and more.
To start off, let’s get a sense of what started you on your professional journey to tax expert—a career not usually found on top 10 lists of professions children would like to have when they grow up. Can you tell us a bit about what led you down this path?
I am not sure I can draw a straight line, or even a curving one, from my childhood to the tax profession, which is as you suggest—no surprise. In fact, I have found that many tax lawyers had no sense that this field would be their ultimate passion. They entered law school with different ideas or perhaps a general sense of exploration, but somewhere along the line it was tax law that drew them in.
Personally, I had always been fascinated by different places, different worlds, different systems. I think this initially led me to pursue an undergraduate degree in anthropology/archaeology. In deciding to go to law school, I had some vision of pursuing research in law and anthropology. As I began to think more directly about practicing law, I explored several fields in my first summer after law school and fell in love with tax law. I do think my decision to focus on international tax reflected my longstanding fascination with exploring the world, both current and past.
My interest in ethics emerged gradually over time as I began to appreciate in a more nuanced way the kinds of pressures placed on the tax system, the risks from those pressures, and the critical role played by tax advisors in ensuring a tax system that is functional, consistent, fair, and effective. The tax system lies at the heart of any democracy, and while there are many different possible designs, a failure to engender adequate trust in the general fairness of the system is universally problematic.
This summer marks your 20th year at BC Law. What drew you and has kept you here?
BC Law has a long-standing reputation as a leader in tax law, especially international tax, so, of course, I was very drawn to the institution and its faculty. But I was also aware that the school was deeply invested in its role of training the next generation of the legal profession and in ensuring that they understood the power and potential of law in the broader society. Once here, I became enmeshed in the entire community and found BC Law to be everything I had anticipated. The staying was obvious—the Law School is a really robust institution that is able to articulate what defines it and what is important to it and that through-line remains unchanged. But simultaneously, the Law School is forward looking which means that it is not exactly the same place it was 20 years ago. And it is this combination that continues to inspire me as a faculty member here.
Aside from your many accomplishments in teaching, research and writing, which includes three casebooks to date, you also served as interim dean at BC Law. This was for about a year and a half from 2021 to 2023 after former dean Vince Rougeau departed to become president of the College of the Holy Cross, and before the appointment of current dean Odette Lienau. What was that experience like for you, and did it change your perspective on law school education at all?
First, I will say that it was an amazing opportunity to see another side of BC Law. I had been associate dean previously, once just before becoming interim dean, and also about 10 years earlier. From those associate dean experiences, I had been exposed to and engaged with many facets of running a law school. But jumping to the dean role introduced me to the full scope of the operations that had been less central to my work before, including building and infrastructure, staffing, budgeting, accreditation, alumni engagement, and university relations. Moreover, the 2021-2023 period included the return from COVID, the largest ever 1L class, and our ABA accreditation, along with a host of other major projects.
Personally, it was exciting to be able to sit down with my associate deans and other integral law school colleagues and map out a vision for our interim period that would place BC Law in the best position possible for the arrival of our new dean.
I am not sure that the experience changed my perspective on legal education per se, but it certainly broadened it. I benefited from working with other deans across the country and gaining their perspective on a range of challenges that both law schools and law students are facing. What I would say is that the key elements of legal education—the ability to engage in critical thinking about legal issues and legal materials and to articulate that thinking through very effective writing—remain the heart of legal education.
Combined with the additional, less tangible, but no less essential, skills of client advising and ethical decision making, they together map the ongoing heart of legal education. But important and exciting developments are emerging as AI becomes more deeply integrated into businesses, government, and the work of the lawyer. In my Tax Concentration Seminar this semester, we will be working with tax lawyers in practice to get a sense how AI is being brought into the practice of tax law.
You have been engaged in a variety of projects regarding whistleblowers in the private and public sectors. This work seems as important as it has ever been. Can you tell us a bit more about it?
Whistleblowers play a vital role in any community, ranging from a single business, to a government agency or regulator, to political leadership of a country. Important whistleblower disclosures have identified significant corruption, large-scale tax evasion, serious food safety violations, and even failures of political leaders to make required disclosures of financial and other interests. Even in such cases of vital disclosures, the whistleblowers themselves face significant reputational, financial, career, and mental health harms from their decision to come forward.
