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Reuven S. Avi-Yonah

Reuven S. Avi-Yonah

Irwin I. Cohn Professor of Law
Member of University of Michigan Law School Faculty 2000-



Books

  • U.S. International Taxation, Cases and Materials. 4th ed. Diane M. Ring and Yariv Brauner, co-authors. University Casebook Series. St. Paul, Minn.: Foundation Press, 2019.
    MLaw Catalog
  • Advanced Introduction to International Tax Law. 2nd ed. Elgar Advanced Introductions. Cheltenham, U.K.: Edward Elgar Publishing, 2019.
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  • Editor. International Tax Law, vols. I & II. International Law Series, 10. Northampton, Mass.: Edward Elgar Publishing, 2016.
    MLaw Catalog
  • Co-editor. Taxation and Migration. J. Slemrod, co-editor. Series on International Taxation, vol. 54. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2015.
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  • Advanced Introduction to International Tax Law. Elgar Advanced Introductions. Cheltenham, U.K.: Edward Elgar Publishing, 2015.
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  • 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.
    MLaw Catalog
  • Global Perspectives on Income Taxation Law. N. Sartori and O. Marian, co-authors. New York: Oxford University Press, 2011.
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  • The Integrated 2006 United States Model Income Tax Treaty. M. B. Tittle, co-author. Tax Law Series, 3. Lake Mary, Fla.: Vandeplas Publishing, 2008.
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  • International Tax as International Law: An Analysis of the International Tax Regime. Cambridge Tax Law Series. Cambridge: Cambridge University Press, 2007.
    MLaw Catalog
    Full Text: SSRN
  • Co-editor. Comparative Fiscal Federalism: Comparing the European Court of Justice and the U.S. Supreme Court's Tax Jurisprudence. J. R. Hines Jr. and M. Lang, co-editors. EUCOTAX Series on European Taxation, 14. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2007.
    MLaw Catalog
  • U.S. International Taxation: Cases and Materials. 2nd ed. D. M. Ring and Y. Brauner, co-authors. University Casebook Series. New York: Foundation Press, 2005. (Also co-authors supplements to this work.)
    MLaw Catalog
  • U.S. International Taxation: Cases and Materials. University Casebook Series. New York: Foundation Press, 2002.
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  • The Attribution Rules. Tax Management Portfolios, vol. 554, 2nd ed. Washington, D.C.: Tax Management Inc., 1996.
    MLaw Catalog
  • Transfer Pricing: Judicial Strategy and Outcomes. D. I. Meyer and A. D. Webber, co-authors. Tax Management Portfolios, vol. 888. Washington, D.C.: Tax Management Inc., 1995.
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  • Collapsible Corporations. F. A. Nicholson, co-author. Tax Management Portfolios, vol. 793. Washington, D.C.: Tax Management Inc., 1995.
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  • Amortization of Intangibles. Tax Management Portfolios, vol. 533. Washington, D.C.: Tax Management Inc., 1994-2001.
    MLaw Catalog
  • Taxation of Financial Instruments. D. B. Newman and D. M. Ring, co-authors. St. Paul, Minn.: West Group, 1996-1999. (Work published when author not on Michigan Law faculty.)
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Book Chapters

