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Avi-Yonah, Reuven S.

Irwin I. Cohn Professor of Law
Director, International Tax LLM Program

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, specializes in corporate and international taxation. He has served as a consultant to the U.S. Department of the Treasury 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 also is a member of the American Law Institute, a fellow of the American Bar Foundation and the American College of Tax Counsel, 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 in New York; and with Ropes & Gray in 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 more than 150 books and articles, including Advanced Introduction to International Tax (Elgar, 2015), Global Perspectives on Income Taxation Law (Oxford University Press, 2011), and International Tax as International Law (Cambridge University Press, 2007).

Recent Publications

More Publications...


Stanley Surrey, the Code and the Regime. Nir Fishbien and Gianluca Mazzoni, co-authors. Working Paper.
Full Text: SSRN

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.
Full Text: SSRN

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.
Full Text: SSRN

Globalization, Tax Competition and the Fiscal Crisis of the Welfare State: A Twentieth Anniversary Retrospective. University of Michigan Law & Economics Research Paper No. 19-002; University of Michigan Public Law & Legal Theory Research Paper No. 634. Working Paper.
Full Text: MLaw Repository | SSRN

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.
Full Text: MLaw Repository | SSRN

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.
Full Text: SSRN

Altera and the Arm's Length Standard. University of Michigan Public Law Research Paper No. 616. Working Paper.
Full Text: 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).
Full Text: SSRN

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.
Full Text: SSRN

Due Diligence in International Tax Law. Gianluca Mazzoni, co-author. University of Michigan Public Law Research Paper No. 608. Working Paper.
Full Text: SSRN

The International Provisions of the TCJA: A Preliminary Summary and Assessment. University of Michigan Public Law Research Paper No. 605. Working Paper.
Full Text: 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.
Full Text: MLaw Repository | SSRN

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.
Full Text: MLaw Repository | SSRN

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.
Full Text: MLaw Repository | SSRN

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.
Full Text: MLaw Repository | 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.
Full Text: SSRN

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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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.
Full Text: SSRN

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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Special Tax Zones and the WTO. M. Vallespinos, co-author. University of Michigan Public Law & Legal Theory Research Paper No. 545. Working Paper.
Full Text: SSRN

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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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.
Full Text: 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.
Full Text: MLaw Repository | SSRN

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.
Full Text: SSRN

Are Taxes Converging? G. Mazzoni, co-author. Review of A Global Analysis of Tax Treaty Disputes, by E. Baistrocchi, ed. University of Michigan Law & Economics Research Paper No. 17-018; University of Michigan Public Law & Legal Theory Research Paper No. 573. Working Paper.
Full Text: MLaw Repository | SSRN

Taxation and Human Rights: A Delicate Balance. G. Mazzoni, co-author. Public Law and Legal Theory Research Paper No. 520. Working Paper.
Full Text: 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.
Full Text: SSRN

The International Tax Regime: A Centennial Reconsideration. University of Michigan Public Law & Legal Theory Research Paper No. 462. Working Paper.
Full Text: SSRN​​​

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.
Full Text: SSRN

Are we Trapped by Our Capital Gains? D. Zelik, co-author. University of Michigan Public Law & Legal Theory Research Paper No. 476. Working Paper.
Full Text: 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.
Full Text: MLaw Repository | SSRN

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.
Full Text: SSRN

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.
Full Text: MLaw Repository |SSRN

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.
Full Text: SSRN

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.
Full Text: SSRN

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.
Full Text: SSRN

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.
Full Text: SSRN

IGAs vs. MAATM: Has Tax Bilateralism Outlived Its Usefulness? G. Savir, co-author. University of Michigan Public Law & Legal Theory Research Paper No. 384; University of Michigan Law & Economics Research Paper No. 14-002. Working Paper.
Full Text: MLaw Repository | SSRN

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.
Full Text: SSRN

Virtual PE: International Taxation and the Fairness Act. University of Michigan Public Law & Legal Theory Research Paper No. 328. Working Paper.
Full Text: SSRN

Tax Competition and the Trend toward Territoriality. University of Michigan Public Law & Legal Theory Research Paper No. 297. Working Paper.
Full Text: SSRN

​FIRPTA, Branch Profit Tax and Earning Stripping: Reflections on Non-Discrimination. University of Michigan Public Law & Legal Theory Research Paper No. 319. Working Paper.
Full Text: 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.
Full Text: MLaw Repository | SSRN

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.
Full Text: MLaw Repository | 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.
Full Text: MLaw Repository | SSRN | WWW

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.
Full Text: MLaw Repository | SSRN

"What Goes Around Comes Around: Why the USA is Responsible for Capital Flight (And What it Can Do About it)." דין ודברים [Haifa Law Review] 21 (Forthcoming, 2019).
Full Text: SSRN

"BEPS, ATAP and the New Tax Dialogue: A Transatlantic Competition?" Gianluca Mazzoni, co-author. In Combating Tax Avoidance in the EU: Harmonization and Cooperation in Direct Taxation, edited by José M. A. Cid, Jorge A. F. Gutiérrez, and Pablo A. H. González-Barreda, 1-36. EUCOTAX Series on European Taxation, 61. Alphen aan den Rijn, The Netherlands: Kluwer Law International B.V., Forthcoming, 2019.

