Faculty Publications

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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

“The International Implications of Tax Reform”

MLaw Repository

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

MLaw Repository

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”