Faculty Publications

Tax Law

Tax Notes

2024

Taxation, Citizenship and Democracy in the 21st Century

Tax Law

2024

“Rethinking Taxing Excess Profits”

Tax Law

The Tax Lawyer

2024

“The Case for Targeted Location Incentives”

Tax Law

Tax Notes International

2024

“Littlejohn’s Unjust Tax Sentence”

Tax Law

Tax Notes International

2024

“Can Investment Treaties Defeat Pillar 2?”

Tax Law

Tax Notes International

2024

“Taxing Fat Cats Abroad”

Tax Law

Tax Notes Federal

2024

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

Tax Law

Tax Notes International

2024

“Should U.S. Tax Law Be Constitutionalized?”

Tax Law

Tax Notes International

2024

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

Tax Law

Tax Notes International

2024

“Capital Gains Realizations”

Tax Law

Economics Letters

2024

“Has Cost Sharing Outlived Its Usefulness?”

Tax Law

Tax Notes International

2024

“Once More: Digital Services Taxes Should Be Creditable”

Tax Law

Tax Notes International

2024

“Limitation on Benefits or Principal Purpose Test? Part 2”

Tax Law

Tax Notes International

2024

“Sourcing Derivatives: Time to Reverse the Rule?”

Tax Law

Tax Notes International

2024

“The Usefulness of Pillar 1”

Tax Law

Tax Notes International

2024

“Limitation on Benefits or Principal Purpose Test? Part 1”

Tax Law

Tax Notes International

2024

“The Role of Trusts in Taxing the Rich”

Tax Law

Oxford Review of Economic Policy

2023

An Introduction to Tax Law and Policy

Tax Law

2023

“Do Taxes Affect Marriage? Lessons from History”

Tax Law

American Law and Economics Review

2023

“Digital Tax Arithmetic”

Tax Law

National Tax Journal

2023

“Coordinated Withholding Taxes: a Possible Solution to the Tax Evasion Problem”

Tax Law

Revue Européenne et Internationale de Droit Fiscal

2023

“What is the Law’s Role in a Recession?”

Tax Law

Harvard Law Review

2022

U.S. International Taxation, Cases and Materials

Tax Law

2022

“No New Tax Cuts? Examining the Rescue Plan’s New State Tax Limits”

Tax Law

Tax Notes State

2022

“Tax Harmony: The Promise and Pitfalls of the Global Minimum Tax”

Tax Law

Michigan Journal of International Law

2022

“Corporate Taxes and Union Wages in the United States”

Tax Law

International Tax and Public Finance

2022

“The Psychology of Taxing Capital Income: Evidence from a Survey Experiment on the Realization Rule”

Tax Law

Journal of Public Economics

2022

Global Goliaths: Multinational Corporations in the 21st Century Economy

Tax Law

2021

“Lecture in Human Rights: Tax Policy, Global Economics, Labor and Justice in Light of COVID-19”

Tax Law

Rutgers International Law and Human Rights Journal

2021

“Tax Treaties, the Constitution, and the Noncompulsory Payment Rule”

Tax Law

International Tax Journal

2021

“Is GILTI Constitutional?”

Tax Law

TaxNotes Federal

2021

“Due Diligence in International Tax Law”

Tax Law

Due Diligence in International Tax Legal Order

2021

“The Worst Tax Law Ever Enacted?”

Tax Law

International Tax Journal

2021

“Rebellion, Rascals, and Revenue: Pleasingly Gaudy and Preposterous”

Tax Law

TaxNotes International

2021

“Has Tax Competition Been Curbed? Reaction to L. Ahrens, L. Hakelberg & T. Rixen”

Tax Law

Intertax

2021

“The Baby and the Bathwater: Reflections on the TCJA’s International Provisions”

Tax Law

TaxNotes International

2021

“The Ingenious Biden Tax Plan”

Tax Law

TaxNotes International

2021

“Should U.S. Tax Law Be Constitutionalized? Centennial Reflections on Eisner v. Macomber (1920)”

International and Comparative Law
Tax Law

Duke Journal of Constitutional Law & Public Policy

2021

“Stanley Surrey, the 1981 US Model, and the Single Tax Principle”

International and Comparative Law
Tax Law

Intertax

2021

“Gucci Gulch Redux: The Problems of Wyden Proposal”

International and Comparative Law
Tax Law

Tax Notes International

2021

“Is New York’s Mark-to-Market Act Unconstitutionally Retroactive?”

International and Comparative Law
Tax Law

Tax Notes State

2021

“Certain Effects of Random Taxes”

Tax Law

Journal of Public Economics

2021

The Psychology of Taxing Capital Income: Evidence from a Survey Experiment on the Realization Rule

Tax Law

2021

“COVID-19 and US Tax Policy: What Needs to Change?”

Tax Law

Intertax

2020

“Federalizing Tax Justice”

Tax Law

Indiana Law Journal

2020

“Taxing the Digital Economy: The Effect of Coronavirus on Pillar 1”

Tax Law

Tax Notes International

2020

“Rodriguez, Tucker, and the Dangers of Textualism”

Tax Law

Tax Notes

2020

“The Digital Consumption Tax”

Tax Law

Intertax

2020

“A New Corporate Tax”