"The Games They Will Play: Tax Games, Roadblocks, and Glitches Under the 2017 Tax Legislation." David Kamin et al., co-authors. Minn. L. Rev. 103, no. 3 (2019): 1439-521.
Full Text: MLaw Repository | HEIN (UMich Users) | HEIN | Lexis | Westlaw | WWW

"India's New Profit Attribution Proposal and the Arm's-Length Standard." Ajitesh Kir, co-author. Tax Notes Int'l (2019): 1183-90.

​Foreword to Digitalisation and Transfer Pricing - The Way Ahead, by Mohanish Verma, v-vi. Mohali, India: Wolters Kluwer, 2019.

"Complete Distributive Rules and the Single Tax Principle: A Review of Recent Italian Case Law." Gianluca Mazzoni, co-author. Bull. for Int'l Tax'n 73, no. 4 (2019).
Full Text: IBFD (UMich users) | IBFD

"Amazon Goldcrest Project and the Relevance of Comparability Analysis under the Arm's Length Principle." Andrea Musselli, co-author. Int'l Transfer Pricing J. 26, no. 3 (2019): 159-66.
Full Text: IBFD (UMich users) | IBFD

Advanced Introduction to International Tax Law. 2nd ed. Elgar Advanced Introductions. Cheltenham, U.K.: Edward Elgar Publishing, 2019.

"The Transitional Period and its Impact on Tax Competition and the Implementation of the BEPS Project." Haiyan Xu, co-author. In The Implementation of Anti-BEPS Rules in the EU: A Comprehensive Study, edited by Pasquale Pistone and Dennis Weber, 209-58. Amsterdam, The Netherlands: IBFD, 2018.

"The International Implications of Wayfair." Tax Notes 160 (2018): 215-9.
Full Text: MLaw Repository

"The BEAT and Treaty Overrides: A Brief Response to Rosenbloom and Shaheen." Bret Wells, co-author. Tax Notes Int'l 92, no. 4 (2018): 383-91.
Full Text: MLaw Repository

"Formulating a General Anti-Abuse Rule (GAAR) in Tax Legislation: Insights and Recommendations." Amir Pichhadze, co-author. In The Routledge Companion to Tax Avoidance Research, edited by Nigar Hashimzade and Yuliya Epifantseva, 117-35. Routledge Companions in Business, Management and Accounting. London: Routledge, 2018.

"Does the United States Still Care About Complying with Its WTO Obligations?" Colum. J. Tax L. Tax Matters 9, no. 2 (2018): 12-3.
Full Text: MLaw Repository | WWW

"China and BEPS." Haiyan Xu, co-author. Laws 7, no. 1 (2018): 4-30.
Full Text: MLaw Repository | WWW

"BEPS, ATAP, and the New Tax Dialogue: 'A Transatlantic Competition?'" Gianluca Mazzoni, co-author. Intertax 46, no. 11 (2018): 885-904.
Full Text: MLaw Repository

"Be Careful What You Wish For? Reducing Inequality in the 21st Century." Orli K. Avi-Yonah, co-author. Review of The Great Leveler: Violence and the History of Inequality from the Stone Age to the Twenty-First Century, by Walter Scheidel. Mich. L. Rev. 116, no. 6 (2018): 1001-18.
Full Text: MLaw Repository | HEIN (UMich Users) | HEIN | Lexis | Westlaw | SSRN | WWW

"A Global Treaty Override? The New OECD Multilateral Tax Instrument and Its Limits." H. Xu, co-author. Mich. J. Int'l L. 39, no. 2 (2018): 155-216.
Full Text: MLaw Repository | HEIN (UMich Users) | HEIN | Lexis | Westlaw | SSRN

"The United States." D. Zelik, co-author. In Capital Gains Taxation: A Comparative Analysis of Key Issues, edited by M. Littlewood and C. Elliffe, 363-401. Northampton, Mass.: Edward Elgar Publishing, 2017.
Full Text: Elgar Online

"The Four Transformations of the Corporate Form." In Understanding the Company: Corporate Governance and Theory, edited by B. Choundhury and M. Petrin, 17-36. Cambridge: Cambridge University Press, 2017.

