“China Yawns at Pillar 2”
Tax Notes International
2023
“Pillar 1 and DSTs: OECD Optimism and U.S. Reality”
Tax Notes International
2023
“Reforming the Exit Tax”
International Tax Journal
2023
“What Would Surrey Say? The Long Reach of Stanley S. Surrey”
Law and Contemporary Problems
2023
“Nothing New Under the Sun? The Historical Origins of the Benefits Principle”
Intertax
2023
Research Handbook on Corporate Taxation
2023
“Commensurate With Income: IRS Nonenforcement Has Cost $1 Trillion”
Tax Notes Federal
2023
“Comment on Cong et al. “Tax loss harvesting with cryptocurrencies””
Journal of Accounting and Economics
2023
“Introduction”
Research Handbook on Corporate Taxation
2023
“A New Corporate Tax”
Research Handbook on Corporate Tax
2023
“The US Taxpayer Bill of Rights: Reflections on a Toddler”
Studi in Memoria di Francesco Teasauro
2023
“Pillar 2 and the Credits”
International Tax Journal
2023
“Moore Questions Than Answers”
Tax Notes International
2023
“The UTPR Reconsidered: A Response to Fadi Shaheen”
Tax Notes International
2023
“Antitrust and the Corporate Tax, 1908-1928”
Antimonopoly and American Democracy
2023
“Amicus Brief in Moore v. United States”
US Supreme Court Docket
2023
“International Taxation, Globalization, and the Economic Digital Divide”
Journal of International Economic Law
2023
“Taxing the Right Book: Arguments for the Corporate AMT”
Tax Notes International
2023
“Can Moore Be Limited?”
Tax Notes International
2023
“Much Ado: Why the United States Should Calm Down About DSTs”
Tax Notes International
2023
“Credit Where It’s Due? Reflections on Christensen”
Tax Notes International
2023
“Moores Needed Tax Advice, Not Crystal Ball”
Tax Notes International
2023
“International Tax Law: Status Quo, Trends and Perspectives”
The Oxford Handbook of International Tax Law
2023
“Do Not Waste Your Time Deciphering the Multilateral Tax Convention”
Tax Notes International
2023
“Could Moore Have Been Mooted?”
Tax Notes Federal
2023
“The Moores’ and Altria’s Realization Requirement Dance”
TaxNotes International
2023
“Coordinated Withholding Taxes: a Possible Solution to the Tax Evasion Problem”
- Tax Law
Revue Européenne et Internationale de Droit Fiscal
2023
“The UTPR and the Treaties”
Tax Notes International
2023
U.S. International Taxation, Cases and Materials
- Tax Law
2022
Michigan Journal of International Law
2022
“Billionaire Mark-to-Market Reforms: Response to Susswein and Brown”
Tax Notes Federal
2022
“Medtronic II and the Profit Shifting Problem”
Tax Notes International
2022
“Pillar Two: Down but not Out”
Tax Notes International
2022
“Minimum Taxation in the United States in the Context of GloBE”
Intertax
2022
“Pillar 2 and the Corporate AMT”
Tax Notes International
2022
“The BEAT and the BITs: Can the United States be Sued over the BEAT?”
International Tax Journal
2022
“A Response to Professor Marian on Cryptocurrency Tax Policy”
Tax Notes
2022
“Stateless Income and Beyond: Ed Kleinbard’s Contribution to International Tax Policy”
National Tax Journal
2022
“First Impressions of the International Tax Provisions of BB: A Reasonable Compromise”
International Tax Journal
2022
“The Parallel March of the Ginis: How Does Taxation Relate to Inequality, and What Can Be Done About It?”
American Journal of Law and Equality
2022
Preface to Tax Transfer Pricing: Under the Arm’s Length and the Sale Country Principles
Tax Transfer Pricing: Under the Arm’s Length and the Sale Country Principles
2022
“A New Framework for Digital Taxation”
Harvard International Law Journal
2022
“The Dubious Constitutional Origins of Treaty Overrides: A Response to Rosenbloom and Shaheen”
Florida Tax Review
2022
“UTPR’s Dynamic Connection to Customary International Tax Law”
Tax Notes International
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
“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