  • "Taxation and Human Rights: A Delicate Balance." G. Mazzoni, co-author. In Tax, Inequalities, and Human Rights, edited by P. Alston and Nikki R. Reisch, 259-77. Oxford, 2019.
    Full Text: Oxford Scholarship Online (UMich users) | Oxford Scholarship Online | SSRN
  • "Special Tax Zones and the World Trade Organization." Martin Vallespinos, co-author. In Special Tax Zones in the Era of International Tax Coordination, edited by Pasquale Pistone, Jan de Goede, and Antti Laukkanen, 127-56. Amsterdam: IBFD, 2019.
  • "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., 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.
  • "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.
    MLaw Catalog
  • "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 (UMich users) | 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.
  • "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: MLaw Repository | WWW
  • "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.
  • "Hanging Together: A Multilateral Approach to Taxing Multinationals." In Global Tax Fairness, edited by T. Pogge and K. Mehta. Oxford: Oxford University Press, 2016.
    Full Text: MLaw Repository | SSRN
  • "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
  • "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.​
  • "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. Series on International Taxation, vol. 54. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2015.
    MLaw Catalog
  • "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
  • "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
  • "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.
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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 University Press, 2012.
    Full Text: MLaw Repository
  • "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, D.C.: Tax Analysts, 2011.
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  • "Rethinking Treaty Shopping: Lessons for the European Union." C. H. Panayi, co-author. In Tax Treaties: Building Bridges between Law and Economics, edited by M. Lang et al., 21-50. Amsterdam: IBFD, 2010.
    Full Text: MLaw Repository | SSRN | WWW
  • "International Law: Private Law in United States Law." In Oxford International Encyclopedia of Legal History, edited by S. N. Katz, 284-90. Oxford: Oxford University Press, 2009.
    Full Text: MLaw Repository
  • "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 University Press, 2009.
    Full Text: MLaw Repository | SSRN
  • "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.
    Full Text: MLaw Repository
  • "Reforming Corporate Taxation in a Global Economy: A Proposal to Adopt Formulary Apportionment." K. A. Clausing, co-author. In Path to Prosperity: Hamilton Project Ideas on Income Security, Education, and Taxes, edited by J. Furman and J. E. Bordoff, 319-44. Washington, D.C.: Brookings Institution Press, 2008.
    Full Text: MLaw Repository | SSRN | WWW
  • "Corporate Social Responsibility and Strategic Tax Behavior." 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 | SSRN
  • "Business Profits (Article 7 OECD Model Convention)." K. A. Clausing, co-author. In Source versus Residence: Problems Arising from the Allocation of Taxing Rights in Tax Treaty Law and Possible Alternatives, edited by M. Lang et al., 9-20. EUCOTAX Series on European Taxation, 20. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2008.
    Full Text: MLaw Repository | SSRN
  • "Why Was the U.S. Corporate Tax Enacted in 1909?" In Studies in the History of Tax Law, edited by J. Tiley, vol. 2, 377-92. Portland, Oreg.: Hart Pub., 2007.
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  • "What Can the US Supreme Court and the European Court of Justice Learn from Each Other's Tax Jurisprudence?" In Comparative Fiscal Federalism: Comparing the European Court of Justice and the US Supreme Court's Tax Jurisprudence, edited by R. S. Avi-Yonah, J. R. Hines Jr., and M. Lang, 465-9. EUCOTAX Series on European Taxation, 14. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2007.
    MLaw Catalog
    Full Text: SSRN
  • "A Historical Perspective on Corporate Form and Corporate Real Entity: Implications for Corporate Social Responsibility." D. Sivan, co-author. In The Firm as an Entity: Implications for Economics, Accounting, and the Law, edited by Y. Biondi, A. Canziani, and T. Kirat, 153-85. The Economics of Legal Relationships. London: Routledge, 2007.
    MLaw Catalog
  • "Commentary." In The Tillinghast Lecture, 1996-2005, by New York University School of Law; 117-25. New York: NYU School of Law, 2007. (Commentary on "International Tax Arbitrage and the 'International Tax System'" by H. D. Rosenbloom)
    Full Text: MLaw Repository
  • "Tax Treaty Overrides: A Qualified Defence of U.S. Practice." In Tax Treaties and Domestic Law, edited by G. Maisto, 65-80. EC and International Tax Law Series, vol. 2. Amsterdam: IBFD Publications, 2006.
    MLaw Catalog
    Full Text: SSRN
  • "The WTO, Export Subsidies, and Tax Competition." In WTO and Direct Taxation, edited by M. Lang et al., 115-31. Eucotax Series on European Taxation, vol. 10. The Hague, The Netherlands: Kluwer Law International, 2005.
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  • "The Story of the Separate Corporate Income Tax: A Vehicle for Regulating Corporate Managers." In Business Tax Stories, edited by S. A. Bank and K. J. Stark, 11-26. Law Stories Series. New York: Foundation Press, 2005.
    MLaw Catalog
    Full Text: SSRN
  • "From Income to Consumption Tax: Some International Implications." In Tax Reforms, edited by D. Gliksberg, 395-426. Jerusalem: Harry and Michael Sacher Institute for Legislative Research and Comparative Law, 2005.
  • "Closing the International Tax Gap." J. Guttentag, co-author. In Bridging the Tax Gap: Addressing the Crisis in Federal Tax Administration, edited by M. B. Sawicky, 99-110. Washington, D.C.: Economic Policy Institute, 2005.
    Full Text: MLaw Repository
  • "Annex 3: Definition of 'Tax' in US Law." In The Concept of Tax, edited by B. Peeters et al., 327. EATLP International Tax Series, 3. Amsterdam: European Association of Tax Law Professors, 2005.
  • "Corporate Income Tax Act of 1909." In Major Acts of Congress, edited by B. K. Landsberg, vol. 1(A-E), 190-4. New York: Macmillan Reference USA; Thomson Gale, 2004.
    U-M Library Search
  • "Analysis of Judicial Decisions Interpreting §482." In Transfer Pricing: Judicial Strategy and Outcomes, A-101 to A-131. Tax Management: Foreign Income Portfolios, vol. 888. Washington, D.C.: Tax Management, Inc., 2003.
    MLaw Catalog
  • "Key Federal Income Tax and Transfer Tax Issues Relating to Real Estate Workouts and Bankruptcies." D. M. Einhorn, co-author. In Real Estate Workouts and Bankruptcies, 197-210. Practising Law Institute Real Estate Law and Practice Course Handbook Series, 379, no. 5/6. New York: Practising Law Institute, 1992. (Work published when author not on Michigan Law faculty.)