Although these whistleblower issues are not directly connected to my work in legal ethics, there are important connections and sometimes direct overlaps. I have engaged in a variety of projects related to whistleblower issues, including my role as member of the Scientific Advisory Board to the Corporate Crime Observatory, as a special advisor to the VIRTEU project (an 18-month legal research project funded by the EU under the HERCULE III programme), and as a co-convener of many roundtables and conferences (some of which were part of a research projected funded by NATO’s Public Diplomacy Division).
In the course of this work, we engage with whistleblowers, journalists, lawyers, public officials, law enforcement, nonprofits and other researchers. Although the current legal regimes across jurisdictions have generally been inadequate to protect whistleblowers, those working in the field are developing interesting ideas and systems for ensuring that critical information is not kept quiet and that whistleblowers need not risk everything personally to make that disclosure, whether internally or externally.
At the domestic level, you have written about controversial topics at the intersection of tax law and higher education. One example was when Purdue University launched an initiative called an income share agreement, which was an arrangement where it would cover the costs of higher education in return for a percentage of a student’s future earnings. Purdue insisted it was not a loan per se, but the Department of Education under the Biden administration effectively disagreed and Purdue ultimately rescinded the program. Where do you see this issue headed with increasing pressure on institutions of higher education on multiple fronts?
More than 10 years ago, my co-author and I began looking at an emerging area of “financing” broadly labeled as income share agreements (ISAs)—or more colloquially, “human equity.” The underlying idea drew upon the observation that corporations have multiple financing options available—specifically debt and equity. Investors in a corporation seeking minimal risk (and minimal upside) would take traditional debt terms in their investment of funds in a company. In contrast, other investors, who thought they “saw” something special in the business, might be willing to contribute their money in exchange for stock—essentially sharing in the future success or failure of the venture.
But what about financing for people? Debt was already an option for individuals seeking cash. But what about an investment in a person comparable to corporate equity—something akin to saying, “I believe in your future, here is some money, and if you do well, we will share the fruits.” This idea began to grow in the context of funding for education, as well as funding individual business start-up costs, or acquiring a stake in a high-profile (or hoped to be high-profile) athlete.
In 2012, one business introduced a financing model in which investors could fund individuals seeking support for their education or business in exchange for receiving a share of that individual’s earnings over a period of time. Ultimately, this model of financing was retired and replaced with traditional debt—and among the reasons were the host of legal questions surrounding these income share agreements.
In the intervening years, a number of universities developed their own versions of income share agreements. You mentioned Purdue, which was well known for its “Back a Boiler Income Share Agreement Fund.” Others pursued this idea, including the University of Utah, Clarkson University, and Colorado Mountain College.
These programs have struggled, in part for legal reasons, in part for operational reasons, and—in the university context—in part for some education policy reasons. For example, some ISA providers sought to limit fields of study to STEM or nursing. Even for those ISA providers casting a wider net, questions emerged about the terms that would be made available to, say, an English Lit major as compared to an Engineering major.
But returning to the heart of your question—yes, the cost of higher education is a driving force in encouraging students, families, and universities to explore multiple and alternative ways to finance higher education—and that pressure has not abated. We have also seen versions of this financing model in some federal government income-based loan repayment plans. Even if they do see a resurgence and become more widely available, income share agreements could, at best, be only one of many tools for responding to education costs.
Turning to international issues: In 2021, 130 countries agreed to implement a global minimum corporate tax rate of at least 15 percent on the largest 100 multinational companies, designed to prevent tax avoidance by these companies that often manipulate loopholes in laws to seek lower tax rates where they may be found. Though still subject to ratification in each signatory country’s legislature, the agreement was widely lauded as a landmark example of international cooperation on taxation. What has happened since then and what are the current major challenges to attaining a fairer international tax regime?
