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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 is also a trustee of the American Tax Policy Institute, 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...


Co-author. "Formulating a General Anti-Abuse Rule (GAAR) in Tax Legislation: Insights and Recommendations." A. Pichhadze, co-author. In The Routledge Companion to Tax Avoidance Research, edited by N. Hashimzade and Y. Epifantseva. Routledge Companion in Business, Management and Accounting. London: Taylor & Francis Group, Forthcoming, 2018.

Co-author. 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

Why Not Tax the Rich? Review of Kleinbard's 'We are Better Than This'. U of Michigan Public Law & Legal Theory Research Paper No. 426. Working Paper.
Full Text: SSRN

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.
Full Text: SSRN

Virtual PE: International Taxation and the Fairness Act. University of Michigan Public Law & Legal Theory Research Paper Series, No. 328. Working Paper, 2013.
Full Text: SSRN

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.
Full Text: MLaw Repository | SSRN

Too Big to Tax? Vanguard and the Arm's Length Standard. U of Michigan Law & Economics Research Paper Series No. 15-015. Working Paper.
Full Text: SSRN

The Three Causes of Inversions: Reflections on Pfizer/Allergan and Notice 2015-79. U of Michigan Law & Economics Research Paper No. 15-021; U of Michigan Public Law & Legal Theory Research Paper No. 488. Working Paper.
Full Text: SSRN

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.
Full Text: MLaw Repository | SSRN

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

co-author. The Trump Tax Reform Plan: Implications for Europe. G. Mazzoni, co-author. U of Michigan Law & Econ Research Paper No. 17-009 and U of Michigan Public Law Research Paper No. 559. Working Paper.
Full Text: SSRN

The Inexorable Rise of the VAT: Is the US Next? U of Michigan Law & Economics Research Paper No. 15-022; U of Michigan Public Law & Legal Theory Research Paper No. 489. Working Paper.
Full Text: SSRN

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.
Full Text: SSRN

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

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.
Full Text: SSRN

Co-author. Special Tax Zones and the WTO. M. Vallespinos, co-author. Working Paper.
Full Text: SSRN

Should the US Dictate World Tax Policy? Reflections on PPL Corporation v. Commissioner. U of Michigan Public Law & Legal Theory Research Paper No. 308. Working Paper.
Full Text: SSRN

Reinventing the Wheel: What We Can Learn from the Tax Reform Act of 1986. U of Michigan Public Law & Legal Theory Research Paper No. 424; U of Michigan Law & Economics Research Paper No. 14-018. Working Paper.
Full Text: SSRN

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.
Full Text: MLaw Repository | SSRN | WWW

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.
Full Text: SSRN

Co-author. Leveling the Playing Field: The Case for an Education Value Added Tax. S. Avi-Yonah, co-author. U of Michigan Public Law & Legal Theory Research Paper No. 474. Working Paper.
Full Text: SSRN

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.
Full Text: SSRN

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.
Full Text: MLaw Repository | SSRN

Co-author. Global Taxation After the Crisis: Why BEPS and MAATM are Inadequate Responses, and What Can Be Done About It. H. Xu, co-author. U of Michigan Public Law & Legal Theory Research Paper No. 494. 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 Series, No. 319. Working Paper, 2013.
Full Text: SSRN

Find It and Tax It: From TIEAs to IGAs. Savir, G., co-author. U of Michigan Public Law Research Paper No. 443. Working Paper.
Full Text: SSRN

Co-author. Double or Nothing: A Tax Treaty for the 21st Century. O. Halabi, co-author. Working Paper, 2012.
Full Text: MLaw Repository | SSRN

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.
Full Text: MLaw Repository | SSRN | WWW

Destination Based Corporate Tax: An Alternative Approach. University of Michigan Law and Economics Research Paper Series 16-028. Working Paper.
Full Text: SSRN

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.
Full Text: MLaw Repository | WestlawSSRN

Co-author. Be Careful What You Wish For? Reducing Inequality in the 21st Century. O. Avi-Yonah, co-author. U. of Michigan Law & Economics Research Paper Series No. 17-002. Working Paper.
Full Text: SSRN | MLaw Repository