Journal Articles


Reviews

  • Review of Double Taxation and the League of Nations, by Sunita Jogarajan. Gianluca Mazzoni, co-author. Intertax 46, no. 12 (2018): 1027-29.
  • "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 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
  • Review of The Making of Tax Law: The Development of the Swedish Tax System, by Sven-Olof Lodin. Tax Notes Int'l 66, no. 8 (2012): 745-6.
    Full Text: SSRN
  • "Why Tax the Rich? Efficiency, Equity, and Progressive Taxation." Review of Does Atlas Shrug? The Economic Consequences of Taxing the Rich, by Joel B. Slemrod, editor. Yale L.J. 111, no. 6 (2002): 1391-416.
    Full Text: MLaw Repository | HEIN (UMich users) | HEIN | Lexis | Westlaw | SSRN | WWW

Other Publications

  • Foreword to Digitalisation and Transfer Pricing - The Way Ahead, by Mohanish Verma, v-vi. Mohali, India: Wolters Kluwer, (2019).
  • "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) | De Gruyter
  • 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.
  • 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.
  • "Can Income Tax Survive Globalization?" ElgarBlog (January 20, 2015).
    Full Text: WWW
  • 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.
  • "Senator McCain's Corporate Tax Proposals A Critical Examination." Report for the Center for American Progress Action Fund. Washington, D.C.: April 2008.
    Full Text: MLaw Repository
  • "Preface." Preface to Comparative Fiscal Federalism: Comparing the European Court of Justice and the US Supreme Court's Tax Jurisprudence, by R. S. Avi-Yonah, J. R. Hines Jr., and M. Lang, co-editors, xvii-xviii. EUCOTAX Series on European Taxation, 14. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2007.
    MLaw Catalog
  • "Tax Arbitrage and the International Tax Regime." Preface to Tax Arbitrage and the Changing Structure of International Tax Law, by L. Dell'Anese, IX-XXIII. Milan: EGEA, 2006.
  • "Foreign Direct Investment in Latin America Overview and Current Status", by M. B. Tittle, co-author. Inter-American Development Bank, 2002.
    Full Text: MLaw Repository | WWW

Reprints (Articles and other publications reprinted in full and Law Quadrangle)

