Publications
Books
United States International Taxation: Outbound and Inbound Activities, Commerce Clearing House / Wolters Kluwer and Carolina Academic Press, Tenth and Eleventh Editions, Vols. 1-2, 2014 to present (with Postlewaite)
United States International Taxation, Carolina Academic Press, Fourth and Fifth Editions, 2019 to present (with Postlewaite and Tokic)
Tax Cuts and Jobs Act Impact: Guide to International Tax, Commerce Clearing House / Wolters Kluwer, December 2018 (with Postlewaite)
Partnership Taxation: Introductory, Advanced, and International: Student Problems and Instructor's Manual, Thomson Reuters Checkpoint, Eighth and Ninth Editions, April 2018 to present (with Postlewaite)
Articles
Co-author, “IRS Clarifies 'Foreign Derived' Service Income for FDII Regime,” Bloomberg Tax: Tax Management International Journal, March 2025
Co-author, “A Tax Treaty By Any Other Name: The United States-Taiwan Expedited Double-Tax Relief Act,” 50 Int’l Tax J. 36, June 2024
Co-author, “Disproportionately Difficult: Determining a U.S. Partner’s Proportionate Share of Partnership Intangible Property Under Code Sec. 367(d),” 49 Int’l Tax J. 49, December 2023
Co-author, “Controlled Foreign Corporations — Part 2,” 100 Taxes 33, November 2022
Co-author, “Controlled Foreign Corporations — Part I,” 100 Taxes 41, September 2022
Co-author, “The All Earnings and Profits Amount of a Domesticating Foreign Target: The Non-Recognition Cleansing Exception,” 48 Int’l Tax J. 5, June 2022
Co-author, “Export Activities,” 99 Taxes 23, June 2021
“Related Person Downward Attribution: Rules Similar to the Rules of Section 958(b),” 47 Int'l Tax J. 23, April 2021
“The Participation Dividends-Received Deduction: More than Meets the Eye,” 45 Int'l Tax J. 49, June 2019
Co-author, “Inbound Dispositions of Partnership Interests: The Uncertainty Continues,” 44 Int'l Tax J. 7, May 2018
Co-author, “Section 956 in the Partnership World: An Aggregate Tour de Force with Some Bumps in the Road,” 43 Int'l Tax J. 5, April 2017
“Post-Inversion Partnership Restructurings under Notice 2015-52: A Cure Worse than the Disease,” 41 Int'l Tax J. 29, September 2015
Co-author, “American Bar Association Section of Taxation, Comments on Notice 2014-52,” Tax Notes Today, 12 June 2015
Co-author, “Income Derived Through Fiscally Transparent Entities: Practical Issues and Unintended Consequences,” The Tax Adviser, March 2014
Co-author, “U.S. Sandwich Structures in the International Inbound Context,” The Tax Adviser, March 2012
Co-author, “New York City Bar Report Offering Proposed Guidance Regarding the Passive Foreign Investment Company Rules,” Tax Notes Today, 19 September 2009
Co-author, “Abandoning the Tax Havens: The Redomestication of Inverted Multinationals and Bermuda-Based Insurers,” Practical U.S. International Tax Strategies, March 2009
Co-author, “Changes to the Germany-U.S. Double Taxation Treaty,” BNA Tax Planning Int'l Rev., February 2008
Co-author, “Financing U.S. Subsidiaries of European Multinationals: Tax Efficient Structuring of Intercompany Loans and Hybrid Financing Arrangements,” Practical European Tax Strategies, August 2007
Co-author, “United States Mergers and Acquisitions: Jumping the Gun under the Hart-Scott Rodino Antitrust Improvements Act,” Competition Law Insight, September 2006
“International Tax Competition: An Efficient or Inefficient Phenomenon?,” 16 Akron Tax J. 99, 2001
“Mr. Justice Holmes's Constitutionally Crooked Path Part II: The State Sovereignty Jurisdictional Stopgap,” 47 Clev. S. Law Rev. 497, 1999
Co-author, “Restrictions to the Section 936 Credit Imposed by the RRA of 1993,” 20 Int'l. Tax J. 24, 1994