“The U.S. Treasury’s Subpart F Report: Plus Ça Change, Plus C’est La Même Chose?”

  • Tax Law
Bulletin for International Fiscal Documentation
2001

“Commentary (Response to article by H. David Rosenbloom)”

  • Tax Law
Tax Law. Review
2000

“Tax, Trade and Harmful Tax Competition: Reflections on the FSC Controversy (Foreign Sales Corporations)”

  • Tax Law
Tax Notes International
2000

“World-Class Tax Evasion: Competition for Investment Capital Is Eroding the Tax Base of the Advanced Countries and Making a Safety Net Harder to Finance”

  • Tax Law
The American Prospect
2000

“Globalization, Tax Competition, and the Fiscal Crisis of the Welfare State”

  • Tax Law
Harvard Law Review
2000

“Competition and Competitiveness: Review of NFTC Subpart F Report”

  • Tax Law
Tax Notes
1999

“Comment on Peroni, Fleming and Shay, ‘Getting Serious about Curtailing Deferral of U.S. Tax on Foreign Source Income’ ”

  • Tax Law
Southern Methodist University Law Review
1999

“Tax Competition and Multinational Competitiveness: The New Balance of Subpart F - Review of the NFTC Foreign Income Project”

  • Tax Law
Tax Notes International
1999

“Memo to Congress: It’s Time to Repeal the U.S. Portfolio Interest Exemption”

  • Tax Law
Tax Notes International
1998

“U.S. Notice 98-11 and the Logic of Subpart F: A Comparative Perspective”

Tax Notes International
1998

“International Taxation of Electronic Commerce”

  • Tax Law
Tax Law. Review
1997

“Comment on Shay and Summers: Selected International Aspects of Fundamental Tax Reform Proposals”

  • Tax Law
University of Miami Law Review
1997

“U.S. International Treatment of Financial Derivatives”

Tax Notes
1997

“To End Deferral as we Know It: Simplification Potential of Check-the-Box”

Tax Notes
1997

“Review of John Head and Richard Krever, Company Tax Systems”

Tax Notes International
1997

“Comment on Grubert and Newlon, ‘The International Implications of Consumption Tax Proposals’ ”

  • Tax Law
National Tax Journal
1996

“From Income to Consumption Tax: Some International Implications”

  • Tax Law
San Diego Law Review
1996

The Attribution Rules

  • Tax Law
1996

“The Structure of International Taxation: A Proposal for Simplification”

  • Tax Law
Texas Law Review
1996

Taxation of Financial Instruments

  • Tax Law
1996

“Virtual Taxation: Source-Based Taxation in the Age of Derivatives”

Proceedings of the Annual Conference on Taxation Held under the Auspices of the National Tax Association-Tax Institute of America
1996

Transfer Pricing: Judicial Strategy and Outcomes

  • Tax Law
1995

Collapsible Corporations

  • Tax Law
1995

“The Rise and Fall of Arm’s Length: A Study in the Evolution of U.S. International Taxation”

  • Tax Law
Virginia Tax Review
1995

“The International Implications of Tax Reform”

Tax Notes
1995

Amortization of Intangibles

  • Tax Law
1994

The New International Tax Regime

  • International and Comparative Law
  • Tax Law

Taxation for a New ‘New Deal’: Short-, Medium-, and Long-Term Options

  • Tax Law

Taxing Nomads: Reviving Citizenship-Based Taxation for the 21st Century

Regressive Taxation and Money Machines: Reconciling a Us VAT with Progessivity

The Benefits Principle

The Dubious Constitutional Origins of Treaty Overrides

A Different Tax on Stock Buybacks

The Single Tax Principle

The Interaction Between Unilateralism and Multilateralism in International Tax

Build Back Better and Pillar Two: Two Alternative Scenarios

“Pillar Two and the Bits”

Canadian Tax Journal

The United States and the Pillars

Follow the Money: Why is International Tax Bilateral?

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?”

Why 15%? Justifying the Global Corporate Minimum Tax

“Building the Gateway: Why the Two Pillars Need Each Other”

“Taxation and Corporate Governance”

“Whither LOB?”

The Historical Origins of the Multilateral Tax Convention

“The Meaning of «IS»: Reflections on Nestle”