科普第54期 美国法学名师介绍（22）税法

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"Microsoft's Cost-Sharing Arrangement: Frankenstein Strikes Again," Tax Notes Federal(2023)

"If Moore is Reversed," Volume 110, June 26 Tax Notes International(2023)

"A New Framework for Digital Taxation," Harvard International Law Journal(2023)

"Nothing New Under the Sun? The Historical Origins of the Benefits Principle," Intertax(2023)

"The UTPR and the Credits," Tax Notes International(2023)

"The Historical Origins and Current Prospects of the Multilateral Tax Convention，" World Tax Journal(2023)

"Individual Mobility and the Corporate Tax," Tax Notes International(2023)

"Coordonner les retenues à la source : une solution possible pour lutter contre l’évasion fiscal," Revue Européenne et Internationale de Droit Fiscal(2023)

"After Pillar One," British Tax Review(2023)

"China Yawns at Pillar 2," Tax Notes International(2023)

"Pillar 1 and DSTs: OECD Optimism and U.S. Reality," Tax Notes International(2023)

"Reforming the Exit Tax," International Tax Journal(2023)

"The Parallel March of the Ginis: How Does Taxation Relate to Inequality, and What Can Be Done About It?," American Journal of Law and Equality(2022)

"A New Framework for Taxing Cryptocurrencies," Tax Notes Federal(2022)

"Billionaire Mark-to-Market Reforms: Response to Susswein and Brown," Tax Notes Federal(2022)

"Medtronic II and the Profit Shifting Problem," Tax Notes International(2022)

"Pillar Two: Down but not Out," Tax Notes International(2022)

"Minimum Taxation in the United States in the Context of GloBE," University of Michigan Public Law Research Paper(2022)

"Pillar 2 and the Corporate AMT," Tax Notes International(2022)

"The BEAT and the BITs: Can the United States be Sued over the BEAT?," International Tax Journal(2022)

"A Response to Professor Marian on Cryptocurrency Tax Policy," Tax Notes(2022)

"Stateless Income and Beyond: Ed Kleinbard’s Contribution to International Tax Policy," National Tax Journal(2022)

"First Impressions of the International Tax Provisions of BB: A Reasonable Compromise," International Tax Journal(2022)

"Tax Harmony: The Promise and Pitfalls of the Global Minimum Tax," Michigan Journal of International Law(2022)

"Tax Treaties, the Constitution, and the Noncompulsory Payment Rule" International Tax Journal(2021)

"Is GILTI Constitutional?," TaxNotes Federal(2021)

"The Worst Tax Law Ever Enacted?," International Tax Journal(2021)

"Has Tax Competition Been Curbed? Reaction to L. Ahrens, L. Hakelberg & T. Rixen," Intertax(2021)

"The Baby and the Bathwater: Reflections on the TCJA’s International Provisions," TaxNotes International(2021)

"The Ingenious Biden Tax Plan," TaxNotes International(2021)

"Lecture in Human Rights: Tax Policy, Global Economics, Labor and Justice in Light of COVID-19,"Rutgers International Law and Human Rights Journal(2021)

"Should U.S. Tax Law Be Constitutionalized? Centennial Reflections on Eisner v. Macomber (1920),"

Duke Journal of Constitutional Law & Public Policy(2021)

"Stanley Surrey, the 1981 US Model, and the Single Tax Principle," Intertax(2021)

"Gucci Gulch Redux: The Problems of Wyden Proposal," Tax Notes International(2021)

"Is New York's Mark-to-Market Act Unconstitutionally Retroactive?," Tax Notes State(2021)

"A Two-Edged Sword: Reflections on CIC Services LLC v. IRS," Tax Notes Federal(2021)

"Is the Net Investment Income Tax a Treaty Override? Reflections on Toulouse," Tax Note International(2021)

"A Different Way to Tax Stock Buybacks," Tax Notes International(2021)

"Stanley Surrey, the Code and the Regime," Florida Tax Review(2021)

"The new international tax framework: evolution or revolution?," American Society of International Law(2021)

"The International Tax Regime at 100: Reflections on the OECD's BEPS Project," Bulletin for International Taxation(2021)

"Reforming State Corporate Income Taxes Can Yield Billions," Tax Notes State(2020)

"Taxing the Digital Economy: The Effect of Coronavirus on Pillar 1,"Tax Notes International(2020)

