Faculty Publications

Tax Notes International

2024

"What is the Best Candidate for a Post-Moore Constitutional Challenge?"

Tax Notes Federal

2024

"Has Cost Sharing Outlived Its Usefulness?"

Tax Law

Tax Notes International

2024

The Global Corporate Minimum Tax and MNE Home Countries

2024

"Now You Have It, Now You Don’t: Taxing Crypto, Part 1"

Tax Law

Tax Notes International

2024

"European Union/OECD/International - Klaus Vogel Lecture 2023: The Past, Present and Future of Destination-Based Income Taxation"

Bulletin for International Taxation

2024

"What Matters in Moore"

Tax Notes International

2024

"Preventing Inversions"

Tax Notes International

2024

"Taxing Fat Cats Abroad"

Tax Law

Tax Notes Federal

2024

"Taxation With Realization After Moore"

Tax Notes International

2024

"Can Investment Treaties Defeat Pillar 2?"

Tax Law

Tax Notes International

2024

"Sourcing Derivatives: Time to Reverse the Rule?"

Tax Law

Tax Notes International

2024

"Building the Gateway: Why the Two Pillars Need Each Other"

Tax Law

Intertax

2024

"Once More: Digital Services Taxes Should Be Creditable"

Tax Law

Tax Notes International

2024

Fifty Years of ‘Cut To Grow’: How Changing Narratives around Corporate Tax Policy Have Undermined Child and Family Well-Being

2024

"The High Road and the Low Road: What Should be the US Reaction to the End of Pillar One?"

2024

"Pillar 2 and the United States: What’s Next"

Tax Notes

2024

"The Case for Targeted Location Incentives"

Tax Law

Tax Notes International

2024

"Now You Have It, Now You Don’t: Taxing Crypto, Part 2"

Tax Law

Tax Notes International

2024

The First US Tax Treaty and Its Influence

2024

"Taxing the Super-Rich after Moore"

Tax Notes International

2024

"Limitation on Benefits or Principal Purpose Test? Part 2"

Tax Law

Tax Notes International

2024

"Why Did the IRS Win? A Remarkable Year in Tax Litigation, Part 2"

Tax Notes International

2024

"Rethinking Taxing Excess Profits"

Tax Law

The Tax Lawyer

2024

"Littlejohn's Unjust Tax Sentence"

Tax Law

Tax Notes International

2024

"Are Exit Taxes Discriminatory?"

Tax Notes International

2024

Taxation, Citizenship and Democracy in the 21st Century

Tax Law

2024

"Crypto and the Exit Tax"

Tax Law

Tax Notes International

2024

Congress Can Maintain IRS Rulemaking Authority

Tax Law

2024

"Should U.S. Tax Law Be Constitutionalized?"

Tax Law

Tax Notes International

2024

"The Usefulness of Pillar 1"

Tax Law

Tax Notes International

2024

"Whither LOB?"

International Tax Journal

2024

"The Case Against Expensing R&E"

Tax Notes Federal

2024

"Limitation on Benefits or Principal Purpose Test? Part 1"

Tax Law

Tax Notes International

2024

"Why Did the IRS Win? A Remarkable Year in Tax Litigation"

Tax Notes International

2024

"Effects From Moore: Does the Corporate Tax Require Realization?"

Tax Notes Federal

2024

"Should Large Corporate Mergers Be Subsidized?"

Tax Notes International

2024

"Moore Questions Than Answers"

Tax Notes International

2023

"The UTPR Reconsidered: A Response to Fadi Shaheen"

Tax Notes International

2023

"3M and the Blocked Income Problem"

Tax Notes

2023

"The UTPR and the Credits"

Tax Notes International

2023

"Could Moore Have Been Mooted?"

Tax Notes Federal

2023

"A Response to Professor Choi's Beyond Purposivism in Tax Law"

Univeristy of Iowa Law Review

2023

"Nothing New Under the Sun? The Historical Origins of the Benefits Principle"

Intertax

2023

"What Would Surrey Say? The Long Reach of Stanley S. Surrey"

Law and Contemporary Problems

2023

"Introduction"

Research Handbook on Corporate Taxation

2023

"Comment on Cong et al. "Tax loss harvesting with cryptocurrencies""

Journal of Accounting and Economics

2023

"The UTPR and the Treaties"

Tax Notes International

2023

"Amicus Brief in Moore v. United States"

US Supreme Court Docket

2023

"If Moore is Reversed"