Category Archives: Uncategorized
Jul 14, 2023 Neil H. Buchanan
Why are gender and unpaid work issues continually marginalized in tax policy analysis? After all, feminist legal theorists have spent at least two generations trying to address questions that should be at the center of any analysis of government policy, no matter one’s political priors. People who want to turn the clock back to a 1950’s-style gendered hierarchy, for example, surely would want to know that their version of utopia (which, to be clear, I find positively dystopian) cannot possibly be created without understanding how government taxation and spending policies change people’s decisions about marriage and divorce, child-bearing and -rearing, the challenges of poverty (both sudden and chronic), and so on. Progressives are typically more aware of those connections, but somehow the “tax is different” mantra prevents many people from seeing that gender justice and tax justice are inseparable.
Miranda Stewart, a professor of tax law at the University of Melbourne, has long carried on important work to bring these issues to the fore. Her latest book, Tax & Government in the 21st Century, is a masterwork that covers the full range of issues that confront us, from savings and wealth, to corporate and business taxation, to the global digital economy, and every important issue in between. She builds her book on historical and philosophical foundations, discussing Adam Smith and the interactive development and evolution of states and capitalism (of various varieties). Confronted with a veritable buffet table of enticing potential topics to savor in this short review, I find that her most profound contribution (among many) is in Chapter 5, “Tax, Work, and Family.”
Most books that have attempted the daunting task that Professor Stewart tackles here with such grace have, like much of the literature in this field more generally, tended to treat gender and family issues as a niche topic, as I noted above. In this book, those issues are given equal airtime with classic tax policy topics like capital gains taxation or international jurisdictional disputes. That makes sense, of course, because Professor Stewart is deeply familiar with feminist legal theory, even as she has expertise across the range of topics that she covers in this book.
She begins by defining the “tax state” as having the power to tax but also being dependent on taxation to fund its own activities, noting that wealthier countries, including most of the members of the Organization for Economic Cooperation and Development (P. 3), are tax states. How have those countries’ tax and expenditure systems responded to, and in turn changed, people’s experience of gender and family issues, paid work, and the unpaid work of providing for those who need care? Professor Stewart demonstrates that these issues should be at the front of everyone’s mind, especially policymakers whose decisions (even when they decide to leave policies unchanged) will alter the future.
A particular strength in Chapter 5 is the impressively brief explanation of a fundamental question in all of tax analysis, the “tax unit.” This is where feminist tax theorists have had a significant impact (one that should be even greater, to be sure), because it matters enormously whether the state taxes a “family unit” as a collective entity or instead taxes each individual person within society – no matter their family status – as a solo unit. Professor Stewart offers this summary of the intellectual history of this insight:
Feminist tax theorists pioneered a tax discrimination analysis that argued for an individual unit on efficiency and equity grounds. A key reason or this trend was changing demographic patterns, especially the increased participation of women in the workforce.
The rules about the tax unit, combined with personal and family exception, allowances and transfers, mark a gendered boundary between the ‘taxed’ market and ‘untaxed’ private or domestic family life. Home production is not subject to the income tax, although in a comprehensive income tax applied to individuals, it would be. (P. 126.)
This sleek, stripped-down prose communicates matter-of-factly what is in fact a rather revolutionary thought to a lot of people: there is no “natural” default when it comes to setting up a tax system, even on one of the foundational questions of tax policy: Who will be required to pay taxes? And the choice that we make affects social choices, as Professor Stewart goes on to explain, by changing the marginal tax rates faced by different people, depending on whether their partners’ or spouses’ tax situations are included in their own computations. She concludes:
It is estimated that in Germany and Belgium, moving from a joint tax unit [taxing a couple] to an individual tax unit [taxing each person in the couple separately] would increase women’s work hours by 25 to 35 per cent. In response to these findings, the European Parliament has called for the elimination of joint or family-based provisions in the tax laws of all EU member states and their replacement with individual based rules. (P. 127.)
This analysis is supplemented by an explanation of how eligibility rules for parental leave, child-care costs, fighting discrimination against fathers who take parental leave, child credits (which are now the method by which the US tax code subsidizes child-rearing costs, after the repeal of personal exemptions as part of the most recent major tax legislation in the US took effect in 2018), and other purportedly pro-family policies interact with the “tax unit” question in unexpected ways. She reports that “[a]cross the OECD, women’s careers are one third shorter, on average, than men’s and are much more likely to involve part time work.” (P. 128.)
