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Avi-Yonah, Reuven S.

Irwin I. Cohn Professor of Law

341 Hutchins Hall
734.647.4033
E-mail aviyonah@umich.edu
Reuven S. Avi-Yonah, the Irwin I. Cohn Professor of Law and director of the International Tax LLM Program at the University of Michigan Law School, specializes in corporate and international taxation. He has served as a consultant to the U.S. Treasury Department and the Organisation for Economic Co-operation and Development (OECD) on tax competition, and is a member of the steering group for OECD's International Network for Tax Research. He is also the chair of the AALS Tax Section and trustee of the American Tax Policy Institute, a fellow of the American Bar Foundation, and an international research fellow at Oxford University's Centre for Business Taxation. In addition to prior teaching appointments at Harvard University (law) and Boston College (history), he practiced law with Milbank, Tweed, Hadley & McCloy in New York; with Wachtell, Lipton, Rosen & Katz, New York; and with Ropes & Gray, Boston. After receiving his BA, summa cum laude, from Hebrew University, he earned three additional degrees from Harvard University: an AM in history, a PhD in history, and a JD, magna cum laude, from Harvard Law School. He has published over 150 books and articles, including International Tax as International Law (Cambridge University Press, 2007) and Global Perspectives on Income Taxation Law (Oxford University Press, 2011).

Recent Publications

More Publications...


Advanced Introduction to International Tax Law. Elgar, Forthcoming, 2015.​​

Co-author. A Model Treaty for the Age of BEPS. O. Halabi, co-author. U of Michigan Public Law Research Paper No. 411, U of Michigan Law & Econ Research Paper No. 14-012. Working Paper, 2014.
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The Parallel March of the Ginis: How Does Taxation Relate to Inequality and What Can Be Done About it? Univ. of Michigan Public Law and Legal Theory Working Paper Series, No. 385; Univ. of Michigan Law School, Law & Economics Research Paper Series, No. 14-003. Working Paper, 2014.
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No Country is an Island: Is a Radical Rethinking of International Taxation Needed? Univ. of Michigan Public Law and Legal Theory Working Paper Series, No. 380. Working Paper, 2014.
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Just Say No: Corporate Taxation and Corporate Social Responsibility. Univ. of Michigan Public Law Research Paper No. 402, Univ of Michigan Law & Econ Research Paper No. 14-010. Working Paper, 2014.
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Is it Time to Coordinate Corporate Tax Rates? A Note on Horst. Univ. of Michigan Public Law and Legal Theory Working Paper Series, No. 381. Working Paper, 2014.
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Co-author. IGAs vs. MAATM: Has Tax Bilateralism Outlived Its Usefulness? G. Savir, co-author. Univ. of Michigan Public Law and Legal Theory Working Paper Series, No. 384; Univ. of Michigan Law School, Law & Economics Research Paper Series, No. 14-002. Working Paper, 2014.
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Who Invented the Single Tax Principle? An Essay on the History of US Treaty Policy. University of Michigan Public Law & Legal Theory Research Paper Series, No. 318. Working Paper, 2013.
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What Goes Around Comes Around: Why the US is Responsible for Capital Flight (And What it Can Do About it). University of Michigan Public Law & Legal Theory Research Paper Series, No. 307. Working Paper, 2013.
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Virtual PE: International Taxation and the Fairness Act. University of Michigan Public Law & Legal Theory Research Paper Series, No. 328. Working Paper, 2013.
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Co-author. Unitary Taxation and International Tax Rules. Z. P. Tinhaga, co-author. Univ. of Michigan Public Law and Legal Theory Working Paper Series, no. 369; Univ. of Michigan Law School, Law & Economics Research Paper Series, no. 13-020. Working Paper, 2013.
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Splitting the Unsplittable: Toward a Formulary Approach to Allocating Residuals Under Profit Split. Univ. of Michigan Public Law and Legal Theory Working Paper Series, No. 378. Working Paper, 2013.
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​FIRPTA, Branch Profit Tax and Earning Stripping: Reflections on Non-Discrimination. University of Michigan Public Law & Legal Theory Research Paper Series, No. 319. Working Paper, 2013.
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Tax Competition and the Trend toward Territoriality. University of Michigan Public Law & Legal Theory Research Paper Series, No. 297. Working Paper, 2012.
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Co-author. Double or Nothing: A Tax Treaty for the 21st Century. O. Halabi, co-author. Working Paper, 2012.
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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'. Univ. of Michigan Public Law and Legal Theory Working Paper Series, no. 269. Working Paper.
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Co-author. US Subpart F Legislative Proposals: A Comparative Perspective. N. Sartori, co-author. University of Michigan Law & Economics Research Paper Series, No. 12-003; University of Michigan Public Law & Legal Theory Research Paper Series, No. 264. Working Paper.
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Co-author. Real Time Audit - It is the Time to Act? Oz Halabi, co-author. Univ. of Michigan Empirical Legal Studies Center Working Paper Series, no. 11-010; Univ. of Michigan Public Law and Legal Theory Working Paper Series, no. 242. Working Paper.
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Deja Vu All Over Again? Reflections on Auerbach's "Modern Corporate Tax". Univ. of Michigan Empirical Legal Studies Center Working Paper Series, no. 10-030; Univ. of Michigan Public Law and Legal Theory Working Paper Series, no. 226. Working Paper.
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Corporate and International Tax Reform: Long-, Medium-, and Short Term Proposals. Univ. of Michigan Law School, The John M. Olin Center for Law & Economics Working Paper Series, no. 09-015; Univ. of Michigan Public Law and Legal Theory Working Paper Series, no. 157. Working Paper.
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"The Devil in the Details: Reflections on the Camp Draft." Tax Notes Int'l 73, no. 12 (2014): 1054-7.
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Co-author. "The 1 Percent Solution: Corporate Tax Returns Should be Public (and How to Get There)." A. Siman, co-author. Tax Notes Int'l 73, no. 7 (2014): 627-8.
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​"Reflections on the 'New Wave' Inversions and Notice 2014-52." Tax Notes 145, no. 1 (2014): 95-8. (Published concurrently under the same title in Tax Notes Int'l 76, no. 1 (2014): 63-5.)​
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"Reflections on the 'New Wave' Inversions and Notice 2014-52." Tax Notes Int'l 76, no. 1 (2014): 63-5. (Published concurrently under the same title in Tax Notes 145, no. 1 (2014): 95-8.)
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"Back from the Dead: Reviving Transfer Pricing Enforcement." Tax Notes Int'l 73, no. 1 (2014): 10-3.
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走出迷局:21世纪的税收范式 [And Yet It Moves: Taxation and Labor Mobility in the Twenty-First Century]." Int'l Tax'n China 67, no. 4, 5, 6 (2014): 42-8, 32-7, 28-34. (Published concurrently under the same title in Tax L. Rev.  67 (2014): 169.)​

