Tax Expenditures and Horizontal Equity: A Lost Lesson from Stanley Surrey. Nir Fishbien, co-author. Working Paper.
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Stanley Surrey, the Code and the Regime. Nir Fishbien and Gianluca Mazzoni, co-authors. Working Paper.
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If Not Now, When? US Tax Treaties with Latin America After TCJA. University of Michigan Law & Economics Research Paper No. 19-006; University of Michigan Public Law & Legal Theory Research Paper No. 641. Working Paper.
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Does Customary International Tax Law Exist? University of Michigan Law & Economics Research Paper No. 19-005; University of Michigan Public Law & Legal Theory Research Paper No. 640. Working Paper.
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Human-Centered Business Model, Pillar 4--Ranking Systems. Bonnie Liu, co-author. Working Paper.
The International Provisions of the TCJA: Six Results after Six Months. University of Michigan Law & Economics Research Paper No. 18-021; University of Michigan Public Law & Legal Theory Research Paper No. 621. Working Paper.
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Bridging the Red-Blue Divide: A Proposal for U.S. Regional Tax Relief. Orli Avi-Yonah, Nir Fishbien, and Haiyan Xu, co-authors. University of Michigan Public Law & Legal Theory Research Paper No. 620. Working Paper.
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SSRN Altera and the Arm's Length Standard. University of Michigan Public Law Research Paper No. 616. Working Paper.
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SSRN "Putting the Public Benefit in Cost Benefit Analysis of Tax Regulations: A Response to Hemel, Nou and Weisbach." Yoseph M. Edrey, co-author. (Working Paper).
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Designing a 21st Century Taxing Threshold: Some International Implications of South Dakota vs. Wayfair. University of Michigan Public Law Research Paper No. 611. Working Paper.
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SSRN The International Provisions of the TCJA: A Preliminary Summary and Assessment. University of Michigan Public Law Research Paper No. 605. Working Paper.
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SSRN The Games They Will Play: An Update on the Conference Committee Tax Bill. L. L. Batchelder et al., co-authors. Working Paper.
Full Text: SSRN The Elephant Always Forgets: US Tax Reform and the WTO. Martin Vallespinos, co-author. University of Michigan Law & Economics Research Paper No. 18-006, University of Michigan Public Law Research Paper No. 596. Working Paper.
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The Elephant Always Forgets: Tax Reform and the WTO. University of Michigan Law & Economics Research Paper No. 18-001; University of Michigan Public Law & Legal Theory Research Paper No. 585. Working Paper.
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SSRN Taxation for a New 'New Deal': Short-, Medium-, and Long-Term Options. Working Paper.
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How Terrible Is the New Tax Law? Reflections on TRA17. University of Michigan Law & Economics Research Paper No. 18-002; University of Michigan Public Law & Legal Theory Research Paper No. 586. Working Paper.
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Beat It: Tax Reform and Tax Treaties. University of Michigan Law & Economics Research Paper No. 18-003; University of Michigan Public Law & Legal Theory Research Paper No. 587. Working Paper.
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SSRN The Trump Tax Reform Plan: Implications for Europe. G. Mazzoni, co-author. University of Michigan Law & Economics Research Paper No. 17-009; University of Michigan Public Law & Legal Theory Research Paper No. 559. Working Paper.
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The Triumph of BEPS: US Tax Reform and the Single Tax Principle. University of Michigan Public Law & Legal Theory Research Paper No. 579; University of Michigan Law & Economics Research Paper No. 17-021. Working Paper.
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SSRN What a Difference Thirty Years Make: A Comparison to the Tax Reforms of 1986, 2014 and 2017. University of Michigan Public Law Research Paper No. 576; University of Michigan Law & Economics Research Paper No. 17-019. Working Paper.
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The Three Causes of Inversions: Reflections on Pfizer/Allergan and Notice 2015-79. University of Michigan Law & Economics Research Paper No. 15-021; University of Michigan Public Law & Legal Theory Research Paper No. 488. Working Paper.
