“India’s New Profit Attribution Proposal and the Arm’s-Length Standard”

  • Tax Law
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

“Complete Distributive Rules and the Single Tax Principle: A Review of Recent Italian Case Law”

  • Tax Law
Bulletin for International Taxation
2019

“A U.S. DST? The Potential Impact of the Cloud Regulations”

  • Tax Law
Tax Notes International
2019

“If Not Now, When? US Tax Treaties with Latin America After TCJA”

  • Tax Law
International Tax Journal
2019

“US and Capital Flight”

  • Tax Law
דין ודברים [Haifa Law Review]
2019

“Toward a 21st-Century International Tax Regime”

  • Tax Law
Tax Notes International
2019

“The International Implications of Wayfair”

  • Tax Law
Tax Notes
2018

“Does the United States Still Care About Complying with Its WTO Obligations?”

  • Tax Law
Columbia Journal of Tax Law. Tax Matters
2018

“The Beat and Treaty Overrides: A Brief Response to Rosenbloom and Shaheen”

  • Tax Law
Tax Notes International
2018

“Proposals for International Tax Reform: Problem or Opportunity?”

  • International and Comparative Law
  • Tax Law
Challenge
2017

“Guilty as Charged: Reflections on TRA 17”

  • Tax Law
Tax Notes
2017

“Altera, the Arm’s Length Standard, and Customary International Tax Law”

  • Tax Law
Michigan Journal of International Law Opinio Juris
2017

“Tax Symposium: Introduction”

  • Tax Law
Michigan Journal of International Law
2017

“Problems with Destination-Based Corporate Taxes and the Ryan Blueprint”

  • Tax Law
Columbia Journal of Tax Law
2017

“Once More, With Feeling: TRA 17 and Original Intent of Subpart F”

  • Tax Law
Tax Notes
2017

“Full Circle? The Single Tax Principle, BEPS, and The New US Model”

  • Tax Law
Global Taxation
2016

“Constructive Unilateralism: U.S. Leadership and International Taxation”

  • Tax Law
International Tax Journal
2016

“A Bipartisan Tax Reform?”

  • Tax Law
Tax Notes
2016

“Back to 1913?: The Ryan Blueprint and Its Problems”

  • Tax Law
Tax Notes
2016

“Evaluating BEPS: A Reconsideration of the Benefits Principle and Proposal for UN Oversight”

  • Tax Law
Harvard Business Law Review
2016

“Country by Country Reporting and Corporate Privacy: Some Unanswered Questions”

  • Tax Law
Columbia Journal of Tax Law. Tax Matters
2016

“All or Nothing? The Obama Budget Proposals and BEPS”

  • Tax Law
International Tax Journal
2015

“Inversions and Competitiveness: Reflections in the Wake of Pfizer-Allrgan”

  • Tax Law
International Tax Journal
2015

“The Case for Destination-Based Corporate Tax”

  • Tax Law
International Tax Journal
2015

“Too Big to Tax? Vanguard and the Arm’s Length Standard”

  • Tax Law
Tax Notes
2015

“[Japanese Title Goes Here] Corporate Social Responsibility and Strategic Tax Behavior”

  • Tax Law
[Japanese Characters] [Journal of Osaka University of Economics]
2015

“Avi-Yonah Finds Fault With U.S. International Reform Report”

  • Tax Law
Tax Notes International
2015

“Leveling the Playing Field: The Case for an Education VAT”

  • Tax Law
Tax Notes
2015

“Reflections on the ‘New Wave’ Inversions and Notice 2014-52”

  • Tax Law
Tax Notes International
2014

“Corporate Taxation and Corporate Social Responsibility”

  • Tax Law
New York University Journal of Law & Business
2014

“The Devil in the Details: Reflections on the Camp Draft”

  • Tax Law
Tax Notes International
2014

“Back from the Dead: Reviving Transfer Pricing Enforcement”

  • Tax Law
Tax Notes International
2014

“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

“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

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

  • Tax Law
Bulletin for International Taxation
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

“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

“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