Richmond Home
 Hayes R. Holderness
Hayes R. Holderness
Assistant 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, "The State of State Tax Planning," ABA Tax Section Meeting, Washington D.C. (May 2019).
Presenter, "Navigating 21st Century Tax Jurisdiction," Faculty Colloquium, Temple University Beasley School of Law, Philadelphia (March 2019).
Commentator, "Tax Limits and Public Control," Tax Policy Colloquium, Loyola Law School, Los Angeles (Nov. 2018).
Presenter, "South Dakota v. Wayfair: Its Immediate Meaning and its Future Implications," National Association of State Bar Tax Sections 39th Annual Meeting, San Francisco (Oct. 2018).
Commentator, "Optimal Tax Theory as a Theory of Distributive Justice," Colloquy Series, University of Richmond School of Law (Sept. 2018).
Presenter, "Whither Transactional Nexus?," Junior Tax Scholars Conference, University of Colorado Law School (June 2018).
Presenter, "Whither Transactional Nexus?," Mid-Atlantic Junior Faculty Forum, University of Richmond School of Law (May 2018).

Presenter, "Questioning Quill," The Ohio State University Moritz College of Law Summer Workshop Series (Aug. 2017).

Presenter, "Strategic Non-Enforcement," Big Ten Junior Scholars Conference, Indiana University Maurer School of Law (Aug. 2017).

Presenter, "'Other' Constitutional Issues," New York University Summer Institute in Taxation State and Local Tax Program, New York (July 2017).
Bar Admissions
New York Bar
Professional Experience
Assistant Professor of Law (2017-Present)
University of Richmond School of Law
Visiting Assistant Professor of Law (2015-2017)
University of Illinois College of Law
Tax Associate (2012-2015)
McDermott Will & Emery LLP, New York, New York
Tax Policy Fellow (2011)
Joint Committee on Taxation, United States Congress, Washington, D.C.

Navigating 21st Century Tax Jurisdiction, 79 Md. L. Rev. ___ (2019).

Questioning Quill, 37 Va. Tax Rev. 313 (2018). 

Taxing Privacy, 21 Geo. J. on Poverty L. & Pol’y 1 (2013).


Revenue Departments’ Cloudy Minds Lead to Wrong Answers (revised), in Richard D. Pomp, State and Local Taxation (8th ed. 2015), originally in New York University Institute on State and Local Taxation— 2013 (Matthew Bender & Co., Inc., pub.), at 6-1 (2013).

The workability of Pike balancing for sales and use tax collection obligations, The Surly Subgroup (April 2018). Excerpted in State and Local Taxation, Richard D. Pomp.

In the News

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

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

Ill. Bill Would Deny Tax Credit To Jussie Smollett Employers (Law360)
Wed., Mar. 27, 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 retail? (Globe St.)
Fri., Jun. 22, 2018

Did the Supreme Court just save brick and mortar retail? (Points and Figures)
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

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

High court arguments in Wayfair may reshape internet sales (Law360)
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

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