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Transfer Pricing: Judicial Strategy and Outcomes
“The Rise and Fall of Arm’s Length: A Study in the Evolution of U.S. International Taxation”
“The International Implications of Tax Reform”
Amortization of Intangibles
The New International Tax Regime
- International and Comparative Law
- Tax Law
Taxation for a New ‘New Deal’: Short-, Medium-, and Long-Term Options
Taxing Nomads: Reviving Citizenship-Based Taxation for the 21st Century
Regressive Taxation and Money Machines: Reconciling a Us VAT with Progessivity
The Dubious Constitutional Origins of Treaty Overrides
A Different Tax on Stock Buybacks
The Interaction Between Unilateralism and Multilateralism in International Tax
Build Back Better and Pillar Two: Two Alternative Scenarios
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”
The Historical Origins of the Multilateral Tax Convention
“The Meaning of «IS»: Reflections on Nestle”