"Rodriguez, Tucker, and the Dangers of Textualism," Tax Notes(2020)

"Coca-Cola: A Decisive IRS Transfer Pricing Victory, at Last," TaxNotes Federal(2020)

"Biden’s International Tax Plan," TaxNotes International(2020)

"COVID-19 and US Tax Policy: What Needs to Change?," Intertax(2020)

"Federalizing Tax Justice," Indiana Law Journal(2020)

"The Digital Consumption Tax," Intertax(2020)

An Introduction to Tax Law and Policy (Avi-Yonah, Reuven S.2023)

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“A Major Simplification of the OECD’s Pillar 1 Proposal” (January 11, 2021). Tax Notes Federal,

Vol. 170, January 11, 2021. Tax Notes International, January 11, 2021.

“Foreward—The 2017 Tax Cuts: How Polarized Politics Produced Precarious Policy,” The Yale

Law Journal Forum (2018).

The Wolf at the Door: The Menace of Economic Insecurity and How to Fight It，February 18, 2020 Harvard University Press，Michael J. Graetz

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"Against Anti-Tax Exceptionalism," 77 Tax Law Review (2023) (forthcoming)

"Regulatory Trading," University of Chicago Law Review (2023) (forthcoming)

"Trade, Leakage, and the Design of a Carbon Tax," Environmental and Energy Policy and the Economy (2023) (forthcoming) (with Sam Kortum, Michael Wang & Yujia Yao)

"Climate Change Policy in the International Context: Solving the Carbon Leakage Problem," 31 New York University Environmental Law Journal 1 (2023) (with Sam Kortum)

"The Legal Envelope Theorem," 102 Boston University Law Review 449 (2022) (with Daniel Hemel)

"A Two-Step Carbon Pricing Scheme Enabling a Net-Zero and Net-Negative CO2-Emissions World," 171 Climatic Change 18 (2022) (with Viola Becattini, Paolo Gabrielli, Linda Frattini & Marco Mazzotti)

"The Behavioral Elasticity of Tax Revenue," 13 Journal of Legal Analysis 381 (2021) (with Daniel Hemel)

"Debating Debating Climate Ethics," 24 Ethics, Policy & Environment 112 (2021)

"Financial Services Under A Consumption Tax: Grubert and Mackie (2000) Revisited," 72 National Tax Journal 237 (2019)

"The Marginal Revenue Rule in Cost-Benefit Analysis," 160 Tax Notes 1507 (2018) (with Daniel Hemel & Jennifer Nou)

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"Would an Unapportioned U.S. Federal Wealth Tax Be Constitutional, and What Does That Mean?," 39 Oxford Rev. Econ. Pol’y 630 (2023)

"High Noon in the Tax Policy Corral: Edward Kleinbard's Race Against Time," 75 Nat'l Tax J. 375 (2022) (with Joseph Bankman)

"Mobile Intellectual Property and the Shift in International Tax Policy from Determining the Source of Income to Taxing Location-Specific Rents: Part Two," 2021 Sing. J. Legal Stud. 128

"What Are Minimum Taxes, and Why Might One Favor or Disfavor Them?," 40 Va. Tax Rev. 395 (2021)

"Bittker's Pendulum and the Taxation of Multinationals," 104 Tax Notes Int’l 535 (2021)

"Mobile Intellectual Property and the Shift in International Tax Policy from Determining the Source of Income to Taxing Location-Specific Rents: Part One," 2020 Sing. J. Legal Stud. 681

"The Games They Will Play: Tax Games, Roadblocks, and Glitches Under the 2017 Tax Legislation," 103 Minn. L. Rev. 1439 (2019) (with David Kamin, Lily Batchelder, Mitchell Kane et al.)

