"Minimum Taxation in the United States in the Context of GloBE"
Intertax
2022
"Medtronic II and the Profit Shifting Problem"
Tax Notes International
2022
"A New Framework for Digital Taxation"
Harvard International Law Journal
2022
"Taxes in the Time of Coronavirus: Is It Time to Revive the Excess Profits Tax?"
American Prospect
2022
"New Developments on US Treaty Overrides"
British Tax Review
2022
Michigan Journal of International Law
2022
"Why Does the United States Need the Global Minimum Tax?"
International Tax Journal
2022
"Corporate Taxation to Curb Monopoly Power: A Brief History and A Proposal"
Tax Justice Network
2022
"The BEAT and the BITs: Can the United States be Sued over the BEAT?"
International Tax Journal
2022
"Stateless Income and Beyond: Ed Kleinbard’s Contribution to International Tax Policy"
National Tax Journal
2022
"Pillar 2 and the Corporate AMT"
Tax Notes International
2022
"Is the Net Investment Income Tax a Treaty Override? Reflections on Toulouse"
Tax Note International
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
TaxNotes Federal
2021
"A Two-Edged Sword: Reflections on CIC Services LLC v. IRS"
Tax Notes Federal
2021
"A Different Way to Tax Stock Buybacks"
Tax Notes International
2021
TaxNotes International
2021
"Has Tax Competition Been Curbed? Reaction to L. Ahrens, L. Hakelberg & T. Rixen"
- Tax Law
Intertax
2021
"Is New York's Mark-to-Market Act Unconstitutionally Retroactive?"
- International and Comparative Law
- Tax Law
Tax Notes State
2021
"The New International Tax Framework: Evolution or Revolution?"
American Society of International Law
2021
"Stanley Surrey, the Code and the Regime"
Florida Tax Review
2021
International Tax Journal
2021
TaxNotes International
2021
"The International Tax Regime at 100: Reflections on the OECD's BEPS Project"
Bulletin for International Taxation
2021
"Stanley Surrey, the 1981 US Model, and the Single Tax Principle"
- International and Comparative Law
- Tax Law
Intertax
2021
International Tax Journal
2021
Tax Notes International
2021
Tax Notes International
2020
Tax Notes International
2020
Intertax
2020
Indiana Law Journal
2020
TaxNotes Federal
2020
Intertax
2020
"Medtronic: Has the Tide Turned for Transfer Pricing?"
- Tax Law
Tax Notes International
2020
Tax Notes State
2020
"What’s Everyone’s Problem with DSTs?"
Tax Notes
2020
"Taxing the Digital Economy: The Effect of Coronavirus on Pillar 1"
- Tax Law
Tax Notes International
2020
Tax Notes
2020
TaxNotes International
2020
International Tax Journal
2020
"Antitrust and the Corporate Tax: Why We Need Progressive Corporate Tax Rates"
- Tax Law
Tax Notes International
2020
AJIL Unbound
2020
"Taxation and Born-Again Progressives"
American Prospect
2020
"Complete Distributive Rules and the Single Tax Principle: A Review of Recent Italian Case Law"
- Tax Law
Bulletin for International Taxation
2019
Tax Notes International
2019
International Tax Journal
2019
"Use and Abuse of the Single Tax Principle: A Comparative Review of Recent Italian Supreme Court Treaty Cases"
Diritto e practica tributaria internazionale
2019
Tax Notes International
2019
"The Games They Will Play: Tax Games, Roadblocks, and Glitches Under the 2017 Tax Legislation"
- Tax Law
Minnesota Law Review
2019