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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...


The Games They Will Play: Tax Games, Roadblocks, and Glitches Under the New Legislation. L. L. Batchelder et al., co-authors. 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.
Full Text: MLaw Repository | 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.
Full Text: MLaw Repository | SSRN

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.
Full Text: MLaw Repository | SSRN

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

A Global Treaty Override? The New OECD Multilateral Tax Instrument and Its Limits. H. Xu, co-author. University of Michigan Public Law & Legal Theory Research Paper No. 542. 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

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 No. 307. 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.
Full Text: MLaw Repository | SSRN | WWW

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

"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. 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

"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 | Lexis | Westlaw | SSRN | WWW

"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: Lexis | SSRN

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

"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 | Lexis

"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

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

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

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

"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) | 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.
Full Text: ProQuest (UMich users) | ProQuest | 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.

"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: Lexis | WWW

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

​"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.
MLaw Catalog

"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 K. Koga. 大阪経大論集 [Journal of Osaka University of Economics] 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

"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. de Carli, L. de Andrade, and R. L. Ribeiro, 63-74. Rio de Janeiro: Editoria FGV, 2015.

"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 | Westlaw | SSRN

"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

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

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

"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. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2015​.

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

"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

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

​"Avi-Yonah Finds Fault With U.S. International Reform Report." Tax Notes Int'l 79 (2015): 351-2.
Full Text: Lexis

​"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. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2015.

"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

Advanced Introduction to International Tax Law. Elgar Advanced Introductions. Cheltenham, U.K.: Edward Elgar Publishing, 2015.​

"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
Professor

Activities

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.

Presented a seminar on "U.S. Tax Reform," University of Auckland Law School, New Zealand, December 2017.

Presented "EU and U.S. as Source and Residence States: Main Research Questions," "The U.S. Forthcoming Corporate Tax Reform," and "Brainstorming on Publishing the Research Outputs and Next Steps of the TFF" at the Second Meeting of the Transatlantic Forum, Real Colegio Complutense, Harvard University, October 2017.

Presented "What Can the U.S. Do in Response to State Aids" for the European Union Law and Government Study Group, Harvard Center for European Studies, October 2017.

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.​