"And Yet It Moves: Taxation and Labor Mobility in the Twenty-First Century." Tax L. Rev. 67 (2014): 169. (Published in Chinese under the same title in Int'l Tax'n China 67, no. 4, 5, 6 (2014): 42-8, 32-7, 28-34.)
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"Why Y? Reflections on the Baucus Proposal." Tax Notes Int'l 72, no. 11 (2013): 1005-8. (Published online Dec. 16, 2013)
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"Territoriality: For and Against." Tax Notes Int'l 70, no. 7 (2013): 661-3. (Published online May 13, 2013)
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"Should the US Dictate World Tax Policy? Reflections on PPL." Tax Notes 138 (2013): 871-3.
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"Should the U.S. Dictate World Tax Policy? Reflections on PPL Corporation v. Commissioner." Tax Notes Int'l 69, no. 7 (2013): 671-3. (Published online Feb. 18, 2013)
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"Corporate and International Tax Reform: Proposals for the Second Obama Administration (and Beyond)." Pepp. L. Rev. 40, no. 5 (2013): 1364-72.
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​"Carbon Tax, Health Care Tax, Bank Tax, and Other Regulatory Taxes." In Beyond Economic Efficiency in United States Tax Law, edited by D. A. Brennen, K. B. Brown, and D. K. Jones, 183-90. Aspen Elective Series. New York: Wolters Kluwer Law & Business, 2013.​​

