Faculty Publications

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Taxation of Financial Instruments

Tax Law

1996

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

MLaw Repository

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

1996

“The International Implications of Tax Reform”

MLaw Repository

Tax Notes

1995

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”

MLaw Repository

Tax Law

Virginia Tax Review

1995

Amortization of Intangibles

Tax Law

1994

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

The Dubious Constitutional Origins of Treaty Overrides

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?”

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

MLaw Repository

A Different Tax on Stock Buybacks

“Roman Precursors of Modern Human Rights Doctrine”

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

The United States and the Pillars

Follow the Money: Why is International Tax Bilateral?

The Benefits Principle

Why 15%? Justifying the Global Corporate Minimum Tax

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

The Single Tax Principle

“Taxation and Corporate Governance”

The Interaction Between Unilateralism and Multilateralism in International Tax

“Taxation of Autonomous Artificial Intelligence: Socially Sustainable Expansion of Automation and Impacts on International Tax”

“Whither LOB?”

The Historical Origins of the Multilateral Tax Convention

Build Back Better and Pillar Two: Two Alternative Scenarios