Articles

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Deconstructing the Duty to the Tax System: Unfettering Zealous Advocacy on Behalf of Lesbian and Gay Taxpayers, The Tax Lawyer (2008)

In this article, I consider how the tax lawyer’s generally-acknowledged duty to the tax system...

 

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Tax Equity, Buffalo Law Review (2008)

Simply put, this article stands the traditional concept of tax equity on its head. Challenging...

 

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Review of "Havens in a Storm: The Struggle for Global Tax Regulation", Law & Society Review (2008)
This short essay is a review of J.C. Sharman’s book "Havens in a Storm: The...
 

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Tax as Urban Legend, Harvard BlackLetter Law Journal (2008)

In this essay, I review UC-Berkeley history professor Robin Einhorn’s book, "American Taxation, American Slavery."...

 

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Homo Sacer, Homosexual: Some Thoughts on Waging Tax Guerrilla Warfare, Unbound: Harvard Journal of the Legal Left (2006)
Inspired by Giorgio Agamben’s Homo Sacer: Sovereign Power and Bare Life, this essay raises the...
 

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From the Sidelines: A Deconstructionist View of Circular 230, Tax Notes (2005)
Over the past several months, the new written tax advice rules in Circular 230 have...
 

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A Tax Crit Identity Crisis? Or Tax Expenditure Analysis, Deconstruction, and the Rethinking of a Collective Identity, Whittier Law Review (2005)

Critical tax theory, much like its non-tax critical counterparts, has been consistently marginalized by mainstream...

 

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Prying Open the Closet Door: The Defense of Marriage Act and Tax Treaties, Tax Notes (2004)

In response to a letter from a clearly alarmed conservative organization, the IRS recently...

 

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Tax Protest, A Homosexual, and Frivolity: A Deconstructionist Meditation , St. Louis University Public Law Review (2004)
In this contribution to a symposium entitled Out of the Closet and Into the Light:...
 

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The Internal Revenue Code as Sodomy Statute, Santa Clara Law Review (2004)
This essay attempts to bridge the gap between gay and straight understanding of the Internal...
 

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Cross-Border Outsourcing: U.S. International Tax Pitfalls, Pratfalls, and Opportunities, Taxes (2003)
During the past decade, there has been a surge in outsourcing by businesses both...
 

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Eyese Wide Shut: Surveying Erosion in the Professionalism of the Tax Bar, Virginia Tax Review (2003)

There is a generalized feeling among lawyers today that the legal "profession" is eroding...

 

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The Ethics of Tax Cloning, Florida Tax Review (2003)

During the past decade, stories have appeared from time to time in the tax...

 

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Spontaneous Tax Coordination: On Adopting a Comparative Approach to Reforming the U.S. International Tax Regime, Vanderbilt Journal of Transnational Law (2002)

Despite being widely-acknowledged as an important tax policy goal, simplification of the U.S. international...

 

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The Proposed Domestic Reverse Hybrid Entity Regulations: Can the Treasury Department Override Treaties?, Tax Management International Journal (2001)
This article first describes the proposed regulations issued under section 894 addressing the ability...
 

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Curtailing Tax Treaty Overrides: A Call to Action, University of Pittsburgh Law Review (2001)

During the past 25 years, Congress has with increasing frequency enacted legislation that is...

 

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Structuring Inbound Investments: A Primer on Exit Issues, Taxes (2001)

As technology renders the world a smaller and smaller place, an increasing number of...

 

Contributions to Books

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Domestic Law and Tax Treaties: The United States, Domestic Law and Tax Treaties (2006)

In this paper, I provide an overview of the interaction between U.S. domestic law and...

 

Unpublished Papers

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Taxing Civil Rights Gains (2008)

In this article, I take a novel approach to the question of what constitutes a...

 

Other

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Everyday Law for Gays and Lesbians: An Introduction (2006)

This is the (revised) introductory chapter of a book that I am currently writing. The...