“Arguments For and Against Territoriality”

  • Tax Law
Tax Notes
2013

“Should the U.S. Dictate World Tax Policy? Reflections on PPL Corporation v. Commissioner”

  • Tax Law
Tax Notes International
2013

Foreword to International Taxation of Electronic Commerce

  • Tax Law
International Taxation of Electronic Commerce
2013

“Should the US Dictate World Tax Policy? Reflections on PPL”

  • Tax Law
Tax Notes
2013

“Why Y? Reflections on the Baucus Proposal”

  • Tax Law
Tax Notes International
2013

“Corporate and International Tax Reform: Proposals for the Second Obama Administration (and Beyond)”

  • Tax Law
Pepperdine Law Review
2013

“Carbon Tax, Health Care Tax, Bank Tax, and Other Regulatory Taxes”

  • Tax Law
Beyond Economic Efficiency in United States Tax Law
2013

“Territoriality: For and Against”

  • Tax Law
Tax Notes International
2013

“US Treaty Anti-Avoidance Rules: An Overview and Assessment”

  • Tax Law
Bulletin for International Taxation
2012

Review of The Making of Tax Law: The Development of the Swedish Tax System by Sven-Olaf Lodin

  • Tax Law
Tax Notes International
2012

“Transfer Pricing Disputes in the United States”

  • Tax Law
Resolving Transfer Pricing Disputes: A Global Analysis
2012

“The Effective Tax Rate of the Largest US and EU Multinationals”

  • Tax Law
Tax Law Review
2012

“Vive La Petite Difference: Camp, Obama, and Territoriality Reconsidered”

  • Tax Law
Tax Notes International
2012

“The Case for Dividend Deduction”

  • Tax Law
Tax Lawyer
2011

“The Political Pathway: When Will the US Adopt a VAT?”

  • Tax Law
The VAT Reader: What a Federal Consumption Tax Would Mean for America
2011

U.S. International Taxation: Cases and Materials

  • Tax Law
2011

“Money on the Table: Why the U.S. Should Tax Inbound Capital Gains”

  • Tax Law
Tax Notes International
2011

“Taxation as Regulation: Carbon Tax, Health Care Tax, Bank Tax and Other Regulatory Taxes”

  • Tax Law
Accounting, Economics, and Law: A Convivium
2011

“Citizens United and the Corporate Form”

  • Tax Law
Accounting, Economics, and Law: A Convivium
2011

“Rethinking Treaty Shopping: Lessons for the European Union”

  • Tax Law
Tax Treaties: Building Bridges between Law and Economics
2010

“Xilinx Revisited”

  • Tax Law
Tax Notes International
2010

“The Redemption Puzzle Redux”

  • Tax Law
Tax Notes
2010

“Comparative Tax Law: Theory and Practice”

  • Tax Law
Bulletin for International Taxation
2010

“Tax Convergence and Globalization”

  • Tax Law
Revista Tributária das Américas
2010

“Summary and Recommendations”

  • Tax Law
Tax Law. Review
2010

“Citizens United and the Corporate Form”

  • Tax Law
Wisconsin Law Review
2010

“Between Formulary Apportionment and the OECD Guidelines: A Proposal for Reconciliation”

  • Tax Law
World Tax Journal
2010

“International Law: Private Law in United States Law”

  • Tax Law
Oxford International Encyclopedia of Legal History
2009

“Allocating Business Profits for Tax Purposes: A Proposal to Adopt a Formulary Profit Split”

  • Tax Law
Florida Tax Review
2009

“Structuring a US Federal VAT”

  • Tax Law
International VAT Monitor
2009

“Double Tax Treaties: An Introduction”

  • Tax Law
The Effect of Treaties on Foreign Direct Investment: Bilateral Investment Treaties, Double Taxation Treaties and Investment Flows
2009

“Obama’s International Tax Plan: A Major Step Forward”

  • Tax Law
Tax Notes
2009

“Closing the International Tax Gap Via Cooperations, Not Competition”

  • Tax Law
Toward Tax Reform Recommendations for President Obama’s Task Force
2009

“The OECD Harmful Tax Competition Report: A Tenth Anniversary Retrospective”

  • Tax Law
Brooklyn Journal of International Law
2009

“Tax Reform in a Global Economy: Obama’s Plan”

  • Tax Law
Tax Notes
2009

“Combating Global Climate Change: Why a Carbon Tax is a Better Response to Global Warming than Cap and Trade”

  • Tax Law
Stanford Environmental Law Journal
2009

“Xilinx and the Arm’s-Length Standard”

  • Tax Law
Tax Notes
2009

“Risk, Rents and Regressivity Revisited”

  • Tax Law
Australian Tax Forum
2009

“Back to the Future? The Potential Revival of Territoriality”

  • Tax Law
Bulletin for International Taxation
2008

“Reforming Corporate Taxation in a Global Economy: A Proposal to Adopt Formulary Apportionment”

  • Tax Law
Path to Prosperity: Hamilton Project Ideas on Income Security, Education, and Taxes
2008

“Corporate Social Responsibility and Strategic Tax Behavior”

  • Tax Law
Tax and Corporate Governance
2008

“Comment on Yin, Reforming the Taxation of Foreign Direct Investment by US Taxpayers”

  • Tax Law
Virginia Tax Review
2008

“Enforcing Dividend Withholding on Derivatives”

  • Tax Law
Tax Notes
2008

“Commentary: More Open Issues Regarding the Consolidated Corporate Tax Base in the European Union”

  • Tax Law
Tax Law. Review
2008

“Business Profits (Article 7 OECD Model Convention)”

  • Tax Law
Source versus Residence: Problems Arising from the Allocation of Taxing Rights in Tax Treaty Law and Possible Alternatives
2008

“A Coordinated Withholding Tax on Deductibility Payments”

  • Tax Law
Tax Notes
2008

The Integrated 2006 United States Model Income Tax Treaty

  • Tax Law
2008

“Why Was the U.S. Corporate Tax Enacted in 1909?”

  • Tax Law
Studies in the History of Tax Law
2007

“Federalism and the Commerce Clause: A Comparative Perspective”

  • Tax Law
State and Local Tax Lawyer
2007

Preface to Comparative Fiscal Federalism: Comparing the European Court of Justice and the US Supreme Court’s Tax Jurisprudence

  • Tax Law
Comparative Fiscal Federalism: Comparing the European Court of Justice and the US Supreme Court’s Tax Jurisprudence
2007