"A large number of employees work for tips; but the tip is an ambiguous institution—in economics, ethics, social practice, and law. This article explores those ambiguities in three countries—France, Germany, and the United States. In all three serious efforts were mounted to suppress the tip. In all three those efforts failed. And all three eventually legislated a minimum wage. But the status of the customer's tip as the employer's wage varies in each. This essay explores how that has come about and why it is so."

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