The analysis in Chapter 5 builds on a discussion earlier in the book on budgeting, which includes a discussion of how governments’ summaries of their budgets can highlight gender imbalances. Professor Stewart describes “Gender Budgeting” (Pp. 71-72) as a way to highlight how these nominally neutral tax and spending policies affect people unexpected ways – ways that would otherwise be erased through the use of supposedly “gender-blind” budget summaries.
While it is not quite accurate to say that the tax-policy book market is a crowded one, there are surely plenty of perfectly fine books from which to choose, all of which cover the standard topics (tax base, international tax, wealth taxation, and so on) well enough. What makes this book stand out is not only its breadth and readability but a keen focus on how our tax system can have hidden impacts on people – and bringing those impacts into the light.
Jun 19, 2023 Adam Rosenzweig
Steven Dean,
Surrey’s Silence: Subpart F and the Swiss Subsidiary Tax that Never Was, Brooklyn L. Sch., Legal Stud. Paper No. 728, available at
SSRN (Mar. 28, 2023).
As has become almost cliché at this point, the international tax regime is facing a defining moment … spearheaded by the Base Erosion and Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD). While BEPS addresses a wide-ranging number of topics, one of its primary focuses is combating tax havens. BEPS is the successor to the 1998 OECD Harmful Tax Competition project which, unlike the wide ranging BEPS, focused almost exclusively on a “name-and-shame” campaign against tax havens. These anti-tax haven efforts can trace their history back to the enactment of “Subpart F” of the Internal Revenue Code which is typically considered the first concerted anti-tax haven effort. The intellectual force behind Subpart F was Assistant Secretary of Treasury for Tax Policy Stanley Surrey (while he was on leave from the faculty at Harvard Law). Surrey has been referred to as the greatest tax lawyer of his generation; his influence can be felt to this day throughout the tax laws of the United States and the world.
In the face of this towering presence, Steven Dean dares to ask the question “Was Surrey racist?” in his new article Surrey’s Silence: Subpart F and the Swiss Subsidiary Tax that Never Was. This question is not buried in a footnote or even in the final section but is the first three words of the abstract. The effect is palpable, in part because the reader is forced to consider the provocative question in a vacuum without the benefit of reading the article itself. As with all good use of rhetorical hyperbole, Dean effectively employs strong language to shake the reader’s assumptions and open space to consider a difficult topic in a deep and subtle way.
Dean deftly works within this newly opened intellectual space to introduce the broader thesis of the article – is it possible that the international tax regime as a whole could be imbued with implicit bias from its founding? The argument (substantially simplified) goes as follows: (1) Surrey and his team began the Subpart F project focused specifically and primarily on Switzerland. which was the jurisdiction of choice for the largest US corporations seeking to avoid or evade US taxes; (2) by the time Subpart F was signed into law, Switzerland had disappeared from the legislative narrative; and (3) in its place a new narrative had emerged focusing mostly on small, Caribbean island nations as so-called tax havens.
The article utilizes the so-called “Liberia problem” developed in earlier work as an illustrative example. In summary, the article explains how Liberia was included on one of the first iterations of lists of abusive tax havens, without any tax-related justification. Despite repeated efforts, neither Liberia nor academic tax experts could get Liberia removed from the list, despite consensus that there was no substantive reason for its inclusion. It was not until extraordinary efforts were undertaken by the United States that Liberia was eventually removed from the list. At first it might not seem clear what this has to do with Stanley Surrey, and I think ultimately that is the point. From this perspective, the Switzerland example and the Liberia example stand in stark contrast. There was overwhelming evidence of Switzerland’s role as a tax haven, yet all mention of it was scrubbed from the ultimate version of Subpart F. In contrast, there was no evidence of Liberia’s role as a tax haven, yet overwhelming efforts were necessary for it to be removed from a list of tax havens. The article leaves the reader to sit in that contrast, forced either to attempt to intellectually rationalize the two examples or yield to Occam’s Razor and admit the obvious racial difference.
