"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

"9th Circ. Got Cost-Sharing Right in Altera v. Commissioner"

Law360
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

"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

"The International Implications of Wayfair"

  • Tax Law
Tax Notes
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

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

  • Tax Law
Columbia Journal of Tax Law
2017

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

  • Tax Law
Michigan Journal of International Law Opinio Juris
2017

"Tax Symposium: Introduction"

  • Tax Law
Michigan Journal of International Law
2017

"The Trump Tax Reform Plan: Implications for Europe"

Bulletin for International Taxation
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: Problem or Opportunity?"

  • International and Comparative Law
  • Tax Law
Challenge
2017

"Guilty as Charged: Reflections on TRA 17"

  • Tax Law
Tax Notes
2017

"A Tale of Two Cities: Washington, Brussels, and BEPS"

  • Tax Law
Tax Notes
2016

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

  • Tax Law
Tax Notes
2016

"The International Tax Regime: A Centennial Reconsideration"

Global Taxation
2016

"Apple State Aid Ruling: A Wrong Way to Enforce the Benefits Principle?"

  • Tax Law
Tax Notes International
2016

"Hanging Together: A Multilateral Approach to Taxing Multinationals"

  • Tax Law
Michigan Business & Entrepreneurial Law Review
2016

"Is Corporate Integration a Good Idea?"

  • Tax Law
Tax Notes
2016

"International Tax Evasion and Avoidance"

  • International and Comparative Law
  • Tax Law
The American Prospect
2016

"Three Steps Forward, One Step Back? Reflection on 'Google Taxes' and the Destination-Based Corporate Tax"

  • Tax Law
Nordic Tax Journal
2016

"GAARs and the Nexus between Statutory Interpretation and the Legislative Drafting: Lessons for the U.S. from Canada"

  • Tax Law
Accounting, Economics, and Law: A Convivium
2016

"Full Circle? The Single Tax Principle, BEPS, and The New US Model"

  • Tax Law
Global Taxation
2016

"Evaluating BEPS: A Reconsideration of the Benefits Principle and Proposal for UN Oversight"

  • Tax Law
Harvard Business Law Review
2016

"Constructive Unilateralism: U.S. Leadership and International Taxation"

  • Tax Law
International Tax Journal
2016

"A Bipartisan Tax Reform?"

  • Tax Law
Tax Notes
2016

"Back to 1913?: The Ryan Blueprint and Its Problems"

  • Tax Law
Tax Notes
2016

"Country by Country Reporting and Corporate Privacy: Some Unanswered Questions"

  • Tax Law
Columbia Journal of Tax Law. Tax Matters
2016

"Back to the Future? Medtronic and the Future of Transfer Pricing"

  • Tax Law
International Tax Journal
2016

"Shire/Baxalta Is Not a Tax-Driven Deal, Writer Says"

  • Tax Law
Tax Notes International
2015

"Who Invented the Single Tax Principle?: An Essay on the History of US Treaty Policy"

  • Tax Law
  • Legal History
New York Law School Law Review
2015

"All or Nothing? The Obama Budget Proposals and BEPS"

  • Tax Law
International Tax Journal
2015

"Reinventing the Wheel: What We Can Learn from the Tax Reform Act of 1986"

Tax Notes
2015

"Too Big to Tax? Vanguard and the Arm's Length Standard"

  • Tax Law
Tax Notes
2015

"The Case for Destination-Based Corporate Tax"

  • Tax Law
International Tax Journal
2015

"[Japanese Title Goes Here] Corporate Social Responsibility and Strategic Tax Behavior"

  • Tax Law
[Japanese Characters] [Journal of Osaka University of Economics]
2015

"Avi-Yonah Finds Fault With U.S. International Reform Report"

  • Tax Law
Tax Notes International
2015

"Leveling the Playing Field: The Case for an Education VAT"

  • Tax Law
Tax Notes
2015

"The Rise and Fall of the Consumption Tax"

  • Tax Law
Tax Notes
2015

"Inversions and Competitiveness: Reflections in the Wake of Pfizer-Allrgan"

  • Tax Law
International Tax Journal
2015

"The 1 Percent Solution: Corporate Tax Returns Should be Public (and How to Get There)"

  • Tax Law
Tax Notes International
2014

"Chinese Characters [And Yet It Moves: Taxation and Labor Mobility in the Twenty-First Century]"

  • Tax Law
[Chinese Characters] [International Taxation in China]
2014

"Taxation and Inequality: A Case for the VAT"

Challenge
2014