“Toward a 21st-Century International Tax Regime”

  • Tax Law
Tax Notes International
2019

“Amazon Goldcrest Project and the Relevance of Comparability Analysis under the Arm’s Length Principle”

  • Tax Law
International Transfer Pricing 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

“9th Circ. Got Cost-Sharing Right in Altera v. Commissioner”

Law360
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

“China and BEPS”

  • Tax Law
Laws
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

“Evaluating BEPS”

  • Tax Law
Erasmus Law Review
2017

“The Trump Tax Reform Plan: Implications for Europe”

Bulletin for International Taxation
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

“Back to the Future? Medtronic and the Future of Transfer Pricing”

  • Tax Law
International Tax Journal
2016

“The International Tax Regime: A Centennial Reconsideration”

Global Taxation
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

“The Rise and Fall of the Consumption Tax”

  • Tax Law
Tax Notes
2015

“Reinventing the Wheel: What We Can Learn from the Tax Reform Act of 1986”

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

“And Yet It Moves: Taxation and Labor Mobility in the Twenty-First Century”

  • Tax Law
Tax Law Review
2014

“Veto Extenders, Overturn Check the Box”

Tax Notes
2014

“Taxation and Inequality: A Case for the VAT”

Challenge
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

“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

“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