"Territoriality and the Original Intent of Subpart F." Tax Notes 155, no. 8 (2017): 1581-87.
Full Text: SSRN

"Tax Symposium: Introduction." Mich. J. Int'l L. 38, no. 2 (2017): 161-5.
Full Text: MLaw Repository | HEIN (UMich Users) | HEIN | Lexis | Westlaw

"Taking the First Bite: Who Should Tax Apple's $187 Billion in Ireland?" G. Mazzoni, co-author. Mich. Tax Law. 42, no. 2 (2017): 9-13.
Full Text: Lexis

"Proposals for International Tax Reform: Problem or Opportunity?" Challenge (2017): 1-5.
Full Text: WWW

"Problems with Destination-Based Corporate Taxes and the Ryan Blueprint." K. Clausing, co-author. Colum. J. Tax L. 8, no. 2 (2017): 229-55.
Full Text: MLaw Repository | HEIN (UMich users) | HEIN | Lexis | SSRN | WWW

"Once More, With Feeling: TRA 17 and Original Intent of Subpart F." N. Fishbien, co-author. Tax Notes 157, no. 7 (2017): 959-970.
Full Text: MLaw Repository 

"International Tax Avoidance -- Introduction." Introduction to Accounting, Economics, and Law: A Convivium, by Reuven S. Avi-Yonah, Yuri Biondi, and Shyam Sunder, co-editors. 7, no. 1 (2017).
Full Text: De Gruyter (UMich users)

"Guilty as Charged: Reflections on TRA 17." Tax Notes 157, no. 8 (2017): 1131-6.
Full Text: MLaw Repository

"Formulary Apportionment and International Tax Rules." In Taxing Multinational Enterprises as Unitary Firms, edited by S. Picciotto, 67-74. Brighton, U.K.: Institute of Development Studies, 2017.
Full Text: SSRN | WWW

"Evaluating BEPS." H. Xu, co-author. Erasmus L. Rev. 10, no. 1 (2017): 3-11.
Full Text: MLaw Repository | HEIN (Umich users) | HEIN | Westlaw | SSRN

"Evaluating BEPS." Haiyan Xu, co-author. In Tax Sovereignty in the BEPS Era, edited by Sergio André Rocha and Allison Christians, 97-124. Series on International Taxation, 60. Alphen aan den Rijn, The Netherlands: Wolters Kluwer, 2017.

"Altera, the Arm's Length Standard, and Customary International Tax Law." Mich. J. Int'l L. Opinio Juris 38 (2017): 1-4.
Full Text: MLaw Repository | WWW

"Three Steps Forward, One Step Back? Reflection on "Google Taxes" and the Destination-Based corporate Tax." Nordic Tax J., no. 2 (2016): 69-76.
Full Text: WWW

"The Inexorable Rise of the VAT: Is the U.S. Next?" Review of The Rise of the Value-Added Tax, by Kathryn James, author. Tax Notes 150, no. 1 (2016): 127-28.
Full Text: MLaw Repository

"Proposals for International Tax Reform: Is There a Middle Road?" Tax Notes 153, no. 9 (2016): 1169-76.
Full Text: WWW

"Is Corporate Integration a Good Idea?" B. Burton et al., co-authors. Tax Notes 151, no. 12 (2016): 1697-704.
Full Text: WWW

Introduction to International Tax Law, vols. I & II, by R. S. Avi-Yonah, editor, ix-xvii. International Law Series, 10. Northampton, Mass.: Edward Elgar Publishing, 2016.

Editor. International Tax Law, vols. I & II. International Law Series, 10. Northampton, Mass.: Edward Elgar Publishing, 2016.

"International Tax Evasion and Avoidance." Am. Prospect 27, no. 2 (2016): 63-7.
Full Text: Lexis | Westlaw | ProQuest (UMich users) | ProQuest

"Hanging Together: A Multilateral Approach to Taxing Multinationals." Mich. Bus. & Entrepreneurial L. Rev. 5, no. 2 (2016): 137-59.
Full Text: MLaw Repository | HEIN (UMich Users) | HEIN | Lexis | Westlaw | SSRN

"GAARs and the Nexus between Statutory Interpretation and the Legislative Drafting: Lessons for the U.S. from Canada." A. Pichhadze, co-author. Acct. Econ. & L. 6 (April 2016).​​
Full Text: WWW

"Full Circle? The Single Tax Principle, BEPS, and The New US Model." Global Tax'n 1, pt. 1 (2016): 12-22.​​
Full Text: MLaw Repository | ProQuest (UMich users) | ProQuest | SSRN

​Foreword to Ten Years of Tax: A Celebration of Professor Michael Littlewood's First Decade at the University of Auckland Faculty of Law, 2003-2013, by B. Basrur et al., co-editors. Christchurch, New Zealand: University of Canterbury, 2016.

