"Tax Harmony: The Promise and Pitfalls of the Global Minimum Tax"

  • Tax Law
Michigan Journal of International Law
2022

"Should U.S. Tax Law Be Constitutionalized? Centennial Reflections on Eisner v. Macomber (1920)"

  • International and Comparative Law
  • Tax Law
Duke Journal of Constitutional Law & Public Policy
2021

"Lecture in Human Rights: Tax Policy, Global Economics, Labor and Justice in Light of COVID-19"

  • Tax Law
Rutgers International Law and Human Rights Journal
2021

"Is GILTI Constitutional?"

  • Tax Law
TaxNotes Federal
2021

"Stanley Surrey, the 1981 US Model, and the Single Tax Principle"

  • International and Comparative Law
  • Tax Law
Intertax
2021

"Has Tax Competition Been Curbed? Reaction to L. Ahrens, L. Hakelberg & T. Rixen"

  • Tax Law
Intertax
2021

"The Worst Tax Law Ever Enacted?"

  • Tax Law
International Tax Journal
2021

"Gucci Gulch Redux: The Problems of Wyden Proposal"

  • International and Comparative Law
  • Tax Law
Tax Notes International
2021

"Is New York's Mark-to-Market Act Unconstitutionally Retroactive?"

  • International and Comparative Law
  • Tax Law
Tax Notes State
2021

"The Baby and the Bathwater: Reflections on the TCJA’s International Provisions"

  • Tax Law
TaxNotes International
2021

"Tax Treaties, the Constitution, and the Noncompulsory Payment Rule"

  • Tax Law
International Tax Journal
2021

"The Ingenious Biden Tax Plan"

  • Tax Law
TaxNotes International
2021

"A New Corporate Tax"

  • Tax Law
Tax Notes International
2020

"Why R&D Should be Allocated to Subpart F and GILTI"

  • Tax Law
Tax Notes International
2020

"Medtronic: Has the Tide Turned for Transfer Pricing?"

  • Tax Law
Tax Notes International
2020

"Reforming State Corporate Income Taxes Can Yield Billions"

  • Tax Law
Tax Notes State
2020

"COVID-19 and US Tax Policy: What Needs to Change?"

  • Tax Law
Intertax
2020

"Federalizing Tax Justice"

  • Tax Law
Indiana Law Journal
2020

"Coca-Cola: A Decisive IRS Transfer Pricing Victory, at Last"

  • Tax Law
TaxNotes Federal
2020

"The Digital Consumption Tax"

  • Tax Law
Intertax
2020

"Constructive Dialogue: BEPS and the TCJA"

  • Tax Law
International Tax Journal
2020

"Antitrust and the Corporate Tax: Why We Need Progressive Corporate Tax Rates"

  • Tax Law
Tax Notes International
2020

"A Positive Dialectic: Beps and The United States"

  • Tax Law
AJIL Unbound
2020

"Taxing the Digital Economy: The Effect of Coronavirus on Pillar 1"

  • Tax Law
Tax Notes International
2020

"Rodriguez, Tucker, and the Dangers of Textualism"

  • Tax Law
Tax Notes
2020

"Biden’s International Tax Plan"

  • Tax Law
TaxNotes International
2020

"India's New Profit Attribution Proposal and the Arm's-Length Standard"

  • Tax Law
Tax Notes International
2019

"The Games They Will Play: Tax Games, Roadblocks, and Glitches Under the 2017 Tax Legislation"

  • Tax Law
Minnesota Law Review
2019

"Complete Distributive Rules and the Single Tax Principle: A Review of Recent Italian Case Law"

  • Tax Law
Bulletin for International Taxation
2019

"A U.S. DST? The Potential Impact of the Cloud Regulations"

  • Tax Law
Tax Notes International
2019

"If Not Now, When? US Tax Treaties with Latin America After TCJA"

  • Tax Law
International Tax Journal
2019

"US and Capital Flight"

  • Tax Law
דין ודברים [Haifa Law Review]
2019

"Toward a 21st-Century International Tax Regime"

  • Tax Law
Tax Notes International
2019

"Amazon Goldcrest Project and the Relevance of Comparability Analysis under the Arm's Length Principle"

  • Tax Law
International Transfer Pricing Journal
2019

"BEPS, ATAP, and the New Tax Dialogue: 'A Transatlantic Competition?'"

  • Tax Law
Intertax
2018

"A Global Treaty Override? The New OECD Multilateral Tax Instrument and Its Limits"

  • Tax Law
Michigan Journal of International Law
2018

"The International Implications of Wayfair"

  • Tax Law
Tax Notes
2018

"Does the United States Still Care About Complying with Its WTO Obligations?"

  • Tax Law
Columbia Journal of Tax Law. Tax Matters
2018

"The Beat and Treaty Overrides: A Brief Response to Rosenbloom and Shaheen"

  • Tax Law
Tax Notes International
2018

"China and BEPS"

  • Tax Law
Laws
2018

"Taking the First Bite: Who Should Tax Apple's $187 Billion in Ireland?"

  • Tax Law
Michigan Tax Lawyer
2017

"Territoriality and the Original Intent of Subpart F"

  • Tax Law
Tax Notes
2017

"Altera, the Arm's Length Standard, and Customary International Tax Law"

  • Tax Law
Michigan Journal of International Law Opinio Juris
2017

"Proposals for International Tax Reform: Problem or Opportunity?"

  • International and Comparative Law
  • Tax Law
Challenge
2017

"Guilty as Charged: Reflections on TRA 17"

  • Tax Law
Tax Notes
2017

"Tax Symposium: Introduction"

  • Tax Law
Michigan Journal of International Law
2017

"Problems with Destination-Based Corporate Taxes and the Ryan Blueprint"

  • Tax Law
Columbia Journal of Tax Law
2017

"Once More, With Feeling: TRA 17 and Original Intent of Subpart F"

  • Tax Law
Tax Notes
2017

"Evaluating BEPS"

  • Tax Law
Erasmus Law Review
2017

"Proposals for International Tax Reform: Is There a Middle Road?"

  • Tax Law
Tax Notes
2016