"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
"The Parallel March of the Ginis: How Does Taxation Relate to Inequality, and What Can Be Done About It?"
American Journal of Law and Equality
2022
"A New Framework for Taxing Cryptocurrencies"
Tax Notes Federal
2022
"Billionaire Mark-to-Market Reforms: Response to Susswein and Brown"
Tax Notes Federal
2022
"Medtronic II and the Profit Shifting Problem"
Tax Notes International
2022
"Pillar Two: Down but not Out"
Tax Notes International
2022
"Minimum Taxation in the United States in the Context of GloBE"
Intertax
2022
"Pillar 2 and the Corporate AMT"
Tax Notes International
2022
"The BEAT and the BITs: Can the United States be Sued over the BEAT?"
International Tax Journal
2022
"A Response to Professor Marian on Cryptocurrency Tax Policy"
Tax Notes
2022
"Stateless Income and Beyond: Ed Kleinbard’s Contribution to International Tax Policy"
National Tax Journal
2022
"First Impressions of the International Tax Provisions of BB: A Reasonable Compromise"
International Tax Journal
2022
Preface to Tax Transfer Pricing: Under the Arm's Length and the Sale Country Principles
Tax Transfer Pricing: Under the Arm’s Length and the Sale Country Principles
2022
"Stanley Surrey, the 1981 US Model, and the Single Tax Principle"
- International and Comparative Law
- Tax Law
Intertax
2021
Tax Notes International
2021
"Is New York's Mark-to-Market Act Unconstitutionally Retroactive?"
- International and Comparative Law
- Tax Law
Tax Notes State
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
International Tax Journal
2021
TaxNotes Federal
2021
Due Diligence in International Tax Legal Order
2021
International Tax Journal
2021
TaxNotes International
2021
"Has Tax Competition Been Curbed? Reaction to L. Ahrens, L. Hakelberg & T. Rixen"
- Tax Law
Intertax
2021
TaxNotes International
2021
TaxNotes International
2021
"A Two-Edged Sword: Reflections on CIC Services LLC v. IRS"
Tax Notes Federal
2021
"Is the Net Investment Income Tax a Treaty Override? Reflections on Toulouse"
Tax Note International
2021
"A Different Way to Tax Stock Buybacks"
Tax Notes International
2021
"Stanley Surrey, the Code and the Regime"
Florida Tax Review
2021
"The new international tax framework: evolution or revolution?"
American Society of International Law
2021
"Taxation and Business: The Human Rights Dimension of Corporate Tax Practices"
The Cambridge Companion to Business and Human Rights Law
2021
"Globalization, Tax Competition and the Fiscal Crisis of the Welfare State: A Twentieth Anniversary Retrospective"
Thinker, Teacher, Traveler: Reimagining International Tax
2021
"The International Tax Regime at 100: Reflections on the OECD's BEPS Project"
Bulletin for International Taxation
2021
"Taxing the Digital Economy: A Short Book Review"
- Tax Law
Tax Notes International
2020
Intertax
2020
Accounting, Economics, and Law: A Convivium
2020
Intertax
2020
Indiana Law Journal
2020
Intertax
2020
Tax Notes International
2020
Tax Notes International
2020