"Evaluating BEPS: A Reconsideration of the benefits Principle and Proposal for UN Oversight." H. Xu, co-author. Harv. Bus. L. Rev. 6, no. 2 (2016): 185-238.
Full Text: HEIN (Umich users) | MLaw Repository | HEIN | SSRN

"Country by Country Reporting and Corporate Privacy: Some Unanswered Questions." Colum. J. Tax L. Tax Matters 8, no. 1 (2016): 1-21.
Full Text: MLaw Repository | Lexis | WWW

"Constructive Unilateralism: U.S. Leadership and International Taxation." Int'l Tax J. 42, no. 2 (2016): 17-24.
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Co-editor. Comparative Fiscal Federalism. 2nd ed. M. Lang, co-editor. Eucotax Series. Alphen aan den Rijn, The Netherlands: Wolters Kluwer, 2016.

"Back to the Future? Medtronic and the Future of Transfer Pricing." Int'l Tax J. 42 (2016): 33.
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"Back to 1913?: The Ryan Blueprint and Its Problems." Tax Notes 153, no. 11 (2016): 1367-47.
Full Text: MLaw Repository | Lexis | SSRN

"Apple State Aid Ruling: A Wrong Way to Enforce the Benefits Principle?" G. Mazzoni, co-author. Tax Notes Int'l 84, no. 9 (2016): 837-45.
Full Text: WWW

​"A Tale of Two Cities: Washington, Brussels, and BEPS." Tax Notes 150 (2016): 569-70.

​"A Proposal for Unitary Taxation and Formulary Apportionment (UT+FA) to Tax Multinational Enterprises." In Global Tax Governance: What Is Wrong With It and How to Fix It, edited by P. Dietsch and T. Rixen, 289-306. Colchester, U.K.: ECPR Press, 2016.

"A Bipartisan Tax Reform?" Tax Notes 151, no. 4 (2016): 505-8.
Full Text: MLaw Repository | SSRN
Professor

Activities

Presented "Bridging the Red-Blue Divide: A Proposal for U.S. Regional Tax Relief" at the Oxford University Centre for Business Taxation Academic Symposium, July 2019.

Delivered the keynote address at the 12th Annual U.S. and Latin America Tax Practice Trends Conference, Miami, June 2019.

Served as a panelist on "Effects of the New Tax Law on Corporate and Business Tax Planning Decisions" at the Tax Policy Center, Washington, D.C., June 2019.

Presented "Globalization, Tax Competition, and the Fiscal Crisis of the Welfare State: A Twentieth Anniversary Retrospective" at the Taxation and Globalization Research Workshop, Harry Radzyner Law School, Herzliya, Israel, May 2019.

Awarded the IFA Italy prize for "Complete Distributive Rules and the Single Tax Principle: A Review of Recent Italian Case Law," a co-authored article (with Gianluca Mazzoni) that appeared in Bulletin International Taxation, April 2019.

Participated in the World Bank's Global Forum on Law, Justice, and Development, April 2019.

Presented "Bridging the Red-Blue Divide: A Proposal for U.S. Regional Tax Relief" at the University of Florida and Duke University, April 2019.

Served as a panelist on "Strengthening Residence-Basis Taxation" at the International Tax Policy Forum Conference, Georgetown University Law Center, February 2019.

Presented "Bridging the Red-Blue Divide: A Proposal for U.S. Regional Tax Relief" at the Tax Law Forum Meeting, Hebrew University Law School, Jerusalem, January 2019.

Presented "U.S. Tax Reform and BEPS" at the University of Oxford, December 2018.

Commented on "Modeling Changes in U.S. International Tax Rules" and "Revisiting the Transition Tax" at the National Tax Association annual meeting, New Orleans, November 2018.

Presented "Tax Reform and the WTO" at the International Tax Institute, University of San Diego, November 2018.

Presented "U.S. Tax Reform and Europe" at Lund University, Sweden, June 2018.

Presented "U.S. Tax Reform and EU Multinationals" at Comillas University, Madrid, June 2018.

Presented "U.S. Tax Reform and BEPS" at the Max Planck Institute, Munich, June 2018.

Presented "International Implications of a Carbon Tax Regime" at the 2018 Energy Tax Symposium, Houston, February 2018.

Panelist for "Current Developments in Permanent Establishments and the Multi-Lateral Instruments" at the 2018 Annual Conference of the USA Branch of the International Fiscal Association, Houston, February 2018.

Presented "The Elephant Always Forgets: Tax Reform and the WTO" at the Reconceiving Trade Agreements for Social Inclusion Workshop, University of California, Irvine School of Law, February 2018.