"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

Taxation, Citizenship and Democracy in the 21st Century

  • Tax Law
2024

"Rethinking Taxing Excess Profits"

  • Tax Law
The Tax Lawyer
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

An Introduction to Tax Law and Policy

  • Tax Law
2023

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

  • Tax Law
Revue Européenne et Internationale de Droit Fiscal
2023

U.S. International Taxation, Cases and Materials

  • Tax Law
2022

"Tax Harmony: The Promise and Pitfalls of the Global Minimum Tax"

  • Tax Law
Michigan Journal of International Law
2022

"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

"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"

  • Tax Law
Tax Notes International
2020

"Why R&D Should be Allocated to Subpart F and GILTI"

  • Tax Law
Tax Notes International
2020

"Constructive Dialogue: BEPS and the TCJA"

  • Tax Law
International Tax Journal
2020

"Antitrust and the Corporate Tax: Why We Need Progressive Corporate Tax Rates"

  • Tax Law
Tax Notes International
2020

"A Positive Dialectic: Beps and The United States"

  • Tax Law
AJIL Unbound
2020

"Medtronic: Has the Tide Turned for Transfer Pricing?"

  • Tax Law
Tax Notes International
2020

"Reforming State Corporate Income Taxes Can Yield Billions"

  • Tax Law
Tax Notes State
2020

"Coca-Cola: A Decisive IRS Transfer Pricing Victory, at Last"

  • Tax Law
TaxNotes Federal
2020

"Behavioral Biases and Political Actors: Three Examples from US International Taxation"

  • Tax Law
Behavioural Public Finance: Individuals, Society, and the State
2020

"Biden’s International Tax Plan"

  • Tax Law
TaxNotes International
2020

"Taxing the Digital Economy: A Short Book Review"

  • Tax Law
Tax Notes International
2020

"Why Study Tax History?"

  • Tax Law
Intertax
2020

"Do Lawyers Need Economists?"

  • Tax Law
Accounting, Economics, and Law: A Convivium
2020