"What is the Best Candidate for a Post-Moore Constitutional Challenge?"
Tax Notes Federal
2024
"Pillar 2 and the United States: What’s Next"
Tax Notes
2024
"Why Did the IRS Win? A Remarkable Year in Tax Litigation, Part 2"
Tax Notes International
2024
"European Union/OECD/International - Klaus Vogel Lecture 2023: The Past, Present and Future of Destination-Based Income Taxation"
Bulletin for International Taxation
2024
"Why Did the IRS Win? A Remarkable Year in Tax Litigation"
Tax Notes International
2024
"The Case Against Expensing R&E"
Tax Notes Federal
2024
"Effects From Moore: Does the Corporate Tax Require Realization?"
Tax Notes Federal
2024
"What Matters in Moore"
Tax Notes Federal
2024
"Tax in History: The 1923 Report and the International Tax Revolution"
Intertax
2023
"A new Framework for Taxing Cryptocurrencies"
The Tax Lawyer
2023
"3M and the Blocked Income Problem"
TaxNotes
2023
"Moore Questions Than Answers"
Tax Notes International
2023
"The UTPR Reconsidered: A Response to Fadi Shaheen"
Tax Notes International
2023
"Amicus Brief in Moore v. United States"
US Supreme Court Docket
2023
"International Taxation, Globalization, and the Economic Digital Devide"
Journal of International Economic Law
2023
"Taxing the Right Book: Arguments for the Corporate AMT"
Tax Notes International
2023
"Can Moore Be Limited?"
Tax Notes International
2023
"Much Ado: Why the United States Should Calm Down About DSTs"
Tax Notes International
2023
"Credit Where It's Due? Reflections on Christensen"
Tax Notes International
2023
"A Response to Professor Choi's Beyond Purosivism in Tax Law"
Univeristy of Iowa Law Review
2023
"Moores Needed Tax Advice, Not Crystal Ball"
Tax Notes International
2023
"Do Not Waste Your Time Deciphering the Multilateral Tax Convention"
Tax Notes International
2023
"Could Moore Have Been Mooted?"
Tax Notes Federal
2023
"The Moores' and Altria's Realization Requirement Dance"
TaxNotes International
2023
"Pillar 2 and the Credits"
International Tax Journal
2023
"Constitutional Review of Federal Tax Legislation"
University of Illinois Law Review
2023
"A New Framework for Digital Taxation"
Harvard International Law Journal
2023
"Microsoft's Cost-Sharing Arrangement: Frankenstein Strikes Again"
Tax Notes Federal
2023
"If Moore is Reversed"
Tax Notes International
2023
"The UTPR and the Credits"
Tax Notes International
2023
"The Historical Origins and Current Prospects of the Multilateral Tax Convention"
World Tax Journal
2023
"Individual Mobility and the Corporate Tax"
Tax Notes International
2023
"Coordonner les retenues à la source : une solution possible pour lutter contre l’évasion fiscale"
Revue Européenne et Internationale de Droit Fiscal
2023
"After Pillar One"
British Tax Review
2023
"China Yawns at Pillar 2"
Tax Notes International
2023
"Pillar 1 and DSTs: OECD Optimism and U.S. Reality"
Tax Notes International
2023
"Reforming the Exit Tax"
International Tax Journal
2023
"Nothing New Under the Sun? The Historical Origins of the Benefits Principle"
Intertax
2023
"Commensurate With Income: IRS Nonenforcement Has Cost $1 Trillion"
TaxNotes Federal
2023
"Comment on Cong et al. "Tax loss harvesting with cryptocurrencies""
ScienceDirect
2023
"What Would Surrey Say? The Long Reach of Stanley S. Surrey"
Law and Contemporary Problems
2023
"UTPR's Dynamic Connection to Customary International Tax Law"
Tax Notes International
2022
"Taxes in the Time of Coronavirus: Is It Time to Revive the Excess Profits Tax?"
American Prospect
2022
"New Developments on US Treaty Overrides"
British Tax Review
2022
"Why Does the United States Need the Global Minimum Tax?"
International Tax Journal
2022
"Corporate Taxation to Curb Monopoly Power: A Brief History and A Proposal"
Tax Justice Network
2022
"Pacta Sunt Servanda? The Problem of Tax Treaty Overrides"
British Tax Review
2022
"Is the United States Already Compliant with Pillar Two?"
Tax Notes International
2022
"The Dubious Constitutional Origins of Treaty Overrides: A Response to Rosenbloom and Shaheen"
Florida Tax Review
2022
Michigan Journal of International Law
2022