“Globalization, Tax Competition, and the Fiscal Crisis of the Welfare State”
- Tax Law
Harvard Law Review
2000
“Competition and Competitiveness: Review of NFTC Subpart F Report”
- Tax Law
Tax Notes
1999
“Comment on Peroni, Fleming and Shay, ‘Getting Serious about Curtailing Deferral of U.S. Tax on Foreign Source Income’ ”
- Tax Law
Southern Methodist University Law Review
1999
“Tax Competition and Multinational Competitiveness: The New Balance of Subpart F - Review of the NFTC Foreign Income Project”
- Tax Law
Tax Notes International
1999
“U.S. Notice 98-11 and the Logic of Subpart F: A Comparative Perspective”
Tax Notes International
1998
“Memo to Congress: It’s Time to Repeal the U.S. Portfolio Interest Exemption”
- Tax Law
Tax Notes International
1998
Review of Company Tax Systems by John Head and Richard Krever
Tax Notes International
1997
“U.S. International Treatment of Financial Derivatives”
Tax Notes
1997
“Comment on Shay and Summers: Selected International Aspects of Fundamental Tax Reform Proposals”
- Tax Law
University of Miami Law Review
1997
Tax Law. Review
1997
“To End Deferral as we Know It: Simplification Potential of Check-the-Box”
Tax Notes
1997
“Comment on Grubert and Newlon, ‘The International Implications of Consumption Tax Proposals’ ”
- Tax Law
National Tax Journal
1996
Texas Law Review
1996
San Diego Law Review
1996
The Attribution Rules
- Tax Law
1996
Taxation of Financial Instruments
- Tax Law
1996
“Virtual Taxation: Source-Based Taxation in the Age of Derivatives”
Proceedings of the Annual Conference on Taxation Held under the Auspices of the National Tax Association-Tax Institute of America
1996
Collapsible Corporations
- Tax Law
1995
Transfer Pricing: Judicial Strategy and Outcomes
- Tax Law
1995
“The International Implications of Tax Reform”
Tax Notes
1995
“The Rise and Fall of Arm’s Length: A Study in the Evolution of U.S. International Taxation”
- Tax Law
Virginia Tax Review
1995
Amortization of Intangibles
- Tax Law
1994
Regressive Taxation and Money Machines: Reconciling a Us VAT with Progressivity
“Pillar 2 and Specific Benefits for Multinationals”
University of Michigan Public Law Research Paper
The Benefits Principle
“The High Road and the Low Road: What Should be the US Reaction to the End of Pillar One?”
“Are Exit Taxes Discriminatory?”
University of Michigan Public Law Research Paper
Advanced Introduction to International Tax Law
The International Tax Revolution
“Preventing Inversions”
University of Michigan Public Law Research Paper
“Roman Precursors of Modern Human Rights Doctrine”
“Building the Gateway: Why the Two Pillars Need Each Other”
The United States and the Pillars
The Case for Coordinated Corporate Tax Rates
Follow the Money: Why is International Tax Bilateral?
“The Administrative Procedure Act Problem Reconsidered”
University of Michigan Public Law Research Paper
“The Case for a Carbon Tax Revisited”
University of Michigan Public Law Research Paper
“Taxing the Super-Rich after Moore”
University of Michigan Public Law Research Paper
Why 15%? Justifying the Global Corporate Minimum Tax
Building the Gateway: Why the Two Pillars Need Each Other
A Different Tax on Stock Buybacks
Taxing Nomads: Reviving Citizenship-Based Taxation for the 21st Century
“Political Biases and Taxation Revisited”
University of Michigan Public Law Research Paper
“Taxation With Realization After Moore”
University of Michigan Public Law Research Papers