"Arguments For and Against Territoriality." Tax Notes 139, no. 7 (2013): 797-99. (Published online May 13, 2013)
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​Foreword to International Taxation of Electronic Commerce, by R. Azam, xiii-xviii. Sacher Institute for Legislative Research and Comparative Law. Jerusalem: Hebrew University of Jerusalem, (2013).​​

"Vive La Petite Difference: Camp, Obama, and Territoriality Reconsidered." Tax Notes Int'l 66, no.7 (2012): 617-9.
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Co-author, "US Treaty Anti-Avoidance Rules: An Overview and Assessment." O. Halabi, co-author. Bull. for Int'l Tax'n 66, no. 4/5 (2012): 236-42.
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​"Transfer Pricing Disputes in the United States." In Resolving Transfer Pricing Disputes: A Global Analysis, edited by E. Baistrocchi and I. Roxan. New York: Cambridge Univ. Press, 2012.

Review of The Making of Tax Law: The Development of the Swedish Tax System, by S-O Lodin. Tax Notes Int'l 66, no. 8 (2012): 745-6.
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Co-author. "The Effective Tax Rate of the Largest US and EU Multinationals." Y. Lahav, co-author. Tax L. Rev. 65, no. 3 (2012): 375-90.
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Co-author. "Symposium on International Taxation and Competitiveness: Introduction and Overview." N. Sartori, co-author. Tax L. Rev. 65, no. 3 (2012): 313-22.
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"Slicing the Shadow: A Proposal for Updating U.S. International Taxation." Tax Notes 135, no. 10 (2012): 1229-34. (Originally published under the same title in Tax Notes 58 (1993): 1511)
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Co-author. U.S. International Taxation: Cases and Materials. 3rd ed. D. M. Ring and Y. Brauner, co-authors. University Casebook Series. New York: Foundation Press, 2011.

"The Political Pathway: When Will the US Adopt a VAT?" In The VAT Reader: What a Federal Consumption Tax Would Mean for America, 334-7. Washington, DC: Tax Analysts, 2011.
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Co-author. "The Case for Dividend Deduction." A. C. Chenchinski, co-author. Tax Law. 65, no. 1 (2011): 3-14.
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"Taxation as Regulation: Carbon Tax, Health Care Tax, Bank Tax and Other Regulatory Taxes." Acct. Econ. & L. 1, no. 1 (2011): Article 6.
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"Money on the Table: Why the U.S. Should Tax Inbound Capital Gains." Tax Notes Int'l 63, no. 1 (2011): 41-7.
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Co-author. Global Perspectives on Income Taxation Law. N. Sartori and O. Marian, co-authors. New York: Oxford Univ. Press, 2011.

Co-author. "Formulary Apportionment: Myths and Prospects - Promoting Better International Policy and Utilizing the Misunderstood and Under-Theorized Formulary Alternative." Ilan Benshalom, co-author. World Tax J. 3, no. 3 (2011): 371-98.
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"Citizens United and the Corporate Form." Acct. Econ. & L. 1, no. 3 (2011): 1-54. (A previous version of this paper was published in Wis. L. Rev. 2010, no. 4 (2010): 999-1047.)
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"Beyond Territoriality and Deferral: The Promise of "Managed and Controlled"." Tax Notes Int'l 63, no. 9 (2011): 667-8.
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"Xilinx Revisited." Tax Notes Int'l 59, no. 2 (2010): 1141-2.
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"The Redemption Puzzle Redux." Tax Notes 128, no. 11 (2010): 1183.
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"The Redemption Puzzle." Tax Notes 128, no. 8 (2010): 853-5.
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"The Case Against Taxing Citizens." Tax Notes Int'l 58, no. 5 (2010): 389-94.
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"Tax Convergence and Globalization." Revista Tributaria das Americas 1 (2010): 140.
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"Summary and Recommendations." Tax L. Rev. 63, no. 2 (2010): 285-300. (Symposium on Designing a Federal VAT, Part I.)
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Co-author. "Rethinking Treaty Shopping: Lessons for the European Union." C. H. Panayi, co-author. In Tax Treaties: Building Bridges between Law and Economics, 21-50. Amsterdam: IBFD, 2010.
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Co-author. "Comparative Tax Law: Theory and Practice." G. Inbar, O. Marian, and L. Mello, co-authors. Bull. for Int'l Tax'n 64, no. 3 (2010): 183-5.
Full Text: IBFD (UMIch users) | IBFD