This epiphany unifies the paper, and the opening rhetorical question slowly begins to take shape in context. Was Surrey racist? Does it matter? Or might the better question be – did Surrey’s legacy manifest itself as implicit racial bias throughout the international tax regime? Regardless of Surrey’s actual beliefs, the article highlights that today there is no doubt that the term “tax haven” in fact invokes visions of beaches in the Caribbean and not snow in the Alps thus raising the question – why does virtually every academic article use the Cayman Islands or Bermuda as examples of a tax haven rather than Switzerland or Ireland?
Under this framework, the article then narrows focus from the regime as a whole to the term “tax haven” itself. Since at least the 1998 OECD Harmful Tax Competition project the term “tax haven” has been explicitly associated with “harmful” competition. In fact, the “tax haven” label has been used consistently as a cudgel; today merely being labeled a “tax haven” can be enough to force changes in policy. But what if the term is also tainted with implicit racial bias (in the sense of a bias against applying the label to majority-white countries)? In that case, the conclusion quickly emerges that explicit normative association of “tax haven” with “bad” can construct an implicit and powerful association of “bad” with majority non-white countries.
While reading the article I found myself repeatedly thinking, “if someone as brilliant as Surrey couldn’t recognize his own implicit bias, then what chance do I have?” Rather than feel hopeless, however, I found the internal dialogue inspiring. What if the one crucial difference between Surrey and myself is precisely that I am having this internal dialogue? In this respect perhaps the greatest strength of Dean’s article is its ability to engage a reader in such a dialogue, and thereby invite the reader to join the difficult, at times painful, and ultimately crucially important life-long conversation the world needs.
May 18, 2023 Kim Brooks
The hard work that went into authoring The Administrative Foundations of the Chinese Fiscal State is palpable from the first page. Cui seeks to achieve two aims: (1) to tease out aspects of Chinese taxation of general interest to policy makers and social scientists in other countries (P. 3) and (2) to offer a new framework for understanding the policies and politics of taxation in China (P. 4). Both aims are accomplished handily.
Particularly fun for those of us who like tax administration, Cui claims that ground-level tax administration is essential to understanding the Chinese tax system. Focusing on tax administration, tax collection and revenue mobilization, allows Cui to show us something new about our own tax systems. He offers us the opportunity to see more clearly our own paradigmatic orientation: one that centres the importance of rule of law.
Instead of accepting standard stories – that third-party reporting will reduce evasion, that offering incentives to tax administrators will facilitate greater collection of tax revenues, and that boosting taxpayer morale and enhancing audit capacity will result in greater revenue collection – Cui explores how the Chinese tax administration has managed to enhance its gross tax ratio without relying on the standard advice.
Perhaps most fascinating for those of us used to the dominance of “rule of law” as a necessary feature of a functioning social order, Cui’s work demonstrates that “a state that is organized, peaceful, and in many ways compatible with modern market economies may nevertheless largely dispense with legal norms” (P. 18). Cui’s bold claim that “law may be an inessential instrument for governance” (P. 18) is likely to make some of us squeamish. Such a fundamental challenge to our narratives about the importance of law in tax (or any other subject) is absolutely worth reading.
If the broad claim (about the relative unimportance of law) gives us pause, it’s possible that Cui’s exploration of the practices of tax administration in China might be recast in ways that nevertheless affirm our sense of the importance of “law”. Cui’s book offers a deep dive into the practices of tax administrators. For those of us inclined to legal pluralism as a paradigm, tax administration practices are law – just not formal law “on the books”. Put another way, in the space left by formal legal rules, Cui finds hundreds of thousands of non-specialized revenue managers in tax administration.
I admit to having carried Cui’s book with me on many flights intending to read it and yet feeling daunted, but once I got started I could not put the monograph down. It is filled with fascinating insights: from an exploration of how China’s revenue management system persisted through the importation of substantial legal reforms in the mid-1990s to an examination of how “audit” is a misnomer for the kinds of activities undertaken by tax administration personnel (which is more like a “self-inspection” or tax amnesty process). Cui develops a concept of “atomistic coercion” (a kind of non-rule-based tax collection practice exercised by individual tax administration personnel). He dives into what he calls the “paradox of taxpayer information”: that if you need good quality information to secure compliance it is likely unavailable and when that high-quality information is available you likely don’t need it. And his expertise on value added taxes, in particular, shines through (I suspect inadvertently, since the particularities of the formal tax system is not the direct focus of Cui’s work in this monograph).
