Works in Progress

Books

Introduction to United States International Taxation, 6th Edition (with James R. Repetti and Paul R. McDaniel), James R. Repetti (2014)

The new edition of this well-known reference work for the tax community provides an introduction...

 

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Federal Income Taxation of Corporate Enterprise (with Bernard Wolfman) (2012)

This is a comprehensive casebook on federal income taxation of corporations, focusing almost entirely on...

 
U.S. International Taxation: Cases and Materials (with Reuven S. Avi-Yonah and Yariv Brauner) (2011)
 
Ethical Problems in Federal Tax Practice (with Bernard Wolfman and Deborah H. Schenk) (2008)

Ethical Problems in Federal Tax Practice, Fourth Edition, is the ideal tool for introducing students...

 
Federal Income Taxation of Corporate Enterprise (with Bernard Wolfman) (2008)
 
U.S. Income Taxation of Foreign Corporations (with Jessica L. Katz and Charles T. Plambeck) (2008)

U.S. Income Taxation of Foreign Corporations describes the Internal Revenue Code provisions applicable to foreign...

 
Federal Income Taxation of Corporate Enterprise (with Bernard Wolfman) (2005)
 
U.S. International Taxation: Cases and Materials (with Reuven S. Avi-Yonah and Yariv Brauner) (2005)
 
Taxation of Financial Instruments (with Reuven Avi-Yonah and David Newman) (1996)
 

Contributions to Books

United States, Taxation of Permanent Establishments (2014)
 

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Exchange of Information, United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries (2013)
 

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International Dynamics of International Tax, Beyond Economic Efficiency in United States Tax Law (2013)
 
United States, Taxation of Permanent Establishments (2013)
 

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Horizontal Equity Revisited (with James R. Repetti), The Proper Tax Base: Structural Fairness from an International and Comparative Perspective (2012)

In the years since McDaniel and Repetti’s 1993 article evaluating the intellectual landscape on horizontal...

 
The Debt-Equity Conundrum: U.S. National Report, Cahiers De Droit Fiscal International (2012)

One of the fundamental challenges in corporate taxation is managing the distinction between debt and...

 
United States, Taxation of Permanent Establishments (2012)
 

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United States, Taxation of Permanent Establishments (2011)
 
Inside the United States APA Program, Proceedings of the International Seminar on Harmonious Society & Tax Judicial Reform in China & PKU-UMICH Tax Law Forum (2006)
 
U.S. National Report on Double Nontaxation, Cahier de Droit Fiscal Inrternational (2004)
 

Articles

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Horizontal Equity Revisited (with James R. Repetti), Florida Tax Review (2013)

From the introduction:

No tax policy analysis stands complete without examination of equity implications. But...

 

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The Promise of International Tax Scholarship and its Implications for Research Design, Theory and Methodology, St. Louis University Law Journal (2010)

What should international tax scholars be doing? Over the past two decades, international tax has...

 

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Who is Making International Tax Policy? International Organizations as Power Players in a High Stakes World, Fordham International Law Journal (2010)

Who makes international tax policy in today’s world? Certainly no single body possesses that power...

 

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Democracy, Sovereignty and Tax Competition: The Role of Tax Sovereignty in Shaping Tax Cooperation, Florida Tax Review (2009)

This paper considers the question of how sovereignty shapes arguments over the merits of tax...

 

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What's at Stake in the Sovereignty Debate?: International Tax and the Nation-State, Virginia Journal of International Law (2008)

The international tax problems of today are typically beyond the scope of a single nation...

 

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A New View of Global Tax, BC Law Magazine 16, no.2 (Spring/Summer 2008): 30, 52-53. (2008)

This column is based on the article “International Tax Relations: Theory and Implications,” which was...

 

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Taxation as a Global Socio-Legal Phenomenon (with Allison Christians, Steven Dean, and Adam H. Rosensweig), ILSA Journal of International and Comparative Law (2008)

This essay makes a proposal that might be controversial among tax scholars even if it...

 

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Why Happiness?: A Commentary On Griffith's Progressive Taxation And Happiness, Boston College Law Review (2004)

This Commentary examines three issues raised in Professor Thomas D. Griffith's Article on the connection...

 
U.S. National Report on Double Taxation, Cahiers de Droit Fiscal International (2004)
 

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One Nation Among Many: Policy Implications of Cross-Border Tax Arbitrage, Boston College Law Review (2002)

Cross-border tax arbitrage arises where a transaction is subject to two or more countries’ differing...

 

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Prospects for a Multilateral Tax Treaty, Brooklyn Journal of International Law (2001)
 

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On the Frontier of Procedural Innovation: Advance Pricing Agreements and the Struggle to Allocate Income for Cross Border Taxation, Michigan Journal of International Law (2000)

The past decade has been a tumultuous and energized period in the study of administrative...

 
Tax Aspects of Derivative Financial Instruments (with David Rosenbloom and Charles Plambeck), Cahiers de Droit Fiscal International (1995)
 

Selected Professional Activities

Transparency and Disclosure, U.N. Workshop on Tax Base Protection for Developing Countries (2014)
 
The New Human Equity Transactions, Law & Society Conference (2014)

Also presented at the University of Baltimore Law School Critical Tax Theory Workshop (2014).

