I identify an empirical limitation in Chomsky’s (2013, 2015) Labeling Theory, and propose a theoretical modification that solves that problem. Chomsky argues that a labeling indeterminacy blocks movement of wh-subjects from Spec-TP into Spec-CP. However, I give evidence wh-subjects can move from Spec-TP to Spec-CP. To solve the labeling problem, I propose (i) that labeling applies to the transferred constituent (normally the phase-head-complement), rather than the full phase, and (ii) that labeling can be delayed by one application of Transfer. This proposal preserves core aspects of Labeling Theory, without requiring a costly complementizer deletion operation for wh-subject extraction.

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