Richmond Home
 Hayes Ragland Holderness
Hayes Ragland Holderness
Associate Professor of Law
Courses Taught Tax Law

Hayes Holderness is an expert in the field of state and local taxation. His scholarship, which primarily focuses on the political, historical, and constitutional forces that shape state and local tax systems, has been published in the University of Chicago Law Review, the Virginia Tax Review, the Florida Tax Review, and Professor Richard D. Pomp’s leading casebook, State and Local Taxation. He is also consistent contributor to outlets such as State Tax Notes and TaxProf Blog. Prior to joining academia, Professor Holderness practiced tax law at McDermott Will & Emery LLP in New York, New York. He also served as a Tax Policy Fellow for the United States Congress’ Joint Committee on Taxation, where he assisted in the drafting and analysis of proposed federal tax legislation.

Presenter, "Insidious Regulatory Taxes," New Voices in Taxation, AALS 2021 Annual Meeting, Association of American Law Schools (January 2021)
Presenter, "Hate the Sin, Tax the Sinner," Junior Tax Scholars Workshop, University of Utah S.J. Quinney College of Law (October 2020)
"The Tax System and Social Policy," ABA Webinar, American Bar Association (October 2020)
"Cracking Judicial Deference for Regulatory Taxes," SEALS New Scholars Workshop, Southeastern Association of Law Schools (August 2020)
"State Tax Effects of Federal Tax Reform," Texas Society of CPAs Annual Summit, Texas Society of CPAs (August 2020)
Panelist, "Indirect Effects of Wayfair," National Association of State Bar Tax Sections 40th Annual Meeting, National Association of State Bar Tax Sections (October 2019)
Presenter, "Legislative Evasion through Tax," Junior Tax Scholars Conference, University of Richmond School of Law (June 2019)
Presenter, "Legislative Evasion through Tax," Junior Faculty Forum, University of Richmond School of Law (May 2019)
Presenter, "The State of State Tax Planning," ABA Tax Section Meeting, ABA Tax Section (May 2019)
Presenter, "Navigating 21st Century Tax Jurisdiction," Faculty Colloquium, Temple Law School (March 2019)
Bar Admissions
New York Bar
Professional Experience
Associate Professor of Law (2020 - present)
University of Richmond School of Law, Richmond, VA
Assistant Professor of Law (2017 - 2020)
University of Richmond School of Law, Richmond, VA
Visiting Assistant Professor of Law (2015 - 2017)
University of Illinois College of Law
Tax Associate (2012 - 2015)
McDermott Will & Emery LLP, New York, NY
Tax Policy Fellow (2011 - 2011)
Joint Committee on Taxation, United States Congress, Washington, DC
Journal Articles

Changing Lanes: Tax Relief for Commuters, Virginia Tax Review (2021).

Navigating 21st Century Tax Jurisdiction, 79 Maryland Law Review 1 (2019).

Questioning Quill, 37 Virginia Tax Review 313 (2018).

The Case for Preempting SALT Cap Workarounds, 89 State Tax Notes 737 (2018).

The Unexpected Role of Tax Salience in State Competition for Businesses, 84 University of Chicago Law Review 1091 (2017).

Taxing Privacy, 21 Georgetown Journal on Poverty Law and Policy 1 (2013).

Note: Price Includes Tax: Protecting Consumers from Tax-Exclusive Pricing, 66 New York University Annual Survey of American Law 783 (2011).

Book Chapters

Revenue Departments' Cloudy Minds Lead to Wrong Answers (Revised), in State and Local Taxation (Richard Pomp, ed.) (2019) (originally in New York University Institute on State and Local Taxation, Matthew Bender & Co., 2013).

Report on State and Local Taxes Implications of the Federal Tax Cuts and Jobs Act of 2017, in American Bar Association Tax Section State and Local Tax Committee (2018).

Blog Posts

Holderness Reviews New Technologies and the Evolution of Tax Compliance, TaxProf Blog (May 2020).

Magazine/Trade Publications

Citrix and the Non-Legislated Rewrite of Massachusetts Law, 95 Tax Notes State 735 (with Arthur Rosen) (2020).

Wayfair's Warning for Inappropriate Tax Planning, 92 State Tax Notes 507 (with Sherfón Coles-Williams) (2019).

Congress Should Sprinkle Some SALT on the Federal Courts, 89 State Tax Notes 329 (with Arthur Rosen) (2018).

In Defense of the Physical Presence Rule, but Not for Use Tax, 87 State Tax Notes 981 (2018).