"The Future of the New International Tax Regime: Panel I," 24 Fordham J. Corp. & Fin. L. 242 (2019) (other panelists include Michael Graetz)

"Goodbye to All That? A Requiem for the Destination-Based Cash Flow Tax," 72 Bull. for Int'l Tax'n 248 (2018)

"Evaluating the New U.S. Pass-Through Rates," 2018 Brit. Tax Rev. 49

"The New Non-Territorial U.S. International Tax System (pt. 1.)," 160 Tax Notes 57 (2018)

"The New Non-Territorial U.S. International Tax System (pt. 2.)," 160 Tax Notes 171 (2018)

Federal Income Taxation (Aspen Publishing 19th ed., 2023; 18th ed., 2018; 17th ed., 2017; 16th ed., 2012; 15th ed., 2009; 14th ed., 2006; 13th ed., 2003; 12th ed., 2000) (with Joseph Bankman, Kirk J. Stark & Erin Adele Scharff)

Bonfires of the American Dream in American Rhetoric, Literature and Film (Anthem Press, 2022)

Literature and Inequality: Nine Perspectives from the Napoleonic Era Through the First Gilded Age (Anthem Press, 2020)

Fixing U.S. International Taxation (Oxford University Press, 2014)

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Stanley S. Surrey: A Life in Taxes, 175 Tax Notes Federal 741-749 (2022) (with Ajay K. Mehrotra)

The Two "Two Americas" of Trump and Romney, 85 Law and Contemporary Problems 87-100 (2022)

1924, 2021: Taxes of the Ultrarich, and Mark-to-Market Reforms, 172 Tax Notes Federal 583-592 (2021)

The American Families Plan and the Future of the Mass Income Tax, 172 Tax Notes Federal 1277- 1288 (2021)

The Deductibility of Capital Losses in a Mark-to-Market Regime, 172 Tax Notes Federal 1965-1972 (2021)

Examining the Internal Revenue Code for Disparate Racial Impacts, 168 Tax Notes Federal 1807-1821 (2020)

Giving Credits Where Credits Are (Arguably) Due: A Half Century's Evolution in the Design of Personal Tax Expenditures, 24 Florida Tax Review 51-150 (2020)

Seven-Plus Decades of the Federal Income Tax in Sitcoms: An Update, 167 Tax Notes Federal 1211-1215 (2020)

“We Will See That You Are Troubled Right Along”: Women and the Politics of the Early Federal Income Tax, 27 Duke Journal of Gender Law & Policy 279-295 (2020)

Tax in History: The Federal Income Tax Goes to War, 47 Intertax 766-769 (2019)

The NCAA and the IRS: Life at the Intersection of College Sports and the Federal Income Tax, 92 Southern California Law Review 1087-1153 (2019) (with Richard L. Schmalbeck)

Foreword: The Past, Present, and Future of the Federal Tax Legislative Process, 81 Law and Contemporary Problems 1-6 (2018) (with George K. Yin)

Leaving it up to Treasury: Congressional Abdication on Major Policy Issues in the Early Years of the Income Tax, 81 Law and Contemporary Problems 137-165 (2018)

SALT Ceiling Workarounds and Tax Shelters, 160 Tax Notes 521-535 (2018)

Federal Income Taxation: A Law Student's Guide to the Leading Cases and Concepts (Concepts and Insights Series) (Foundation Press, 12th ed. 2012, 13th ed. 2015, 14th ed. 2018, 15th ed. 2023) (with Marvin A. Chirelstein)

A Half-Century With the Internal Revenue Code: The Memoirs of Stanley S. Surrey (Carolina Academic Press, 2022) (editor with Ajay Mehrotra)

Federal Income Taxation (Aspen Publishing, 2004, 2d ed. 2007; Wolters Kluwer Law & Business, 3d ed. 2011; Wolters Kluwer, 4th ed. 2015, 5th ed. 2018) (with others)

Figuring Out the Tax: Congress, Treasury, and the Design of the Early Modern Income Tax (Cambridge University Press, 2018)

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“Rethinking Fiscal Policy,” in O. Blanchard and L. Summers, eds., Evolution or Revolution?

Rethinking Macroeconomics after the Great Recession, 2019, 81–103.

“Tax Equivalences and their Implications,” in R. Moffitt, ed., Tax Policy and the Economy

33, 2019, 81–107. Reprinted with revisions as “Fiscal Equivalences,” in Christian Hagist and

Tobias Kohlstruck, eds., Fiskalische Nachhaltigkeit: Von der ökonomischen Theorie zum

politischen Leitbild, 2022, 1–14.

“Local Fiscal Multipliers and Fiscal Spillovers in the United States,” IMF Economic Review,

March 2020, 195–229 (with Yuriy Gorodnichenko and Daniel Murphy).

“Effects of Fiscal Policy on Credit Markets,” American Economic Association Papers and

Proceedings, May 2020, 119–124 (with Yuriy Gorodnichenko and Daniel Murphy).

