Significant Articles

Tax Base Erosion: Reformation of Section 482’s Arm’s Length Standard 15 Florida Tax Review __ (2014) (with C. Lowell)
Pass-Through Entity Taxation: A Tempest in the Tax Reform Teapot, 14 Hous. Bus. & Tax L.J. 1 (2014) (forthcoming)
Income Tax Treaty Policy in the 21st Century: Residence vs. Source, __ Colum. Tax J. __ (2013) (forthcoming) (with C. Lowell)
Cant and the Inconvenient Truth About Corporate Inversions, 136 TAX NOTES 429 (July 23, 2012)
Territorial Taxation: Homeless Income is the Achilles Heel, 12 Hous. Bus. & Tax L.J. 1 (2012)
Disposable Personal Goodwill, Frosty the Snowman, and Martin Ice Cream All Melt Away in the Bright Sunlight of Analysis, 91 NEB. L. REV. 170 (2012) (with C. Bergez)
Tax Base Erosion and Homeless Income: Collection at Source is the Linchpin, 65 TAX L. REV. 535 (2012) (with C. Lowell)
New Schedule UTP: Uncertain Tax Positions in the Age of Transparency, 63 Baylor L. Rev. 392 (2011)
Economic Substance: How Codification Changes Decided Cases, 10 Florida Tax Review 411 (2010)
Voluntary Compliance: This Return Might Be Right But Probably Isn’t, 29 Virginia Tax Review 645 (2010)
What Corporate Inversions Teach Us About International Tax Reform, 127 TAX NOTES 1345 (June 21, 2010)
Adopting the More Likely Than Not Standard for Tax Returns, 2010 TNT 82-10, Doc. 2010-7488 (April 29, 2010)
Comment Letter: Proposed Change to §901 Definition of Foreign Tax, 2007 Tax Notes Today 160-10 (August 6, 2007)
Tax-Effective Methods to Finance Latin American Operations, 28 INT’L TAX J. 21 (2002)
Interest Allocation: The Dog Days of Summer, 53 Tax Executive 365 (2001)
Interest Allocation: A Regime in Desperate Need of Sound Policy, 53 TAX LAW. 859 (2000)
Tax Consequences of Participations in International Trade Finance, 13 TAX NOTES INT’L 1883 (1996)

Treatise

Lowell, Donahue, Martin, & Wells, US International Taxation: Agreements, Checklist, and Commentary (WG&L Treatise available on RIA Checkpoint)