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Slicing and Dicing: The Structural Problems of the Tax Reform Framework. University of Michigan Law & Economics Research Paper No. 17-015; University of Michigan Public Law & Legal Theory Research Paper No. 567. Working Paper.
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SSRN Should Us Tax Law Be Constitutionalized? Centennial Reflections on Eisner v. Macomber (1920). Working Paper.
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Destination Based Corporate Tax: An Alternative Approach. University of Michigan Law & Economics Research Paper No. 16-028; University of Michigan Public Law & Legal Theory Research Paper No. 529. Working Paper.
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SSRN China and the Future of the International Tax Regime. H. Xu, co-author. University of Michigan Law & Economics Research Paper No. 17-017; University of Michigan Public Law & Legal Theory Research Paper No. 572. Working Paper.
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Amazon vs. Commissioner: Has Cost Sharing Outlived Its Usefulness? University of Michigan Law & Economics Research Paper No. 17-003; University of Michigan Public Law & Legal Theory Research Paper No. 551. Working Paper.
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SSRN Are Taxes Converging? G. Mazzoni, co-author. Review of
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SSRN Global Taxation After the Crisis: Why BEPS and MAATM are Inadequate Responses, and What Can Be Done About It. H. Xu, co-author. University of Michigan Public Law & Legal Theory Research Paper No. 494. Working Paper.
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The International Tax Regime: A Centennial Reconsideration. University of Michigan Public Law & Legal Theory Research Paper No. 462. Working Paper.
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Find It and Tax It: From TIEAs to IGAs. Savir, G., co-author. University of Michigan Public Law & Legal Theory Research Paper No. 443. Working Paper.
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SSRN A Model Treaty for the Age of BEPS. O. Halabi, co-author. University of Michigan Public Law & Legal Theory Research Paper No. 411; University of Michigan Law & Economics Research Paper No. 14-012. Working Paper.
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Why Not Tax the Rich? Review of Kleinbard's 'We are Better Than This'. University of Michigan Public Law & Legal Theory Research Paper No. 426. Working Paper.
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The Parallel March of the Ginis: How Does Taxation Relate to Inequality and What Can Be Done About it? University of Michigan Public Law and Legal Theory Research Paper No. 385; University of Michigan Law & Economics Research Paper No. 14-003. Working Paper.
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Splitting the Unsplittable: Toward a Formulary Approach to Allocating Residuals Under Profit Split. University of Michigan Public Law & Legal Theory Research Paper No. 378. Working Paper.
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Reinventing the Wheel: What We Can Learn from the Tax Reform Act of 1986. University of Michigan Public Law & Legal Theory Research Paper No. 424; University of Michigan Law & Economics Research Paper No. 14-018. Working Paper.
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No Country is an Island: Is a Radical Rethinking of International Taxation Needed? University of Michigan Public Law & Legal Theory Research Paper No. 380. Working Paper.
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Is it Time to Coordinate Corporate Tax Rates? A Note on Horst. University of Michigan Public Law & Legal Theory Research Paper No. 381. Working Paper.
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A World Turned Upside Down: Reflections on the 'New Wave' Inversions and Notice 2014-52. University of Michigan Public Law & Legal Theory Research Paper No. 421. Working Paper.
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Virtual PE: International Taxation and the Fairness Act. University of Michigan Public Law & Legal Theory Research Paper No. 328. Working Paper.
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Tax Competition and the Trend toward Territoriality. University of Michigan Public Law & Legal Theory Research Paper No. 297. Working Paper.
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FIRPTA, Branch Profit Tax and Earning Stripping: Reflections on Non-Discrimination. University of Michigan Public Law & Legal Theory Research Paper No. 319. Working Paper.
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SSRN US Subpart F Legislative Proposals: A Comparative Perspective. N. Sartori, co-author. University of Michigan Law & Economics Research Paper No. 12-003; University of Michigan Public Law & Legal Theory Research Paper No. 264. Working Paper.
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Taxation in a Small Country: Review of Sven-Olof Lodin's 'The Making of Tax Law - The Development of Swedish Taxation'. University of Michigan Public Law & Legal Theory Research Paper No. 269. Working Paper.