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

A World Turned Upside Down: Reflections on the 'New Wave' Inversions and Notice 2014-52. Univ. of Michigan Public Law & Legal Theory Research Paper Series, no. 421. Working Paper, 2014.
Full Text: SSRN

Amazon vs. Commissioner: Has Cost Sharing Outlived Its Usefulness? U of Michigan Law & Econ Research Paper No. 17-003; U of Michigan Public Law and Legal Theory Research Paper No. 551. Working Paper.
Full Text: SSRN

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

Co-author. A Global Treaty Override? The New OECD Multilateral Tax Instrument and Its Limits. H. Xu, co-author. U of Michigan Law & Economics Research Paper No. 16-037. Working Paper.
Full Text: SSRN

Co-author. "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, MA: 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.
MLaw Catalog

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

Co-author. "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: SSRN | WWW

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

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

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

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

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

Co-author. "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.

"Back to 1913?: The Ryan Blueprint and Its Problems." Tax Notes 153, no. 11 (2016): 1367-47.
Full Text: MLaw Repository | SSRN

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.

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

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

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

"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

Co-author. "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) | 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 | WWW

"Constructive Unilateralism: U.S. Leadership and International Taxation."Int'l Tax J. 42, no. 2 (2016): 17-24.
Full Text: ProQuest (UMich users) | ProQuest | SSRN

Editor. International Tax Law, vols. I & II. International Law series. Northampton, MA: Edward Elgar Publishing, 2016.

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

"企業の社会的責任と戦略的租税行動" [Corporate Social Responsibility and Strategic Tax Behavior]. Translated by Koga, K. 大阪経大論集 [J. Osaka Univ. Econ.] 65, no. 5 (2015): 161-74. (Originally published under the same title in Tax and Corporate Governance, edited by W. Schön, 183-98. MPI Studies on Intellectual Property, Competition and Tax Law, 3. Berlin: Springer Verlag, 2008.)
Full Text: MLaw Repository

"Who Invented the Single Tax Principle?: An Essay on the History of US Treaty Policy." N. Y. L. Sch. L. Rev. 59, no. 2 (2015): 305-15.
Full Text: MLaw Repository | HEIN (UMich users) | HEIN​ | ​ Lexis | SSRN |

Co-author. "Why a carbon tax is the best way to address global climate change." D.M.Uhlmann, co-author. In Treibutacao e sustenabilidade ambiental, edited by A.A.DeCarli, L.deAndrade, and R.L.Ribeiro, 63-74. Rio de Janeiro, Brasil: Editoria FGV, 2015.​​

Co-author. "Leveling the Playing Field: The Case for an Education VAT." S.S.Avi-Yonah, co-author. Tax Notes 148, no. 13 (2015): 1529-34.

"Too Big to Tax? Vanguard and The Arm's Length Standard." Tax Notes 149, no. 1 (2015): 105-10.​

"The Case for Destination-Based Corporate Tax." Int'l Tax J. 41, no. 5 (2015): 11-3.
Full Text: LegalTrac (UMich users) | LegalTrac

Co-editor. Taxation and Migration. J.Slemrod, co-editor. International Taxation, 54. The Netherlands: Kluwer Law International, 2015​.​

"And Yet it Moves: Taxation and Labor Mobility in the Twenty-First Century." In Taxation and Migration, edited by R. S. Avi-Yonah and J.Slemrod, 45-56. International Taxation, 54. The Netherlands: Kluwer Law International, 2015.​​

Co-author. "Unitary Taxation and International Tax Rules." Z. Pouga, co-author. In International Taxation: Law and Practice in Hong Kong and China, edited by J. Chaisse and M. Lang. Hong Kong: Wolters Kluwer, 2015.
Full Text: MLaw Repository | SSRN

Co-author. "Inversions and Competitiveness: Reflections in the Wake of Pfizer-Allrgan." O.Marian, co-author. Int'l Tax J. 41, no. 6 (2015): 39-46.
Full Text: LegalTrac (UMich users) | LegalTrac

