Theodore S. Sims

Professor of Law

AB, Columbia University
JD cum laude, University of Chicago Law School
PhD in Economics, Massachusetts Institute of Technology

Areas of Interest
Corporate Finance, Federal Taxation, Tax Law, Tax Policy
  • Office Room 1604A
  • Phone 617-353-2797

Following law school, Theodore Sims clerked for the Honorable John C. Godbold, of the United States Court of Appeals for the (then) 5th Circuit, practiced with (then) Wilmer, Cutler & Pickering, in Washington, DC, and served with the Office of Tax Policy of the United States Treasury. Upon leaving government service in 1981 he joined the faculty of the George Washington University Law School. While at GW Professor Sims completed a PhD in economics at MIT. He visited at the University of Michigan Law School in 1995, and joined the BU Law faculty in 1996. He visited at Harvard Law School in 2005.

Professor Sims’ areas of expertise include the taxation of capital income (including timing issues and the taxation of financial instruments), wealth transfer taxation, federal tax policy (including structural aspects of the tax system), and the effects of tax policy on inequality. He has taught federal income taxation, taxation of financial instruments, taxation of corporations and shareholders, tax policy, law and economics, social scientific methods, and trusts and estates. His current research interests include the taxation of cancellation of indebtedness income, the income taxation of risk, aspects of the taxation of financial instruments, and the treatment of deferral in general. His past work includes studies of the structure of wealth transfer taxation and structural aspects of tax shelters, as well as theoretical and econometric work on the relationship between tax-motivated trading and stock market returns.

Professor Sims has taught courses in discounting and the taxation of debt in the NYU/IRS continuing legal education program, in connection with which he developed materials on discounting that integrate the study of the present value fundamentals with the implementation of present value in computer spreadsheets, and apply those methods to understanding the taxation of debt instruments. He has served as a consultant to the US Treasury, has been a member of the American Law and Economics Association and is a member of the American Law Institute.

  1. Theodore Sims, "A Tale of Four Treatments: Preferential Taxation and Asset Valuation," Tax Law Review (forthcoming).
    SSRN | Scholarly Commons
  2. Theodore Sims, "Income Taxation and Asset Valuation (II) The Value of Preferential Taxation," 71 Tax Law Review 53 (2017).
  3. Theodore Sims, "Income Taxation, Wealth Effects, and Uncertainty: Portfolio Adjustments with Isoelastic Utility and Discrete Probability," 135 Economic Letters 52 (2015).
  4. Theodore Sims, "Capital Income, Risky Investments, and Income and Cash-Flow Taxation," 67 Tax Law Review 3 (2013).
    SSRN | Scholarly Commons
  5. Theodore Sims, "Qualified Conservation Restrictions: Recollections of and Reflections on the Origins of Section 170(h)," 33 Utah Environmental Law Review 41 (2013).
    HeinOnline (BU) | HeinOnline
  6. Theodore Sims, "Income Taxation and Asset Valuation (I): Economic Depreciation, Accrual Taxation, and the Samuelson Theorem," 66 Tax Law Review 217 (2012).
    HeinOnline (BU) | HeinOnline
  7. Theodore Sims, "Debt, Accelerated Depreciation, and the Tale of a Teakettle: Tax Shelter Abuse Reconsidered," 42 UCLA Law Review 263 (1994).
    HeinOnline (BU) | HeinOnline
  8. Theodore Sims, "Environmental 'Remediation' Expenses and a Natural Interpretation of the Capitalization Requirement," 47 National Tax Journal 703 (1994).
  9. Theodore Sims, "Long-Term Debt, the Term Structure of Interest and the Case for Accrual Taxation," 47 Tax Law Review 313 (1992).
    HeinOnline (BU) | HeinOnline
  10. Theodore Sims & Emil M. Sunley, review of Myron S. Scholes et al., Taxes and Business Strategy: A Planning Approach, Prentice Hall (1992), 45 National Tax Journal 451 (1992).
  11. Theodore Sims, James S. Halpern et al., "The Passive Activity Loss Limitation Rules: Where Are We Now? Part I," 12 Review of Taxation of Individuals 187 (1988).
  12. Theodore Sims, James S. Halpern et al., "The Passive Activity Loss Limitation Rules: Where Are We Now? Part II," 12 Review of Taxation of Individuals 291 (1987).
  13. Theodore Sims, review of Howard M. Zaritsky, Tax Planning for Family Wealth Transfers: Analysis with Forms, Warren, Gorham & Lamont (1985), 11 Review of Taxation of Individuals 89 (1987).
  14. Theodore Sims, Noel Cunningham & James S. Halpern, "Selected Problems on the Time Value of Money," in Time Value of Money Rules Under the 1984 Tax Act , Mortimer Maxwell Caplin, ed., Law and Business (1984).
  15. Theodore Sims, The Equity Return to Mutual Life Insurance Companies and Their Policyholders, paper submitted for Tax Treatment of Life Insurance: Hearings Before the Subcommittee on Select Revenue Measures of the House Committee on Ways and Means, 98th Cong. 1st Sess., at 591, Serial No. 98-39, (1983).
  16. Theodore Sims, "Timing Under a Unified Wealth Transfer Tax," 51 University of Chicago Law Review 34 (1983).
    HeinOnline (BU) | HeinOnline
  17. Theodore Sims, "Once More into the Breach: Promissory Estoppel and Traditional Damage Doctrine," 37 University of Chicago Law Review 559 (1970).
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