 
Research Methodology, Legal Research in International and EU Tax Law, Leiden University International Tax Center (2014)
 
Panelist: Teaching Ethics: Just Whose Responsibility Is It?, ABA Tax Section Mid-Year Meeting (2014)
 
Panelist: Ethical Issues in International Tax Practice, 25th Annual Institute on Current Issues in International Taxation, Sponsored by the Internal Revenue Service & George Washington University Law School (2013)
 
Sovereign Harmony, Domestic Discord: Democracy and the Gap Between International Tax Cooperation and Domestic Politics, Tax Policy Colloquium at the McGill Faculty of Law (2013)

Also presented at the Law & Society Conference (2014).

 
Panelist, "U.S. Tax Policy in a Global Economy", The 100th Anniversary of the Revenue Act of 1913: Marking a Century of Income Tax Law in the United States, New York Law School (2013)
 
Current Efforts to Tackle International Tax Evasion, Radzyner School of Law Symposium on Current Issues in International Taxation (2013)
 
Conceptualizing a New Institutional Framework for International Taxation, International Taxation Roundtable, Washington University Law School (2013)
 
Ethical Issues in International Tax Practice, International Fiscal Association Conference (2013)
 
Ethical Issues in International Tax Practice, GWU-IRS International Tax Conference (2012)
 
Transfer Pricing Update and New Directions, Boston Tax Forum (2012)
 
Moderator, International Tax Research Symposium, 66th Congress of the International Fiscal Association (2012)
 
Comparisons v. Comparative Analysis, International Tax Conference in honor of Hugh Ault (2012)
 
The Ethical Framework - Duties of the Tax Practitioner to the Client and to the System, 64th Annual Virginia Conference On Federal Taxation (2012)
 
Incubator Session: Understanding the OECD as a Global Tax Power, Critical Tax Theory Workshop, Seton Hall Law School (2012)
 
Backdoor Harmonization?: Implications of the New Era of Tax Information Exchange, Australasian Tax Teachers Association Annual Conference, University of Sydney (2012)
 
Ethical Problems in Tax Practice, 24th Annual IRS-GWU International Tax Conference, Internal Revenue Service and George Washington University (2011)
 
Passive Foreign Investment Companies, Unversity of Chicago Annual Federal Tax Conference (2011)
 
Sovereign Harmony, Domestic Discord, Critical Tax Theory Workshop, Santa Clara University School of Law (2011)
 
The Ethical Framework: Duties of the Tax Practitioner to the Client and to the System (with Scott Michel), University of Miami Law School (2011)
 
Backdoor Harmonization?: Implications of the New Era of Tax Information Exchange, Tulane Tax Roundtable, Tulane Law School (2011)
 
Ethical Problems in International Tax Practice, 23rd Annual IRS-GWU International Tax Conference (2010)
 
The Changing Face of International Tax Scholarship and Its Implications for Research, Design, Theory and Methodology, St. Louis University School of Law Conference on Critical Issues in International and Comparative Taxation (2010)
 
Role of International Organizations in Shaping Tax Policy, Hebrew University Law School Tax Policy Workshop (2010)
 
Current Issues in Transfer Pricing, Boston Tax Forum (2010)
 
Aggressive Tax Planning Using Cross Border Financial Instruments, 3rd International Tax Dialogue Global Conference (2009)
 
An Overview of Innovative Financial Instruments and Their Implications for Tax Policy, The 3rd International Tax Dialogue Global Conference (2009)
 
Taxation of Mobile Income - Income from Intangibles, International Fiscal Association Annual Meeting (2009)
 
Role of International Organizations in Shaping Tax Policy, Critical Tax Theory Workshop, Florida State University Law School (2009)
 
Role of International Organizations in Shaping Tax Policy, Critical Tax Theory Workshop (2009)
 
Role of International Organizations in Shaping Tax Policy, McGill University Faculty of Law Tax Policy Workshop (2009)
 
Tax Sovereignty as a Window onto the Possibilities and Limits of Tax Cooperation, University of Montreal Invited Conference on Tax Competition (2008)
 
What's at Stake in the Sovereignty Debate?: International Tax and the Nation-State, Northwestern University Law School Tax Policy Seminar (2008)
 
Democracy Sovereignty and Tax Competition: The Role of Tax Sovereignty in Shaping Tax Cooperation, University of Florida International Tax Symposium, University of Florida Levin College of Law (2008)
 
Sovereignty and International Tax Policy, International Law Association, International Law Weekend (2007)
 
Role of Sovereignty in International Tax, Harvard Law School Seminar on Current Research Issues in Tax Policy (2007)
 
Sovereignty and International Tax, 2007 Annual Critical Tax Conference (2007)
 
International Tax Relations: Theory and Implications, University of Toronto Law School (2006)
 
International Tax Relations: Theory and Implications, Mercer University School of Law (2006)
 
Inside the United States APA Program, Peking University (2005)
 
Double Nontaxation Report, IFA US Meeting (2004)