In the News

Trump's Seven Springs Property Could Be Subject to SALT Cap (Tax Notes - Premium)
Tue., Sep. 29, 2020

Equal Protection and the Railroad Revitalization and Reform Act (Tax Notes - Premium)
Mon., Aug. 3, 2020

NY Bill Seeks Tax Up To 10% On Targeted Digital Ads (Law360 - Premium)
Mon., Mar. 16, 2020

States Face Uphill Battle In Attempts To Tax Digital Ads (Law360)
Tue., Feb. 11, 2020

State court action (Politico)
Fri., Jan. 31, 2020

Final SALT Rules Could Save Scholarship Fund, Parents Tell IRS (Bloomberg Law: Tax)
Tue., Jan. 7, 2020

States Face Uphill Battle to Ditch the SALT Cap in 2020 (Bloomberg Law: Tax)
Thu., Dec. 26, 2019

DoorDash and Uber Eats aren't collecting sales tax on delivery fees in some states. That could be a problem. (Vox)
Wed., Nov. 20, 2019

Not All Candy is Created Equal -- At Least for Tax Purposes (TIME)
Thu., Oct. 31, 2019

States Turning To Economic Nexus To Extend Biz Tax Reach (Law360)
Fri., Oct. 11, 2019

Top 5 State & Local Tax Cases Of 2019: Midyear Report (Law360)
Wed., Jul. 3, 2019

SALT Battle Lines to Watch With IRS Rules Nearing (Bloomberg Law)
Tue., Jun. 4, 2019

Colorado Supreme Court Rules for Taxpayers in Water's-Edge Cases (Tax Notes)
Wed., May. 29, 2019

Sovereignty Ruling Emboldens States To Push Taxing Bounds (Law360)
Tue., May. 14, 2019

Supreme Court Again Overturns Precedent in Ruling for States (Tax Notes)
Tue., May. 14, 2019

Ill. Bill Would Deny Tax Credit To Jussie Smollett Employers (Law360)
Wed., Mar. 27, 2019

Poor Richmonders Would Be Hit Hardest By Cigarette Tax, Experts Say (WCVE)
Thu., Mar. 14, 2019

Justices Raise Bar On State Tax Discrimination In W.Va. Case (Law360)
Thu., Feb. 21, 2019

Justices' lean toward states' rights boosts taxing powers (Law360)
Wed., Nov. 21, 2018

MTC plans white paper, no post-Wayfair model, panelist says (Law360)
Fri., Oct. 26, 2018

Mega Millions winner faces massive tax bill (Bloomberg BNA)
Wed., Oct. 24, 2018

IRS notice on SALT workarounds causes more confusion (Law360)
Thu., Sep. 6, 2018

Kavanaugh not a Kennedy: Supreme Court nominee scarce on tax (Bloomberg BNA)
Wed., Sep. 5, 2018

State will push marketplace tax collection duties, experts predict (Tax Notes)
Thu., Jul. 26, 2018

4 constitutional questions to ponder in a post-Quill world (Law360)
Fri., Jun. 29, 2018

Etsy's reset (and its discontents)
Wed., Jun. 27, 2018

Did the Supreme Court just save brick and mortar retail? (Points and Figures)
Fri., Jun. 22, 2018

Did the Supreme Court just save retail? (Globe St.)
Fri., Jun. 22, 2018

Etsy sellers confront unknowns after Supreme Court ruling (CNN)
Fri., Jun. 22, 2018

State sales tax collections finally move into the internet age (Route Fifty)
Thu., Jun. 21, 2018

Supreme Court widens reach of sales tax for online retailers (The New York Times)
Thu., Jun. 21, 2018

Will you have to pay sales taxes on your online purchases? (Kiplinger Alerts)
Wed., May. 2, 2018

The online sales tax debate has its day in the US Supreme Court (Digital Commerce 360)
Tue., Apr. 17, 2018

High court arguments in Wayfair may reshape internet sales (Law360)
Mon., Apr. 16, 2018

Supreme Court prepares to reconsiders limits on state, local tax authority (Route Fifty)
Mon., Apr. 16, 2018

Today's must-reads for entrepreneurs: Would Harold and Kumar eat an 'impossible slider'? (Forbes)
Mon., Apr. 16, 2018

Supreme Court considers whether states should have power to tax all online sales (The Washington Post)
Sun., Apr. 15, 2018

E-sellers' bid to keep Quill ignores case law, SD says (Law360)
Mon., Apr. 9, 2018

US asks to argue for internet state tax before high court (Law360)
Tue., Mar. 20, 2018

Internet sales taxes are just another government money grab (Hot Air)
Sun., Mar. 18, 2018

US' position that Quill isn't important raises eyebrows (Law360)
Thu., Mar. 8, 2018

High court signals interest in hearing 2nd state tax case (Law360)
Fri., Jan. 19, 2018

Justices likely to set new tax standard for remote vendors (Law360)
Mon., Jan. 15, 2018

The Amazon deal, according to an expert (The States)
Tue., Oct. 3, 2017

Navigating sales taxes in online markets (The Regulatory Review)
Wed., Sep. 20, 2017

Law Keeps Pennsylvania from Collecting Sales Tax from Many Online Retailers (The Morning Call)
Sat., Jun. 24, 2017

Amazon's Sales Tax Collection Deals Show Shift in Strategy, Legal Landscape (State Tax Today, premium)
Tue., Jan. 31, 2017

B.A., University of North Carolina
J.D., New York University School of Law 2011
LL.M., New York University School of Law 2012
Contact Information
Room 250, Law School
(804) 662 3071
(804) 289 8992 (Fax)
Areas of Expertise
Tax Law
State and Local Taxation