Full Text: SSRN Double or Nothing: A Tax Treaty for the 21st Century. O. Halabi, co-author. University of Michigan Law & Economics Research Paper No. 12-009. Working Paper.
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SSRN Real Time Audit - It is the Time to Act? O. Halabi, co-author. University of Michigan Empirical Legal Studies Center Research Paper No. 11-010; University of Michigan Public Law & Legal Theory Research Paper No. 242. Working Paper.
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Deja Vu All Over Again? Reflections on Auerbach's "Modern Corporate Tax". University of Michigan Law & Economics Empirical Legal Studies Center Research Paper No. 10-030; University of Michigan Public Law & Legal Theory Research Paper No. 226. Working Paper.
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Corporate and International Tax Reform: Long-, Medium-, and Short Term Proposals. University of Michigan John M. Olin Center for Law & Economics Research Paper No. 09-015; University of Michigan Public Law & Legal Theory Research Paper No. 157. Working Paper.
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SSRN "Federalizing Tax Justice." Co-authored by Orli Avi-Yonah, Nir Fishbien, and Hayian Xu.
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WWW"Reforming State Corporate Income Taxes Can Yield Billions." Darien Shanske and David Gamage, co-authors. Tax Notes State 96, no. 10 (2020): 1211-8.
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"Do Lawyers Need Economists?" Review of
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MLaw Repository"COVID-19 and US Tax Policy: What Needs to Change?"
Intertax 48, no. 8 & 9 (2020): 790-3.
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Int'l Tax J. 46, no. 2 (2020): 29-33.
"Why R&D Should be Allocated to Subpart F and GILTI." Stephen E. Shay, Patrick Driessen, J. Clifton Fleming Jr., and Robert J. Peroni, co-authors.
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MLaw Repository"The Digital Consumption Tax." N. Fishbien, co-author. Intertax 48 (2020): 538.
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"Taxing the Digital Economy: A Short Book Review." Review of Taxing the Digital Economy: Theory, Policy and
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"Rodriguez, Tucker, and the Dangers of Textualism." Tax Notes. 166 (2020): 87.
"Why Study Tax History?" Review of Studies in the History of Tax Law, Volume 9, by Peter Harris and Dominic de Cogan, editors.
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MLaw Repository"Antitrust and the Corporate Tax: Why We Need Progressive Corporate Tax Rates." Lior Frank, co-author.
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MLaw Repository"A Positive Dialectic: Beps and The United States."
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MLaw Repository"A U.S. DST? The Potential Impact of the Cloud Regulations." Karen Sam, co-author.
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"BEPS, ATAP and the New Tax Dialogue: A Transatlantic Competition?" Gianluca Mazzoni, co-author. In
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SSRN"Use and Abuse of the Single Tax Principle: A Comparative Review of Recent Italian Supreme Court Treaty Cases." Gianluca Mazzoni, co-author. Diritto e practica tributaria internazionale 16, no. 4 (2019): 849-86.
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IBFD"Amazon Goldcrest Project and the Relevance of Comparability Analysis under the Arm's Length Principle." Andrea Musselli, co-author.
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Advanced Introduction to International Tax Law. 2nd ed. Elgar Advanced Introductions. Cheltenham, U.K.: Edward Elgar Publishing, 2019.
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MLaw Repository "The BEAT and Treaty Overrides: A Brief Response to Rosenbloom and Shaheen." Bret Wells, co-author.
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"Does the United States Still Care About Complying with Its WTO Obligations?"
Colum. J. Tax L. Tax Matters 9, no. 2 (2018): 12-3.
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MLaw Repository"Be Careful What You Wish For? Reducing Inequality in the 21st Century." Orli K. Avi-Yonah, co-author. Review of
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MLaw Repository "International Tax Avoidance -- Introduction." Introduction to
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WWW"Three Steps Forward, One Step Back? Reflection on "Google Taxes" and the Destination-Based corporate Tax."
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