"Citizens United and the Corporate Form." Wis. L. Rev. 2010, no. 4 (2010): 999-1047.
Full Text: MLaw Repository | SSRN | HEIN (UMich users) | HEIN | Westlaw

"Between Formulary Apportionment and the OECD Guidelines: A Proposal for Reconciliation." World Tax J. 2, no. 1 (2010): 3-18.
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"Xilinx and the Arm's-Length Standard." Tax Notes 123, no. 10 (2009): 1231-6.
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"The OECD Harmful Tax Competition Report: A Tenth Anniversary Retrospective." Brook. J. Int'l L. 34, no. 3 (2009): 783-95.
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"Taxation, Corporate Social Responsibility and the Business Enterprise." Comparative Research in Law & Political Economy Research Paper no. 19/2009. Toronto: Osgoode Hall Law School, vol. 5, no. 3 (2009).
Full Text: SSRN

"Tax Reform in a Global Economy: Obama's Plan." Tax Notes 123, no. 6 (2009): 735-8.
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"Structuring a US Federal VAT." Int'l VAT Monitor 20, no. 4 (2009): 275-9.
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"Risks, Rents and Regressivity Revisited." Austl. Tax F. 24, no. 1 (2009): 41-57.

"International Law: Private Law in United States Law." In Oxford International Encyclopedia of Legal History, edited by S.N. Katz, 284-90. Oxford: Oxford Univ. Press, 2009.

"Double Tax Treaties: An Introduction." In The Effect of Treaties on Foreign Direct Investment: Bilateral Investment Treaties, Double Taxation Treaties and Investment Flows, edited by K. P. Sauvant and L. E. Sachs, 99-106. Oxford: Oxford Univ. Press, 2009.
Full Text: SSRN

Co-author. "Combating Global Climate Change: Why a Carbon Tax is a Better Response to Global Warming than Cap and Trade." D.M. Uhlmann, co-author. Stan. Envtl. L.J. 28, no. 1 (2009): 3-50.
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"Closing the International Tax Gap Via Cooperations, Not Competition." In Toward Tax Reform: Recommendations for President Obama's Task Force, 13-5. Falls Church, VA: Tax Analysts, 2009.

Co-author. "Allocating Business Profits for Tax Purposes: A Proposal to Adopt a Formulary Profit Split." K.A.Clausing and M.C.Durst, co-authors. Fla. Tax Rev. 9, no. 5 (2009): 497-553.
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Professor

Activities

Taught transfer pricing and value-added tax at Catholic University Law School's Tax Summer School, Lisbon, Portugal, June 2013.

Presented on taxation and corporate social responsibility and tax at the School of Advanced Legal Studies, University of London, June 2013.

Presented papers on capital and labor mobility and on base erosion at the Oxford University Centre for Business Taxation, June 2013.

Moderated a panel, "Does the U.S. need a VAT?", at the AALS Annual Meeting, New Orleans, January 2013.

Presented "Taxation and Capital/Labor Mobility" at McGill University, Montreal, October 2012.

Keynote speaker at the San Diego Law School's 2012 International Tax Institute, where he received the Richard Pugh Distinguished International Tax Award, October 2012.

Presented "International Allocation of the Corporate Tax Base" and "Capital/Labor Mobility and 21st Century Taxation" at the International Fiscal Association Conference, Boston, October 2012.

Testified before the Senate Permanent Subcommittee on Investigations about offshore profit sharing and the U.S. tax code, September 2012.

Keynote speaker for the Tax Justice Network/Ministry of Foreign Affairs conference on transfer pricing at the Parliament of Finland, June 2012.

Presented "And Yet It Moves: A Tax Paradigm for the 21st Century" at a workshop at Tel Aviv University; at the Columbia-Ono Conference on Corporate Governance, Taxes, and Social Justice; and at Israel's College of Management Law School, June 2012.

Chaired panel on corporate tax reform, ABA Tax Section meeting, Boca Raton, Florida, January 2011.

Chaired panel on "Taxation in Developing Countries," AALS annual meeting, San Francisco, January 2011.

 
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