  • "The Structure of International Taxation: A Proposal for Simplification." In International Tax Law, vol. I, edited by R. S. Avi-Yonah, 1-59. International Law Series, 10. Northampton, Mass.: Edward Elgar Publishing, 2016. (Originally published under the same title in Tex. L. Rev. 74 no. 6 (1996): 1301-59.)
    MLaw Catalog
  • "International Tax as International Law." In International Tax Law, vol. I, edited by R. S. Avi-Yonah, 1-19. International Law Series, 10. Northampton, Mass.: Edward Elgar Publishing, 2016. (Originally published under the same title in Tax L. Rev. 57, no. 4 (2004): 483-501.)
    MLaw Catalog
  • "International Taxation of Electronic Commerce." In International Tax Law, vol. I, edited by R. S. Avi-Yonah, 149-97. International Law Series, 10. Northampton, Mass.: Edward Elgar Publishing, 2016. (Originally published under the same title in Tax L. Rev. 52, no. 3 (1997): 507-55.)
    MLaw Catalog
  • "Globalization, Tax Competition, and the Fiscal Crisis of the Welfare State." In International Tax Law vol. I, edited by R. S. Avi-Yonah, 257-88. International Law Series, 10. Northampton, Mass.: Edward Elgar Publishing, 2016. (Originally published under the same title in Harv. L. Rev. 113, no. 7 (May): 1573-676.)
    MLaw Catalog
  • "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
  • "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.)
  • "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.)
    Full Text: MLaw Repository | HEIN (UMich users) | HEIN | De Gruyter (UMich users) | De Gruyter | SSRN
  • "Passport to Toledo: Cuno, the WTO, and the ECJ." Tax Notes Int'l 41, no. 3 (2006): 289-97. (Originally published as "Passport to Toledo: Cuno, the World Trade Organization, and the European Court of Justice." Tax Notes 109, no. 13 (2005): 1661-8.)
    Full Text: SSRN
  • "Passport to Toledo: Cuno, the World Trade Organization, and the European Court of Justice." St. Tax Notes 39, no. 2 (2006): 121-9. (Originally published under the same title in Tax Notes 109, no. 13 (2005): 1661-8.)
    Full Text: SSRN
  • "Globalization and Tax Competition: Implications for Developing Countries." Fin. & Tax L. Rev. 8 (2006): 310-21. (This reprinted version of this article is in Chinese. Translator: Ding Yi.)
  • "Comparative Fiscal Federalism: What Can the U.S. Supreme Court and the European Court of Justice Learn From Each Other's Tax Jurisprudence?" Law Quad. Notes 48, no. 3 (2006): 65-8. (Originally published under the same title in J. Int'l Inst. 13, no. 2 (2006).)
    Full Text: MLaw Repository | SSRN
  • "The Pitfalls of International Integration: A Comment on the Bush Proposal and its Aftermath." Int'l Tax & Pub. Fin. 12 (2005): 87-95. (Originally published under the same title in Diritto e practica tributaria internazionale 75, no. 1 (2004): 3-12.)
    Full Text: MLaw Repository | Lexis | DeepBlue | SSRN
  • "Risk, Rents, and Regressivity: Why the United States Needs Both an Income Tax and a VAT." Tax Notes Int'l 37, no. 2 (2005): 177-95. (Originally published under the same title in Tax Notes 105, no. 13 (2004): 1651-66.)
    Full Text: WWW
  • "Back to the 1930s? The Shaky Case for Exempting Dividends." Tax Notes Int'l 29, no. 1 (2003): 91-100. (Originally published under the same title in Tax Notes 97, no. 12 (2002): 1599-607.)
  • "For Haven's Sake: Reflections on Inversion Transactions." Tax Notes Int'l 27, no. 2 (2002): 225-31. (Originally published under the same title in Tax Notes 95, no. 12 (2002): 1793-9.)
  • "Competition and Competitiveness: Review of NFTC Subpart F Report." Tax Notes 83, no. 4 (1999): 582-8. (Work published when author not on Michigan Law faculty. Orginally published under the title "Tax Competition and Multinational Competitiveness: The New Balance of Subpart F - Review of the NFTC Foreign Income Project." in Tax Notes Int'l 18, no. 16 (1999): 1575-86.)

Works in Progress & Working Papers

  • Tax Expenditures and Horizontal Equity: A Lost Lesson from Stanley Surrey. Nir Fishbien, co-author. Working Paper.
    Full Text: SSRN
  • Stanley Surrey, the Code and the Regime. Nir Fishbien and Gianluca Mazzoni, co-authors. 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.
  • 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
  • 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 RepositorySSRN
  • 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 G. 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 RepositorySSRN
  • 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 RepositorySSRN
  • 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
  • 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.
    Full Text: MLaw Repository | 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
  • 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
  • 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: MLaw Repository | 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: 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 & 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 Law & Economics 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


Revised 10/09/2019