In addition to Cui’s detailed and thoughtful analysis, another feature of the work that makes it a must read bears mention. Occasionally you get glimpses of Cui himself – for example, where he recounts stories of his own experiences teaching in China, meeting with tax administration personnel, or getting a foot massage. These stories gave me a much richer sense of how Cui came to build his theory of tax administration, policy making and politics. And his observations from his experiences enabled me to better see the thoughtfulness behind his questions and his approach to making sense of the Chinese tax system.
Apr 18, 2023 Jon Choi
Brian D. Galle & Stephen E. Shay,
Admin Law and the Crisis of Tax Administration, __
N.C. L. Rev. __ (forthcoming 2023), draft available at
SSRN (Jan. 27, 2023).
Tax regulations and subregulatory guidance abound with apparent giveaways to taxpayers, favorable interpretations with little or no statutory justification. Examples include the check-the-box rules, the waiver of 382(l)(5) net operate loss carryforward limitations during the financial crisis, and many more. On the other hand, it’s hard to think of cases where Treasury or the IRS has deviated from the statute at taxpayers’ expense. The typical explanation for this asymmetry is standing doctrine: if my tax bill is too high because of an agency rule, I can sue the government, but if it’s too low, nobody can sue to raise it. Now, a terrific new article by Brian Galle and Stephen Shay considers the implications of this “tilt against revenue” for administrative law.
Galle and Shay bring a fresh perspective to the classic debate on administrative tax exceptionalism. They suggest that the tilt against revenue cuts against the formalist, anti-exceptionalist position (most famously promoted by Kristin Hickman) that tax regulations should follow the same procedural rules that apply to all other regulations. Instead, they suggest that courts should counter-act the tilt against revenue by applying administrative law requirements more leniently to Treasury and the IRS.
To illustrate their arguments, Galle and Shay consider as case studies two regulatory interpretations of the GILTI rules, one pro-taxpayer and one anti-taxpayer. The pro-taxpayer regulation was lauded by comments submitted by interested parties and will likely never be challenged due to lack of standing; the anti-taxpayer regulation was heavily criticized (again by interested parties) and will likely be challenged in court. The article also helpfully summarizes existing literature on the standing asymmetry in tax law, written by scholars like Larry Zelenak and Daniel Hemel.
And although Galle and Shay begin with the problem of standing, they don’t end there. They catalog how a variety of current administrative conditions create a bias against the collection of revenue. For example, the current IRS resource deficit makes it difficult for existing tax regulations to be adequately enforced as written, making IRS action more difficult and further favoring taxpayers.
So what’s the solution? Galle and Shay essentially propose a thumb on the scale against taxpayers in tax administration, essentially a tilt toward revenue to counteract the existing tilt against revenue. They lay out some concrete suggestions relating to ongoing debates in administrative tax law: for example, they suggest that courts should be more lenient in declaring tax regulations “interpretive” and therefore exempt from notice and comment, and more generous in applying the exceptions to notice and comment for “good cause” or “harmless error.”
One of the article’s best features is that it deftly navigates the difficult line between normative and positive arguments. Many tax scholars may find Galle and Shay’s arguments persuasive as a normative matter but have lingering doubts as a matter of positive law. Consider the basic case against exceptionalist tax administration: the Administrative Procedure Act purports to apply to all agencies equally, and nothing in the statute justifies special treatment for the IRS. But as Galle and Shay argue, courts must make normative policy judgments all the time in tough cases, and their normative judgments are the basis of much of the common law surrounding the APA. Thus normative judgments are unavoidable, and perhaps even desirable, even when one takes a positivist view of statutory administrative law.
Whether you agree or disagree, Galle and Shay’s new article makes a valuable contribution to the literature on tax administration and is well worth a read.
Mar 8, 2023 Charlene D. Luke
In Taxing Data, Omri Marian argues that taxing data-rich markets requires rejecting income taxation—not only as implemented but also “in its optimal theoretical form”—as the best proxy for ability to pay. Instead, Marian makes the radical suggestion that data itself “may be a better proxy” for ability to pay, and he offers three fundamental features that should guide “a reimagined tax on data.”