“Did the 2017 Tax Reform Discriminate against Blue State Voters?” National Tax Journal,

December 2020, 1087–1108 (with David Altig, Patrick Higgins, Darryl Koehler, Laurence

Kotlikoff, Ellyn Terry, and Victor Ye).

“The Effects of the COVID Pandemic on the Federal Budget Outlook,” Business Economics

(with William Gale), October 2020.

“Effects of COVID-19 on Federal, State, and Local Government Budgets,” Brookings Papers

on Economic Activity, Fall 2020, 229–270 (with William Gale, Byron Lutz, and Louise

Sheiner).

“Inequality, Fiscal Policy, and COVID-19 Restrictions in a Demand-Determined Economy,”

European Economic Review, August 2021, 103810 (with Yuriy Gorodnichenko and Daniel

Murphy).

“Tax Policy Design with Low Interest Rates,” in R. Moffitt, ed., Tax Policy and the

Economy 36, 2022, 93–121 (with William G. Gale).

“Fiscal Multipliers in the COVID19 Recession,” Journal of International Money and

Finance, September 2022, 102669 (with Yuriy Gorodnichenko, Peter McCrory, and Daniel

Murphy).

“U.S. Inequality and Fiscal Progressivity: An Intragenerational Accounting,” Journal of

Political Economy, May 2023, 1249–1293 (with Laurence Kotlikoff and Darryl Koehler).

“Macroeconomic Frameworks: Reconciling Evidence and Model Predictions from Demand

Shocks,” American Economic Journal: Macroeconomics, forthcoming (with Yuriy

Gorodnichenko and Daniel Murphy).

Taxing Profit in a Global Economy (with Michael Devereux, Michael Keen, Paul Oosterhuis,

Wolfgang Schön, and John Vella), Oxford University Press, 2021.

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“Though Money Moves: Taxing the Wealthy at the State Level” (with Brian Galle and Darien Shanske, under review, draft manuscript available upon request).

“Tax Base Diversification as an Enforcement Tool” (with Brian Galle and Yulia Kuchumova, under review).

“The Policy and Politics of Alternative Minimum Taxes,” NATIONAL TAX JOURNAL (with Ari Glogower, forthcoming).

“Taxation and the Constitution, Reconsidered,” 76 TAX LAW REVIEW (with John R. Brooks, forthcoming).

“Did the Washington Supreme Court Rule Correctly on the Capital Gains Tax?,”108 TAX NOTES STATE 516 (2023) (with Jared Walczak).

“Why States Should Conform to the New Corporate AMT,” 107 TAX NOTES STATE 601 (2023) (with Darien Shanske).

“Solving the Valuation Challenge: The ULTRA Method for Taxing Extreme Wealth,” 72 DUKE LAW JOURNAL 1257 (2023) (with Brian Galle and Darien Shanske).

“Phased Mark-to-Market for Billionaire Income Tax Reforms,” 176 TAX NOTES FEDERAL 1875 (2022) (with Darien Shanske).

“Tax Now or Tax Never: Political Optionality and the Case for Current-Assessment Tax Reform,” 100 NORTH CAROLINA LAW REVIEW 487 (2022) (with John R. Brooks).

“Billionaire Mark-to-Market Reforms: A Response to Susswein and Brown,” 176 TAX NOTES FEDERAL 555 (2022) (with Reuven Avi-Yonah).

“Wage Enslavement: How the Tax System Holds Back Historically Disadvantaged Groups of Americans,” 110 KENTUCKY LAW JOURNAL 665 (2021-2022) (with Goldburn P. Maynard Jr.) (invited).

“Weathering State and Local Budget Storms: Fiscal Federalism with an Uncooperative Congress,” 55 UNIVERSITY OF MICHIGAN JOURNAL OF LAW REFORM 309 (2021) (with Darien Shanske, Gladriel Shobe, and Adam Thimmesch).

“Maryland's Digital Tax and the ITFA's Catch-22,” TAX NOTES STATE (2021) (with Darien Shanske and Chris Moran).

“Is New York’s Mark-to-Market Act Unconstitutionally Retroactive?,” TAX NOTES STATE (2021) (with Reuven S. Avi-Yonah, Darien Shanske, and Kirk Stark).