"All or Nothing? The Obama Budget Proposals and BEPS." Int'l Tax J. 41, no. 2 (2015): 17-8, 75-6.
Full Text: ProQuest (UMich users) | ProQuest | SSRN​ |

"A Perspective of Supra-Nationality in Tax Law." In BRICS and the Emergence of International Tax Coordination, edited by P. Pistone and Y. Brauner, 33-40. Global Tax Series. Amsterdam: IBFD Academic, 2015.
Full Text: SSRN
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Advanced Introduction to International Tax Law. Elgar Advanced Introductions. Edward Elgar Publishing, 2015.​

"Can Income Tax Survive Globalization?" ElgarBlog (January 20, 2015).
Full Text: WWW

​"The Rise and Fall of the Consumption Tax." Tax Notes 146 (2015): 247-51.
Full Text: MLaw Repository ​​​

"The Devil in the Details: Reflections on the Camp Draft." Tax Notes Int'l 73, no. 12 (2014): 1054-7.
Full Text: MLaw Repository | SSRN | Lexis

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.
Full Text: SSRN | ​Lexis

​"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.)​
Full Text: MLaw Repository​​​​ | Lexis

"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.)​​ ​​​
Full Text: Lexis

"Corporate Taxation and Corporate Social Responsibility." N. Y. U. J. L. & Bus. 11, no. 1 (2014): 1-29.
Full Text: MLaw Repository | HEIN (UMich users) | HEIN | SSRN​ | Westlaw

"Back from the Dead: Reviving Transfer Pricing Enforcement." Tax Notes Int'l 73, no. 1 (2014): 10-3.
Full Text: MLaw Repository | Lexis | SSRN

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.)
Full Text: WWW (Part I) | WWW (Part II ) | WWW (Part III) ​​

"And Yet It Moves: Taxation and Labor Mobility in the Twenty-First Century." Tax L. Rev. 67 (2014): 169.
Full Text: MLaw Repository | HEIN (UMich users) | HEIN | Westlaw | SSRN

"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.
Professor

Activities

Presented "Prospects for U.S. Tax Reform and its International Implications," London School of Economics, May 2017.

Presented the main lecture at the Tax Seminar in U.S. and Italian International Tax Policies, Università Degli Studi di Milano-Bicocca Dottorato Di Ricerca in Scienze Giuridiche, Italy, May 2017.

Presented "The Tax Policies of the New U.S. Administration in the Global Scenario" at the International Taxation Seminars Series, Università Commerciale Luigi Bocconi, Italy, May 2017.

Participated in "The E.U. and the U.S. Before the New Global Challenges: Trade and International Taxation from a Transatlantic Perspective," Center for European Studies, Harvard University, October 2016.

Presented "Evaluating BEPS," Oxford Centre for Business Taxation Annual Symposium, June 2016.

Commentator, Corporation Tax for the ​21st Century, the Oxford Centre for Business Taxation Summer Conference 2016, June 2016.​

Presented "Evaluating BEPS" at the annual conference of the European Association of Tax Law Professors, Munich, June 2016.​

Served as the IBFD Professor in Residence and presented "Evaluating BEPS" at the International Bureau of Fiscal Documentation, Amsterdam, May 2016.​

Taught a class on U.S. corporate tax at Bocconi University in Milan; presented "Evaluating BEPS" during a faculty seminar at Bocconi School of Law; and participated in the second Global BEPS Conference at Bocconi School of Management, May 2016.

Participated in "The OECD Base Erosion and Profit Shifting (BEPS) Project: Ensuring Tax Responsibility by Multinational Corporations" sponsored by the Hoops Institute of Taxation Research & Policy, Washington State University, March 2016.​

Participated in a panel discussion on the future of corporate tax research, Summer Conference 2015: UK Corporation Tax: Past, Present and Future, Oxford University Centre for Business Taxation, June 2015.​

Presented "Reinventing the Wheel" at the Ninth Annual Symposium of the Oxford University Centre for Business Taxation, June 2015. ​

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.