The article is rich in detail and is at its most persuasive in discussing the income taxation of business entities. Drawing on the work of tax historians and scholars, Marian summarizes two dominant narratives explaining the origins of the corporate income tax: the corporate income tax as a proxy for shareholder income, and the corporate income tax as a means to rein in management. Marian points out that if corporate ownership and management is largely local and traceable, which it was “at the dawn of corporate taxation,” then “whether the attempt was to target shareholders’ ability to pay, or managerial interest, the taxation of corporate income made sense.”
On the horizon, however, was a perfect storm of globalization, dispersion, and “intangible-ization,” which, Marian asserts, “our data-rich economy amplifies by orders of magnitude.” These forces have now so completely swamped the corporate income tax’s ability to identify source or ownership and to measure value that it is time to “revisit our conceptual tax design.”
Dispersion, for example, is not only a matter of diffuse, multi-layered ownership, but it also “defines all other functions of the modern multinational corporate entity.” If corporate income taxation no longer operates “as a functional instrument to tax corporate owners or managers,” then there is “no substantively meaningful corporate ‘home’” to support residence-based taxation. Marian asserts further that, because “‘value creation’ is fragmented, outsourced, and facilitated through a multitude of intercompany transactions between affiliated companies,” “‘source taxation’ in the context of corporate entities seems equally meaningless.”
In turning to “intangible-ization,” Marian emphasizes that the “transformation of capitalism” wrought by intangible investment overtaking tangible investment has caused “insurmountable tax administration challenges.” Among these is the obvious difficulty of measuring intangible investment, and “[i]f we cannot measure investment, how can we measure the return on investment.”
As Marian notes, the challenges to the income tax arising from globalization, dispersion, and intangible-ization are well known and have yielded multiple reform efforts, including the OECD’s recent two-pillar approach. While Marian applauds these reform efforts, he concludes that they will be insufficient because they continue to rely on the concepts of source, residence, ownership, and monetary value.
Marian contends that, to reach the data economy, what is needed is a bold move away from reliance on income as a tax base. This would include moving away from reliance on proposals tied to consumption or savings since they are simply “economic components of income.” He argues that a data tax would provide an administrable, equitable and efficient solution, and he proposes three fundamental features for such a data tax. The combined effect of the three fundamental features is somewhat reminiscent of a wealth tax, but one that is tied to data volume, flow, and use rather than to monetary value and ownership.
First, the tax base should be raw data, so that the “tax depends on the volume of data, not on the monetary value of data.” Marian explains that “each little piece of data” generally has no measurable value because “[o]nly when terabytes of data come together do they become valuable, and only because they are aggregated.”
Second, tax should be “collected on the flow of data.” This approach alleviates the need to source the data to a particular location. Marian explains that the source of value of data is “probably not where people whose data [is] collected reside because . . . each individual piece of data has no value.” Trying to locate source where “the data is analyzed. . . also seems theoretically farfetched” given the dispersion of those locations and that much of the “manipulation of data is outsourced to robots.” He posits that such a tax would be readily administrable given that it is clearly possible to tie fees to data volume given the use of such measures by internet service provider and cell phone data plans.
Third, “the users of the data” should be the taxpayers. This approach allows for a tax not dependent on ownership, which is needed because owning data “is in no way an economically meaningful concept.” As an example, Marian discusses data “owned” by both an individual and by Google: “If both you and Google own your data, have you and Google experienced an equal increase in your ability to pay?” The answer is, unsurprisingly, that the “data is more beneficial to Google, because of the other data it has.”
Marian acknowledges that these features could lead to equity concerns, but he argues that, as is also the case with other types of taxes, “generous exemption[s]” could be provided in working out system details, and the tax burden could be made progressive based on data usage. He notes, “[d]ata-rich taxpayers are also the richest taxpayers in traditional terms.” Further, because a data tax would reach taxpayers who are adept at avoiding an income tax, adding such a tax will increase progressivity.
Marian reasons that a data tax would be efficient, in the sense that it is unlikely to change taxpayer behavior. He likens a data tax to mineral taxation: “Activity must happen where the minerals are. As long as the tax is not prohibitively expensive and there is profit to be made, activity will take place where the valuable resources are found.” It is possible, he concedes, that some data users will pass the burden onto others “by charging for . . . services that are now free.” He points out that this is not a bad thing—first because it may decrease use of platforms that are arguably causing social harms, and second, because this would generate income that could be taxed under the current income tax system.
