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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 the forthcoming 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

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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

"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

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.
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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.
Full Text: MLaw Repository |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

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

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

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.
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. 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.
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.
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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.
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

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.
Full Text: SSRN | BePress

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

"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

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 | Tax Analysts (UMich users) | Tax Analysts

"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.
Full Text: SSRN | Tax Analysts (UMich Users) | Tax Analysts

​"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 | Tax Analysts (UMich users) | Tax Analysts

"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: Tax Analysts (UMich users) | Tax Analysts​​

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

"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.)
Full Text: MLaw Repository | SSRN

"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)
Full Text: SSRN | Tax Analysts (UMich Users) | Tax Analysts

"Corporate and International Tax Reform: Proposals for the Second Obama Administration (and Beyond)." Pepp. L. Rev. 40, no. 5 (2013): 1364-72.
Full Text: MLaw Repository | SSRN | HEIN (UMich users) | HEIN | Lexis | Westlaw | WWW

​"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)
Full Text: SSRN | Tax Analysts (UMich Users) | Tax Analysts

​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.
Full Text: SSRN | Lexis | Tax Analysts (UMich users) | Tax Analysts

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.
Full Text: SSRN | WWW

​"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.
Full Text: SSRN | Tax Analysts (UMich users) | Tax Analysts

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.
Full Text: MLaw Repository | SSRN | HEIN (UMich users) | HEIN | Lexis

Co-author. "Symposium on International Taxation and Competitiveness: Introduction and Overview." N. Sartori, co-author. Tax L. Rev. 65, no. 3 (2012): 313-22.
Full Text: MLaw Repository | SSRN | HEIN (UMich users) | HEIN | Lexis

"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)
Full Text: Tax Analysts (UMich users) | Tax Analysts

"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

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.

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.

 
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