“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
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
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
San Diego Law Review
1996
The Attribution Rules
- Tax Law
1996
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
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
“Pillar Two and the Bits”
Canadian Tax Journal