In the final section of his article, Marian reviews existing proposals for direct taxes on data or for data proxies. For example, he discusses a proposal from the mid-1990s by Arthur Cordell for a “bit tax,” as well as suggestions for taxing the infrastructure for the transmission and collection of data. Although Marian does not dismiss any proposal out of hand, given the three fundamental features outlined above, he clearly favors a tax that functions as an excise on data volume.
While the article’s scope did not permit addressing the full range of detailed issues that would have to be worked out in implementing a data tax, Marian more than fulfills his stated goal of “start[ing] a discussion about a data tax as a remedy for the failure of income taxes in data-rich markets.”
Feb 6, 2023 Leigh Osofsky
In this illuminating article, Heather Field describes her adoption of a flipped classroom model for teaching tax law during the pandemic. Like many, Field learned lessons from her pandemic teaching that will continue to be instructive now that we are (hopefully) back to an in-person teaching world. Field’s thoughtful article is well worth a read for those (like me!) wanting to do more with flipped classroom teaching.
As Field describes, a flipped classroom involves moving content delivery outside of the classroom (for instance to pre-class videos created by the instructor), thereby creating more space in the class period for active learning in the form of activities and problems. The purported benefits of flipped classrooms include more time for active student learning in class, the ability of students to learn and review content from the videos at their own pace, and the possibility of more differentiation in in-class problem sets. Flipped classrooms certainly were not new to the pandemic, but rather had existed in a variety of educational spaces prior to the turn to remote learning. However, like Field, many professors had not embraced the flipped classroom before the emergency teaching experience that was Spring 2020.
Field’s flipping of classes involved providing students before-class mini-lecturettes, which gave students an overview and explanation of the material. Class time was then spent going through problems, potentially with polls and additional bonus problems added in to the class to better gauge student understanding. Overall, her experience was a positive one. Students appreciated the opportunity to review the content at their own pace and potentially revisit it, students had more time in class to work on problems, Field was better able to direct students to the important parts of the course, weaker students were able to participate more fully in the class, Field could cover more difficult material much more efficiently, and Field had the opportunity to think more carefully though all her explanations of the course material.
One of Field’s most interesting insights is how a flipped classroom allowed her to exchange certain types of classroom rigor for other types. One of her principal concerns with flipping a classroom was that it would reduce rigor. By providing students with explanations of the law, she worried, she would relieve students of the difficult task of having to interpret the law themselves. This was particularly concerning to Field in teaching tax law, because a big part of the job of tax lawyers is to read the primary source tax materials themselves and explain the materials to someone else. To some extent, Field found that her concerns about rigor were not entirely unfounded – when she explained a statute in a pre-class video, students did not have to try to make sense of it themselves first. However, Field unexpectedly found that the use of the videos also created opportunities for new kinds of rigor. With a quicker understanding of the basics of the law, students had time to examine harder problems. They also had time to work on other skills, such as using the law to engage in planning or strategizing.
I found this insight particularly valuable for a couple of reasons. First, it emphasized that, as professors, we should be trying to teach our students a variety of lawyerly skills. How to read and interpret the law as a primary source is a critical skill students should learn, but so are more advanced skills such as how to apply the law in strategic ways. I also appreciated Field’s insight because it illustrated how pre-class videos need not be an all or nothing approach. As a professor, I tend to favor using the same type of format each class. This can be useful (in terms of developing teaching routines), but I think Field is right that professors should first think through what their pedagogical goals are on a given day, and then think about how and whether pre-class videos will help facilitate those goals on that day.
In addition to some of these major lessons, Field also offers a host of smaller tips. As Field describes, flipping a class is a lot of work, and professors should take care to create materials in a way that makes them re-usable in later years. One tip I found particularly useful was that professors should use the same slide deck for the pre-class videos and the in-class portion of the course. However, the in-class portion should also include blank slides, which enable the students to work through additional problems in class. Using the same slides for both purposes can reduce confusion for the students and unnecessary work for the professor. Field also widely counsels that professors also should not hesitate to flip one unit at a time, to see how it works and what, if any, adjustments to make.
In short, Field’s article is a useful and inspirational synopsis of how she made the switch to flipped classrooms during the pandemic. I really appreciate Field sharing her process and journey. I believe that many professors will find the article useful as they continue to grow in their teaching practices.
