"Giving people the words to say no leads them to feel freer to say yes"
"Pillar 2 and the United States: What’s Next"
"Feedback Loops: Going Negative"
"European Union/OECD/International - Klaus Vogel Lecture 2023: The Past, Present and Future of Destination-Based Income Taxation"
"No More Tax-Free Lunch for Billionaires: Closing the Borrowing Loophole"
"What is the Best Candidate for a Post-Moore Constitutional Challenge?"
"Why Did the IRS Win? A Remarkable Year in Tax Litigation, Part 2"
"Fair Use and the Judicial Search for Meaning"
"Why Did the IRS Win? A Remarkable Year in Tax Litigation"
"The Case Against Expensing R&E"
"Effects From Moore: Does the Corporate Tax Require Realization?"
"All Stick and No Carrot? Reforming Public Offerings"
"The New Major Questions Doctrine"
"Collusive Prosecution"
"Responding to the New Major Questions Doctrine"
"If Moore is Reversed"
"Leadership for the Next Generation of Great Lakes Stewardship"
"The Investor-State Dispute Settlement Reform Process: Design, Dilemmas and Discontents"
"The War in Ukraine and Legal Limitations on Russian Vetoes"
"Amicus Brief in Moore v. United States"
"Restoring Indian Reservation Status: An Empirical Analysis"
"Intentionally Harming Others Without Benefit to Oneself"
"The Historical Origins and Current Prospects of the Multilateral Tax Convention"
"International Taxation, Globalization, and the Economic Digital Devide"
"Unprecedented Precedent and Original Originalism: How the Supreme Court’s Decision in Dobbs Threatens Privacy and Free Speech Rights"
"Microsoft's Cost-Sharing Arrangement: Frankenstein Strikes Again"
"Implicit Tax, Tax Incidence, and Pretax Returns"
"After Pillar One"
"Commensurate With Income: IRS Nonenforcement Has Cost $1 Trillion"
"A Texas Judge Just Invalidated The Preventive Services Mandate. What Happens Next?"
"Methodological and Normative Elements of the New Antitrust"
"The Dark Matter of Federal Indian Law: The Duty of Protection"
"Public Engagement, Equity, and Executive Order 14,094"
"Constitutional Losses and (Some) Statutory Wins for Criminal Defendants: Select Criminal Law and Procedure Cases from the Supreme Court's 2022-2023 Term"
"Legal Pluralism's Other: Mythologizing Modern Law"
"China Yawns at Pillar 2"
"Meeting Clean Energy Goals Will Require the Grid of the Future"
"Commentary on the 2022 Grotius Lecture"
"Much Ado: Why the United States Should Calm Down About DSTs"
"Feedback Loops: E-D-I-T"
"Back to Basics: The Benefits of Paradigmatic International Organizations"
"Tax in History: The 1923 Report and the International Tax Revolution"
"Credit Where It's Due? Reflections on Christensen"
"Editing, Vehicles in the Park, and the Virtue of Clarity"
- Legal Writing and Research