“How States Should Now Consider Expanding Sales Taxes to Services,” TAX NOTES STATE (2021)(with Gladriel Shobe, Grace Stephenson Nielsen, and Darien Shanske).

“Why States Should Consider Expanding Sales Taxes to Services,” TAX NOTES STATE (2020) (with Gladriel Shobe, Grace Stephenson Nielsen, and Darien Shanske).

“The Case for State Borrowing as a Response to the Current Crises,” TAX NOTES STATE (2020) (with Darien Shanske).

“Strategic Nonconformity, State Corporate Income Taxes, And the TCJA: Part II,” TAX NOTES STATE (2020) (with Adam Thimmesch and Darien Shanske).

“Strategic Nonconformity to the TCJA, Part I: Personal Income Taxes,” TAX NOTES STATE (2020) (with Adam Thimmesch and Darien Shanske).

“Conformity and State Income Taxes: Suggestions for the Crisis,” TAX NOTES STATE (2020) (with Michael Livingston).

“Reforming State Corporate Income Taxes Can Yield Billions,” TAX NOTES STATE (2020) (with Reuven Avi-Yonah and Darien Shanske).

“States Should Consider Partial Wealth Tax Reforms,” TAX NOTES STATE (2020) (with Darien Shanske).

“States Should Quickly Reform Unemployment Insurance,” TAX NOTES STATE (2020) (with Brian Galle, Erin Scharff, and Darien Shanske).

“How the Federal Reserve Should Help States and Localities Right Now,” TAX NOTES STATE (2020) (with Darien Shanske).

“The Ordinary Diet of the Law: How to Interpret Public Law 86-272,” TAX NOTES STATE (2020) (with Darien Shanske).

“Tax Cannibalization by State Corporate Taxes: Policy Implications,” TAX NOTES STATE (2020) (with Darien Shanske).

“Tax Cannibalization by State Corporate Taxes: Revised Estimates,” TAX NOTES STATE (2020) (with Darien Shanske).

“The Games They Will Play: Tax Games,” Roadblocks, and Glitches Under the 2017 Tax Legislation, 103 MINNESOTA LAW REVIEW 1439 (2019) (with David Kamin et al.).

“Taxing E-Commerce in the Post-Wayfair World,” 58 WASHINGTON UNIVERSITY JOURNAL OF LAW AND POLICY 71 (2019) (with Adam Thimmesch and Darien Shanske) (invited).

“Will States Step Up in 2020? We Hope So,” 94 STATE TAX NOTES 977 (2019) (with Darien Shanske).

“States Should Conform to GILTI,” Part 3: Elevator Pitch and Q&A, 94 STATE TAX NOTES 121 (2019) (with Darien Shanske).

“On Yang’s Proposed Federal Tax On Subnational Tax Incentives,” 94 STATE TAX NOTES 25 (2019) (with Darien Shanske).

“Why States Can Tax the GILTI,” 91 STATE TAX NOTES 967 (2019) (with Darien Shanske).

“Why States Should Tax the GILTI,” 91 STATE TAX NOTES 751 (2019) (with Darien Shanske).

Buy, Borrow, Die and the Breaking of the Income Tax (with Edward J. McCaffery, under review, work-in-progress, partial draft manuscript available upon request).

Taxation: Law, Planning, and Policy (Carolina Academic Press, 3rd ed., 2019) (with Michael Livingston).

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"The Untold Tale of A Tax Rulings Haven" (submitted Aug. 2023)

"Is the Taxpayer Bill of Rights Enforceable?" (SSRN Working Paper, 2019)

"Avoiding Scandals Through Tax Rulings Transparency," 50 Fla. State L. Rev. 219 (2023)

"Valuation As a Challenge For Tax Administration," 96 Notre Dame L. Rev. 1495 (2021) (symposium essay)

"The Fraud Triangle and Tax Evasion," 106 Iowa L. Rev. 1153 (2021).

"Information Matters in Tax Enforcement," 2020 B.Y.U. L. Rev. 145 (with Joseph C. Dugan).

Information Matters in Tax Enforcement, 2020 Brigham Young University Law Review (with Joseph C. Dugan) (forthcoming 2020)

Tax Controversies: Practice and Procedure, 4th ed.(with Stephen W. Mazza). Durham, NC: Carolina Academic Press, 2018. 2019 Supplement

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