Wow. I am not sure where to begin. Aside from US tariff policy (which is in part connected to the global minimum tax issues), this is one of the major topics of international tax today. As a starting point, we did see a number of countries bring their domestic implementation of the global minimum tax into effect in 2024, with others scheduled for rollout over the next few years. This list of countries does not include the United States, which is not directly participating in this global minimum tax, but which reached a “shared understanding” at the G-7 summit in June 2025 to create a US carveout from these minimum tax rules. The carveout was based on the US having other related rules, essentially creating a “side-by-side system.” The ultimate impact of this June 2025 understanding remains to be seen as it did not include all of the countries that originally “agreed” to the global minimum tax.
As to cooperation and fairness in international taxation, that is more hotly debated than the US carveout. My co-author and I recently explored some of these issues in examining the call by many countries for the UN to play a greater role in global tax policymaking going forward (beyond its noted role in drafting the UN Model Income Tax Treaty). In a recent article, we focused on identifying a range of drivers underlying this call and underlying the less than full appreciation of the issue by other countries and organizations. Now that this call for greater UN action in tax policy development has met with some success—in December 2024 the UN General Assembly approved a Resolution for negotiating a UN Framework Convention on International Tax Cooperation—we are continuing to track the new work on tax cooperation centered at the UN.
I see that you have co-authored many articles with Shu-Yi Oei, now on faculty at Duke Law and formerly at BC Law. This includes your forthcoming “Global Tax Decluttering,” which looks at efforts to eliminate some existing domestic tax laws worldwide in the wake of the corporate minimum tax agreement referenced above. What are the two of you able to do together that has resulted in such prolific co-authorship?
By working together, we can more quickly and effectively push and test our ideas and arguments. We have similar enough legal perspectives to write articles that offer a single coherent voice, but we are different enough to be able to challenge each other as we develop our analyses. Additionally, we have similar work styles, which allows the pace of our projects to move forward in ways that work well for both of us—and provide a bit of accountability. And you can’t forget humor. To work continuously with someone on many projects over the years, you need to have a shared sense of humor!
In that forthcoming article, the two of you argue for a cautious approach by countries when responding to these often-external pressures to reform their tax laws with an ostensible eye toward simplification and efficiency. Can you talk a little about how you arrived at this conclusion?
On the surface, who does not want a simple and efficient tax system? Who raises their hand for complexity and inefficiency? But digging a little deeper into what has been a chorus for “tax decluttering” reveals that what may sound like appealing legislative and regulatory reform is perhaps something else.
The story starts back a few years, as the global tax agreement (the minimum tax) you raised earlier, was being agreed to by over 140 countries. Part of the vision behind the minimum tax is exactly what it sounds like, a minimum tax that all covered large multinationals would be paying somewhere. The expectation was that with this new regime in place, large multinationals would not be able to maneuver around the tax system any longer.
We soon started to see various global actors advising countries to “declutter” their tax system and repeal existing domestic anti-abuse rules now that the world had agreed to the new global minimum tax. The claim was that these old domestic regimes were redundant and were no longer needed to ensure that these taxpayers did not avoid paying tax—moreover, their continued existence would create unnecessary tax compliance work on both taxpayers and governments.
How would this be a problem? This call for decluttering was before the global minimum tax was in effect anywhere, much less tested. And already, some tax policy observers had identified potential and significant weak spots in the new regime. Additionally, the reach of the global minimum tax was limited, only covering the largest multinationals. Many other global taxpayers capable of quite sophisticated tax planning would remain beyond the orbit of the new minimum tax. What would govern them if the old anti-abuse rules were eliminated?
As we pulled back the layers of the decluttering arguments, it became apparent that a number of intersecting political economy stories were likely driving the call—that is, different actors saw strategic advantage in having many countries reduce or eliminate anti-abuse provisions in their domestic law. Accordingly, domestic decluttering carries with it important strategic risks in a transnational context. We sought to more explicitly articulate the likely motivations, risks, and benefits, and then to map a tempered approach that recognizes the value of decluttering in some contexts, drawing on prior theory regarding obsolete legislation.
Finally, to conclude, let me add my congratulations to you on being named the Marianne D. Short and Ray Skowyra Professor at BC Law! A well-deserved honor.