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“The International Implications of Tax Reform”
Transfer Pricing: Judicial Strategy and Outcomes
“The Rise and Fall of Arm’s Length: A Study in the Evolution of U.S. International Taxation”
Amortization of Intangibles
The Case for Coordinated Corporate Tax Rates
“The High Road and the Low Road: What Should be the US Reaction to the End of Pillar One?”
The New International Tax Regime
- International and Comparative Law
- Tax Law
Taxation for a New ‘New Deal’: Short-, Medium-, and Long-Term Options
Taxing Nomads: Reviving Citizenship-Based Taxation for the 21st Century
A Different Tax on Stock Buybacks
Regressive Taxation and Money Machines: Reconciling a Us VAT with Progessivity
The United States and the Pillars
Follow the Money: Why is International Tax Bilateral?
Why 15%? Justifying the Global Corporate Minimum Tax
The Dubious Constitutional Origins of Treaty Overrides
“Building the Gateway: Why the Two Pillars Need Each Other”
“Taxation and Corporate Governance”
The Interaction Between Unilateralism and Multilateralism in International Tax
The Historical Origins of the Multilateral Tax Convention
Build Back Better and Pillar Two: Two Alternative Scenarios
“The Meaning of «IS»: Reflections on Nestle”
